NAVAJO GENERATING STATION 

PO. Box 850 

Page, AZ 86040 

(928) 645-62 17 

Fax (928) 645-7298 

May 1, 2015 

Mr. Gerardo Rios 

fR!ECIE~\?'lE!D 

MAY 1 2 2015 

---------------

U.S. Environmental Protection Agency, Region IX 

75 Hawthorne Street 

Mail Code: AIR-3 

San Francisco, California 94105 

Re: Administrative Permit Revision Application 

Navajo Generating Station 

PSD Permit Number AZ 08-0JA 

Dear Mr. Rios: 

ROBERT K. TALBOT 

Manager 

The Navajo Generating Station (NGS) is a pulverized coal steam electric generating facility that 

is operated by the Salt River Project Agricultural Improvement and Power District (SRP). NGS 

currently operates under Title V permit number NN-ROP 05-06 issued by the Navajo Nation 

Environmental Protection Agency (NNEP A). Additionally, NGS has been issued Prevention of 

Significant Deterioration (PSD) permit number AZ 08-0lA by United States Environmental 

Protection Agency's (EPA) Region 9. 

On March 31 , 2015, SRP submitted to NNEPA and EPA an addendum to it Title V permit 

renewal application to incorporate the applicable mercury (Hg) provisions of the Mercury and 

Air Toxics Standard (MATS) Rule and to authorize the Hg control equipment necessary for 

complying with the MATS Hg emission limits. On April 20, 2015, SRP had been notified by 

EPA that the new Hg control equipment to be installed is subject to the administrative permit 

revision requirements under 40 CFR §49.159(f) 1

• As a result, SRP is submitting this 

administrative permit revision application under the direction of EPA to authorize the Hg control 

equipment. 

Description of Change 

1 Per telephone conversation between Lisa Beckham, EPA Region 9, and Kyle Heckel, SRP on April 20, 2015. 
The proposed Hg control system will consist of a new calcium bromide application system and a 

new powdered activated carbon (PAC) injection system. Details of each system are described 

below: 

Calcium Bromide Application System 

The calcium bromide application system will consist of one main 60,000 gallon storage tank, 

three 4,500 gallon day tanks, and several pumping skids for transferring the calcium bromide. 

Liquid calcium bromide will be truck delivered into the main storage tank. The calcium bromide 

will be transferred to each unit's day tank via dedicated transfer pumps. From the day tanks, 

calcium bromide will applied to the coal directly at each exi ting coal pulverizer feeder. 

No air emissions are anticipated from the calcium bromide application system. 

PAC Injection System 

The PAC injection system will consist of two 40 ton storage silos, each equipped with a 

baghouse, two feed tanks containing PAC slurry, and various pumping skids for transferring the 

PAC slurry. 

PAC will be truck delivered into the main storage silos for bulk storage. From the storage silos, 

the PAC will be mixed with water creating a PAC slurry and subsequently transferred to the feed 

tank. PAC slurry will then be fed to each absorber as needed. 

Particulate matter emissions are anticipated from the unloading of PAC into the storage silos. 

Potential Emissions 

The proposed PAC storage silo dust collectors are anticipated to be sources of particulate matter 

(PM, PM10, and PM25) emissions. Using the manufacture's design flow rate and particulate grain 

loading rate for the baghouses and assuming 8,760 hours of operation per year, the total potential 

emissions from the project are estimated to be 0.08 tons per year for PM, PMw and PM2.s. 

Detailed emission calculations and the manufacture's specification sheet for the baghouses are 

attached. 

If you have any questions regarding this application submittal, please contact Kyle Heckel at 

(602) 236-5493 or me at (928) 645-6217. 

Sincerely, ~ 

~;{! Robert Talbot, Manager 

Navajo Generating Station 
cc w/attachment: Stephen B. Etsitty, NNEP A 

Paul Ostapuk, NGS 

LOC 6-2-6 
Table 1: p, . I E . . f1 Dust Coll s 

Description Control Flow Rate PM EF1 PM10 EF1 PM2.s EF1 PM Emissions PM10 Emissions PM2.

5 Emissions 

Device (acfm) (gr/act) (2r/acO (l!r/acf) llb/hd (tons/yr)3 (lb/hd (tonstvd (lb/hd (tons/vr)

3 

PAC Storage Silo A Baghouse 1,200 8.80E-04 8.80E-04 8.80E-04 0.009 1 0.040 0.009 1 0.040 0.009 1 0.0396 

PAC Storage Silo B Baghouse 1,200 8.80E-04 8.80E-04 8.80E-04 0.0091 0.040 0.009 1 0.040 0.009 1 0.0396 

Total Emissions from Dust Collection Systems 0.02 0.08 0.02 0.08 0.02 0.08 

l) Emission factors based on manufacturers' data (see Attachment). 

2) Emissions (lb/hr)= Flow Rate (acfm) x Emission Factor (gr/act) x (lb/7,000 grain) x (60 min/hr) 

3) Emissions (tons/yr) = Emissions (lb/hr) x 8, 760 hr/yr x ( l ton/2,000 lb) 
• 

CHEMCO Equipment Company 

1500 Industrial Drive 

Monongahela, PA 15063 

-

CHE MC -O •Tele.: (724) 258-7333 •Fax.: (724) 258-7350 

EQUIPMENT •e-mail: sales@chemcoequipment.com 

February 16, 2007 

RE: Dust Collector Emission Information 

Below is the requested for information on the dust collector. We are proposing to 

furnish a CHEMCO Model CEC-DC300 dust collector with the following design 

specifications: 

• Filter Area: 300 Square Feet 

• Fi lter Media: Pleated polyester 

• Blow In Rate: 750 SCFM 

• Fill Cycle Duration: 60-90 Minutes per Fill Cycle 

• Cloth Loading: 2.5 SCFM/Square Feet 

• Fan Capacity: 1200 SCFM @ 5" W.C. 

• Outlet Emissions: .00088 Grains/CF (2mg/M3

) 

• Efficiency: 99.9% Based upon an inlet loading of 20 grains/cubic foot 

If you need additional information on the dust collector for your air permit application, 

please advise. 

Sincerely, 

CHEMCO 

Jeffrey A. Tennant 

Visit our web site at www.chemcoequipment.com