PREVENTION OF SIGNIFICANT DETERIORATION PERMIT 

FOR GRE ENHOUSE GAS EMISSIONS 

ISSUED PURSUANT TO THE REQUIREMENTS AT 40 CFR § 52.21 

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 6 

PSD PERMIT NUMBER: 

PERMITTEE: 

FACILITY NAME: 

MAILING AD:ORESS: 

FACILITY LOCATION: 

PSD-TX-1348-GHG 

Victoria WLE, L.P. 

Victoria Power Station 

919 Milam Street, Suite 2300 

Houston, TX 77002 

1205 Soutl~ Bottom Street 

Victoria, TX 77901 

Pursuant to the 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 Plan 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) permilt 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 application (and plans submitted with 

the permit application), the federal PSD regulations at 40 CPR§ 52.21, and other terms and 

conditions set forth in chis PSD permit in conjunction with the corresponding Texas Commission 

on Environmental Quality (TCEQ) PSD permit No. PSD-TX-1348. Failure to comply with any 

condition or term set forth in this PSD Permit may result in enforcement action pursuant to 

Section 113 of the Clean Air Act (CAA). This PSD Permit does not relieve VPS of the 

responsibility to comply with any other applicable provisions of the CAA (focluding applicable 

implementing regulations in 40 CFR Parts 51, 52, 60, 61, 72 through 75, and 98) or other federal 

and state requirements (including the Btate PSD program that remains under approval at 40 CFR 

§ 52.2303). 

In accordance with 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. 

Date 
Victoria WLE, L.P. (PSD-TX-1348-GHG) 

Prevention of Significant Deterioration Permit 

For Greenhouse Gas Emissions 

Permit Conditions 

PROJECT DESCRIPTION 

Pursuant to the provisions of this permit, Victoria WLE, L.P. (Victoria) will carry out a major 

modification at the existing Victoria Power Station (VPS) located in Victoria, Victoria County, 

Texas. The existing VPS is a natural gas-fired combined cycle base load power generating 

station that currently operates in a 1 by I by 1 (1 x 1 x 1) configuration (one combustion 

turbine, one HRSG and one steam turlbine) with a gas turbine (M50 lf), heat recovery steam 

generator (HRSG) equipped with duc1t burners and a steam generator (General Electric 05). The 

project would add a new gas turbine (GE.7FA.04 or equivalent) and HRSG equipped with duct 

burners. After these additions, the facility will be able to operate in a natural gas-fired combined 

cycle generating unit in a 2 by 2 by l (2 x 2 x 1) configuration (two combustion turbines, two 

HRSG and one steam turbine) that utilizes the existing non-modified M501 F combustion 

turbine and HRSG and the existing non-modified steam turbine. The VPS plant is authorized to 

operate in a 1 x 1 x 1 combined cycle configuration with the new gas turbine and new HRSG, 

and it retains ab11ity to operate in Tts orTglnal 1 x 1 x 1 combined cycle configuration-without an 

assigned GHG BACT limit. VPS operations covered by the permit will consist of the following 

sources of GHG emissions: 

• Natural Gas-Fired Combined Cycle Combustion Turbine (GE.7F A.04 or equivalent). The 

combustion turbine is equipped with a heat recovery steam generator (BRSG) and duct 

burners, dry low NOx (DLN) combustion system, and selective catalytic reduction 

(SCR), and oxidation catalyst; 

• Process Fugitives; and, 

• Electrical equipment insulated with sulfur hexafluoride (SFG). 

EQUIPMENT LIST 

The following devices are subject to this GHG PSD permit: 

FIN EPN Description 

Natural Gas-Fired Combined Cycle Combustion Turbine 

VIC IO YIClO (GE.7FA.04 or equivalent). The combustion turbine is equipped 

with heat recovery steam generator (HRSG) and duct burners, 

dry low NOx (DLN) combustion system, and selective catalytic 

reduction (SCR), and oxidation catalyst. 

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VlClO-FUG- VIClO-FUG- Process Fugitives 

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 §52.21 (b )(9)) within 18 months after the 

approval takes .effect; .or: 

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

3. is not completed 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 extension is justified. 

B. PERMIT NOTIFICATION IIBQUIREMENTS 

Permittee shall notify EPA Region 6 in writing or by electronic mail of the: 

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

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

of such date; and 

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

provisions of Section V, 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 Condition V .B. 

C. FACILITY OPERATION 

At all times, including periods of startup, shutdown, and maintenance, Permittee shaJJ, 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 

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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, review of operating maintenance procedures and inspection of the facility. 

D. MALFUNCTION REPORTING 

1. Permittee shall notify EPA by mail within 48 hours 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 GHG emissions above the 

allowable emission limits stated in Sections II and HI of this permit. 

2. Within l 0 days of the restoration of normal operations after any failure described in 

1.0.1., Pe1mittee shall provide a written supplement to the initial notification that 

includes 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 of the failure, the estimated resultant emissions 

in excess of those allowed in Section II and Ill, and tbe methods utiiized to mitigate 

emissions and restore normal operati011s. 

3. Com15liance with this malfunction notification provision shall not excuse ur utherwise 

constitute a defense to any violation of this permit or any law or regulation such 

malfunction may cause. 

E. RIGHT OF ENTRY 

EPA authorized representatives, upon the presentation of credentials, shall be permitted: 

I. to enter the premises where the facility is located or where any records are required to 

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

2. 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; 

3. to inspect any equipment: operation, or method subject to requirements in this PSD 

Permit; and, 

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

F. TRANSFER OF OWNERSHIP 

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

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

succeeding owner and operator of the: existence of the PSD Permit and its conditions by letter; a 

copy of the letter shall be forwarded to EPA Region 6 within thirty days of the letter signature. 

G. SEVERABILITY 

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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 Emission Limits 

Annual emissions, in tons per year (TPY) on a 12-month, rolling total, shall not exceed the 

following: 

Table 1. Annual Emission Limits1 

FIN EPN GHG Mass Basis TPY Description BACT Requirements TPY C02e2

•

3 

C02 l ,070,879.0 940 lb C02/MWh (gross) on 

Natural Gas- a I 2-month roll ing average. 

Fired CH. 23 Start-up and Shutdown 

Combined emissions limited to 1,000 

VICIO VJC IO Cycle 1,072,053 hours per year. MSS 

Combustion emissions are limited to I 08 

Turbine NiO 2 tons C02/hr. See Special 

(GE.7FA.04)4 Conditions IV.A. l. and Table 

2. 

No Emission 

No VICIO- VICIO- Process Emission ruG- FUG- CH4 Li mil 

NGAS NGAS Fugitives Established5 Limit 

Established5 

SF6 Insulated No Emission No 

VICIO- VICIO- Emission 

INS-SF6 INS-SF6 Electrical SF6 Limit Limit Equipment Established6 

Established6 

Totals7 C02 1,070,879 

CH, 41 

NiO 2 1,072,498 

SF6 0.000056 

I. Compliance with the annual emission limits (tons per year) is based on a 12-month rolling average. 

2. The TPY emission limits specified in this table are not to be exceeded for this facility and include emissions 

from the facil ity during all operations and include MSS activities. This total is rounded off for estimation 

purposes to two significant figures. 

3. Global Warming Potentials (GWP): C02 = I, Cl-J4 ,: 25, N20 ~ 298, SF6 = 22,800 

4. Includes emissions during all operationa l modes, including purging venting associated with the CT and DB 

shutdown and maintenance events. CH4 is vented via an automatic double block and bleed at the CTG during 

each shutdown event. Additionally, CH4 is vented from the duct burner system each time the ducts are 

shutdown. Annual emissions for these activities are included in the annual C02e limit for VIC l 0. 

5. Fugitive process emissions from EPN VJICIO-FUG-NGAS are estimated to be 17.8 TPY CH4, and 445 TPY 

C02e. Fugitive process emission totals are for information only and do not constitute an emission limit. The 

emission limit will be a design/work practice standard as specified in the permit. 

6. SF6 emissions from EPA VICI O-£NS-SF6 are estimated to be 0.000056 tpy SF6 and 1.28 tpy C02e. Fugitive 

process emission totals are for informati•on only and do not constitute an emission limit. The emission limit will 

be a design/work practice standard as specified in the permit. 

7. Totals are given for informational purposes only and do not constitute emission limits. 

Page 6of13 
IV. SPECIAL PERMIT CONDITllONS 

A. Requirements for Combustion T111rbine Generator and Heat Recovery Steam Generator 

(EPN: VIClO) 

1. BACT Emission Limits for EPN: VIClO 

Table 2. BACT Emission Limits for EPN: VIClO 

- Combustion Combustion Duct Burners Output Based MSS Emission 

Turbine Model Turbine Annual Annual Firing Emission Limit, Limit2

•

3 

Firing Rate 1 Rate1 gross basis2 

(MMBtu/hr) (MMBtu/hr) (lb COvMWh) (tons C02/hr) 

(HHV) (HHV) 

GE.7FA.04 or 1,816 483 940 108 

equivalent 

1 Limits are based on a 12-month rolling average, 2 This limit applies with and without duct burner firing during normal operation 

3 Limit is based on a 12-month rolling total. 

a. For facility operations in a 1 x 1 x 1 plant configuration operation, compliance with the 

output based emission limit shall be determined by the following method, The COi mass 

emission values shall be calculated over each operational hour of the compliance period 

and summed. The summed hourly C02 mass emission values shall be divided by the 

summed hourly total gross elec:trical output. Compliance shall be demonstrated on a 12-

month rolling average. 

b. For facility operations in a 2 x 2 x 1 plant configuration operation, compliance with the 

output based emission limit shall be determined as follows: 

1. The hourly gross electric output from the existing non-modified steam turbine shall 

be apportioned based on either the measured steam load or measured heat input. A 

plan to demonstrate the apportionment of the gross electric output shall be 

submitted 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 generator. 

11. The C02 mass emission values shall be calculated over each operational hour of 

the compliance period and summed. The summed hourly C02 mass emission 

values shall be divided by the combined sum of the total gross electrical output 

from the steam turbine (as determined by the corresponding apportionment 

calculations represented in the plan) and the total gross electrical load from the 

combustion turbine generator. The resulting quotient is added to the sum of 

quotients of the previous 11 operating months and divided by 12 to determine 

compliance with the 12-month rolling average. 

c. Upon initial demonstration that the combustion turbine complies with the emission limit 

via emission tests, the Permittee shall not exceed the combustion turbine and duct burner 

annual firing rate, MMBtu/hr (HHV) from Table 2 on a 12-month rolling average. To 

Page 7of13 
determine the limit, the Permit1tee shall calculate the average hourly heat input rate over 

the applicable compliance period consistent with equation F-20 and procedure provided 

in 40 CFR Part 75, Appendix F § 5.5.2 and the GCV of the fuel combusted for the 

corresponding compliance period. Add the quotient to the sum of the quotients of the 

previous 11 operating months and divide by 12 to determine the 12-month rolling 

average. 

d. The Permittee shall not discharge or cause the discharge of emissions into the atmosphere 

in excess of the limits in tons of C02e on a 12-month rolling total as listed in Table 1. 

e. The duct burners are limited to 4,3 75 hours of operation per year. 

f. Startup and Shutdown events are limited to 1,000 hours per year and shall comply with 

the MSS BACT emission limit of 108 tons C02 per hour on a 12-month rolling total 

basis. 

2. Emissions Monitoring for EPN~ VIClO 

a. Upon initial demonstration that the combustion turbine complies with the emissions limit 

via emission tests, the Permittee shall not exceed the C02e annual emission limit from 

Table 1 during normal operation. To determine the amount of C02e, the Perrnittee shall 

calculate the amount of C02, CH4 and N20 io short tons per month based on the equation 

G-4 of 40 CFR Part 75, Appendix G and 40 CFR Part 98, Appendix C, and the monthly 

hours of operation on a 12-mo:nth rolling total. The Perrnittee shall also use the default 

Cl-14 and N10 emission factors contained in Table C-2 of 40 CFR Part 98 and the 

measured actual hourly heat input (HHV) to determine compliance with the CH4 and N2·o 

emission limits. The short tons per month values are multiplied by the respective Global 

Warming Potentials (GWP) contained in the Greenhouse Gas Regulations, 40 CFR Part 

98, Subpart A, Table A-1 to calculate the amount of CChe emitted in short TPY. The 

resulting C02e value is added to the previous l l months to determine the 12 month 

rolling total of C0 2e emissions. 

b. As an alternative, the Permittee may install and operate a volumetric stack gas flow 

monitor and associated data acquisition and handling system in accordance with the C02 

CEMS system provided in 40 CFR 75.1 O(a)(3) and (a)(5). If a C02 CEMS system is 

utilized, the hourly C02 emission value shall be measured by installing and operating a 

volumetric stack gas flow monitor or calculating the volumetric stack gas flow by tbe 

procedures of 40 CFR 75, Appendix D and associated data acquisition and handling 

system in accordance with the C02 CEMS system provided in 40 CFR § 75. l 0. 

c. In accordance with 40 CFR Part 75, Appendix D and 40 CFR Part 60, the Permittee shall 

ensure that all required fuel flow meters are installed, a periodic schedule for GCV fuel 

sampling is initiated and all ce:rtification tests are completed on or before the earlier of 90 

unit operating days or 180 calcmdar days after the date the unit commences commercial 

operation (as defined in 40 CFR § 72.2). 

d. The Permittee shall ensure compliance with the specifications and test procedures for fuel 

flow meter and/or C02 emission monitoring system at stationary sources, 40 CFR Part 75 

and 40 CFR Part 60. 

e. The Permittee shall meet the appropriate quality assurance requirements specified in 40 

CFR Part 75, Appendixes D and F and 40 CFR Part 60 for the fuel flow meter and/or 

C02 emission monitoring system. 

Page 8of13 
3. Work Practice and Operational Requirements for EPN: VIClO 

a. The combined cycle combustion turbine and duct burners are limited to burning only 

natural gas. The gross calorific: value of the fuel shall be determined monthly by the 

procedures contained in 40 CFR Part 75, Appendix F, § 5.5.2, and records shall be 

maintained of the monthly fuel gross calorific value for a period of five years. Upon 

request, the Permittee shall provide a sample and/or analysis of the fuel fired in the 

combustion turbine and/or duc1 burners or shall allow a sample to be taken by EPA for 

analysis. 

b. The flow rate of the fuel combusted in the combustion turbine and duct burners shall be 

measured and recorded using an in-line flow meter and automatically record the data with 

a data acquisition and handling; system. The steam load and/or heat input to the steam 

turbine shall also be measured and recorded. 

c. The Permittee shall measure and record the energy output of the apportioned steam 

turbine and combustion turbine (MWh, gross) on an hourly basis. 

d. On or before the date of initial performance test required by 40 CFR § 60.8, and •'- A ,.., n ,,j.4. ~ 1 11 • • t1 , • • 1 • ' • • • · ' .. ....---- tnefeaaef, lne r emuuee snau msiau, ana contmuous1y operate, ana mamtam tne HK~Us 

equipped with a SCR and oxidation catalyst so emissions are at or below the emissions 

limits specified in this permit. 

e. The Permittee shall perform a01 annual compliance-test, -at or above 90% of maximum 

load operations and conducted under such conditions to ensure representative 

performance of the affected facility. The conditions of the performance tests shall be 

recorded and made available for review upon request. 

f. On or after initial performance testing, the Permittee shall use BACT practices and 

designs represented in the pem1it application. 

4. Requirements during Startup andl Shutdown for EPN: VIClO 

a. Permittee shall minimize emissions during startup and shutdown activities by operating 

and maintaining the facility and associated air pollution control equipment in accordance 

with good air pollution control practices, safe operating practices, and protection of the 

facility. 

b. Emissions during startup and slhutdown activities shall be minimized by limiting the 

duration of operation in startup and shutdown mode as follows: 

1. A startup ofEPN: VIClO is initiated when the Data Acquisition and 

Handling System (DAHS) detects a flame signal (or equivalent signal) and 

ends when the permissives for the emission control system are met (i.e., 

steady state emissions compliance is achieved). A startup for the combustion 

turbine is limited to 10 hours (cold startup) per event. 

11. A shutdown ofEPN: VI Cl 0 begins when the load drops to the point at which 

steady state emissions compliance can no longer be assured and ends when a 

flame-off signal is detected. A shutdown for the combustion turbine is 

limited to 60 minutes per event. 

m. Start-up and Shutdown events are limited to 1,000 hours per year. 

c. Permittee must record the 1ime, date, fuel heat input (HHV) in mmBtu/hr and 

duration of each startup and shutdown event in order to calculated the total C02e 

emissions. The records must include hourly C02 emission levels as measured by the 

Page 9of13 
fuel flow meter (or C02 CEMS with volumetric stack gas flowrate) and the 

calculations based on the actual heat input for the C02, C02e, N10, and CH4 

emissions during each startup and shutdown event based on the equations represented 

in the permit application. These records must be kept for five (5) years following the 

date of such event. 

d. During startup and shutdown, <~missions from EPN: VIC 10 shall comply with all 

provisions of BACT emission limitations in Special Condition IV.A. l. 

B. Requirements 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 calculated annually (calendar year) in 

accordance with the mass balance approach provided in equation DD-I of the Mandatory 

Greenhouse Gas Reporting rules for Electrical Transmission and Distribution Equipment 

Use, 40 CFR Part 98, Subpart DD. Perrnittee shall not exceed insulated circuit breaker 

SF6 capacity of 23 lbs. 

3. Permittee 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 measurements, reports and documents 

related to the fugitive emission sources including, but not limited to, the following: all 

records or reports pertaining to maintenance performed, all records relating to compliance 

with the Monitoring and Quality Assurance and Quality Control (QA/QC) procedures 

outlines in 40 CFR § 98.304. 

V. RECORDKEEPING AND REJPORTING 

A. In order to demonstrate compliance with the GHG emission limits in Table 1, the 

Permittee will monitor the following parameters and summarize the data on a calendar 

month basis. 

1. Operating hours for all air emission sources; 

2. The natural gas fuel usag1e for all combustion sources, using continuous fuel flow 

monitors (a group of equipment can utilize 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 shall maintain a file of all records, data, measurements, reports, and documents 

related to the operation of the facility, including, but not limited to, the following: all 

records or reports pertaining to significant maintenance performed on any system or device 

at the plant; duration of startup, shutdown; the initial startup period for the emission units; 

pollution control units; malfunctions; all records relating to performance tests, calibrations, 

checks, and monitoring of combiustion equipment; duration of an inoperative monitoring 

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 inspection. 

The file must be retained for not less than five years following the date of such 

measurements, maintenance, reports, and/or records. 

Page 10of13 
C. Permittee shall maintain records and submit a written report of all excess emissions to EPA 

semi-annually, except when: more .frequent reporting is specifically required by an 

applicable subpart; or the Admini:strator or authorized representative, on a case-by-case 

basis, determines that more frequent reporting is necessary to accurately assess the 

compliance status of the source. The report is due on the 30th day following the end of each 

semi-annual period and shall include the following: 

1. Time intervals, data and magnitude of the excess emissions, the nature and cause (if 

known), corrective actions taken and preventive measures adopted; 

2. Applicable time and date of ea4ch period during which the monitoring equipment was 

inoperative (monitoring down-time); 

3. A statement in the report of a negative declaration; that is; a statement when no excess 

emissions occurred or when the monitoring equipment has not been inoperative, repaired 

or adjusted; 

4. Any failure to conduct any required source testing, monitoring, or other compliance 

activities; and 

5. Any violation of limitations on operation. 

D. Excess emissions shall be defined as ruzy period.in_ which the facility emissions exceed a 

maximum emission limit set forth in this permit, or a malfunction occurs causing an 

emissions exceedance. 

E. Excess emissions indicated by GHG emission performance testing or compliance 

monitoring shall be considered v][olations of the applicable emission limit for the purpose of 

this permit. 

F. Instruments and monitoring systems required by this PSD permit shall have a 95% onstream time on an annual basis. 

G. All records required by this PSD Permit shall be retained for not less than 5 years following 

the date of such measurements, maintenance, and reportjng. 

H. Continuously means individual measurement no less frequent than once every 15 minutes. 

Electronic data may be reduced to hourly averages for recordkeeping purposes. 

VI. SHAKEDOWN PERIODS 

The combustion turbine emission limits and requirements in Conditions III and IV .A. l shall not 

apply during combustion shakedown periods. Shakedown is defined as the period beginning with 

initial startup and ending no later than initial performance testing, during which the Perrnittee 

conducts operational and contractual testing and tuning to ensure the safe, efficient and reliable 

operation of the plant. The shakedown period shall not exceed the time period for performance 

testing as specified in 40 CFR § 60.8. The requirements of special condition I.C. 

Page 11of13 
VII. PERFORMANCE 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 Table 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% humidity). Sampling shall be conducted in accordance with 40 CFR § 60.8 and 

EPA Method 3a or 3b for the concentration of C02. 

1. Multiply 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 does not exceed tbe tons per year (TPY) 

specified in Table 1, no compliance strategy needs to be developed. If the above 

- calculated C02 emission total exceeds-the tons peryem.r(TPY) specified-in Table 1, the--

facility shall: 

a. Document the potential to exceed in the test report; and 

b. Explain within the report how the facility will assure compliance with the C02 

emission limit listed in Table 1. 

B. No later than 180 days after initial start-up, or restart after modification of the facility, 

performance 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 required by TCEQ or EPA. 

C. Permittee shall 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 notice of any performance k~st, except as specified under other subparts, to afford the 

EPA the opportunity to have an observer present and/or to attend a pre-test meeting. If there 

is a delay in the original test date, the facility must provide at least 7 days prior notice of the 

rescheduled date of the performance test. 

D. Performance tests must be conducted at or above 90% of maximum load operations for the 

atmospheric conditions which ex).st during testing. The duct burners shall be tested at their 

maximum firing 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 holder shall present in the performance test protocol the manner in which stack 

Page 12of13 
sampling will be executed in order to demonstrate compliance with the emission limits 

contained in Section 11. 

E. Air emissions from the HRSG exhaust stack shall be tested while firing at the minimum 

normal operating load (minimum normal load above 50 percent). The normal operating 

range consistent with emission limits is to be determined during stack testing. Air emissions 

that will be sampled and analyzed while at the minimum load include (but are not limited to) 

C0 2 to characterize the emissions at this load. 

F. Performance tests must be conducted under such conditions to ensure representative 

performance of the affected facility. The owner or operator must make available to EPA 

such records as may be necessary to determine the conditions of the performance tests. 

G. The owner or operator shall provide, or cause to be provided, performance testing facilities 

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\,;LUVU;) appu\.aUJI:' LU Uil::> H:l\.J!I LJ, 

2. Safe sampling platform(s), 

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

4. Utilities for sampling and testing equipment. 

H. Unless otherwise specified, each performance test shall consist of three separate runs using 

the applicable test method. Each run shall be conducted for the time and under the 

conditions specified in the applicable standard. For purposes of determining compliance 

with an applfoable standard, the a:rittunetic mean of the results of the three runs shall apply. 

VIII. AGENCY NOTIFICATIONS 

Permittee shall submit GHG permit applications, pennit amendments, and other applicable 

permit information to: 

Multimedia Planning and Permitting Division 

EPA Region 6 

1445 Ross Avenue (6 P'D-R) 

Dallas, TX 75202 

Email: Group R6AirPermits@EPA.gov 

Pennirtee shall submit a copy of all compliance and enforcement correspondence as required by 

this Approval to Construct to: 

Compliance Assurance and Enforcement Division 

EPA Region 6 

1445 Ross Avenue (6EN) 

Dallas, TX 75202 

Page 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, 2014 

 
2

Table of Contents 

I. Summary of the Formal Public Participation Process...........................................Page 3 

II. EPA’s Responses to Public Comments............................................................Page 3 

III. Revisions in Final Permit...........................................................................Page 6 

IV. National Historic Preservation Act (NHPA)......................................................Page 6 

 
3

I. Summary of the Formal Public Participation Process 

The U.S. Environmental Protection Agency, Region 6 (EPA) proposed to issue a Prevention of 

Significant Deterioration (PSD) permit to Victoria WLE, L.P. (Victoria), Victoria 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 comment period through a public notice published in 

the Victoria Advocate on August 12, 2014 and on Region 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 provided the public with notice of the public hearing 

explaining that it was subject to cancellation 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 by EPA from the permit applicant 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 accuracy of 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 than 20 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 specifications. (emphasis added). 

Since the rule requirement for QA testing is once every four fuel flowmeter QA operating quarters, 

why will Victoria have to complete testing once each calendar quarter? Victoria requests that QA 

testing be required once every four fuel flowmeter 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 Part 75, Appendix D, is provided at 

40 CFR § 72.2 and means: “a calendar 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 base-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 coincide 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 specified in 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 demonstration will be required for CO2 emissions from EPN: VIC10. VPS 

proposes to demonstrate compliance with the proposed heat rate with an initial compliance test at 

or above 90% load (corrected to ISO conditions) and subsequent annual testing. The conditions 

of the performance demonstration 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 percent load, corrected to ISO conditions. An initial stack 

test demonstration for CH4 and N2O emissions is not required because the CH4 and N2O 

emissions comprise approximately 0.01% of the total CO2e 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 major maintenance inspection. Is there any reason why 

annual testing is proposed in the draft permit? 

Response: The permittee will be operating the proposed facility 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 percentage 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 with the demonstrated performance testing results. 

The results of the test will inform the permittee and EPA of the source’s ability to comply with the 
5

CO2 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 Step 3) 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 necessarily have to meet the § 72.2 definition of pipeline 

natural gas. 

Response: We agree with the comment, and it is consistent 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 analysis 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 valid. 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 

SF6 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 with a 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 SF6 circuit breakers. It remains the case, however, that repair efforts would be 

expected for any leaking, malfunctioning circuit breaker. See Special 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 Victoria 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 Historic Preservation Officer (SHPO) requesting 

concurrence on EPA findings for Victoria’s cultural survey. The SHPO sent 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 

the 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 CO2 

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

and 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

CO2

 Emission Factor (8) lbCO2/MMBtu (HHV) 118.9 118.9 118.9

CO2 Output-Based Emission Rate, Gross Basis (9) lbCO2/MWh 889 979 940

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 Gross 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:

CT Heat 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 CO2 emission rate on a 12-month rolling average and gross basis, independently of the final hours running in each of the operational modes.

Annual 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]

Proposed 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) CO2 emission factor calculated per 40 CFR Part 75, Appendix G, Equation G-4, as referenced in §98.43(a), where:

Carbon based F-factor, FC: 1,040 scf/MMBtu

Standard Molar Volume: 385 scf/lbmole

Molecular Weight CO2, MWCO2: 44 lb/lbmole

CO2 Emission Factor = 1,040 scf/MMBtu / 385scf/lbmole * 44lb/lbmole = 118.9 lb/MMBtu

(9) CO2 Emission Limit (lbCO2/MWh) = Heat Rate (Btu/kWh) * 1MMBtu/1,000,000 Btu * CO2 Emission Factor (lbCO2/MMBtu) * 1,000 kW/MW

CO2 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 Units

VIC10 (Full Load, Gross Basis)

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

Proposed Standards VIC10

Proposed MSS BACT Limit

Parameter Units VIC10

Max. Heat Input (HHV) (1) MMBtu/hr (HHV) 1,816

CO2 Emission Factor (2) lbCO2/MMBtu (HHV) 118.9

CO2 Emission Rate Limit (SU/SD) (3) tonCO2/hr 108

Notes:

(1) Maximum heat input per manufacturer data

(2) CO2 emission factor calculated per 40 CFR Part 75, Appendix G, Equation G-4, as referenced in §98.43(a), where:

Carbon based F-factor, FC: 1,040 scf/MMBtu

Standard Molar Volume: 385 scf/lbmole

Molecular Weight CO2, MWCO2: 44 lb/lbmole

CO2 Emission Factor = 1,040 scf/MMBtu / 385scf/lbmole * 44lb/lbmole = 118.9 lb/MMBtu

(3) CO2 Emission Rate Limit (SU/SD) (ton/hr) = Max. Heat Input (MMBtu/hr) * CO2 Emission Factor (lbCO2/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