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 c ontinued 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-NO

x 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 cont rol 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, m echanically induced draft cooling towers, 500 kV and 69 kV switchyards a nd 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 curre ntly installed and operati ng, 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-NO

x Burners and Overfire Air Selective Catalytic Reduction (Unit 2 Only) Baghouses
Dust Extractors

Hot-side electrostatic precipitators (ESP) are de signed to remove 99.875 percent of the ash from the boiler flue gas. Two ESPs are provided for each un it and divided into two halves. Each half is provided with a single level of six parallel chambe rs 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 transporte d 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 desulfur ization (FGD) units are installed and operating on
Unit 1 to reduce SO 2 emissions. A vertical countercurrent flow limestone FGD unit is currently installed and operating on Unit 2. The existing hor izontal FGD units on Unit 1 are planned to be replaced with a single vertical countercurrent FGD un it, 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 Stat es Environmental Protection Agency (EPA) to upgrade air quality control equipment for nitrogen oxides (NO

x ) and sulfur dioxide (SO 2 ) 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 scr ubber systems to Unit 1 and 2. In addition,

Air Quality TV Renewal Perm it #52639 Page 2 of 24 December 06, 2011 SRP – Coronado Generating StationSRP will install a selective catalytic reduction (SCR) system on Unit 2. The changes associated with the CECP were approved in 2008 under si gnificant revision #46326. Table 2 lists the equipment installation status:

Table 2: Control Equipment Installation Status

Equipment Unit 1 Unit 2
Low-NO

x 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 NO

x , CO, SO 2 , VOCs,
PM 10 , 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) *

PM 10 4,323 2,003

VOC 117 143

SO 2 33,771 8,271

NO

x 29,052 8,291

CO 991 20,674

Federal HAPs > 25 tpy Total HAPs > 10 tpy Individual HAP *Following completion of all of th e changes associated with the CECP

Table 4: PTE Emissions of Criteria Pollutants*

Unit PM10 SO

x NO

x 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

Air Quality TV Renewal Perm it #52639 Page 3 of 24 December 06, 2011 SRP – Coronado Generating StationLimestone 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 st eam 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 Decembe r 21, 2005, 2 on-site inspec tions 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. U pon inspection, the inspectors did not observe any violation. The inspectors noted that SRP had comp leted the installation of new low-NOx burner on Unit 1. All quarterly Monitoring and Semiannual Complia nce Certifications were submitted on time and no violations were noted. Annual performance tests c onducted 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 (NO

x ) and sulfur dioxide (SO 2 ). 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.

Air Quality TV Renewal Perm it #52639 Page 4 of 24 December 06, 2011 SRP – Coronado Generating StationIV. 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 perm it 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, SO 2 , 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 su b ject 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 Perm it #52639 Page 5 of 24 December 06, 2011 SRP – Coronado Generating StationAir Quality TV Renewal Perm it #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 operationsV. 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 upg rade 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 Perm it #52639 Page 7 of 24 December 06, 2011 SRP – Coronado Generating StationSystem 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) eachequipped 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 perm it 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 Perm it #52639 Page 8 of 24 December 06, 2011 SRP – Coronado Generating StationAir Quality TV Renewal Perm it #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 operationa l 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 lb s/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 histori cally 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 ha d agreed that monitoring the current and voltage on a continuous basis allows for a mo re accurate way of determining how the ESPs operated. Having continuous data of the electri cal 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 Testi ng, 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 we t 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 ra te 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 SO 2 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 Perm it #52639 Page 10 of 24 December 06, 2011 SRP – Coronado Generating Stationrolling 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 establis hed 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 th e 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 standa rd 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 SO 2 removal efficiency of at least 95% or a 30-day rolling average SO 2 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 Perm it #52639 Page 11 of 24 December 06, 2011 SRP – Coronado Generating Station60.44(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- NO

x burners, the source is subject to a 30-day rolling average NO

x 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 inst allation 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 NO

x emissions. Compliance test results indicate that the units are able to meet the standard. The Permittee is required to operate a continuous emi ssions 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 conti nuous 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 sta ndards 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 re quired 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 ob served 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 th e 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 op acity 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 o il is burned continuously in the units.

Air Quality TV Renewal Perm it #52639 Page 12 of 24 December 06, 2011 SRP – Coronado Generating Station2. 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 Pe rmittee 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 “ba llpark” the particulate matter emissions. No engineering estimation using ash content is prescribed in the permit since it could be interpreted to incorrectly correlate particulat e 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:

SO 2 (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 availa ble. 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 Perm it #52639 Page 13 of 24 December 06, 2011 SRP – Coronado Generating Station1. Opacity

The generators or internal combustion engin es 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 Referen ce 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 emissi on 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 s ource is also required to keep a record of the corrective action performed.

2. Particulate Matter

The source is required to monitor the lower hea ting 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 emerge ncy fire pump (less than 500 hp) engine only for emergency use and up to 100 hours of required main tenance 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 re quired 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% op acity 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 certifie d 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 w ill keep a record of the corrective action

Air Quality TV Renewal Perm it #52639 Page 14 of 24 December 06, 2011 SRP – Coronado Generating Stationperformed. 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 opera te the baghouses and wet dust extractors in accordance with the manufacturer’s specificati on. 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 sta ndard, the observer shall conduct a certified EPA Reference Method 9 observation. The Permittee will be required to k eep 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 obser ver, 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 require d to initiate appropriate corrective action to reduce the opacity below the standard. The Pe rmittee 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 m atter 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 sta ndard, the observer shall conduct a certified EPA Reference Method 9 observation. The Permittee will be required to k eep 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 obser ver, 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 Perm it #52639 Page 15 of 24 December 06, 2011 SRP – Coronado Generating Stationthe opacity standard, the Permittee will be require d to initiate appropriate corrective action to reduce the opacity below the standard. The Pe rmittee 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 ope rate 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 to wers 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 st andard 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 sta ndard, the observer shall conduct a certified EPA Reference Method 9 observation. The Permittee will be required to k eep 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 obser ver, 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 require d to initiate appropriate corrective action to reduce the opacity below the standard. The Pe rmittee 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 Ad ministrative 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 Perm it #52639 Page 16 of 24 December 06, 2011 SRP – Coronado Generating Station8. 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 b asis the visible emissions are in excess of the opacity standard, then he is required to ma ke 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 re quired 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 satisfi ed 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 requireme nts 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 require ment, 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 pain ts and solvents used in the project.

Air Quality TV Renewal Perm it #52639 Page 17 of 24 December 06, 2011 SRP – Coronado Generating Station3. 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 sha ll not fall below 100 degrees Fahrenheit. The amount
of used oil shall not exceed 350 ba rrels 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 re quirements 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 performan ce tests for opacity, particulate matter, SO 2 and NO

x in accordance with 40 CFR Part 60, Subpart D.

1. Particulate Matter

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

Air Quality TV Renewal Perm it #52639 Page 18 of 24 December 06, 2011 SRP – Coronado Generating StationReference 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 produc tion 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 perfo rmance 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 pr oduction rate, but not later than 180 days after the installation of second flue gas desulfurizati on unit, the Permittee is required to conduct an initial performance test for PM/PM 10 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 th e use fuel oil annually for Arsenic, Cadmium, Chromium, and Lead usi ng 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 locat ed 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 subpa rt and of subpart A of the 40 CFR 63. No initial notification is required. The only engines at th e 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 Perm it #52639 Page 19 of 24 December 06, 2011 SRP – Coronado Generating StationX. 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 insigni ficant 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 scavenge r 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 ta nk (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 ta nk (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 Perm it #52639 Page 20 of 24 December 06, 2011 SRP – Coronado Generating Station25 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 he rbicides 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 Perm it #52639 Page 21 of 24 December 06, 2011 SRP – Coronado Generating Station51 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 ot her 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 Perm it #52639 Page 22 of 24 December 06, 2011 SRP – Coronado Generating Station64 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 opera tions 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 boile r 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 produc tion 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 Perm it #52639 Page 23 of 24 December 06, 2011 SRP – Coronado Generating StationAir 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.....................................................................................................Combusti on Air Systems CECP................................................................................ Coronado Emissions Control Project CEMS...................................................................... Continuous Emission Monitoring Systems
CFR ............................................................................................... Code of Fe deral 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.....................................................................................................Electrosta tic Precipita tors FF ............................................................................................................................F abric Filter FGD.................................................................................................. Flue Gas Desulphurization

o F ................................................................................................................... Degree Fahr enheit
GCP................................................................................................ Good Combustion Practices
H 2 SO 4 ......................................................................................................................................................................................... Sulfuric Acid
HAP...................................................................................................... Hazardous Air Pollutan t HS-ESP ...............................................................................Hot Side Electro Static Precipitator lb/hr .................................................................................................................. Pound p er Hour
LEAR .................................................................................. Lowest Achiev able Emission Rate
LNB................................................................................................................Low NO

x Burners
LOI....................................................................................................................Loss on Ignition NAAQS........................................................................National Ambient Air Quality Standard
NNSR............................................................................... Non-attainment New Source Review
NO

x ................................................................................................................. Nitrogen Oxi des
PM ................................................................................................................. Particulate Matter
PM 10 ....................................................Particulate Matter Nominally less than 10 Micrometers
PRB .............................................................................................................Powder River Ba sin 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 Le vel
SO 2 ......................................................................................................................Sulfur Di oxide
SRP................................................................................................................. Salt River Project WESP..........................................................................................Wet electrostatic precipitation VOC .............................................................................................. Volatile Organic Compound