SUSANA MARTINEZ

GOVERNOR

JOHN A. SANCHEZ

LIEUTENANT GOVERNOR

New Mexico

ENVIRONMENT DEPARTMENT

Air Quality Bureau

525 Camino de los Marquez Suite 1

Santa Fe, NM 87505-1816

Phone (505) 476-4300

Fax (505) 476-4375

www.nmenv.state.nm.us

RYAN FLYNN

CABINET SECRETARY-Designate

BUTCH TONGATE

DEPUTY SECRETARY

Template version: 7/1/13

NEW SOURCE REVIEW PERMIT

Issued under 20.2.72 NMAC

Certified Mail No: 7013 0600 0001 7154 3402

Return Receipt Requested

NSR Permit No: 0063-M8R3 

Facility Name: San Juan Generating Station

Facility Owners: Unit 1: Public Service Company of New Mexico; Tucson Electric Power

Unit 2: Public Service Company of New Mexico; Tucson Electric Power

Unit 3: Public Service Company of New Mexico; Southern California Public 

Power Authority; Tri-State Generation and Transmission Association, Inc.

Unit 4: Public Service Company of New Mexico; Utah Associated Municipal 

Power Systems; City of Farmington, New Mexico; M-S-R Public Power 

Authority; City of Anaheim, California; Los Alamos County, New Mexico

Operator/Permittee Name: Public Service Company of New Mexico (PNM)

Mailing Address: Alvarado Square, Albuquerque, NM 87158

TEMPO/IDEA ID No: 1421–PRN20130004

AIRS No: 35-045-00902

Permitting Action: NSR Technical Revision

Source Classification: Major-TV and Major-PSD 

Facility Location: 36°48’2” N and -108°26’19” W

County: San Juan

Air Quality Bureau Contact: Joseph Kimbrell

Main AQB Phone No. (505) 476-4300

November 1, 2013

Richard L. Goodyear, PE Date

Bureau Chief

Air Quality Bureau
NSR Permit No. 0063M8R3 Page 2 of 62

TABLE OF CONTENTS

Part A FACILITY SPECIFIC REQUIREMENTS .................................................................... 3

A100 Introduction................................................................................................................. 3

A101 Permit Duration (expiration)....................................................................................... 3

A102 Facility: Description.................................................................................................... 3

A103 Facility: Applicable Regulations................................................................................. 6

A104 Facility: Regulated Sources ...................................................................................... 10

A105 Facility: Control Equipment ..................................................................................... 13

A106 Facility: Allowable Emissions.................................................................................. 13

A107 Facility: Allowable Startup, Shutdown, & Maintenance (SSM) .............................. 21

A108 Facility: Allowable Operations................................................................................. 21

A109 Facility: Reporting Schedules................................................................................... 22

A110 Facility: Fuel Sulfur Requirements – not required ................................................... 22

A111 Facility: 20.2.61 NMAC Opacity – not required ...................................................... 22

A112 Construction Options................................................................................................ 22

A113 Compliance Plan – Not Required ............................................................................. 29

A114 Reducing Facility Emissions..................................................................................... 29

EQUIPMENT SPECIFIC REQUIREMENTS ............................................................................. 30

Oil and Gas Industry ..................................................................................................................... 30

A200 Oil and Gas Industry – not required.......................................................................... 30

Construction Industry.................................................................................................................... 30

A300 Construction Industry - not required......................................................................... 30

Power Generation Industry ........................................................................................................... 30

A400 Power Generation Industry ....................................................................................... 30

A401 Turbines - Not Required ........................................................................................... 31

A402 Boilers....................................................................................................................... 31

A403 Engines...................................................................................................................... 39

A404 Heaters - Not Required ............................................................................................. 39

A405 Cooling Towers......................................................................................................... 39

A406 Haul Roads/Storage piles (Coal-Fired Plants).......................................................... 40

A407 Storage Silos (activated carbon, fly ash)................................................................... 42

Part B GENERAL CONDITIONS .......................................................................................... 43

B100 Introduction............................................................................................................... 43

B101 Legal ......................................................................................................................... 43

B102 Authority................................................................................................................... 44

B103 Annual Fee ................................................................................................................ 44

B104 Appeal Procedures.................................................................................................... 45

B105 Submittal of Reports and Certifications.................................................................... 45

B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations ................... 45

B107 Startup, Shutdown, and Maintenance Operations..................................................... 46

B108 General Monitoring Requirements ........................................................................... 46

B109 General Recordkeeping Requirements ..................................................................... 48

B110 General Reporting Requirements.............................................................................. 49
NSR Permit No. 0063M8R3 Page 3 of 62

B111 General Testing Requirements.................................................................................. 50

B112 Compliance ............................................................................................................... 53

B113 Permit Cancellation and Revocation......................................................................... 53

B114 Notification to Subsequent Owners.......................................................................... 54

B115 Asbestos Demolition................................................................................................. 54

B116 Short Term Engine Replacement.............................................................................. 54

Part C MISCELLANEOUS ..................................................................................................... 58

C100 Supporting On-Line Documents............................................................................... 58

C101 Definitions................................................................................................................. 58

C102 Acronyms.................................................................................................................. 60

PART A FACILITY SPECIFIC REQUIREMENTS

A100 Introduction

A. This permit NSR 0063-M8R3 supersedes all portions of Air Quality Permit 0063-

M8R2, issued June 12, 2013, except the portion requiring compliance tests. 

Compliance test conditions from previous permits, if not completed, are still in 

effect, in addition to compliance test requirements contained in this permit.

A101 Permit Duration (expiration)

A. The term of this permit is permanent unless withdrawn or cancelled by the 

Department.

A102 Facility: Description

A. This facility consists of four coal-fired electric generating units and associated 

support facilities. Each coal-fired unit burns pulverized coal and No. 2 Diesel oil in 

a boiler and produces high-pressure steam which powers a steam turbine coupled 

with an electrical generator. Electrical power produced by the units is supplied to 

the electric power grid for sale. Coal for the units is supplied by the adjacent San 

Juan Mine and is delivered to the facility by conveyor. For the purposes of this 

permit, the four generating units at San Juan Generating Station (SJGS) are 

designated Unit 1, Unit 2, Unit 3, and Unit 4.

B. This facility is located approximately 3 miles north-northeast of Waterflow, New 

Mexico in San Juan County. 

C. This revision consists of implementing the Revised New Mexico Regional Haze 

State Implementation Plan (RH SIP) adopted September 5, 2013 by the New 

Mexico Environmental Improvement Board (EIB), which is based on a tentative 
NSR Permit No. 0063M8R3 Page 4 of 62

Agreement between the State of New Mexico, Public Service Company of New 

Mexico (PNM), and the Environmental Protection Agency (EPA). The revision 

consists of adding a scenario (Scenario C) to the two existing scenarios in the SJGS 

NSR permit to incorporate the terms of this agreement. These terms include the 

addition (by January 31, 2016) of SNCR control technology to reduce nitrogen 

oxides (NOx) emissions from Units 1 and 4 to no greater than 0.23 lb/MMBtu; a 

testing program to determine if additional NOx emission reductions can be 

achieved; and the retirement of Units 2 and 3 by December 31, 2017. In addition, 

the sulfur dioxide (SO2) emission limit for Units 1 and 4 will be reduced from the 

current 0.15 lb/MMBtu emission limit to 0.10 lb/MMBtu. The SO2 emission limit 

reduction will occur no later than six months from the date the EIB adopted the 

Regional Haze SIP. With the exception of the reduction in the permitted SO2 limit 

to 0.10 lb/MMBtu, the provisions under Scenario C shall only become effective 

upon final approval of the RH SIP by the EPA. The description of this modification

is for informational purposes only and is not enforceable.

Specific Permit Conditions Modified by this Revision:

Condition 

Number

Pollutant Limit Condition implementation date begins or 

requirement end date

Table 106.A SO2 Scenario C – 0.10 lb/MMBtu Effective date of March 5, 2014

Table 106.C See Table 106.C See Table 106.C Scenario A/B - Ends no later than 9/20/16

Table 106.J See Table 106.J See Table 106.J Scenario A/B - Begins no later than 9/20/16

Table 106.A Unit 1 and 4 NOx 0.23 lb/MMBtu 01/31/16*

A112.C NA Retirement of Units 2 and 3 12/31/17

A112. C Ammonia Slip TBD 4/30/16*

* Date will be revised if the date extends past 01/31/16 due to a delay in EPA’s SIP approval.

D. Table 102.A and Table 102.B show the total potential emissions from this facility

for information only, not an enforceable condition, excluding exempt sources or 

activities. 

Table 102.A: Total Potential Pollutant Emissions from Entire Facility 

Pollutant Emissions (tons per year)

Nitrogen Oxides (NOx) (Pre-construction) 24,703.0

Nitrogen Oxides (NOx) (Scenario A, SCR) 4118.0

Nitrogen Oxides (NOx) (Scenario B, SNCR) Units 1-4 18,941.0

Nitrogen Oxides (NOx) (Scenario C, SNCR) Units 1 and 4 9,425.0

Carbon Monoxide (CO) 35,497.0

Carbon Monoxide (CO) (Scenario C) Units 1 and 4 21,900

Volatile Organic Compounds (VOC) 248.0

Volatile Organic Compounds (VOC) (Scenario C) Units 1 and 4 123.1

Sulfur Dioxide (SO2) 12,352.0

Sulfur Dioxide (SO2) (Scenario C) Units 1 and 4 4,097
NSR Permit No. 0063M8R3 Page 5 of 62

Pollutant Emissions (tons per year)

Total Suspended Particulates (TSP) Total 3381.0

Total Suspended Particulates (TSP) Total (Scenario C) Units 1 

and 4 Filterable Only

1,683.0

Particulate Matter less than 10 microns (PM10) Filterable 1,550.0

Particulate Matter less than 10 microns (PM10) Filterable 

(Scenario C) Units 1 and 4

1,383.0

Particulate Matter less than 2.5 microns (PM2.5) Total 2836.0

Particulate Matter less than 2.5 microns (PM2.5) Total (Scenario 

C) Units 1 and 4

2,810.0

Table 102.B: Total Potential HAPS that exceed 1.0 ton per year 

Pollutant Emissions (tons per year)

Ammonia (Scenario A, SCR) (NM-TAP) 105.9

Ammonia (Scenario B, SNCR) (NM-TAP) Units 1-4 525.0

Ammonia (Scenario C, SNCR) (NM-TAP) (Scenario C) Units 1 

and 4 ***275.0

Hydrochloric acid (HCl) 21.3

Hydrofluoric Acid; (Hydrogen fluoride) 44.7

Sulfuric Acid (H2SO4) (Scenario A, SCR Only) (HAP&TAP) 21.6

Total HAPs (Scenario A, SCR Only) 88.2

Total HAPs(Scenario B, SNCR) Units 1-4 66.8

Total HAPs(Scenario C, SNCR) Units 1 and 4 ***40.0

Total HAPs**(Pre-construction) 74.6

* HAP emissions are already included in the VOC emission total.

** The total HAP emissions may not agree with the sum of individual HAPs because only individual HAPs greater 

than 1.0 tons per year are listed here.

*** Ammonia slip and resulting potential emissions will be determined based on the SNCR performance testing 

described in Condition A112(C)(6).
NSR Permit No. 0063M8R3 Page 6 of 62

A103 Facility: Applicable Regulations

A. The permittee shall comply with all applicable sections of the requirements listed in 

Table 103.A. 

Table 103.A: Applicable Requirements

Applicable Requirements Federally

Enforceable

Unit

No.

20.2.1 NMAC General Provisions X Entire Facility

20.2.3 NMAC Ambient Air Quality Standards X Entire Facility

20.2.7 NMAC Excess Emissions X Entire Facility

20.2.14 NMAC Coal Burning Equipment –

Particulate Emissions X E301, E302, E303, E304

20.2.31 NMAC Coal Burning Equipment – Sulfur 

Dioxide X E301, E302, E303, E304

20.2.32 NMAC Coal Burning Equipment – Nitrogen 

Dioxide X E301, E302, E303, E304

20.2.61 NMAC Smoke and Visible Emissions X E602, E603, E604, E605, 

E606

20.2.70 NMAC Operating Permits X Entire Facility

20.2.71 NMAC Operating Permit Emission Fees X Entire Facility

20.2.72 NMAC Construction Permit X Entire Facility

20.2.73 NMAC Notice of Intent and Emissions 

Inventory Requirements X Entire Facility

20.2.74 NMAC Permits – Prevention of Significant 

Deterioration (PSD) X Entire Facility

20.2.77 NMAC New Source Performance X E301, E302, E303, E304, 

E803, E804, E805

20.2.300 NMAC, Reporting of Greenhouse Gas 

Emissions – Effective Jan 1, 2011 X E301, E302, E303, E304

40 CFR 50 National Ambient Air Quality Standards X Entire Facility

40 CFR 60, Subpart A, General Provisions X E301, E303, E304, E803, 

E804, E805

40 CFR 60 Subpart D – Standards of Performance 

for Fossil-Fuel-Fired Steam Generators X E301, E303, E304

40 CFR 60 Subpart OOO – Standards of 

Performance for Nonmetallic Mineral Processing 

Plants

X E803, E804, S805

40 CFR 63, Subpart A, General Provisions X E301, E302, E303, E304

40 CFR 63, Subpart UUUUU, Mercury and Air 

Toxics Rule (effective date April 16 ,2015) X E301, E302, E303, E304

40 CFR 64 Compliance Assurance Monitoring X E301, E302, E303, E304

40 CFR 68 Chemical Accident Prevention X Entire Facility

40 CFR 72 Subparts B, D, and I – Acid Rain Permit 

Regulations X E301, E302, E303, E304
NSR Permit No. 0063M8R3 Page 7 of 62

Applicable Requirements Federally

Enforceable

Unit

No.

40 CFR 73 Subparts B, C, and D – Sulfur Dioxide 

Allowance System X E301, E302, E303, E304

40 CFR 75 Subparts A-G - Continuous Emission 

Monitoring X E301, E302, E303, E304

40 CFR 76 Acid Rain Nitrogen Oxides Emission 

Reduction Program X E301, E302, E303, E304

40 CFR 77 Excess Emissions X E301, E302, E303, E304

40 CFR 82 Subpart B – Protection of Stratospheric 

Ozone, Servicing of Motor Vehicles X Entire Facility

March 10, 2005 Consent Decree filed in the United 

States District Court, District of New Mexico X E301, E302, E303, E304

Demister Settlement Agreement X E301, E302, E303, E304

SJGS Federal Implementation Plan (FIP) 

published in 40 CFR 52.1628 (August 22, 2011) X E301, E302, E303, E304

Regional Haze State Implementation Plan (SIP) 

under 40 CFR 51.309 (June 15, 2012) X E301, E302, E303, E304

Revised New Mexico Regional Haze State 

Implementation Plan (RH SIP) adopted 

September 5, 2013.

X E301, E302, E303, E304

B. Table 103.B lists requirements that are not applicable to this facility. This table

only includes those requirements cited in the application as applicable and 

determined by the Department to be not applicable, or the Department determined 

that the requirement does not impose any conditions on a regulated piece of 

equipment.

Table 103.B: Non-Applicable Requirements 

Non-Applicable Requirements (1) (2) Justification For 

Non-Applicability

40 CFR 60 Subpart K – Standards of 

Performance for Storage Vessels for Petroleum 

Liquids

X

See note (2) below

40 CFR 60 Subpart Ka –Standards of 

Performance for Storage Vessels for Petroleum 

Liquids

X

See note (2) below

(1) Not Applicable For This Facility: No existing or planned operation/activity at this facility triggers the 

applicability of these requirements.

(2) No Requirements: Although these regulations may apply, they do not impose any specific requirements on the 

operation of the facility as described in this permit.
NSR Permit No. 0063M8R3 Page 8 of 62

C. Applicable requirements that give rise to emissions limits in this permit.

Table 103.C: Applicable Requirements Giving Rise to Permit Emission Limits

(for information only, not an enforceable condition)

Emission Unit Nos. Applicable 

Requirement Description of Requirement

E301, E303, E304 40 CFR 60.42(a)(1) PM Emission Limit

E301, E303, E304 40 CFR 60.42(a)(2) Opacity Emission Limit

E301, E303, E304 40 CFR 60.43(a)(2) SO2 Emission Limit

E301, E303, E304 40 CFR 60.44(a)(3) NOx Emission Limit

E301, E303, E304 20.2.14.201.A NMAC PM Emission Limit

E301, E303, E304 20.2.14.201.B NMAC PM-2 Emission Limit

E301, E303, E304 20.2.31.109.B NMAC SO2 Emission Limit

E301, E303, E304 20.2.32.109 NMAC NOx Emission Limit

E302 20.2.14.202.A NMAC PM Emission Limit

E302 20.2.14.202.B NMAC PM-2 Emission Limit

E302 20.2.31.110.A NMAC SO2 Control Efficiency Limit

E302 20.2.32.110.C NMAC NOx Emission Limit

E301, E302, E303, E304 20.2.31.109.C NMAC SO2 Emission Limits 

(Plant-Wide)

E301, E302, E303, E304 NSR No. 63-M6 Emission Limits for NOx, SO2, 

PM-10, TSP, CO, and VOC 

E803 40 CFR 60.672(a) PM and Opacity Emission Limits

E804, E805 40 CFR 60.672(b) Opacity Emission Limit

E602, E603, E604, E605, E606 20.2.61.109 NMAC Opacity Emission Limit
NSR Permit No. 0063M8R3 Page 9 of 62

Emission Unit Nos. Applicable 

Requirement Description of Requirement

E101, E102, E103, E104, E201, 

E406, E407, E408, E409, E410, 

E411, E505, E506, E507, E508, 

E509, E510, E701, E702, E703, 

E704, E705, E706, E707, E801, 

E802 

NSR No. 63-M6 Emission Limits for NOx, SO2, 

PM-10, TSP, CO, or VOC

E301, E302, E303, E304 PNM self-imposed SO2 Emission Limits

E301, E302, E303, E304 FIP (Scenario A) NOx, Ammonia, H2SO4 and HAP 

Limits

E301, E302, E303, E304 SIP (Scenario B) NOx and Ammonia Limits

E301and E304 RH SIP (Scenario C) NOx and Ammonia Limits

D. Units E301, E303, and E304 are subject to federal new source performance standards 

(NSPS) found in CFR Title 40, Part 60, Subpart A - General Provisions, and Subpart 

D and shall comply with both the notification requirements in Subpart A and with the 

specific requirements of Subpart D.

E. New Source Performance Standards (NSPS) found in 40 CFR 60, Subpart A -

General Provisions, and Subpart OOO applies to certain pieces of equipment in the 

limestone handling system. Affected units shall comply with both the notification 

requirements in Subpart A and with the specific requirements of Subpart OOO.

F. Units E301, E302, E303, and E304 are subject to the applicable requirements of 

20.2.14, 20.2.31, 20.2.32 NMAC. Table 103.F identifies whether the boiler unit is a 

new or existing unit including its vintage designation.

Table 103.F: Boiler Designation (NMAC) Information

Unit 

Number

Vintage 20.2.14, 20.2.31, and 20.2.32 NMAC

20.2.31.7(H) 20.2.32.7(O)

E301 1 -- New Coal Burning Equipment

E302 -- D Existing Coal Burning Equipment

E303 2 -- New Coal Burning Equipment

E304 3 -- New Coal Burning Equipment
NSR Permit No. 0063M8R3 Page 10 of 62

A104 Facility: Regulated Sources

A. Table 104 lists the emission units authorized for this facility. Emission units 

identified as exempt activities and/or equipment (as defined in 20.2.72.202 NMAC)

not regulated pursuant to the Act are not included.

Table 104: Regulated Sources List

Unit No. 1 Description Manufacture Manufacture 

Date

Model 

No.

Serial 

No. Capacity Control Equipment

S301/E301

Unit 1 Coal 

Boiler

Begin 

Commercial 

Operation 

12/1976

Foster 

Wheeler -- 08-1266 --

3707

MM Btu/hr 4

Fabric Filter

SO2 Scrubber

Scenario A: SCR

Scenario B: SNCR

Scenario C: SNCR

S302/E302

Unit 2 Coal 

Boiler

Begin 

Commercial 

Operation 

11/1973

Foster 

Wheeler -- 08-1266 --

3688

MM Btu/hr 4

Fabric Filter

SO2 Scrubber

Scenario A: SCR

Scenario B: SNCR

S303/E303

Unit 3 Coal 

Boiler

Begin 

Commercial 

Operation 

12/1979

Babcock & 

Wilcox -- RB-544 --

5758

MM Btu/hr 4

Fabric Filter

SO2 Scrubber

Scenario A: SCR

Scenario B: SNCR

S304/E304

Unit 4 Coal

Boiler

Begin 

Commercial 

Operation 

4/1982

Babcock & 

Wilcox -- RB-545 --

5649

MM Btu/hr 4

Fabric Filter

SO2 Scrubber

Scenario A: SCR

Scenario B: SNCR

Scenario C: SNCR

S508/E501 Unit 1 Duct 

Leaks -- -- -- -- -- Good air pollution control practices

S509/E502 Unit 2 Duct 

Leaks

S510/E503 Unit 3 Duct 

Leaks -- -- -- -- --

S511/E504 Unit 4 Duct 

Leaks -- -- -- -- --

S111/E101 Coal Pile A 

Maintenance -- -- -- -- -- TBD

S112/E102 Coal Pile A 

Maintenance -- -- -- -- -- TBD

S113/E103 Coal Pile A 

Maintenance -- -- -- -- -- TBD

S114/E104 Coal Pile A 

Maintenance -- -- -- -- -- TBD
NSR Permit No. 0063M8R3 Page 11 of 62

Unit No. 1 Description Manufacture Manufacture 

Date

Model 

No.

Serial 

No. Capacity Control Equipment

S201/E202

Coal Silo 

Transfer 

Point

-- -- -- -- -- Enclosure

S203/E203

Coal Belt to 

Pulverizers 

transfer 

Point

-- -- -- -- -- Enclosure

S204/E201 Coal 

Pulverizers Multiple Multiple Multiple Multiple 8,200,000 tpy 3 Building Enclosure

S425/E406

Unit 1 

Cooling 

Tower

Marley Note 2 D52 6615-5-

11

170,000 

gpm

Drift 

Eliminators/Design

S426E407

Unit 2 

Cooling 

Tower

Marley Note 2 D52 6615-5-

11

165, 000 

gpm

S427/E408

Unit 3 

Cooling 

Tower

Marley Note 2 Model 2 644-12-

333-75

220, 000 

gpm

S428/E409

Unit 4 

Cooling 

Tower

Marley Note 2 Model 2

6616-

12-113-

80

227,500 

gpm

S429/E410

Aux #1/#2

Cooling 

Tower

Marley 1978 600 

series NA 35,000 gpm

S518/E518

Unit 1 Fly 

Ash Silo 

Vent

W.W. Sly Oct 2008 JM3586 NA 291846 tpy Fabric Filter 

Baghouse

S519/E519

Unit 2 Fly 

Ash Silo 

Vent

W.W. Sly Mar 2009 JM3586 NA 290430 tpy Fabric Filter 

Baghouse

S512/E505

Unit 3 Fly 

Ash Silo 

Vent

W.W. Sly Dec 1979 JM3586 NA 25,400 scfm Fabric Filter 

Baghouse

S513/E506

Unit 4 Fly 

Ash Silo 

Vent

W.W. Sly Apr 1982 JM3586 NA 25,400 scfm Fabric Filter 

Baghouse

S514/E507

Unit 1 Fly 

Ash Silo 

Unloading

-- -- -- -- 291846 tpy Moisture Control 

(Bulk Unloading)

S515/E508

Unit 2 Fly 

Ash Silo 

Unloading

-- -- -- -- 290430 tpy

S516/E509

Unit 3 Fly 

Ash Silo 

Unloading

-- -- -- -- 453424 tpy

S517/E510

Unit 4 Fly 

Ash Silo 

Unloading

-- -- -- -- 453424 tpy
NSR Permit No. 0063M8R3 Page 12 of 62

Unit No. 1 Description Manufacture Manufacture 

Date

Model 

No.

Serial 

No. Capacity Control Equipment

S738/E704

Front End 

Loader 

(Around 

Coal Piles)

-- -- -- -- -- Watering

S753/E707

Front End 

Loader 

(Around 

Gypsum 

Piles)

-- -- -- -- -- Watering

E702, 

E703, 

E704-B, 

and E706

Un-Paved 

Haul Roads -- -- -- -- -- Watering

E701, 

E705, and 

E708

Paved Road 

Emissions -- -- -- -- -- Water Truck Street 

Sweeper

S804/E802

Lime Stone 

Pile 

Maintenance

-- -- -- -- -- TBD

E801

Limestone 

Truck 

Unloading

__ __ __ __ __ None

S806/E803 Limestone 

Silo loading __ __ __ __ __ Baghouse

E804

Limestone 

Hopper to 

Transfer 

Conveyor

__ __ __ __ __ None

E805

Limestone 

Silo to 

Weigh

__ __ __ __ __ None

S901/E901 Activated 

Carbon Silo -- Nov 2008 -- -- 578 scfm Dedicated Baghouse (E901)

S902/E902 Activated 

Carbon Silo -- Mar 2009 -- -- 578 scfm Dedicated Baghouse (E902)

S903/E903 Activated 

Carbon Silo -- Mar 2008 -- -- 578 scfm Dedicated Baghouse (E903)

S904/E904 Activated 

Carbon Silo -- Nov 2007 -- -- 578 scfm Dedicated Baghouse (E904)

E520

Unit 1/2 

Sorbent Silo 

(Scenario A)

TBD TBD

TBD Silo Vent Filer

E521

Unit 3 

Sorbent Silo 

(Scenario A)

TBD TBD

TBD Silo Vent Filer

E522

Unit 4 

Sorbent Silo 

(Scenario A)

TBD TBD

TBD Silo Vent Filer

1 Unit number designations starting with an “S” indicate Source and “E” Designations indicate emissions points
NSR Permit No. 0063M8R3 Page 13 of 62

2 The manufacture date for the boilers (Units E301 – E304), the boiler specific cooling towers (Units 406 – 409), 

and the coal pulverizer (Unit E201) is assumed to be the “begin commercial operations” date for the respective 

boilers.

3 The coal pulverizers have a capacity of 1,600,000 tons per year of coal for each emissions unit E301 and E302. 

The coal pulverizers have a capacity of 2,500,000 tons per year of coal for each emissions unit E303 and E304. 

These capacity values are rounded to the nearest 100,000 tons per year. These values are based on historical 

coal use, scaled up to 100 percent unit utilization (i.e 100 percent load at 8760 hours per year).”

4 The Btu/hr value listed in Table 104 Includes a 6% safety factor added to nominal rated capacity of the boilers 

existing at the time of permit issuance.

A105 Facility: Control Equipment

A. Table 104 lists all the pollution control equipment required for this facility. Each 

emission point is identified by the same number that was assigned to it in the 

permit application. 

A106 Facility: Allowable Emissions

A. The following Section list the emission units and their allowable emission limits. (40 

CFR 50, 40 CFR 60, Subparts A and D, and OOO; 40CFR72 Subparts B, D, and I;

40CFR73 Subparts B, C, and D; 40CFR75 Subparts A-G; 40CFR76; 20.2.72.210.A 

and B.1 NMAC).

Table 106.A: Maximum Allowable Emission Rates for Units E301 (1), E302 (2), E303 (3), 

and E304 (4)

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement

Compliance 

Method

E301 

E302 

E303 

E304

CO

E301 – 3000 lb/hr

E302 – 2000 lb/hr

E303 – 2000 lb/hr

E304 – 2000 lb/hr

Per Compliance Method

20.2.3 NMAC, 40 

CFR 50,

NSR No. 63-M2

Quarterly Testing

E303 CO 4,837 tons/yr Monthly rolling, 12-month 

Total NSR No. 63-M8R2

Quarterly testing

& Process 

Records

E301 

E302 

E303 

E304

NOx

E301 – 1,573.7 lb/hr

E302 – 2,435.3 lb/hr

E303 – 2,444.4 lb/hr

E304 – 2,398.1 lb/hr

24-Hour Average NSR No. 63-M2

20.2.32 NMAC, CEMS

E301 

E302 

E303 

E304

NOx

E301 – 4871 tons/yr

E302 – 4844 tons/yr

E303 – 7564 tons/yr

E304 – 7424 tons/yr

Daily rolling 365-day Total NSR No. 63-M2

20.2.32 NMAC, CEMS

E301 

E303 

E304

NOx 0.70 lb/MMBtu 3-Hour Average, Rolled 

Hourly 40 CFR 60.44(a)(3) CEMS

E302 NOx 0.70 lb/MMBtu 3-Hour Average, Rolled 

Hourly 20.2.32.110.C NMAC CEMS
NSR Permit No. 0063M8R3 Page 14 of 62

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement

Compliance 

Method

E301 

E303 

E304

NOx 0.45 lb/MMBtu 3-Hour Average, Rolled 

Hourly 20.2.32.109 NMAC CEMS

E301 

E302 

E303 

E304

NOx 1, 5

Current-0.30 lb/MMBtu

Scenario A – 0.05 lb/MMBtu

Scenario B – 0.23 lb/MMBtu

30 day rolling average5

30-boiler operating day 

rolling average10

30 day rolling average10

0063-M4

FIP & 0063-M8

CEMS & Process 

Records

E301 

E304 NOx 1, 11

Combined emissions from 

Units 1 and 4 under Scenario 

C – 0.23 lb/MMBtu

30-boiler operating day 

rolling average10

NSR 63M6R3 and 

RH SIP

CEMS & Process 

Records

E301 

E302 

E303 

E304

Opacity8 20% 6-Minute Average

40 CFR 60.42(a)(2); 

for E302-NSR 63M4 

and Consent Decree

COMS

E301 

E302 

E303 

E304

TSP4

(Filterable)

E301 – 174.8 lb/hr

E302 – 173.9 lb/hr

E303 – 271.6 lb/hr

E304 – 266.5 lb/hr

Per Compliance Method NSR No. 63-M2 Quarterly Testing

E301 

E302 

E303 

E304

TSP4

(Filterable)

E301 – 765.8 tons/yr

E302 – 761.9 tons/yr

E303 – 1,189.6 tons/yr

E304 – 1,167.1 tons/yr

Per Compliance Method NSR No. 63-M2 Quarterly Testing

E301 

E302 

E303 

E304

PM4,7

(Filterable)

0.015 lb/MMBtu Per Compliance Method 0063-M4 and Consent 

Decree Quarterly Testing

E301 

E303 

E304

PM4

(Filterable)

0.1 lb/MMBtu Per Compliance Method 40 CFR 60.42(a)(1) Quarterly Testing

E301 

E303 

E304

PM4

(Filterable)

0.05 lb/MMBtu Per Compliance Method 20.2.14.201.A NMAC Quarterly Testing

E302 PM4

(Filterable)

0.05 lb/MMBtu Per Compliance Method 20.2.14.202.A NMAC Quarterly Testing

E301 

E302 

E303 

E304

PM-104

(Filterable)

E301 – 174.8 lb/hr

E302 – 173.9 lb/hr

E303 – 271.6 lb/hr

E304 – 266.5 lb/hr

Per Compliance Method NSR No. 63-M2 Quarterly Testing

E301 

E302 

E303 

E304

PM-104

(Filterable)

E301 – 765.8 tons/yr

E302 – 761.9 tons/yr

E303 – 1,189.6 tons/yr

E304 – 1,167.1 tons/yr

Per Compliance Method NSR No. 63-M2 Quarterly Testing

E301 

E302 

E303 

E304

PM-2.54

(Filterable)

E301 – 55.6 lb/hr

E302 – 55.3 lb/hr

E303 – 86.4 lb/hr

E304 – 84.7 lb/hr

Per Compliance Method 0063-M6 Quarterly Testing

E301 

E302 

E303 

E304

PM-2.54

(Filterable)

E301 – 243.5 tons/yr

E302 – 242.2tons/yr

E303 – 378.4 tons/yr

E304 – 371.0 tons/yr

Per Compliance Method 0063-M6 Quarterly Testing
NSR Permit No. 0063M8R3 Page 15 of 62

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement

Compliance 

Method

E301 

E302 

E303 

E304

PM-2.54

(Total)

0.034 lb/MMBtu Per Compliance Method NSR No. 63-M7 Annual Testing

E301 

E302 

E303 

E304

PM-2.54

(Total)

E301 – 126.0 lb/hr

E302 – 125.4 lb/hr

E303 – 195.8 lb/hr

E304 – 192.1 lb/hr

Per Compliance Method NSR No. 63-M7 Annual Testing

E301 

E302 

E303 

E304

PM-2.54

(Total)

E301 – 552.0 tons/yr

E302 – 549.0 tons/yr

E303 – 858.0 tons/yr

E304 – 841.0 tons/yr

Per Compliance Method NSR No. 63-M7 Annual Testing

E301 

E303 

E304

PM-24

(Filterable)

0.02 lb/MMBtu Per Compliance Method 20.2.14.201.B NMAC Note 2

E302 PM-24

(Filterable)

0.04 lb/MMBtu Per Compliance Method 20.2.14.202.B NMAC Note 2

E301 

E302 

E303 

E304

SO2 90% removal Annual Average 0063-M4 CEMS

E301 

E302 

E303 

E304

SO2

6 0.250 lb/MMBtu 7-day block average 0063-M4

CEMS & 

Process 

Records

E301 

E302 

E303 

E304

SO2

E301 – 2435.0 tpy

E302 – 2423.0 tpy

E303 – 3783.0 tpy

E304 – 3711.0 tpy

Per Compliance Method 20.2.3 NMAC,

40 CFR 50 CEMS

E301 

E302 

E303 

E304

SO2

9 0.15 lb/MMBtu9 30-Day Average,

Rolled Daily

PNM self imposed

limit, NSR 63M6R2

and FIP

CEMS & Process 

Records

E301 

E304 SO2

12

Combined emissions from 

Units 1 and 4, 0.10 

lb/MMBtu12

30-Boiler Operating Day 

Average,

Rolled Daily

NSR 63M6R3 and 

RH SIP

Standard becomes 

effective on March 5, 

2014

CEMS & Process 

Records

E301 

E303 

E304

SO2 1.2 lb/MMBtu 3-Hour Average,

Rolled Hourly 40 CFR 60.43(a)(2) CEMS

E301 

E303 

E304

SO2 1.2 lb/MMBtu 3-Hour Average, Rolled 

Hourly 20.2.31.109.B NMAC CEMS

E302 SO2

Minimum

72% Control

30-Day Average, Rolled 

Daily 20.2.31.110.A NMAC CEMS

E301 

E302 

E303 

E304

VOC

E301 – 11.1 lb/hr

E302 – 11.1 lb/hr

E303 – 17.3 lb/hr

E304 – 17.0 lb/hr

Per Compliance Method NSR No. 63-M2 Note 3
NSR Permit No. 0063M8R3 Page 16 of 62

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement

Compliance 

Method

E301 

E302 

E303 

E304

H2SO4

Scenario A Only – 0.00026 

lb/MMBtu hourly basis FIP - 40 C.F.R. § 52.1628

Annual

Method 8A

E301 

E302 

E303 

E304

Ammonia 

Slip 2 ppm design basis FIP - 40 C.F.R. § 

52.1628 SCR design

E301 

E302 

E303 

E304

Ammonia 

Slip 10 ppm design basis SIP - 40 C.F.R. § 

51.309(g) SNCR design

1 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2

2 PNM shall show compliance with either the PM or PM2 limits as required in 20.2.14 NMAC.

3 Test results that demonstrate compliance with CO emission limits shall also be considered to demonstrate 

compliance with VOC emission limits for the subject emission unit.

4 The TSP emission limits in this permit only include filterable particulate emissions since the test method only 

measures filterable TSP. PM10 and PM2.5 filterable limits will remain. PM2.5 Total limits include both 

filterable and condensibles. 

5 For purposes of calculating the thirty (30) day rolling average, NOx emissions for the first three (3) hours of a 

cold startup after coal is fed to the boiler shall be capped at 0.30 lb/MMBtu. Cold startup is defined as a startup 

when the boiler is at ambient indoor temperature measured at the time fuel is first fed to the boiler.

6 The seven (7) day average emission rate of SO2 at San Juan Units E301, E302, E303, and E304 shall not exceed 

0.250 lb-SO2/MMBtu for each unit, calculated as a block average as measured by SO2 CEMS located 

downstream of the scrubber outlet and any scrubber by-pass return. For purposes of calculating the block 

average, SO2 emissions for the first three (3) hours of a cold startup after coal is fed to the boiler shall be capped 

at 0.250 lb./MMBtu. Cold startup is defined as a startup when the boiler is at ambient indoor temperature 

measured at the time fuel is first fed to the boiler.

7 The PM average emission rate for each of Units E301, E302, E303, and E304 shall not exceed 0.015 lbPM/MMBtu, as measured by EPA Reference Method 5 or 5i stack tests, conducted at least once each calendar 

quarter at times and conditions specified by the Department, and according to test protocols approved by the 

Department, but in all cases under conditions and in a manner no less stringent than described in EPA’s 2009

Clean Air Act National Stack Testing Guidance.

8 The opacity limit for San Juan Units E301, E303, and E304 as required by 40 CFR 60.D and E301, E302, E303, 

and E304 as required by this permit shall be twenty (20) percent, averaged over any six (6) minute period 

except for one six (6) minute average per hour of up to twenty-seven (27) percent opacity. This limit shall apply 

at all times when air pollutants are being discharged into the atmosphere, unless PNM demonstrates that any 

excess opacity reading: (a) was caused by a startup, shutdown, malfunction, or emergency, or (b) occurred when 

both the boiler and all fans that move flue gas in the unit were off. Load changes, poor coal quality, air heater 

cleaning, sootblowing, and high ash hoppers shall not be used as a defense for any excess opacity reading. 

Opacity shall be measured in the duct or, if approved by EPA, after the outlet of the baghouse and corrected to 

stack exit. (CD 9a)

9 Prior to January 31, 2013: Compliance with the 0.15 lb/MMBtu heat input daily rolling, 30-day average SO2

emission limitation for Units 2 and 3 is determined by calculating at the end of each rolling 30 successive boiler 

operating days the arithmetic average of all hourly emission rates for SO2, except for data obtained during 

emergency conditions. Hourly emission rates will only be determined based on valid SO2 CEMs data for any 

hour where fuel is combusted in the unit. No missing hour substitute data will be used in determining 

compliance with the proposed 0.15 lb/MMBtu heat input 30-day rolling average SO2 emission limit. “Boiler 

operating day” means a 24-hour period between 12 midnight and the following midnight (MST) during which 

any fuel is combusted at any time in the steam-generating unit. If Scenario A becomes effective and the SCR is 
NSR Permit No. 0063M8R3 Page 17 of 62

installed, then effective on September 20, 2016: The SO2 emission rate limit for each unit in the plant shall be 

0.15 pounds per million British thermal units (lbs/MMBtu), as averaged over a rolling 30 boiler operating- day 

period. For each unit on each boiler-operating-day, the hourly SO2 emissions measured in lbs/MMBtu, shall be 

averaged over the hours the unit was in operation to obtain a daily boiler-operating-day average. Each day, the 

30-day-rolling average SO2 emission rate for each unit (in lbs/MMBtu) shall be determined by averaging the 

daily boiler-operating-day average emission rate from that day and those from the preceding 29 days. This 

method of calculating SO2 emissions becomes effective on September 20, 2016 if SCR is installed.

10 Under Scenario A: Per FIP at 40CFR52.1628 d(2), The NOx limit for each unit in the plant, expressed as 

nitrogen dioxide (NO2), shall be 0.05 pounds per million British thermal units (lb/MMBtu) as averaged over a 

rolling 30 calendar day period. For each unit, NOx emissions for each calendar day shall be determined by 

summing the hourly emissions measured in pounds of NOx. For each unit, heat input for each calendar day shall 

be determined by adding together all hourly heat inputs, in millions of BTU. Each day the thirty-day rolling 

average for a unit shall be determined by adding together the pounds of NOx from that day and the preceding 29 

days and dividing the total pounds of NOx by the sum of the heat input during the same 30-day period. The 

result shall be the 30 day–rolling average in terms of lb/MMBtu emissions of NOx. If a valid NOx pounds per 

hour or heat input is not available for any hour for a unit, that heat input and NOx pounds per hour shall not be 

used in the calculation of the 30-day rolling average for NOx. This method of calculating NOx emissions 

becomes effective on September 20, 2016 if SCR is installed. Unless SCRs are installed and before the 

September 20, 2016 effective date, footnotes 5 and 9 remain in effect.

11. The daily NOx 30-boiler operating day rolling average for Units 1 and 4 will be determined based on the 

calculation method described in Condition A112 (C)(3). 

12. The daily SO2 30-boiler operating day rolling average for Units 1and 4 will be determined based on the 

calculation method described in Condition A112 (C)(9).

B. Table 106.B contains the maximum allowable emission rates for Units E301, E302, 

E303, and E304 combined. 

Table 106.B, Maximum Allowable Emission Rates for Units E301-E304 Combined 

Pollutant

Maximum 

Allowable 

Emission Rate

Averaging 

Period

Applicable 

Requirement

Compliance 

Method

NOx 1 9,000 lb/hr 24-Hour Average, 

Rolled Hourly

NSR No. 63-M2,

40 CFR Part 50

CEMS

SO2 13,000 lb/hr 3-Hour Average, 

Rolled Hourly 20.2.31.109.C NMAC

CEMS

SO2 0.55 lb/MMBtu 30-Day Average,

Rolled Daily 20.2.31.109.C NMAC

CEMS & Process 

Records

SO2 0.46 lb/MMBtu Annual Average NSR No. 63-M2

CEMS & Process 

Records

1 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2
NSR Permit No. 0063M8R3 Page 18 of 62

C. Table 106.C list the allowable emissions from duct leaks. Compliance shall be 

determined by implementation of a duct leak management program.

Table 106.C, Maximum Allowable Emission Rates for Duct Leaks 

Emission

Unit No.

Maximum Allowable Emission Rates

TSP PM-10 PM-2.5 NOx CO SO2

pph tpy pph tpy pph tpy pph tpy pph tpy pph tpy

E501 11.3 45.0 4.5 18.1 2.1 9.2 0.3 0.8 0.5 2.0 1.1 4.5

E502 12.4 50.0 4.9 20.0 2.1 9.2 0.4 0.8 0.4 1.5 1.2 4.9

E503 12.6 50.4 5.0 20.1 2.0 8.9 -- 0.8 0.2 1.0 1.3 5.0

E504 14.5 58.3 5.8 23.3 2.0 8.9 0.3 1.0 0.3 1.1 1.5 5.8

1 Emission rates for Duct Leaks under Scenarios A or B ends not later September 20, 2016.

D. Table 106.D lists the allowable emission limits for non-boiler emission units. The 

emissions from any individual piece of equipment shall not exceed the limits listed 

in the table. (NSR 63M6R1, Condition 2.e)

Table 106.D, Maximum Allowable Emission Rates for Non-Boiler Emission Units

Emission

Unit No.

Maximum Allowable Emission Rates

in Pounds per Hour (pph) and Tons per Year (tpy)

TSP PM-10

pph tpy pph tpy

E101 1.6 7.0 -- 1.6

E102 1.6 7.0 -- 1.6

E103 1.6 7.0 -- 1.6

E104 1.6 7.0 -- 1.6

E201 7.3 32.0 2.8 12.0

E202 -- 3.1 -- 1.5

E203 -- 3.1 -- 1.5

E406 10.2 44.7 2.4 10.5

E407 9.9 43.4 2.3 10.2

E408 6.4 28.2 2.5 10.9

E409 13.7 59.8 3.2 14.1

E410 1.4 6.0 -- 2.3

E505 2.2 9.5 2.2 9.5

E506 2.2 9.5 2.2 9.5

E507 0.6 2.4 -- 1.1

E508 0.6 2.4 -- 1.1

E509 0.9 3.7 -- 1.8

E510 0.8 3.7 -- 1.7

E518 1.6 7.0 1.6 7.0
NSR Permit No. 0063M8R3 Page 19 of 62

Emission

Unit No.

Maximum Allowable Emission Rates

in Pounds per Hour (pph) and Tons per Year (tpy)

TSP PM-10

pph tpy pph tpy

E519 1.6 7.0 1.6 7.0

Paved Roads 

(E701, E705, E708) 16.4 68.8 3.3 13.8

Unpaved Roads 

(E702, E703, 

E704B, ,E706) 21.7 77.9 6.6 23.8

E801 0.7 3.1 -- 1.5

E802 2.4 10.4 -- 1.6

E803 -- 1.1 -- --

E804 -- -- -- --

E805 -- -- -- --

S901 -- -- -- --

S902 -- -- -- --

S903 -- -- -- --

S904 -- -- -- --

E520 -- -- -- --

E521 -- -- -- --

E522 -- -- -- --

“--“ indicates that the emissions are less than 1.0 pph or 1.0 tpy and emission limits are not required for this permit.

E. Unless otherwise required by this permit or another applicable regulation, 

compliance with the NOx emission limits shall be determined on a unit-specific basis 

using data from NOx CEMS that have been installed, calibrated, and operated in 

accordance with 40 CFR. 75 and any other applicable requirement. 

F. Unless otherwise required by this permit or another applicable regulation, 

compliance with the SO2 emission limits shall be determined on a unit-specific basis 

using data from SO2 CEMS that have been installed, calibrated, and operated in 

accordance with 40 CFR 75 and any other applicable requirement.

G. Each affected facility as defined in 40 CFR 60 Subpart OOO of the limestone 

handling system, including the limestone silo, shall meet the standards for particulate

matter specified in 40 CFR 60.672.

H. In accordance with 20.2.61.109 NMAC, the owner or operator of stationary 

combustion equipment shall not permit, cause, suffer or allow visible emissions from 

the stationary combustion equipment to equal or exceed an opacity of 20 percent; 

provided, however, stationary combustion equipment which is regulated by Parts 

20.2.10 NMAC through 20.2.18 NMAC, 20.2.37 NMAC, and 20.2.42 NMAC, and 

any other Part of Chapter 2 which specifically limits particulate emissions is 
NSR Permit No. 0063M8R3 Page 20 of 62

exempted from this Part. The emergency generators are subject to 20.2.61.109 

NMAC.

I. The activated carbon silo baghouses shall be designed and operated so there are no 

visible emissions.

(1) For mercury control, the operating procedures needed to maximize mercury 

removal per the consent decree requirements are not yet available to explicitly 

incorporate in this permit renewal. Once PNM, NMED and the Plaintiffs agree 

on the maximal mercury removal rate and procedure, then this permit will be reopened or modified to incorporate limits and/or conditions to meet consent 

decree requirements. (CD 9d)

(2) The permittee shall use the mercury (Hg) sorbent traps for two purposes: to 

conduct a Hg study to determine the optimal activated carbon injection rate as 

required by the SJGS Consent Decree, and secondly, to operate the sorbent traps 

as Hg continuous monitoring devices based on the applicable QA/QC 

requirements in Appendix A of 40 CFR 63, Subpart UUUUU (i.e. MATS 

regulation), which references performance specification (PS) 12b. SJGS will use 

the sorbent traps as continuous monitoring devices except when the Hg study 

testing is being conducted.

J. Emission limits totals are used solely for assessing annual fees in accordance with 

20.2.71 NMAC. SJGS has many limits for each pollutant. This table shows the most 

stringent of these limits for each pollutant for which the annual fees will be based. 

Only pollutants for which we can assess fees are shown. (B103A) Emission totals 

from NSR Permit 0063M7 will be used for fees until all units under NSR 0063M8 

have been modified and new pollution controls are operational.

Table 106.J: Emissions (tons per year) total for annual fees use

Unit 1NOx 2CO 3VOC 4SO2

5

PM

E301

Scenario A

Scenario B

4,871

812

3,734

13,140 48.7 2,435 552

244

244

E302

Scenario A

Scenario B

4,844

808

3,715

8,760 48.5 2,423 549

242

242

E303

Scenario A

Scenario B

7,564

1,261

5,801

4,837 75.8 3,783 858

378

378

E304

Scenario A

Scenario B

7,424

1,237

5,691

8,760 74.5 3,711 841

371

371

Misc 6455
NSR Permit No. 0063M8R3 Page 21 of 62

Unit 1NOx 2CO 3VOC 4SO2

5

PM

Scenario A

Scenario B

455

455

Totals*

Scenario A

Scenario B

24,703

4,118

18,941

35,497

No Change

No Change

247.5

No Change

No Change

12,352

No Change

No Change

3,255

3,255

3,255

Scenario C TBD TBD TBD TBD TBD

Used for fees

(based on 63M7)

6,000 6,000 247.5 6,000 3,255

* Amounts are capped at 6,000 tpy per pollutant by regulation (20.2.71.111.C(4) NMAC).

1 Units 1,2,3,4: Tons per year NOx limits obtained by scaling up 0.3 lbs/MMBtu 30-day average (CD 9cii; Table 

106.A). 2 Units 1,2,4: Tons per year CO limits obtained by scaling up lbs/hr limits (Table 106.A). Unit 3 tpy limit from 

Table 106.A.

3 Units 1,2,3,4: VOC totals based on average coal Btu content and revised heat input values (Application dated 

January 2009). 4 Units 1,2,3,4: Tons per year SO2 limits by scaling up 0.15 lb/MMBtu SO2 PNM self imposed limit. 5 Units 1,2,3,4: Tons per year PM limits obtained by scaling up 0.015 lb/MMBtu (CD 9cii; Table 106.A) plus the 

PM-2.5 condensibles of 0.019 lb/MMBtu (NSR 63M7). 6 Represents sum of the non-boiler PM (TSP) is 455 tpy (calculated from Tables 2E, by eliminating the boiler PM).

A107 Facility: Allowable Startup, Shutdown, & Maintenance (SSM) 

A. SJGS Units have multiple NOx limits for different averaging times. Some limits 

are expressed in lb/MMBtu rather than lbs/hr. Units 1, 3 and 4 have a 3-hr average 

limit of 0.45 lb/MMBtu. During SSM this limit may be exceeded for each of these 

units. The maximum NOx emission rate during SSM for these units is 0.7 

lb/MMBtu. The Unit 2 3-hr NOx limit is 0.7 lb/MMBtu and Unit 2 NOx emissions 

are not expected to exceed this rate during SSM. The permittee shall maintain 

records in accordance with Condition B109.E. SJGS shall comply with all other 

emission limits established for steady state operations even during SSM events.

A108 Facility: Allowable Operations

A. This facility is authorized for continuous operation. No monitoring, recordkeeping, 

and reporting are required to demonstrate compliance with continuous hours of 

operation.
NSR Permit No. 0063M8R3 Page 22 of 62

A109 Facility: Reporting Schedules

A. For the Title V Permit: A Semi-Annual Report of monitoring activities is due 

within 45 days following the end of every 6-month reporting period. The six month 

reporting periods start on January 1st and July 1st of each year.

B. For the Title V Permit: The Annual Compliance Certification Report is due within 

30 days of the end of every 12-month reporting period. The 12-month reporting 

period starts on January 1st of each year.

C. The quarterly reportable items required by this permit shall be submitted quarterly.

A110 Facility: Fuel Sulfur Requirements – not required

A111 Facility: 20.2.61 NMAC Opacity – not required

A112 Construction Options

This permit has three distinct permitting scenarios that are mutually exclusive, i.e., if 

one scenario becomes final the other two scenarios become moot. While permitting 

scenarios A, B and C are distinct, this permit includes permit modifications that are 

common to all scenarios. The permitting description given below, therefore, lists the 

permitting elements as “Common”, “Scenario A” only, “Scenario B” only and “Scenario 

C” only.

A. Scenario A is the permitting scenario required to implement the SJGS Federal 

Implementation Plan (FIP) published in 40 CFR 52.1628 (dated August 22, 2011, 

effective September 21, 2011). The provisions of this FIP are under judicial review, 

but the FIP implementation date makes it necessary to proceed with obtaining the 

authority-to-construct air permit immediately to insure construction of the required 

equipment (SCR) can begin in time to meet the FIP operational deadline. 

Permitting changes/updates to Scenario A (FIP) only:

(1) An SCR system on each boiler unit.

(2) An anhydrous ammonia injection system used for supplying ammonia to the 

SCR system consisting of ammonia delivery, storage and injection equipment.

(3) A dry sorbent injection system (DSI) consisting of DSI delivery, storage and 

injection equipment.

(4) Modification of the fly ash handling system through addition of ash hoppers at 

the economizer outlets on each boiler unit and bypass of the existing ESP 

structure.
NSR Permit No. 0063M8R3 Page 23 of 62

(5) Modification of the fan system to achieve “balanced” draft configuration 

allowing for the elimination of emission points E510, E502, E503 and E504.

(6) EPA extended the time for compliance with the emission limits from 3 years to 

5 years, the maximum period allowed by the Clean Air Act. Therefore, SCR 

shall be installed on each of the four units as expeditiously as practicable, but in 

no event later than 5 years from the effective date of our final rule. The Federal 

register date was August 22, 2011, effective on September 20, 2011. Installation 

of all control equipment and compliance with new emission limits shall be not 

later than September 20, 2016.

B. Scenario B is intended to implement the requirements of the State of New Mexico 

Regional Haze State Implementation Plan, (SIP) adopted pursuant to 40 CFR 

51.309, which specifies controls for SJGS that are different than the FIP. If the 

judicial review of the FIP results in vacatur of the FIP requirements, PNM would 

implement the SIP requirements which require installation and operation of an 

SNCR control system, rather than SCR. SNCR is represented in this permit as 

Scenario B. Permitting changes/updates to Scenario B (SIP) only:

(1) A system for delivery, storage and injection of 50 percent urea solution into the 

flue gas of each boiler for NOx control by SNCR.

(2) Modification of the fan system to achieve “balanced” draft configuration 

allowing for the elimination of emission points E510, E502, E503 and E504.

(3) In accordance with 40 CFR 51.308(e)(1)(iv), the Department determined that 

SNCR shall be installed on each of the four units as expeditiously as practicable, 

but in no event later than 5 years after approval by the EPA of the SIP. As of 

July 6, 2012, EPA has not approved the SIP. NMED establishes the deadline 

date to be the same as the FIP of September 20, 2016.

C. Scenario C is intended to implement the terms of the Revised New Mexico 

Regional Haze State Implementation Plan (RH SIP) adopted September 5, 2013 by

the New Mexico Environmental Improvement Board (EIB), which is based on a 

tentative Agreement between the State of New Mexico, PNM, and the 

Environmental Protection Agency (EPA). These terms include the addition (by 

January 31, 2016) of SNCR control technology to reduce nitrogen oxides (NOx) 

emissions from Units 1 and 4 to no greater than 0.23 lb/MMBtu; a testing program 

to determine if additional NOx emission reductions can be achieved; and the 

retirement of Units 2 and 3 by December 31, 2017. In addition, the sulfur dioxide 

(SO2) emission limit for Units 1 and 4 will be reduced from the current 0.15 

lb/MMBtu emission limit to 0.10 lb/MMBtu. The SO2 emission limit reduction 

will occur no later than six months from the date the EIB adopted the RH SIP. The 

revised RH SIP is based on the “Term Sheet Between the U.S. Environmental 

Protection Agency, Public Service Company of New Mexico, and the State of New 

Mexico” dated February 15, 2013, included as attachment G to the RH SIP (and 
NSR Permit No. 0063M8R3 Page 24 of 62

hereafter in this permit referenced as the “Term Sheet”). The following terms are 

taken directly from the Term Sheet and are being incorporated into the Permit as 

part of Scenario C:

(1) The New Mexico Environment Department (NMED) will develop and seek 

adoption by the New Mexico Environmental Improvement Board (NM EIB) of 

a State Implementation Plan (SIP) revision. If the NM EIB approves the SIP 

revision after following all applicable procedural requirements including notice 

and public hearing, the Governor of the State of New Mexcio or her designee 

will submit the SIP revision to EPA for approval with supporting administrative 

and technical information and visibility modeling. The SIP revision will include 

the following elements:

a. Rulemaking addressing a NOx Best Available Retrofit Technology 

(BART) determination and enforceable emissions limits for SO2.

b. A five-factor BART analysis in accordance with the BART 

Guidelines, and other EPA guidance, as applicable, including 

documentation relied upon making the BART determination. The 

use of confidential business information will be minimized to the 

extent practical in making the analysis.

c. New Mexico’s rulemaking will require that fifteen (15) months 

after EPA final approval of the Revised SIP, no earlier than 

January 31, 2016, Public Service Company of New Mexico (PNM) 

will complete installation of selective non-catalytic reduction 

(SNCR) technology on SJGS Unit 1 and 4 and achieve an average 

nitrogen oxide (NOx) emission rate for Units 1 and 4 of no greater 

than 0.23 lb/MMBtu on a daily rolling 30-day average basis. 

Within 30 days after this “Term Sheet” is signed, PNM will submit 

a project schedule to the State and EPA that demonstrates the 

critical milestones for meeting the January 31, 2016, installation 

completion date. The dates that follow with an asterisk (*) in

paragraph d. will be revised accordingly if the installation date 

extends past January 31, 2016 due to delay in EPA’s SIP approval.

d.

i. Testing Program. PNM will commence a program of testing 

and evaluation, after the installation of the SNCRs. The 

Testing Program consisting of SNCR Performance Testing, 

Fuel Performance Testing, and Long-Term Performance 

Evaluation is to be completed no later than January 31, 2017*, 

unless the Long-Term Performance Evaluation is delayed per 

the language in paragraph 1.d.iv.

ii. SNCR Performance Testing will be conducted to develop a 

targeted ammonia/urea injection rate range at various load 
NSR Permit No. 0063M8R3 Page 25 of 62

levels without exceeding a to-be-agreed-upon preliminary slip 

limit of between 5 and 10 ppm, with the goal of minimizing 

NOx emissions. PNM shall provide the results of the 

performance test, recommended final slip limit, and target 

ammonia/urea injection rates to NMED and EPA by April 1,

2016*. PNM will allow up to April 30, 2016* for the agencies 

to either concur with PNM’s slip limit recommendation or to 

concur on a different slip limit that PNM will comply with for

Units 1 and 4.

iii. PNM will conduct Fuel Performance Testing (in conjunction 

with the SNCR Performance Testing) of its pre-treated coal 

technology, so long as it has not been previously determined to 

result in any detrimental effect to SJGS Units 1 and 4 or their 

operation, with the objective of further reducing NOx 

emissions. If the Fuel Performance Testing demonstrates that 

it does not: (i) measurable increase NOx emissions, or (ii) 

adversely impact overall unit operations, PNM shall also use 

such pre-treated coal for the 9-month Long-Term Performance 

Evaluation Period described below. PNM will also use pretreated coal on Units 2 and 3 when used on Units 1 and 4.

iv. Long-Term Performance Evaluation Period. PNM will begin 

collecting NOx emission and ammonia/urea injection rate data 

from Units 1 and 4 on a daily rolling 30-day average basis for 

nine continuous months beginning on May 1, 2016* and 

provide such data and any recommendations on the NOx 

emission limit to NMED and EPA by February 28, 2017* or no 

later than 28 days after completing the Long-Term 

Performance Evaluation Period. PNM may request more time 

if a slip is not agreed upon by April 30, 2016*. The LongTerm Performance Evaluation Period must include 60 days 

between June 1st and August 30th and 60 days between 

December 1st and February 28th. The Demonstrated Emission 

Rate will be the highest daily rolling 30-day average emission

rate during the 9-month Long-Term Performance Evaluation 

Period (not including periods of malfunction or abnormal 

operating conditions) adjusted to three significant digits. If the 

Demonstrated Emission Rate is greater than or equal to 0.200 

lb/MMBtu on a daily rolling 30-day average basis no 

adjustment to the NOx emission rate for Units 1 and 4 will be 

made. If the Demonstrated Emission Rate is less than 0.200 

lb/MMBtu on a daily rolling 30-day average basis PNM will 

apply for a permit modification by March 31, 2017* (or no 

later than 60 days after completing the Long-Term 
NSR Permit No. 0063M8R3 Page 26 of 62

Performance Evaluation Period) to reduce the permitted 

emission rate by 60% of the difference between 0.23 

lb/MMBtu and the Demonstrated Emission Rate, provided the 

revised emission rate does not adversely impact overall unit 

operations. The permit modification will include the agreed 

upon ammonia slip limit. 

e. New Mexico’s rulemaking will require that no later than six 

months from NM EIB adoption of SO2 emission limit in the RH 

and Interstate Visibility Transport SIP revisions, PNM will comply 

with the new sulfur dioxide (“ SO2”) emission rates at Units 1 and 

4 of 0.10 lb/MMBtu on a daily rolling 30-day average basis.

f. New Mexico’s rulemaking will require that PNM diligently seek 

all necessary regulatory approvals to allow for retirement of SJGS 

Units 2 and 3 by December 31, 2017. New Mexico’s rulemaking 

will require PNM to retire SJGS Units 2 and 3 by December 31, 

2017.

2. NMED and EPA intend that the Regional Haze and Interstate Transport SIP 

revisions as adopted and submitted to EPA will, if approved by EPA, lead to 

EPA action withdrawing the federal implementation plan for SJGS. Nothing in 

the Regional Haze and Interstate Transport SIP revisions as adopted and 

submitted to EPA by New Mexico shall relieve SJGS from its obligations to 

comply with all applicable federal, state, and local laws and regulations, 

including laws, regulations, and compliance deadlines that become applicable 

after the date of any revisions to New Mexico’s Regional Haze SIP that may be 

approved by EPA.

3. NMED also will develop and propose as part of the revised BART 

determination for PNM, a revision to the Visibility Interstate Transport SIP for 

NOx and SO2. NMED’s Visibility Interstate Transport SIP revision will require 

enforceable emission limits for NOx and SO2 consistent with the emission limits 

established in the Regional Haze SIP submission in accordance with Item 1.

4. PNM agrees that the natural gas combustion turbine(s) to be sited at the San 

Juan Generating Station to partially replace the retired Unit 2 and Unit 3 coal 

capacity will undergo BACT analysis and control even if not subject to major 

source PSD, with the goal of minimizing the visibility impact of emissions of 

NOx. PNM agrees that the aggregate annual NOx emissions from any such on 

site replacement power shall not exceed 75 tons.

(2) In accordance with the Term Sheet, fifteen (15) months after EPA final 

approval, but no earlier than January 31, 2016, PNM will complete installation 

of SNCR technology on SJGS Units 1 and 4 to achieve an average NOx 

emission rate for Units 1 and 4 of no greater than 0.23 lb/MMBtu on a daily 
NSR Permit No. 0063M8R3 Page 27 of 62

rolling 30-day average. The method to calculate the NOx emission rate of Units 

1 and 4 and demonstrate compliance with the emission limit is provided below:

i. The daily rolling 30-day average NOX emission rate for Units 1 and 4

shall be calculated for each calendar day, even if a unit is not in operation 

on that calendar day, in accordance with the following procedure: 

ii. Step One, for Units 1 and 4, sum the hourly pounds of NOX emitted 

during the current boiler-operating day (or most recent boiler-operating 

day if the unit is not in operation), and the preceding twenty-nine (29) 

boiler-operating days, to calculate the total pounds of NOX emitted over 

the most recent thirty (30) boiler-operating day period for each coal-fired 

unit; 

iii. Step Two, for Units 1 and 4, sum the hourly heat input, in MMBtu, during 

the current boiler-operating day (or most recent boiler-operating day if the 

unit is not in operation), and the preceding twenty-nine (29) boileroperating days, to calculate the total heat input, in MMBtu, over the most 

recent thirty (30) boiler-operating day period for each coal-fired unit; 

iv. Step Three, sum together the total pounds of NOX emitted from Units 1 

and 4 over each unit’s most recent thirty (30) boiler-operating day period 

(the most recent 30 boiler-operating day periods for different units may be 

different); 

v. Step Four, sum together the total heat input from Units 1 and 4 over each 

unit’s most recent thirty (30) boiler-operating day period (the most recent 

30 boiler-operating day periods for different units may be different); and 

vi. Step Five, divide the total pounds of NOX emitted from Step Three by the 

total heat input from Step Four for Units 1 and 4, to calculate the daily 

rolling 30-day average NOX emission rate from Units 1 and 4, in pounds 

of NOX per MMBtu, for each calendar day. Each daily rolling 30-day 

average NOX emission rate shall include all emissions and all heat input 

that occur during all periods within any boiler-operating day, including 

emissions from startup, shutdown, and malfunction.

NOx pounds per hour shall be adjusted using the diluents cap as defined in 

40 CFR Part 72.2 Definitions. All valid CEMS hourly data shall be used to 

determine compliance with the combined Unit 1 and 4 emission limitation 

for NOx. If the CEMs data is not valid, that CEMs data shall be treated as 

missing data and not used to calculate the emission average. CEMs data 

does not need to be bias adjusted as defined in 40 CFR Part 75.

(3) In accordance with the Term Sheet, no later than March 5, 2013 (six months 

from NM EIB adoption of the SO2 emission limit in the Regional Haze and 

Interstate Visibility Transport SIP revisions, which occurred on September 5, 
NSR Permit No. 0063M8R3 Page 28 of 62

2013), PNM will comply with new SO2 emission rates at Units 1 and 4 of 0.10 

lb/MMBtu on a daily rolling 30-day average basis. The method to calculate the 

SO2 emission rate of Units 1 and 4 and demonstrate compliance with the 

emission limit is provided below:

i. The daily rolling 30-day average SO2 emission rate for Units 1 and 4 shall

be calculated for each calendar day, even if a unit is not in operation on that 

calendar day, in accordance with the following procedure:

ii. Step One, for Units 1 and 4, sum the hourly pounds of SO2 emitted during 

the current boiler-operating day (or most recent boiler-operating day if the 

unit is not in operation), and the preceding twenty-nine (29) boiler-operating 

days, to calculate the total pounds of SO2 emitted over the most recent thirty 

(30) boiler-operating day period for each coal-fired unit; 

iii. Step Two, for Units 1 and 4, sum the hourly heat input, in MMBtu, during 

the current boiler-operating day (or most recent boiler-operating day if the 

unit is not in operation), and the preceding twenty-nine (29) boiler-operating 

days, to calculate the total heat input, in MMBtu, over the most recent thirty 

(30) boiler-operating day period for each coal-fired unit;

iv. Step Three, sum together the total pounds of SO2 emitted from Units 1 and 

4 over each unit’s most recent thirty (30) boiler-operating day period (the 

most recent 30 boiler-operating day periods for different units may be 

different); 

v. Step Four, sum together the total heat input from Units 1 and 4 over each 

unit’s most recent thirty (30) boiler-operating day period (the most recent 30 

boiler-operating day periods for different units may be different); and 

vi. Step Five, divide the total pounds of SO2 emitted from Step Three by the 

total heat input from Step Four from Units 1 and 4, to calculate the daily 

rolling 30-day average SO2 emission rate for Units 1 and 4, in pounds of 

SO2 per MMBtu, for each calendar day. Each daily rolling 30-day average 

SO2 emission rate shall include all emissions and all heat input that occur 

during all periods within any boiler-operating day, including emissions from 

startup, shutdown, and malfunction.

All valid CEMS hourly data shall be used to determine compliance with the 

Unit 1 and 4 emission limitation on for SO2. If the CEMs data is not valid, 

that CEMs data shall be treated as missing data and not used to calculate the 

emission average. CEMs data does not need to be bias adjusted as defined in 

40 CFR Part 75.

(4) In accordance with the Term Sheet, PNM is required to diligently seek all 

necessary regulatory approvals to allow for the retirement of SJGS Units 2 and 

3 by December 31, 2017. Scenario C which, if effective, will require the 

retirement of Units 2 and 3. PNM shall submit a separate permit application to 
NSR Permit No. 0063M8R3 Page 29 of 62

address the reduction in emissions attributable to the retirement of Units 2 and 3 

and revise all applicable requirements accordingly. 

(5) Modification of the fan systems on Units 1 and 4 to achieve “balanced” draft 

configuration allowing for the elimination of emission points E510 and E504.

A113 Compliance Plan – Not Required

A114 Reducing Facility Emissions

A. Certain terms and conditions of this permit reduce the potential emission rate of 

regulated equipment to values below those allowed prior to the date of issuance of 

this permit. The compliance date for construction or operation of the emission 

units and pollution control equipment required to achieve this reduction in potential 

emission rate is in accordance with the implementation scheduled in the FIP 

(September 20, 2016) or SIP (September 20, 2016).
NSR Permit No. 0063M8R3 Page 30 of 62

EQUIPMENT SPECIFIC REQUIREMENTS

OIL AND GAS INDUSTRY

A200 Oil and Gas Industry – not required

CONSTRUCTION INDUSTRY

A300 Construction Industry - not required

POWER GENERATION INDUSTRY

A400 Power Generation Industry

This section has common equipment related to most Electric Service Operations (SIC4911).

A. This facility and Units E301, E302, E303, and E304 (boilers) are subject to and 

shall have complied with the requirements of 40 CFR Part 72 by applying for and 

obtaining an Acid Rain Permit, P062AR2.

B. Acid Rain Program Monitoring

Requirement: Emission Units E301, E302, E303, and E304 (boilers) are subject to and shall 

comply with the requirements of 40 CFR Part 75 for installation, calibration, maintenance and 

operation of NOx and SO2 continuous emissions monitoring systems (NOx and SO2 CEMS)

and for continuous opacity monitoring systems (COMS). 

Monitoring: The permittee shall comply with the requirements at 40 CFR 75.12(a) and 

75.12(b) for continuous monitoring of NOx emissions; with the requirements at 40 CFR 

75.11(a) and 75.11(b)(2) for continuous monitoring of SO2 emissions; with the requirements at 

40 CFR 75.14(a) for continuous monitoring of opacity; and with the requirements at 40 CFR 

75.13(b) and 75.13(c) for continuous monitoring of CO2 emissions. 

Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements 

of 40 CFR Part 75, Continuous Emission Monitoring, subpart F, Sections 75.50 through 75.59; 

and in accordance with Section B109 of this permit.

Reporting: In accordance with 40 CFR 75.

C. Mercury (Hg) Monitoring System

Requirement: The permittee shall install, maintain, and operate a Hg continuous monitoring 

devices based on the applicable QA/QC requirements in Appendix A of 40 CFR 63, Subpart 

UUUUU (i.e. MATS regulation), which references performance specification (PS) 12b.

Monitoring: The permittee shall continually monitor the mercury emissions using sobent 
NSR Permit No. 0063M8R3 Page 31 of 62

traps that are installed and maintained in accordance with the applicable QA/QC requirements 

in Appendix A of 40 CFR 63, Subpart UUUUU (i.e. MATS regulation), which references 

performance specification (PS) 12b.

Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements 

of Appendix A of 40 CFR 63, Subpart UUUUU (i.e. MATS regulation), which references 

performance specification (PS) 12b and in accordance with Section B109 of this permit.

Reporting: The permittee shall comply with the applicable reporting requirements of 

Appendix A of 40 CFR 63, Subpart UUUUU (i.e. MATS regulation), which references 

performance specification (PS) 12b and in accordance with Section B110 of this permit.

Testing: The permittee shall follow the requirements of Subpart UUUUU and PS 12b to 

perform an initial RATA within 180 boiler operating days of installation of the mercury 

sorbent trap system on each unit. After the initial RATA, a RATA will be performed annually 

to provide annual QA/QC certification. Testing shall also comply with Sections, B109, B110, 

and B111.

D. PNM shall maintain, calibrate, and operate CEMS at San Juan Units E301, E303, and 

E304 to measure accurately and continuously opacity and the emissions of SO2, 

NOx, and the exhaust flow rate from each unit in full compliance with the 

requirements of 40 CFR Parts 60 and 75, including requirements for heat input rate 

measurements. Although Unit 302 is not an affected unit for purposes of NSPS 40 

CFR 60, Subpart D, PNM shall maintain, calibrate, and operate CEMS at San Juan 

Unit E302 to measure continuously opacity and the emissions of SO2, NOx, and the 

exhaust flow rate from the unit in accordance with the requirements of 40 CFR Parts 

60 and 75, including requirements for heat input rate measurements.

A401 Turbines - Not Required

A402 Boilers

A. Units E301, E302, E303, and E304

Requirement: Each boiler shall be equipped and operated with a baghouse, to meet the 

emission limits, except as otherwise allowed under the applicable provisions of 20.2.7 NMAC 

and 40 CFR 60 Subpart A (E301, E303, and E304 only). In addition, Control Devices 

associated with Emission Units E301, E303, and E304 are subject to the requirements of 40 

CFR 60.11(d). Each baghouse associated with the boilers shall be maintained and operated in 

accordance with good air pollution control practices for minimizing emissions. Individual 

boilers shall only be operated when its associated baghouse is achieving a control efficiency 

sufficient to ensure compliance with all applicable particulate emission limits listed in this 

permit.

Monitoring: For baghouses associated with Units E301, E302, E303, and E304, PNM shall 

record the pressure drop across each baghouse with a continuous monitoring device. The 

continuous monitoring device shall be designed with an alarm that records and signals to the 

operator any excursion outside the normal operating range of the baghouse. The normal 
NSR Permit No. 0063M8R3 Page 32 of 62

operating range of the baghouse shall be determined by the manufacture or another 

Department approved method.

Recordkeeping: In accordance with Section B109, the pressure drop for each baghouse will 

be recorded hourly and these records will be kept on site for review.

Reporting: No reporting required in accordance with Section B110 of this permit.

B. CAM Monitoring, Units E301, E302, E303, and E304

Requirement: CAM Rule Corrective Action Requirements: 

(1) The units are pollutant specific emission units for SO2, NOx and PM and are subject to and 

shall comply with the requirements of 40 CFR Part 64, Compliance Assurance Monitoring, 

including the requirements of 40 CFR 64.7(d) for corrective actions. Each unit has CEMS for 

SO2 and NOx which are required under acid rain regulations and, therefore, exempt SO2 and 

NOx from CAM requirements. 

(2) As a requirement of this permit the permittee is subject to and shall comply with the 

corrective provisions of the PM CAM Plan dated July 2010 submitted in the application for 

this permit and attached to this permit, except that the trigger points for corrective actions and 

excursions shall be those specified in Table 402.B.

(3) In accordance with 40 CFR 64.6(b), the permittee shall submit COM data 12-months after 

the issuance of this permit to show that the indicator range of 6% for Opacity has been set 

sufficiently to satisfy the requirements of 40 CFR 64 and to confirm the appropriateness of the 

indicator.

(40 CFR 64 and 20.2.70.302.A(7) NMAC)

Monitoring: 

(1) The permittee shall continuously monitor opacity of the units in accordance with the 

specifications of 40 CFR Part 60, Appendix B for continuous opacity monitors (COMs). (40 

CFR 64.6(c)(1)(ii) and 20.2.70.302.A(7)).

(2) The COMs shall collect at least one duct opacity reading every 10 seconds, except as 

allowed by (4) below (40 CFR 64.6(c)(1)(iii), 40 CFR 64.3(b)(4), 40 CFR 64.3(d)(3), and 

20.2.70.302.A(7)).

(3) The COMs shall be maintained at all times, including but not limited to maintaining the 

spare parts necessary for routine repairs (40 CFR 64.6(c)(3) and 40 CFR 64.7(b)).

(4) Except for applicable monitoring malfunctions, associated repairs, and required quality 

assurance or control activities, the permittee shall conduct the opacity monitoring at all times 

that each unit is operating. Data recorded during monitoring malfunctions, associated repairs, 

and required quality assurance or control activities shall not be used to meet the requirements 

of this permit that implement the requirements of 40 CFR Part 64. All data collected during all 

other periods shall be used in assessing the operation of the control devices for those emission 

units (40 CFR 64.6(c)(3), 40 CFR 64.7(c)).

(5) For the purposes of terms and conditions of this permit that implement the requirements of 

40 CFR Part 64, a monitoring malfunction is any sudden, infrequent, not reasonably 

preventable failure of the monitoring to provide valid data. Monitoring failures that are caused 

in part by poor maintenance or careless operation are not malfunctions (40 CFR 64.6(c) and 40 

CFR 64.7(c)).
NSR Permit No. 0063M8R3 Page 33 of 62

CAM Indicators:

(6) Visible emissions (opacity) as measured by COM systems meeting the 40 CFR60 

Performance Specification One and located in the fabric filter outlet duct from each unit (per 

an Alternative Monitoring Plan submitted to EPA).

(7) Differential pressure drop across the fabric filter on each unit.

(8) By-pass damper position (open/closed) indicator.

Recordkeeping: The Permittee shall comply with the requirements of 40 CFR Part 64, 

Compliance Assurance Monitoring, including the recordkeeping requirements of 40 CFR 

64.9(b). (40 CFR 64 and 20.2.70.302.A(7) NMAC).

Reporting: The Permittee shall comply with the requirements of 40 CFR Part 64, Compliance 

Assurance Monitoring, including the reporting requirements of 40 CFR 64.9(a). (40 CFR 64 

and 20.2.70.302.A(7)).

Table 402.B, CAM Indicator Trigger Points for Corrective Actions and Excursions

Indicator Trigger Point1

1 An excursion is defined as a condition when the average opacity exceeds six (6) 

percent for any consecutive 3-hr period.

2 An excursion is defined as a condition when the fabric filter average differential 

pressure exceeds 10 inches water column (w.c) for any consecutive 3-hr period.

3 An excursion is defined as a condition when the by-pass damper is in the open 

position any time when the boiler is in operation. 1

The permittee shall use the permit modification procedures of 20.2.70.404.B NMAC to change the CAM Plan. 

C. Duct Leak Management Program on Units E501, E502, E503, and E504

Requirement: The Duct leak management program shall be conducted in accordance with 

good air pollution control practices for minimizing emission. All remaining combustion gasses 

shall be exhausted through the primary stack of each unit. Compliance with this requirement 

shall be determined using data generated by the monitoring and by Department inspections of 

the units. 

The Expansion Joint Maintenance Program (EJMP) shall include:

a. A written procedure that identifies expansion joint inspection procedures, inspection 

points, inspection locations, inspection frequency and recordkeeping procedures.

b. Identification of measures and time taken to mitigate (minimize) and repair leaks 

including immediate and long-term corrective actions.

c. Quarterly assessment and evaluation of the EJMP covering the ability of the EJMP to 

detect and identify leaks, potential preventive maintenance measures identified to prevent 

or minimize leaks, and assessment of effectiveness of measures taken to minimize leaks.

When each boiler is taken out of service for the purpose of installing the new SCR/SNCR 

control technologies (balanced draft conversion), this requirement is no longer valid. If the 

SCR/SNCR technologies are not installed then this requirement remains valid.

Monitoring: Monitor performance of the EJMP to ensure that the program meets the 

requirements of this permit. At a minimum, this quarterly monitoring shall include an 

assessment of the program’s performance in meeting the requirements above, including an 
NSR Permit No. 0063M8R3 Page 34 of 62

estimate of the actual area of duct leaks present on the subject emission units.

Recordkeeping: Records of the EJMP practices, quarterly inspections, and quarterly 

assessment of the program’s performance shall be maintained on site. 

Reporting: No reporting required in accordance with Section B110 of this permit.

D. Limestone Forced Oxidation (LSFO) Scrubber Operations

Requirement: The boilers (E301, E302, E303, and E304) shall be equipped and operated with 

limestone scrubbers. PNM shall not exceed the emission limits. To the extent necessary to 

meet the SO2 emission limits and the SO2 control efficiency requirements of this permit (Table 

106.C), PNM shall add dibasic acid to the limestone slurry feed of each scrubber. The 

limestone scrubbers (E301, E302, E303, and E304) shall be maintained and operated in 

accordance with good air pollution control practices for minimizing emissions, except as 

otherwise allowed under the applicable provisions of 20.2.7 NMAC and 40 CFR 60 Subpart A 

(E301, E302, and E304 only). Compliance with these requirements shall be determined using 

data generated and by Department inspections of the units.

Monitoring: Control Devices C09, C11, C13, and C15, associated with Emissions Units 

E301, E302, E303, and E304, respectively, are subject to monitoring for good air pollution 

control practices and proper operation and maintenance. This monitoring shall consist of 

keeping monthly records of the performance of maintenance and repair activities on these 

control devices.

Recordkeeping: In accordance with Section B109, records of performance on maintenance 

and repair activities shall be kept on site for review.

Reporting: No reporting required in accordance with Section B110 of this permit.

E. Heat Input

Requirement: Heat input to these boilers shall not increase as a result of installation of the 

low-NOx burners. Compliance with this condition shall be provided upon request of the 

Department. An increase in heat input solely due to an increase in demand is authorized.

Monitoring: 

(1) For each boiler, the 24-hour heat input value shall be calculated by multiplying the 24-hour 

coal flow rate with the 7-day rolling average Btu content of the coal. The 7-day rolling 

average Btu content of the coal shall be derived from as delivered coal sample analysis. In the 

event no coal is delivered for 7 or more days, the last 7-day rolling average will be used.

(2) PNM shall keep records of the “as-delivered” heat content of the coal. The heat content of 

the coal shall be analyzed using an appropriate ASTM method, in accordance with the 

requirements of the coal contract.

(3) For each boiler, the 365-day rolling total heat input shall be calculated as a summation of 

the 24-hour heat input value calculated. 

Recordkeeping: In accordance with Section B109, records of the “as delivered” heat content 

of the coal and the 365 day rolling total heat input calculations shall be maintained.

Reporting: No reporting required in accordance with Section B110 of this permit. Upon 

written request by the Department, PNM shall summarize and report the 365-day rolling total 

heat input values calculated in (1) above.
NSR Permit No. 0063M8R3 Page 35 of 62

F. Continuous Opacity Monitors

Requirement:

(1) Units E301, E303, and E304 are subject to 40 CFR 60 Subpart D and PNM shall operate 

the COMs for units E301, E303, and E304 as required in 40 CFR 60 Subpart D. 

(2) Although Unit 302 is not an affected unit for purposes of NSPS 40 CFR 60, Subpart D, 

PNM shall install, calibrate, maintain, and operate COMs on Unit E302 per the procedures 

specified in 40 CFR 60 Subpart D. The COMs for Unit E302 shall be installed in a 

location comparable to the COM location of Units E301, E303, and E304, unless 

otherwise approved by the Department.

(3) For units E301, E302, E303, and E304 the permittee shall determine compliance with the 

opacity limits of the permit on a continuous basis, using data from the current COMS or 

an EPA approved COMs and an alternative location. All COMs shall be certified or 

recertified per the procedures in 40 CFR Part 60. 

Monitoring: For units E301, E302, E303, and E304 the permittee shall determine compliance 

with the opacity limits of the permit on a continuous basis, using data from the current COMS 

or an EPA approved COMs and an alternative location.

Recordkeeping: Records of opacity readings and QA/QC events will be maintained and 

records of compliance with applicable recordkeeping requirements of 40 CFR 60, Subparts A 

and D.

Reporting: In accordance with applicable reporting requirements of 40 CFR Part 60, 

Subparts A and D.

G. 20.2.31 NMAC (Units E301, E302, E303, and E304)

Requirement: The units are subject to and shall comply with the requirements of 20.2.31.112 

NMAC for SO2 continuous emissions monitoring (CEMS).

Monitoring: SO2 continuous emissions monitoring (CEMS).

Recordkeeping: In accordance with Section B109 of this permit and compliance with 

applicable recordkeeping requirements of 20.2.31.113 NMAC.

Reporting: No reporting is required in accordance with Section B110 of this permit.

H. Periodic Stack Test For Units E301, E302, E303, E304, and E803

Requirement:

(1) Units E301, E302, E303, and E304 (boilers) are subject to periodic compliance testing for 

PM, TSP, PM10, PM2.5, and CO using stack tests and Emission Unit E803 is subject to periodic 

compliance testing for PM using stack tests. The tests for PM, TSP, PM10, and PM2.5 on 

Emission Units E301, E302, E303, and E304 (boilers) shall be performed quarterly. The tests 

for CO on Emission Units E301, E302, E303, and E304 (boilers) shall be performed quarterly. 

The tests on Emission Unit E803 shall be performed at the discretion of the Department. 

(2) For Unit E303, the permittee shall demonstrate compliance with the tons per year CO 

emission limit in Table 106.A.

Monitoring: 

(1) The permittee shall perform quarterly tests and keep records of the periodic emissions tests 
NSR Permit No. 0063M8R3 Page 36 of 62

in accordance with Table 402.H and Section B111 of this permit.

(2) On a monthly basis, the permittee shall calculate the monthly CO emissions produced by 

Unit E303 and record a 12-month rolling total in tons per year to demonstrate compliance with 

the CO emission limit in Table 106.A. The Unit 3 CO emission rate (in pounds per MMBtu) 

determined by each stack test will represent the emission rate for the calendar month in which 

the stack test occurred and for each succeeding calendar month until the month prior to the 

next stack test. Monthly CO emissions in tons/month will be calculated by multiplying the 

quarterly CO stack test result in lb/MMBtu by the monthly Unit 3 heat input in MMBtu and 

divided by 2000. The first month in which a monthly CO determination will be made is the 

month following the month the permit is issued. The initial compliance period will occur 12-

months following the initial monthly CO emissions determination.

a) During the first 12 months of monitoring, each month the permittee shall calculate the 

cumulative total of CO emissions; and

b) After the first 12 months of monitoring, each month the permittee shall calculate the 

monthly rolling 12-month total of CO emissions in tons per year to demonstrate compliance 

with the CO emission limit in Table 106.A.

Recordkeeping: 

(1) Calculated Monthly CO emissions.

(2) Monthly 12-month total CO emissions

In accordance with Sections B109 and B111 of this permit.

Reporting: Quarterly reports of the monthly CO emissions and 12-month CO total shall be 

prepared and maintained onsite. The Quarterly reports will be summarized in the semi-annual 

monitoring report. In accordance with Sections B110 and B111 of this permit.

Table 402.H: Quarterly testing Requirements

Pollutant Reference Method

CO 1 Methods 1-4 and 10

PM (TSP, PM10, PM2.5)

2,3,4 Method 1-5, 5i 1 Test results that demonstrate compliance with CO emission limits shall also be considered to demonstrate 

compliance with VOC emission limits for the subject emission unit. 2 PNM may use Method 5 or 5i testing to demonstrate compliance with the PM10 and PM2.5 standards. 3 PM10 and PM2.5 particulate emissions include condensable particulate matter. 4 PNM shall conduct compliance testing to determine the condensable portion of actual PM10 and PM2.5 emissions 

using EPA Method 202, annually. PNM will also conduct a Method 5i test at approximately the same time it 

conducts each Method 202 test. 

I. Demister Operations

Requirement: PNM shall install pressure monitoring systems across the demister elements 

associated with all of the scrubber modules. The monitoring systems shall have the accuracy, 

reliability and quality to determine whether the demisters are operating in as represented in the 

Demister Report that is associated with the 14 fps maximum velocity of the demister and 

based on actual pressure drop readings. 

(1) Each demister will be cleaned with “clean wash water sprays” on a wash sequence which 

is in automatic mode and in continuous operation. The wash sequence will automatically 
NSR Permit No. 0063M8R3 Page 37 of 62

switch from cell to cell.

(2) During plant outages, PNM will conduct manual cleaning to remove stubborn deposits as 

noted during inspections.

Monitoring: 

(1) PNM shall monitor hourly the pressure drop across each demister from a continuous 

monitoring device. The continuous monitoring device shall be designed with an alarm that 

records and signals to the operator any excursion equal to or above 0.5 inches W.C. across 

either level or 1.0 across both. 

(2) During outages of 96 hours or more, PNM shall inspect the demisters based on 

manufacturers’ recommendations for deposit which are not cleaned by the clean wash water 

spraying.

Recordkeeping: 

(1) PNM shall record hourly the pressure drop across each demister.

(2) Record the time and dates of all 3 hour averages equal to or above 0.5 inches W.C. for

either of the two (2) levels or 1.0 combined.

(3) Record the corrective action taken to return the demister back to normal operation.

(4) Record the findings from the demister inspections.

(5) Record when manual cleaning is performed.

Reporting: PNM shall provide the demister data in the quarterly report while the Consent 

Decree is in effect. Once the Consent Decree is terminated then the quarterly reports shall be 

prepared and maintained onsite in accordance with Condition B110. The Quarterly reports will 

continue to be summarized in the semi-annual monitoring report.

J. 40 CFR 60, Subpart D (Units E301, E303, and E304)

Requirement: The units are subject to 40 CFR 60, Subpart D and the permittee shall comply 

with the applicable requirements of 40 CFR 60, Subpart A and Subpart D.

Monitoring: The permittee shall comply with all applicable monitoring and testing 

requirements of 40 CFR 60, Subpart D.

Recordkeeping: Records of compliance with applicable recordkeeping requirements of 40 

CFR Part 60, Subparts A and D.

Reporting: In accordance with applicable reporting requirements of 40 CFR Part 60, 

Subparts A and D.

K. Coal Pulverizer Unit E201

Requirement: The coal pulverizers (E201) shall be entirely enclosed in a structure that is 

maintained and operated in accordance with good air pollution control practices in order to 

minimize particulate emissions. 

Monitoring: Annual operational inspection, no less than once per calendar year, PNM shall 

inspect the coal pulverizers to insure operation is in accordance with good air pollution control 

practices in order to minimize particulate emissions. 

Recordkeeping: In accordance with Section B109, PNM shall record the results of the 

inspections for the coal pulverizes.

Reporting: No reporting required in accordance with Section B110 of this permit.
NSR Permit No. 0063M8R3 Page 38 of 62

L. H2SO4, Sulfuric Acid Mist Units E301, E302, E303, and E304

Requirement: Only for scenario A as required by the FIP and to demonstrate compliance with 

the emission limits identified in Table 106.A, the following monitoring is required on a per 

unit basis.

Monitoring:

The current Method 8A test, as specified in the FIP, does not have the sensitivity to measure 

accurately to 0.00026 lb/MMBtu levels. As a result, each unit shall be considered in 

compliance with the sulfuric acid emission limit if the results of the Method 8A test are at or 

below the level representing three times the representative detection limit (RDL) of Method 

8A, which is 0.0018 lb/MMBtu (equal to three times the RDL of 0.0006 lb/MMBtu). This 

method of demonstrating compliance is consistent with EPA’s approach in addressing 

measurement imprecision and variability for electric generating units, like those at SJGS, and 

for other industries as well. 77 Fed. Reg. 9304, 9390 (Feb. 16, 2012) (describing a 3xRDL 

approach). Once every three years from the issuance of this permit, PNM shall conduct a 

survey of test methods approved by EPA to determine if new test methods are available that 

can accurately measure 0.00026 lb/MMBtu with a measurement imprecision of less than 

20%. Once a new, more accurate test method becomes available, PNM shall perform the test 

once every calendar year on each unit to demonstrate compliance with the emission limit of 

0.00026 lb/MMBtu. 

Note, CTM-013 (i.e., Method 8A) indicates that “the minimum detectable limit (MDL) of the 

method is 0.50 milligrams/cubic meter,” which translates to 0.0006 lb/MMBtu for SJGS.

Recordkeeping: In accordance with Section B109, PNM shall record the methodology used 

to calculate the lb/MMBtu emissions and the data used to support the calculations. PNM shall 

record summaries of the product searches for available test methods. PNM shall record any 

tests performed.

Reporting: In accordance with Section B110 of this permit, the permittee shall report semiannually a summary of the Sulfuric Acid Mist emissions in lb/MMBtu and any changes in 

available testing options.

M. Ammonia Slip Units E301, E302, E303, and E304

Requirement: To demonstrate compliance with the emission limits identified in Table 106.A, 

PNM must confirm as part of its initial compliance demonstration following the construction 

of the additional control equipment authorized by this permit that the controls are designed to 

meet the applicable ammonia slip limits (2 ppm for SCR under Scenario A, 10 ppm for SNCR 

under Scenario B and to be determined [See Condition A112.C(6)] for Scenario C). Since no 

further emission limits apply, no additional monitoring is required.

Monitoring: None

Recordkeeping: In accordance with Section B109, PNM shall record the initial compliance 

demonstration.

Reporting: In accordance with Section B110 of this permit, the permittee shall report the 

initial compliance demonstration.
NSR Permit No. 0063M8R3 Page 39 of 62

A403 Engines 

A. Units E602, E603, E604, E605, E606, and E607 (emergency generators)

Requirement: Units shall burn only No. 2 Diesel Fuel Oil. Except for maintenance and testing 

activities, units shall only be operated during the unavoidable loss of commercial utility power. 

Each emergency generator shall not operate more than 500 hours per year. Compliance with 

this requirement shall be determined using hours of operation data. 

Monitoring: Monitor emission by maintaining records to demonstrate that only No. 2 Diesel 

Fuel Oil was used and that each unit did not operate more than 500 hours per calendar year 

during an unavoidable loss of commercial utility power. PNM shall monitor the operating 

hours of the emergency generators.

Recordkeeping: In accordance with Section B109, PNM shall record the monthly and 12 

month total operating hours of each emergency generator.

Reporting: No reporting is required in accordance with Section B110 of this permit.

A404 Heaters - Not Required

A405 Cooling Towers

A. Operational Requirements for Units E406, E407, E408, E409, and E410

Requirement: Cooling towers shall be maintained and operated according to manufacturer’s 

recommendations and good engineering practices, and the circulating water rate, total 

dissolved solids (TDS) content of that water, and the drift rate for the units shall not exceed the 

values specified in Table 405.A below. Compliance with these limits shall be determined using 

data generated by the monitoring and by Department inspections of the units.

Monitoring: PNM shall measure the TDS concentration of each cooling tower no less than 

once each calendar quarter.

Recordkeeping: In accordance with Section B109, no less than once each calendar quarter, 

the permittee shall record the TDS concentration of each cooling tower. The permittee shall 

then calculate and record the individual cooling tower PM emissions quarterly, based on the 

maximum capacity of the circulating water pump(s) for each unit, the actual TDS content, and 

the units specific drift rate. 

Reporting: No reporting required in accordance with Section B110 of this permit.

Table 405.A, Circulating Rate, TDS, and Drift Rate Operational Limits for Cooling Towers

Emission 

Unit No. Circulating Water Rate (gpm) TDS Content(milligrams/liter) Drift Rate (percent)

E406 170,000 6,000 0.002

E407 165,000 6,000 0.002
NSR Permit No. 0063M8R3 Page 40 of 62

Emission 

Unit No. Circulating Water Rate (gpm) TDS Content(milligrams/liter) Drift Rate (percent)

E408 220,000 3,900 0.0015

E409 227,500 6,000 0.002

E410 35,000 3,900 0.002

A406 Haul Roads/Storage piles (Coal-Fired Plants)

A. Road Area Operational Requirements Units E701, E702, E703, E704, E705, E706, 

and E707

Requirement: Road areas shall comply with the operational requirements specified in Table 

406.A. Compliance is demonstrated by monitoring and by Department inspections of the units. 

Monitoring: The permittee shall monitor emissions by maintaining a log/records of the times 

and location of water application, the times and location of sweeping, amount of water applied 

to the haul road, occurrences of visual inspections and by performing weekly visual 

inspections of the road area to determine that emissions are minimized. 

Recordkeeping: In accordance with Section B109, the records will be maintained on site for 

review.

Reporting: No reporting required in accordance with Section B110 of this permit.

Table 406.A, Operational Requirements for Road Areas

Emission Unit No. Operational Requirements

E701, E705, and E708 Unit shall be paved, and swept and watered as necessary, to 

minimize emissions of TSP and PM10

E702, E703, E704, E706, and 

E707

Unit shall be watered as necessary to minimize emissions of 

TSP and PM10

B. Facility-Wide Raw Material Limits

Requirement: The calendar year material processing limits in Table 406.B were calculated 

from the AP-42 emission factors and pounds per hour emission rates for tons processed or 

gallons consumed. To demonstrate compliance with annual emission limits, the facility shall 

not process more than the quantities of raw materials specified in Table 406.B. Compliance 

with this limit shall be determined using data generated here.

Monitoring: The permittee shall monitor and record facility-wide raw material usage on a 

calendar quarter basis (which coincides with the reporting periods established at Condition 

A109). PNM shall monitor the quantities of coal, diesel fuel, and limestone processed. (NSR 

63M6R1, Condition 3.j) For each 24-hour period, the permittee shall monitor the coal flows in 

each boiler.
NSR Permit No. 0063M8R3 Page 41 of 62

Recordkeeping: In accordance with Section B109, PNM shall maintain quarterly and annualto-date records of the quantities of coal, diesel fuel, and limestone processed.

Reporting: No reporting required in accordance with Section B110 of this permit.

Table 406.B, Facility-Wide Operational Limits on Raw Materials

Material Annual Limit

Coal 8,200,000 tons

No. 2 Diesel Fuel Oil 4,112,500 gallons(4 million gpy for the coal fired boilers and 112, 

500 gpy for the emergency generators)

Limestone 227,000 tons

C. Good Air Pollution Control Practices

Requirement: Coal pile maintenance (E101, E102, E103, and E104), fly ash silo unloading to 

trucks (E507, E508, E509, E510), limestone delivery system, and limestone pile maintenance 

(E802) shall be operated in accordance with good air pollution control practices to minimize 

emissions.

Monitoring: No less than once each calendar year, PNM shall inspect the coal pile 

maintenance, fly ash silo unloading to trucks, limestone delivery, and limestone pile 

maintenance. 

Recordkeeping: In accordance with Section B109, PNM shall record the results of the 

inspection for the coal pile maintenance, fly ash silo unloading to trucks, limestone delivery, 

and limestone pile maintenance. Records and/or logs of control practices to demonstrate 

compliance with the controls in the permit application shall be maintained and summarized in 

the Semi-annual reports.

Reporting: No reporting required in accordance with Section B110 of this permit.

D. NSPS Subpart OOO (Units E803, E804, and E805 (limestone process equipment))

Requirement: Allowable emission limits

Monitoring: The units are subject to and shall comply with the requirements of 40 CFR 60, 

Subpart A and of 40 CFR 60, Subpart OOO, 60.675(c) for monitoring emissions.

Recordkeeping: In accordance with the applicable requirements of 40 CFR 60, Subpart 

OOO, 60.676(f). Records of any periodic opacity determinations will be maintained.

Reporting: In accordance with the applicable requirements of 40 CFR 60, Subpart OOO. 

Opacity test results will be submitted to the NMED.
NSR Permit No. 0063M8R3 Page 42 of 62

A407 Storage Silos (activated carbon, fly ash)

A. Activated Carbon Silo Baghouses (Units E901, E902, E903, and E904)

Requirement: Activated Carbon for Mercury emissions control

(1) Each of the activated carbon silos shall be equipped with a baghouse operated according 

to manufacturer’s guidelines and specification. The baghouse shall have a design PM emission 

rate of 0.0092 grains/scf or less and a design baghouse exhaust flow rate of 578 scfm.

(2) The activated carbon shall be introduced into the exhaust stream prior to the baghouse 

used to control particulate matter from the respective boilers.

(3) Each activated carbon baghouse shall be equipped and operated with a device to 

continuously monitor the pressure differential across the baghouse to insure continued 

compliance.

Monitoring: PNM shall monitor the pressure drop across each activated carbon silo baghouse 

whenever the silos are loaded. The data capture rate shall be no less than once every six 

minutes. At a minimum the record shall include the silo designation, date, time, pressure 

differential, and in the event that the pressure differential is not continually monitored, the silo 

loading status (fan on or off).

Recordkeeping: PNM shall follow the General Recordkeeping requirement in Section B109.

(1) PNM shall keep manufacturer’s documentation onsite indicting that each activated carbon 

silo baghouse was designed to control PM emissions 0.0092 grains/scf or less and design 

baghouse exhaust flow rate is 578 scfm.

(2) PNM shall keep records of the pressure drop across each activated carbon silo baghouse.

(3) PNM shall keep the manufacturer’s documentation onsite that indicates the proper range 

that the pressure drop should be during normal operations of each activated carbon silo 

baghouse.

Reporting: No reporting required in accordance with Section B110 of this permit.

B. Fly Ash/Limestone Silo Baghouses

Requirement: The fly ash silo loading (E505, E506, E518, and E519) and limestone silo loading 

(E803) shall be equipped and operated with baghouses. The baghouses shall be equipped and operated 

with devices to monitor the differential pressure drop across the baghouse. The control devices shall be 

operated and maintained in accordance with manufacturer’s specifications, including specifications for 

pressure drop, in order to achieve a minimum 99.5% control of TSP, PM10, and PM emissions. 

Compliance with these requirements shall be determined using data generated and by Department 

inspections of the units. 

Monitoring: The permittee shall monitor emissions by measuring the pressure drop across 

each filter, daily. PNM shall monitor and record the pressure drop across each fly ash silo 

baghouse (Units 505 and 506). For baghouse associated with the Units E505, E506, E518, 

E519 and E803, PNM shall monitor the differential pressure drop across the baghouses daily.

(Units 505 and 506).

Recordkeeping: In accordance with Section B109, PNM shall record the daily pressure drop 

measurements for each baghouse. 

Reporting: No reporting required in accordance with Section B110 of this permit.
NSR Permit No. 0063M8R3 Page 43 of 62

PART B GENERAL CONDITIONS

B100 Introduction

A. The Department has reviewed the permit application for the proposed 

construction/modification/revision and has determined that the provisions of the 

Act and ambient air quality standards will be met. Conditions have been imposed 

in this permit to assure continued compliance. 20.2.72.210.D NMAC, states that 

any term or condition imposed by the Department on a permit is enforceable to the 

same extent as a regulation of the Environmental Improvement Board.

B101 Legal

A. The contents of a permit application specifically identified by the Department shall 

become the terms and conditions of the permit or permit revision. Unless modified 

by conditions of this permit, the permittee shall construct or modify and operate the 

Facility in accordance with all representations of the application and supplemental 

submittals that the Department relied upon to determine compliance with 

applicable regulations and ambient air quality standards. If the Department relied 

on air quality modeling to issue this permit, any change in the parameters used for 

this modeling shall be submitted to the Department for review. Upon the 

Department’s request, the permittee shall submit additional modeling for review by 

the Department. Results of that review may require a permit modification. 

(20.2.72.210.A NMAC)

B. Any future physical changes, changes in the method of operation or changes in 

restricted area may constitute a modification as defined by 20.2.72 NMAC, 

Construction Permits. Unless the source or activity is exempt under 20.2.72.202 

NMAC, no modification shall begin prior to issuance of a permit. (20.2.72 NMAC 

Sections 200.A.2 and E, and 210.B.4)

C. Changes in plans, specifications, and other representations stated in the application 

documents shall not be made if they cause a change in the method of control of 

emissions or in the character of emissions, will increase the discharge of emissions 

or affect modeling results. Any such proposed changes shall be submitted as a 

revision or modification. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4)

D. The permittee shall establish and maintain the property’s Restricted Area as 

identified in plot plan submitted with the application. (20.2.72 NMAC Sections 

200.A.2 and E, and 210.B.4)

E. Applications for permit revisions and modifications shall be submitted to:
NSR Permit No. 0063M8R3 Page 44 of 62

Program Manager, Permits Section

New Mexico Environment Department

Air Quality Bureau

525 Camino de los Marquez, Suite 1

Santa Fe, New Mexico 87505-1816

F. At all times, including periods of startup, shutdown, and malfunction, owners and 

operators shall, to the extent practicable, maintain and operate the source including 

associated air pollution control equipment in a manner consistent with good air 

pollution control practice for minimizing emissions. (20.2.7.109, 20.2.72.210.A, 

20.2.72.210.B, 20.2.72.210.C, 20.2.72.210.E NMAC) The establishment of 

allowable malfunction emission limits does not supersede this requirement.

B102 Authority

A. This permit is issued pursuant to the Air Quality Control Act (Act) and regulations 

adopted pursuant to the Act including Title 20, Chapter 2, Part 72 of the New 

Mexico Administrative Code (NMAC), (20.2.72 NMAC), Construction Permits 

and is enforceable pursuant to the Act and the air quality control regulations 

applicable to this source.

B. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to 

the delegation and exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 

NMAC (NESHAP), and 20.2.82 NMAC (MACT).

B103 Annual Fee

A. The Department will assess an annual fee for this Facility. The regulation 20.2.75 

NMAC set the fee amount at $1,500 through 2004 and requires it to be adjusted 

annually for the Consumer Price Index on January 1. The current fee amount is 

available by contacting the Department or can be found on the Department’s 

website. The AQB will invoice the permittee for the annual fee amount at the 

beginning of each calendar year. This fee does not apply to sources which are 

assessed an annual fee in accordance with 20.2.71 NMAC. For sources that satisfy 

the definition of “small business” in 20.2.75.7.F NMAC, this annual fee will be 

divided by two. (20.2.75.11 NMAC)

B. All fees shall be remitted in the form of a corporate check, certified check, or 

money order made payable to the “NM Environment Department, AQB” mailed to 

the address shown on the invoice and shall be accompanied by the remittance slip 

attached to the invoice.
NSR Permit No. 0063M8R3 Page 45 of 62

B104 Appeal Procedures

A. Any person who participated in a permitting action before the Department and who 

is adversely affected by such permitting action, may file a petition for hearing 

before the Environmental Improvement Board. The petition shall be made in 

writing to the Environmental Improvement Board within thirty (30) days from the 

date notice is given of the Department's action and shall specify the portions of the 

permitting action to which the petitioner objects, certify that a copy of the petition 

has been mailed or hand-delivered and attach a copy of the permitting action for 

which review is sought. Unless a timely request for hearing is made, the decision 

of the Department shall be final. The petition shall be copied simultaneously to the 

Department upon receipt of the appeal notice. If the petitioner is not the applicant 

or permittee, the petitioner shall mail or hand-deliver a copy of the petition to the 

applicant or permittee. The Department shall certify the administrative record to 

the board. Petitions for a hearing shall be sent to: (20.2.72.207.F NMAC)

Secretary, New Mexico Environmental Improvement Board

1190 St. Francis Drive, Runnels Bldg. Rm. N2153

Santa Fe, New Mexico 87502

B105 Submittal of Reports and Certifications

A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to 

Stacktest.AQB@state.nm.us or as directed by the Department.

B. Excess Emission Reports shall be submitted as directed by the Department. 

(20.2.7.110 NMAC)

C. Routine reports shall be submitted to the mailing address below, or as directed by 

the Department:

Manager, Compliance and Enforcement Section

New Mexico Environment Department

Air Quality Bureau

525 Camino de los Marquez, Suite 1

Santa Fe, New Mexico 87505-1816

B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations

A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator 

that installs and operates a continuous monitoring device required by a NSPS 

regulation shall comply with the excess emissions reporting requirements in 

accordance with 40 CFR 60.7(c), unless specifically exempted in the applicable 

subpart.
NSR Permit No. 0063M8R3 Page 46 of 62

B. If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 

CFR 60.8(c), emissions in excess of the level of the applicable emission limit 

during periods of startup, shutdown, and malfunction shall not be considered a 

violation of the applicable emission limit unless otherwise specified in the 

applicable standard.

C. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject 

to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 

CFR 63.6(e)(3), unless specifically exempted in the applicable subpart.

B107 Startup, Shutdown, and Maintenance Operations

A. The establishment of permitted startup, shutdown, and maintenance (SSM) 

emission limits does not supersede the requirements of 20.2.7.14.A NMAC. Except 

for operations or equipment subject to Condition B106, the permittee shall establish 

and implement a plan to minimize emissions during routine or predictable start up, 

shut down, and scheduled maintenance (SSM work practice plan) and shall operate 

in accordance with the procedures set forth in the plan. (SSM work practice plan. 

(20.2.7.14.A NMAC)

B108 General Monitoring Requirements

A. These requirements do not supersede or relax requirements of federal regulations.

B. The following monitoring requirements shall be used to determine compliance with 

applicable requirements and emission limits. Any sampling, whether by portable 

analyzer or EPA reference method, that measures an emission rate over the 

applicable averaging period greater than an emission limit in this permit constitutes 

noncompliance with this permit. The Department may require, at its discretion, 

additional tests pursuant to EPA Reference Methods at any time, including when 

sampling by portable analyzer measures an emission rate greater than an emission 

limit in this permit; but such requirement shall not be construed as a determination 

that the sampling by portable analyzer does not establish noncompliance with this 

permit and shall not stay enforcement of such noncompliance based on the 

sampling by portable analyzer.

C. If the emission unit is shutdown at the time when periodic monitoring is due to be 

accomplished, the permittee is not required to restart the unit for the sole purpose of 

performing the monitoring. Using electronic or written mail, the permittee shall 

notify the Department’s Compliance and Enforcement Section of a delay in 

emission tests prior to the deadline for accomplishing the tests. Upon 

recommencing operation, the permittee shall submit any pertinent pre-test 

notification requirements set forth in the current version of the Department’s 
NSR Permit No. 0063M8R3 Page 47 of 62

Standard Operating Procedures For Use Of Portable Analyzers in Performance 

Test, and shall accomplish the monitoring.

D. The requirement for monitoring during any monitoring period is based on the 

percentage of time that the unit has operated. However, to invoke monitoring 

exemptions at B108.D(2), hours of operation shall be monitored and recorded. 

(1) If the emission unit has operated for more than 25% of a monitoring period, 

then the permittee shall conduct monitoring during that period.

(2) If the emission unit has operated for 25% or less of a monitoring period then the 

monitoring is not required. After two successive periods without monitoring, the 

permittee shall conduct monitoring during the next period regardless of the time 

operated during that period, except that for any monitoring period in which a 

unit has operated for less than 10% of the monitoring period, the period will not 

be considered as one of the two successive periods.

(3) If invoking the monitoring period exemption in B108.D(2), the actual operating 

time of a unit shall not exceed the monitoring period required by this permit 

before the required monitoring is performed. For example, if the monitoring 

period is annual, the operating hours of the unit shall not exceed 8760 hours 

before monitoring is conducted. Regardless of the time that a unit actually 

operates, a minimum of one of each type of monitoring activity shall be

conducted during any five-year period.

E. For all periodic monitoring events, except when a federal or state regulation is 

more stringent, three test runs shall be conducted at 90% or greater of the unit’s 

capacity as stated in this permit, or in the permit application if not in the permit, 

and at additional loads when requested by the Department. If the 90% capacity

cannot be achieved, the monitoring will be conducted at the maximum achievable 

load under prevailing operating conditions except when a federal or state regulation 

requires more restrictive test conditions. The load and the parameters used to 

calculate it shall be recorded to document operating conditions and shall be 

included with the monitoring report.

F. When requested by the Department, the permittee shall provide schedules of testing 

and monitoring activities. Compliance tests from previous NSR and Title V permits 

may be re-imposed if it is deemed necessary by the Department to determine 

whether the source is in compliance with applicable regulations or permit 

conditions.

G. If monitoring is new or is in addition to monitoring imposed by an existing 

applicable requirement, it shall become effective 120 days after the date of permit 

issuance. For emission units that have not commenced operation, the associated 

new or additional monitoring shall not apply until 120 days after the units 
NSR Permit No. 0063M8R3 Page 48 of 62

commence operation. All pre-existing monitoring requirements incorporated in 

this permit shall continue to apply from the date of permit issuance.

B109 General Recordkeeping Requirements

A. The permittee shall maintain records to assure and verify compliance with the terms 

and conditions of this permit and any other applicable requirements that become 

effective after permit issuance. The minimum information to be included in these 

records is: 

(1) equipment identification (include make, model and serial number for all tested 

equipment and emission controls); 

(2) date(s) and time(s) of sampling or measurements;

(3) date(s) analyses were performed;

(4) the qualified entity that performed the analyses;

(5) analytical or test methods used;

(6) results of analyses or tests; and

(7) operating conditions existing at the time of sampling or measurement.

B. Except as provided in the Specific Conditions, records shall be maintained on-site 

or at the permittee’s local business office for a minimum of two (2) years from the 

time of recording and shall be made available to Department personnel upon 

request. Sources subject to 20.2.70 NMAC “Operating Permits” shall maintain 

records on-site for a minimum of five (5) years from the time of recording.

C. Malfunction emissions and routine and predictable emissions during startup, 

shutdown, and scheduled maintenance (SSM):

(1) The permittee shall keep records of all events subject to the plan to minimize 

emissions during routine or predictable SSM. (20.2.7.14.A NMAC)

(2) If the facility has allowable SSM emission limits in this permit, the permittee 

shall record all SSM events, including the date, the start time, the end time, and 

a description of the event. This record also shall include a copy of the 

manufacturer’s, or equivalent, documentation showing that any maintenance 

qualified as scheduled. Scheduled maintenance is an activity that occurs at an 

established frequency pursuant to a written protocol published by the 

manufacturer or other reliable source. The authorization of allowable SSM 

emissions does not supersede any applicable federal or state standard. The most 

stringent requirement applies.

(3) If the facility has allowable malfunction emission limits in this permit, the 

permittee shall record all malfunction events to be applied against these limits, 
NSR Permit No. 0063M8R3 Page 49 of 62

including the date, the start time, the end time, and a description of the event. 

Malfunction means any sudden, infrequent, and not reasonably preventable 

failure of air pollution control and monitoring equipment, process equipment, or 

a process to operate in a normal or usual manner which causes, or has the 

potential to cause, the emission limitations in an applicable standard to be 

exceeded. Failures that are caused in part by poor maintenance or careless 

operation are not malfunctions. (40 CFR 63.2, 20.2.7.7.E NMAC) The 

authorization of allowable malfunction emissions does not supersede any 

applicable federal or state standard. The most stringent requirement applies. 

This authorization only allows the permittee to avoid submitting reports under 

20.2.7 NMAC for total annual emissions that are below the authorized limit. 

B110 General Reporting Requirements

(20.2.72 NMAC Sections 210 and 212)

A. Records and reports shall be maintained on-site unless specifically required to be 

submitted to the Department or EPA by another condition of this permit or by a 

state or federal regulation. Records for unmanned sites may be kept at the nearest 

company office.

B. The permittee shall notify the Department’s Compliance Reporting Section using 

the current Submittal Form posted to NMED’s Air Quality web site under 

Compliance and Enforcement/Submittal Forms in writing of, or provide the 

Department with (20.2.72.212.A and B):

(1) the anticipated date of initial startup of each new or modified source not less 

than thirty (30) days prior to the date. Notification may occur prior to issuance 

of the permit, but actual startup shall not occur earlier than the permit issuance 

date;

(2) after receiving authority to construct, the equipment serial number as provided 

by the manufacturer or permanently affixed if shop-built and the actual date of 

initial startup of each new or modified source within fifteen (15) days after the 

startup date; and 

(3) the date when each new or modified emission source reaches the maximum 

production rate at which it will operate within fifteen (15) days after that date.

C. The permittee shall notify the Department’s Permitting Program Manager, in 

writing of, or provide the Department with (20.2.72.212.C and D):

(1) any change of operators or any equipment substitutions within fifteen (15) days 

of such change;

(2) any necessary update or correction no more than sixty (60) days after the 

operator knows or should have known of the condition necessitating the update 

or correction of the permit.
NSR Permit No. 0063M8R3 Page 50 of 62

D. Results of emission tests and monitoring for each pollutant (except opacity) shall 

be reported in pounds per hour (unless otherwise specified) and tons per 

year. Opacity shall be reported in percent. The number of significant figures 

corresponding to the full accuracy inherent in the testing instrument or Method test 

used to obtain the data shall be used to calculate and report test results in 

accordance with 20.2.1.116.B and C NMAC. Upon request by the Department, 

CEMS and other tabular data shall be submitted in editable, MS Excel format.

E. The permittee shall submit reports of excess emissions in accordance with 

20.2.7.110.A NMAC. 

B111 General Testing Requirements

A. Compliance Tests

(1) Compliance test requirements from previous permits (if any) are still in effect, 

unless the tests have been satisfactorily completed. Compliance tests may be reimposed if it is deemed necessary by the Department to determine whether the 

source is in compliance with applicable regulations or permit conditions. 

(20.2.72 NMAC Sections 210.C and 213)

(2) Compliance tests shall be conducted within sixty (60) days after the unit(s) 

achieve the maximum normal production rate. If the maximum normal 

production rate does not occur within one hundred twenty (120) days of source 

startup, then the tests must be conducted no later than one hundred eighty (180) 

days after initial startup of the source.

(3) Unless otherwise indicated by Specific Conditions or regulatory requirements, 

the default time period for each test run shall be at least 60 minutes and each 

performance test shall consist of three separate runs using the applicable test 

method. For the purpose of determining compliance with an applicable emission 

limit, the arithmetic mean of results of the three runs shall apply. In the event 

that a sample is accidentally lost or conditions occur in which one of the three 

runs must be discontinued because of forced shutdown, failure of an 

irreplaceable portion of the sample train, extreme meteorological conditions, or 

other circumstances, beyond the owner or operator's control, compliance may, 

upon the Department approval, be determined using the arithmetic mean of the 

results of the two other runs.

(4) Testing of emissions shall be conducted with the emissions unit operating at 90 

to 100 percent of the maximum operating rate allowed by the permit. If it is not 

possible to test at that rate, the source may test at a lower operating rate, subject 

to the approval of the Department.
NSR Permit No. 0063M8R3 Page 51 of 62

(5) Testing performed at less than 90 percent of permitted capacity will limit 

emission unit operation to 110 percent of the tested capacity until a new test is 

conducted.

(6) If conditions change such that unit operation above 110 percent of tested 

capacity is possible, the source must submit a protocol to the Department within 

30 days of such change to conduct a new emissions test.

B. EPA Reference Method Tests

(1) All compliance tests required by this permit, unless otherwise specified by 

Specific Conditions of this permit, shall be conducted in accordance with the 

requirements of CFR Title 40, Part 60, Subpart A, General Provisions, and the 

following EPA Reference Methods as specified by CFR Title 40, Part 60, 

Appendix A:

i. Methods 1 through 4 for stack gas flowrate

ii. Method 5 for TSP

iii. Method 6C and 19 for SO2

iv. Method 7E for NOX (test results shall be expressed as nitrogen dioxide 

(NO2) using a molecular weight of 46 lb/lb-mol in all calculations (each 

ppm of NO/NO2 is equivalent to 1.194 x 10-7 lb/SCF)

v. Method 9 for opacity

vi. Method 10 for CO

vii. Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate

upon approval of the Department. A justification for this proposal must 

be provided along with a contemporaneous fuel gas analysis (preferably 

on the day of the test) and a recent fuel flow meter calibration certificate 

(within the most recent quarter).

viii. Method 7E or 20 for Turbines per 60.335 or 60.4400

ix. Method 29 for Metals

x. Method 201A for filterable PM10 and PM2.5 (Dry Stacks)

xi. Method 5, 5B or 5I for filterable PM10 and PM2.5 (Wet Stacks)

xii. Method 202 for condensable PM

xiii. Method 320 for organic Hazardous Air Pollutants (HAPs)

xiv. Method 25A for VOC reduction efficiency

(2) Alternative test method(s) may be used if the Department approves the change

C. Periodic Monitoring and Portable Analyzer Requirements
NSR Permit No. 0063M8R3 Page 52 of 62

(1) Periodic emissions tests (periodic monitoring) may be conducted in accordance 

with EPA Reference Methods or by utilizing a portable analyzer. Periodic 

monitoring utilizing a portable analyzer shall be conducted in accordance with 

the requirements of ASTM D 6522-00. However, if a facility has met a 

previously approved Department criterion for portable analyzers, the analyzer 

may be operated in accordance with that criterion until it is replaced.

(2) Unless otherwise indicated by Specific Conditions or regulatory requirements, 

the default time period for each test run shall be as follows:

i. For quarterly monitoring, at least 20 minutes

ii. For annual monitoring, at least 60 minutes

Each performance test shall consist of three separate runs. The arithmetic mean 

of results of the three runs shall be used to determine compliance with the 

applicable emission limit

(3) Testing of emissions shall be conducted with the emissions unit operating at 90 

to 100 percent of the maximum operating rate allowed by the permit. If it is not 

possible to test at that rate, the source may test at a lower operating rate, subject 

to prior approval of the Department.

(4) During emissions tests, pollutant, O2 concentration and fuel flow rate shall be 

monitored and recorded. This information shall be included with the test report 

furnished to the Department.

(5) Pollutant emission rate shall be calculated in accordance with 40 CFR 60, 

Appendix A, Method 19 utilizing fuel flow rate (scf) and fuel heating value 

(Btu/scf) obtained during the test.

D. Test Procedures:

(1) The permittee shall notify the Department’s Program Manager, Compliance and 

Enforcement Section at least thirty (30) days before the test date and allow a 

representative of the Department to be present at the test.

(2) Equipment shall be tested in the "as found" condition. Equipment may not be 

adjusted or tuned prior to any test for the purpose of lowering emissions, and 

then returned to previous settings or operating conditions after the test is 

complete.

(3) Contents of test notifications, protocols and test reports shall conform to the 

format specified by the Department’s Universal Test Notification, Protocol and 

Report Form and Instructions. Current forms and instructions are posted to 

NMED’s Air Quality web site under Compliance and Enforcement Testing. 

(4) The permittee shall provide (a) sampling ports adequate for the test methods 

applicable to the facility, (b) safe sampling platforms, (c) safe access to 

sampling platforms and (d) utilities for sampling and testing equipment. 
NSR Permit No. 0063M8R3 Page 53 of 62

(5) The stack shall be of sufficient height and diameter and the sample ports shall 

be located so that a representative test of the emissions can be performed in 

accordance with the requirements of EPA Method 1 or ASTM D 6522-00 as 

applicable.

(6) Where necessary to prevent cyclonic flow in the stack, flow straighteners shall 

be installed

(7) Unless otherwise indicated by Specific Conditions or regulatory requirements,

test reports shall be submitted to the Department no later than 30 days after 

completion of the test.

B112 Compliance

A. The Department shall be given the right to enter the facility at all reasonable times 

to verify the terms and conditions of this permit. Required records shall be 

organized by date and subject matter and shall at all times be readily available for 

inspection. The permittee, upon verbal or written request from an authorized 

representative of the Department who appears at the facility, shall immediately 

produce for inspection or copying any records required to be maintained at the 

facility. Upon written request at other times, the permittee shall deliver to the 

Department paper or electronic copies of any and all required records maintained 

on site or at an off-site location. Requested records shall be copied and delivered at 

the permittee’s expense within three business days from receipt of request unless 

the Department allows additional time. Required records may include records 

required by permit and other information necessary to demonstrate compliance 

with terms and conditions of this permit. (NMSA 1978, Section 74-2-13)

B. A copy of the most recent permit(s) issued by the Department shall be kept at the 

permitted facility or (for unmanned sites) at the nearest company office and shall be 

made available to Department personnel for inspection upon request.

(20.2.72.210.B.4 NMAC)

C. Emissions limits associated with the energy input of a Unit, i.e. lb/MMBtu, shall 

apply at all times unless stated otherwise in a Specific Condition of this permit. 

The averaging time for each emissions limit, including those based on energy input 

of a Unit (i.e. lb/MMBtu) is one (1) hour unless stated otherwise in a Specific 

Condition of this permit or in the applicable requirement that establishes the limit. 

B113 Permit Cancellation and Revocation

A. The Department may revoke this permit if the applicant or permittee has knowingly 

and willfully misrepresented a material fact in the application for the permit. 

Revocation will be made in writing, and an administrative appeal may be taken to 

the Secretary of the Department within thirty (30) days. Appeals will be handled in 
NSR Permit No. 0063M8R3 Page 54 of 62

accordance with the Department's Rules Governing Appeals From Compliance 

Orders.

B. The Department shall automatically cancel any permit for any source which ceases 

operation for five (5) years or more, or permanently. Reactivation of any source 

after the five (5) year period shall require a new permit. (20.2.72 NMAC)

C. The Department may cancel a permit if the construction or modification is not 

commenced within two (2) years from the date of issuance or if, during the 

construction or modification, work is suspended for a total of one (1) year. (20.2.72 

NMAC)

B114 Notification to Subsequent Owners

A. The permit and conditions apply in the event of any change in control or ownership 

of the Facility. No permit modification is required in such case. However, in the 

event of any such change in control or ownership, the permittee shall notify the 

succeeding owner of the permit and conditions and shall notify the Department’s 

Program Manager, Permits Section of the change in ownership within fifteen (15) 

days of that change. (20.2.72.212.C NMAC)

B. Any new owner or operator shall notify the Department’s Program Manager, 

Permits Section, within thirty (30) days of assuming ownership, of the new owner’s

or operator’s name and address. (20.2.73.200.E.3 NMAC)

B115 Asbestos Demolition

A. Before any asbestos demolition or renovation work, the permittee shall determine 

whether 40 CFR 61 Subpart M, National Emissions Standards for Asbestos applies. 

If required, the permittee shall notify the Department’s Program Manager, 

Compliance and Enforcement Section using forms furnished by the Department.

B116 Short Term Engine Replacement

A. The following Alternative Operating Scenario (AOS) addresses engine breakdown 

or periodic maintenance and repair, which requires the use of a short term 

replacement engine. The following requirements do not apply to engines that are 

exempt per 20.2.72.202.B(3) NMAC. Changes to exempt engines must be reported 

in accordance with 20.2.72.202.B NMAC. A short term replacement engine may 

be substituted for any engine allowed by this permit for no more than 120 days in 

any rolling twelve month period per permitted engine. The compliance 

demonstrations required as part of this AOS are in addition to any other compliance 

demonstrations required by this permit.
NSR Permit No. 0063M8R3 Page 55 of 62

(1) The permittee may temporarily replace an existing engine that is subject to the 

emission limits set forth in this permit with another engine regardless of 

manufacturer, model, and horsepower without modifying this permit. The 

permittee shall submit written notification to the Department within 15 days of 

the date of engine substitution according to condition B110.C(1).

i. The potential emission rates of the replacement engine shall be 

determined using the replacement engine’s manufacturer specifications 

and shall comply with the existing engine’s permitted emission limits.

ii. The direction of the exhaust stack for the replacement engine shall be 

either vertical or the same direction as for the existing engine. The 

replacement engine’s stack height and flow parameters shall be at least 

as effective in the dispersion of air pollutants as the modeled stack 

height and flow parameters for the existing permitted engine. The 

following equation may be used to show that the replacement engine 

disperses pollutants as well as the existing engine. The value calculated 

for the replacement engine on the right side of the equation shall be 

equal to or greater than the value for the existing engine on the left side

of the equation. The permitting page of the Air Quality Bureau website 

contains a spreadsheet that performs this calculation.
NSR Permit No. 0063M8R3 Page 56 of 62

EXISTING ENGINE REPLACMENT ENGINE

[(g) x (h1)] + [(v1)2/2] + [(c) x (T1)] <= [(g) x (h2)] + [(v2)2/2] + [(c) x (T2)]

q1 q2

Where

g = gravitational constant = 32.2 ft/sec2

h1 = existing stack height, feet

v1 = exhaust velocity, existing engine, feet per second

c = specific heat of exhaust, 0.28 BTU/lb-degree F

T1 = absolute temperature of exhaust, existing engine = degree F + 460

q1 = permitted allowable emission rate, existing engine, lbs/hour

h2 = replacement stack height, feet

v2 = exhaust velocity, replacement engine, feet per second

T2 = absolute temperature of exhaust, replacement engine = degree F + 460

q2 = manufacturer’s potential emission rate, replacement engine, lbs/hour

The permittee shall keep records showing that the replacement engine is at least 

as effective in the dispersion of air pollutants as the existing engine.

iii. Test measurement of NOx and CO emissions from the temporary 

replacement engine shall be performed in accordance with Section B111 

with the exception of Condition B111A(3) and B111B for EPA 

Reference Methods Tests or SectionB111C for portable analyzer test 

measurements. Compliance test(s) shall be conducted within fifteen (15) 

days after the unit begins operation, and records of the results shall be 

kept according to section B109.B. This test shall be performed even if 

the engine is removed prior to 15 days on site.

i. These compliance tests are not required for an engine certified 

under 40CFR60, subparts IIII, or JJJJ, or 40CFR63, subpart 

ZZZZ if the permittee demonstrates that one of these 

requirements causes such engine to comply with all emission 

limits of this permit. The permittee shall submit this 

demonstration to the Department within 48 hours of placing the 

new unit into operation. This submittal shall include 

documentation that the engine is certified, that the engine is 

within its useful life, as defined and specified in the applicable 

requirement, and shall include calculations showing that the 

applicable emissions standards result in compliance with the 

permit limits.

ii. These compliance tests are not required if a test was conducted 

by portable analyzer or by EPA Method test (including any 

required by 40CFR60, subparts IIII and JJJJ and 40CFR63, 
NSR Permit No. 0063M8R3 Page 57 of 62

subpart ZZZZ) within the last 12 months. These previous tests 

are valid only if conducted at the same or lower elevation as the 

existing engine location prior to commencing operation as a 

temporary replacement. A copy of the test results shall be kept

according to section B109.B.

iv. Compliance tests for NOx and CO shall be conducted if requested by the 

Department in writing to determine whether the replacement engine is in 

compliance with applicable regulations or permit conditions.

v. Upon determining that emissions data developed according to 

B116.A.1(c) fail to indicate compliance with either the NOx or CO 

emission limits, the permittee shall notify the Department within 48 

hours. Also within that time, the permittee shall implement one of the 

following corrective actions:

i. The engine shall be adjusted to reduce NOx and CO emissions 

and tested per B116.A.1(c) to demonstrate compliance with 

permit limits. 

ii. The engine shall discontinue operation or be replaced with a 

different unit. 

(2) Short term replacement engines, whether of the same manufacturer, model, and 

horsepower, or of a different manufacturer, model, or horsepower, are subject to 

all federal and state applicable requirements, regardless of whether they are set 

forth in this permit (including monitoring and recordkeeping), and shall be 

subject to any shield afforded by this permit.

(3) The permittee shall maintain a contemporaneous record documenting the unit 

number, manufacturer, model number, horsepower, emission factors, emission 

test results, and serial number of any existing engine that is replaced, and the 

replacement engine. Additionally, the record shall document the replacement 

duration in days, and the beginning and end dates of the short term engine 

replacement. 

(4) The permittee shall maintain records of a regulatory applicability determination 

for each replacement engine (including 40CFR60, subparts IIII and JJJJ and 

40CFR63, subpart ZZZZ) and shall comply with all associated regulatory 

requirements. 

B. Additional requirements for replacement of engines at sources that are major as 

defined in regulation 20.2.74 NMAC, Permits – Prevention of Significant 

Deterioration, section 7.AF. For sources that are major under PSD, the total 

cumulative operating hours of the replacement engine shall be limited using the 

following procedure:
NSR Permit No. 0063M8R3 Page 58 of 62

(1) Daily, the actual emissions from the replacement engine of each pollutant 

regulated by this permit for the existing engine shall be calculated and recorded. 

(2) The sum of the total actual emissions since the commencement of operation of 

the replacement engine shall not exceed the significant emission rates in Table 2 

of 20.2.74 NMAC, section 502 for the time that the replacement engine is 

located at the facility.

C. All records required by this section shall be kept according to section B109.

PART C MISCELLANEOUS

C100 Supporting On-Line Documents

A. Copies of the following documents can be downloaded from NMED’s web site 

under Compliance and Enforcement or requested from the Bureau.

(1) Excess Emission Form (for reporting deviations and emergencies)

(2) Universal Stack Test Notification, Protocol and Report Form and Instructions 

(3) SOP for Use of Portable Analyzers in Performance Tests 

C101 Definitions

A. “Daylight” is defined as the time period between sunrise and sunset, as defined by 

the Astronomical Applications Department of the U.S. Naval Observatory. (Data 

for one day or a table of sunrise/sunset for an entire year can be obtained at 

http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a 

Farmer’s Almanac or from http://www.almanac.com/rise/).

B. “Exempt Sources” and “Exempt Activities” is defined as those sources or 

activities that are exempted in accordance with 20.2.72.202 NMAC. Note; 

exemptions are only valid for most 20.2.72 NMAC permitting actions. 

C. “Fugitive Emission” means those emissions which could not reasonably pass 

through a stack, chimney, vent, or other functionally equivalent opening.

D. “Insignificant Activities” means those activities which have been listed by the 

department and approved by the administrator as insignificant on the basis of size, 

emissions or production rate. Note; insignificant activities are only valid for 

20.2.70 NMAC permitting actions.

E. “Natural Gas” is defined as a naturally occurring fluid mixture of hydrocarbons 

that contains 20.0 grains or less of total sulfur per 100 standard cubic feet (SCF) 
NSR Permit No. 0063M8R3 Page 59 of 62

and is either composed of at least 70% methane by volume or has a gross calorific 

value of between 950 and 1100 Btu per standard cubic foot. (40 CFR 60.631)

F. “Natural Gas Liquids” means the hydrocarbons, such as ethane, propane, butane, 

and pentane, that are extracted from field gas. (40 CFR 60.631)

G. “National Ambient air Quality Standards” means, unless otherwise modified, 

the primary (health-related) and secondary (welfare-based) federal ambient air 

quality standards promulgated by the US EPA pursuant to Section 109 of the 

Federal Act. 

H. “Night” is the time period between sunset and sunrise, as defined by the 

Astronomical Applications Department of the U.S. Naval Observatory. (Data for 

one day or a table of sunrise/sunset for an entire year can be obtained at 

http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a 

Farmer’s Almanac or from http://www.almanac.com/rise/).

I. “Night Operation or Operation at Night” is operating a source of emissions at 

night.

J. “NO2” or "Nitrogen dioxide" means the chemical compound containing one atom 

of nitrogen and two atoms of oxygen, for the purposes of ambient determinations. 

The term "nitrogen dioxide," for the purposes of stack emissions monitoring, shall 

include nitrogen dioxide (the chemical compound containing one atom of nitrogen 

and two atoms of oxygen), nitric oxide (the chemical compound containing one 

atom of nitrogen and one atom of oxygen), and other oxides of nitrogen which may 

test as nitrogen dioxide and is sometimes referred to as NOx or NOx. (20.2.2 

NMAC)

K. “NOx” see NO2

L. “Potential Emission Rate” means the emission rate of a source at its maximum 

capacity to emit a regulated air contaminant under its physical and operational 

design, provided any physical or operational limitation on the capacity of the 

source to emit a regulated air contaminant, including air pollution control 

equipment and restrictions on hours of operation or on the type or amount of 

material combusted, stored or processed, shall be treated as part of its physical and 

operational design only if the limitation or the effect it would have on emissions is 

enforceable by the department pursuant to the Air Quality Control Act or the 

federal Act.

M. “Restricted Area” is an area to which public entry is effectively precluded. 

Effective barriers include continuous fencing, continuous walls, or other continuous 

barriers approved by the Department, such as rugged physical terrain with a steep 

grade that would require special equipment to traverse. If a large property is 
NSR Permit No. 0063M8R3 Page 60 of 62

completely enclosed by fencing, a restricted area within the property may be 

identified with signage only. Public roads cannot be part of a Restricted Area.

N. "Shutdown", for requirements under 20.2.72 NMAC, means the cessation of 

operation of any air pollution control equipment, process equipment or process for 

any purpose, except routine phasing out of batch process units. 

O. "SSM", for requirements under 20.2.7 NMAC, means routine or predictable 

startup, shutdown, or scheduled maintenance.

(1) "Shutdown", for requirements under 20.2.7 NMAC, means the cessation of 

operation of any air pollution control equipment or process equipment. 

(2) "Startup", for requirements under 20.2.7 NMAC, means the setting into 

operation of any air pollution control equipment or process equipment.

P. "Startup" , for requirements under 20.2.72 NMAC, means the setting into 

operation of any air pollution control equipment, process equipment or process for 

any purpose, except routine phasing in of batch process units.

C102 Acronyms

2SLB ........................................................................................................ 2-stroke lean burn

4SLB ........................................................................................................ 4-stroke lean burn

4SRB.........................................................................................................4-stroke rich burn

acfm........................................................................................... actual cubic feet per minute

AFR....................................................................................................................air fuel ratio

AP-42 ...........................................................................EPA Air Pollutant Emission Factors

AQB........................................................................................................Air Quality Bureau

AQCR ....................................................................................... Air Quality Control Region

ASTM ............................................................. American Society for Testing and Materials

BTU......................................................................................................British Thermal Unit

CAA.............................................................Clean Air Act of 1970 and 1990 Amendments

CEM................................................................................. continuous emissions monitoring

cfh ........................................................................................................... cubic feet per hour

cfm .......................................................................................................cubic feet per minute

CFR........................................................................................... Code of Federal Regulation

CI ........................................................................................................compression ignition

CO............................................................................................................ carbon monoxides

COMS ...................................................................... continuous opacity monitoring system

EIB............................................................................... Environmental Improvement Board

EPA.......................................................... United States Environmental Protection Agency

gr./100 cf.......................................................................... grains per one hundred cubic feet

gr./dscf .............................................................................grains per dry standard cubic foot

GRI.....................................................................................................Gas Research Institute
NSR Permit No. 0063M8R3 Page 61 of 62

HAP...................................................................................................hazardous air pollutant

hp .......................................................................................................................horsepower

H2S..............................................................................................................hydrogen sulfide

IC ..........................................................................................................internal combustion

KW/hr ...................................................................................................... kilowatts per hour

lb/hr..............................................................................................................pounds per hour

lb/MMBtu .............................................................pounds per million British Thermal Unit

MACT ............................................................. Maximum Achievable Control Technology

MMcf/hr......................................................................................million cubic feet per hour

MMscf.........................................................................................million standard cubic feet

N/A..................................................................................................................not applicable

NAAQS.................................................................National Ambient Air Quality Standards 

NESHAP .................................National Emission Standards for Hazardous Air Pollutants

NG ....................................................................................................................... natural gas

NGL ......................................................................................................... natural gas liquids

NMAAQS ......................................................New Mexico Ambient Air Quality Standards

NMAC............................................................................ New Mexico Administrative Code

NMED.....................................................................New Mexico Environment Department

NMSA.................................................................................New Mexico Statues Annotated

NOx...............................................................................................................nitrogen oxides 

NSCR.................................................................................non-selective catalytic reduction

NSPS............................................................................. New Source Performance Standard

NSR.......................................................................................................New Source Review

PEM ..................................................................................parametric emissions monitoring

PM................................ particulate matter (equivalent to TSP, total suspended particulate)

PM10 .......................................................particulate matter 10 microns and less in diameter

PM2.5 .....................................................particulate matter 2.5 microns and less in diameter

pph................................................................................................................pounds per hour

ppmv ......................................................................................... parts per million by volume

PSD .........................................................................Prevention of Significant Deterioration

RATA...........................................................................Relative Accuracy Test Assessment

RICE ....................................................................reciprocating internal combustion engine

rpm.................................................................................................... revolutions per minute

scfm.......................................................................................standard cubic feet per minute

SI ................................................................................................................... spark ignition

SO2 ..................................................................................................................sulfur dioxide

SSM...................................................Startup Shutdown Maintenance (see SSM definition)

TAP........................................................................................................ Toxic Air Pollutant

TBD.............................................................................................................to be determined

THC..........................................................................................................total hydrocarbons

TSP..........................................................................................Total Suspended Particulates

tpy .....................................................................................................................tons per year

ULSD ..................................................................................................ultra low sulfur diesel

USEPA..................................................... United States Environmental Protection Agency
NSR Permit No. 0063M8R3 Page 62 of 62

UTM......................................................Universal Transverse Mercator Coordinate system

UTMH................................................................Universal Transverse Mercator Horizontal

UTMV....................................................................Universal Transverse Mercator Vertical

VHAP...................................................................................volatile hazardous air pollutant

VOC.......................................................................................... volatile organic compounds