### PREVENTION OF SIGNIFICANT DETERIORATION PERMIT FOR**GRE ENHOUSE**  

### GAS EMISSIONS ISSUED PURSUANT TO THE REQUI REMENTS AT 40 CFR 

### § 52.21
U

. S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6 PSD PERMIT NUMBER:
PERMITTEE: FACILITY NAME:
MAILING AD:ORESS:

FACILITY LOCATI ON: PSD-TX-1348-GHG
Victoria WLE , L.P

. Victoria Power Sta tion
919 Milam Street, Suite 2300 Houston, TX 77002
1205**Soutl~** 

### Bottom Street Vict oria, TX 77901
Pursuant to th e provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. 

### § 7470, 

### et. Seq.), and the Code of Federal Regulations 

### (CPR) Title 40, Section**5~.21,** 

### and the Federal Implementation P l an at 40 CFR 

### § 52.2305 (effective May l, 2011 and published at 76 FR 

### 25178), the 

### U.S. Environmental Protection Agency, Region 

### 6 is issuing a Prevention of Significant Deterioration (PSD) permil t to Victoria WLE, L.P. for Greenhouse Gas (GHG) emissions. The Permit authorizes a major modification that adds natural gas combined cycle generating capacity to the existing Victoria Power Station (VPS) plant.
VPS is authorized to expand its existing natural gas fired combined cycle electric generating facility as described herein, in accordance with the permit app li cation (and plans submitted with the permit application), the federa l PSD regulations at 40 CPR§ 52.2 1 , and other terms and conditions set forth in 

### chis PSD permit in conjunction with the corresponding Texas Commission on Environmen tal Qua li ty (TCEQ) PSD permit No. PSD-TX-1348. Fai lure to 

### comply w i th any condition or term set forth in this PSD Permit may result 

### in enforcement action pursuant to Section 113 of the Clean A ir Act (CAA). This PSD Permit does not relieve VPS of the responsibility to comp l y with any other applicable provisions of the CAA (focluding appl icab le implementing regulations in 40 CFR Parts 51, 52, 60, 61, 72 through 75, and 98) or other federal and state require men t s (including the Btate PSD program that remains under approval at 40 CFR 

### § 52.2303)

. 

### In accordance w ith 40 CFR § l 

### 24. l 

### 5(b), this PSD Permit becomes effective 30 days after the

· service of notice of this final decision unless review is requested on the permit pursuant to 40 CFR §124.19.

DateVictoria WLE , L.P. (PSD-TX-1348
- GHG) Prevention of Significant Deterioration Permit For Greenhouse Gas Emissions Permit Conditions
PROJECT DESCRIPTION


### Purs uant to th e p rovisions of this permit , Victoria WLE, L.P

. (Vict o ria) will carry out a maj or modification at th e existing Victoria Powe r Station (VPS) located in Victoria, Victoria County, Texas. The exis ting VPS i s a n atu ral gas-fired combined cycle base load power gene ratin g station that curr e ntly operates in a 1 

### b y I 

### by 1 ( 1 

### x 1 

### x 1 ) 

### co nfi guratio n (one combusti on turbine , one H RSG and one s team turlb in e) with a gas tu rbi ne (M50 lf ), 

### heat re covery steam generator ( H R SG) equ i pped with duc1t burners and a s team generator (General E le ctric 

### 05)

. The project would add a new gas turb ine (GE.7FA.04 or equivale nt) and HRS G equipped with duct burners. After t h es e additio n s, the facility will be able to operate in a natural gas-fired combined cycl e ge nerat in g unit in a 2 by 2 by l (2 x 2 x 

### 1 ) configuration (two combu stion turbines, two HRSG and one ste am turbin e) that utilizes the existing non-modified 

### M501 F combustion turbine and HR SG a nd the existing non-modified steam turbine. Th e VPS plant is authorized to operate in a 1 

### x 1 

### x 

### 1 comb in ed cy cle configuration with the n ew gas turbine and new HR SG, and it r etains ab 11 ity to operate in Tts orTglnal 1 

### x 

### 1 x 

### 1 combined cycle configurat ion-without an as s i g n ed GH G BACT limit. VPS operations covered by the permit will consi st o f the followin g sources of GH G e mission s:

• Nat ural Gas- Fired Co mb ined Cycle Com bu s ti on Turbine (GE.7F A.04 or equival ent). The combus tio n turbine is equipped with a heat rec overy steam ge nerator (BRSG) and duct burners , dr y low NOx (DLN) combustion system, and selective catalytic reduction (S CR), an d oxidation cata lyst ; • Process Fug itives; and , • Electric al equipment ins ulated with sulfur hexafluoride (SF G). EQUIPMENT LIS T


### The followi n g devices are subject to this GHG PSD permit:

FIN E PN Descriptio n 

### Natura l Gas-F ired Combined Cycle Co mbu st ion Turbine VIC IO YIClO (GE .7FA.04 or eq ui val ent)

. The comb ustion tu rbine is eq uipped with heat r e covery s team generator (HRSG) and duct burners, dry low NOx (DLN) combustion syste m , and se lective cata l yti c reduction (SC R ), and ox ida tion catalyst.

Page 2of13VlClO-FUG- VIClO-FUG- Process Fugiti ves NGAS NGAS

YIClO-fNS- VlClO-INS- SF6 Insulated Electrical Equipment (i.e., circuit breakers) not to SF6 SF6 exceed 23 lbs



### I. GENERAL PERMIT CONDITION A. PERMIT EXPIRATION

1. is not commenced (as defined in 40 CFR §52.2 1(b)(9)) within 18 months after the approval takes .effect; 

### .or: 2. i s discontinued for a period of 18 months or more; o r 3. is not complete d within a reasonable time.
Pursuant to 40 CFR §52.2 l (r), EPA may extend the 18-month period upon a written satisfactory showing that an exte nsion is justified. 

### B. PERMIT NOTIFICATION IIBQUIREMENTS
Permittee sha ll notify 

### EPA Region 6 in writing or by e lectronic mail of the:
l. date construction is commenced, postmarked within 30 day s of such date;
2. actua l date of initial startup, as defined in 40 CFR §60.2, postmarked within 15 days of suc h date; and
3. date upon w hich ini tial performance tests w ill commence, in accordance with the provisions o f Section V, postmarked not less than 30 da ys prior to such date. Notification may be provided with the s ubmittal of the performance te st protocol required pursuant to Condi t ion V 

### .B. C. FACILITY OPERATION
At all times , inc luding periods of startup, shutdown, and maintenance, Permittee s haJJ , to the extent practicab l e, maintain and operate the facility including associated air pollution control equipment in a manner consistent w i th good a ir pollution contro l practice for minimizing

Page 

### 3of13

### emiss i ons. Dete rm i nati on of whether acceptable op erating and mai ntenance pro cedures are being used will be based on information availabl e t o the EPA , whi ch may i nclude , but i s not limited to, monitoring r esu lts, r evie w of operating maintenance pr oce dures and inspection of the facility.
D. MALFUNCT ION REPORTING 

### 1. Perm ittee shall n otify E PA by mail within 48 hours following t he di scovery of any fa ilu re of air pollution control e quipment, process equipment, or of a process to op erate in a norma l manner , which results in an increase in GHG emissions abov e the allo w ab le emissio n limits stated in Sectio ns 

### II and 

### H I of 

### th is permit.
2. 

### Wit hin l 0 

### days of the restoration of norm a l op eration s after any failure described in 1.0 .1., 

### Pe 1mitte e s hall provide a written supplement to the initial noti fication that includ es a description of the malfunctioning equipment o r abnorma l operation , th e date of the in iti al malfunction , the period of time over w hi ch emi ssions were increas ed due to the fai lure , th e 

### cause of the fai lure , the es timated resultant emissions in excess of tho se a ll o wed in Sec tion II 

### and Ill , 

### and tb e methods ut ii ize d to mitig ate emi ss ions and r estore normal operati011s. 

### 3. Com 15l ia nce with t his malfunction notificat io n provision shall 

### not excuse ur uthe rw ise con stitute a de fense to any violation of thi s permit or any law or re gulatio n such ma l fun ction may cause. E. RIGHT OF ENT RY 

### EPA authorized rep r ese ntatives, upon the presentation of credentials, s hall be permitted:
I

. 

### to ente r the premises wher e the fac ilit y i s located or where any r ecords are req uired to be kept unde r the terms and co nd itions of thi s PS D Permit ; 2. 

### duri ng normal bu s iness hours, t o 

### have access to and to copy any rec ords requir e d to be ke pt under th e terms and condit ions of this PSD Perm it ; 3. to ins pect any equipment: operation, or method subject to 

### re quirements in 

### thi s P SD Pe rmi t ; and, 4

. to sa mple material s and emis s ions from the so urce (s)

. F. TRAN SFER OF OWNERSHIP In 

### the event of any change s in control or ownership of the facilities to be constructed, this PSD P

erm it shall be bind ing on all s ubsequent owners and operators

. Permittee shall notify the s u cceedi ng owner and operator of th e : existence of the PSD Permit and its conditions by letter; a copy of the lett er shall be forwarded to EPA Region 6 within thirty days of the l e tter signature.
G. SEVERABIL ITY



### Page 4of13

### The provisions of this 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.


### H . ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS
Permittee shall construct this project i:n compliance with this PSD Permit, the application on

, which this permit is based, the TCEQ PSD Permit PSD-TX-1348 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 an.d local environmental laws and regulations, including the Clean Air A.ct.


### II. ACRONYMS AND ABBREVIATIONS
AVO BACT


# cc ccs CEMS CFR 

### CH4 C02 C02e CT 

### EF EPN FIN 

### FR GCV GHG GWP 

### HHV lb LDAR MMBtu MSS N10 

### NSPS 02 PSD QA/QC RATA TAC TCEQ TOC TPY Auditory, Visual, and Olfactory Best Available Control Technology
Carbon Content Carbon Capture and Sequestration Continuous Emissions Monitoring 

### Sy.stem.

- Code of Federal Regulations Methane Carbon Dioxide Carbon Dioxide Equivalent Combus:tion Turbine Emission Factor Emission Point Number Facility Identification Number Federal Register Gross Calorific Value Greenhouse Gas Global 'Narming Potential High Heating Value Pound Leak Detection and Repair Million British Thermal Units Maintenance, Start-up and Shutdown Nitrous Oxides New So:urce Performance Standards Oxygen Prevention of Significant Deterioration Quality Assurance and/or Quality Control Relative : Accuracy Test Audit Texas Administrative Code Texas Commission on Environmental Quality Total Organic Carbon Tons per Year

Page 

### 5of13- 

### USC 

# voe United States Code Volatile Organic Compound
HI. Annual E miss io n Limits
Annual emissio ns, in tons per ye ar ( T PY) 

### on a 12

- month , roll ing to tal, s hall n ot exceed th e following:
Table 1

. Annual Emission Limits 1
F IN 

### EPN GHG M a ss Bas is 

### TPY BACT Re q u i reme n ts Descrip ti o n TPY C02e 2 • 3 C0 2 l , 070,879.0 940 lb C02/M Wh (gross) on Natural Gas- a I 2-month ro ll ing avera ge. Fired CH. 23 Start-up and Shutdown Combined emissions limited to 1,000 VIC I O VJC I O Cycle 1 ,072,053 ho urs per year. MSS Combu stion emissions are limited to I08 Turb ine NiO 2 to n s C0 2 /hr. See Special (GE.7FA.04) 4 Conditions IV.A. l. and Table 2. No Emi ss io n No VI CIO- VI C I O

- Proce ss Emi s si o n 

## ruG- FUG

- CH4 Li mil NGA S NG AS Fugitives Es ta b l ished 5 Limit Es tab l ished 5 SF6 In s ulated No Emission No VICIO- VICIO- Emission INS-SF6 IN S-SF6 Electric al S F 6 Limit Limit Equipment Establi s h ed 6 Estab l ish ed 6 To t a ls 7 C02 1,070,879 CH, 41 NiO 2 1, 072 , 498
S F6 0.0 00056
I. Co mplian ce wit h the annual emission limits (tons per year) is based on a 12 -mont h rollin g average. 2. The TPY emission limits specified in thi s table are not to be exceede d for this facility an d include emission s from the facil ity during all operations and include MSS activit ies. This total is rounded off fo r estimation purposes to two s ignificant figure s. 3. G lobal Warm in g Potentia ls (GWP): C02 = I , Cl-J4 ,: 25 , N2 0**~** 298, SF6 

### = 22 , 800 4

. Includes emi ssio n s during all operationa l mod es, including purgi ng ventin g associated with the CT and DB sh utdown and maintenance events. CH4 is ve nted via an automatic double bl ock and bleed at the CTG durin g each shutdo wn eve nt. Additionally , CH4 is vented from the du ct burner system each time th e duc t s ar e s hutdown. Annual emissions for th ese activities are included in the annual C0 2 e limit for VIC l 0. 5. Fugiti ve proc ess em iss ions from EPN V JICIO-FUG-NG AS are estimate d to be 1 7.8 TP Y CH4, an d 445 TPY C02e. Fugiti ve p rocess emis s ion totals are for information only and do not constitute an emi ss ion l imit. Th e em ission limit wi ll be a de s ign / work practice standa rd as specified in the permit. 6. SF6 e m iss io ns from EP A VICI O-£NS -S F 6 are es timate d to be 0

. 000056 tpy SF6 and 1 .28 tpy C02e. Fugit ive proce ss emis sio n to ta ls are for informati•on only and do no t constitute an emission limit. The emiss ion limit will b e a design/wor k practice standard as specified in the permit. 7. Tota l s are gi ven for informational purposes only and do not constitute emis sio n limits.



### Pa ge 6of13

### IV. SPECIAL PERMIT CO NDITllONS
A. R equirements for Combustion T 111rbin e Generator and Heat Recovery St eam Generator (EPN: VIClO)


### 1. BACT Em is s ion Limits for EPN: VIClO
T able 2. BACT E mission Limits for EPN: VIClO



# -

Co mb u s tion Co mbu s tio n Duct Burners Output Based MSS Emission Turb i ne Mode l Tu rbin e Ann ual Ann ual Firing Em i ss ion Limit , L i m it 2 •

3 

### Firing Rate 1 

### Rate 1 

### gross bas is 2 (MMBtu/hr) (MMBtu/hr) ( lb COvMWh) (tons C02/hr) (HHV) (HHV) G

E.7 FA.04 or 1 , 816 483 940 108 equival ent 1 

### Limit s are bas e d on a 1 2-month ro lling average, 2 Thi s limi t app lie s with and without duct burner firing durin g normal operati on 3 

### Limit is based o n a 12

- month rolling total.

a . For faci lity operations in a 1 x 1 x 1 plant co nfi gura ti on oper atio n , comp li ance with the output b as ed emission limit shall b e determined by th e followi ng method, The COi 

### ma ss emission val ues s h all b e calculat ed over each o p erati onal hour of th e compl iance p eriod and summe d. Th e sum med hourly C0 2 mass emission va lu es shall b e divided by the summed h ourly total gross elec:trical o utput. Compliance s hall be dem o n s trated on a 1 2- month rolling average . b

. F or fac i li ty ope ratio n s in a 2 x 2 x 1 p lant co nfi gur at i on opera ti on , compli ance w i th th e o u tput b a se d e mi ss ion li mit shall be determined as fo ll ows: 1. 

### The hourly gross e l ectric output from th e ex istin g non-modifi e d steam turbin e sh a ll b e apportione d b ase d on either the measured steam load or measured heat input. A p l an to dem onstrate the apportionment of t h e g ross e l ect ri c output s ha ll be s ubmitted within 60 days after ac hieving the maximum produ ction rat e at which th e affected facility will b e ope rated, but not later than 180 da ys o f the dat e of i nit ial startup of the combustion turbine generator. 11. 

### The C02 mass em ission values sh all be calcul a t ed over each operational hour of t he c o mplianc e pe riod and summed. The summed hourly C02 mass e mission v alue s shall be divided by the combined sum of t he total gross e l ectrica l output fr o m the steam tu rbi ne ( as det e rmined by the co rrespo ndin g apportionment c a lc u lation s repres ented in th e plan) and t h e tot al g ross electrical load from th e c o mbustion turbine generator. T he resulting qu ot ient is added to t he su m of quo tients of th e previous 11 o perating month s and divided by 1 2 to determin e c o mpliance with the 12-m o n th rolling aver age.

c . Upon i nit ial d e m onst ra tion tha t th e combustio n turb i ne com plie s with the e mi ss i on l im it via emi ssi o n tests , the Permittee shall not exceed the combus tio n turbine and duc t burn er annual fi ri ng rate , MMBtu/hr (HHV) from Ta ble 2 on a 12 -month rolling average. To

P age 7of13determine the l imit, the Permit1 tee shall calcula te the average hourly heat input rate over the appl ic ab le compliance period consistent wi th e quation F- 20 and procedure provid ed in 40 CF R Part 75 , Ap pendix F 

### § 5.5.2 and the GCV of the fuel com bu ste d for the corre spondin g com plianc e period

. Add the quotient to the sum o f th e quoti e nts of the p rev ious 11 operating months and di vide by 12 to determine the 12-month roll i ng average . d

. The Per m ittee shall n o t di scharge or cause 

### the di sc harge of emiss ion s into the atmosphe re in exces s of th e lim its in tons of C02e o n a 1 2- m onth rolling tota l as l i ste d in Table 1. e. The duc t burne rs are limit ed t o 4 , 3 75 hour s of operation per year. 

### f. Startup a nd Shutdown events are limit ed to 1 , 000 h ou rs 

### per year and shall co mpl y with the MS S BACT emissio n limit of 108 ton s C02 p er hour on a 1 2- m o nth rolling total basis.
2. Emiss ions Monitoring for**EPN~** VIClO

a. U pon initi al demo nstration that the combu s tion turbine complies with the emissio n s limit v i a emi ss ion test s, th e Permittee 

### shall not ex ceed the C02e annual e mi ss ion limit from Table 1 du ring no rmal operation . To determine the amo unt of C02e, the P errnittee shall calcu lat e the amount of C02, CH4 and N 2 0 io sho rt tons per month based on the equati o n G-4 of 40 CF R Part 75 , Appendi x G and 40 CFR Part 98, Append i x C, and the monthly hours of operation on a 12-mo:nth rolling total. The Perrnitt ee s hall also us e the default Cl-14 and N10 e missio n factors contain ed in Ta ble C-2 of 40 CFR Part 98 and the measured actual hourly heat input ( HHV) to d etermine compl iance with the CH4 and N2· o emission limits

. The s hort ton s per month val u es are multipli e d by the respective Global Warming Po te n tial s (GWP ) contained i n the Greenhouse Ga s Reg ul ation s, 40 CFR P art 98, Subpart A, Tab le A-1 to calcul ate th e amount of CChe emitted in s h ort TPY

. The resultin g C02 e value is added to th e pre viou s l l months to de termine the 12 month rolling to tal of C 0 2e emiss ion s. b. As an al tern at i ve, the Permittee may in sta ll and operate a volumetric stack gas flow monitor and assoc iate d data acquisition and handling system in accordance with the C0 2 CEMS sys tem provided 

### in 40 CFR 75

. 1 O(a)(3) and (a)(5). 

### If a C02 CEMS system is utilized , the hourly C02 emission value s hall be measured b y in s talling a nd operating a volu me t ric stac k gas flow monitor or ca lculating the volumet ric stack g a s fl ow by tbe procedures of 40 C FR 75, Appendix D an d as sociated data acquisition and handlin g system i n accordance w ith the C0 2 CEMS syste m provided in 40 CF R 

### § 75. l 0. c. In accordance wi th 40 CFR P art 75, Appendix D a nd 40 CFR Part 60, the Permittee sha ll ens ure that a ll req uired fu el flow m eters are installed , a periodic sc h edule for GCV fuel sampling is initiate d and a ll ce:rtification tests are completed on or b efore the earlier of 90 unit op eratin g day s or 180 calcmdar day s after the date the unit commences commercial operati on (as defined in 40 CFR 

### § 72 .2). d. The Permittee s hall ensure compliance with the s pecifications and test procedures for fuel flow m e ter and/or C02 em i ss io n m onitori ng system at stationary so urces, 40 CFR P art 75 and 40 C FR Part 60. e . The Permittee s h all meet the appropriate quality assurance requirement s spec ified 

### in 40 CFR P art 75 , Appe nd ixes D an d F and 40 CFR P art 60 for the fuel flow meter and/ or C02 emi ss ion monitoring system.

Page 8of13

### 3. Work Practic e and Operational Requirements for E P N : VIClO

a. The combined cycl e com bu stion turbine and duct burners are l im ited to burning o nly natural gas . The g ross calorific: value of the fu e l s hall be determine d monthly by the procedures contained in 40 CFR Part 75 , Appendix F, § 5.5.2 , and records shall be mai ntained of th e monthly fuel gross ca lorific value for a peri od of five yea r s. Upon reques t, t he Permittee shall p rovi de a samp l e and/or analysis of the fue l fired in the combustion turbine and/o r duc1 b urn ers or shall allow a sample to be taken b y EPA for analysis. b. The fl ow rate of the fuel combusted in the combustion turbine and d u ct burners s h a ll be measured and recorded using an in

- line flow meter and automatically r ecord the data with a d ata acquisition and handling; s ystem . T he steam load and/or heat input to the steam turbine sha ll a l so b e measured and re cord e d. c. The Permittee sha ll measure and re cord the energy output of th e apport i o ned s team turb ine a nd combus ti on turbine (MWh , gross) on an hourl y basis

. d. On or before the date of initial p erformance test required by 40 CFR 

### § 60.8, and

•'- A ,.., n**,,j.4. ~**  1**11** • • t1 , • • 1 • ' • • • · '

.. ....---- 

### tnefeaaef, lne r emuuee s nau m siau, ana contmuous1y operate, ana mamtam tne**HK ~Us**  equipped with a SCR and oxidation cata lyst so emissions are at or b e low the emission s lim its specified in this permit. e. The Permittee shall perform a01 annual compliance-test , -at or above 

### 90% of maximum l oad operations and cond ucted unde r s uch cond iti o n s to e nsure representative performance of the affected facility

. The co nditions of the perform a n ce tests shall be recorded and ma d e availa bl e for review upon request. f. On o r after initial performance testing , the Permittee s hall use BACT practices and des ig n s repr esented in the pem1it app li cation.


### 4. Requirements during S tartup andl Shutdown for E P N: VIClO

a. Permittee sha ll minimize emiss i ons during startu p and shutdown activities by operating and maintaining the facility and associated a ir pollution control e quipm ent in accordance with good air pollution c ontrol practice s, safe operating practice s, and protection of th e facility. b. Emissions during startup and slhutd own activit ies s h a ll be minimi ze d by limiting the duration of operation in start u p and shu tdown mode as follows: 1. A s tartup ofEPN: VIClO is initiated w h e n the Data Acq ui sit i on and Handlin g System (DAHS) detect s a flame s i g na l (or equ i val ent signal) and end s w h en the permissive s for the emission co n tro l system are met (i.e., steady state emission s compliance is ac hieve d) . A startup fo r the combustion tu rbi n e i s limited to 10 hour s (co ld s tartup) p er event. 11. A sh u tdown ofEPN: VIC l 0 b eg ins when the load drops to the point at which steady state e missions co mplian ce can no lon ger be assured and ends w hen a flame-off signal is detected. A shu td own for the combustion tur bi ne i s limited to 60 minu tes per event. m. Start-up and S hu tdown eve nts a r e limited to 

### 1,000 hour s p er year. c. Permittee mu st reco r d the 1ime , date , fue l heat input ( HH V) in mmBtu/hr and duration of eac h startup and shutdown event in order to calc ul a ted the total C0 2e emiss i ons. The records must include h ou rly C02 emission leve l s as measured by th e

Page 9of13fuel flo w meter (or C02 CEMS with volumetric stack ga s flowrate) and the calc u lations based on the actual heat input for the C02, C02e, N 10, and CH4 emi s sions during each startup and shutdown event based on the equations represented in th e permi t application. These record s must be kept for five (5) years fo llowing the date of such event. d

. During sta rtup and shutdown,**<~missions** from EPN: V I C 10 sha ll compl y w ith all provisions of BACT emission limitations in Special Condition IV.A. 

### l.
B. Requ irements for Fugitive Ellllissions EPNs: VlClO-FUG

- NGAS and VIC10

- INS-SF6
l. The Pennittee shall implement and auditory/ visual/ olfactory (A VO) method for detecting leaking from natural gas piping components, and make observations on a daily basis. 2

. for emission unit FUG-SF6, SF6 emissions shall be calculate d annuall y (calendar year) in accordance with the mass balance approach provided in equation DD- I of the Mandatory Greenh o u se Gas Reporting rules for Electrical Transmission and Distribution Equipment Use, 40 CFR Part 98, Subpart DD. Perrnittee shall not exceed insulated circuit breaker SF6 cap ac ity of 23 lb s. 3. Permitt ee shall equip the circuit breakers with a low pressure alarm and a low pressure lockout. The Sf 6 leak detection system shall be able to detect leaks. 4. Permittee shall maintain a file of all records, data measuremen ts, reports and documents related to the fugitive emission sources including , but not limited to , the following: all records o r reports pertaining to maintenance performed, all r e cords relating to compliance with the Monito r ing and Quality Assurance and Quality Control (QA/QC) procedures outline s in 40 CFR 

### § 98.304.
V. RECORDKEEPING AND RE JPORTIN G
A. In order to demonstrate compliance with the GHG e mission li mi ts in Table 

### 1 , the Permittee will monitor the following parameters and summarize the data o n a calendar month ba sis. 1. Operating hours for all air emission sources ; 2. Th e natural gas fuel usag 1e for a ll combustion sources , u sing continuous fuel flow m on itors (a group of equipment can utili ze a common fuel flow meter, as long as actual fuel usage is allocated to the individual equipment based upon actual operating hours and maximum firing rate) ; and 3. Annual fuel sampling for natural gas. B. Permittee s hall maintain a file of all records , data , measuremen ts, reports, and document s r e lated to the operation of the facility , including, but not limite d to, the following: all records or repo rts pertaining to significant maintenance perform e d on any system or device at the plan t; duration of startup, shutdown; the initial startup period for the emission unit s; pollution co ntrol units ; malfunctions ; all records re l ating to performance tests , calibrations , checks, and monitoring of combiustion equipment; duration of an inoperative monitorin g device and emission units with the required corresponding emission data; and 

### all other information required by this pennit recorded in a permanent form suitable for i nspection. The file must be retained for not le ss than five yea rs following the date of such measurements, maintenance, reports , and/or record s.

Page 10of13C. Permittee sh all m ainta in r ec ords and submit a written report of all exce ss emissions to E PA se mi-ann ual l y , except w h en: mor e .frequent r ep o rting is specifically required by an applicable s ubpart ; or the Admini:strator or authorized represe ntative , on a case -by- case bas i s, determines that more frequent re porting is ne cess ary to accurately a ssess the co mpliance sta tus of the source . The report i s due on the 30 th day following t h e end of each se mi-annu a l period and shall includ e the following:


### 1. Time interv al s, data and magnitude of the excess emiss i ons, the nature and c au se ( i f known), corrective actions take n and preve ntive m e asure s adopted; 

### 2. Applicable time and d ate of ea4ch period during whic h th e monito ri ng equipment was inoperative (m onitorin g down-ti m e); 3. A stateme nt in the report of 

### a n egative declaration ; that is; a statement wh en no excess e mi ssions occurr ed or wh en the monitoring equipment h as not been inop erative, rep ai red or adj usted; 4. Any failure to conduct any required source testin g, monitoring , or other compliance 

### acti vi ties; and 5. Any violat ion of limitatio ns on ope ra t ion

. 

### D. Exce ss emissions s hall b e defined as ruzy 

### period.in_ which the facility emi ssi ons exceed a maximum emiss i o n limit se t forth in t his p ermit, or a malfun ction occurs causing an e mission s e xceedance.
E. Excess emiss ion s ind icated by GHG emiss io n perfo rmanc e testing or co mpli ance monitorin g sha ll be consid e red v ] [olations of the applicable emission limit for the purpose o f th

i s permit.
F

. In st rument s and monitoring systems require d by thi s PSD p e rmit shall have a 95% on strea m time on an annua l bas i s . G. All record s require d by thi s PSD Permit shall be retained for not les s than 5 years foll owin g th e date of s uch m e asurem e nts, mainte na nce, and reportjng

. 

### H. Co ntinuou s l y means indiv idual me as urement no le ss frequent than once every 

### 15 minutes

. E l ect ron ic d ata m ay be reduced to hourl y averages fo r recordkeeping purpo ses. 

### VI. SHAKEDOWN PERIODS
T he combust ion turbine emissi o n limit s and requirements in Co ndition s 

### III and 

### IV .A. 

### l s hall not apply during co mbu stion shakedown periods

. Shakedown is de fined as the period beginnin g wi th initia l s tartup and ending no l ater than initial p e r fo rman ce testing , durin g which the Perrnittee conducts oper atio nal and contrac tual testing and tuning to e nsur e the safe , efficien t and reliable operation of th e plant. The shakedown period s h a ll not exceed the time period for performance testin g as specified in 40 CFR § 60.8

. T h e requiremen ts of s pec ial condition I.C

.

Page 11of13VII. PERFORMA NCE TESTING
A

. Within 60 days after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days of the date of initial startup of the combustion turbine generators, the Permittee :shall perfonn an initial emission test for C02 and use emission factors from 40 CFR Part 

### 98. The Permittee shall ensure that GHG emissions from the Combustion Turbine Generator and heat recovery steam generator in to the atmosphere do 

### not exceed the limits in lbs C02/MWh (gross) from Tab le 2 during the test. To determine this BACT emission limit, Permittee shall calculate the limit based on the measured hourly energy output (MWh (gross)), the: CTG is operating at, or above 90% of its design capacity with duct burner firing and the results shall be corrected to ISO conditions (59°F, 14.7 psia , and 67% h um idity). Sampling shall be conducted 

### in accordance with 40 CFR 

### § 60.8 and 

### E

PA Method 3a or 3b for the concentration of C02.
1

. Multipl y the C02 hourly average emission rate determined under maximum operating test conditions by 

### 8, 760 hours for the combustion turbines and 4,375 hours for the duct burners. 2. If the above calculated C02 emission total do es not exceed tbe tons 

### per year (TPY) specified in Table 1, no compliance strategy needs to be developed. If the above

- calculat e d C02 e m issiontotal exceeds- t he tons peryem.r (TPY) specified

-in Tab le 

### 1, the-- facility sha ll: a . Document the potential to exceed in the test report; and b. E xp l ain within the report how the facility will assure compliance with the C02 emission limit listed in Tab l e 

### 1
. B. No later than 180 days after initial start-up, or restart after modification of the facility, performan c e test( s) must be conducted and a written report of the performance testing results fumished to the EPA with 60 days after the testing is completed. During subsequent operations, stack sampling shall be performed within 120 days if current production rates exceed the production rate during stack testing by 10 percent or greater, additional sampling may be re q uired by TCEQ or E PA

. C. Permittee s hall submit a performance test protocol to EPA no later than 30 days prior to the test to allow review of the test 

### pl21n 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. The owner or operator must provide ' the EPA at least 30 days prior notic e of any performance**k~st,** except as specified under other subparts, to afford the EPA the o p portunity to have an observer present and/or to attend a pre-test me eting. If there is a delay in the original tes t date, the facility must provide at least 7 days prior notice of the rescheduled date of the performance test.
D. Performanc e tests must be conducted at or above 90% of maximum load operations for the atmospheri c conditions which ex).st during testing. The duct burners shall be tested at their maximum fi ring rate within the mechanical limits of the equipment for the atmospheric conditions which exists during the performance test while the turbine is operating as close to base load as possible. The tested 1turbine load shall be identified in the sampling report. The permit hol de r shall present in the performance test protocol the manner in which stack

Page 

### 12of13

### sampling wi ll be executed in order to de m o n st rate co mpliance w i th the em i ssio n limits co ntained in Section 11

. E. A ir emissions from th e HRSG exhaust stack s hall be tested while firing at the minimum no rma l operating load (minimum normal load above 50 percent). The normal operating range cons is tent with em issio n limits is to be determined during stac k testing. Air emi ss ions that will be sampled a nd ana lyze d while at the minimum load in c lude (b ut are not limited t o) 

### C 0 2 to c har acteri ze the em i ssio n s at this load.
F. Perfo rman ce tests mu st be conducted under such co ndi t ion s to ensure represe ntative performance of the affected facility. The owner or operator must make avail ab le to EPA such records as may be neces sary to dete rmine the conditions of the performance tests. G. The owner or operator shall provide , or cause to b e provided , performance te s ting facilitie s as follows:

1**~-:::timnlinn T\** **l"\ ri** **~ adon** **u~t o**  f'rvr• io • .. + _..,o. f&..i l'"'\,.J,... n --t: ,..,.,, i..1

- ·- .t...:

... ..c
........**:1: ~**  . • • LJ

.......y
.. u5 pv1 '" 

### "''i" '""' lV.L L\, ;)L Ul \,; LU VU;) appu\.aUJI:' LU Uil::> H:l\.J!I L J, 

### 2

. Safe samplin g platform (s), 3. Safe access to sampling platform(s), and 4

. Utilities for 

### samp ling and testing equipm e nt.
H. Un less otherwise spe cified , each performance tes t s hall consist of three se parate runs usin g the appl i c a bl e test method. Each run shall be co nducted for the time an d under th e con dition s spec ifi ed in the applicable s tand ard. For purposes of determ i n in g compliance with an app l foable s tandard , the a: rittun e ti c mean of the resu lts of the three runs shall apply

. VIII. AGENCY 

### N OTIFI CAT ION S
Permittee shall submit GHG permit applications , pennit amendments , and othe r app licabl e permit informa ti on to: Multimedia Planning and Permittin g Division EPA Region 6 1 445 

### Ros s Avenue (6 P'D-R) Dallas , TX 75 202 E mail : Group R6AirPermit s@E PA.gov
Pennirtee shall s ubmit a copy of all complianc e an d e nforcement correspondence as required 

### by this Approval to Construct to : Complianc e Assurance and Enforcement Division E PA Region 6 1 445 

### Ross Avenue (6EN) Dalla s, TX 75202

Pag e 13of13

### Victoria WLC, L.P., Victoria Power Station Prevention of Significant Deterioration Permit for Greenhouse Gas Emissions
PSD-TX-1348-GHG

Summary of Revisions And Responses to Public Comments

U.S. Environmental Protection Agency, Region 6 October 3, 20142 

### Table of Contents I. Summary of the Formal PublicParticipation Process...........................................Page 3 II. EPA’s Responses to Public Comments............................................................Page 3 III. Revisions in Final Permit...........................................................................Page 6 IV. National Historic Pres ervation Act (NHPA)......................................................Page 63 

### I. Summary of the Formal Public Participation Process The U.S. Environmental Protection Agency, Regi on 6 (EPA) proposed to issue a Prevention of Significant Deterioration (PSD) permit to Victoria WLE, L.P. (Victoria), Vi ctoria Power Station on August 12, 2014. The public comment period on the draft permit began August 12, 2014 and closed on September 11, 2014. EPA announced the public commentperiod through a publicnotice published in the Victoria Advocate on August 12, 2014 and on Regi on 6’s website. EPA also notified agencies and municipalities on August 11, 2014 in accordance with 40 CFR Part 124. The Administrative Record for the draft permit was made available at EPA Region 6’s office. EPA also made the draft permit, statement of basis and other supporting documentation available on Region 6’s website, and at the Victoria Public Library, Victoria, Texas. EPA’s public notice for the draft permit also providedthe public with notice of the public hearing explaining that it was subject tocancellation if no requests for a hearing were received or if EPA determined that there was not a significant degree of public interest. EPA did not receive any written requests for a public hearing, and the public hearing arrangements were cancelled on September 5, 2014. EPA received written comments from the permit applicant on September 5, 2014, which we respond to below. II. EPA’s Response to Public Comments This section summarizes the comments received byEPA from the permit a pplicant and provides our responses. 1. Comment: Page 19 of the statement of basis reads: “VPS is subject to all applicable requirements for fuel flow monitoring and quality assurance pursuant to 40 CFR Part 75, Appendix D, which include: • Fuel flow meter shall meet an accuracyof 2.0% and is required to be tested once each calendar quarter pursuant to 40 CFR Part 75, Appendix D §§ 2.1.5 and 2.1.6(a).” (emphasis added). 40 CFR Part 75 Appendix D § 2.1.6, Quality Assurance, reads: (a) Test the accuracy of each fuel flowmeter prior to use under this part and at least once every four fuel flowmeter QA operating quarters, as defined in § 72.2 of this chapter, thereafter. Notwithstanding these requirements, no more than20 successive calendar quarters shall elapse after the quarter in which a fuel flowmeter was last tested for accuracy without a subsequent flowmeter accuracy test having been conducted. Test the flowmeter accuracy more frequently if required by manufacturer speci fications. (emphasis added). Since the rule requirement for QA testing is onc e every four fuel flowmeter QA operating quarters, why will Victoria have to completetesting once each calendar quarter? Victoria requests that QA testing be required once every four fuel flowmete r QA operating quarters as defined by 40 CFR Part 75 Appendix D § 2.1.6

.4 

### Response: The definition of “QA operating quarter” as used in Part75, Appendix D, is provided at 40 CFR § 72.2 and means: “a calend ar quarter in which there are at least 168 unit operating hours... or, for a common stack or bypass stack, a calendar quarter in which there are at least 168 stack operating hours....” The project is described as a ba se-load electric power generation unit and the supporting calculations for the BACT emission limits are based on 7,760 hours per year of normal operation and 1,000 hours per year of maintenance, startup and shutdown. With baseload operations, EPA anticipated that the QA operating quarter and calendar quarter would co incide with each other and therefore had not differentiated them in the portion of the statement of basis cited by the comment. The language of the draft permit appropriately proposed that the Permittee be required to meet fuel flow meter requirements specifiedin 40 CFR Part 75, Appendix D, and with the clarification provided here, we have determined no changes to final permit language are needed as a result of this comment. 2. Comment: Page 19 of the statement of basis reads: “An initial stack test demons tration will be required for CO 2

### emissions from EPN: VIC10. VPS proposes to demonstrate compliance with the proposedheat rate with an initial compliance test at or above 90% load (corrected to ISO conditions) and subsequent annual testing . The conditions of the performance demonstrati on tests shall be conducted under such conditions to ensure representative performance of the affected facility and shall be recorded and made available for review upon request. VPS will demonstrate compliance with the proposed heat rate with an annual compliance test at or above 90 pe rcent load, corrected to ISO conditions . An initial stack test demonstration for CH4

### and N 2 

### O emissions is not required because the CH 4

### and N 2 

### O emissions comprise approximately 0.01% of the total CO 2 

### e emissions from the combustion turbines.” (emphasis added) We request that annual testing not be required for continuous compliance demonstration of the proposed heat rate. VPS proposed to demonstrate compliance with the heat rate by testing within 90 days after the completion of each gas turbine ma jor maintenance inspection. Is there any reason why annual testing is proposed in the draft permit ? Response: The permittee will be operating the proposedfacility over various load ranges (between 50%-100% load) with 1,000 hours per year of startup and shutdown events. A 10 percent compliance margin was added to the base heat rate limit to account for variations in margins associated with design, performance and degradation. Referenced literature notes that the original gas turbine power and efficiency can be expected to progressively decline a few perc entage points, and then stabilize, as the result of normal wear and tear. With these expected performance changes under normal operations, it is important for the permittee to measure and provide a continuous demonstration of compliance with the BACT limit prescribed by the permit. The annual performance test will provide a point for reference (at 90 percent loading) to compare the calculations relying on measured fuel combustion and emissions factors withthe demonstrated performance testing results. The results of the test will inform the permittee and EPA of the source’s ability to comply with the5 

### CO 2

### emission limit at the maximum normal operating scenario. Further, terms that are equivalent to Special Condition IV.A.3.e have been consistently applied to other GHG permits issued by EPA Region 6 for similar facilities. See, for example, La Paloma Energy Center (PSD-TX-955-GHG), Pinecrest Energy Center (PSD -TX-1298-GHG), Lon C. Hill Power Station (PSD-TX-955-GHG) and Austin Energy (PSD-TX-1012-GHG). Special Condition IV .A.3.e, is not changed in the final permit.
3. Comment: Page 20 (IX Process Fugitives Step3) of the statement of basis reads: “However, since pipeline natural gas is odorized with very small quantities of mercaptan, AVO observation is a very effective method for identifying and correcting leaks in natural gas systems.” Natural gas fired at Victoria does not necessarilyhave to meet the § 72.2 definition of pipeline natural gas. Response: We agree with the comment, and it is c onsistent with the absence of terms and conditions in the draft permit that would require use of pipeline natural gas. The comment is also consistent with an earlier-provided chemical composition analys is for the natural gas proposed to be used that is part of our administrative record. The analysis provides the following information:

We do not understand this comment to suggest that gas would not be odorized with mercaptan, and thus the associated BACT discussion remains vali d. We believe no changes to the final permit are needed in response to this comment requesting clarification.
4. Comment: Page 22 (XI SF6 Emissions from Electrical Equipment Insulation Leaks Step 5) reads: “An LDAR program to identify and repair leaks and leaking equipment as quickly as possible;....” LDAR is not a technology discussed in Step 1 of the BACT analysis. VPS has proposed to use circuit breakers with totally enclosed insulation systems equipped with a temperature compensated density monitor that alarms, and if pressure drops sufficiently, prevents the closing or opening of the circuit breaker. Therefore we do not believe LDAR should be imposed

.6 

### Response: We agree that the stray reference to LDAR in the Step 5 of the BACT discussion for the SF 6

### circuit breakers was misplaced and not discussed an earlier parts of that BACT analysis. The terms of the draft permit appropriately specify that daily AVO monitoring applies to natural gas piping components, while the circuit breakers shall be equipped witha leak detection system that includes a low pressure alarm and a low pressure lockout. See Special Condition IV.B.1. While LDAR merely stands for “leak detection and repair ,” we understand that special usages for the term may not apply to SF 6

### circuit breakers. It remains the case, however, that repair efforts would be expected for any leaking, malf unctioning circuit breaker. See Sp ecial Condition IV.B.2-3. We note the permit elsewhere requires that maintenance be consistent with “ good air pollution control practice for minimizing emissions.” See Section I.C. We do not believe any changes to the final permit are warranted as a result of this comment. III. Final Revisions to the Permit No changes were made to the final permit of the Vi ctoria WLC, L.P., Victoria Power Station (PSD-TX1348-GHG)
IV. National Historic Preservation Act (NHPA) On July 9, 2014, EPA sent a letter to the State Hi storic Preservation Offi cer (SHPO) requesting concurrence on EPA findings for Victoria’s cultural survey. The SHPOsent concurrence to the EPA on July 14, 2014.Victoria Power Station

Proposed Standards VIC10 Victoria will operate with the existing unit (VIC7), the new unit (VIC10), and the existing ST in a 2x2x1 configuration. Both CTs (VIC7 and VIC10) will supply steam to t he ST. Victoria could also potentially operate in a 1x1x1 configuration with either CT (VIC7 or VIC10) in combination with the existing ST. Because only one CT will contribute to steam production, the ST will not be able to achieve its full capacity in a 1x1x1 configuration. Since VIC7 is an existing unit, it is not subject to a CO 2 output-base emission rate; therefore, this analysis is required only for VIC10. During operation in the 2x2x1 configuration, it is necessary to separate the emissions a nd power generation contribution of VIC10 from that of VIC7 to obtain a VIC10-specific output-based emission rate. Compliance with the proposed CO2 output-based BACT emission rate limit (940 lbCO2/MWh) will be demonstrated on a 12-month rolling average and gross basis. This limit applies only during full load with and without supplemental duct burning. The lb/MWh BACT limit does not apply during part load maintenance, startup or shutdown (MSS) periods. VIC10 MSS emissions will be limited to 108 ton CO2/hr on a 12-month rolling average basis. Proposed Output-Based Emission Rate (Full Load)
Unfired Fired Proposed VIC10 CTG Nominal Gross Output (1) MW 177.3 177.3 STG Gross Output attributed to VIC10 (2) MW 89.8 101.5 Max. Heat Input (HHV) (3) MMBtu/hr (HHV) 1,816 2,088 Compliance Margin (4) % 10.0% 10.0% Annual Hours of Operation (5) hr/yr 3 ,385 4,375 7,760 Heat Rate, Gross Basis (6), (7) Btu/kWh (HHV) 7 ,480 8,240 7,908 CO 2Emission Factor (8) lb CO2/MMBtu (HHV) 1 18.9 118.9 118.9 CO 2Output-Based Emission Rate, Gross Basis (9) lb CO2/MWh 8 89 979 940 Notes: (1) Estimated units output per vendor and actual data. Final values may vary depending on final design and ambient temperatures: Mitsubishi 501F (VIC7) = 177.3 MW General Electric 7FA.04 or equivalent (VIC10) = 177.3 MW General Electric D5 Steam Turbine Unfired (ST) = 173.3 MW

Duct Fired Capacity (total both units) = 11.7 MW (2) ST Gross Output attributed to VIC10 has been estimated based on VIC10 Gross Output and 2012 actual heat balance data for current configuration with VIC7.

VIC7 CT ST

(operating with VIC7) Avg. Gross Capacity CY 2012 165.3 MW 83.7 MW ST Gross Output attributed to VIC10 (Unfired) = ST Gross Output operating with VIC7 * VIC 10 Gross Output / VIC7 Gross Output ST Capacity Operating with VIC10 (Unfired) = 83.7 MW * 177.3 MW / 165.3 MW = 89.8 MW ST Gross Output attributed to VIC10 (Fired) = ST Gros s Output operating with VIC7 * VIC 10 Gross Output / VIC7 Gross Output + DB Gross Output ST Capacity Operating with VIC10 (Fired) = 83.7 MW * 177.3 MW / 165.3 MW + 11.7 MW = 101.5 MW (3) Maximum Heat Input: CTHeat Input (HHV) = 1,816 MMBtu/hr (manufacturer data) DB Heat Input (HHV) = 483 MMBtu/hr (manufacturer data) Max. Heat Input (HHV) (Fired) = CT Heat Input * Unfired Hours of Operation + (CT + DB) Heat Input * Fired Hours of Operation / Total Hours of Operation Max. Heat Input (HHV) (Fired) = [ 1,816 MMBtu/hr * 3, 385 hr/yr + (1,816 MMBtu/hr + 483 MMBtu/hr) * 4,375 hr/yr ] / [3,385 hr/yr unfired + 4,375 hr/yr fired] = 2,088 MMBtu/hr (4) Compliance margin is an adjustment factor to the design rates to arrive at the proposed efficiency standards. It includes a margin to reflect actual vs. design differences, degradation between maintenance overhauls, and degradation of plant auxiliary equipment. Design Margin = 2.0% Performance Margin on CTG and STG = 5.0% Degradation Margin for the Auxiliary Plant Equipment = 3.0% (5) Estimated annual hours of operation are based on engineering knowledge of the plant performance but are not intended to contractually limit Victoria operation. Victoria will meet the proposed output-based CO 2emission rate on a 12-month rolling average and gross basis, independently of the final hours running in each of the operational modes. A nnual Hours of Operation Unfired = 3,385 hr/yr Annual Hours of Operation Fired = 4,375 hr/yr

Annual Startup Hours = 1,000 hr/yr (6) Heat Rate (Btu/kWh) = Heat Input (MMBtu/hr) * 1,000,000 Btu/MMBtu / (VIC10 Output + STG Output attributed to VIC10 ) (MW) * 1 MW / 1,000 kW * Comp. Margin Heat Rate (Unfired), Gross Basis = 1,816 MMBtu/hr * 1,000,000 Btu/MMBtu / (177.3 MW + 89.8 MW) * 1 MW / 1,000 kW * 1.10 = 7,480 Btu/kWh (HHV) Heat Rate (Fired), Gross Basis = 2,088 MMBtu/hr * 1,000,000 Btu/MMBtu / (177.3 MW + 101.5 MW) * 1 MW / 1,000 kW * 1.10 = 8,240 Btu/kWh (HHV) (7) Proposed Heat Rate (Btu/kWh) = [ [HR (Btu/kWh) * Annual Op (hr/yr)] Unfired+ [HR (Btu/kWh) * Annual Op (hr/yr)] Fired ] / [Annual Op (hr/yr) Unfired+ Annual Op (hr/yr) Fired ] P roposed Heat Rate = [7,480 Btu/kWh * 3,385 hr/yr + 8 ,240 Btu/kWh * 4,375 hr/yr ] / 7,760 hr/yr = 7,908 Btu/kWh (8) CO 2emission factor calculated per 40 CFR Part 75, Appendix G, Equation G-4, as referenced in §98.43(a), where: C arbon based F-factor, F C : 1 ,040 scf/MMBtu Standard Molar Volume: 385 scf/lbmole Molecular Weight CO 2 , MW CO2 : 4 4 lb/lbmole CO2 Emission Factor = 1,040 scf/MMBtu / 385scf/lbmole* 44lb/lbmole = 118.9 lb/MMBtu (9) CO 2 Emission Limit (lb CO2/MWh) = Heat Rate (Btu/kWh) * 1MMBtu/1,000,000 Btu * CO 2Emission Factor (lb CO2/MMBtu) * 1,000 kW/MW C O2 Output-Based Emission Rate (Unfired), Gross Basis = 7,480 Btu/kWh * 1 MMBtu/1,000,000 Btu * 118.9 lbCO2/MMBtu * 1,000 kW/MW = 889 lbCO2/MWh CO2 Output-Based Emission Rate (Fired), Gross Basis = 8,240 Btu/kWh * 1 MMBtu/1,000,000 Btu * 118.9 lbCO2/MMBtu * 1,000 kW/MW = 979 lbCO2/MWh CO2 Output-Based Emission Rate (Fired), Gross Basis = 7,908 Btu/kWh * 1 MMBtu/1,000,000 Btu * 118.9 lbCO2/MMBtu * 1,000 kW/MW = 940 lbCO2/MWh

Parameter U nits VIC10 (Full Load, Gross Basis)

Victoria Power Station A-1 Application for GHG PSD PermitVictoria Power Station

Proposed Standards VIC10 Proposed MSS BACT Limit Parameter Units VIC10 Max. Heat Input (HHV) (1) MMBtu/hr (HHV) 1,816 CO 2Emission Factor (2) lb CO2/MMBtu (HHV) 1 18.9 CO 2Emission Rate Limit (SU/SD) (3) ton CO2/hr 1 08 Notes: (1) Maximum heat input per manufacturer data (2) CO 2emission factor calculated per 40 CFR Part 75, Appendix G, Equation G-4, as referenced in §98.43(a), where: C arbon based F-factor, F C : 1 ,040 scf/MMBtu Standard Molar Volume: 385 scf/lbmole Molecular Weight CO 2 , MW CO2 : 4 4 lb/lbmole CO2 Emission Factor = 1,040 scf/MMBtu / 385scf/lbmole* 44lb/lbmole = 118.9 lb/MMBtu (3) CO 2Emission Rate Limit (SU/SD) (ton/hr) = Max. Heat Input (MMBtu/hr) * CO 2Emission Factor (lb CO2/MMBtu) * 1 ton / 2,000 lb CO2 Emission Rate Limit (SU/SD) = 1,816 MMBtu/hr * 118.9 lb/MMBtu * 1ton/2000lb = 108 ton/hr

Victoria Power Station A-2 Application for GHG PSD Permit