PREVENTION OF SIGNIFICANT DETERIORATION PERMIT
 

ISSUED PURSUANT TO THE
 

REQUIREMENTS AT 40 CFR § 52.21
 

u.s. ENVIRONMENTAL PROTECTION AGENCY, REGION 9 

PSD PERMIT NUMBER:	 AZ 08-01 

PERMITTEE:	 Salt River Project Agricultural and Power District 

Mail Station PAB352 

P.O. Box 52025 

Phoenix, AZ 85072 

FACILITY NAME: Navajo Generating Station 

FACILITY LOCATION:	 On the Navajo Nation Indian Reservation, 

approximately five miles east of Page offU.S. 

Highway 98, in Coconino County, Arizona. 

Pursuant to the provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. Section 

7470, et. seq.), and the Code of Federal Regulations (CFR) Title 40, Section 52.21, the United 

States Environmental Protection Agency Region 9 (EPA) is issuing a Prevention ofSignificant 

Deterioration (PSD) air quality permit to the Salt River Project Agricultural and Power District 

(SRP). The PSD Permit applies to the installation of Low-Nt), Burners (LNBs) and Separated 

Over-fire Air (SOFA) systems on three existing coal-fired steam generating units at the Navajo 

Generating Station (NGS). 

SRP is authorized to construct and operate the LNBs and SOFA systems at the NGS as described 

herein, in accordance with the permit application (and plans submitted with the permit 

application), the federal PSD regulations at 40 CFR § 52.21, and other terms and conditions set 

forth in this PSD Permit. Failure to comply with any condition or term set forth in this PSD 

Permit is subject to enforcement action pursuant to Section 113 ofthe Clean Air Act. This permit 

does not relieve NGS from the obligation to comply with applicable federal, state, and Navajo 

Nation Environmental Protection Agency air pollution control rules and regulations. 

This PSD Permit becomes effective on the date of issuance pursuant to 40 CFR § 124.l5(b)(3). 

Date 
NAVAJO GENERATING STATION - LOW-NOx BURNER PROJECT (AZ 08-01)
 

PREVENTION OF SIGNIFICANT DETERIORATION PERMIT
 

PROPOSED PERMIT CONDITIONS
 

PROJECT DESCRIPTION 

The Navajo Generating Station (NGS) has a combined power generating capacity of2,250 net 

megawatts and consists of three existing coal-fired steam generating units (Boiler Units 1,2, and 

3), associated air pollution control devices, and auxiliary equipment. The facility was constructed 

in 1970 and is located on the Navajo Nation Indian Reservation approximately five miles east of 

Page, Arizona. Units 1, 2, and 3 are operated by the Salt River Project Agricultural and Power 

District (SRP) and co-owned by the following six entities: U.S. Bureau of Reclamation, SRP, 

Los Angeles Department of Water and Power, Arizona Public Service Company, Nevada Power, 

and Tucson Electric Power Company. The Permittee receives coal with a maximum sulfur 

content of 1.5% by weight from the Peabody Western Coal Company's Kayenta Mine. 

SRP has decided to implement voluntary emission reduction projects at the NGS by retrofitting 

all three boilers with Low-NOx Burners (LNBs) and separated over-fire air (SOFA) systems. 

One boiler will be retrofitted during each of the next three calendar years. SRP will commence 

operation in March 2009, provided this permit is finalized in 2008. The installation of all three 

new burners will reduce total nitrogen oxide (NOx) emissions by 22,386 tons per year (tpy) 

although carbon monoxide (CO) emissions will increase by 36,570 tpy. 

Because of the increases in CO emissions, the facility is subject to the Prevention of Significant 

Deterioration (PSD) Program. 

EQUIPMENT DESCRIPTION 

Unit ID /	 Maximum Unit Description	 Existing Controls New Controls Stack ID Capacity
 

Boiler 1 One (1) pulverized coal-fired 7,725 FGD system, LNB/SOFA
 

UI/Stack boiler, using No.2 fuel oil MMBtulhr; SCBR1 (1999); system
 

Sl	 for ignition fuel. Stack S1 is 750 Net ESPI
 

equipped with S02, CO, and MW
 

NOx CEMS, and a CaMS.
 

Boiler 2 One (1) pulverized coal-fired 7,725 FGD system, LNB/SOFA
 

U2/Stack boiler, using No.2 fuel oil MMBtulhr; SCBR2 (1998); system
 

S2	 for ignition fuel. Stack S1 is 750 Net ESP2
 

equipped with S02, CO, and MW
 

NOx CEMS, and a CaMS.
 

Boiler 3 One (1) pulverized coal-fired 7,725 FGD system, LNB/SOFA
 

U3/Stack boiler, using No.2 fuel oil MMBtulhr; SCBR3 (1997); system
 

S3	 for ignition fuel. Stack S1 is 750 Net ESP3
 

equipped with S02, CO, and MW
 

NOx CEMS, and a CaMS.
 

Navajo Generating Station (AZ 08-01) Final PSD Permit 

November 2008 

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PERMIT CONDITIONS 

I.	 PERMIT EXPIRATION 

As provided in 40 CFR 52.21(r), this PSD Permit shall become invalid if construction: 

A.	 is not commenced (as defined in 40 CFR 52.21(b)(9)) within 18 months after the 

approval takes effect; or 

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

C.	 is not completed within a reasonable time. 

II.	 PERMIT NOTIFICATION REQUIREMENTS 

Permittee shall notify EPA Region 9 in writing or by electronic mail of the: 

A.	 date construction is commenced, postmarked within 30 days of such date. 

B.	 actual date of initial startup, as defined in 40 CFR 60.2, postmarked within 15 

days of such date. 

C.	 date upon which initial performance tests will commence, in accordance with the 

provision of Section IX.F, postmarked not less than 30 days prior to such date. 

Notification may be provided with the submittal of the performance test protocol 

required pursuant to Section IX.F. 

D.	 date upon which initial performance evaluation of the CEMS will commence in 

accordance with 40 CFR 60.13(c), postmarked not less than 30 days prior to such 

date. Notification may be provided with the submittal ofthe CEMS performance 

test protocol required pursuant to Condition IX.E.5. 

III.	 FACILITY OPERATION 

At all times, including periods of startup, shutdown and malfunction, Permittee shall, to 

the extent practicable, maintain and operate the facility including associated air pollution 

control equipment in a manner consistent with good air pollution control practice for 

minimizing emissions. Determination of whether acceptable operating and maintenance 

procedures are being used will be based on information available to the EPA which may 

include, but is not limited to, monitoring results, opacity observations, review of 

operating maintenance procedures and inspection of the source. 

Navajo Generating Station (AZ 08-01) Final PSD Permit 

November 2008 

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IV.	 MALFUNCTION REPORTING 

A.	 Permittee shall notify EPA by facsimile or electronic mail at R9.AEO@epa.gov 

within two (2) working days following the discovery of any failure of air 

pollution control equipment, process equipment, or of a process to operate in a 

normal manner, which results in an increase in emissions above the allowable 

emission limit stated in Condition IX.B ofthis permit. 

B.	 In addition, Permittee shall notify EPA in writing or electronic mail within fifteen 

(15) days of any such failure described under Condition IV.A. This notification 

shall include a description of the malfunctioning equipment or abnormal 

operation, the date of the initial malfunction, the period of time over which 

emissions were increased due to the failure, the cause ofthe failure, the estimated 

resultant emissions in excess of those allowed in Condition IX.B, and the methods 

utilized to mitigate emissions and restore normal operations. 

C.	 Compliance with this malfunction notification provision shall not excuse or 

otherwise constitute a defense to any violation of this permit or any law or 

regulation such malfunction may cause. 

V.	 RIGHT OF ENTRY 

The EPA Regional Administrator, and/or an authorized representative, upon the 

presentation of credentials, shall be permitted: 

A.	 to enter the premises where the source is located or where any records are 

required to be kept under the terms and conditions of this PSD Permit; and 

B.	 during normal business hours, to have access to and to copy any records required 

to be kept under the terms and conditions of this PSD Permit; and 

C.	 to inspect any equipment, operation, or method subject to requirements in this 

PSD Permit; and 

D.	 to sample materials and emissions from the source(s). 

VI.	 TRANSFER OF OWNERSHIP 

In the event of any changes in control or ownership ofthe facilities to be constructed, this 

PSD Permit shall be binding on all subsequent owners and operators. Permittee shall 

notify the succeeding owner and operator ofthe existence of this PSD Permit and its 

conditions by letter, a copy of which shall be forwarded to EPA Region 9 at the address 

shown in Section X. 

Navajo Generating Station (AZ 08-01) Final PSD Permit 

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VII.	 SEVERABILITY 

The provisions ofthis PSD Permit are severable, and, if any provision of the PSD Permit 

is held invalid, the remainder of this PSD Permit shall not be affected. 

VIII.	 OTHER APPLICABLE REGULATIONS 

Permittee shall construct and operate this project in compliance with this PSD Permit, the 

application on which this Permit is based, and all other applicable federal, state, and local 

air quality regulations. This PSD Permit does not release the Permittee from any liability 

for compliance with other applicable federal, state and local environmental laws and 

regulations, including the Clean Air Act. 

IX.	 SPECIAL CONDITIONS 

Low-Nt), Burner (LNB) & Separated Over-fire Air (SOFA) Requirements 

A.	 Prior to commencement of installation, the Permittee shall submit the following 

information to EPA: 

1.	 Design specifications ofthe LNB/SOFA system to be installed. 

2.	 At least one month prior to the date ofinitial start-up, an LNB/SOFA system 

operating plan which sets forth measures that will be taken to maintain and 

operate the system in a manner to ensure compliance with the emission 

limits specified in Condition IX.B. 

B.	 Emission Limits 

1.	 Carbon monoxide (CO) emissions from each unit shall not exceed 0.42 

lb/MMBtu based on a 30-day rolling average. 

2.	 Nitrogen oxide emissions (NOx) from each unit shall not exceed 0.24 

lb/MMBtu based on a 3D-day rolling average. 

C.	 Demonstration Period Requirements 

1.	 Demonstration Period is defined as the first 18 months of operation after 

installation of the LNB/SOFA system. 

2.	 After the Demonstration Period for each LNB/SOFA system, the Permittee 

shall submit to EPA a written report together with CO CEMS data showing 

actual CO emissions which evaluates whether a lower CO emissions limit 

can be consistently and reasonably achieved while maintaining NOx 

emission levels at or below 0.24 lb/MMbtu on a 3D-day rolling average. The 

Navajo Generating Station (AZ 08-01) Final PSD Permit 

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report shall provide all supporting documentation identifying the 

combustion characteristics that impact CO emissions and evaluate the 

potential for reducing the CO emission limit to a level that can be 

consistently and reasonably met. Within 30 days after the EPA concludes in 

writing that the report is acceptable, the Permittee shall apply for a permit 

modification to decrease the CO emission limit. This report shall also 

evaluate the ten highest occurrences for a one-hour average and an 8-hour 

average for pounds per hour CO. If these averages are inconsistent (higher) 

with the modeling submittal, either a new modeling analysis will be required 

to assure maintenance of the CO NAAQS or a short term limit will be 

established for the permit. 

D.	 At all times, including periods of startup and shutdown, the Permittee shall, to the 

extent practicable, maintain and operate the LNB/SOFA system in a manner 

consistent with good combustion practices to minimize emissions. 

E.	 Continuous Emission Monitoring Systems 

1.	 Within 60 days of completion of installation of each LNB/SOFA system, the 

Permittee shall install, and thereafter operate, maintain, certify, and qualityassure a continuous emission monitoring system (CEMS) for each boiler 

which measures stack gas CO concentrations in Ib/MMbtu. 

2.	 The CO CEMS shall meet the applicable requirements of 40 CFR Part 60 

Appendix B, Performance Specifications 3 and 4A, and 40 CFR Part 60 

Appendix F, Procedure 1. The diluent monitor (02 or CO2) must meet the 

requirements of 40 CFR Part 75. 

3.	 Permittee shall operate, maintain, and quality-assure according to the 

requirements of 40 CFR Part 75, a CEMS for each boiler which measures 

stack gas NOx concentrations in Ib/MMbtu. The NOx CEMs must meet the 

requirements of 40 CFR Part 75. 

4.	 The CO CEMS shall complete a minimum of one cycle of operations 

(sampling, analyzing and data recording) for each successive IS-minute 

period. 

5.	 Permittee shall submit a CO CEMS performance test protocol to the EPA no 

later than 30 days prior to the test date to allow review of the test plan and to 

arrange for an observer to be present at the test. The performance test shall 

be conducted in accordance with the submitted protocol, and any changes 

required by EPA. 

6.	 Permittee shall furnish the EPA a written report of the results of 

performance tests within 60 days of completion. 

7.	 The CO CEMS shall be tested annually and quarterly in accordance with the 

requirements of 40 CFR 60 Appendix F, Procedure 1. The NOx CEMS shall 

meet the quality assurance requirement found in 40 CFR Part 75. 

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F. Performance Test 

A thirty day initial performance test for CO and NOx shall be conducted with the 

CEMS starting the day after successful completion of the performance testing for 

the CO CEMs. A report of the NOx and CO hourly emissions during this initial 

test shall be submitted to EPA within 30 days of completion of the test. 

G. Recordkeeping and Reporting Requirements 

1.	 Permittee shall maintain records of the hours of operation for U I, U2 and 

U3 on a monthly basis. 

2.	 Permittee shall maintain records of the amount of fuel used in UI, U2 and 

U3 on a monthly basis. 

3.	 Permittee shall maintain all records on site of actual operating data and 

emissions calculations for emissions limits required in Condition IX.B. 

4.	 Permittee shall maintain CEMS records that contain the following: the 

occurrence and duration of any startup, shutdown or malfunction, 

performance testing, evaluations, calibrations, checks, adjustments, 

maintenance, duration of any periods during which a continuous monitoring 

system or monitoring device is inoperative, and emission measurements. 

5.	 Permittee shall maintain records and submit a written report of all excess 

emissions to EPA semi-annually. The report is due on the so" day 

following the end of the calendar quarter and shall include the following: 

a.	 Time intervals, data and magnitude of the excess emissions, the 

nature and cause (if known), corrective actions taken and preventive 

measures adopted; 

b.	 Applicable time and date of each period during which the CEMS 

was inoperative (monitor down time), except for zero and span 

checks, and the nature of system repairs or adjustments; and 

c.	 A negative declaration when no excess emissions occurred or when 

the CEMS has not been inoperative, repaired, or adjusted. 

6.	 Excess emissions shall be defined as any operating day in which the 30-day 

rolling average CO and NOx concentration, as measured by the CEMS, 

exceeds the maximum emission limits set forth in Condition IX.B. 

7.	 A period of monitor down time shall be any unit operating hour in which 

sufficient data are not obtained to validate the hour for CO, NOx, or O2. 

Navajo Generating Station (AZ 08-0 I) Final PSD Permit 

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8. Excess emissions indicated by the CEMS shall be considered violations of 

the applicable emission limit for the purpose of this permit. 

9. All records required by this PSD Permit shall be retained for five years 

following the date of such measurements, maintenance, and reports. 

X. AGENCY NOTIFICATIONS 

All correspondence as required by this permit must be forwarded to: 

1) Director, Air Division (Attn: AIR-3)

EPA Region 9

75 Hawthorne Street

San Francisco, CA 94105-3901

e-mail: R9AirPermits@epa.gov

facsimile: (415) 947-3579

2) Environmental Department Director

Navajo Nation EPA

P.O. Box 9000

Window Rock, AZ 86515

Navajo Generating Station (AZ 08-01) Final PSD Permit 

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