UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 2

290 BROADWAY

NEWYORK. NY 10007-1866

APR -1 2004

Mr. Jaime A. Plaza, Head

Environmental Protection and

Quality Assurance Division

Puerto Rico Electric and Power Authority

P.O. Box 364267

San Juan, Puerto Rico 00936-4267

Re: Final Permit- Prevention ofSignificant Deterioration (PSD)- for the San Juan Combined

Cycle Project- Puerto Rico Electric and Power Authority (pREPA)

Dear Mr. Plaza:

On December 16, 2002, PREPA submitted a PSD permit application for the construction

of a 476 megawatt combustion turbine combined cycle electric generating station at the San Juan

site. The U.S. Environmental Protection Agency (EPA) issued a Proposed PSD Permit for public

comments on January 23, 2004. The public comment period commenced on February 6,2004.

EPA also held two Public Availability Sessions on February 18, 2004, related to this permit. The

purpose ofthese sessions was to conduct outreach to the public beyond that which is required by

40 CFR Part 124, in order to explain the project and be available to clarify the permitting actions

and procedures. During these sessions only one individual asked for clarifications. EPA also

indicated many times during these sessions that any comment on this PSD permit must be

submitted in writing by the close ofthe public comment period. This is consistent with the

requirements in 40 CFR §124.11 that comments must be submitted in writing. EPA also

indicated in its draft permit public notice that any request for a public hearing must be submitted

within 15 days ofthe notice. No such request was submitted. EPA did not receive any written

comments during the public comment period which ended on March 8, 2004. Therefore, EPA

today issues the proposed permit as final without any changes to the proposed permit.

This final permit will allow PREPA to construct two new Westinghouse 501 combustion

turbines which will use distillate oil with 0.05% sulfur as the only fuel. These turbines will be

limited to operate for a total of 15,000 hours per year. Additionally, the existing four boilers (7-

10) will be modified to lower the nitrogen oxide (NOx) emissions and use heavy oil with 0.5%

sulfur. EPA has determined that this final permit meets all applicable requirements ofthe PSD

regulations codified at 40 CFR §52.21 and the Clean Air Act (the Act). Accordingly, EPA

hereby approves PREPA's PSD permit for the Combined Cycle Project. This letter and its

enclosures represent EPA's final permit decision. A project description and summary ofthe

control technologies to be used are provided in Enclosure I. The permit conditions are delineated

in Enclosure II. This final permit decision becomes effective today. Since no comments were

received during the public comment period, this permit may not be challenged under the

Consolidated Permit Regulations, codified at 40 CFR Part 124, that apply to EPA's

Intemet Address (URL). http://www.epa.gov

Recycled/Recyclable.Printed with Vegetable 011 Baed Inks on Recycled Paper (MInimum 50% Postconaumer content)
processing ofthis pennit decision and no judicial review is available. Nptice:ofthe Agency's

final action with respect to this pennit wili be published in the Federal Register. Under Section

307(b) ofthe Act, this final Agency action shall not be subject to judicial review in civil or

criminal proceedings for enforcement.

If you have any questions regarding this letter, please call Mr. Steven C. Riva, Chief,

Pennitting Section, Air Programs Branch, at (212) 637-4074.

~h:J/i<-- Walter Mugdan, I5irector

Division ofEnvironmental Planning and Protection

Enclosures

cc: Angel Berrios, Associate Member

Puerto Rico Environmental Quality Board (w/o)

Evelyn Rodriguez Citron, Director, Air Quality Area

Puerto Rico Environmental Quality Board (wi)

David Shea, ENSR (wI)
ENCLOSURE I

PUERTO RICO ELECTRIC POWER AUTHORITY (PREPA)

SAN JUAN COMBINED CYCLE PROJECT·

Final Permit

GENERAL PROJECT DESCRIPTION: On December 16,2002, the Puerto Rico Electric

Power Authority (PREPA) submitted an application for a combined cycle project ~t its San Juan

location. On January 23, 2004, EPA issued a proposed pennit for this project. In this project,

PREPA proposed to install and operate two (2) 238 megawatt (MW, net) combined cycle

turbines. The facility will produce electricity from Westinghouse 501 distillate oil fired

. combustion turbines, each with a power output of 171 MW, an additional 67 MW electricity will

be produced by two steam turbines driven by two Heat Recovery Steam Generators (HRSG). No

supplemental firing offuel will be used in the HRSGs. Each combustion turbine will burn No.2

fuel oil having a maximum sulfur content of 0.05 percent by weight. Both turbine units will be

operated 15,000 hours per year. As a part ofthis project, PREPA proposes to modify burners to

lower Nitrogen Oxide (NOx) emissions from four existing residual fired boiler units (7 through

10) and switch to using 0.5% from 1.5% sulfur heavy oil in those units. The total capacity at this

site will increase from 400 MW to 876 MW after repowering. PREPA also proposed to install

two new 2.5 MW auxiliary diesel generators, convert two existing residual fuel oil storage tanks

to no. 2 oil storage tanks, install two new fixed roofstorage tanks (one for no. 2 oil and the other

for residual oil) and will install six new cooling towers for auxiliary equipment cooling.

PSD-Affected Pollutants Emitted at the PREPA Sa·n Juan Repowering ~roject: The existing

facility is classified as a major stationary source because it has the potential to emit more than

100 tons per year of at least one pollutant regulated by the Clean Air Act. Based on this

proposal, EPA has concluded that PSD will not apply to (i.e., PREPA will net out ofthe PSD

review for) sulfur dioxides (S02)' particulate matter (PMIPM10) and sulfuric acid mist (H2S04).

The lead emission increase will be below significant level for PSD review. However, PSD will

apply to nitrogen oxide (NOx), carbon monoxide (CO) and volatile organic compounds (VOCs).

In addition, the new combustion turbines will be limited to 85.6 % annual capacity (or 15,000

hours) utilization. Under these conditions, there will be a net decrease or no significant increase

in emissions ofsulfur dioxides (S02)' sulfuric acid mist (H2S04), particulate matter (PMIPM1o),

and lead (Pb).

PREPA Combined Cycle Project Control Equipment: The proposed facility will employ

Best Available Control Technology to control NOx, CO and VOC. Emissions of nitrogen oxide

will be controlled by installing a steam injection system in the combustion turbines. The steam

to fuel ratio for each unit shall be established during perfonnance testing and shall be

incorporated into this PSD pennit. NOx emissions from the existing four residual oil fired units

7 through 10 shall be reduced by modifying burners and good combustion control. Emissions of

carbon monoxide and volatile organic compounds will be controlled by implementing good

combustion practices.

PREPA shall be required to operate each turbine within the designed combustion parameters of

the Westinghouse 501 distillate oil fired combustion turbine. In addition, PREPA shall be

Page 1 of 7
required to monitor t. combustion temperature and fuel flow rate ol_.ch turbine, and to

maintain each turbine in good working order.

\,

This pennit further requires that the proposed facility.employthe following control techniques to

net out ofPSD applicability for the other pollutants:

Emissions ofsulfur dioxide and sulfuric acid mist shall be controlled by the use 9fonly low

sulfur No.2 fuel oil in which the sulfur content may not exceed 0.05% by weight in the

combustion turbines and by the use of 0.5% sulfur heavy oil in the existing boiler units 7-10.

Emissions of total particulate matter and particulate matter less than 10 microns will be

controlled by implementing good combustion practices.

The auxiliary diesel generators will be limited to a total of40 hours per year of operation. The

storage tanks will be installed with a fixed roof and the cooling tower particulate emissions will

be controlled by installing drift eliminators.

Summary: Table I provides the summary ofnet emissions from this project. As indicated in the

table, there are three pollutants, NOx, CO and VOC, for which the facility is subject to PSD.

Table II summarizes the PSD netting analyses and Table ill lists BACT and other controls for

this project. Table IV and V relate to air quality analyses pertaining to this project.

a e - missions nalYSIS

POLLUTANT PSD PREPASAN PSD

SIGNIFICANT JUAN'S NET APPLICABLE

EMISSION EMISSIONS

RATE TONSIYEAR*

TONSIYEAR

Nitrogen Oxides (NOJ 40 1107 Yes

Sulfur Dioxide (SOl) 40 (10812) No

Sulfuric Acid Mist (H2SO4) 7 (1) No

Particulate Matt~r - Total 25 (1) No

(PM)

Particulate Matter less 15 (1) No

than 10 microns (PM1O)

Carbon Monoxide (CO) 100 1222 Yes

Volatile Organic Compounds 40 124 Yes

(VOC)

Lead 0.6 0.1 No

PREPA San Juan

T bl I PSD E·· A I ·

Page 2 of 7
• Net erh_...lons reflect emission increases due to new turbines and emission det._Aes due to modifications and

operational changes at the existing units on site. Thus net emissions reflect actual emissions before the project is

implemented as compared with the poten~ial to emit after the changes take place. () indicates that there will be a net

decrease of emissions at this site due to repowering

Page 3 of 7
...

(t I)

PREPA San Juan

fPSD N tt eTable II_.Summar"'0 e Ing Analyses ons'yr

POLLU COMBUSTION AUX NEW NEW CONTEMPORARY BURNER NET PSD PSD

-TANT TURBINE DIESEL COOLING STORAGE CHANGES DUE TO MODIFI.. EMISSIONS De MINIMIS APPLICEMISSIONS GENER- TOWER TANK NET FUEL SULFUR CATIONS CHANGE LEVELS ABLE?

ATOR NET EMISSIONS REDUCTION IN AT UNITS AT THIS

EMISSIONS EMISSION UNITS 7-10 7-10 FACILITY

S

S02 640.1 0.047 0.0 0 (11452.4) NA (10812.3) 40 NO

H2SO4 98 0.0072 0.0 0 (99) NA (1) 7 NO

LEAD 0.11 8.2E-06 0.0 0 0 NA 0.1 0.6 NO

NOx 1658.9 2.048 0.0 0 0 (553.6) 1107.4* 40 YES

PM 360.9 0.093 0.623 0 (362.6) NA (1) 25 NO

PMIO 453.1 0.093 0.015 0 (454.1) NA (1) 15 NO

CO 1221.5 0.465 0.0 0 0 NA 1222 100 YES

VOC 116.6 0.084 0.0 7.377 0 NA 124.1 40 YES

TOTAL 4549.2 2.836 0.638 7.377 (12368.1) (553.6) (8361.7)

( ) denotes decrease in emissions

• Unlike the November 30, 2000, PSD Permit, which showed a 84.8 tons/year net decrease in NOx emissions, this proposed permit netting analyses shows a net

emission increase in NOx. This is because EPA is no longer crediting decreases in NOx for the retiring ofUnits 5 and 6. Note that PREPA proposes to operate

the turbines 15,000 hours per year vs. 12,067 hours per year in the earlier PSD permit.

Page 4 of 7
PREPA San Juan

TABLE 111- BACT and Other Controls (each turbine)

POLI.,UTANT NSPSLEVELS EMISSION LIMITS EMISSION CONTROL

FOR NEW TURBINES FOR NEW TURBINES

S02 150 PPMDV*** 13 PPMDV LOW SULFUR No.2

FUEL (0.05%)

NOx 110 PPMDV 34.2 PPMDV STEAM INJECTION

PM N/A 0.041 Ibs/MMBtu COMBUSTION

CONTROL

PM-IO N/A 0.052 Ibs/MMBtu COMBUSTION

CONTROL

H2SO4 N/A 13.81bslhr LOW SULFUR OIL

(0.05%)

CO N/A 60 PPMDV @ 60% COMBUSTION

LOAD CONTROL

25 PPMDV @ BASE

LOAD

VOC N/A 10 PPMDV @ 60% COMBUSTION

LOAD CONTROL

6.2 PPMDV @ BASE

LOAD

•••All ppmdv emission limits are corrected to 15°tlo oxygen

Page 5 of 7
PREPA San Juan

Table IV- Air Quality Analyses (concentrations in ug/m3)

Pollutant Modeled Significant Increment & .Monitoring Existing PREPA

Averaging Impact of Impact NAAQS Exemption Monitored Exempt from

Period New Level Required? Level Concentration Installing

Emissions Monitor?

N02

Annual 4.09 1 YES 14 34 YES

CO

1 hour 584 2000 NO --- 12,190 YES

8 hour 166 500 575 6,670

t ti I 3)

PREPA San Juan

T ble V Ca - umuIat-Ive Source PSD ltdncremen an NAAQS (coocen ra ODS 10 Ugl m

Pollutant Modeled .Allowable Modeled + Allowable Comply

Averaging Increment Increment Background NAAQS with Increment

Period NAAQS andNAAQS?

(i.e.total impact) .

N02

Annual 4.09 25 73.7 100 YES

CO

1 hour NonApplicable NonApplicable 12,774 40,000 YES8 hour NonApplicable NonApplicable 6,836 . 10,000 YES

Page 6 of 7
- Representative measured ozone concentrations were obtained. The maximum measured ozone concentration was 196ug/m3. This is

below the ozone NAAQS of235 ug/m3.

Page 7 of 7
ENCLOSURE II ;;

PUERTO RICO ELECTRIC POWER AUTHORITY

SAN JUAN REPOWERING PROJECT

Final Permit

The PREPA San Juan Repowering Project as described in Enclosure I is subject to the following

conditions. .

I. Penni. Expiration

This PSD Pennit shall become invalid ifconstruction:

1. has not commenced (as defined in 40 CFR Part 52.21(b)(9» within 18 months

ofthe effective date ofthis pennit;

2. is discontinued for a period of 18 months or more; or

3. is not completed within a reasonable time.

I. ~otification ofCommencement ofConstruction and Startup

The Regional Administrator (RA) shall be notified in writing ofthe anticipated date of

initial startup (as defined in 40 CFR Part 60.2) of each combustion turbine not more than

sixty (60) days nor less than thirty (30) days prior to such date. The RA shall be notified in

writing ofthe actual date ofboth commencement of construction and startup of each

combustion turbine within fifteen (15) days after such date.

m. Plant Operations

All equipment, facilities, and systems, including the combustion and electric generation

"units, installed or used to achieve compliance with the tenns and conditions ofthis PSD

Pennit shall at all times be maintained in good working order and be operated as efficiently

as possible so as to minimize air pollutant emissions. The continuous emission monitoring.

systems required by this permit shall be on-line and in operation 95% ofthe time when

turbines are operating. PREPA shall demonstrate initial and continuous compliance with

the operating, emission and other limits according to but not limited to the perfonnance

testing and compliance assurance requirements ofthis pennit.

IV. Right to Entry

Pursuant to Section 114 ofthe Clean Air Act (Act), 42 U.S.C. §7414, the Administrator

and/or hislher authorized representatives have the right to enter and inspect for all purposes

authorized· under Section 114 ofthe Act. Thepennittee acknowledges that the Regional

Administrator and/or his/her auth~rized representatives, upon the presentation of

Page 1 of 21
credentials shall be permitted: ."

! : j (

1. to enter at any time upon the premises where the source is located or in which any

records are required to'be kept under the tenns and conditions ofthis PSD Pennit;

2. at ,reasonable times to access and to copy any records required to be kept ~nder the

tenns and conditions ofthis PSD Pennit;

3. to inspect any equipment, operation, or method required in this PSD Pennit; and

4. to sample emissions from the source relevant to this pennit.

v. Transfer ofOwnership

In the event of any changes in control or ownership offacilities to be constructed, this PSD

Pennit shall be binding on all subsequent owners and operators. The applicant shall notify

the succeeding owner and operator ofthe existence ofthis PSD Pennit and its conditions

by letter, ? copy ofwhich shall be forwarded to the Regional Administrator.

VI. Operating Requirements

Each Combustion Turbine

1. Each Westinghouse 501 distillate oil fired combustion turbine unit shall be limited to a

maximum fuel consumption rate (24 hour average) of 12,548 gallons per hour based on

135,000 British Thennal Units HHV per gallon.

2. Except for startup and shutdown, each Westinghouse 501 distillate oil fired combustion

turbine unit shall only be allowed to operate between the following two heat input

levels (24 hour average) (the tenn "load" refers to power output):

a. base load (1,694 MM Btulhr); and

b. 60% load (1,167 MM Btulhr)

3. Heat Recovery Steam Generators (HRSG) shall riot combust supplemental fuel.

4. For the purposes ofthis PSD pennit, startup and shutdown shall be defined as:

a. Startup for each Westinghouse 501 distillate oil fired combustion turbine is defined

as tile period beginning with the initial firing ofNo. 2 fuel oil in the combustion

turbine combustor and ending at the time when the load has increased to the 60%

load. The duration ofthe startup shall not exceed for any given cold startup 5.4

hours(>72 hours shutdown), wann startup 2.75 hours (10 to 72 hours shutdown)

and hot" startup1 hour «10 hours shutdown).

b. Shutdown for each Westinghouse 501 distillate oil fired combustion turbine is

Page 2 of 21
defined as· the period oftime beginning with the load decreasing from 60% load and

ending when the cessation ofoperation ofthe combustion turbine. The duration of

the shutdown shall not exceed three (3) hours for any given combustion turbine

shutdown. '

1

c. During startup and shutdown, PREPA shall comply with all mass emission limits

except for Carbon Monoxide, NOx and VOC emissions which shall be limited to

0.943 IbslMMBtu, 0.533 IbslMMBtu and 0.070 IbslMMBtu respectively for each

start up and shut down. PREPA shall demonstrate compliance with the

startup/shutdown CO and NOx emission rate pursuant to condition XIX ofthis

pennit. PREPA shall also comply with the opacity limits during each startup and

.shutdown. 1·he total number ofcold, wann and hot startup-shutdown cycles· for

both turbines combined shall be limited to 24, 104 and 200 respectively, in a year.

The two turbines shall not be started up or shut down simultaneously.

5. At all times, including periods ofstartup, shutdown, and malfunction, PREPA shall, to

the extent practicable, maintain and operate the two Westinghouse 501 distillate oil

fired combustion t\lrbines including associated air pollution control equipment in a

manner consistent with good air pollution control practice for minimizing emissions.

Determination ofwhether acceptable operating and maintenance procedures are being

used will be based on infonnation available to EPA and/or EQB which may include, but

is not limited to, monitoring results, opacity observations, review of operating and

maintenance procedures, and inspection ofthe plant.

Auxiliary Diesel Generators

1. The maximum design capacity of each Auxiliary Diesel Generator shall be 2500

kilowatts (2.5 MW).

2. The Auxiliary Diesel generators shall be limited to a maximum operation of40-hours

total in a year. The maximum fuel usage shall be limited to 13,690 gallons per year on

a monthly rolling average basis.

3. The Auxiliary Diesel Generator(s) shall not operate concurrently with any two

combustion turbines except during combustion turbine startup and Auxiliary Diesel

Generator testing.

Vll. Emission Limitations

Each Westinghouse 501 Combustion Turbine

1. Carbon Monoxide (CO) (3-hour rolling average)

The concentration/mass emission rate ofCO in the exhaust gas, corrected to 15%

oxygen, shall not exceed:

(i) 25 ppmdv/0.06 IbslMMBtu at the base load heat input level; and

(ii) 60 ppmdv/0.141bsIMMBtu between 60% and the base load heat input level

Page 3 of 21
2. Volatile Organic Compounds (VOC) (l-hour~verage):l.

The concentration/mass emission rate ofVOC (as methane) in the exhaust gas,

corrected to 15% oxygen, shall not exceed:

(i) 6.2 ppmdv/0.0083 IbslMMBtu at the base load heat input level; and

(ii) 10 ppmdv/0.0133 IbslMMBtu between 60% and the base load heat input level

3. Oxides ofNitrogen (NOx) (8-hour rolling average)

The concentration ofNOxin the exhaust gas'shall not exceed 34.2 parts-per-million by

volume on a dry basis (ppmdv), corrected to J5% oxygen and 0.131 IbslMMBtu at load

60% and above.

4. Opacity: Opacity of emissions, as measured by 40 CFR Part 60, Method 9 and an

Opacity monitor, shall not exceed 20% except for a period or periods ofnot more than 4

minutes in any 30-minute interval when the opacity shall not exceed 60%.

Each Auxiliary Diesel Qenerator

1. Carbon Monoxide (CO)

The CO emissions shall not exceed 23.3 lbslhr

2. Volatile Organic Compounds (VOC)

The VOC emissions shall not exceed 4.19 lbslhr

3. Oxides ofNitrogen (NOx)

The NOx emissions shall not exceed 102 pounds per hour (lbslhr) calculated as N02•

4. Opacity

Opacity of emissions, as measured by 40 CFR Part 60, Method 9, shall not exceed 200/0,

except for a period or periods of not more than 4 minutes in any 30-minute interval

when the opacity shall not exceed 60%.

VIII Pollution Control Equipment and Opacity Measurement

1. Each Westinghouse 501 distillate oil fired combustion turbine shall continuously

operate in accordance with its design specified combustion parameters.

2. PREPA shall install and shall continuously operate at each Westinghouse 501 distillate

oil fired combustion turbine a steam injection system; and a curve showing the variation

ofthe steam to fuel ratio for each unit shall be established during the perfonnance

testing. PREPA operators will-'use this curve detennined during the perfonnance

testing and contained within the written report·submitted to EPA.

3. PREPA shall conduct weekly opacity observations at each turbine emission point in

accordance with 40 CFR Part 60, Method 9. The opacity observations shall be made at

Page 4 of 21
the point ofgreatest opacity in that portion ofQle plume where condensed water vapor

is not present. Opacity shall not exceed 20%, :except fora period not more than 4

minutes in any30-minute interval'when opacity shall not exceed 60%.

IX. Continuous Emission Monitoring (eEM) Requirements .

1. Prior to the date ofstartup and thereafter, PREPA shall install, calibrate, maintain, and

operate the following continuous monitoring systems in each ofthe combustion turbine

exhaust stack.

a. A CEM to measure and record stack gas carbon monoxide concentrations. The

system shall meet all applicable EPA Ir10nitoring perfonnance specifications

(including but not limited to 40 CFR Part 60.13 and 40 CFR Part 60, Appendix B,

Perfonnance Specifications 4, and Appendix F). .

b. A continuous emission monitoring system (CEM) to measure and record stack gas

NO" (as measured as N02) concentrations. The system shall meet all applicable

EPA monitoring perfonnance specificatio11s (including but not limited to 40 CFR

Part 60.13 and 40 CFR Part 60, Appendix B, Perfonnance Specifications 2, and

Appendix F).

c. A continuous opacity monitoring system (COM) to measure and record stack

opacity levels. The system shall meet all applicable EPA monitoring perfonnance

specifications (irlcluding but not limited to 40 CFR Part 60.13 and 40 CFR Part 60,

Appendix B, Perfonnance Specifications 1).

d. Continuous monitoring systems to measure and record steam to fuel ratios. Upon

request ofEPA, PREPA shall conduct a perfonnance evaluation ofthe monitor

when testing procedures are fonnalized by the Agency in the future.

2. Not less than 90 days prior to the date ofstartup of each combustion turbine, PREPA

shall submit a written report to EPA of a Quality Assurance Project Plan for the

certification ofthe combustion turbine's monitoring systems. Perfonnance evaluation

ofthe monitoring systems may not begin until the Quality Assurance Project Plan has

been approved by EPA.

3. PREPA shall conduct perfonnance evaluations ofthe COMS's, CEMS's and continuous

monitoring systems during the initial perfonnance testings required under Pennit

Condition X ofthis pennit or wit)lin 30 days thereafter in accordance with the

applicable perfonnance specifications in 40 CFR Part 60, Appendix B, and 40 CFR Part

52, Appendix E. PREPA shall notify the Regional Administrator (RA) 15 days in

advance ofthe date upon which demonstration of,the monitoring system(s) performance

will commence. In addition, PREPA shall comply with Method 203, except that

PREPA may conduct perfonnance audits under Section 5.3 ofMethod 203 semiannually instead ofquarterly.

Page 5 of 21
4. PREPAshall submit a written report to EPA ofthe results of all monitor perfonnance

specification evaluations conducted on the monitoring system(s) within 60 days ofthe ,.-

completion ofthe tests. The monitoring systems must meet all the requirements ofthe

applicable perfonnance specification test in order for the monitors to be certified.

x. Perfonnance Testing Requirements For Each Combustion Turbine

1. Within 60 days after achieving the maximum production rate ofthe combustion turbine,

but no later than 180 days after initial startup as defined in 40 CFR Part 60.2, and at

such other times as specified by the EPA, PREPA shall conduct perfonnance tests for

NOx, CO and VOCs at the combustion turbines. All perfonnance tests shall be

conducted at base load conditions, 60% load conditions andlor other loads specified by

EPA. .

2. Three test runs shall be conducted for each load condition and compliance for each

operating mode shall be based on the average emission rate ofthese runs.

3. At least 60 days prior to actual testing, PREPA shall submit to the EPA a Quality

Assurance Project Plan detailing methods and procedures to be used during the

perfonnance stack testing. A Quality Assurance Project Plan that does not have EPA

approval may be grounds to invalidate any test and require are-test.

4. PREPA shall use the following test methods, or a test method which would be

applicable at the time ofthe test and detailed in a test protocol approved by EPA:

a. Perfonnance tests to detennine the stack gas velocity, s~mple area, volumetric flow

rate, molecular composition, excess air offlue gases, and moisture content offlue

gas shall be conducted using 40 CFR Part 60, Appendix A, Methods 1, 2, 3, and 4.

b. Perfonnance tests for the emissions ofCO shall be conducted using 40 CFR Part 60,

Appendix A, Method 10.

c. Perfonnance tests for the emissions ofNO" shall be conducted using 40 CFR Part

~O, Appendix A, Method 20

d. Perfonnance tests for the emissions ofVOCs shall be conducted using 40 CFR Part

60, Appendix A, Method 25A. PREPA may subtract methane/ethane emissions

from' the VOC emissions detennined using Method 25A. Methane and ethane

emissions shall be detennined using 40 CFR Part 60, Appendix A, Method 18.

e. Perfonnance tests for the visual detennination ofthe opacity of emissions from the

stack shall be conducted using 40 CFR Part 60, Appendix A, Method 9 and the

procedures stated in 40 CFR Part 60.11.

5. Test results indicating that emissions are below the limits ofdetection shall be deemed

to be in compliance.

Page 6 of 21
6. 'Additional perfonnance tests may be required at the discretion ofthe EPA or EQB for

any or all.ofthe above polllltants.

7. For perfonnance test purposes, sampling ports, platfonns and access shall be provided

by PREPA on each ofthe combustion turbine units in accordance with 40 CFR Part

60.8(e).

8. PREPA shall submit a written report to EPA ofthe results of all emission testIng within

60 days ofthe completion ofthe perfonnance test.

9. Operations during periods ofstartup, shutdown, and malfunction shall not constitute

representative conditions for the purpose ofa perfonnance test.

XI. Record keeping Requirements

1. Logs shall be kept and updated daily to record the following:

a. the hours ofoperation of each Westinghouse SO1 distillate oil fired combustion

turbine;

b. the amount of electrical output (MW) on an hourly basis from each Westinghouse

501 distillate oil fired combustion turbine;

c. the steam/fuel ratio at each Westinghouse 501 distillate oil fired combustion turbine

to control NOx emissions;

d. any adjustments and maintenance perfonned on each Westinghouse 501 distillate·

oil fired combustion turbine;

e. any adjustments and maintenance perfonned on monitoring systems; and

2. All monitoring records, fuel sampling test results, calibration test results and logs must

be maintained for a period offive years after the date ofrecord, and made available

upon request. All rolling averages shall be computed on an hourly basis.

3. Compliance assurance with the NOx and CO mass emission limit shall be demonstrated

using data from the CEMs, fuel flow and equation 19.1 in 40 CFR Part 60 Appendix A

Method 19. PREPA will comply with this condition in addition to the requirement to

conduct performance tests.

Page 7of21
PREPA SAN JUAN'REPOWERINGPROJECT

PERMIT CONDITIONS xn thiough xvm ARE BASED ON PSD NETTING ANALYSES

xn Operating Reauirements (based on PSD netting analyses)

CombustiQn Turbine(s)

1. Each Westinghouse 501 distillate oil fired combustion turbine unit shall continuously

use upon start-up No.2 distillate fuel oil which contains no more than:

a. 0.050 percent sulfur by weight; and

b. 0.10 percent nitrogen by weight.

2. Each Westinghouse 501 distillate oil fired combustion turbine unit shall be limited to a

maximum heat input of 1,694 million British Thennal Units per hour (MMBtulhr)(24

hour average), based upon higher heating value (HHV). Maximum total fuel use for

both turbines shall be limited to 188,201,000 gallons/year. Daily compliance shall be

determined by adding the total amount ofgallons offuel used by both turbines during

each calendar day to the total gallons offuel use by both turbines in the preceding 364

calendar days

3. Both Westinghouse 501 distillate oil fired combustion turbines shall only be allowed to

operate for up to 15,000 hours per year. Daily compliance shall be determined by

adding the total amount ofbours operated by both turbines during each calendar day to

the total hours operated by both turbines in the preceding 364 calendar days.

Auxiliary Diesel Generator

The Auxiliary Diesel Generator shall continuously use upon start-up distillate fuel oil

which contains no more than:

a) 0.050 percent sulfur by weight

b) 0.1 0 percent nitrogen by weight

Boiler units 7,8,9 and 10

a. Each existing boiler unit 7 through 10 shall use No.6 oil or lighter.

b. The sulfur content in the fuel oil shall not exceed 0.50% by weight. '

c. The·maximum total fuel use in these four boiler units shall be limited to 173.1 million

gallons per year.

Distillate oil Storage Tanks

A fixed rooftank shall be used for the storage ofdistillate oil.

Page 8 of 21
Cooling Towers: ,:

1. The cooling tower drift shall be limited to less than',or equal to 0.0050/0 ofthe

circulating flow using two stages ofmist eliminators.

2. The mist eliminators shall be inspected every year for wear and tear and replaced

pursuant to good 9perational practices.

xm Emission limits (based oD,the PSD netting analyses):

(Emission values expressed as IbslMMBtu are based on the higher heating value (HHV) of

the fuel)

Each Combustion Turbine

1. Sulfur Dioxide·(S02) (3-hour rolling average)

The S02 emissions shall not exceed 0.05 IbslMMBtu.

2. Sulfuric Acid Mist (H2S04)

The H2S04 emissions shall not exceed 0.0077 IbslMMBtu.

3. Particulate Matter (PM)

The PM emissions shall not exceed 0.041 IbslMMBtu.

4. Particulate Matter < 10 microns (PM-10)

The PM-IO emissions shall not exceed O.0521bs1MMBtu

6. Lead (Pb):

The Pb emissions shall not exceed 9 E -06 IbIMMBtu.

Auxiliary Diesel Generator

1. Sulfur Dioxide (S02)

The S02 emissions shall not ex~eed 2.35 Ibs/hr.

2. Particulate Matter < 10 microns (PM-tO)

The PM-1 0 emissions shall not exceed 4.65 lbs/hr.

Boiler Units 7,8,9 and 10

1. The total NOx emissions calculated as N02from all four boiler units shall not exceed

1571 pounds per hour (lbs/hr) on a rolling 8-hour average basis. The potential to emit

NOx emissions from all four units shall be limited to 5,078 tons/year. PREPA shall

meet these emission limits irrespective ofnitrogen content ofthe no. 6 fuel oil.

2. The PM-I 0 emissions shall be limited to 0.0753 IbslMMBtu.

Page 9 of 21
3. The PM emissions shall be limited to 0)99 IbsIMMBtu~

4. The Sulfuric Acid emissions shall be limited to 0.0405 IbsIMM~tu.

Cooling Towers

Particulate Matter < 10 microns (PM-l 0) (one hour average) shall not exceed 0.0035

Ibs/hour.

XIV Pollution Control Equipment (based on PSDnetting analyses)

1. Each Westinghouse 501 distillate oil fired combustion turbine shall continuously use

upon startup No.2 fuel oil in which:

a. the sulfur content does not exceed 0.050 % by weight; and

b. the nitrogen content does not exceed 0.10% by weight.

2 PREPA shall construct and maintain the facility in a manner that physically prevents

blending ofno. 2 fuel oil with any other oil at the facility. PREPA shall also label and

color code the delivery system for the no. 2 oil.

4. PREPA shall install and operate at each existing boiler unit 7 through lOa modified

burner system. These burner systems shall be installed and operated at least four

months prior to the startup ofthe combustion turbines. The modifications ofthese

burners shall consist ofreplacing swirler assemblies, oil nozzles and plug assemblies or

any equivalent technology that meets the level ofreduction expected from this

equipment and meet the NOx emission limit in xm. PREPA shall notify EPA 60 days

prior to installing equivalent technology.

xv. Fuel Sampling Requirements (based on PSD netting analyses)

1. PREPA shall receive/sample fuel oil for the combustion turbines and the boiler Units 7

through 10 as follows:

a. For Combustion Turbines- PREPA shall take a distillate fuel (no. 2 oil) oil sample

prior to unloading the oil from the supplier. PREPA shall not receive any distillate

fuel oil with a sulfur content greater than 0.050% by weight. Prior to unloading the

oil from the supplier, PREPA shall verify that the sulfur content ofthe oil being

delivered is no greater than 0.050% by weight by evaluating the fuel oil analyses

provided by the supplier and by independently analyzing" andconfinning the sulfur

content ofthe fuel oil. The distillate fuel oil shall also be analyzed for the nitrogen

content.

b. For Boiler Units 7 through 1O-PREPA shall sample no. 6 fuel oil for sulfur content

upon delivery.

Page 10 of 21
2. Compliance with the sulfur content standard shall 'be detennined using the testing

methods est~bllshed in 40 CFR 60.33S(d). ~-' . --. .

3. Compliance with the nitrogen content standard for the distillate oil to be used in the I

combustion turbines shall be detennined using analytical methods and procedures that

are accurate to within 5 percent and are approved by the Administrator to detennine the

nitrogen content ofthe fuel being fired. .

XVI. Continuous Emission Monitoring (GEM) Requirements (based on P§D netting analyses)

1. Prior to the date ofstartup and thereafter, PREPA shall install, calibrate, maintain, and

operate the following continuous monitoring systems in each ofthe combustion turbine

exhaust stack.

a. A CEM to measure and record stack gas oxygen or CO2 concentrations. The system

shall meet all applicable EPA monitoring perfonnance specifications (including but

not limited to 40 CFR Part 60.13 and 40 CFR Part 60, Appendix B, Perfonnance

Specifications 3, and Appendix F).

b. A continuous monitoring system to measure and record fuel flow rate. The system

shall meet all applicable EPA monitoring perfonnance specifications.

2. At least four months prior to the date ofstartup of any combustion turbine and

thereafter, PREPA shall inst~ll, calibrate, maintain, and operate a continuous emission

monitoring system (CEM) to measure and record stack gas NOx (as measured as N02)

concentrations in each ofthe boiler unit 7 through 10 exhaust stack. The system shall

meet all applicable EPA monitoring perfonnance specifications (including but not

limited to 40 CFR Part 60.13 and 40 CFR Part 60, Appendix B, Perfonnance

Specifications 2, and Appendix F). In addition, PREPA shall install a CEM to

measure and record stack gas oxygen concentrations meeting (including but not limited

to 40 CFR Part 60.13 and 40 CFR Part 60, Appendix B, Perfonnance Specifications 3,

and Appendix F). PREPA shall also continuously measure and record fuel flow rate in

lbs per hour. The CEMs shall be on line and in operation.95% ofthe time when the

boilers are operating.

3. Not less than 90 days prior to the date ofstartup ofeach combustion turbine/bumer

modifications in the existing boiler units 7 through 10, PREPA shall submit a written

report to EPA of a Quality Assurance Project Plan for the certification ofthe

monitoring systems. Perfonnance evaluation ofthe monitoring systems may not -begin

until the Quality Assurance Project Plan has been approved by EPA.

4. PREPA shall conduct perfonnance evaluations oftheCOMS's, CEMS's and continuous

monitoring systems during the initial perfonnance testings required under Pennit

Condition xvn ofthis pennit or within 30 days thereafter in accordance with the

applicable perfonnance specifications in 40 CFR Part 60, Appendix B, and 40 CFR Part

Page 11 of 21
52, AppendixE. ,PREPA shall notify the Regional Administrator (RA) 15 days i~

advance ofthe' date uPori which d~monst~ation oftpe monitoring '~ystem(s) performance will commence. ::. .: : -. ' . - -'

s. PREPA shall submit a written report to EPA ofthe results of all monitorperfonnance

specification evaluations conducted on the monitoring system(s) within 60 days ofthe

completion ofthe tests. The monitoring systems must meet all the requiremen~s ofthe

applicable perfonnance specification test in order for the monitors to be certified.

xvu. Perfonnance Testing Requirements (based on PSD netting analyses)

1. PREPA shall conduct perfonnance tests for each combustion turbine and each boiler

unit 7 through 10 as follows:

a. Each Combustion Turbine- Within 60 days after achieving the maximum production

rate ofthe combustion turbine, but no later than 180 days after initial startup as

defined in 40 CFR Part 60.2, and at such -other times as specified by the EPA,

PREPA shall conduct perfonnance tests for S02' H2S04, PM, PM10 and Lead at the

combustion turbines. All perfonnance tests shall be conducted at base load

conditions, 60% load conditions and/or other loads specified by EPA.

b. Each Boiler Unit 7 through 10- Within 60 days after modifying burners, but no later

than 180 days after the modified burners' startup as defined in 40 CFR Part 60.2,

and at such other times as specified by th~ EPA, PREPA shall conduct perfonnance

tests for NOx, PM, PM10' and H2S04 at each boiler unit exhaust stack. All

perfonnance tests shall be conducted at maximum load conditions, 60% load

conditions and/or other loads specified by EPA.

2. Three test runs shall be conducted for each load condition and compliance for each

operating mode shall be based on the average emission rate ofthese runs.

3. At least 60 days prior to actual testing, PREPA shall submit to the EPA a Quality

Assurance Project Plan detailing methods and procedures to be used during the

perfonnance stack testing. A Quality Assurance Project Plan that does not have EPA

approval may be grounds to invalidate any test and require are-test.

4. PREPA shall use the following test methods, or a test method which would be

applicable at the time ofthe test and detailed in a test protocol approved by EPA:

a. Perfonnance tests to detennine the stack gas velocity, sample area, volumetric flow

rate, molecular composition, excess air offlue gases, and moisture content offlue

gas shall be conducted using 40 CFR Part 60, Appendix A, Methods 1,2, 3, and 4.

b. Perfonnance tests for the emissions ofNOx shall be conducted using 40 CFR Part

60, Appendix A, Method 20.

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c. Perfonnance tests for the emissions ofS02 shall-be conducted using 40 CFR Part

60, Appendix A, Method 8. -~ :d-

,- - ,~ -

d. Perfonnance tests'for the emi"ssions ofH2S04 shall be conducted using 40 CFR Part

60, Appendix A, Method 8. -

e. Perfonnance tests for the emissions ofPM shall be conducted using 40 CFR Part

60, Appendix~, Method S.

f. Perfonnance tests for the emissions ofPM1o shall be conducted using 40 CFR Part

51, Appendix M, Method 201 (exhaust gas recycle) or Method 201A (constant flow

rate), and Method 202. PM10 emissions shall be the sum ofnoncondensible

emissions detennined using Method 201 or 201 A and condensible emissions

detennined using Method 202.

g. Perfonnance tests for the emissions ofPb (lead) shall be conducted using 40 CFR

Part 60, Appendix A, Method 12.

h. Compliance with the cooling tower PMlPM-lO emission limit shall be detennined

by multiplying the maximum cooling water circulation rate with cooling water's

drift rate and total dissolved solids (TDS) concentration. The TDS shall be

monitored once per day.

s. Test results indicating that emissions are below the limits ofdetection shall be deemed

to be in compliance.

6. Additional perfonnance tests may be required at the discretion ofthe EPA or EQB for

any or all ofthe above pollutants.

7. For perfonnance test purposes, sampling ports, platfonns and access shall be provided

by PREPA on each ofthe combustion turbine units in accordance with 40 CFR Part

60.8(e).

8. PREPA shall submit a written report to EPA ofthe results of all emission testing within

60 days ofthe completion ofthe perfonnance test.

9. Operations during periods ofstartup, shutdown, and malfunction shall not constitute

representative conditions for the purpose of a perfonnance test.

XVill. Record keeping Requirements (based on PSD ~etting analyses)

1. Logs shall be kept and updated daily to record the following:

a. the gallons ofNo. 2 fuel oil fired on an hourly basis at each Westinghouse 501

distillate oil fired combustion turbine and the auxiliary generator;

Page 13 of 21
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b. the hours ofoperation of each Westinghouse 501 distilJateoil fired combustion

turbine and the auxiliary generator; '~': ' ~(" t '

c. the sulfur and nitrogen content offuel oil burned in each turbine and the auxiliary

generator; "

d. any adjustments and inaintenance performed on each Westinghouse 501 distillate

oil fired combustion turbine;

e. any adjustments and maintenance performed on monitoring systems;

f. all fuel sampling results; the distillate fuel oil supplier's and PREPA's analyses

verifying that the sulfur content is no greater than 0.050%

g. the gallons offuel oil fired on an hourly basis at each existing boiler unit 7 through

10;

h. t~le hours ofoperation of each existing boiler unit 7 through 10;

1. all calculations and infonnation related to emission determinations

2. All monitoring records, fuel sampling test results, calibration test results and logs must

be maintained for a period offive years after the date ofrecord, and made available

upon request. All rollirig averages shall be computed on an hourly basis.

Page 14 of 21
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PREPA SAN JUAN REPOWERING· PROJECT , ."

. '~ERMIT'cONDITlbNS XIX and XX APPLY

TO BOTH PSD AND PSD-NETTING RELATED CONDITIONS

XIX. Compliance Assurance

Combustion Turbine(s)

1. Capacity Restriction

(max fuel use of 188,201,000 gallons per year, 15,000 hours ofoperation per year and

12,548 gph-24 hr average)

8. Daily compliance with the limit on fuel use shall be detennined by adding the total

amount ofgallons offuel used by both turbines during each calendar day to the total

gallons offuel use by both turbines in the preceding 364 calendar days. This fuel

use shall not exceed 188,201,000 gallons.

b Daily compliance with the limit on number ofhours ofboth combustion turbines

shall be detennined by adding the total amount ofbours operated by both turbines

during each calendar day to the total hours operated by both turbines in the

preceding 364 calendar days. The total number ofhours shall not exceed 15,000..

c. Daily compliance with the maximum firing rate of 12,548 gallons per hour in each

turbine shall be demonstrated by adding the total amount offuel fired by each

turbine every hour Md adding the total amount offuel fired by each turbine during

the previous 23 hours and dividing this number by 24. The minimum firing rate of

8,644 gallons per hour shall be maintained in each turbine to demonstrate

compliance with the requirement to operate the turbines at a minimum of60% load

except during startup and shutdown.

2. Startup/Shutdown

a. The number ofhours taken to startup and shutdown each turbine shall be recorded.

A verifiable load data between zero and 60% shall be correlated with the number of

hours for each startup and shutdown. The total number ofstartups and shutdowns

shall be recorded and complied with on a calender-year basis.

b. Continuous opacity monitoring system shall be operating during each period of

startup and shutdown. Opacity readings shall not exceed 20%.

c. PREPA shall \,;omply with all mass emission limits except CO and NOx during

startup and shutdown as summarized in conditions 3a, 3b, 3c and 3e below.

d. The CO and NOx emissions during startup shall not exce.ed 323 lbslhr and 263

Ibslhr respectjvely, calculated in the following manner: For each startup, PREPA

Page 15 of 21
•

will monitor and record the total CO and:oNOx emissions (lbs) for initial 8 hours.

PREPA shall sum up all CO and NOx emissions in Ibs that occurred during initial 8

hours (including startup hours)Oand divide by 8 to obtain startup emission rate in Ibs

per hour. .

The CO and NOx emissions during shutdown shall not exceed 323 lbs/hr and 263

Ibs/hr respectively, calculated in the following manner: For each shutdown,

PREPA will monitor and record the total CO and NOx emissions (lbs) for 8 hour

period before a complete shutdown. PREPA shall sum up all CO and NOx

emissions in Ibs that occurred during prior 8 hours (including shutdown process

time) and divide by 8 to obtain shutdown emission rate in Ibs per hour.

CO and NOx emissions in pounds per hour shall be calculated as described below

(Emission Limits in lbs/hr- condition 3 a and b).

3. Emission Limits in IbslMMBtu and ppm

a. Nitrogen Oxides- PREPA v/:l1 continuously measure and record stack gas NOx

concentrations in ppmvd using a CEM. The emission rate in ppmvd shall be

measured and recorded every hour 'as an eight-hour rolling average. Monitored

oxygen concentrations (vol % dry) will be used to convert NOx concentrations to

emission rates (lbsIMMBtu) pursuant to equation 19.1 in EPA Method 19 (40 CFR

Part 60 Appendix A). NOx emission rates in IbslMMBtu will be calculated and

re::orded every hour as an eight-hour rolling average (lbsIMMBtu) and every day as

a 365-day rolling average (tons/yr). Emission for both turbines will be summed.

PREPA will comply with this condition in addition to the requirement to conduct a

perfonnance test.

Startup/Shutdown: The emission rate in Ibs/hr will be detennined and recorded for

a 8-hour period for each startup and shutdown by multiplying the emission rate in

IbslMMBtu times the fuel flow (lbs/hr) times the fuel's typical heating value 18,536

Btu/lb. NOx emission rates will be calculated and recorded for each startup and

shutdown as an eight-hour average in lbs/hr.

PREPA shall use a computerized data logger to record all emissions and emission

rates.

b. CO-oPREPA will measure and record ppmvd by the CEMs continuously and

detennine emission in IbslMMBtu every hour. PREPA shall demonstrate

compliance with the CO mass emission limit in IbslMMBtu by using data from the

CEMs, fuel flow and equation 19.1 (with appropriate molecular weight

modification) in 40 CFR Pait 60 Appendix A Method 19. PREPA will comply with

this condition in addition to the requirement to conduct a perfonnance test. CO

emissions will be calculated and recorded every hour as a three-hour rolling average

(lbs/hr). PREPA will comply with this condition in addition to the requirement to

conduct a perfonnance test.

Page 16 of 21
•

•

Startup/Shutdown: The emission rate in lbs/hr will be detennined and recorded for

a 8-bour period for each startup and shutdown by multiplying the emission rate in

IbslMMBtu times the fuel flow (Ibs/hr) times the fuel's typical heating value 18,536

Btu/lb. CO emission rates will be calculated and recorded for each startup and

shutdown as an eight-hour average in lbslhr. I

PREPA shall use a computerized data logger to record all emissions and emission

rates.

c. PM-IO- Initial stack test is required within 180 days ofthe startup ofthis plant.

PREPA shall conduct subsequent stac~ tests every 30-months. PREPA shall

conduct weekly opacity observations at each emission point in accordance with 40

CFR Part 60, Method 9. The opacity observatic;ns shall be made at the point of

greatest opacity in that portion ofthe plume where condensed water vapor is not

present. Opacity as measured by Method 9 and by an Continuous Opacity Monitor

shall not exceed 20%. All possible corrective actions shall be taken as soon as

visible emissions are observed from the v\rbine stacks. PREPA shall maintain

records of all corrective actions and the duration ofvisible emissions to verify

compliance with PM-l 0 emissions.

d. Sulfur Dioxide- PREPA shall calculate by 40 CFR Part 60, Method 19 the hourly

sulfur dioxide emissions based on the average fuel sulfur content ofthe previous

week, the hourly fuel flow and assuming that all sulfur gets converted to sulfur

dioxide. This hourly emissions shall be added to previous two hours' emissions and

divided by three. This 3-hour average shall not exceed 89.9 Ibs/hour. PREPA shall

·use a computerized data logger to record all emissions and emission rates.

e. VOC- Initial stack test is required within 180 days ofthe startup ofthis plant.

PREPA shall conduct subsequent stack tests every 30-months.

Boilers (Units 7 through 10)

1. Maximum fuel use restriction

The maximum total fuel use in these four boiler units shall be limited to 173.1 million

gallons per year. Daily compliance with the annual maximum fuel usage shall be

detennined by adding the total amount ofgallons offuel used by four boiler units

during each calendar day to the total gallons offuel use by those boiler units in the

preceding 364 calendar days.

2. Emission limit in IbslMMBtu and tons/year

Nitrogen Oxides- PREPA will continuously measure and record stack gas NOx

concentrations in ppmvd using a CEM. Monitored oxygen concentrations (vol % dry)

will be used to convert NOx concentrations to emission rates (lbsIMMBtu) pursuant to

Page 17 of 21
•

equation 19.1 in E~A Method 19 (40.CFR Part 60 Appendix A). NOx emission rates

will be calculated~and recorded ev~ryhour as an eight.;.hour rolling average (lbs/hr) and

every day as a 36S-day rolling average (tons/yr). Emission" for all four units will be

summed. PREPA will comply with this condition in addition to the requirement to

conduct a perfonnance test.

PREPA shall use a computerized data logger to record all emissions and emission rates.

3. Sulfur content of no. 6 fuel oil

For Boiler Units 7 through 10- PREPA shall sample no. 6 'fuel oil upon delivery and

analyze for the sulfur content.

4. PMlPM-lO

In addition to initial stack tests, PREPA shall conduct subsequent stack tests every 60-

months. PREPA shall conduct weekly opacity observations at each emission point in

accordance wiLh 40 CFR Part 60, Method 9. The opacity observations shall be made at

the point ofgreatest opacity in that portion ofthe plume where condensed water vapor

is not present. Opacity as measured by Method 9 and .by an Co,ntinuous Opacity

Monitor shall not exceed 20%. All possible corrective actions shall be taken as soon as

visible emissions are observed from the turbine stacks. PREPA shall maintain records

of all corrective actions and the duration ofvisible emissions to verify compliance with

PM-tO emissions.

Certification-Combustion Turbines and Units 7 through 10

A responsible PREPA official as defined under the title V ofthe Clean Air Act shall submit

a yearly compliance certification to EPA and EQB as follows:

ttl certify under penalty oflaw that I have personally examined and am familiar with the

infonnation contained in or accompanying this compliance certification submission; I

certify that, based on my inquiry ofthose individuals immediately responsible for obtaining

the infonnation, the infonnation is true, accurate and complete."

xx. Reporting Reauirements

Each Combustion Turbine

1. PREPA shall submit a written report ofall excess emissions to EPA for every calendar

quarter. All quarterly reports shall be postmarked by the 30th day following the end of

each quarter and shall include the infonnation specified·b~low:

a. The magnitude of excess emissions computed in accordance with 40 CFR Part

60. 13(h), any conversion factor(s) used, and the date and time of commencement

and completion of each time period of excess emissions.

Page 18 of 21
•

•

b. Specific identification of each period ofexcess emissions that occurs during

startups, shutdowns, and malfunctions for each turbine unit. The nature and cause

of any malfunction (ifknown) and the corrective action taken or preventive

measures adopted shall also be reported. For CO andNOx emission rates during

the startup/shutdowns, report all emissions in IbslMMBtu for each startup and

shutdown ca]culated·during that quarter. 1

c. The date ~d time identifying each period during which the continuous monitoring

system was inoperative except for zero and span checks and the nature ofthe system

repairs or adjustments.

d. When no excess emissions have occurred or the monitoring sys~ms have not been

inoperative, repaired, or adjusted, such infonnation shall be stated in the report.

e. Results ofquarterly monitor perfonnance audits, as required in 40 CFR Part 60,

Appendix F (including the Data Assessment Report) and all reporting requirements

in 40 CFR 60.7 including the submission ~f excess emissions and CEMs downtime

summary sheets

f. For the purposes ofthis PSD Pennit, excess emissions indicated by monitoring

systems shall be considered violations ofthe applicable emission limits.

g. Any failure of air pollution control equipment, process equipment, or of a process to

operate in a nonnal manner which results in an increase in emissions above any

allowable emission limit stated in Pennit Condition vn and xm ofthis pennit and

actions taken on any unit must be reported by telephone within 24 hours to:

Chief, Air Pennit Division

Puerto Rico Environmental Quality Board

P.O. Box 11488, Santurce, Puerto Rico 00910

(787) 767-8071

h In addition, the U. S. EPA's Caribbean Environmental Protection Division and

Puerto Rico Environmental Quality Board (EQB) shall be notified in writing within

fifteen (15) days ofany such failure. This notification shall include: a description

ofthe malfunctioning equipment or abnonnal operation; the date ofthe initial

failure; the period oftime over which emissions were increased due to the failure;

the cause ofthe failure; the estimated resultant emissions in excess ofthose allowed

under Condition vn and:xm ofthis pennit; and the methods utilized to restore

Donnal operations. Compliance with this malfunction notification provision shall

not excuse or otherwis: constitute a defense to any violations ofthis permit or of

any law or regulations which such malfunction may cause.

2. For the purpose ofreporting required pursuant to 40 CFR Section 60.7 (New Source

Perfonnance Standards), periods ofexcess emissions that shall be reported include:

Page 19 of 21
•

Nitrogen Oxides- Anyone-hour period during which the average steam-to-fuel, as

measured by continuous monitoring system, falls below the steam-to-fuel ratio

detennined to demonstrate compliance with 40 CFRSection 60.332 by the

perfonnance test required in 40 CFR Section 60.8. Each report shall include the

average fuel consumption, ambient conditions, gas turbine load, the periods of

excess emissions,and graphs or figures developed under 40 CFR Section

60.335(a).

3. Any period during which fuel sulfur content exceeds 0.050 % and fuel nitrogen content

exceeds 0.10% shall be reported immediately to the EQB.

Each Boiler Unit 7 through 10

1. PREPA shall submit a written report of all excess emissions to EPA· for every calendar

quarter. All quarterly reports shall be postmarked by the 30th day following the end of

each quarter and shall include the infonnation specified below:

a. The magnitude of excess emissions computed in accordance with 40 CFR Part

60.13(h), any conversion factor(s) used, and the date and time of commencement

and completion of each time period of excess emissions.

b. The date and time identifying each period during which the continuous monitoring

system was inoperative except for zero and span checks and the nature ofthe system

repairs or adjustments.

c. In addition to the reporting pursuant to XXI-2, all reports related to boiler units 7

through 10 shall be submitted to:

Chief: Air Pennit Division

Puerto Rico Environmental Quality Board

P.O. Box 11488, Santurce, Puerto Rico 00910

XXI. Other Requirements

1. PREPA shall meet all other applicable federal, state and local requirements, including

but not limited to those contained in the Puerto Rico State Implementation Plan·(SIP),

the General Provisions ofthe New Source Perfonnance Standards (NSPS) (40 CFR Part

60, Subpart A), and the NSPS for Stationary Gas Turbines (40 CFR, Part 60, Subpart

00).

2. All reports and Quality Assurance Project Plans required by this pennit shall be

submitted to:

Page 20 of 21
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Director, Caribbean Environmental Protection Division

U.S. Environmental Protection Agency"

Centro Europa Building, Suite 417

Ponce de Leon Avenue

San Juan, Puerto Rico 00907

3. Copies ofall reports ~d Quality Assurance Project Plans shall also be submi~ed to:

a. Region nCEM Coordinator b.

U. S. Environmental Protection Agency

Air and Water Q/A Team

Monitoring & Assessment Branch

2890 Woodbridge Avenue· MS - 220

Edison, New Jersey 08837-3679

Page 21 of 21

Director, Air Pennits Division

Puerto Rico Environmental

Quality Board

P.O. Box 11488

San Juan, Puerto Rico 00910