**TECHNICAL SUPPORT DOCUMENT**

TECHNICAL INFORMATION PRESENTED IN REVIEW OF AN

APPLICATION FOR A PART 70 OPERATING PERMIT

SUBMITTED BY

####### Las Vegas Cogeneration Limited Partnership

for

**Las Vegas Cogeneration**

**North Las Vegas, Nevada**

**Part 70 Operating Permit Number: 329**

SIC Code - 4911: Electric Utility Services

NAICS Code -- 221112: Fossil Fuel Electric Power Generation

![](media/image1.wmf){width="1.3229166666666667in"
height="1.2958333333333334in"}

Clark County

Department of Air Quality and Environmental Management

Permitting Section

August 2006

***This Technical Support Document (TSD) accompanies the proposed Part
70 Operating Permit for Las Vegas Cogeneration Limited Partnership.***

**[TABLE OF CONTENTS]{.underline}**

> Page

[I. EXECUTIVE SUMMARY 3](#i.-executive-summary)

[II. FACILITY INFORMATION 4](#ii.-facility-information)

[A. General 4](#a.-general)

[B. Description of Process 4](#b.-description-of-process)

[C. Permitting History 5](#c.-permitting-history)

[D. Operating Scenario 5](#d.-operating-scenario)

[E. Proposed Exemptions 6](#e.-proposed-exemptions)

[III. EMISSIONS INFORMATION 6](#iii.-emissions-information)

[A. Total Facility Potential to Emit
6](#a.-total-facility-potential-to-emit)

[B. Emission Units and PTE 6](#b.-emission-units-and-pte)

[C. Performance Testing and Continuous Emission Monitoring
8](#c.-performance-testing-and-continuous-emission-monitoring)

[IV. REGULATORY REVIEW 9](#iv.-regulatory-review)

[A. Local Regulatory Requirements 9](#a.-local-regulatory-requirements)

[B. Federally Applicable Regulations
12](#b.-federally-applicable-regulations)

[V. COMPLIANCE 24](#v.-compliance)

[A. Compliance Certification 24](#a.-compliance-certification)

[B. Summary of Monitoring for Compliance
25](#b.-summary-of-monitoring-for-compliance)

[VI. MITIGATION 26](#vi.-mitigation)

[VII. ADMINISTRATIVE REQUIREMENTS 26](#vii.-administrative-requirements)

# I. EXECUTIVE SUMMARY

Las Vegas Cogeneration, owned by Las Vegas Cogeneration Limited
Partnership, is located in North Las Vegas, Nevada, which is in
Hydrographic Area 212 (Las Vegas Valley).

The facility consists of five (5) General Electric LM-6000 44 megawatt
combined-cycle natural-gas turbines, two (2) IBW 13.7 MMBtu/hr boilers,
two (2) GEA mechanical draft cooling towers, one (1) 125 kW diesel
emergency generator and one (1) 121 horsepower diesel emergency fire
pump. The potential emissions for the facility are shown in the table
below.

Table 1-1: Maximum Facility PTE (tons per year)

+---------+---------+---------+---------+---------+---------+--------+
| **P     | **      | **CO**  | **      | **VOC** | ####    | #      |
| M~10~** | NO~X~** |         | SO~2~** |         | ### HAP | ###### |
|         |         |         |         |         |         |  NH~3~ |
+---------+---------+---------+---------+---------+---------+--------+
| **      | **      | **      | *       | **      | *       | **10   |
| 64.63** | 96.27** | 52.52** | *5.70** | 36.82** | *9.40** | 1.00** |
+---------+---------+---------+---------+---------+---------+--------+

Clark County Department of Air Quality and Environmental Management
(DAQEM) has delegated authority to implement the requirements of the
Part 70 operating permit program.

Based on information submitted by the applicant and a technical review
performed by the DAQEM staff, DAQEM proposes the issuance of a Part 70
Operating Permit to Las Vegas Cogeneration.

# II. FACILITY INFORMATION

## A. General

+------------------------------+---------------------------------------+
| Permittee                    | #                                     |
|                              | ######## Las Vegas Cogeneration Limit |
|                              | ed Partnership {#las-vegas-cogenerati |
|                              | on-limited-partnership-1 .unnumbered} |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Mailing Address              | 1701 East Alexander Road              |
|                              |                                       |
|                              | North Las Vegas, Nevada 89030         |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Contacts                     | Fred Carl, Director Environmental     |
|                              | Services                              |
|                              |                                       |
|                              | David Robb, General Manager           |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Phone Number                 | \(702\) 642-0331                      |
+------------------------------+---------------------------------------+
| Fax Number                   | \(702\) 642-8738                      |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Source Location              | 1701 East Alexander Road              |
|                              |                                       |
|                              | North Las Vegas, Nevada 89030         |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Hydrographic Area            | 212                                   |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| Township, Range, Section     | T20S, R61E, Section 11                |
+------------------------------+---------------------------------------+
|                              |                                       |
+------------------------------+---------------------------------------+
| SIC Code                     | 4911 - Electric Services              |
+------------------------------+---------------------------------------+
| NAICS Code                   | 221112 -- Fossil Fuel Electric Power  |
|                              | Generation                            |
+------------------------------+---------------------------------------+

## B. Description of Process

The Las Vegas Cogeneration (Las Vegas Cogeneration Limited Partnership)
facility is located at 1701 East Alexander Road in North Las Vegas,
Nevada, which is approximately two (2) miles northeast of Las Vegas. The
facility is located in Hydrographic Area 212 (Las Vegas Valley). This
area is designated serious nonattainment for CO and PM~10~, basic
nonattainment for ozone (as regulated through NO~X~ and VOC), and
prevention of significant deterioration (PSD) for SO~2~.

The facility consists of five (5) General Electric LM-6000 natural
gas-fired combined-cycle combustion turbine/generators, each of which
are equipped with dry low-NO~X~ burners. The combined-cycle units each
produce approximately 44 MW of electricity. The total plant net
dependable rating is 220 MW.

Also present at the facility are two (2) IBW 13.7 MMBtu/hr boilers, two
(2) GEA mechanical draft cooling towers, one (1) 125 kW diesel emergency
generator and one (1) 121 horsepower diesel emergency fire pump.

[]{.mark}

## C. Permitting History

#### Table II-C-1: Permits Issued to Las Vegas Cogeneration Limited Partnership

+---------+------------+-----------------------------------------------+
| **Date  | **Permit** | **Description**                               |
| I       |            |                                               |
| ssued** | **Number** |                                               |
+=========+============+===============================================+
| 09/     | Mo         | Issuance of operating permit and authority to |
| 02/2004 | dification | construct                                     |
|         | 3          |                                               |
+---------+------------+-----------------------------------------------+
| 12/     | Mo         | Issuance of authority to construct            |
| 20/2001 | dification |                                               |
|         | 2          |                                               |
+---------+------------+-----------------------------------------------+
| 07/     | Mo         | Issuance of authority to construct            |
| 20/2001 | dification |                                               |
|         | 1          |                                               |
+---------+------------+-----------------------------------------------+
| 03/     | Mo         | Issuance of initial authority to construct    |
| 29/2001 | dification |                                               |
|         | 0          |                                               |
+---------+------------+-----------------------------------------------+

### Table II-C-2: BACT Determinations for Las Vegas Cogeneration Limited Partnership

+----------+---------------------------------+------------------------+
| ##       | **Description**                 | **Control Technology** |
| ##### EU |                                 |                        |
+----------+---------------------------------+------------------------+
| A01      | Turbine Unit 1 - GE LM-6000     | SCR, dry low-NO~X~     |
|          | turbine; 397 (LHV) MMBtu/hr;    | burners, oxidation     |
|          | natural gas only; no            | catalyst, water        |
|          | supplemental HRSG firing; 44 MW | injection, natural gas |
|          |                                 | combustion, inlet air  |
|          |                                 | filters                |
+----------+---------------------------------+------------------------+
| A02      | GEA Thermo 2-cell mechanical    | 3,000 ppm TDS, 0.005   |
|          | draft cooling tower; 14,200 gpm | percent drift loss     |
+----------+---------------------------------+------------------------+
| A03      | Turbine Units 2 through 5 -GE   | SCR, dry low-NO~X~     |
|          | LM-6000 turbine; 451 MMBtu/hr   | burners, oxidation     |
| through  | (HHV); natural gas only; no     | catalyst, water        |
|          | supplemental HRSG firing; 44 MW | injection, natural gas |
| A06      | each                            | combustion, inlet air  |
|          |                                 | filters                |
+----------+---------------------------------+------------------------+
| A07      | GEA 10-cell mechanical draft    | 3,000 ppm TDS, 0.001   |
|          | cooling tower, 58,610 gpm       | percent drift loss     |
+----------+---------------------------------+------------------------+
| B01 and  | IBW 13.7 MMBtu/hr boiler        | Low-NO~X~ burners,     |
| B02      |                                 | natural gas combustion |
+----------+---------------------------------+------------------------+
| C01      | Diesel fire pump; 121 hp        | Timing retard,         |
|          |                                 | turbocharging,         |
|          |                                 | aftercooling, low      |
|          |                                 | sulfur diesel          |
+----------+---------------------------------+------------------------+
| D01      | Emergency diesel generator; 125 | Timing retard,         |
|          | kW                              | turbocharging,         |
|          |                                 | aftercooling, low      |
|          |                                 | sulfur diesel          |
+----------+---------------------------------+------------------------+

## D. Operating Scenario

Turbine Unit 1 (EU: A01) may operate 24 hours per day, seven days per
week, 52 weeks per year. Natural gas consumption for Turbine Unit 1 (EU:
A01) shall be limited to 440,000 cubic feet per hour, corrected to
standard conditions. For Turbine Units 2 through 5 (EUs: A03 through
A06, inclusive) total annual start-up/shut-down cycles per turbine shall
not exceed 792 occurrences annually. Each start-up cycle shall
constitute one occurrence and each shut-down cycle will constitute one
occurrence. The diesel fire pump (EU: C01) is permitted to operate 100
hours per year for testing and maintenance purposes only. The emergency
diesel generator (EU: D01) may operate a total of 200 hours per year for
testing and maintenance purposes only. The GEA Thermo cooling tower (EU:
A02) may operate 365 days per year, 8,760 hours per year. Maximum water
flow shall be 14,200 gallons per minute. The GEA cooling tower (EU: A07)
may operate 365 days per year, 8,760 hours per year. Maximum water flow
shall be 58,610 gallons per minute.

## E. Proposed Exemptions

There are no restrictions for the operation of the diesel emergency fire
pump or the diesel emergency generator during emergency situations, as
defined in Air Quality Regulations (AQR) Section 0.

# III. EMISSIONS INFORMATION

## A. Total Facility Potential to Emit

The facility potential to emit (PTE) for pollutants (Table III-A-1), as
presented in the Las Vegas Cogeneration Part 70 Operating Permit
application, reflects the permitted emission limits established in the
September 2, 2004 ATC/OP (Permit 329, Modification 3, Revision 1).

#### Table III-A-1: Maximum Facility Potential to Emit (tons per year)^1^

  ----------- ------------ ----------- -------- ----------- --------- --------- -----------
              **PM~10~**   **NO~X~**   **CO**   **SO~2~**   **VOC**   **HAP**   **NH~3~**

  Lbs/hour    17.54        35.19       23.37    2.03        10.95     1.91      28.32

  Tons/year   64.63        96.27       52.52    5.70        36.82     9.40      101.00
  ----------- ------------ ----------- -------- ----------- --------- --------- -----------

^1^ Note that the facility-wide PTEs, except for ammonia, less than the
sum of the annual PTEs of each of the individual emission units as
delineated in Table III-B-2.

## B. Emission Units and PTE

The following tables summarize the allowable limits for each emission
unit.

**Table III-B-1: Emission Units at Facility**

+----+---------------------------------------------+--------+--------+
| ## | #####                                       | #      | **Type |
| ## | #### Description {#description .unnumbered} | ### SC | Code** |
| ## |                                             | C Code |        |
| ## |                                             |        |        |
| #  |                                             |        |        |
| E. |                                             |        |        |
| U. |                                             |        |        |
|  { |                                             |        |        |
| #e |                                             |        |        |
| .u |                                             |        |        |
| .  |                                             |        |        |
| .u |                                             |        |        |
| nn |                                             |        |        |
| um |                                             |        |        |
| be |                                             |        |        |
| re |                                             |        |        |
| d} |                                             |        |        |
+====+=============================================+========+========+
| A  | Turbine Unit 1 GE LM-6000 turbine; 397      | 20     | TR1,   |
| 01 | MMBtu/hr (LHV) natural gas only; no         | 100201 | MEQ    |
|    | supplemental HRSG firing; 44 MW; 44 MEQ     |        |        |
+----+---------------------------------------------+--------+--------+
| A  | GEA Thermo 2-cell mechanical draft cooling  | 38     | P1     |
| 02 | tower                                       | 500101 |        |
+----+---------------------------------------------+--------+--------+
| A  | Turbine Unit 2 GE LM-6000 turbine; 451      | 20     | TR1,   |
| 03 | MMBtu/hr (HHV) natural gas only; no         | 100201 | MEQ    |
|    | supplemental HRSG firing; 44 MW; 44 MEQ     |        |        |
+----+---------------------------------------------+--------+--------+
| A  | Turbine Unit 3 GE LM-6000 turbine; 451      | 20     | TR1,   |
| 04 | MMBtu/hr (HHV) natural gas only; no         | 100201 | MEQ    |
|    | supplemental HRSG firing; 44 MW; 44 MEQ     |        |        |
+----+---------------------------------------------+--------+--------+
| A  | Turbine Unit 4 GE LM-6000 turbine; 451      | 20     | TR1,   |
| 05 | MMBtu/hr (HHV) natural gas only; no         | 100201 | MEQ    |
|    | supplemental HRSG firing; 44 MW; 44 MEQ     |        |        |
+----+---------------------------------------------+--------+--------+
| A  | Turbine Unit 5 GE LM-6000 turbine; 451      | 20     | TR1,   |
| 06 | MMBtu/hr (HHV) natural gas only; no         | 100201 | MEQ    |
|    | supplemental HRSG firing; 44 MW; 44 MEQ     |        |        |
+----+---------------------------------------------+--------+--------+
| A  | GEA 10-cell mechanical draft cooling tower, | 38     | P1     |
| 07 |                                             | 500101 |        |
+----+---------------------------------------------+--------+--------+
| B  | IBW 13.7 MMBtu/hr boiler                    | 10     | F1     |
| 01 |                                             | 200602 |        |
+----+---------------------------------------------+--------+--------+
| B  | IBW 13.7 MMBtu/hr boiler                    | 10     | F1     |
| 02 |                                             | 200602 |        |
+----+---------------------------------------------+--------+--------+
| C  | Diesel fire pump; 121.0 hp                  | 20     | DM     |
| 01 |                                             | 200102 |        |
+----+---------------------------------------------+--------+--------+
| D  | Emergency diesel generator; 125 kW          | 20     | DM     |
| 01 |                                             | 200102 |        |
+----+---------------------------------------------+--------+--------+

**^Table\ III-B-2:\ Emission\ Unit\ Potential\ to\ Emit\ Including\ Startup\ and\ Shutdown^**1

<table>
<colgroup>
<col style="width: 5%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
</colgroup>
<thead>
<tr class="header">
<th rowspan="2"><h3 id="eu-1">EU</h3></th>
<th colspan="2"><strong>PM<sub>10</sub></strong></th>
<th colspan="2"><strong>NO<sub>X</sub></strong></th>
<th colspan="2"><strong>CO</strong></th>
<th colspan="2"><strong>SO<sub>X</sub></strong></th>
<th colspan="2"><strong>VOC</strong></th>
<th colspan="2"><strong>NH<sub>3</sub></strong></th>
</tr>
<tr class="odd">
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
<th><strong>lb/hr</strong></th>
<th><strong>tpy</strong></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td>A01</td>
<td>3.00</td>
<td>7.70</td>
<td>14.00</td>
<td>48.00</td>
<td>9.00</td>
<td>22.00</td>
<td>0.30</td>
<td>0.80</td>
<td>2.00</td>
<td>5.00</td>
<td>5.00</td>
<td>13.20</td>
</tr>
<tr class="even">
<td>A02</td>
<td>1.06</td>
<td>4.66</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>A03</td>
<td>2.50</td>
<td>10.95</td>
<td>3.15</td>
<td>13.14</td>
<td>1.92</td>
<td>8.00</td>
<td>0.30</td>
<td>1.31</td>
<td>2.00</td>
<td>8.76</td>
<td>5.83</td>
<td>24.28</td>
</tr>
<tr class="even">
<td>A04</td>
<td>2.50</td>
<td>10.95</td>
<td>3.15</td>
<td>13.14</td>
<td>1.92</td>
<td>8.00</td>
<td>0.30</td>
<td>1.31</td>
<td>2.00</td>
<td>8.76</td>
<td>5.83</td>
<td>24.28</td>
</tr>
<tr class="odd">
<td>A05</td>
<td>2.50</td>
<td>10.95</td>
<td>3.15</td>
<td>13.14</td>
<td>1.92</td>
<td>8.00</td>
<td>0.30</td>
<td>1.31</td>
<td>2.00</td>
<td>8.76</td>
<td>5.83</td>
<td>24.28</td>
</tr>
<tr class="even">
<td>A06</td>
<td>2.50</td>
<td>10.95</td>
<td>3.15</td>
<td>13.14</td>
<td>1.92</td>
<td>8.00</td>
<td>0.30</td>
<td>1.31</td>
<td>2.00</td>
<td>8.76</td>
<td>5.83</td>
<td>24.28</td>
</tr>
<tr class="odd">
<td>A07</td>
<td>2.88</td>
<td>12.61</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>B01</td>
<td>0.03</td>
<td>0.01</td>
<td>0.50</td>
<td>0.15</td>
<td>2.52</td>
<td>0.75</td>
<td>0.01</td>
<td>0.05</td>
<td>0.17</td>
<td>0.05</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>B02</td>
<td>0.03</td>
<td>0.01</td>
<td>0.50</td>
<td>0.15</td>
<td>2.52</td>
<td>0.75</td>
<td>0.01</td>
<td>0.05</td>
<td>0.17</td>
<td>0.05</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>C01</td>
<td>0.20</td>
<td>0.01</td>
<td>2.81</td>
<td>0.11</td>
<td>0.61</td>
<td>0.02</td>
<td>0.19</td>
<td>0.01</td>
<td>0.23</td>
<td>0.01</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>D01</td>
<td>0.34</td>
<td>0.03</td>
<td>4.78</td>
<td>0.36</td>
<td>1.04</td>
<td>0.08</td>
<td>0.32</td>
<td>0.03</td>
<td>0.38</td>
<td>0.03</td>
<td>0.00</td>
<td>0.00</td>
</tr>
</tbody>
</table>

> ^1^ Hourly limits are based on 36 ^º^F ambient temperature. Annual
> limits are based upon 66^º^F ambient temperature.
>
> []{.mark}

**Table III-B-3: Enforceable Emission Limitations (ppmvd)**

+------+-----------------------+------------+------------+------------+
| **   | **Description**       | **CO**     | **NO~X~**  | **NH~3~**  |
| EU** |                       |            |            |            |
+======+=======================+============+============+============+
| A01^ | Turbine Unit 1 w/ SCR | 10         | 10         | 10         |
| 1,2^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+
| A03^ | Turbine Unit 2 w/ SCR | 2.0        | 2.0        | 10         |
| 1,2^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+
| A04^ | Turbine Unit 3 w/ SCR | 2.0        | 2.0        | 10         |
| 1,2^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+
| A05^ | Turbine Unit 4 w/ SCR | 2.0        | 2.0        | 10         |
| 1,2^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+
| A06^ | Turbine Unit 5 w/ SCR | 2.0        | 2.0        | 10         |
| 1,2^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+
| B0   | ###### IBW Boi        | 400        | 30         | NA         |
| 1^3^ | ler w/ DLN {#ibw-boil |            |            |            |
|      | er-w-dln .unnumbered} |            |            |            |
+------+-----------------------+------------+------------+------------+
| B0   | IBW Boiler w/ DLN     | 400        | 30         | NA         |
| 2^3^ |                       |            |            |            |
+------+-----------------------+------------+------------+------------+

^1^ CO and NH~3~ concentration limits are based on a one-hour averaging
period. @ 15 percent O~2~.

^2^ NO~X~ concentration limits are based on a three-hour averaging
period @ 15 percent O~2~.

^3^ Concentration limits are based on an average over a consecutive
15-minute period @ 3 percent O~2~.

**Table III-B-4: Hazardous Air Pollutant (HAP) Emissions Speciation**

+-----------+---------------+--------------+------------+-------------+
| **HAP**   | **Pounds per  | **Pounds per | **Tons per | **Tons per  |
|           | Hour**        | Hour**       | Year**     | Year**      |
+-----------+---------------+--------------+------------+-------------+
|           | **per         | **           | **per      | **C         |
|           | Turbine**     | Cumulative** | Turbine**  | umulative** |
+-----------+---------------+--------------+------------+-------------+
| Ace       | 0.04          | 0.16         | 0.16       | 0.80        |
| taldehyde |               |              |            |             |
+-----------+---------------+--------------+------------+-------------+
| Acrolein  | \< 0.01       | 0.01         | 0.01       | 0.05        |
+-----------+---------------+--------------+------------+-------------+
| Benzene   | \< 0.01       | 0.02         | 0.02       | 0.10        |
+-----------+---------------+--------------+------------+-------------+
| Eth       | 0.02          | 0.07         | 0.07       | 0.35        |
| ylbenzene |               |              |            |             |
+-----------+---------------+--------------+------------+-------------+
| For       | 0.32          | 1.29         | 1.27       | 6.35        |
| maldehyde |               |              |            |             |
+-----------+---------------+--------------+------------+-------------+
| Na        | \< 0.01       | \< 0.01      | \< 0.01    | 0.05        |
| phthalene |               |              |            |             |
+-----------+---------------+--------------+------------+-------------+
| PAH       | \< 0.01       | \< 0.01      | \< 0.01    | 0.05        |
+-----------+---------------+--------------+------------+-------------+
| Toluene   | 0.07          | 0.26         | 0.25       | 1.25        |
+-----------+---------------+--------------+------------+-------------+
| Xylene    | 0.02          | 0.08         | 0.08       | 0.40        |
+-----------+---------------+--------------+------------+-------------+
| ########  | **0.51**      | **1.91**     | **1.88**   | **9.40**    |
|  Total {# |               |              |            |             |
| total .un |               |              |            |             |
| numbered} |               |              |            |             |
+-----------+---------------+--------------+------------+-------------+

Only those HAPs with a potential to exceed 0.0005 tons per year (1.0
pounds per year) are listed. These factors are being used by DAQEM to
more accurately determine HAP emissions and possible source subjectivity
to Maximum Achievable Control Technology (MACT) standards per the April
2001 promulgated rule. No single facility-wide HAP emission shall exceed
ten tons per year and total facility-wide HAP emissions shall not exceed
25 tons per year. Therefore, this facility is not subject to 40 CFR 63
Subpart YYYY for combustion turbines.

## C. Performance Testing and Continuous Emission Monitoring

Initial performance testing for the turbines was completed on May 14,
2002. Any additional required testing will be performed using the
following methods:

Table III-C-1: Performance Testing Requirements (40 CFR 60, Appendix A)

+-----------------------------+-------+-------------------------------+
| ####### Test Point          | ##    | ####### Method                |
|                             | ##### |                               |
|                             |  Poll |                               |
|                             | utant |                               |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack; | NO~X~ | Chemiluminescence Analyzer    |
| Auxiliary Boiler Exhaust    |       | (EPA Method 7E, Method 20)    |
| Stack                       |       |                               |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack; | CO    | EPA Method 10                 |
| Auxiliary Boiler Exhaust    |       |                               |
| Stack                       |       |                               |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack  | VOC   | EPA Method 25A                |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack  | NH~3~ | Method preapproved by         |
|                             | slip  | DAQEM/EPA                     |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack  | P     | EPA Method 201/202 or         |
|                             | M~10~ | 201A/202                      |
+-----------------------------+-------+-------------------------------+
| Turbine/HRSG Exhaust Stack; | Op    | EPA Method 9                  |
| Auxiliary Boiler Exhaust    | acity |                               |
| Stack                       |       |                               |
+-----------------------------+-------+-------------------------------+
| Stack Gas Parameters        | \-\-- | EPA Method 1, Method 2,       |
|                             |       | Method 3, Method 4            |
+-----------------------------+-------+-------------------------------+

[]{.mark}

Annual Relative Accuracy Test Audits (RATA) testing must be performed on
each NO~X~, CO, and O~2~ CEM Continuous Emissions Monitoring Systems
(CEMS).

All performance tests on the turbine units must conform to 40 CFR 60
Subparts A and GG and 40 CFR 75. All performance tests on the two
boilers (EU: B01 and B02) must conform to AQR Section 49.

#### Continuous Emissions Monitoring

Las Vegas Cogeneration Limited Partnership is operating a NO~X~ and CO
CEMS on each turbine unit. The February 5, 2003 ATC/OP contains the
following requirements:

CEMS installed on emission units A01 and A03 shall demonstrate
continued, direct compliance with operational limitations and the
three-hour rolling average and annual emissions limitations for CO and
NO~X~ specified in Section III of this document. The CEMS shall monitor
and record the following parameters for each individual CTG:

1.  exhaust gas concentration of NO~X~, CO, and diluent O~2~, including
    periods of startup and shutdown;

2.  exhaust gas flow rate (by direct or indirect methods);

3.  fuel flow rate;

4.  hours of operation;

5.  three-hour rolling averages for NO~X~ concentration and CO
    concentration;

6.  hourly, daily, and quarterly accumulated mass emissions of NO~X~ and
    CO; and

7.  hours of downtime for each CEMS.

Excluding start-up or shut-down periods not to exceed 180 minutes per
unit per event, any exceedance of the hourly, daily, or annual CO and/or
NO~X~ emissions limitations expressed in Section III as determined by
the CEMS shall be considered a violation of the emission limit imposed
and may result in enforcement action.

Las Vegas Cogeneration Limited Partnership must also operate an ammonia
predictive emissions monitoring system (PEMS) on each combined cycle
emission unit stack. The ammonia PEMS is based on the principle that
NO~x~ reduction occurs at a 1:1 molar ratio with ammonia. Typically
though, more ammonia is injected at a greater molar ratio because the
physical process doesn\'t allow for ideal conditions like complete
mixing, uniform ammonia flow, gas flow, temperature distributions, etc.
The unreacted ammonia slips through the catalyst bed and out of the
stack as ammonia emissions.

The PEMS uses two NO~x~ readings. One NO~x~ reading is from an analyzer
at the selective catalytic reduction (SCR) inlet, and the other is from
the stack CEMS analyzer. These measure the change in NO~x~ across the
SCR (always a reduction), which is converted to an ideal ammonia usage
based on the stoichiometric principle noted above. This is then
subtracted, on a molar basis, from actual ammonia usage and converted to
an ammonia concentration going out of the stack.

The calculation is carried out in the CEMS and stored in the computer
that stores the CEMS parameters.

# IV. REGULATORY REVIEW

## A. Local Regulatory Requirements

DAQEM has determined that the following public law, statutes and
associated regulations are applicable:

1.  Clean Air Act, as amended (CAAA), Authority: 42 U.S.C. § 7401, et
    seq.;

2.  Title 40 of the Code of Federal Regulations (CFR);

3.  Nevada Revised Statutes (NRS), Chapter 445B;

4.  Portions of the AQR that are included in the State Implementation
    Plan (SIP) for Clark County, Nevada. SIP requirements are federally
    enforceable. All requirements from Authority to Construct permits
    and Section 16 Operating Permits issued by DAQEM are federally
    enforceable because these permits were issued pursuant to
    SIP-included sections of the AQR; and

5.  Portions of the AQR that are not included in the SIP. These locally
    applicable requirements are locally enforceable only.

The Nevada Revised Statutes (NRS) and the Clean Air Act Amendments
(CAAA) are public laws that establish the general authority for the
Regulations mentioned.

The DAQEM Part 70 (Title V) Program received Final Approval on November
30, 2001 with publication of that approval appearing in the Federal
Register December 5, 2001 Vol. 66, No. 234. AQR Section 19 - Part 70
Operating Permits \[Amended 07/01/04\] details the Clark County Part 70
Operating Permit Program. These regulations may be accessed on the
Internet at: [http://www.co.clark.nv. us/air_quality/Regs.htm]()

Clark County Air Quality Regulations (AQR) contain sections that are
federally enforceable and sections that are locally enforceable only.
Rules that are only locally enforceable have not been approved by EPA
for inclusion into the State Implementation Plan (SIP). Requirements and
conditions that appear in the Part 70 OP which are related only to
non-SIP rules are notated as locally enforceable only.

Table IV-A-1: AQR Section 12 and 55 Summary Table for This Facility

+----------+--------+--------+--------+-----+---------+-------+-----+
|          | **PM   | **N    | **CO** | **S | **VOC** | **    | **  |
|          | ~10~** | O~X~** |        | O~2 |         | HAP** | TCS |
|          |        |        |        | ~** |         |       | (NH |
|          |        |        |        |     |         |       | ~3~ |
|          |        |        |        |     |         |       | )** |
+----------+--------+--------+--------+-----+---------+-------+-----+
| ######   | Severe | Basic  | Severe | PSD | Basic   | N/A   | N/A |
| Air Qual | n      | n      | n      |     | nonatt  |       |     |
| ity Area | onatta | onatta | onatta |     | ainment |       |     |
|          | inment | inment | inment |     | (ozone) |       |     |
|          |        | (      |        |     |         |       |     |
|          |        | ozone) |        |     |         |       |     |
+----------+--------+--------+--------+-----+---------+-------+-----+
| **       | 64.63  | 96.27  | 52.52  | 5   | 36.82   | 9.40  | 101 |
| Facility |        |        |        | .70 |         |       | .00 |
| PTE      |        |        |        |     |         |       |     |
| tpy**    |        |        |        |     |         |       |     |
+----------+--------+--------+--------+-----+---------+-------+-----+
| **Major  | ≥ 70   | ≥ 50   | ≥ 100  | ≥   | ≥ 50    | ≥ 10  | ≥ 1 |
| Source** | tpy    | tpy    | tpy    | 70  | tpy     | tpy   | tpy |
|          |        |        |        | tpy |         | for   |     |
|          |        |        |        |     |         | each  |     |
|          |        |        |        |     |         | HAP,  |     |
|          |        |        |        |     |         | or ≥  |     |
|          |        |        |        |     |         | 25    |     |
|          |        |        |        |     |         | tpy   |     |
|          |        |        |        |     |         | for   |     |
|          |        |        |        |     |         | com   |     |
|          |        |        |        |     |         | bined |     |
|          |        |        |        |     |         | HAPs  |     |
+----------+--------+--------+--------+-----+---------+-------+-----+

**Discussion:** Las Vegas Cogeneration Limited Partnership is a major
source of NO~X,~ and TCS (NH~3~). As part of the original New Source
Review Analysis all of these emissions triggered notice of proposed
action.

Table IV-A-2: Clark County Department of Air Quality and Environmental
Management -- Air Quality and State Implementation Plan with Facility
Compliance or Requirement

+-------------------+------------------------------+----+-------------+
| Applicable        | **Applicable Subsection -    | *  | *           |
| Section -- Title  | Title**                      | *S | *Affected** |
|                   |                              | IP |             |
|                   |                              | ** | **Emission  |
|                   |                              |    | Unit**      |
+===================+==============================+====+=============+
| 0\. Definitions   | applicable definitions       | y  | entire      |
|                   |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 1\. Definitions   | applicable definitions --    | y  | entire      |
|                   |                              | es | facility    |
|                   | > "Affected Facility", "Air  |    |             |
|                   | > Contaminant", "Air         |    |             |
|                   | > Pollution Control          |    |             |
|                   | > Committee", "Area Source", |    |             |
|                   | > "Atmosphere", "Board",     |    |             |
|                   | > "Commercial Off-Road       |    |             |
|                   | > Vehicle Racing", "Dust",   |    |             |
|                   | > "Existing Facility",       |    |             |
|                   | > "Existing Gasoline         |    |             |
|                   | > Station", "Fixed Capital   |    |             |
|                   | > Cost", "Fumes", "Health    |    |             |
|                   | > District", "Hearing        |    |             |
|                   | > Board", "Integrated        |    |             |
|                   | > Sampling", "Minor Source", |    |             |
|                   | > "Mist", "New Gasoline      |    |             |
|                   | > Station", "New Source",    |    |             |
|                   | > "NIC", "Point Source",     |    |             |
|                   | > "Shutdown", "Significant", |    |             |
|                   | > "Single Source", "Smoke",  |    |             |
|                   | > "Source of Air             |    |             |
|                   | > Contaminant", "Special     |    |             |
|                   | > Mobile Equipment",         |    |             |
|                   | > "Standard Commercial       |    |             |
|                   | > Equipment", "Standard      |    |             |
|                   | > Conditions", "Start Up",   |    |             |
|                   | > "Stop Order", "Uncombined  |    |             |
|                   | > Water", and "Vapor         |    |             |
|                   | > Disposal System"           |    |             |
+-------------------+------------------------------+----+-------------+
| 4\. Control       | all subsections              | y  | entire      |
| Officer           |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 5\. Interference  | all subsections              | y  | entire      |
| with Control      |                              | es | facility    |
| Officer           |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 8\. Persons       | all subsections              | y  | entire      |
| Liable for        |                              | es | facility    |
| Penalties -       |                              |    |             |
| Punishment:       |                              |    |             |
| Defense           |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 9\. Civil         | all subsections              | y  | entire      |
| Penalties         |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 10\. Compliance   | when applicable; applicable  | y  | entire      |
| Schedule          | subsections                  | es | facility    |
+-------------------+------------------------------+----+-------------+
| 11\. Ambient Air  | applicable subsections       | y  | entire      |
| Quality Standards |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 12\.              | All subsections              | y  | entire      |
| Preconstruction   | [except]{.underline} the     | es | facility    |
| Review for New or | following:                   |    |             |
| Modified          |                              |    |             |
| Stationary        | § 12.2.18 HAP Sources in     |    |             |
| Sources           | Clark County.                |    |             |
|                   |                              |    |             |
|                   | § 12.2.20 Additional         |    |             |
|                   | Requirements for [Stationary |    |             |
|                   | Source]{.smallcaps}s with    |    |             |
|                   | Beryllium, Mercury, Vinyl    |    |             |
|                   | Chloride, or Asbestos        |    |             |
|                   | [Emissions]{.smallcaps} in   |    |             |
|                   | Clark County                 |    |             |
+-------------------+------------------------------+----+-------------+
| 14\. New Source   | CCAQR Section 14.1.56:       | no | Applicable  |
| Performance       | Subpart GG Standards of      |    | -- CTG      |
| Standards         | Performance for Gas Turbines |    | units       |
|                   |                              |    |             |
|                   | CCAQR Section 14.1.15:       |    | Applicable  |
|                   | Subpart DC                   |    | -- 13.7     |
|                   |                              |    | MMBtu/hour  |
|                   | Standards of Performance for |    | boilers     |
|                   | Industr                      |    |             |
|                   | ial-Commercial-Institutional |    |             |
|                   | Steam Generating Units       |    |             |
+-------------------+------------------------------+----+-------------+
| 16\. Operating    | all subsections              | y  | entire      |
| Permits           |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 18\. Permit and   | § 18.1 Operating Permit Fees | y  | entire      |
| Technical Service |                              | es | facility    |
| Fees              | § 18.2 Annual Emission Unit  |    |             |
|                   | Fees                         |    |             |
|                   |                              |    |             |
|                   | § 18.4 New Source Review     |    |             |
|                   | Application Review Fee       |    |             |
|                   |                              |    |             |
|                   | § 18.5 Part 70 Application   |    |             |
|                   | Review Fee                   |    |             |
|                   |                              |    |             |
|                   | § 18.6 Annual Part 70        |    |             |
|                   | Emission Fee                 |    |             |
|                   |                              |    |             |
|                   | § 18.14 Billing Procedures   |    |             |
+-------------------+------------------------------+----+-------------+
| 19\. Part 70      | § 19.2 Applicability         | N  | entire      |
| Operating Permit  |                              | /A | facility    |
|                   | § 19.3 Part 70 Permit        |    |             |
| Federal Approval  | Applications                 |    |             |
| (11/25/01)        |                              |    |             |
|                   | § 19.4 Part 70 Permit        |    |             |
|                   | Content                      |    |             |
|                   |                              |    |             |
|                   | § 19.5 Permit Issuance,      |    |             |
|                   | Renewal, Re-openings, and    |    |             |
|                   | Revisions                    |    |             |
|                   |                              |    |             |
|                   | § 19.6 Permit Renewal by the |    |             |
|                   | EPA and Affected States      |    |             |
|                   |                              |    |             |
|                   | § 19.7 Fee Determination and |    |             |
|                   | Certification                |    |             |
+-------------------+------------------------------+----+-------------+
| 24\. Sampling and | § 24.1 Requirements for      | y  | entire      |
| Testing - Records | installation and maintenance | es | facility    |
| and Reports       | of sampling and testing      |    |             |
|                   | facilities                   |    |             |
|                   |                              |    |             |
|                   | § 24.2 Requirements for      |    |             |
|                   | emissions record keeping     |    |             |
|                   |                              |    |             |
|                   | § 24.3 Requirements for the  |    |             |
|                   | record format                |    |             |
|                   |                              |    |             |
|                   | § 24.4 Requirements for the  |    |             |
|                   | retention of records by the  |    |             |
|                   | emission sources             |    |             |
+-------------------+------------------------------+----+-------------+
| 25.1              | § 25.1 Requirements for the  | no | entire      |
| Upset/Breakdown,  | excess emissions caused by   |    | facility    |
| Malfunctions      | upset/breakdown and          |    |             |
|                   | malfunctions                 |    |             |
+-------------------+------------------------------+----+-------------+
| 25.2              | § 25.2 Reporting and         | y  | entire      |
| Upset/Breakdown,  | Consultation                 | es | facility    |
| Malfunctions      |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 26\. Emission of  | § 26.1 Limit on opacity (≤   | y  | entire      |
| Visible Air       | 20 percent for 3 minutes in  | es | facility    |
| Contaminants      | a 60-minute period)          |    |             |
+-------------------+------------------------------+----+-------------+
| 28\. Fuel Burning | Emission Limitations for PM  | y  | entire      |
| Equipment         |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 29\. Sulfur       | Sulfur content shall be      | no | diesel      |
| Contents of Fuel  | equal to or less than 0.05   |    | generator,  |
| Oil               | percent sulfur by weight     |    |             |
|                   |                              |    | diesel fire |
|                   |                              |    | pump        |
+-------------------+------------------------------+----+-------------+
| 40\. Prohibitions | § 40.1 Prohibitions          | no | entire      |
| of Nuisance       |                              |    | facility    |
| Conditions        |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 41\. Fugitive     | § 41.1 Prohibitions          | y  | entire      |
| Dust              |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 42\. Open Burning | § 42.2                       | no | entire      |
|                   |                              |    | facility    |
+-------------------+------------------------------+----+-------------+
| 43\. Odors In the | § 43.1 Prohibitions coded as | no | entire      |
| Ambient Air       | Section 29                   |    | facility    |
+-------------------+------------------------------+----+-------------+
| 49\. Emission     | Local enforcement only all   | no | entire      |
| Standards for     | subsections                  |    | facility    |
| Boilers and Steam |                              |    |             |
| Generators        |                              |    |             |
| Burning Fossil    |                              |    |             |
| Fuels             |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 55\.              | all subsections              | no | entire      |
| Preconstruction   |                              |    | facility    |
| Review for New or |                              |    |             |
| Modified          |                              |    |             |
| Stationary        |                              |    |             |
| Sources in the    |                              |    |             |
| 8-hour Ozone      |                              |    |             |
| Nonattainment     |                              |    |             |
| Area              |                              |    |             |
+-------------------+------------------------------+----+-------------+
| 60\. Evaporation  | all subsections              | y  | entire      |
| and Leakage       |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 70\. Emergency    | all subsections              | y  | entire      |
| Procedures        |                              | es | facility    |
+-------------------+------------------------------+----+-------------+
| 80\.              | all subsections              | y  | entire      |
| Circumvention     |                              | es | facility    |
+-------------------+------------------------------+----+-------------+

## B. Federally Applicable Regulations

**[40 CFR PART 60-STANDARDS OF PERFORMANCE FOR NEW STATIONARY
SOURCES]{.underline}**

#### Subpart A - General Provisions

**40 CFR § 60.7**-**Notification and record keeping** requires
notification to DAQEM of modifications, opacity testing, records of
malfunctions of process equipment and/or continuous monitoring device,
CEMS data, and performance test data. These requirements are found in
the Part 70 OP in Sections III-D, III-E, III-F, and III-G.

DAQEM requires records to be maintained for five (5) years, a more
stringent requirement than the two (2) years required by § 60.7.

**40 CFR § 60.8-Performance tests** requirements are found in the Part
70 OP in Section III-F. Notice of intent to test, the applicable test
methods, acceptable test method operating conditions, and the
requirement for three (3) runs are outlined in this regulation. DAQEM
requirements for initial performance testing are identical to § 60.8.
DAQEM also requires periodic performance testing on emission units based
upon throughput or usage. More discussion is in this document under the
compliance section.

**40 CFR § 60.11-Compliance with standards and maintenance
requirements.**

\(a\) Compliance with standards in this part, other than opacity
standards, shall be determined only by performance tests established by
§ 60.8, unless otherwise specified in the applicable standard.

**Discussion:** Subpart GG also requires fuel monitoring and sampling to
meet a standard. Subpart GG requirements are addressed in the Part 70
permit.

\(b\) Compliance with opacity standards in this part shall be determined
by conducting observations in accordance with Reference Method 9 in
appendix A of this part, any alternative method that is approved by the
Administrator, or as provided in paragraph (e)(5) of this section. For
purposes of determining initial compliance, the minimum total time of
observations shall be 3 hours (30 6-minute averages) for the performance
test or other set of observations (meaning those fugitive-type emission
sources subject only to an opacity standard).

**Discussion:** Visible emissions from each turbine stack shall not
exceed twenty (20) percent opacity for a period or periods aggregating
more than three (3) minutes in any 60-minute period. A Method 9 test
shall be performed initially and every two (2) years thereafter per
Condition III-F-5 of the Part 70 operating permit.

\(c\) The opacity standards set forth in this part shall apply at all
times except during periods of startup, shutdown, malfunction, and as
otherwise provided in the applicable standard.

**Discussion:** Section 26 of the AQR is more stringent than the federal
opacity standards, setting a maximum of 20 percent obscurity for a
period or periods aggregating more than three (3) minutes in any
60-minute period.

\(d\) 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 Administrator which may
include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and
inspection of the source.

**Discussion:** Las Vegas Cogeneration Limited Partnership shall operate
in a manner consistent with this section of the regulation.

**40 CFR § 60.12- Circumvention** prohibition is Condition I-A-27 in the
Part 70 OP. This is also local rule § 80.1.

**40 CFR § 60.13-Monitoring requirements.**

This section requires that CEMS meet Appendix B and Appendix F standards
of operation, testing and performance criteria. Section III-E of the
Part 70 OP contains the CEMS conditions and citations to Appendix B and
F. In addition, the QA plan approved for the CEMS follows the
requirements outlined including span time and recording time.

[]{.mark}

Subpart GG-Standards of Performance for Stationary Gas Turbines

**40 CFR § 60.330-Applicability and designation of affected facility.**

\(a\) The provisions of this subpart are applicable to all stationary
gas turbines with a heat input at peak load equal to or greater than
10.70 gigajoules per hour (ten MMBtu per hour), based on the lower
heating value of the fuel fired.

\(b\) Any facility under paragraph (a) of this section which commences
construction, modification, or reconstruction after October 3, 1977, is
subject to the requirements of this part except as provided in
paragraphs (e) and (j) of § 60.332. \[44 FR 52798, Sept. 10, 1979, as
amended at 52 FR 42434, Nov. 5, 1987\]

**Discussion:** The five (5) combined-cycle turbines began construction
in 2000. The lower heating value of the natural gas fuel is above the
10-MMBtu per hour threshold. Subpart GG shall apply to all EUs: A01, A03
through A06, inclusive.

**40 CFR § 60.332-Standard for nitrogen oxides. (NO~X~ limits using the
F formula)**

(a) On and after the date on which the performance test required by §
    60.8 is completed, every owner or operator subject to the provisions
    of this subpart as specified in paragraphs (b), (c), and (d) of this
    section shall comply with one of the following, except as provided
    in paragraphs (e), (f), (g), (h), (i), (j), (k), and (l) of this
    section.

    1.  No owner or operator subject to the provisions of this subpart
        shall cause to be discharged into the atmosphere from any
        stationary gas turbine, any gases which contain nitrogen oxides
        in excess of:

STD = 0.0075 x 14.4/Y + F

where:

> STD = allowable NOx emissions (percent by volume at 15 percent oxygen
> and on a dry basis).
>
> Y = manufacturer's rated heat rate at manufacturer's rated load
> (kilojoules per watt hour) or, actual measured heat rate based on
> lower heating value of fuel as measured at actual peak load for the
> facility. The value of Y shall not exceed 14.4 kilojoules per
> watt-hour.
>
> F = NOx emission allowance for fuel-bound nitrogen as defined in
> paragraph (a)(3) of this section.

**Discussion:** Per the application for the Title V operating permit,
the New Source Performance Standard (NSPS) NO~X~ emission limit is
calculated with a heat rate of 1.0548 kilojoules/Btu. Assuming that
there are 8.29 Btus per watt-hour, the value of Y in this equation is
8.74 kilojoules per watt-hour. Because the facility uses PUC natural
gas, the F factor is zero. Therefore:

0.0075 x 14.4/8.74 + 0 = 0.0124 percent by volume at 15 percent oxygen

0.0124 volume% x (10,000 ppm/volume%) = 124 ppmv NO~X~ at 15 percent
oxygen

Las Vegas Cogeneration Limited Partnership shall comply with this
standard.

**40 CFR § 60.333-Standard for sulfur dioxide.**

On and after the date on which the performance test required to be
conducted by § 60.8 is completed, every owner or operator subject to the
provision of this subpart shall comply with one or the other of the
following conditions:

(a) No owner or operator subject to the provisions of this subpart shall
    cause to be discharged into the atmosphere from any stationary gas
    turbine any gases which contain sulfur dioxide in excess of 0.015
    percent by volume at 15 percent oxygen and on a dry basis.

(b) No owner or operator subject to the provisions of this subpart shall
    burn in any stationary gas turbine any fuel which contains sulfur in
    excess of 0.8 percent by weight.

**Discussion:** The use of pipeline quality PUC natural gas will satisfy
this regulation. This is stipulated in Condition III-D-9 of the Part 70
operating permit. The sulfur is limited to 0.75 grains per 100 dry
standard cubic feet.

**40 CFR § 60.334-Monitoring of operations.**

\(b\) The owner or operator of any stationary gas turbine subject to the
provisions of this subpart shall monitor sulfur content of the fuel
being fired in the turbine. The frequency of determination of these
values shall be as follows:

> \(2\) If the turbine is supplied its fuel without intermediate bulk
> storage the values shall be determined and recorded daily. Owners,
> operators or fuel vendors may develop custom schedules for
> determination of the values based on the design and operation of the
> affected facility and the characteristics of the fuel supply. These
> custom schedules shall be substantiated with data and must be approved
> by the Administrator before they can be used to comply with paragraph
> (b) of this section.

**Discussion:** This requirement is stipulated in Condition III-D-6 of
the Part 70 operating permit. Sulfur content shall be verified annually
and based on data from the gas supplier.

**40 CFR § 60.335-Test methods and procedures.**

\(b\) In conducting the performance tests required in § 60.8, the owner
or operator shall use as reference methods and procedures the test
methods in appendix A of this part or other methods and procedures as
specified in this section, except as provided for in § 60.8(b).
Acceptable alternative methods and procedures are given in paragraph (f)
of this section.

\(c\) The owner or operator shall determine compliance with the nitrogen
oxides and sulfur dioxide standards in §§ 60.332 and 60.333(a) as
follows:

> \(2\) The monitoring device of § 60.334(a) shall be used to determine
> the fuel consumption and the water-to-fuel ratio necessary to comply
> with § 60.332 at 30, 50, 75, and 100 percent of peak load or at four
> points in the normal operating range of the gas turbine, including the
> minimum point in the range and peak load. All loads shall be corrected
> to ISO conditions using the appropriate equations supplied by the
> manufacturer.
>
> \(3\) Method 20 shall be used to determine the nitrogen oxides, sulfur
> dioxide, and oxygen concentrations. The span values shall be 100 ppm
> of nitrogen oxide and 21 percent oxygen. The NO~X~ emissions shall be
> determined at each of the load conditions specified in paragraph
> (c)(2) of this section.

**Discussion:** These requirements are found in the conditions for
performance testing found in Section III-F of the Part 70 OP.

#### Subpart Da- Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978

### 40 CFR § 60.40a - Applicability

\(a\) The affected facility to which this subpart applies is each
electric utility steam generating unit:

> \(1\) That is capable of combusting more than 73 megawatts (250
> million Btu/hour) heat input of fossil fuel (either alone or in
> combination with any other fuel); and
>
> \(2\) For which construction or modification is commenced after
> September 18, 1978.

\(b\) Unless and until subpart GG of this part extends the applicability
of subpart GG of this part to electric utility steam generators, this
subpart applies to electric utility combined cycle gas turbines that are
capable of combusting more than 73 megawatts (250 million Btu/hour) heat
input of fossil fuel in the steam generator. Only emissions resulting
from combustion of fuels in the steam generating unit are subject to
this subpart. (The gas turbine emissions are subject to subpart GG of
this part.)

**Discussion:** Duct burners are not present at this facility and the
turbines combust only 44 MW each. The boilers (EUs: B01 and B02) are
rated at 13.7 MMBtu/hour each. Therefore, this provision is not
applicable.

**40 CFR § 60.40 (c): Subpart Dc standards**

(a) The affected facility to which this subpart applies is each
    steam-generating unit for which construction, modification, or
    reconstruction is commenced after June 9, 1989 and that has a
    maximum design heat input capacity of 29 megawatts or less but
    greater than or equal to 2.9 MW.

**Discussion:** Subpart Dc applies to the two (2) IBW 13.7 MMBtu/hr
boilers as the facility was built after 1989. Records of fuel usage are
required.

**[40 CFR PART 64-COMPLIANCE ASSURANCE MONITORING]{.underline}**

**40 CFR § 64.2 -- Applicability**

\(a\) General applicability. Except for backup utility units that are
exempt under paragraph (b)(2) of this section, the requirements of this
part shall apply to a pollutant-specific emissions unit at a major
source that is required to obtain a part 70 or 71 permit if the unit
satisfies all of the following criteria:

> \(1\) The unit is subject to an emission limitation or standard for
> the applicable regulated air pollutant (or a surrogate thereof), other
> than an emission limitation or standard that is exempt under paragraph
> (b)(1) of this section;
>
> \(2\) The unit uses a control device to achieve compliance with any
> such emission limitation or standard; and
>
> \(3\) The unit has potential pre-control device emissions of the
> applicable regulated air pollutant that are equal to or greater than
> 100 percent of the amount, in tons per year, required for a source to
> be classified as a major source. For purposes of this paragraph,
> ''potential pre-control device emissions'' shall have the same meaning
> as ''potential to emit,'' as defined in § 64.1, except that emission
> reductions achieved by the applicable control device shall not be
> taken into account.

\(b\) Exemptions

> \(1\) Exempt emission limitations or standards. The requirements of
> this part shall not apply to any of the following emission limitations
> or standards:
>
> \(i\) Emission limitations or standards proposed by the Administrator
> after November 15, 1990 pursuant to section 111 or 112 of the Act.
>
> \(ii\) Stratospheric ozone protection requirements under title VI of
> the Act.
>
> \(iii\) Acid Rain Program requirements pursuant to sections 404, 405,
> 406, 407(a), 407(b), or 410 of the Act.
>
> \(iv\) Emission limitations or standards or other applicable
> requirements that apply solely under an emissions trading program
> approved or promulgated by the Administrator under the Act that allows
> for trading emissions within a source or between sources.
>
> \(v\) An emissions cap that meets the requirements specified in §
> 70.4(b)(12) or § 71.6(a)(13)(iii) of this chapter.
>
> \(vi\) Emission limitations or standards for which a part 70 or 71
> permit specifies a continuous compliance determination method, as
> defined in § 64.1. The exemption provided in this paragraph (b)(1)(vi)
> shall not apply if the applicable compliance method includes an
> assumed control device emission reduction factor that could be
> affected by the actual operation and maintenance of the control device
> (such as a surface coating line controlled by an incinerator for which
> continuous compliance is determined by calculating emissions on the
> basis of coating records and an assumed control device efficiency
> factor based on an initial performance test; in this example, this
> part would apply to the control device and capture system, but not to
> the remaining elements of the coating line, such as raw material
> usage).

**Discussion:** Las Vegas Cogeneration Limited Partnership is major for
PM~10~, NO~X~, CO, and NH~3~. Control devices are used on the combustion
turbines (EUs: A01, A03-A06) for NO~X~ and CO; therefore, PM~10~ and
NH~3~ emissions are not subject to Compliance Assurance Monitoring
(CAM). There are no control devices on the boilers (EUs: B01 and B02),
fire pump (EU: C01) or emergency generator (EU: D01), so none of these
four emission units are subject to CAM.

The turbines at Las Vegas Cogeneration Limited Partnership are subject
to the NO~X~ emission limits of 40 CFR 60 Subpart GG, which was
promulgated in 1979; therefore, the exemption listed in § 64.2(b)(1)(i)
does not apply. The only acid rain provision that applies to NO~X~ is
Section 407 of the CAA, however the section only applies to coal-fired
utility units. Because the turbines at Las Vegas Cogeneration Limited
Partnership are natural gas-fired, this section of the CAA does not
apply and the exemption listed in § 64.2(b)(1)(iii) does not apply.
Because none of the exemptions in § 64.2(b) applies to the NO~X~
emissions at this facility, the turbines at Las Vegas Cogeneration
Limited Partnership are subject to CAM for NO~X~.

The turbines at Las Vegas Cogeneration Limited Partnership are subject
to the CO emission limits presented in the facilities ATC/OP. There are
no promulgated NSPS or DAQEM emission limits; therefore, the exemption
listed in § 64.2(b)(1)(i) does not apply. Because none of the exemptions
in § 64.2(b) applies to the CO emissions at this facility, the turbines
at Las Vegas Cogeneration Limited Partnership are subject to CAM for CO.

Las Vegas Cogeneration Limited Partnership shall comply with the CAM
rule through the NO~X~ and CO CEMS that are installed on the turbine
exhaust stacks.

**[40 CFR PART 72-ACID RAIN PERMITS REGULATION]{.underline}**

**Subpart A -- Acid Rain Program General Provisions**

**40 CFR § 72.6 -- Applicability**

\(a\) Each of the following units shall be an affected unit, and any
source that includes such a unit shall be an affected source, subject to
the requirements of the Acid Rain Program:

> \(1\) unit listed in table 1 of § 73.10(a) of this chapter.
>
> \(2\) A unit that is listed in table 2 or 3 of § 73.10 of this chapter
> and any other existing utility unit, except a unit under paragraph (b)
> of this section.
>
> \(3\) A utility unit, except a unit under paragraph (b) of this
> section, that:
>
> \(i\) Is a new unit; or
>
> \(ii\) Did not serve a generator with a nameplate capacity greater
> than 25 MWe on November 15, 1990 but serves such a generator after
> November 15, 1990.
>
> \(iii\) Was a simple combustion turbine on November 15, 1990 but adds
> or uses auxiliary firing after November 15, 1990;
>
> \(iv\) Was an exempt cogeneration facility under paragraph (b)(4) of
> this section but during any three calendar year period after November
> 15, 1990 sold, to a utility power distribution system, an annual
> average of more than one-third of its potential electrical output
> capacity and more than 219,000 MWe-hrs electric output, on a gross
> basis;
>
> \(v\) Was an exempt qualifying facility under paragraph (b)(5) of this
> section but, at any time after the later of November 15, 1990 or the
> date the facility commences commercial operation, fails to meet the
> definition of qualifying facility;
>
> \(vi\) Was an exempt IPP under paragraph (b)(6) of this section but,
> at any time after the later of November 15, 1990 or the date the
> facility commences commercial operation, fails to meet the definition
> of independent power production facility; or
>
> \(vii\) Was an exempt solid waste incinerator under paragraph (b)(7)
> of this section but during any three calendar year period after
> November 15, 1990 consumes 20 percent or more (on a Btu basis) fossil
> fuel.

**Discussion:** Las Vegas Cogeneration Limited Partnership is defined as
a utility unit pursuant to the definitions in Part 72; therefore, the
provisions of this regulation apply.

**40 CFR § 72.9 -- Standard Requirements**

\(a\) *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 this part in accordance with the deadlines
> specified in § 72.30;
>
> \(ii\) Submit in a timely manner a complete reduced utilization plan
> if required under § 72.43; and
>
> \(iii\) 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.

\(b\) *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 part 75 of this chapter.
>
> \(2\) The emissions measurements recorded and reported in accordance
> with part 75 of this chapter shall be used to determine compliance by
> 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 part 75 of this chapter 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.

\(c\) *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
> unit's compliance subaccount (after deductions under § 73.34(c) of
> this chapter) not less than the total annual emissions of sulfur
> dioxide for the previous calendar year from the unit; and
>
> \(ii\) Comply with the applicable Acid Rain emissions limitation 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 (c)(1) of this section as follows:
>
> \(i\) Starting January 1, 1995, an affected unit under § 72.6(a)(1);
>
> \(ii\) Starting on or after January 1, 1995 in accordance with §§
> 72.41 and 72.43, an affected unit under § 72.6(a) (2) or (3) that is a
> substitution or compensating unit;
>
> \(iii\) Starting January 1, 2000, an affected unit under § 72.6(a)(2)
> that is not a substitution or compensating unit; or
>
> \(iv\) Starting on the later of January 1, 2000 or the deadline for
> monitor certification under part 75 of this chapter, an affected unit
> under § 72.6(a)(3) that is not a substitution or compensating unit.
>
> \(4\) 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 (c)(1)(i) of this section, 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 §§ 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.

\(d\) *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.

\(e\) *Excess Emissions Requirements.*

> \(1\) The designated representative of an affected unit that has
> excess emissions in any calendar year shall submit a proposed offset
> plan, as required under part 77 of this chapter.
>
> \(2\) The owners and operators of an affected unit 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 part 77 of this chapter; and
>
> \(ii\) Comply with the terms of an approved offset plan, as required
> by part 77 of this chapter.

\(f\) *Recordkeeping and Reporting Requirements.*

> \(1\) Unless otherwise provided, the owners and operators of the
> source and each affected unit at the source shall keep on site at the
> source each of the following documents for a period of 5 years from
> the date the document is created. This period may be extended for
> cause, at any time prior to the end of 5 years, in writing by the
> Administrator or permitting authority.
>
> \(i\) The certificate of representation for the designated
> representative for the source and each affected unit at the source and
> all documents that demonstrate the truth of the statements in the
> certificate of representation, in accordance with § 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 part
> 75 of this chapter; *provided* that to the extent that 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.
>
> \(iv\) 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 subpart I of this part and part 75 of this chapter.

\(g\) *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 § 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. Except as provided under § 72.41 (substitution
> plans), § 72.42 (Phase I extension plans), § 72.43 (reduced
> utilization plans), § 72.44 (Phase II repowering extension plans), §
> 74.47 of this chapter (thermal energy plans), and § 76.11 of this
> chapter (NOX averaging plans), and except with regard to the
> requirements applicable to units with a common stack under part 75 of
> this chapter (including §§ 75.16, 75.17 and 75.18 of this chapter),
> the owners and operators and the designated representative of one
> affected unit shall not be liable for any violation by any other
> affected unit of which they are not owners or operators or the
> designated representative and that is located at a source of which
> they are not owners or operators or the designated representative.
>
> \(7\) Each violation of a provision of this part, parts 73, 74, 75,
> 76, 77, and 78 of this chapter, 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.

\(h\) *Effect on Other Authorities.* No provision of the Acid Rain
Program, an Acid Rain permit application, an Acid Rain permit, or an
exemption under § 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 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 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.
>
> \(5\) Interfering with or impairing any program for competitive
> bidding for power supply in a State in which such program is
> established.

**Discussion:** Las Vegas Cogeneration Limited Partnership has applied
for all of the proper permits under this regulation. An ORIS Code
(#10761) for emission units GE LM-6000 Turbine Unit #1 through GE
LM-6000 Turbine Unit #5 (EUs: A01, A03 through A06, inclusive) has been
obtained. A Certificate of Representation for Designated Representative
has been registered with Tom Ohlmacher as the primary representative and
Fred Carl as the alternate representative.

**Subpart B -- Designated Representative**

Las Vegas Cogeneration Limited Partnership has a Certificate of
Representation for Designated Representative on file. They have
fulfilled all requirements under this subpart.

**Subpart C -- Acid Rain Permit Applications**

Las Vegas Cogeneration Limited Partnership has applied for an acid rain
permit.

**Subpart D -- Acid Rain Compliance Plan and Compliance Options**

This subpart discusses the individual requirements necessary for a
complete compliance plan. A compliance plan exists for each combustion
turbine.

**Subpart E -- Acid Rain Permit Contents**

Las Vegas Cogeneration Limited Partnership has applied for an acid rain
permit, and it will contain all information to demonstrate compliance
with this subpart.

**[40 CFR PART 73 -- ACID RAIN SULFUR DIOXIDE ALLOWANCE
SYSTEM]{.underline}**

**Subpart A -- Background and Summary**

**§ 73.1 Purpose and scope.**

The purpose of this part is to establish the requirements and procedures
for the following:

\(a\) The allocation of sulfur dioxide emissions allowances;

\(b\) The tracking, holding, and transfer of allowances;

\(c\) The deduction of allowances for purposes of compliance and for
purposes of offsetting excess emissions pursuant to parts 72 and 77 of
this chapter;

\(d\) The sale of allowances through EPA-sponsored auctions and a direct
sale, including the independent power producers written guarantee
program; and

\(e\) The application for, and distribution of, allowances from the
Conservation and Renewable Energy Reserve.

\(f\) The application for, and distribution of, allowances for
desulfurization of fuel by small diesel refineries.

**§ 73.2 Applicability.**

The following parties shall be subject to the provisions of this part:

\(a\) Owners, operators, and designated representatives of affected
sources and affected units pursuant to § 72.6 of this chapter;

\(b\) Any new independent power producer as defined in section 416 of
the Act and § 72.2 of this chapter, except as provided in section
405(g)(6) of the Act;

\(c\) Any owner of an affected unit who may apply to receive allowances
under the Energy Conservation and Renewable Energy Reserve Program
established in accordance with section 404(f) of the Act;

\(d\) Any small diesel refinery as defined in § 72.2 of this chapter,
and

\(e\) Any other person, as defined in § 72.2 of this chapter, who
chooses to purchase, hold, or transfer allowances as provided in section
403(b) of the Act.

**Discussion:** Las Vegas Cogeneration Limited Partnership is an
affected source pursuant to § 72.6 of this chapter because it fits the
definition of a utility unit; therefore, this regulation shall apply.

**Subpart B -- Allowance Allocations**

Las Vegas Cogeneration Limited Partnership is not listed on either the
Phase I or Phase II tables because it is a newer power plant; therefore,
it will not have an initial allocation per § 73.10.

**Subpart C -- Allowance Tracking System**

Las Vegas Cogeneration Limited Partnership is considered a new unit. A
complete certificate of representation has been received and an account
has been established for this facility. Las Vegas Cogeneration Limited
Partnership shall follow all guidelines and instructions presented in
this subpart while maintaining its allowance account.

**Subpart D -- Allowance Transfers**

When an allowance transfer is necessary, Las Vegas Cogeneration Limited
Partnership shall follow all procedures in this subpart.

**Subpart E -- Auctions, Direct Sales, and Independent Power Producers
Written Guarantee**

This subpart outlines the auction process for allowance credits.

**Subpart F -- Energy Conservation and Renewable Energy Reserve**

There are no qualified conservation measures or renewable energy
generation processes at this facility; therefore, this subpart does not
apply.

**[40 CFR PART 75-CONTINUOUS EMISSION MONITORING]{.underline}**

**Subpart A -- General**

**40 CFR § 75.2 -- Applicability**

\(a\) Except as provided in paragraphs (b) and (c) of this section, the
provisions of this part apply to each affected unit subject to Acid Rain
emission limitations or reduction requirements for SO~2~ or NO~X~.

**Discussion:** Las Vegas Cogeneration Limited Partnership is subject to
the Acid Rain emission limitations of 40 CFR Part 72; therefore, the
facility is subject to the monitoring requirements of this regulation.

Each combined cycle turbine unit has been equipped with both a NO~X~
CEMS and a diluent oxygen monitor. Each turbine unit is also equipped
with a fuel flow monitor. Each turbine unit also has a CO CEMS and a
CEMS-equivalent monitoring device to measure ammonia emissions. The data
from the CEMS are used to provide quarterly acid rain reports to both
EPA and DAQEM.

All required monitoring plans, RATA testing protocols, and
certification-testing reports have been provided to EPA and DAQEM.
Initial CEMS certification testing was completed on April 10, 2003. The
CEMS Quality Assurance Plan was approved on January 2, 2002.

# V. COMPLIANCE

## A. Compliance Certification

1\. Regardless of the date of issuance of this Part 70 OP, the schedule
for the submittal of reports to the DAQEM Compliance Reporting
Supervisor shall be as follows:

+------+--------------------+-------+---------------------------------+
| **Q  | **Applicable       | **Due | **Required Contents**           |
| uart | Period**           | D     |                                 |
| er** |                    | ate** |                                 |
+------+--------------------+-------+---------------------------------+
| 1    | January, February, | April | Quarterly Report for 1^st^      |
|      | March              | 30    | Calendar Quarter                |
|      |                    |       |                                 |
|      |                    | each  |                                 |
|      |                    | year  |                                 |
+------+--------------------+-------+---------------------------------+
| 2    | April, May, June   | July  | Quarterly Report for 2^nd^      |
|      |                    | 30    | Calendar Quarter                |
|      |                    |       |                                 |
|      |                    | each  |                                 |
|      |                    | year  |                                 |
+------+--------------------+-------+---------------------------------+
| 3    | July, August,      | Oc    | Quarterly Report for 3^rd^      |
|      | September          | tober | Calendar Quarter                |
|      |                    | 30    |                                 |
|      |                    |       |                                 |
|      |                    | each  |                                 |
|      |                    | year  |                                 |
+------+--------------------+-------+---------------------------------+
| 4    | October, November, | Ja    | Quarterly Report for 4^th^      |
|      | December           | nuary | Calendar Quarter, any           |
|      |                    | 30    | additional annual records       |
|      |                    |       | required, and                   |
|      |                    | each  |                                 |
|      |                    | year  | Annual Certification of         |
|      |                    |       | Compliance                      |
+------+--------------------+-------+---------------------------------+

> *\[Authority: AQR § 19.3.3.9\]*

2\. A statement of methods used for determining compliance, including a
description of monitoring, record keeping, and reporting requirements
and test methods.

3\. A schedule for submission of compliance certifications during the
permit term.

4\. A statement indicating the source\'s compliance status with any
applicable enhanced monitoring and compliance certification requirements
of the Act.

## B. Summary of Monitoring for Compliance

+-----+------+------+-----------+-----------+-------------------------+
| **E | **P  | **M  | **A       | **Requi   | **Compliance            |
| mis | roce | onit | pplicable | rements** | Monitoring**            |
| sio | ss** | ored | S         |           |                         |
| n** |      | Poll | ubsection |           |                         |
|     | **D  | utan | Title**   |           |                         |
| **U | escr | ts** |           |           |                         |
| nit | ipti |      |           |           |                         |
| \   | on** |      |           |           |                         |
| #** |      |      |           |           |                         |
+=====+======+======+===========+===========+=========================+
| A   | Co   | CO,  | AQR       | Annual    | CEMS for NO~X~ and CO.  |
| 01, | mbus | NO   | Section   | and       |                         |
| A   | tion | ~X~, | 12,       | s         | Stack testing by EPA    |
| 03, | turb | SO   | Section   | hort-term | Methods as approved by  |
| A   | ines | ~2~, | 19,       | emission  | DAQEM and EPA in        |
| 04, | u    | PM~  | Section   | limits.   | current ATC/OP.         |
| A   | nits | 10~, | 55        |           |                         |
| 05, |      | VOC, |           |           | Compliance for HAPs and |
| A06 |      | H    | 40 CFR 60 |           | non-CEMS monitored      |
|     |      | APs, | Subpart   |           | emissions shall be      |
|     |      | N    | GG        |           | based on fuel           |
|     |      | H~3~ |           |           | consumption and         |
|     |      |      |           |           | emission factors.       |
|     |      |      |           |           |                         |
|     |      |      |           |           | PEMS for NH~3~          |
|     |      |      |           |           |                         |
|     |      |      |           |           | Recording is required   |
|     |      |      |           |           | for compliance          |
|     |      |      |           |           | demonstration.          |
+-----+------+------+-----------+-----------+-------------------------+
| A   | Co   | Opa  | 40 CFR 60 | Opacity   | EPA Method 9 performed  |
| 01, | mbus | city | Subpart   | shall not | every two years         |
| A   | tion |      | GG        | exceed    |                         |
| 03, | turb |      |           | 20%,      |                         |
| A   | ines |      | AQR       | except    |                         |
| 04, | u    |      | Section   | for 3     |                         |
| A   | nits |      | 26        | min. out  |                         |
| 05, |      |      |           | of every  |                         |
| A06 |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+
| A   | Coo  | PM~  | AQR       | Opacity   | Additional monitoring   |
| 02, | ling | 10~, | Section   | shall not | per the request of the  |
| A07 | to   |      | 12        | exceed    | Control Officer         |
|     | wers |      |           | 20%,      |                         |
|     |      |      | AQR       | except    |                         |
|     |      |      | Section   | for 3     |                         |
|     |      |      | 26        | min. out  |                         |
|     |      |      |           | of every  |                         |
|     |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+
| B   | Boi  | CO,  | AQR       | Opacity   | Method testing once     |
| 01, | lers | N    | Section   | shall not | every five years        |
| B02 |      | O~X~ | 49        | exceed    |                         |
|     |      |      |           | 20%,      |                         |
|     |      |      |           | except    |                         |
|     |      |      |           | for 3     |                         |
|     |      |      |           | min. out  |                         |
|     |      |      |           | of every  |                         |
|     |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+
| B   | Boi  | Opa  | AQR       | Opacity   | Additional monitoring   |
| 01, | lers | city | Section   | shall not | per the request of the  |
| B02 |      |      | 26        | exceed    | Control Officer         |
|     |      |      |           | 20%,      |                         |
|     |      |      |           | except    |                         |
|     |      |      |           | for 3     |                         |
|     |      |      |           | min. out  |                         |
|     |      |      |           | of every  |                         |
|     |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+
| C01 | Di   | SO   | AQR       | Opacity   | Hours of operation,     |
|     | esel | ~2~, | Section   | shall not | sulfur content of fuel. |
|     | E    | Opa  | 26        | exceed    | Additional monitoring   |
|     | merg | city |           | 20%,      | per the request of the  |
|     | ency |      |           | except    | Control Officer         |
|     | G    |      |           | for 3     |                         |
|     | ener |      |           | min. out  |                         |
|     | ator |      |           | of every  |                         |
|     |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+
| D01 | Di   | SO   | AQR       | Opacity   | Hours of operation,     |
|     | esel | ~2~, | Section   | shall not | sulfur content of fuel. |
|     | Fire | Opa  | 26        | exceed    | Additional monitoring   |
|     | Pump | city |           | 20%,      | per the request of the  |
|     |      |      |           | except    | Control Officer         |
|     |      |      |           | for 3     |                         |
|     |      |      |           | min. out  |                         |
|     |      |      |           | of every  |                         |
|     |      |      |           | 60 min.   |                         |
|     |      |      |           | period    |                         |
+-----+------+------+-----------+-----------+-------------------------+

# VI. MITIGATION

At the time of this permitting action, the source has no federal offset
requirements. *\[Authority: AQR Section 59 (Amended 10/7/04)\]*

# VII. ADMINISTRATIVE REQUIREMENTS

AQR Section 19 requires that DAQEM identify the original authority for
each term and condition in the Part 70 Operating Permit. Such reference
of origin or citation is denoted by \[italic text in brackets\] after
each Part 70 Permit condition.

DAQEM proposes to issue the Part 70 Operating Permit conditions on the
following basis:

Legal:

On December 5, 2001 in Federal Register Volume 66, Number 234 FR30097
the EPA fully approved the Title V Operating Permit Program submitted
for the purpose of complying with the Title V requirements of the 1990
Clean Air Act Amendments and implementing Part 70 of Title 40 Code of
Federal Regulations.

Factual:

Las Vegas Cogeneration Limited Partnership has supplied all the
necessary information for DAQEM to draft Part 70 Operating Permit
conditions encompassing all applicable requirements and corresponding
compliance.

Conclusion:

DAQEM has determined that Las Vegas Cogeneration Limited Partnership
shall continue to determine compliance through the use of CEMS,
performance testing, quarterly reporting, daily record keeping, coupled
with annual certifications of compliance. DAQEM proceeds with the
preliminary decision that a Part 70 Operating Permit should be issued as
drafted to Las Vegas Cogeneration Limited Partnership for a period not
to exceed five (5) years.

**END OF TSD**