January 26, 2010 

Suzanne Stevens 

Senior EHS Specialist 

Colorado-Golden Energy Corp. 

25 10th Street, P.O. Box 4088 

Golden, CO 80401 

Subject: Questions/Review for Colorado Energy Nations “NOx Technical Feasibility and Emission 

Control Costs Colorado Energy Nations Golden, Colorado” Submittal (November 16, 2009) 

Please review the following questions discussed in the Division/Colorado-Golden Energy Corp. 

Conference Call on January 26, 2010. 

1. CEN will be required to install LNB w/ OFA for BART. Can you provide support that 

ULNBs will not result in further NOx reductions for documentation purposes? 

2. CEN explained thoroughly the basis for using the current coal supply. For a complete review 

of fuel-switching, CEN needs to also examine fuels besides coal. These types of fuels 

include natural gas, biomass, etc. Please provide a qualitative discussion of the feasibility of 

using these fuels and whether these types of fuels will result in NOx benefits. The Division 

conducted a cursory review of the most recent Operation Permit (96OPJE143) for Boilers 4 

& 5 to determine if fuel-switching would have beneficial NOx reductions from fuel 

switching to wood/biomass. Other facilities of similar size in Colorado have reviewed using 

other fuels, such as wood, fuel oil, biomass (e.g. biodiesel or other renewable fuels), and 

natural gas. There is currently a paucity of information regarding emission factors for 

biodiesel and other biomass fuels from the Division’s broad literature review. However, 

there is available emission factors regarding wood fuels under EPA’s AP-42 emission factor 

database at: 

http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s06.pdf

An example operating permit to review for wood-fired emission limits is Black Hills W.N. 

Clark Power Plant (95OPFR076) at: 

http://www.cdphe.state.co.us/ap/downop/fr076p06.pdf

 
The Division will use literature review and similar facility data to determine the plausibility 

of using other fuels for these two boilers. A qualitative explanation regarding the feasibility 

of using natural gas, fuel oil, ethanol, sludge and/or wood as the primary fuel for Boilers 4 

and 5 will aid in the Division’s documentation in the four-factor analysis for Colorado 

Energy Nation’s Golden facility. 

3. CEN needs to conduct a brief review of the other three factors: non-air and energy impacts, 

time necessary for compliance, and useful life. 

i. Currently, the analysis mentions urea and electricity use, but only from cost 

perspective. The Division has conducted a literature review of non-air and 

energy impacts from SCR and SNCR and compiled an overall summary 

(Attachment 1). Please add any relevant information for your facility to this 

summary (see Note to Facilities at end). 

ii. Used remaining useful life from EPA Cost Control Manual – 20 years. 

iii. Time necessary quoted by other sources – 2015 for SNCR (2-3 years) and 

2016 (3-4 years) for SCR (from EPA SIP approval) – does this seem 

reasonable? 

NOTE: Documentation that is provided by the source allows the Division to account for sourcespecific data and unique factors. Otherwise, the Division will be forced to rely on similar facility 

information and a broad literature review. 

Please contact Kirsten King, Roland Hea, Curt Taipale, or Lisa Clarke with any further questions or 

comments. Any additional information that Colorado Energy Nations can provide as soon as 

possible as facilitate the Division’s analysis. 

Sincerely, 

Lisa Clarke 

Air Pollution Control Division - Policy & Planning Program 

Colorado Department of Public Health and Environment 

(303) 692-3117 

Lisa.Clarke@state.co.us