TECHNICAL REVIEW AND EVALUATION OF APPLICATION 

FOR 

SALT RIVER PROJECT – CORONADO GENERATING STATION 

AIR QUALITY TITLE V PERMIT # 52639 

I. INTRODUCTION 

This Class I, Title V permit renewal is for the continued operation of Salt River Project’s Coronado 

Generating Station which is located 6 miles northeast of St. Johns off U.S. Highway 191 in St. Johns, 

Apache County, Arizona. This permit is a renewal of Air Quality Title V Permit #30732. 

 

II. Company Information 

Company Name: Salt River Project Agricultural Improvement and Power District (SRP) 

Facility Name: Coronado Generating Station (CGS) 

 

Mailing Address: PO Box 52025, PAB 352 

 Phoenix, AZ 85072-2025 

 

Facility Location: Six miles Northeast of St. Johns off U.S. Highway 191 

 St. Johns, AZ 85936 

 

Attainment Classification: Apache County is designated as Unclassifiable/Attainment for the 

(Source: 40 CFR §81.303) National Ambient Air Quality Standards (NAAQS) for criteria 

 pollutants

 

III. FACILITY DESCRIPTION 

A. Process Description 

SRP Coronado operates two coal-fired electric utility steam generating units. The two units have a 

combined electrical output capacity of 912 gross megawatts (MW). Electrostatic precipitators and 

wet flue gas desulfurization systems are operated to control particulate matter emissions and sulfur 

dioxide emissions, respectively. Low-NOx Burners and Overfire Air are used to control nitrogen 

oxide emissions. Beginning on or before January 1, 2012, calcium bromide will be applied to the 

coal to control mercury emissions. Beginning on or before June 1, 2014, Selective Catalytic 

Reduction (SCR) will be installed on Unit 2 to provide additional control of nitrogen oxide 

emissions. 

An auxiliary boiler is used to provide auxiliary steam during startup if main boiler steam or turbine 

extraction steam is unavailable. Other operations at the plant include a main power building, coal 

mixing facilities, coal and ash handling facilities, ash disposal area, limestone handling equipment, 

process water treatment facilities, a forty-three mile railroad spur, water storage reservoirs, a 330 

acre evaporation pond for non-recoverable waters, mechanically induced draft cooling towers, 500 

kV and 69 kV switchyards and water supply from satellite well fields. The power plant 

commenced construction on July 25, 1974. 
The below table lists the maximum process rates and operating hours of the main units: 

Table 1: Maximum Estimated Process Rates 

Unit Maximum Hours of 

Operation

Maximum Steam 

Output 

Nominal Electric 

Generation (Gross) 

Unit 1 Boiler 8,760 2,747,000 lbs/hr 456 MW 

Unit 2 Boiler 8,760 2,747,000 lbs/hr 456 MW 

Auxiliary Boiler < 10% Annual Average 

Capacity Factor 105,000 lbs/hr --- 

B. Air Pollution Controls 

 The following air pollution control equipment is currently installed and operating, or planned to be 

installed on Units 1 and 2 as part of the Coronado Emission Control Project (CECP): 

 Hot-Side Electrostatic Precipitators (ESP) 

 Wet Flue Gas Desulfurization Units 

 Low-NOx Burners and Overfire Air 

 Selective Catalytic Reduction (Unit 2 Only) 

 Baghouses 

 Dust Extractors 

 

Hot-side electrostatic precipitators (ESP) are designed to remove 99.875 percent of the ash from the 

boiler flue gas. Two ESPs are provided for each unit and divided into two halves. Each half is 

provided with a single level of six parallel chambers consisting of seven fields each. The fly ash 

collected in the precipitator hoppers is pneumatically transferred to fly ash storage bins. Fly ash is 

unloaded from these bins into trucks and transported to the ash disposal area at CGS. The ash s 

deposited in layers and the layers are compacted, stabilized, and covered with wet bottom ash to 

eliminate dusting and wind erosion. 

Particulate matter emissions from material handling in the coal, fly ash, limestone, and other 

systems are controlled by baghouses or dust extractors. 

Two four-stage horizontal wet flue gas desulfurization (FGD) units are installed and operating on 

Unit 1 to reduce SO2 emissions. A vertical countercurrent flow limestone FGD unit is currently 

installed and operating on Unit 2. The existing horizontal FGD units on Unit 1 are planned to be 

replaced with a single vertical countercurrent FGD unit, identical to the one installed on Unit 2, in 

2012. Limestone slurry and water treatment sludge are used as reagents in the FGD system. A 

limestone handling system, complete with unloading, stack out and crushing facilities processes the 

limestone. Baghouses and wet dust extractors are provided on the limestone storage silos for dust 

control. 

On December 19, 2008, the United States District Court for the District of Arizona entered a 

Consent Decree executed by SRP and the United States Environmental Protection Agency (EPA) to 

upgrade air quality control equipment for nitrogen oxides (NOx) and sulfur dioxide (SO2) at CGS. 

The upgrade project, referred to as the Coronado Emissions Control Project (CECP), includes the 

addition of new low-NOx burners (LNB) and new scrubber systems to Unit 1 and 2. In addition, 

Air Quality TV Renewal Permit #52639 Page 2 of 24 December 06, 2011 

SRP – Coronado Generating Station 
SRP will install a selective catalytic reduction (SCR) system on Unit 2. The changes associated 

with the CECP were approved in 2008 under significant revision #46326. Table 2 lists the 

equipment installation status: 

Table 2: Control Equipment Installation Status 

Equipment Unit 1 Unit 2 

Low-NOx burners Installed & Operational since 

2009 

Installed & Operational since 

June 2011 

New FGD systems To be installed & Operational by 

January 1, 2013 

Installed & Operational since 

May 2011 

SCR None To be installed & Operational 

by June 1, 2014 

II. EMISSIONS 

The facility is classified as a Major Source pursuant to Arizona Administration Code (A.A.C.) R18-2-

101.64. The facility’s potential emissions exceed the major source thresholds for NOx, CO, SO2, VOCs, 

PM10, and HAPs pollutants. Table 3 summarizes the potential to emit (PTE) for the facility and Table 4 

summarizes the PTE for each emissions unit. 

Table3: PTE Facility-Wide Emissions* 

Pollutant Tons per Year 2005 Tons per Year 

 (Future) * 

PM10 4,323 2,003 

VOC 117 143 

SO2 33,771 8,271 

NOx 29,052 8,291 

CO 991 20,674 

Federal HAPs > 25 tpy Total HAPs 

> 10 tpy Individual HAP 

 *Following completion of all of the changes associated with the CECP 

Table 4: PTE Emissions of Criteria Pollutants* 

Unit PM10 SOx NOx VOC CO 

Unit 1 Boiler (Coal) 826 4,134 6,614 71 10,335 

Unit 2 Boiler (Coal) 963 4,134 1,654 71 10,335 

Auxiliary Boiler (Fuel Oil) 2 3 12 0.1 2 

Emergency Generators 0.2 0.1 6 0.2 1 

Emergency Fire Pump 0.1 0.1 2 0.1 0.4 

Booster Pump 0.1 0.1 5 0.1 1 

Coal Handling 36 

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SRP – Coronado Generating Station 
Limestone Handling 6 

Fly Ash 0 

Cooling Towers 78 

Coal Piles 0.5 

Limestone Piles 0.1 

Fly Ash Disposal 7 

Vehicular Traffic & 

Off-Road Machinery 3 

* Following completion of all of the changes associated with the CECP 

Table 5 lists the operating parameters of the steam generating units and the auxiliary boiler. 

Table 5: Typical Operating Parameters 

Description Units 1 & 2 

Boilers Auxiliary Boiler 

Maximum Annual Process Rate 24,063,720,000 lbs (steam) 919,800,000 lbs (steam) 

Maximum Hourly Process Rate 2,747,000 lbs (steam) 105,000 lbs (steam) 

Maximum Hourly Theoretical Heat 

Input 4,719 MMBtu/hr 157.34 MM Btu/hr 

Type of Fuel Used Coal, Oil, Used Oil Fuel Oil 

Quantity of Fuel Used/Year 35,040,000 MMBtu 32,000 barrels of oil 

Maximum Hourly Use 4,719 MMBtu 7,528 lb 

Higher Heating Value of Fuel (max) 8,710 Btu/lb 20,900 Btu/lb 

Sulfur Content 0.54% N/A 

Density of oil (lb/gal) N/A 6.97 

III. COMPLIANCE HISTORY 

Since the issuance of the previous permit on December 21, 2005, 2 on-site inspections were conducted and 

no violation was noted during the first inspection. The second inspection was conducted as a result of a 

complaint that the facility emitted black smoke. Upon inspection, the inspectors did not observe any 

violation. The inspectors noted that SRP had completed the installation of new low-NOx burner on Unit 

1. All quarterly Monitoring and Semiannual Compliance Certifications were submitted on time and no 

violations were noted. Annual performance tests conducted showed compliance with the permit limits. 

On December 19, 2008, the US EPA and SRP entered into a Consent Decree in which SRP agreed to 

upgrade the air pollution control systems at CGS to reduce emissions of nitrogen oxides (NOx) and sulfur 

dioxide (SO2). In addition, SRP agreed to install PM continuous emission monitoring systems (CEMS), 

and to accept a lower particulate matter emission limit. Table 2 above lists the status of the equipment 

upgrade and installation timelines. 

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SRP – Coronado Generating Station 
IV. APPLICABLE REGULATIONS 

The Permittee has identified the applicable regulations that apply to each unit in its permit application. 

Table 6 below summarizes the findings of the Department with respect to the regulations that are 

applicable to each emissions unit. Previous permit conditions are discussed under Section VI of this 

technical review document. 

Table 6: Applicable Regulations 

Unit ID

Startup 

date

Control 

Equipment

Applicable 

Regulations Verification

Units 1 & 

Unit 2 

7/25/74 -ESP 

(2/unit), 

-Low-NOx 

Burners, 

-Wet FGD 

-SCR on 

Unit2 (to be 

installed) 

40 CFR Part 60 

Subpart D

60.42(a)(1) 

60.42(a)(2) 

60.43(a)(1) & (c) 

60.44(a)(2), & (3) 

60.44(b) 

60.45(a) 

60.45(g)(1), (2), & (3) 

60.46(b)(1), (2), (3), & 

(5) 

60.46(b)(5) 

60.46(d)(1) 

40 CFR Part 64

CAM 

A.A.C. 

R18-2-903.1 & 903.3 

The units commenced construction 

after August 17, 1971 and are 

greater than 73 MW capacity. 

There are standards for PM, SO2, 

NOx and Opacity are included. 

Auxiliary 

Boiler 

7/25/74 None A.A.C. 

R18-2-724.A, B, C.1, 

E, G, J & K 

The heat input of this unit is 157 

MMBtu/hr (<250 MMBtu/hr) and 

the date of construction is prior to 

the trigger date (6/9/89) for 40 

CFR 60, Subpart Da. Hence, this 

unit is subject to R18-2-724. The 

unit is subject to an opacity 

standard of 15% and SOx standard 

of 1.0 lb/MMBtu. 

Generator 

and 

Emergency 

Fire pumps* 

None A.A.C. 

R18-2-719.A, B, C.1, 

E, F, I, H, J, K 

NESHAP 

40 CFR 63 Subpart 

ZZZZ 

The engines are subject to state 

requirements. 

Subpart ZZZZ requirements are 

applicable only to the fire pump 

(<500hp at a major source). Other 

ICEs > 500hp are exempt from 

Subpart ZZZZ requirements. 

NSPS Subpart IIII is not 

applicable since the engines were 

built before July 2006. 

Air Quality TV Renewal Permit #52639 Page 5 of 24 December 06, 2011 

SRP – Coronado Generating Station 
Air Quality TV Renewal Permit #52639 Page 6 of 24 December 06, 2011 

SRP – Coronado Generating Station 

Unit ID

Startup 

date

Control 

Equipment

Applicable 

Regulations Verification

Limestone 

Handling Baghouses 

and Wet 

Dust 

Extractors 

A.A.C. 

R18-2-702.B 

R18-2-720.B.2 

R18-2-612 

R18-2-722.F 

R18-2-722.G 

NSPS OOO 

The A.A.C. regulations listed are 

applicable to existing Lime 

Manufacturing Plants. Certain 

sources within the Limestone 

Handling System are also subject 

to NSPS OOO. 

Coal 

Handling 

Baghouses 

and Wet 

Dust 

Extractors 

A.A.C. 

R18-2-702.B 

R18-2-716.B, D, E 

The regulations listed are 

applicable to existing Coal 

Preparation Plants 

Fly Ash 

Handling 

Baghouses A.A.C. 

R18-2-702.B 

R18-2-730.A.1.b 

The regulations listed are 

applicable to existing unclassified 

sources. 

Cooling 

Towers 

None A.A.C. 

R18-2-702.B 

R18-2-730.A.1.b 

R18-2-730.D, & G. 

The regulations listed are 

applicable to existing unclassified 

sources. 

Fugitive 

Dust 

N/A Control 

Measures 

A.A.C. 

R18-2-602 

R18-2-604.A, & B. 

R18-2-605 

R18-2-606 

R18-2-607 

R18-2-612 

The regulations listed are 

applicable to non point sources 

Abrasive 

Blasting 

N/A Wet 

blasting, 

enclosure 

or 

equivalent 

approved 

by director 

A.A.C. 

R18-2-726 

R18-2-702.B 

Relevant requirements applicable 

to abrasive blasting 

Spray 

Painting 

N/A Control 

measures 

that attain 

96% 

efficiency 

A.A.C. 

R18-2-727 

R18-2-702.B 

Relevant requirements applicable 

to spray painting 

Mobile 

Sources 

N/A Control 

Measures 

A.A.C. 

R18-2-801 

R18-2-802.A 

R18-2-804 

These regulations are applicable 

to all mobile sources regulated 

under A.A.C. Title 18, Chapter 2, 

Article 8. 

Demolition

/ 

Renovation 

N/A None A.A.C. 

R18-2-1101.A.8 

(NESHAPs for 

asbestos) 

Relevant requirements applicable 

to demolition and renovation 

operations 
V. PREVIOUS PERMITS AND CONDITIONS 

A. Previous Permits 

Table 6 below table lists the previous permits that have been issued to SRP Coronado. 

 Table 6: Previous Permits 

Permit Number / 

Permit Type 

Issued 

Date 

Affected 

Equipment 

Description of Change 

42684 

R18-2-317 change 

12/2006 ESPs Rapper replacements 

43208 – 

R18-2-317 change 

2/5/2007 Dust Collectors 

(DC-4, -5d, -5e, -

5f) in Unit 2 coal 

gallery 

New Engart Dust Extractor System – 

Dust laden air picked up by a fan is 

subjected to countercurrent water spray 

which is then passed through a woven 

knit-mesh extractor panel to remove dust 

laden slurry. Increased efficiency 

>99.6%. 

44900 – 

Minor Revision 

12/13/2007 Coal Silo Addition of Coal Additive soda ash silo 

(Capacity: 3000 cu.ft.) 

Baghouse (Capacity: 750 cfm) 

46236 – 

Significant Revision 

1/22/2009 Unit 1 & 2 

Boilers 

Addition of New Low-NOx burners, SCR 

(Unit 2 only), New Wet Limestone FGD 

Systems and PM CEMS 

46361 – 

R18-2-317 change 

12/28/2007 DC-2 Baghouse 

(Capacity: 

16,200 cfm) 

New Engart Dust Extractor (Capacity: 

11,500 cfm). Increased efficiency 

>99.6%. 

48052 – 

Significant Revision 

Withdrawn 

48511 – 

R18-2-317 Change 

9/15/2008 DC-3 

DC-5-1, DC-5-2, 

DC-5-3 

Baghouses in 

coal handling 

area 

Replaced with Engart Type 30 Dust 

Extraction System (DES) 

Replaced with single Engart Type 18 

DES 

49759 – 

R18-2-317 change 

3/27/2009 Unit 1 tubes in 

super heater/ 

reheater 

Unit 1 feed 

water heater 

Replaced with new tubes 

Like-kind replacement 

50171 – 

R18-2-317 change 

6/2/2009 Limestone 

handling system 

Use of temporary limestone conveying 

system (hopper & screw conveyors) until 

existing system is upgrade as approved in 

SR46236 

50966 – 

Minor Revision 

8/2/2010 Revisions to 

Limestone 

Handling System 

& Dry Bottom 

Ash Handling 

-Transfer Tower renamed “TT-1” and 

dust collector replaced with Wet Dust 

Extractor, DC-12 

-New Transfer Tower “TT-2” and dust 

collector replaced with Wet Dust 

Air Quality TV Renewal Permit #52639 Page 7 of 24 December 06, 2011 

SRP – Coronado Generating Station 
System 

previously 

approved under 

SR 46236 

Extractor, DC-13 

-Conveyor Belt A renamed “BC-101B” 

-Lime Storage Silo (300 tons) replaced 

with 2 bins (each 73 tons capacity) each 

equipped with new Bin Vent Filters (DC14 & DC-15) 

-Bin Vent Filter DC-14 renamed “DC16” 

51780 – 

Significant Revision 

02/28/11 Unit 1 & 2 - Early mercury control strategy as an 

alternative plan for delaying requirements 

of AAC R18-2-734(B) until Dec 31, 2015 

- Reduction done by use of chemical 

oxidant in feed coal that will oxidize in 

the boiler furnace and subsequently 

removed in the limestone slurry 

circulating in the sulfur dioxide scrubbers

B. Previous Permit Conditions 

The following are discussions on the previous permits that have been issued to the source. 

CLASS I, TITLE V OPERATING PERMIT NO. 30732 

This operating permit was issued to SRP Coronado on 12/11/2005 to operate their two coal-fired dry bottom 

steam electric generating units. 

OP #30732, 

References

Determination Comments

Revise Keep Delete Stream-line

Att. A. X General provisions – References to 

NESHAP added 

Att. B.I.A, B, & 

C. 

X Unit 1 & 2 operational requirements 

Att. B.I.D.3.l X CAM plan revised to reflect use of PM 

CEMS and Wet FGD 

Att. B.I.E, F, G, 

H, I, & J 

X No changes 

Att. B.I.K X Revised to clarify monitoring 

Att. B.III X PM Standard of 43 nanograms per 

joule heat input for the boilers of Units 

1 and 2 

Att. B.IV X NESHAP Subpart ZZZZ requirements 

added for fire pump less than 500hp 

Att. B.V, VI, 

VII, VIII, IX, 

X, XI, & XII 

X Coal, limestone & flyash handling, 

Cooling towers, Used-oil 

specifications, fugitive emissions and 

other periodic emissions 

Attachment “C X Equipment List – revised to reflect new 

equipment added 

Air Quality TV Renewal Permit #52639 Page 8 of 24 December 06, 2011 

SRP – Coronado Generating Station 
Air Quality TV Renewal Permit #52639 Page 9 of 24 December 06, 2011 

SRP – Coronado Generating Station 

OP #30732, 

References

Determination Comments

Revise Keep Delete Stream-line

Attachment 

“D” 

X Phase II Acid Rain Provisions – 

revised to reflect the most recent years’ 

data. 

VI. COMPLIANCE ASSURANCE MONITORING (CAM) (40 CFR 64) FOR UNITS 1 AND 2: 

A. Particulate Matter 

1. Background 

a. Emission Unit

 Description: Coal Fired Steam Electric Generating Units 

 Unit Identification: Unit 1 and Unit 2 

 Air Pollution Control ID: ESP 1 and ESP 2 

 Wet FGDs 

 Facility: Coronado Generating Station 

b. Applicable Regulation, Emissions Limit, and Monitoring Requirements

 Regulation: A.A.C. R18-2-901.2 (40 CFR 60, Subpart D) 

 Emission Limit: PM<0.1 lb/MMBtu 

 Monitoring Requirements: Continuous Opacity Monitoring System (COMS) 

 

c. Control Technology Hot-Side Electrostatic Precipitators

 Wet FGD 

d. Monitoring PM CEMS 

2. Monitoring Approach 

Until the installation of the wet FGD system, the primary and secondary indicators are as 

follows: 

Primary Indicator – Measure opacity using COMS 

Secondary Indicator - Measure secondary current and voltage 

Excursion – when opacity is at or over 18% and the secondary current and voltage are outside 

the range established previously. 

After the installation of the wet FGD, and prior to the Department’s approval of the secondary 

indicators proposed based on the PM CEMS Correlation Testing, the primary and secondary 

indicators are as follows: 

Primary Indicator – Measure secondary current and voltage 

Secondary Indicator - Monitor operational status of the limestone slurry recycle pumps 

Excursion – when all pumps are non operational and the secondary current and voltage are 

outside the range established previously. 
After the Department’s approval of the secondary indicators proposed based on the PM 

CEMS Correlation Testing, the primary and secondary indicators are as follows: 

Primary Indicator – PM emissions as measured by the CEMS 

Secondary Indicator - Indicators established during CEMS correlation test 

Excursion – when PM emissions exceed 0.028 lbs/MMBtu and outside the range of indicators 

established during the correlation test. 

3. Monitoring Approach Justification 

Until the FGD is installed, opacity was selected as the primary performance indicator because, 

as the opacity of emissions increases, it can be reasonably assumed that PM emissions 

increase. In addition, the facility has historically been required by permit to conduct annual 

PM testing, and past data indicates that the unit opacity limits provide a significant margin of 

compliance with the PM limits. The indicator range selected for opacity is a 1-hour rolling 

average opacity of less than 18%. 

The secondary indicator range is the electrical parameters (secondary current and voltage for 

each section of each ESP). Both ADEQ and EPA had agreed that monitoring the current and 

voltage on a continuous basis allows for a more accurate way of determining how the ESPs 

operated. Having continuous data of the electrical parameters allows the Department and EPA 

the flexibility to determine if the facility is in compliance in the future. 

Upon installation of the FGD and until the Department’s approval of the secondary indicators 

proposed based on the PM CEMS Correlation Testing, monitoring of the operational status of 

the limestone slurry recycle pumps associated with the wet FGD would provide a reasonable 

approach to ensuring PM control. The new wet FGD contains four limestone slurry recycle 

pumps. Each pump is connected to a separate level of sprays in the FGD absorber. The 

recycle pumps are either on or off; the flow rate associated with the pumps cannot be altered 

manually. At least one pump is running at all times when the boiler is operating. Additional 

pumps are operated as needed to maintain compliance with the SO2 emission limit in the 

permit based on the unit’s operation and the coal sulfur content. The operational status of 

each pump is recorded continuously in the plant Digital Control System (DCS) historian based 

on the pump amperage. 

 Upon installation and operation of the PM CEMS, PM emissions will be measured directly. 

The feasibility of operating the PM CEMS is determined under a 2-year demonstration period. 

If after the 2-year period, the PM CEMS are determined to be infeasible, new parameters will 

be established at that time. 

 

CAM Plan Summary* 

Indicator and its 

measurement 

approach 

Opacity from the stack shall be the primary 

indicator and continuous opacity monitoring 

systems (COMS) will be used as the measurement 

approach. The secondary indicator will be the 

electrical parameters (current and voltage) for each 

section of each ESP. 

Until PM CEMS is operated, the pump operation of 

the FGD will be continuously measured. 

Indicator Range The indicator range for opacity will be over a 1 hour 

Air Quality TV Renewal Permit #52639 Page 10 of 24 December 06, 2011 

SRP – Coronado Generating Station 
rolling average of less than 18% opacity. The 

indicator range for the electrical parameters will be 

the same as previously established. 

Upon installation of the CEMS, new secondary 

parameters will be established during the correlation 

test. Upon approval of the new parameters, the 

Permittee will monitor and record the data. 

Data 

representativeness 

The data will represent normal operating conditions; 

this will exclude startup, shutdown, and 

malfunctions. 

Verification of 

operational status 

N/A 

QA/QC practices and 

criteria 

SRP is required by the permit to meet the QA/QC 

requirements of 40 CFR 60, Appendix B, 

Performance Specification 1, “Specification and 

Test Procedures for Opacity and PM Continuous 

Emission Monitoring Systems in Stationary 

Sources” 

Monitoring 

Frequency 

The COMS shall be in continuous operation and 

shall complete a minimum of one cycle of sampling 

and analyzing for each successive 10-second period 

and one cycle of data recording for each successive 

6-minute period. The source will also monitor and 

record the electrical parameters on a continuous 

basis (at least once every 15 minutes) for each 

section of each ESP. 

The FGD pump operation will be monitored 

continuously. 

The CEMS will be in continuous operation. 

Data Collection 

Procedure 

SRP will reduce all data from the COMS to 6-

minute averages. Six-minute opacity averages shall 

be calculated from 36 or more data points equally 

spaced over each 6-minute period. 

Averaging period SRP will be required the monitor the opacity over a 

1-hour averaging period. 

* The CAM Plan summarized in this table applies until the new wet FGD systems are installed on each unit. At 

that time, the applicable CAM requirements are those described in the Section VI.A.3. 

B. Sulfur Oxides 

The source is subject to the sulfur dioxide standard of 0.8 lb/MMBtu heat input in A.A.C. R18-2-

903.1 while burning coal. After installation and commencement of operation of the FGD, the 

source is subject to a 30-day rolling average SO2 removal efficiency of at least 95% or a 30-day 

rolling average SO2 emissions rate no greater than 0.08 lbs/MMBtu. The Permittee is required to 

operate a continuous emissions monitoring system (CEMS) for recording emissions of sulfur 

dioxide. The CEMS will be used as CAM for sulfur dioxide for both units. The monitoring system 

is required to meet the requirements of 40 CFR 60.13 and 40 CFR 75. 

C. Nitrogen Oxides 

The units are subject to the nitrogen oxide standard of 0.70 lb/MMBtu heat input in 40 CFR 

Air Quality TV Renewal Permit #52639 Page 11 of 24 December 06, 2011 

SRP – Coronado Generating Station 
60.44(a)(3) when burning coal and 0.30 lb/MMBtu in 60.44(a)(2) when burning fuel oil. If burning 

a combination of coal and fuel oil, the units are subject to the standard calculated by the equation of 

40 CFR 60.44(b). After installation and commencement of operation of the low- NOx burners, the 

source is subject to a 30-day rolling average NOx emissions rate of 0.32 lbs/MMBtu and upon 

installation of the SCR on Unit 2, the source is subject to a 30-day rolling average NOx emissions 

rate of 0.08 lbs/MMBtu. In addition, after installation and commencement of operation of the SCR, 

the source is subject to an annual plant-wide rolling total not to exceed 7,300 tons of NOx

emissions. Compliance test results indicate that the units are able to meet the standard. The 

Permittee is required to operate a continuous emissions monitoring system (CEMS) for recording 

emissions of nitrogen oxides. The CEMS will be used as CAM for nitrogen oxide for both units. 

The monitoring system is required to meet the requirements of 40 CFR 60.13 and 40 CFR 75. 

VII. PERIODIC MONITORING 

A. Unit 1 and 2 Boilers 

1. Opacity 

The units are subject to an opacity standard of 20% under 40 CFR 60.42(a)(2). There is an 

exception that allows for one six-minute period per hour of not more than 27% opacity. In 

accordance with 40 CFR 60.11(c), this limitation is exempt during periods of startup, 

shutdown, or malfunction. The source provided specific definitions for these three categories 

which are included in the permit conditions.

The Permittee is required to operate a continuous monitoring system for opacity. This 

monitor will be used as the periodic monitoring method. The monitoring system is required 

to meet the requirements of 40 CFR 60.13 and 40 CFR 60, Appendix B, Performance 

Specification 1. In accordance with Permit #30732, the Permittee shall maintain two sets of 

opacity filters, one to be used as calibration standards and one to be used as audit standards. 

2. Fuel 

Permittee is restricted to burning only coal, Number 2 fuel oil, and on specification used oil 

in the boilers. In addition, the Permittee is required to maintain a record of any change in 

fuel type. 

B. Auxiliary Boiler 

1. Opacity 

The boiler is subject to the opacity standard of 15% in A.A.C. R18-2-724.J. The Permittee 

will be required to conduct a weekly survey of visible emissions emanating from Auxiliary 

Boiler. If the opacity of the emissions observed exceeds 15%, the observer shall conduct a 

certified EPA Reference Method 9 observation. The Permittee will be required to keep 

records of the initial survey and any EPA Reference Method 9 observations performed. 

These records will include the emission point observed, location of observer, name of 

observer, date and time of observation, and the results of the observation. If the observation 

shows a Method 9 opacity reading in excess of 15%, the Permittee will be required to initiate 

appropriate corrective action to reduce the opacity below the standard. The Permittee will 

keep a record of the corrective action performed. The Permittee is also required to monitor 

and record the number of hours fuel oil is burned continuously in the units. 

Air Quality TV Renewal Permit #52639 Page 12 of 24 December 06, 2011 

SRP – Coronado Generating Station 
2. Particulate Matter 

This unit is subject to the particulate matter emissions standard in A.A.C. R18-2-724.C.1. 

Because fuel oil is burned in the boiler, the Permittee is required to monitor particulate matter 

emissions by monitoring the fuel burned in the unit. The Permittee is also required to 

monitor the following information about the fuel found in the contractual agreement with the 

liquid fuel vendor: 

a. Heating value; and 

b. Ash content. 

Although ash content by itself is not a valid measure of particulate matter emissions, 

monitoring this would help the agency to “ballpark” the particulate matter emissions. No 

engineering estimation using ash content is prescribed in the permit since it could be 

interpreted to incorrectly correlate particulate matter emissions to ash content only. The 

Permittee is also required to keep on record a copy of the contractual agreement and notify 

the Director within 30 days of any change in the contractual agreement. 

As part of this Title V renewal, ADEQ is hereby removing the annual performance test for 

PM because potential PM emissions from the boiler are less than 1 tpy, which is less the 

allowable emission rate set forth by the process rate weight equation. 

3. Sulfur Oxides 

The boiler is subject to sulfur dioxide standard in A.A.C. R18-2-724.E. Because the unit 

burns fuel oil, the emissions standard is 1.0 lb/MMBtu. The Permittee is required to keep on 

record fuel supplier certification including the following information: 

a. The name of the oil supplier; 

b. The sulfur content and the heating value of the fuel from which the shipment came 

from; and 

c. The method used to determine the sulfur content of the oil. 

Permittee is required to make engineering calculations for SOx emissions using the 

information from above according to the following equation for each fuel delivery: 

SO2 (lb/MMBtu) = 2.0 x [(Weight percent of sulfur/100) x Density (lb/gal)]/[(Heating 

value (Btu/gal)) x (1 MMBtu/1,000,000 Btu)] 

4. Fuel 

The Permittee is not allowed to burn high sulfur oil (>0.9% by weight) as a fuel unless it is 

demonstrated that low sulfur oils aren’t available. In addition, Number 2 fuel oil and on 

specification used oil may be burned in the auxiliary boiler. 

C. Internal Combustion Engines 

Air Quality TV Renewal Permit #52639 Page 13 of 24 December 06, 2011 

SRP – Coronado Generating Station 
1. Opacity 

The generators or internal combustion engines are subject to a 40% opacity limitation The 

Permittee will be required to conduct a weekly survey of visible emissions emanating from the 

internal combustion engines. If the opacity of the emissions observed exceeds 40%, the 

observer shall conduct a certified EPA Reference Method 9 observation. The Permittee will be 

required to keep records of the initial survey and any EPA Reference Method 9 observations 

performed. These records will include the emission point observed, location of observer, name 

of observer, date and time of observation, and the results of the observation. If the observation 

shows a Method 9 opacity reading in excess of 40%, the Permittee will be required to initiate 

appropriate corrective action to reduce the opacity below the standard. The Permittee will keep 

a record of the corrective action performed. The source is also required to keep a record of the 

corrective action performed. 

2. Particulate Matter 

The source is required to monitor the lower heating value of the fuel being combusted in the 

internal combustion engines. Compliance with this requirement may be demonstrated by 

maintaining copy of the fuel supplier certification specifying the lower heating value. 

3. Sulfur Dioxide 

The source is not allowed to burn high sulfur fuel, and is limited to emissions of sulfur dioxide 

to 1.0 pound per million Btu heat input. The source is required to maintain records of daily 

sulfur content and lower heating value of the fuel fired in the internal combustion engines. This 

may be accomplished by keeping a copy of the fuel supplier certification specifying the sulfur 

content and lower heating value of the fuel. 

4. Hazardous Air Pollutants 

 The source is required to operate the emergency fire pump (less than 500 hp) engine only for 

emergency use and up to 100 hours of required maintenance and testing. Of the 100 hours, the 

source may operate the fire pump up to 50 hours in non-emergency situations. Operation of the 

engine in accordance with the manufacturer’s plan is required. Monitoring involves oil and 

filter change every 500 hours of operation and inspection of air cleaner every 1000 hours of 

operation. A non-resettable hour-meter is required to log the operational hours. These 

requirements are effective May 03, 2013. 

D. Coal Handling 

1. Opacity 

The coal handling facility is subject to a 20% opacity standard, as stated in A.A.C. R18-2-702. 

 The Permittee will be required to conduct a weekly survey of visible emissions emanating 

from the coal handling facility. If the opacity of the emissions observed exceeds the opacity 

standard, the observer shall conduct a certified EPA Reference Method 9 observation. The 

Permittee will be required to keep records of the initial survey and any EPA Reference 

Method 9 observations performed. These records will include the emission point observed, 

location of observer, name of observer, date and time of observation, and the results of the 

observation. If the observation shows a Method 9 opacity reading in excess of the opacity 

standard, the Permittee will be required to initiate appropriate corrective action to reduce the 

opacity below the standard. The Permittee will keep a record of the corrective action 

Air Quality TV Renewal Permit #52639 Page 14 of 24 December 06, 2011 

SRP – Coronado Generating Station 
performed. The source is also required to keep a record of the corrective action performed. 

2. Particulate Matter 

The source is subject to the particulate matter standard in A.A.C. R18-2-716.B.2. The 

Permittee is required to maintain and operate the baghouses and wet dust extractors in 

accordance with the manufacturer’s specification. Permittee is also required to hold these 

specifications on file. Emissions related maintenance work needs to be recorded. 

E. Limestone Handling 

1. Opacity 

The limestone handling plant is subject to a 20% opacity standard, as stated in A.A.C. R18-2-

702. The Permittee will be required to conduct a weekly survey of visible emissions 

emanating from the limestone handling facility. If the opacity of the emissions observed 

exceeds the opacity standard, the observer shall conduct a certified EPA Reference Method 9 

observation. The Permittee will be required to keep records of the initial survey and any EPA 

Reference Method 9 observations performed. These records will include the emission point 

observed, location of observer, name of observer, date and time of observation, and the 

results of the observation. If the observation shows a Method 9 opacity reading in excess of 

the opacity standard, the Permittee will be required to initiate appropriate corrective action to 

reduce the opacity below the standard. The Permittee will keep a record of the corrective 

action performed. The source is also required to keep a record of the corrective action 

performed. 

Certain sources within the Limestone Handling System are also subject to NSPS OOO. 

NSPS OOO requires monitoring liquid flow rate and pressure drop for each of the Wet Dust 

Extractors (DC-12 and DC-13). In addition, NSPS OOO requires the Permittee to conduct 

quarterly 30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60,

Appendix A-7) on the Bin Vent Dust Collectors (DC-14, DC-15, and DC-16). 

2. Particulate Matter 

The source is subject to the particulate matter standard in A.A.C. R18-2-720.B.2. The 

Permittee is required to maintain and operate the Bin Vent Dust Collectors and Wet Dust 

Extractors in accordance with the manufacturer’s specification. Permittee is also required to 

hold these specifications on file. Emissions related maintenance work must be recorded. 

F. Fly Ash Handling 

1. Opacity 

The fly ash handling plant is subject to a 20% opacity standard, as stated in A.A.C. R18-2-

702. The Permittee will be required to conduct a weekly survey of visible emissions 

emanating from the fly ash handling facility. If the opacity of the emissions observed 

exceeds the opacity standard, the observer shall conduct a certified EPA Reference Method 9 

observation. The Permittee will be required to keep records of the initial survey and any EPA 

Reference Method 9 observations performed. These records will include the emission point 

observed, location of observer, name of observer, date and time of observation, and the 

results of the observation. If the observation shows a Method 9 opacity reading in excess of 

Air Quality TV Renewal Permit #52639 Page 15 of 24 December 06, 2011 

SRP – Coronado Generating Station 
the opacity standard, the Permittee will be required to initiate appropriate corrective action to 

reduce the opacity below the standard. The Permittee will keep a record of the corrective 

action performed. The source is also required to keep a record of the corrective action 

performed 

2. Particulate Matter 

The source is subject to the particulate matter standard in A.A.C. R18-2-730.B.1. The 

Permittee is required to maintain and operate the baghouses in accordance with the 

manufacturer’s specification. Permittee is also required to hold these specifications on file. 

Emissions related maintenance work must be recorded. 

G. Cooling Towers 1 and 2 

SRP does not use Chromium-6 in the cooling towers at the Coronado Generating Station. 

Therefore, they are not subject to MACT for cooling towers under 40 CFR Part 63, Subpart Q. 

1. Opacity 

The cooling tower is subject to the opacity standard of 20% opacity standard, as stated in 

A.A.C. R18-2-702. The Permittee will be required to conduct a weekly survey of visible 

emissions emanating from the cooling towers. If the opacity of the emissions observed 

exceeds the opacity standard, the observer shall conduct a certified EPA Reference Method 9 

observation. The Permittee will be required to keep records of the initial survey and any EPA 

Reference Method 9 observations performed. These records will include the emission point 

observed, location of observer, name of observer, date and time of observation, and the 

results of the observation. If the observation shows a Method 9 opacity reading in excess of 

the opacity standard, the Permittee will be required to initiate appropriate corrective action to 

reduce the opacity below the standard. The Permittee will keep a record of the corrective 

action performed. The source is also required to keep a record of the corrective action 

performed 

2. Particulate Matter 

The units are also subject to particulate matter emissions standard under A.A.C. R18-2-

730.A.1. 

H. Fugitive Emissions 

The standards in Article 6 of the Arizona Administrative Code (A.A.C.) are applicable 

requirements for non-point sources. The following sources will be monitored:

1. Driveways, parking areas, vacant lots 

2. Unused open areas 

3. Open areas (Used, altered, repaired, etc.) 

4. Construction of roadways 

5. Material transportation 

6. Material handling 

7. Storage piles 

Air Quality TV Renewal Permit #52639 Page 16 of 24 December 06, 2011 

SRP – Coronado Generating Station 
8. Stacking and reclaiming machinery at storage piles 

All of these areas must comply with the opacity limitation of 40%. The control measures for most 

of these activities include dust suppressants and/or wetting agents and reasonable precautions. To 

conduct open burning, Permittee must obtain a permit from ADEQ, or the local officer in charge of 

issuing burn permits. 

The Permittee is required to make a bi-weekly survey of the visible emissions from all non-point 

sources. The Permittee is required to create a record of the date on which the survey was taken, the 

name of the observer, and the results of the survey. If the visible emissions do not appear to exceed 

the standard, the Permittee would note in the record that the visible emissions were of low opacity, 

and it did not require a Method 9 to be performed. 

If the Permittee finds that on an instantaneous basis the visible emissions are in excess of the 

opacity standard, then he is required to make a six-minute Method 9 observation. If this 

observation indicates opacity in excess of the standard, then the Permittee is required to report it as 

excess emissions. In addition, the Permittee is required to adjust the process equipment or process 

control equipment to bring the opacity below the standard. If the Permittee finds that the visible 

emissions is less than the opacity standard, then the Permittee is required to record the source of 

emission, date, time, and result of the test. 

Monitoring and recordkeeping requirements for the nonpoint sources include a record of the date 

and type of activity performed, and the type of controls used. Also, monitoring requirements for 

the applicable open burning rule may be satisfied by keeping all open burn permits on file. 

I. Other Periodic Activities 

1. Abrasive Sand Blasting 

SRP has indicated in the permit application that abrasive sand blasting activities are 

conducted on-site. The applicable requirements are A.A.C. R18-2-726 and A.A.C. R18-2-

702(B) and are included in the permit. Monitoring requirements include: 

a. Date project was conducted; 

b. Duration of project; 

c. Type of control measures employed 

2. Spray Painting 

SRP has indicated in the permit application that spray painting activities are conducted onsite. The applicable requirements are A.A.C. R18-2-727 and A.A.C. R18-2-702(B) and are 

included in the permit. A.A.C. R18-2-727(A) and A.A.C. R18-2-727(B) are included in the 

approved State Implementation Plan (SIP). A.A.C. R18-2-727(C) and A.A.C. R18-2-727(D) 

are also a part of the approved SIP. They are present in the definitions section of the SIP as 

R9-3-101.117. EPA approved SIP provision R9-3-527.C is not present in the amended rule. 

However, R9-3-527.C is an applicable requirement, and is federally enforceable until the 

current State SIP is approved by the EPA. Monitoring requirements include: 

a. Date project was conducted; 

b. Duration of project; 

c. Type of control measures employed; 

d. Material Safety Data Sheets for all paints and solvents used in the project. 

Air Quality TV Renewal Permit #52639 Page 17 of 24 December 06, 2011 

SRP – Coronado Generating Station 
3. Mobile Sources 

The Permittee is required to keep a record of all emissions related maintenance activities 

performed on Permittee's mobile sources stationed at the facility as per manufacturer’s 

specifications for the purposes of monitoring and recordkeeping 

4. Asbestos Demolition/Renovation 

The Permittee is required to keep a record of all required paperwork on file for the purposes 

of monitoring and recordkeeping. The required paperwork includes “NESHAP Notification 

for Renovation and Demolition Activities” form and all supporting documents. 

5. Non-vehicle Air Conditioner Maintenance and/or Services 

The Permittee is required to keep a record of all paperwork required by the applicable 

requirements of 40 CFR 82 - Subpart F on file for the purposes of monitoring and 

recordkeeping. 

J. Used Oil Fuel 

All of the previous permit conditions regarding used oil fuel have been incorporated into this Title 

V permit. The Permittee is required to burn only on-site generated on-specification used oil with 

contaminants less than the following: 

Arsenic 5 ppm 

Cadmium 2 ppm 

Chromium 10 ppm 

Lead 100 ppm 

PCBs 2 ppm 

Total Halogens 1000 ppm 

In addition, the flash point of the used oil shall not fall below 100 degrees Fahrenheit. The amount 

of used oil shall not exceed 350 barrels annually. This requirement carried over from a prior permit 

condition. 

Recordkeeping and reporting requirements include semi-annual report which contains an inventory 

of the fuel oil used throughout the year. Testing requirements include a test for chlorinated solvents 

prior to burning and an annual test for arsenic, cadmium, chromium, and lead. 

VIII. TESTING REQUIREMENTS 

A. Unit 1 and Unit 2 Boilers 

SRP is required to perform annual performance tests for opacity, particulate matter, SO2 and NOx in 

accordance with 40 CFR Part 60, Subpart D. 

1. Particulate Matter 

The Permittee is required to perform annual tests for particulate matter emissions using EPA 

Air Quality TV Renewal Permit #52639 Page 18 of 24 December 06, 2011 

SRP – Coronado Generating Station 
Reference Methods 5, 5b, or 17. 

2. Sulfur Dioxide 

The testing requirements for sulfur dioxide have been removed on account of the fact that they 

are included in the QA/QC requirements of the Acid Rain provisions for the CEMs. 

3. Nitrogen Oxides 

The testing requirements for nitrogen oxides have been removed on account of the fact that they 

are included in the QA/QC requirements of the Acid Rain provisions for the CEMs. 

B. Limestone Handling 

1. Opacity 

 Within 60 days after achieving the maximum production rate at which the affected facility will 

be operated, but not later than 180 days after initial startup of such facility, the Permittee is 

required to conduct an initial performance test for opacity for the bin vent filters (DC-14, DC-15 

and DC-16). 

2. Particulate Matter 

 Within 60 days after achieving the maximum production rate, but not later than 180 days after 

the installation of second flue gas desulfurization unit, the Permittee is required to conduct an 

initial performance test for PM/PM10 for the wet dust extractors (DC-12 and DC-13).

C. Used Oil Fuel 

1. The Permittee shall test all used oil prior to burning for chlorinated solvents by using EPA 

Method 9007. 

2. The Permittee test a representative sample of the use fuel oil annually for Arsenic, Cadmium, 

Chromium, and Lead using approved EPA Methods. 

IX. MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT)(40 CFR 63) 

Stationary Reciprocating Internal Combustion Engines (RICE)( Subpart ZZZZ) 

This MACT is applicable to stationary RICE located at major sources of Hazardous Air Pollutant (HAP) 

emissions. An affected facility does not have to be a major source of HAPs to be subject to this MACT. 

It only has to be located at a major source of HAP emissions. Since the SRP Coronado facility is major 

for HAPs this MACT needs to be listed as a potentially applicable requirement. 

According to 40 CFR 63.6590(b)(3), any existing emergency engines over 500 horsepower located at the 

facility are exempt from all requirements of this subpart and of subpart A of the 40 CFR 63. No initial 

notification is required. The only engines at the SRP Coronado facility are the emergency generator 

(938hp) built in 1978 and the two emergency fire pumps (800 hp & 266 hp) built in 1977, as stated in the 

equipment list of the permit. The generator and one fire pump over 500 hp are exempt from the RICE 

MACT while the small engine is subject to the requirements of this subpart. 

Air Quality TV Renewal Permit #52639 Page 19 of 24 December 06, 2011 

SRP – Coronado Generating Station 
X. INSIGNIFICANT ACTIVITIES 

The following table includes a list of activities proposed by SRP Coronado to be insignificant. This table 

includes an evaluation of whether the activity can be deemed as insignificant pursuant to A.A.C. R18-2-

101.57. 

The following activities were proposed to be insignificant in the permit application (activities in 

redline format are being evaluated for significance): 

S. No. Activity Insignificant Comment

1 5,000 gallon sulfuric acid storage tank Yes No applicable requirement 

2 7,000 gallon sodium hydroxide storage tank Yes No applicable requirement 

3 5,000 gallon copper corrosion inhibitor storage tank 

(50% water solution of sodium tolytriazole) 

Yes No applicable requirement 

4 3,000 gallon coagulant storage tanks (aqueous 

sodium aluminate solution) (2) 

Yes No applicable requirement 

5 5,000 gallon antiscalant/dispersant storage tank 

(aqueous solution of sodium phosphonate and 

polyacrylates) 

Yes No applicable requirement 

6 2,000 lb pH control/hardness conditioning storage 

tank (phosphates) and 400 gallon morpholine 

Yes No applicable requirement 

7 400 gallon oxygen scavenger storage tank (aqueous 

modified amino compound) 

Yes No applicable requirement 

8 1250 gallon corrosion inhibitor (aqueous solution of 

borate, nitrate and nitrite) 

Yes No applicable requirement 

9 15,000 gallon vehicle diesel fuel storage tank (2) Yes A.A.C. R18-2-101.54.c 

10 1,000,000 gallon fuel oil storage tank (#2 diesel fuel) Yes No applicable requirement 

11 10,000 gallon unleaded gasoline storage tank (2) Yes A.A.C. R18-2-101.54.b 

12 10 nitrogen cylinders at 7500 scf each Yes A.A.C. R18-2-101.54.i 

13 15 hydrogen cylinders at 7500 scf each Yes A.A.C. R18-2-101.54.i 

14 12 chlorine cylinders at 1 ton each No SRP is subject to 40 CFR 

Part 68 for chlorine, which 

has a threshold of 25 lbs. 

15 16,000 gallon turbine lube oil storage tank Yes No applicable requirement 

16 550 gallon hydraulic oil HD 100 storage tank (2) Yes No applicable requirement 

17 550 gallon AW machine oil 150 storage tank (2) Yes No applicable requirement 

18 550 gallon AW machine oil 68 storage tank (2) Yes No applicable requirement 

19 550 gallon AW machine oil 32 storage tank (2) Yes No applicable requirement 

20 550 gallon hydraulic fluid storage tank (2) Yes No applicable requirement 

21 550 gallon ethylene glycol storage tank (2) Yes No applicable requirement 

22 550 gallon almasol gear lube 90 weight storage tank 

(2) 

Yes No applicable requirement 

23 mineral oil storage tank Yes No applicable requirement 

24 lube oil vapor extractors No There is an applicable 

requirement (A.A.C. R18-2-

730) 

Air Quality TV Renewal Permit #52639 Page 20 of 24 December 06, 2011 

SRP – Coronado Generating Station 
25 generator vapor extractors No There is an applicable 

requirement (A.A.C. R18-2-

730) 

26 boiler feed pump Yes No applicable requirement 

27 50,000 gallon bearing cooling water (2) Yes No applicable requirement 

28 15,000 gallon brine sump Yes No applicable requirement 

29 miscellaneous steam vents Yes No applicable requirement 

30 paint building with controls No There is an applicable 

requirement (A.A.C. R18-2-

727) 

31 sandblasting/welding/metal fabrication with controls No There is an applicable 

requirement (A.A.C. R18-2-

726) 

32 permitted asbestos landfill No There is an applicable 

requirement (40 CFR 61 

Subpart M) 

33 miscellaneous rotating machinery less than 325 

aggregate bhp 

No There is an applicable 

requirement (A.A.C. R18-2-

719 

34 IC engine compressors No Subject to A.A.C R18-2-719

35 Quality control/assurance laboratory Yes A.A.C. R18-2-101.54.i 

36 Drum storage and handling Yes No applicable requirement 

37 Boiler feedwater water treatment and storage Yes No applicable requirement 

38 Process water treatment and storage Yes No applicable requirement 

39 On-site domestic wastewater and sewage treatment 

(10,000 gal/day) 

Yes No applicable requirement 

40 Housekeeping activities and associated cleaning 

products 

Yes No applicable requirement 

41 Heating ventilation & air conditioning equipment not 

designed to remove air contaminants 

Yes No applicable requirement 

42 General office activities Yes No applicable requirement 

43 Restroom facilities and associated cleanup operations 

and vents 

Yes No applicable requirement 

44 Normal consumer use of consumer products 

including hazardous substances as defined in 15 

U.S.C. 1261 et. seq. 

No The hazardous substances 

defined are too general to be 

considered insignificant. 

The source may request for 

specific substances to be 

evaluated for insignificance 

45 Vacuum cleaning systems used exclusively for 

commercial/industrial purposes 

Yes No applicable requirement 

46 Landscaping and site housekeeping activities Yes A.A.C. R18-2-101.54.a 

47 Fugitive emissions from landscaping activities Yes A.A.C. R18-2-101.54.a 

48 Use of pesticides, fumigants, and herbicides Yes No applicable requirement 

49 Groundskeeping activities and products Yes A.A.C. R18-2-101.54.a 

50 Firefighting activities and training conducted at the 

source in preparation for fighting fires 

No There is an applicable 

requirement (A.A.C. R18-2-

602) 

Air Quality TV Renewal Permit #52639 Page 21 of 24 December 06, 2011 

SRP – Coronado Generating Station 
51 Open burning activities No There is an applicable 

requirement (A.A.C. R18-2-

602) 

52 Flares used to indicate danger Yes No applicable requirement 

53 Activities associated with the construction, repair, or 

maintenance of roads or other paved or open areas, 

including operation of street sweepers, vacuum 

trucks, spray trucks or other vehicles related to the 

control of fugitive emissions of such roads or other 

areas 

No There is an applicable 

requirement (A.A.C. R18-2-

604) 

54 Road and lot paving operations No There is an applicable 

requirement (A.A.C. R18-2-

605) 

55 Cindering of streets and roads to abate traffic hazards 

caused by ice and snow 

Yes No applicable requirement 

56 Street and parking lot striping No There is an applicable 

requirement (A.A.C. R18-2-

604) 

57 Fugitive dust emissions from the operation of 

passenger vans, automobiles, station wagons, pickup 

trucks, or vans at a stationary source 

No There is an applicable 

requirement (A.A.C. R18-2-

604) 

58 Equipment using water, water and soap or detergent, 

or a suspension of abrasives in water for the purposes 

of cleaning or finishing 

Yes No applicable requirement 

59 Construction and disturbance of surface areas for 

purposes of land development (must still comply 

with AAC title 18, Chapter 2, Article 6 and other 

applicable requirements) 

No There is an applicable 

requirement (A.A.C. R18-2-

604) 

60 Activities at a source associated with the 

maintenance, repair, or dismantlement of an 

emissions unit or other equipment installed at the 

source, including preparation for maintenance, repair 

or dismantlement and preparation for subsequent 

startup, including preparation of a shutdown vessel 

for entry, replacement of insulation, welding, cutting, 

and steam purging of a vessel prior to startup; also 

includes maintenance, repair or dismantlement of 

building, utility lines, pipelines, wells, excavation, 

earthworks, and other structures that do not constitute 

and emissions unit (must comply with all applicable 

requirements) 

No There is an applicable 

requirement (A.A.C. R18-2-

730) 

61 Containers, reservoirs or tanks used exclusively in 

dipping operations to coat objects with oils, waxes, 

or greases 

No There is an applicable 

requirement (A.A.C. R18-2-

730) 

62 Activities directly used in the diagnosis and treatment 

of injury or other medical condition 

Yes No applicable requirement 

63 Manually operated equipment used for buffing, 

polishing, carving, cutting, drilling, machining, 

routing, sanding, sawing, surface grinding, or 

turning, and associated venting 

Yes A.A.C. R18-2-101.54.f 

Air Quality TV Renewal Permit #52639 Page 22 of 24 December 06, 2011 

SRP – Coronado Generating Station 
64 Various emissions points such as: sampling points, 

analyzers, process instrumentation, individual 

burners and sootblowers (emissions calculated as 

aggregate from generating units); transportable test 

equipment; individual flanges, valves, pump seals, 

pressure relief valves, and other individual 

components with the potential for leaks (must 

comply with applicable requirements). 

No There is an applicable 

requirement (A.A.C. R18-2-

730) 

65 Brazing, soldering, or welding operations Yes No applicable requirement 

66 Battery recharging areas Yes No applicable requirement 

67 Aerosol can usage Yes No applicable requirement 

68 Plastic pipe welding Yes No applicable requirement 

69 Acetylene, butane and propane torches and their use Yes No applicable requirement 

as long as remain under 

10,000 lb as stated in 40 

CFR 68.130 

70 Architectural painting and associated surface 

preparation for maintenance purposes (must comply 

with applicable requirements) 

No There is an applicable 

requirement (A.A.C. R18-2-

727) 

71 Steam vents, condenser vents, and boiler blowdown Yes No applicable requirement 

72 Equipment used exclusively for portable steam 

cleaning 

Yes No applicable requirement 

73 Blast cleaning equipment using a suspension of 

abrasives in water and any exhaust system or 

collector serving them exclusively 

Yes No applicable requirement 

74 Surface impoundments such as ash ponds, cooling 

ponds, evaporation ponds, settling ponds, and storm 

water ponds 

No There is an applicable 

requirement (A.A.C. R18-2-

730) 

75 Pump/motor oil reservoirs Yes No applicable requirement 

76 Transformer vents Yes No applicable requirement 

77 Lubricating system reservoirs Yes No applicable requirement 

78 Hydraulic system reservoirs Yes No applicable requirement 

79 Adhesive use not related to production Yes No applicable requirement 

80 Caulking operations not part of production process Yes No applicable requirement 

81 Electric motors Yes No applicable requirement 

82 High voltage induced corona Yes No applicable requirement 

83 Safety devices such as fire extinguishers Yes No applicable requirement 

84 Soil gas sampling Yes No applicable requirement 

85 Filter draining Yes No applicable requirement 

86 General vehicle maintenance and servicing activities Yes No applicable requirement 

with the exception being any 

activity contained in 40 CFR 

82 

87 Station transformers Yes No applicable requirement 

88 Circuit breakers Yes No applicable requirement 

89 Storage cabinets for flammable products Yes No applicable requirement 

90 Fugitive emissions from any landfill operations (if 

landfill not otherwise subject to federal applicable 

requirement) 

No There is an applicable 

requirement (A.A.C. R18-2-

731) 

Air Quality TV Renewal Permit #52639 Page 23 of 24 December 06, 2011 

SRP – Coronado Generating Station 
Air Quality TV Renewal Permit #52639 Page 24 of 24 December 06, 2011 

SRP – Coronado Generating Station 

XI. LIST OF ABBREVIATIONS 

 

A.A.C. ..........................................................................................Arizona Administrative Code 

ADEQ............................................................... Arizona Department of Environmental Quality 

AERMOD ................................................................................................Air Dispersion Model 

MM Btu/hr ................................................................... Million British Thermal Units per hour 

BACT.................................................................................Best Available Control Technology 

CAS.....................................................................................................Combustion Air Systems 

CECP................................................................................ Coronado Emissions Control Project 

CEMS...................................................................... Continuous Emission Monitoring Systems 

CFR ............................................................................................... Code of Federal Regulations 

CGS.............................................................................................. Coronado Generating Station 

CO ..................................................................................................................Carbon Monoxide 

COHPAC ....................................................................... Compact Hybrid Particulate Collector 

CS-ESP..............................................................................Cold Side Electro Static Precipitator 

EPA ..................................................................................... Environmental Protection Agency 

ESP.....................................................................................................Electrostatic Precipitators 

FF ............................................................................................................................Fabric Filter 

FGD.................................................................................................. Flue Gas Desulphurization 

o

F ................................................................................................................... Degree Fahrenheit 

GCP................................................................................................ Good Combustion Practices 

H2SO4 .........................................................................................................................................................................................Sulfuric Acid 

HAP...................................................................................................... Hazardous Air Pollutant 

HS-ESP ...............................................................................Hot Side Electro Static Precipitator 

lb/hr .................................................................................................................. Pound per Hour 

LEAR .................................................................................. Lowest Achievable Emission Rate 

LNB................................................................................................................Low NOx Burners 

LOI....................................................................................................................Loss on Ignition 

NAAQS........................................................................National Ambient Air Quality Standard 

NNSR............................................................................... Non-attainment New Source Review 

NOx ................................................................................................................. Nitrogen Oxides 

PM ................................................................................................................. Particulate Matter 

PM10 ....................................................Particulate Matter Nominally less than 10 Micrometers 

PRB .............................................................................................................Powder River Basin 

PSD .............................................................................. Prevention of Significant Deterioration 

PTE ................................................................. Potential to Emit or Permanent Total Enclosure 

RACT .................................................................... Reasonably Available Control Technology 

RBLC ................................................................................RACT/BACT/LAER Clearinghouse 

SAM..............................................................................................................Sulfuric Acid Mist 

SCR ............................................................................................. Selective Catalytic Reduction 

SIL....................................................................................................... Significant Impact Level 

SO2 ......................................................................................................................Sulfur Dioxide 

SRP................................................................................................................. Salt River Project 

WESP..........................................................................................Wet electrostatic precipitation 

VOC .............................................................................................. Volatile Organic Compound