ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY CLASS I, TITLE V PERMIT 

COMPANY: Salt River Project

FACILITY: Coronado Generating Station

PERMIT #: 52639

DATE ISSUED: December 6, 2011

EXPIRY DATE: December 6, 2016 

SUMMARY 

This Class I, Title V operating permit renewal is issued to Salt River Project (SRP), the Permittee, for the 

continued operation of their Coronado Generating Station located in Apache County, six miles northeast 

of St. Johns, Arizona off U.S Highway 191. This is a renewal of Air Quality Permit #30732. 

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. 

This permit is issued in accordance with Title 49, Chapter 3 of the Arizona Revised Statutes. All 

definitions, terms, and conditions used in this permit conform to those in the Arizona Administrative 

Code R18-2-101 et. seq. (A.A.C.) and 40 Code of Federal Regulations (CFR), except as otherwise 

defined in this permit. All terms and conditions in this permit are enforceable by the Administrator of the 

U.S. Environmental Protection Agency (EPA), except those terms and conditions that are specifically 

identified as “State Enforceable Only.” 
 

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TABLE OF CONTENTS 

ATTACHMENT “A”: GENERAL PROVISION....................................................................................3

I. PERMIT EXPIRATION AND RENEWAL....................................................................................3

II. COMPLIANCE WITH PERMIT CONDITIONS ...........................................................................3

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR 

TERMINATION FOR CAUSE.......................................................................................................3

IV. POSTING OF PERMIT...................................................................................................................4

4

4

4

5

5

6

6

6

11

11

11

12

12

13

15

15

15

15

XI. OTHER PERIODIC ACTIVITIES......................................................... ... ....................................68

V. FEE PAYMENT ..............................................................................................................................

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE ...........................................................

VII. COMPLIANCE CERTIFICATION ................................................................................................

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS .....................................

IX. INSPECTION AND ENTRY ..........................................................................................................

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT 

STANDARD....................................................................................................................................

XI. ACCIDENTAL RELEASE PROGRAM.........................................................................................

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING ...............

XIII. RECORD KEEPING REQUIREMENTS .....................................................................................

XIV. REPORTING REQUIREMENTS .................................................................................................

XV. DUTY TO PROVIDE INFORMATION.......................................................................................

XVI. PERMIT AMENDMENT OR REVISION....................................................................................

XVII. FACILITY CHANGE WITHOUT A PERMIT REVISION.........................................................

XVIII. TESTING REQUIREMENTS .......................................................................................................

XIX. PROPERTY RIGHTS....................................................................................................................

XX. SEVERABILITY CLAUSE ..........................................................................................................

XXI. PERMIT SHIELD..........................................................................................................................

XXII. PROTECTION OF STRATOSPHERIC OZONE .........................................................................

ATTACHMENT “B”: SPECIFIC PROVISIONS ....... ........................................................17 

I. FACILITY WIDE LIMITATIONS........................................................................................... .....17

II. UNITS 1 AND 2 BOILERS ...... ....................................................................................................17

III. AUXILIARY BOILER......................................................................................................... . ........50

IV. INTERNALCOMBUSTIONENGINES.......................................................................... ..............53

V. COAL HANDLING.................................................................................................... ...................57

VI. LIMESTONE HANDLING....... ....................................................................................................59

VII. FLY ASH HANDLING................................................................................ . ................................62

VIII. COOLING TOWERS 1 AND 2.................................................................... .................................63

IX. USED OIL SPECIFICATION.................................................................. .. ...................................65 

X. FUGITIVE EMISSIONS.......................................................................... ... ..................................66

XII. COAL ADDITIVE SODA ASH SILO...........................................................................................72 

ATTACHMENT “C”: EQUIPMENT LIST.... .......................................................................................74 

ATTACHMENT “D”: PHASE II ACID RAIN PROVISIONS.............................................................78 
 

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ATTACHMENT “A”: GENERAL PROVISIONS 

Air Quality Control Permit No. 30732 

for 

Salt River Project, Coronado Generating Station 

I. PERMIT EXPIRATION AND RENEWAL [ARS § 49-426.F, A.A.C. R18-2-304.C.2, and -306.A.1] 

A. This permit is valid for a period of five years from the date of issuance.

B. The Permittee shall submit an application for renewal of this permit at least 6 months, but 

not more than 18 months, prior to the date of permit expiration.

II. COMPLIANCE WITH PERMIT CONDITIONS [A.A.C. R18-2-306.A.8.a and b]

A. The Permittee shall comply with all conditions of this permit including all applicable 

requirements of the Arizona air quality statutes and air quality rules. Any permit 

noncompliance constitutes a violation of the Arizona Revised Statutes and is grounds for 

enforcement action; for permit termination, revocation and reissuance, or revision; or for 

denial of a permit renewal application. In addition, noncompliance with any federally 

enforceable requirement constitutes a violation of the Clean Air Act.

B. It shall not be a defense for a Permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit.

III. PERMIT REVISION, REOPENING, REVOCATION AND REISSUANCE, OR 

TERMINATION FOR CAUSE [A.A.C. R18-2-306.A.8.c, -321.A.1, and -321.A.2]

A. The permit may be revised, reopened, revoked and reissued, or terminated for cause. The 

filing of a request by the Permittee for a permit revision, revocation and reissuance, 

termination, or of a notification of planned changes or anticipated noncompliance does 

not stay any permit condition.

B. The permit shall be reopened and revised under any of the following circumstances:

1. Additional applicable requirements under the Clean Air Act become applicable to 

the Class I source. Such a reopening shall only occur if there are three or more 

years remaining in the permit term. The reopening shall be completed no later 

than 18 months after promulgation of the applicable requirement. No such 

reopening is required if the effective date of the requirement is later than the date 

on which the permit is due to expire, unless an application for renewal has been 

submitted pursuant to A.A.C. R18-2-322.B. Any permit revision required 

pursuant to this subparagraph shall comply with the provisions in A.A.C. R18-2-

322 for permit renewal and shall reset the five-year permit term. 

2. Additional requirements, including excess emissions requirements, become 

applicable to an affected source under the acid rain program. Upon approval by 

the Administrator, excess emissions offset plans shall be deemed to be 
 

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SRP – Coronado Generating Station 

incorporated into the Class I permit. 

3. The Director or the Administrator determines that the permit contains a material 

mistake or that inaccurate statements were made in establishing the emissions 

standards or other terms or conditions of the permit. 

4. The Director or the Administrator determines that the permit needs to be revised 

or revoked to assure compliance with the applicable requirements. 

C. Proceedings to reopen and reissue a permit, including appeal of any final action relating 

to a permit reopening, shall follow the same procedures as apply to initial permit issuance 

and shall, except for reopenings under Condition III.B.1 above, affect only those parts of 

the permit for which cause to reopen exists. Such reopenings shall be made as 

expeditiously as practicable. Permit reopenings for reasons other than those stated in 

Condition III.B.1 above shall not result in a resetting of the five-year permit term.

IV. POSTING OF PERMIT [A.A.C. R18-2-315]

A. The Permittee shall post this permit or a certificate of permit issuance where the facility 

is located in such a manner as to be clearly visible and accessible. All equipment covered 

by this permit shall be clearly marked with one of the following:

1. Current permit number; or 

2. Serial number or other equipment ID number that is also listed in the permit to 

identify that piece of equipment. 

B. A copy of the complete permit shall be kept on site.

V. FEE PAYMENT [A.A.C. R18-2-306.A.9 and -326]

 The Permittee shall pay fees to the Director pursuant to ARS § 49-426(E) and A.A.C. R18-2-326. 

VI. ANNUAL EMISSION INVENTORY QUESTIONNAIRE [A.A.C. R18-2-327.A and B]

A. The Permittee shall complete and submit to the Director an annual emissions inventory 

questionnaire. The questionnaire is due by March 31st or ninety days after the Director 

makes the inventory form available each year, whichever occurs later, and shall include 

emission information for the previous calendar year.

B. The questionnaire shall be on a form provided by the Director and shall include the 

information required by A.A.C. R18-2-327.

VII. COMPLIANCE CERTIFICATION [A.A.C. R18-2-309.2.a, -309.2.c-d, and -309.5.d]

A. The Permittee shall submit a compliance certification to the Director semiannually, which 

describes the compliance status of the source with respect to each permit condition. The 

first certification shall be submitted no later than May 15th, and shall report the 

compliance status of the source during the period between October 1st of the previous 

year and March 31st of the current year. The second certification shall be submitted no 

later than November 15th, and shall report the compliance status of the source during the 
 

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SRP – Coronado Generating Station 

period between April 1st and September 30th of the current year.

 The compliance certifications shall include the following: 

1. Identification of each term or condition of the permit that is the basis of the 

certification; 

2. Identification of the methods or other means used by the Permittee for 

determining the compliance status with each term and condition during the 

certification period. 

3. The status of compliance with the terms and conditions of this permit for the 

period covered by the certification, based on the methods or means designated in 

Condition VII.A.2 above. The certifications shall identify each deviation and 

take it into account for consideration in the compliance certification; 

4. For emission units subject to 40 CFR Part 64, the certification shall also identify 

as possible exceptions to compliance any period during which compliance is 

required and in which an excursion or exceedance defined under 40 CFR Part 64 

occurred; 

5. All instances of deviations from permit requirements reported pursuant to 

Condition XII.B of this Attachment; and 

6. Other facts the Director may require to determine the compliance status of the 

source. 

B. A copy of all compliance certifications shall also be submitted to the EPA Administrator.

C. If any outstanding compliance schedule exists, a progress report shall be submitted with 

the semi-annual compliance certifications required in Condition VII.A above.

VIII. CERTIFICATION OF TRUTH, ACCURACY AND COMPLETENESS [A.A.C. R18-2-304.H]

Any document required to be submitted by this permit, including reports, shall contain a 

certification by a responsible official of truth, accuracy, and completeness. This certification 

shall state that, based on information and belief formed after reasonable inquiry, the statements 

and information in the document are true, accurate, and complete. 

IX. INSPECTION AND ENTRY [A.A.C. R18-2-309.4]

Upon presentation of proper credentials, the Permittee shall allow the Director or the authorized 

representative of the Director to: 

A. Enter upon the Permittee’s premises where a source is located, emissions-related activity 

is conducted, or where records are required to be kept under the conditions of the permit:

B. Have access to and copy, at reasonable times, any records that are required to be kept 

under the conditions of the permit;

C. Inspect, at reasonable times, any facilities, equipment (including monitoring and air 
 

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SRP – Coronado Generating Station 

pollution control equipment), practices, or operations regulated or required under the 

permit;

D. Sample or monitor, at reasonable times, substances or parameters for the purpose of 

assuring compliance with the permit or other applicable requirements; and

E. Record any inspection by use of written, electronic, magnetic and photographic media.

X. PERMIT REVISION PURSUANT TO FEDERAL HAZARDOUS AIR POLLUTANT 

STANDARD [A.A.C. R18-2-304.C]

If this source becomes subject to a standard promulgated by the Administrator pursuant to Section 

112(d) of the Act, then the Permittee shall, within twelve months of the date on which the 

standard is promulgated, submit an application for a permit revision demonstrating how the 

source will comply with the standard. 

XI. ACCIDENTAL RELEASE PROGRAM [40 CFR Part 68]

If this source becomes subject to the provisions of 40 CFR Part 68, then the Permittee shall 

comply with these provisions according to the time line specified in 40 CFR Part 68. 

XII. EXCESS EMISSIONS, PERMIT DEVIATIONS, AND EMERGENCY REPORTING 

A. Excess Emissions Reporting [A.A.C. R18-2-310.01.A and -310.01.B]

1. Excess emissions shall be reported as follows: 

a. The Permittee shall report to the Director any emissions in excess of the 

limits established by this permit. Such report shall be in two parts as 

specified below: 

(1) Notification by telephone or facsimile within 24 hours of the 

time when the Permittee first learned of the occurrence of excess 

emissions including all available information from Condition 

XII.A.1.b below. 

(2) Detailed written notification by submission of an excess 

emissions report within 72 hours of the notification pursuant to 

Condition XII.A.1.a.(1) above. 

b. The report shall contain the following information: [A.A.C. R18-2-310.01.C] 

(1) Identity of each stack or other emission point where the excess 

emissions occurred; 

(2) Magnitude of the excess emissions expressed in the units of the 

applicable emission limitation and the operating data and 

calculations used in determining the magnitude of the excess 

emissions; 
 

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SRP – Coronado Generating Station 

(3) Date, time and duration, or expected duration, of the excess 

emissions; 

(4) Identity of the equipment from which the excess emissions 

emanated; 

(5) Nature and cause of such emissions; 

(6) If the excess emissions were the result of a malfunction, steps 

taken to remedy the malfunction and the steps taken or planned 

to prevent the recurrence of such malfunctions; and 

(7) Steps taken to limit the excess emissions. If the excess 

emissions resulted from start-up or malfunction, the report shall 

contain a list of the steps taken to comply with the permit 

procedures. 

2. In the case of continuous or recurring excess emissions, the notification 

requirements of this section shall be satisfied if the source provides the required 

notification after excess emissions are first detected and includes in such 

notification an estimate of the time the excess emissions will continue. Excess 

emissions occurring after the estimated time period, or changes in the nature of 

the emissions as originally reported, shall require additional notification pursuant 

to Condition XII.A.1 above. 

B. Permit Deviations Reporting [A.A.C. R18-2-306.A.5.b]

The Permittee shall promptly report deviations from permit requirements, including those 

attributable to upset conditions as defined in the permit, the probable cause of such 

deviations, and any corrective actions or preventive measures taken. Prompt reporting 

shall mean that the report was submitted to the Director by certified mail, facsimile, or 

hand delivery within two working days of the time when emission limitations were 

exceeded due to an emergency or within two working days of the time when the owner or 

operator first learned of the occurrence of a deviation from a permit requirement. 

C. Emergency Provision [A.A.C. R18-2-306.E]

1. An “emergency” means any situation arising from sudden and reasonable 

unforeseeable events beyond the control of the source, including acts of God, that 

require immediate corrective action to restore normal operation, and that causes 

the source to exceed a technology-based emission limitation under the permit, 

due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly 

designed equipment, lack of preventative maintenance, careless or improper 

operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emission limitations if Condition 

XII.C.3 is met. 
 

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SRP – Coronado Generating Station 

3. The affirmative defense of emergency shall be demonstrated through properly 

signed, contemporaneous operating logs, or other relevant evidence that: 

a. An emergency occurred and that the Permittee can identify the cause(s) 

of the emergency; 

b. The permitted facility was being properly operated at the time; 

c. During the period of the emergency, the Permittee took all reasonable 

steps to minimize levels of emissions that exceeded the emissions 

standards or other requirements in the permit; and 

d. The Permittee submitted notice of the emergency to the Director by 

certified mail, facsimile, or hand delivery within two working days of the 

time when emission limitations were exceeded due to the emergency. 

This notice shall contain a description of the emergency, any steps taken 

to mitigate emissions, and corrective action taken. 

4. In any enforcement proceeding, the Permittee seeking to establish the occurrence 

of an emergency has the burden of proof. 

5. This provision is in addition to any emergency or upset provision contained in 

any applicable requirement. 

D. Compliance Schedule [ARS § 49-426.I.5]

For any excess emission or permit deviation that cannot be corrected with 72 hours, the 

Permittee is required to submit a compliance schedule to the Director within 21 days of 

such occurrence. The compliance schedule shall include a schedule of remedial 

measures, including an enforceable sequence of actions with milestones, leading to 

compliance with the permit terms or conditions that have been violated. 

E. Affirmative Defenses for Excess Emissions Due to Malfunctions, Startup, and 

Shutdown [A.A.C. R18-2-310] 

1. Applicability 

This rule establishes affirmative defenses for certain emissions in excess of an 

emission standard or limitation and applies to all emission standards or 

limitations except for standards or limitations: 

a. Promulgated pursuant to Sections 111 or 112 of the Act; 

b. Promulgated pursuant to Titles IV or VI of the Clean Air Act; 

c. Contained in any Prevention of Significant Deterioration (PSD) or New 

Source Review (NSR) permit issued by the U.S. EPA; 

d. Contained in A.A.C. R18-2-715.F; or 

e. Included in a permit to meet the requirements of A.A.C. R18-2-406.A.5. 
 

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2. Affirmative Defense for Malfunctions 

Emissions in excess of an applicable emission limitation due to malfunction shall 

constitute a violation. When emissions in excess of an applicable emission 

limitation are due to a malfunction, the Permittee has an affirmative defense to a 

civil or administrative enforcement proceeding based on that violation, other than 

a judicial action seeking injunctive relief, if the Permittee has complied with the 

reporting requirements of A.A.C. R18-2-310.01 and has demonstrated all of the 

following: 

a. The excess emissions resulted from a sudden and unavoidable 

breakdown of process equipment or air pollution control equipment 

beyond the reasonable control of the Permittee; 

b. The air pollution control equipment, process equipment, or processes 

were at all times maintained and operated in a manner consistent with 

good practice for minimizing emissions; 

c. If repairs were required, the repairs were made in an expeditious fashion 

when the applicable emission limitations were being exceeded. Off-shift 

labor and overtime were utilized where practicable to ensure that the 

repairs were made as expeditiously as possible. If off-shift labor and 

overtime were not utilized, the Permittee satisfactorily demonstrated that 

the measures were impracticable; 

d. The amount and duration of the excess emissions (including any bypass 

operation) were minimized to the maximum extent practicable during 

periods of such emissions; 

e. All reasonable steps were taken to minimize the impact of the excess 

emissions on ambient air quality; 

f. The excess emissions were not part of a recurring pattern indicative of 

inadequate design, operation, or maintenance; 

g. During the period of excess emissions there were no exceedances of the 

relevant ambient air quality standards established in Title 18, Chapter 2, 

Article 2 of the Arizona Administrative Code that could be attributed to 

the emitting source; 

h. The excess emissions did not stem from any activity or event that could 

have been foreseen and avoided, or planned, and could not have been 

avoided by better operations and maintenance practices; 

i. All emissions monitoring systems were kept in operation if at all 

practicable; and 

j. The Permittee's actions in response to the excess emissions were 

documented by contemporaneous records 
 

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SRP – Coronado Generating Station 

3. Affirmative Defense for Startup and Shutdown 

a. Except as provided in Condition XII.E.3.b below, and unless otherwise 

provided for in the applicable requirement, emissions in excess of an 

applicable emission limitation due to startup and shutdown shall 

constitute a violation. When emissions in excess of an applicable 

emission limitation are due to startup and shutdown, the Permittee has an 

affirmative defense to a civil or administrative enforcement proceeding 

based on that violation, other than a judicial action seeking injunctive 

relief, if the Permittee has complied with the reporting requirements of 

A.A.C. R18-2-310.01 and has demonstrated all of the following: 

(1) The excess emissions could not have been prevented through 

careful and prudent planning and design; 

(2) If the excess emissions were the result of a bypass of control 

equipment, the bypass was unavoidable to prevent loss of life, 

personal injury, or severe damage to air pollution control 

equipment, production equipment, or other property; 

(3) The air pollution control equipment, process equipment, or 

processes were at all times maintained and operated in a manner 

consistent with good practice for minimizing emissions; 

(4) The amount and duration of the excess emissions (including any 

bypass operation) were minimized to the maximum extent 

practicable during periods of such emissions; 

(5) All reasonable steps were taken to minimize the impact of the 

excess emissions on ambient air quality; 

(6) During the period of excess emissions there were no 

exceedances of the relevant ambient air quality standards 

established in Title 18, Chapter 2, Article 2 of the Arizona 

Administrative Code that could be attributed to the emitting 

source; 

(7) All emissions monitoring systems were kept in operation if at all 

practicable; and 

(8) Contemporaneous records documented the Permittee’s actions in 

response to the excess emissions. 

b. If excess emissions occur due to a malfunction during routine startup and 

shutdown, then those instances shall be treated as other malfunctions 

subject to Condition XII.E.2 above. 

4. Affirmative Defense for Malfunctions During Scheduled Maintenance 

If excess emissions occur due to a malfunction during scheduled maintenance, 

then those instances will be treated as other malfunctions subject to Condition 
 

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SRP – Coronado Generating Station 

XII.E.2 above. 

5. Demonstration of Reasonable and Practicable Measures 

For an affirmative defense under Condition XII.E.2 or XII.E.3 above, the 

Permittee shall demonstrate, through submission of the data and information 

required by Condition XII.E and A.A.C. R18-2-310.01, that all reasonable and 

practicable measures within the Permittee’s control were implemented to prevent 

the occurrence of the excess emissions. 

XIII. RECORD KEEPING REQUIREMENTS [A.A.C. R18-2-306.A.4]

A. The Permittee shall keep records of all required monitoring information including, but 

not limited to, the following:

1. The date, place as defined in the permit, and time of sampling or measurements; 

2. The date(s) analyses were performed; 

3. The name of the company or entity that performed the analyses; 

4. A description of the analytical techniques or methods used; 

5. The results of such analyses; and 

6. The operating conditions as existing at the time of sampling or measurement. 

B. The Permittee shall retain records of all required monitoring data and support information 

for a period of at least 5 years from the date of the monitoring sample, measurement, 

report, or application. Support information includes all calibration and maintenance 

records and all original strip-chart recordings or other data recordings for continuous 

monitoring instrumentation, and copies of all reports required by the permit.

C. All required records shall be maintained either in an unchangeable electronic format or in 

a handwritten logbook utilizing indelible ink. 

XIV. REPORTING REQUIREMENTS [A.A.C. R18-2-306.A.5.a]

The Permittee shall submit the following reports: 

A. Compliance certifications in accordance with Section VII of Attachment “A”.

B. Excess emission; permit deviation, and emergency reports in accordance with Section XII 

of Attachment “A”.

C. Other reports required by any condition of Attachment “B”.

XV. DUTY TO PROVIDE INFORMATION [A.A.C. R18-2-304.G and -306.A.8.e]

A. The Permittee shall furnish to the Director, within a reasonable time, any information that 

the Director may request in writing to determine whether cause exists for revising, 
 

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SRP – Coronado Generating Station 

revoking and reissuing, or terminating the permit, or to determine compliance with the 

permit. Upon request, the Permittee shall also furnish to the Director copies of records 

required to be kept by the permit. For information claimed to be confidential, the 

Permittee shall furnish an additional copy of such records directly to the Administrator 

along with a claim of confidentiality.

B. If the Permittee has failed to submit any relevant facts or has submitted incorrect 

information in the permit application, the Permittee shall, upon becoming aware of such 

failure or incorrect submittal, promptly submit such supplementary facts or corrected 

information.

XVI. PERMIT AMENDMENT OR REVISION [A.A.C. R18-2-318, -319, and -320]

The Permittee shall apply for a permit amendment or revision for changes to the facility which 

does not qualify for a facility change without revision under Section XVII, as follows: 

A. Administrative Permit Amendment (A.A.C. R18-2-318);

B. Minor Permit Revision (A.A.C. R18-2-319); and

C. Significant Permit Revision (A.A.C. R18-2-320).

The applicability and requirements for such action are defined in the above referenced 

regulations. 

XVII. FACILITY CHANGE WITHOUT A PERMIT REVISION [A.A.C. R18-2-306.A.4 and -317]

A. The Permittee may make changes at the permitted source without a permit revision if all 

of the following apply:

1. The changes are not modifications under any provision of Title I of the Act or 

under ARS § 49-401.01(19); 

2. The changes do not exceed the emissions allowable under the permit whether 

expressed therein as a rate of emissions or in terms of total emissions; 

3. The changes do not violate any applicable requirements or trigger any additional 

applicable requirements; 

4. The changes satisfy all requirements for a minor permit revision under A.A.C.

R18-2-319.A; and 

5. The changes do not contravene federally enforceable permit terms and conditions 

that are monitoring (including test methods), record keeping, reporting, or 

compliance certification requirements. 

B. The substitution of an item of process or pollution control equipment for an identical or 

substantially similar item of process or pollution control equipment shall qualify as a 

change that does not require a permit revision, if it meets all of the requirements of 

Conditions XVII.A and XVII.C of this Attachment.
 

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SRP – Coronado Generating Station 

C. For each change under Conditions XVII.A and XVII.B above, a written notice by 

certified mail or hand delivery shall be received by the Director and the Administrator a 

minimum of 7 working days in advance of the change. Notifications of changes 

associated with emergency conditions, such as malfunctions necessitating the 

replacement of equipment, may be provided less than 7 working days in advance of the 

change, but must be provided as far in advance of the change, as possible or, if advance 

notification is not practicable, as soon after the change as possible.

D. Each notification shall include:

1. When the proposed change will occur; 

2. A description of the change; 

3. Any change in emissions of regulated air pollutants; and 

4. Any permit term or condition that is no longer applicable as a result of the 

change. 

E. The permit shield described in A.A.C. R18-2-325 shall not apply to any change made 

under this Section, other than implementation of an alternate to Conditions XVII.A and 

XVII.B above.

F. Except as otherwise provided for in the permit, making a change from one alternative 

operating scenario to another as provided under A.A.C. R18-2-306.A.11 shall not require 

any prior notice under this Section.

G. Notwithstanding any other part of this Section, the Director may require a permit to be 

revised for any change that, when considered together with any other changes submitted 

by the same source under this Section over the term of the permit, do not satisfy 

Condition XVII.A above. 

XVIII. TESTING REQUIREMENTS [A.A.C. R18-2-312]

A. The Permittee shall conduct performance tests as specified in the permit and at such other 

times as may be required by the Director.

B. Operational Conditions During Testing 

 Tests shall be conducted during operation at the maximum possible capacity of each unit 

under representative operational conditions unless other conditions are required by the 

applicable test method or in this permit. With prior written approval from the Director, 

testing may be performed at a lower rate. Operations during periods of start-up, 

shutdown, and malfunction (as defined in A.A.C. R18-2-101 and 40 CFR 60.8) shall not 

constitute representative operational conditions unless otherwise specified in the 

applicable standard. 

C. Tests shall be conducted and data reduced in accordance with the test methods and 

procedures contained in the Arizona Testing Manual unless modified by the Director 

pursuant to A.A.C. R18-2-312.B.
 

TV Permit Renewal Number 52639 Page 14 of 79 December 06, 2011 

SRP – Coronado Generating Station 

D. Test Plan 

At least 14 calendar days prior to performing a test, the Permittee shall submit a test plan 

to the Director in accordance with A.A.C. R18-2-312.B and the Arizona Testing Manual. 

This test plan must include the following: 

1. Test duration; 

2. Test location(s); 

3. Test method(s); and 

4. Source operation and other parameters that may affect test results. 

E. Stack Sampling Facilities 

The Permittee shall provide, or cause to be provided, performance testing facilities as 

follows: 

1. Sampling ports adequate for test methods applicable to the facility; 

2. Safe sampling platform(s); 

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

4. Utilities for sampling and testing equipment. 

F. Interpretation of Final Result 

Each performance test shall consist of three separate runs using the applicable test 

method. Each run shall be conducted for the time and under the conditions specified in 

the applicable standard. For the purpose of determining compliance with an applicable 

standard, the arithmetic mean of the results of the three runs shall apply. In the event that 

a sample is accidentally lost or conditions occur in which one of the three runs is required 

to be discontinued because of forced shutdown, failure of an irreplaceable portion of the 

sample train, extreme meteorological conditions, or other circumstances beyond the 

Permittee’s control, compliance may, upon the Director’s approval, be determined using 

the arithmetic mean of the results of the other two runs. If the Director or the Director’s 

designee is present, tests may only be stopped with the Director’s or such designee’s 

approval. If the Director or the Director’s designee is not present, tests may only be 

stopped for good cause. Good cause includes: forced shutdown, failure of an 

irreplaceable portion of the sample train, extreme meteorological conditions, or other 

circumstances beyond the Permittee’s control. Termination of any test without good 

cause after the first run is commenced shall constitute a failure of the test. Supporting 

documentation, which demonstrates good cause, must be submitted.

G. Report of Final Test Results 

A written report of the results of all performance tests shall be submitted to the Director 

within 45 days after the test is performed. The report shall be submitted in accordance 
 

TV Permit Renewal Number 52639 Page 15 of 79 December 06, 2011 

SRP – Coronado Generating Station 

with the Arizona Testing Manual and A.A.C. R18-2-312.A. 

XIX. PROPERTY RIGHTS [A.A.C. R18-2-306.A.8.d]

This permit does not convey any property rights of any sort, or any exclusive privilege. 

XX. SEVERABILITY CLAUSE [A.A.C. R18-2-306.A.7]

The provisions of this permit are severable. In the event of a challenge to any portion of this 

permit, or if any portion of this permit is held invalid, the remaining permit conditions remain 

valid and in force. 

XXI. PERMIT SHIELD [A.A.C. R18-2-325]

Compliance with the conditions of this permit shall be deemed compliance with all applicable 

requirements identified in the portions of this permit subtitled “Permit Shield”. The permit shield 

shall not apply to minor revisions pursuant to Condition XVI.B of this Attachment and any 

facility changes without a permit revision pursuant to Section XVII of this Attachment. 

XXII. PROTECTION OF STRATOSPHERIC OZONE [40 CFR Part 82]

If this source becomes subject to the provisions of 40 CFR Part 82, then the Permittee shall 

comply with these provisions accordingly. 

XXIII. NEW SOURCE PERFORMANCE STANDARD & NATIONAL EMISSIONS 

STANDARDS FOR HAZARDOUS AIR POLLUTANTS [40 CFR Part 60, Part 63]

For all equipment subject to a New Source Performance Standard/National Emissions Standards 

for Hazardous Air Pollutants, the Permittee shall comply with all applicable requirements 

contained in Subpart A of Title 40, Chapter 60 and Chapter 63 of the Code of Federal 

Regulations. 

XXIV. ACID RAIN 

A. When provisions or requirements of the regulations incorporated pursuant to A.A.C. R18-

2-333.A (Acid Rain) conflict with any of the applicable requirements, the regulations 

incorporated by A.A.C. R18-2-333.A shall apply and take precedence. [A.A.C. R18-2-333]

B. No permit revision shall be required for increases in emissions that are authorized by 

allowances acquired pursuant to acid rain program, provided that such increases do not 

require a permit revision under any other applicable requirement. [A.A.C. R18-2-306.A.6.a]

C. No limit shall be place on the number of allowances held by the source. The source may 

not, however, use allowances as defense to noncompliance with any other applicable 

requirement. [A.A.C. R18-2-306.A.6.c]

D. Any such allowance shall be accounted for according to the procedures established in 

regulations promulgated under Title IV of the Act. [A.A.C. R18-2-306.A.6.c]

E. All of the following are prohibited: [A.A.C. R18-2-306.A.6.d]
 

TV Permit Renewal Number 52639 Page 16 of 79 December 06, 2011 

SRP – Coronado Generating Station 

1. Annual emissions of sulfur dioxide in excess of the number of allowances to emit 

sulfur dioxide held by the owners of the operations of the unit or the designed 

representative of the owners or the operators as of the applicable allowance 

transfer deadline; 

2. Exceedances of applicable emissions rates; 

3. The use of any allowance prior to the year for which it was allocated; and 

4. Contravention of any other provision of the permit. 
 

TV Permit Renewal Number 52639 Page 17 of 79 December 06, 2011 

SRP – Coronado Generating Station 

 

ATTACHMENT “B”: SPECIFIC CONDITIONS 

Air Quality Control Permit No. 52639 

for 

Salt River Project - Coronado Generating Station 

I. FACILITY WIDE LIMITATIONS 

A. The Permittee shall have on site or on call a person that is certified in EPA Reference 

Method 9. [A.A.C. R18-2-306.A.3.c] 

B. Permittee shall record any change in fuel type including: 

1. Type of fuel change; 

2. Date of the fuel change; and 

3. Time of the fuel change. 

 [A.A.C. R18-2-306.A.3.c] 

C. Permittee shall maintain a log of all adjustments, replacements, and maintenance 

performed on all air pollution control equipment. [Permit #30732, Attachment “B”, Condition I.D] 

D. At the time the compliance certifications required by Section VII of Attachment “A” are 

submitted, the Permittee shall submit reports of all monitoring activities required by 

Attachment “B” performed during the six month compliance term. [A.A.C. R18-2-306.A.5.a] 

II. UNIT 1 AND UNIT 2 BOILERS 

A. Applicability 

 This section applies to the Unit 1 and Unit 2 boilers as described in Attachment “C” of 

this permit. 

B. Definitions 

1. Unit Operating Day - A Unit Operating Day for Unit 1 means any calendar day 

on which Unit 1 fires fossil fuel. A Unit Operating Day for Unit 2 means any 

calendar day on which Unit 2 fires fossil fuel. [Significant Revision #46236 Condition II.A.2] 

2. Startup - Startup means the setting into operation of Coronado Generating 

Station (CGS) Unit 1 or Unit 2 for any purpose. [40 CFR 60.2]

 

3. Shutdown - Shutdown means the cessation of operation of Coronado Generating 

Station (CGS) Unit 1 or Unit 2 for any purpose. [40 CFR 60.2]

 

4. Malfunction - Malfunction means any sudden, infrequent, and not reasonably 

preventable failure of air pollution control equipment, process equipment, or a 

process to operate in a normal or usual manner. Failures that are caused in part by 

poor maintenance or careless operation are not malfunctions. [40 CFR 60.2] 
 

TV Permit Renewal Number 52639 Page 18 of 79 December 06, 2011 

SRP – Coronado Generating Station 

C. Operational Limitations 

 1. Fuel Limitations 

 Permittee shall burn only the following as fuel in the boiler units: 

a. Coal; 

b. Fuel Oil (Number 2 fuel oil or used oil and subject to Section IX of this 

Attachment); 

c. Co-firing of coal and Number 2 fuel oil; and 

d. Co-firing of coal and used oil fuel subject to Section IX of this 

Attachment. [A.A.C. R.18-2-306A.2] 

2. Permittee shall maintain a file of all measurements, including continuous 

monitoring system, monitoring device, and performance testing measurements; 

all continuous monitoring system performance evaluations; all continuous 

monitoring system or monitoring device calibration checks; adjustments and 

maintenance performed on these systems or devices; and all other information 

required by this section recorded in a permanent form suitable for inspection. 

The file shall be retained for at least five years following the date of such 

measurements, maintenance, reports and records. [40 CFR 60.7(f)] 

3. Excess Emissions and Monitoring System Performance (MSP) Reports 

The Permittee shall submit excess emissions and monitoring system performance 

(MSP) reports to the Department and EPA Region IX semi-annually for each sixmonth period in the calendar year. All semiannual reports shall be postmarked 

by the 30th day following the end of each six-month period. Periods of excess 

emissions as defined in the applicable sections and monitoring systems (MS) 

downtime shall be reported. Each excess emissions and MSP report shall include 

the following: 

a. The magnitude of excess emissions computed, any conversion factor(s) 

used; the date and time of commencement and completion of each time 

period of excess emissions, and the process operating time during the 

reporting period. 

b. Specific identification of each period of excess emissions that occurs 

during startups, shutdowns, and malfunctions of the affected facility. 

The nature and cause of any malfunction (if known), the corrective 

action taken or preventative measures adopted. 

c. The date and time identifying each period during which the continuous 

monitoring system was inoperative except for zero and span checks and 

the nature of the system repairs or adjustments. 

d. When no excess emissions have occurred or the continuous monitoring 

systems have not been inoperative, repaired, or adjusted, such 
 

TV Permit Renewal Number 52639 Page 19 of 79 December 06, 2011 

SRP – Coronado Generating Station 

information shall be stated in the report. [40 CFR 60.45(g), 60.7(c)] 

4. In addition to II.C.3.above, Permittee shall report emissions exceeding an 

emission limitation or standard as deviations in accordance with Section XII.B of 

Attachment “A” of this permit. 

 [A.A.C. R18-2-306.A.5.b] 

5. Emission Rates for Performance Testing 

 

When conducting the required performance tests, the Permittee shall determine 

compliance with the PM, SO2, & NOx emissions standards as follows: 

 a. Emission Rates Using O2 as Diluent Gas 

 The emission rate (E) of PM, SO2, or NOx shall be computed for each 

run using the following equation: 

E = C Fd (20.9)____ 

 (20.9 - % O2) 

E = Emission rate of pollutant, ng/J (1b/million Btu). 

C = Concentration of pollutant, ng/dscm (1b/dscf). 

%O2 = Oxygen concentration, percent dry basis. 

Fd = Factor as determined from Method 19. 

[40 CFR 60.46(b)(1)] 

 b. Emission Rates Using CO2 as Diluent Gas 

 As an alternate to the reference method, the emission rate (E) of PM, 

SO2, & NOx, may be determined by using the Fc factor in the following 

equation: 

E = C Fc __ 100___ 

 %CO2

E = emission rate of pollutant, ng/J (1b/million Btu). 

C = concentration of pollutant, ng/dscm (1b/dscf). 

%CO2 = carbon dioxide concentration, percent dry basis. 

Fc = factor as determined from Method 19. 

[40 CFR 60.46(d)(1)] 

 6. Permit Shield 

 Compliance with this Section shall be deemed compliance with Permit #30732 

Attachment “B” permit condition II.B.1 & condition I.D. 

 [A.A.C. R18-2-325] 

D. Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. The Permittee shall not cause to be discharged into the atmosphere from 

the stack of each unit any gases which contain particulate matter in 
 

TV Permit Renewal Number 52639 Page 20 of 79 December 06, 2011 

SRP – Coronado Generating Station 

excess of 43 nanograms per joule heat input (0.10 lb per million Btu) 

derived from fossil fuel. 

 [40 CFR 60.42(a)(1)]

b. The Permittee, upon installation and operation of the new FGD system 

associated with Unit 1 as per Condition II.G.2.b, and continuing 

thereafter, shall not emit filterable particulate matter (PM) in excess of 

0.030 lbs/MMBtu, as determined by performance tests.

[Significant Revision #46236 Condition II.C.1.b.(2); 

& A.A.C. R18-2-406.A.4] 

 [Material Permit Conditions are defined by underline and italics] 

c. The Permittee, upon installation and operation of the new FGD system 

associated with Unit 2 as per Condition II.G.2.b, and continuing 

thereafter, shall not emit filterable PM and particulate matter below 10 

micron size (PM10) in excess of 0.030 lbs/MMBtu, as determined by 

performance tests.

[Significant Revision #46236 Condition II.C.1.b.(3); 

& A.A.C. R18-2-406.A.4] 

 [Material Permit Conditions are defined by underline and italics] 

d. The opacity of emissions from the stack of each unit shall not be greater 

than 20 percent except for one six-minute period per hour of not more 

than 27 percent opacity. Periods of startup, shutdown, or malfunction, as 

defined in condition II.B.2, B.3, & B.4, are excluded from the opacity 

standard. Opacity readings of portions of plumes which contain 

condensed, uncombined water vapor shall not be used for the purposes of 

determining compliance with opacity standards. [40 CFR 60.42(a)(2), 60.11(c), 60.11(e)(1); & A.A.C. R18-2-331.A.3.f] 

 [Material Permit Conditions are defined by underline and italics] 

e. Opacity excess emissions for Units 1 and 2 are defined as any six-minute 

period during which the average opacity of emissions exceeds 20 percent 

opacity, except that one six-minute average per hour of up to 27 percent 

opacity need not be reported. 

 [40 CFR 60.45(g)(1)] 

2. Air Pollution Control Requirements 

a. At all times, including periods of startup, shutdown, and malfunction, 

Permittee shall, to the extent practicable, maintain and operate each Hot 

Side Electrostatic Precipitator (HS-ESP) in a manner consistent with 

good air pollution control practices for minimizing particulate matter 

emissions.

 [40 CFR 60.11(d) and A.A.C. R18-2-331.A.3.e] 

[Material Permit Conditions are defined by underline and italics] 

b. The Permittee shall operate each existing HS-ESP on Unit 1 and Unit 2 

at all times when the Unit is in operation to maximize PM reductions to 

the extent practicable, provided that such operation of the HS-ESP is 

consistent with technological limitations, manufacturer’s specifications, 

and good engineering and maintenance practices for the HS-ESP. [Significant Revision #46236 Condition II.C.2.b and A.A.C. R18-2-331.A.3.e] 

[Material Permit Conditions are defined by underline and italics] 
 

TV Permit Renewal Number 52639 Page 21 of 79 December 06, 2011 

SRP – Coronado Generating Station 

c. Except as required during correlation testing under 40 CFR Part 60, 

Appendix B, PS-11, and Quality Assurance Requirements under 

Appendix F, Procedure 2, the Permittee shall at a minimum perform the 

following on the HS-ESP to the extent reasonably practicable: 

i. Fully energize each section of the HS-ESP for each unit and 

repair any failed HS-ESP section at the next planned or 

unplanned unit outage of sufficient length; 

ii. Operate automatic control systems on each HS-ESP to maximize 

particulate matter collection efficiency; 

iii. Maintain power levels delivered to the HS-ESPs, consistent with 

manufacturer’s specifications, the operational design of the unit, 

and good engineering practices; 

iv. Inspect for and repair during the next planned or unplanned unit 

outage of sufficient length any openings in HS-ESP casings, 

ductwork, and expansion joints to minimize air leakage; and 

v. Optimize the plate-cleaning and discharge-electrode-cleaning 

systems for the HS-ESPs at each unit by varying the cycle time, 

cycle frequency, rapper-vibrator intensity, and number of strikes 

per cleaning event. 

 [Significant Revision #46236 Condition II.C.2.c] 

3. Monitoring & Recordkeeping Requirements 

a. Within 180 calendar days following commencement of operation of each 

flue gas desulfurization (FGD) system, the Permittee shall install,

maintain, correlate, and operate a continuous emission monitoring 

systems for measuring PM emissions on the unit being controlled by the 

FGD system. [Significant Revision #46236, Condition II.B.3.b 

 and A.A.C. R18-2-331.A.3.c] 

 [Material Permit Conditions are defined by underline and italics] 

b. No later than 120 days prior to the deadline for commencing operation 

of the PM CEMS, the Permittee shall submit to ADEQ and EPA a 

proposed Quality Assurance/Quality Control (QA/QC) protocol that 

shall be followed for the PM CEMS. 

 [Significant Revision #46236, Condition II.C.3.g.(1)(b); 

 A.A.C. R18-2-331.A.3.c] 

 [Material Permit Conditions are defined by underline and italics] 

c. In developing the plan for installation and correlation of the PM CEMS 

and QA/QC protocol, the Permittee shall use the criteria set forth in 40 

CFR Part 60, Appendix B, PS-11, and Appendix F, Procedure 2. [Significant Revision #46236, Condition II.C.3.g.(1)(c); 

 A.A.C. R18-2-331.A.3.c] 

 [Material Permit Conditions are defined by underline and italics] 
 

TV Permit Renewal Number 52639 Page 22 of 79 December 06, 2011 

SRP – Coronado Generating Station 

d. Following ADEQ’s and EPA’s approval of the QA/QC plan described in 

Condition II.D.3.b, the Permittee shall thereafter operate the PM CEMS 

in accordance with the approved QA/QC protocol.

 [Significant Revision #46236, Condition II.C.3.g(1)(d); 

 A.A.C. R18-2-331.A.3.c] 

 [Material Permit Conditions are defined by underline and italics] 

e. Within 180 calendar days following commencement of operation of each 

FGD, the Permittee shall conduct performance specification tests and 

demonstrate compliance with the PM CEMS installation and 

certification plan approved by ADEQ and EPA.

[Significant Revision #46236, Condition II.C.3.g(1)(e); 

A.A.C. R18-2-331.A.3.c] 

f. The PM CEMS shall comprise a continuous particle mass monitor 

measuring particulate matter concentration, directly or indirectly, on an 

hourly average basis and a diluents monitor used to convert the 

concentration to units expressed in pounds per MMBtu (lbs/MMBtu). 

The PM CEMS installed at Unit 1 and Unit 2 must be appropriate for the 

anticipated stack conditions and capable of measuring PM concentrations 

on an hourly average basis. 

 [Significant Revision #46236, Condition II.C.3.g(1)(f)] 

g. Except for periods of monitor malfunction, maintenance, or repair, SRP 

shall continuously operate the PM CEMS at all times when the Unit it 

serves is operating. 

 [Significant Revision #46236, Condition II.C.3.g(1)(g)] 

h. PM CEMS Demonstration Period

i. Upon completion of the PM CEMS performance specification 

tests, the Permittee shall operate the PM CEMS for at least two 

years. If, after 2 years of operation, the Permittee believes that it 

is infeasible to continue operation of the PM CEMS, the 

Permittee may submit a demonstration of infeasibility to ADEQ 

and EPA within 90 days after the end of the demonstration 

period: 

(1) As part of that demonstration, the Permittee shall submit 

an alternative PM monitoring plan for review and 

approval by ADEQ and EPA. If ADEQ and EPA 

disapprove the alternative monitoring plan, or if ADEQ 

and EPA rejects the Permittee’s assertion that it is 

infeasible to continue operating the PM CEMS, such 

disagreement is subject to dispute resolution as specified 

in Section XV of the EPA Consent Decree (Civil Action 

No. 2:08-cv-1479-JAT).

 [Significant Revision #46236, Condition II.C.3.g(2)(a)(i)] 

(2) The Permittee shall submit a permit revision application 

to ADEQ to incorporate the approved alternative PM 

monitoring plan within 30 days of obtaining approval. 

 [A.A.C. R18-2-306.A.2] 
 

TV Permit Renewal Number 52639 Page 23 of 79 December 06, 2011 

SRP – Coronado Generating Station 

ii. Operation of a PM CEMS shall be considered “infeasible” if, by 

way of example, the PM CEMS: 

(1) Cannot be kept in proper condition for sufficient periods 

of time to produce reliable, adequate, or useful data; or 

(2) The Permittee demonstrates that recurring, chronic, or 

unusual equipment adjustment or servicing needs in 

relation to other types of continuous emission monitors 

cannot be resolved through reasonable expenditures of 

resources; or 

(3) Chronic and difficult operational issues at Unit 1 or Unit 

2 cannot be resolved through reasonable expenditure of 

resources; or 

(4) The data produced by the CEMS cannot be used to 

assess PM emissions from Unit 1 or Unit 2 or 

performance of that Unit’s control devices.

[Significant Revision #46236, Condition II.C.3.g(2)(b)] 

iii If ADEQ and EPA determine that the Permittee has 

demonstrated infeasibility pursuant to Condition II.D.3.h.ii, the 

Permittee shall be entitled to discontinue operation of and 

remove the PM CEMS. [Significant Revision #46236, Condition II.C.3.g(2)(c)] 

iv. If, after 2 years of operation, the Permittee determines that it is 

feasible to continue operation of the PM CEMS, the Permittee 

shall continue to comply with all requirements specified in this 

permit for the operation and maintenance of the CEMS. 

 [A.A.C. R18-2-306.A.3.c] 

i. The Permittee shall maintain, in an electronic database, the hourly 

average emission values from all PM CEMS data in lb/MMBtu. 

 [Significant Revision #46236, Condition II.C.3.g(3)]

j. The Permittee shall calibrate, maintain, and operate continuous opacity 

monitoring system (COMS) for measuring the opacity of emissions.

 [40 CFR 60.45(a), A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

k. COMS Requirements 

The COMS shall meet the following requirements: 

i 40 CFR 60, Appendix B, Performance Specification 1, 

“Specification and Test Procedures for Opacity Continuous 

Emission Monitoring Systems in Stationary Sources” 

(1) Apparatus 
 

TV Permit Renewal Number 52639 Page 24 of 79 December 06, 2011 

SRP – Coronado Generating Station 

(2) Installation Specifications 

(3) Design and Performance Specifications 

(4) Design Specifications Verification Procedure 

(5) Performance Specifications Verification Procedure 

(6) Equations 

[40 CFR 60.13(a)] 

ii. The following quality assurance requirements: 

(1) Calibration Checks 

 Permittee shall check the zero and span calibration drifts 

at least once daily in accordance with a written 

procedure. [40 CFR 60.13(d)(1) and 40 CFR 60, Appendix B, PS1, 5.2] 

(2) Zero and Span Drift Adjustments 

(a) The zero and span shall, as a minimum, be 

adjusted whenever the 24-hr zero drift or 24-hr 

span drift exceeds 4% opacity. 

[40 CFR 60.13(d)(1)] 

(b) The system shall allow for the amount of excess 

zero and span drift measured at the 24-hour 

interval checks to be recorded and quantified. [40 CFR 60.13(d)(1)] 

(c) The optical surfaces exposed to the effluent 

gases shall be cleaned prior to performing the 

zero and span drift adjustments, except for 

systems using automatic zero adjustments. [40 CFR 60.13(d)(1)] 

(d) For systems using automatic zero adjustments, 

the optical surfaces shall be cleaned when the 

cumulative automatic zero compensation 

exceeds 4% opacity. [40 CFR 60.13(d)(1)] 

(3) System Checks 

 A method for producing a simulated zero opacity 

condition and an upscale (span) opacity condition using 

a certified neutral density filter or other related technique 

to produce a known obscuration of the light beam to 

provide a system check of the analyzer internal optical 

surfaces and all electronic circuitry including the lamp 

and photodetector assembly shall be used by the 

Permittee. [40 CFR 60.13(d)(2)]
 

TV Permit Renewal Number 52639 Page 25 of 79 December 06, 2011 

SRP – Coronado Generating Station 

(4) Minimum Frequency of Operation 

 Except during periods of system breakdowns, repairs, 

calibration checks, and zero and span adjustments, the 

Continuous Opacity Monitoring System (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. [40 CFR 60.13(e)(1)] 

(5) Data Reduction and Missing Data 

 

(a) Permittee shall 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. 

(b) Data recorded during periods of system 

breakdowns, repairs, calibration checks, and 

zero and span adjustments shall not be included 

in the data averages computed under the 

previous paragraph. An arithmetic or integrated 

average of all data may be used. 

 [40 CFR 60.13(h)] 

l. Compliance Assurance Monitoring (CAM) & Periodic Monitoring 

for Particulate Matter 

i. Until the new Flue Gas Desulfurization (FGD) commences 

operation for each unit, the Permittee shall comply with the 

following: 

(1) The Permittee shall measure the opacity of exhaust gases 

as an indicator of particulate matter emissions. The 

COMS shall be used to monitor the opacity. The COMS 

shall be installed and operated in accordance with the 

requirements specified in Condition II.D.3.k of this 

Attachment. [40 CFR 64.6(c)(1)(i), 64.6(c)(1)(ii)] 

(2) The Permittee shall measure the secondary current and 

voltage for each section of each ESP. [40 CFR 64.6(c)(1)(i)]

(3) Using COMS data, the Permittee shall calculate rolling 

1-hour average opacities excluding periods of boiler 

startup, shutdown, and malfunction. If at any point, 

excluding periods of startup, shutdown, and malfunction, 

the opacity is equal to or exceeds 18%, then the 

Permittee shall: 
 

TV Permit Renewal Number 52639 Page 26 of 79 December 06, 2011 

SRP – Coronado Generating Station 

(a) Record the secondary current and secondary 

voltage for each section of each ESP at that 

specific moment and determine if the current 

and/or voltage is with in the range established by 

the Permittee previously, and 

(b) Record the operational status of the specific 

boiler (i.e. load change increase or decrease). 

(4) Rolling 1-hour average opacities of 18% or greater and 

electrical parameters (secondary current and secondary 

voltage) outside the range established previously shall be 

considered an excursion. 

[40 CFR 64.6(c)(2)] 

(5) The Permittee shall record and monitor on a continuous 

basis (at least once every 15 minutes) the secondary 

current and voltage for each section of each ESP. If the 

secondary voltage and/or the current is outside the range 

established previously, then the Permittee shall record 

the occurrence and corrective action taken to return the 

electrical parameters back within the established range. 

This event does not constitute a deviation or an 

excursion. 

[A.A.C. R18-2-306.A.3.] 

ii. Beginning on the date on which the new FGD commences 

operation and ending on the date on which the Department 

approves the proposed secondary indicator(s) based on the PM 

CEMS correlation test for each unit, the Permittee shall comply 

with the following: 

(1) The Permittee shall measure the secondary current and 

voltage of the ESP. [40 CFR 64.6(c)(1)(i), 64.6(c)(1)(ii)] 

(2) The Permittee shall monitor the operational status of the 

wet FGD System limestone slurry recycle pumps. [40 CFR 64.6(c)(1)(i)] 

(3) The Permittee shall record and monitor on a continuous 

basis (at least once every 15 minutes) the secondary 

voltage and current for each section of each ESP. If the 

secondary voltage and/or the current are outside the 

range established previously, then the Permittee shall 

record the occurrence and corrective action taken to 

return the electrical parameters back within the 

established range. This event does not constitute a 

deviation or an excursion. [A.A.C. R18-2-306.A.3.] 

(4) When the ESP secondary current and voltage are out of 
 

TV Permit Renewal Number 52639 Page 27 of 79 December 06, 2011 

SRP – Coronado Generating Station 

range and all of the limestone slurry recycle pumps 

associated with the wet FGD system are inoperative, the 

event will be considered as an excursion. 

iii. Beginning on the date the Department approves the proposed 

secondary indicator(s) based on the PM correlation tests, the 

Permittee shall comply with the following indicators: 

(1) Emission measurements from the PM CEMS shall be a 

primary indicator of PM emissions. 

(2) The Permittee shall define secondary indicator(s) 

based on data collected during the PM CEMS 

Correlation tests. The Permittee shall establish an 

acceptable range for the secondary indicator(s) during 

the correlation tests. The proposed indicator(s) and 

range(s) shall be submitted to the Department within 

60 days of the date on which the Correlation test is 

completed. Beginning on the date the Department 

approves the proposed secondary indicator(s), the 

approved indicator(s) shall be monitored and recorded 

as secondary indicators of PM emissions. 

(3) If PM CEMS emission measurements are greater than 

0.028 lb/MMBtu on a 24-hour rolling average, and the 

secondary indicator(s) are outside the allowable range 

established in accordance with Condition 

II.D.3.l.iii(2), this shall be considered an excursion and 

trigger an inspection, corrective action, and 

recordkeeping requirement in accordance with 

Condition II.D.3.l.vi & II.D.3.l.viii of this Attachment. [40 CFR 64.6(c)(1)(i)] 

iv. The Permittee shall maintain the monitoring, including but not 

limited to maintaining necessary parts for routine repair of the 

monitoring equipment. [40 CFR 64.6(c)(3), and - 64.7(b)] 

v. Except for, as applicable, monitoring malfunctions, associated 

repairs, and required quality assurance or control activities 

(including, as applicable, calibration checks and required zero 

and span adjustments), Permittee shall conduct all monitoring in 

continuous operation (or shall collect data at all required 

intervals) at all times that the boilers are operating. Data 

recorded during monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall not be used 

for purposes of this part, including data averages and 

calculations, or fulfilling a minimum data availability 

requirement, if applicable. Permittee shall use all the data 

collected during all other periods in assessing the operation of 

the control device and associated control system. A monitoring 
 

TV Permit Renewal Number 52639 Page 28 of 79 December 06, 2011 

SRP – Coronado Generating Station 

malfunction is any sudden, infrequent, not reasonably 

preventable failure of the monitoring to provide valid data. 

Monitoring failures that are caused in part by poor maintenance 

or careless operation are not malfunctions. [40 CFR 64.6(c)(3), 64.9(c)] 

vi. Response to excursions 

(1) Upon detecting an excursion or exceedance, Permittee 

shall restore operation of the boiler (including the 

control device and associated capture system) to their 

normal or usual manner of operation as expeditiously as 

practicable in accordance with good air pollution control 

practices for minimizing emissions. The response shall 

include minimizing the period of any startup, shutdown, 

or malfunction, and taking any necessary corrective 

actions to restore normal operation and prevent the likely 

recurrence of the cause of an excursion or exceedance 

(other than those caused by excused startup or shutdown 

conditions). Such actions may include initial inspection 

and evaluation, recording that operations returned to 

normal without operator action (such as through 

response by a computerized distribution control system), 

or any necessary follow-up actions to return operations 

to within the indicator range, designated condition, or 

below applicable emission limitation or standard, as 

applicable. 

(2) Determination of whether Permittee has used acceptable 

procedures in response to an excursion or exceedance 

will be based in information available, which may 

include but is not limited to, monitoring results, review 

of operation, and maintenance procedures and records, 

and inspection of the control device, associated capture 

system, and process. [40 CFR 64.6(c)(3), 64.7(d)] 

vii. After approval of the monitoring under this section, if the 

Permittee identifies a failure to achieve compliance with an 

emission limitation or standard for which the approved 

monitoring did not provide an indication of an excursion or 

exceedance while providing valid data, or the results of 

compliance or performance testing document a need to modify 

the existing indicator ranges or designated conditions, Permittee 

shall promptly notify the Department, and if necessary, submit a 

proposed modification to this permit to address the necessary 

monitoring changes. Such a modification may include, but is not 

limited to, re-establishing indicator ranges or designated 

conditions, modifying the frequency of conduction monitoring 

and collecting data, or the monitoring of additional parameters. [40 CFR 64.6(c) (3), 64.9(e)] 
 

TV Permit Renewal Number 52639 Page 29 of 79 December 06, 2011 

SRP – Coronado Generating Station 

viii. Excursions shall be reported as required by Condition VII.A.4 of 

Attachment “A” of this permit. The report shall include, at a 

minimum, the following: 

 

(1) Summary information on the number, duration and cause 

(including unknown cause, if applicable) of excursion or 

exceedances, as applicable, and the corrective actions 

taken; and 

(2) Summary information on the number, duration and cause 

(including unknown cause, if applicable) for monitoring 

downtime incidents (other than downtime associated 

with zero and span or other daily calibration checks, if 

applicable). [A.A.C. R18-2-309(2)(c)(iii), 64.9(a)(2)]

m. The Permittee shall maintain a record of the applicable monitoring 

parameters defined in Condition II.D.3. Records of all excursions and 

corrective actions taken including the date and time of the event shall be 

maintained. [A.A.C. R18-2-306.A.3.b] 

4. Reporting Requirements 

a. The Permittee shall report the data recorded by the PM CEMS, expressed 

in lb/MMBtu on a rolling average 3-hour, 6-hour, 24-hour, 30-day, and 

365-day basis in electronic format to the ADEQ and EPA in accordance 

with Condition VII of Attachment “A”. 

 [Significant Revision #46236, Condition II.C.3.g(4)(a)] 

b. The Permittee shall identify in the report any PM concentrations 

measured by the PM CEMS that are greater than 125% of the highest PM 

concentration level used in the most recent correlation testing performed 

pursuant to PS-11. [Significant Revision #46236, Condition II.C.3.g(4)(b)] 

5. Performance Testing 

a. The Permittee shall perform annual performance tests on each boiler Unit 

to determine compliance with the particulate matter concentration using 

EPA Reference Method 5, 5B, or 17. [40 CFR 60.46(b)(2)] 

b. The Permittee may use Method 17 if the stack gas temperature at the 

sampling location does not exceed an average temperature of 160 °C 

(320 °F). The procedures of sections 8.1 and 11.1 of Method 5B may be 

used with Method 17 when used after wet FGD systems and the effluent 

gas is not saturated or laden with water droplets. [40 CFR 60.46(d)(2)] 

c. FGD Systems 

 Within 180 days of installation and commencing operation of the FGD 

system for each unit, the Permittee shall conduct an initial performance 

test to determine compliance with the PM emissions rate established in 
 

TV Permit Renewal Number 52639 Page 30 of 79 December 06, 2011 

SRP – Coronado Generating Station 

Conditions II.D.1.b and II.D.1.c using the below mentioned reference 

methods and procedures (filterable portion only). Thereafter, the tests 

shall be conducted annually. 

i. 40 CFR Part 60, Appendix A-3, Method 5, Method 5B, or 

Method 5I. 

ii. 40 CFR Part 60, Appendix A-6, Method 17; or 

iii. Alternative stack tests or methods requested by the Permittee and 

approved by ADEQ and EPA. 

 [Significant Revision #46236, Condition II.C.4.c] 

d. Test Procedures 

i. The Permittee shall conduct each test consisting of three separate 

runs performed under representative operating conditions not 

including periods of startup, shutdown, or malfunction. 

ii. The sampling time for each run shall be at least 120 minutes and 

the volume of each run shall be 1.70 dry standard cubic meters 

(60 standard dry cubic feet). 

iii. The Permittee shall calculate the PM emission rate from the 

stack test results in accordance with 40 CFR 60.8 (f). 

e. The Permittee shall submit the results of each PM stack test to EPA and 

ADEQ within forty-five (45) days of completion of each test. 

[Significant Revision #46236, Condition II.C.4.d] 

7. Permit Shield [A.A.C. R18-2-325]

Compliance with this Section shall be deemed compliance with 40 CFR 

60.42(a)(1), 40 CFR 60.42(a)(2), 40 CFR, 60.45(a), 40 CFR 60.45(g)(1), 40 CFR 

60.46(b)(2), 40 CFR 60.46(b)(3), 40 CFR 60.46(d)(2), 40 CFR 64.3, 40 CFR 64.4, 

40 CFR 64.5, 40 CFR 64.6, 40 CFR 64.7, 40 CFR 64.9, and EPA Consent Decree 

VI.A.63, VI.B.64, VI.B.65, VI.C.67, VI.C.68, VI.C.69, VI.C.70, VI.C.71, VI.C.72, 

VI.C.73, and VI.D.74. Compliance with this Section shall be deemed compliance 

with 40 CFR 60.45(a), 40 CFR 60.45(g), 40 CFR 60.46(b)(1), 40 CFR 60.46(d)(1), 

and Permit #30732, Attachment B, Condition II.C.1. 

E. Nitrogen Oxides (NOx) 

1. Emission Limitations/Standards 

a. Coal 

i. Permittee shall not cause to be discharged into the atmosphere 

from the stack of each boiler any gases which contain nitrogen 

oxides, expressed as NO2 in excess of 300 nanograms per joule 

heat input (0.70 lb per million Btu) derived from coal. 

 [40 CFR 60.44(a)(3)] 
 

TV Permit Renewal Number 52639 Page 31 of 79 December 06, 2011 

SRP – Coronado Generating Station 

ii. Beginning on the earlier of ninety (90) Unit Operating Days or 

180 calendar days after the LNB are installed and continuing 

thereafter, the Permittee shall not allow the 30-day rolling 

average NOx emission rate from the stack of each boiler to 

exceed 0.320 lb/MMBtu. 

 [Significant Revision #46236, Condition II.D.1.e] 

iii. Beginning on June 1, 2014, and continuing thereafter, the 

Permittee shall not allow the 30-day rolling average NOx

emission rate from Unit 2 to exceed 0.080 lb/MMBtu. 

 [Significant Revision #46236, Condition II.C.1.f] 

iv. Beginning on June 1, 2014, and continuing thereafter, the 

Permittee shall not allow the 365-day plant-wide rolling NOx

emission rate for Unit 1 and Unit 2 to exceed 7,300 tons per 

year. [Significant Revision #46236, Condition II.C.1.g] 

b. Fuel Oil and Used oil fuel

Permittee shall not cause to be discharged into the atmosphere from the 

stack of each unit any gases which contain nitrogen oxides, expressed as 

NO2 in excess of 129 nanograms per joule heat input (0.30 lb per million 

Btu) derived from used oil fuel. 

 [40 CFR 60.44(a)(2)] 

c. Combination Fuels 

i. When different fossil fuels are burned simultaneously in any 

combination, the applicable standard (in ng/J) is determined by 

proration using the following formula: 

 PSNOX = w(260) + x(86) + y(130) + z(300)

 w + x + y + z 

 Where: 

PSNOX = is the prorated standard for nitrogen oxides when 

burning different fuels simultaneously, in nanograms per 

joule heat input derived from all fossil fuels fired or from 

all fossil fuels and wood residue fired; 

w = is the percentage of total heat input derived from 

lignite; 

x = is the percentage of total heat input derived from 

gaseous fossil fuel; 

y = is the percentage of total heat input derived from liquid 

fossil fuel; and 

z = is the percentage of total heat input derived from solid 

fossil fuel (except lignite) 

[40 CFR 60.44(b)] 

ii. Compliance shall be based on the total heat input from all fossil 

fuels burned, including gaseous fuels. 

 [40 CFR 60.43(c)] 
 

TV Permit Renewal Number 52639 Page 32 of 79 December 06, 2011 

SRP – Coronado Generating Station 

d. Excess Emissions 

i. Excess emissions for Units 1 and 2 are defined as any three-hour 

period during which the average emissions (arithmetic average 

of three contiguous one-hour periods) exceed the applicable 

standards in Section II.E.1 of this Attachment. [40 CFR 60.45(g)(3)] 

ii. Beginning on the earlier of ninety Unit Operating Days or 180 

calendar days after the LNB are installed, excess emissions for 

Units 1 and 2 are defined as any 30-day rolling average that 

exceeds the applicable standards in Section II.E.1.a.ii. 

iii. Beginning June 1, 2014, excess emissions for Units 1 and 2 are 

defined as any 30-day rolling average that exceeds the applicable 

standards in Section II.E.1.a.iii, or a 365-rolling total that 

exceeds the applicable limit specified in Section II.E.1.a.iv. 

 

2. Air Pollution Control Requirements 

a. The Permittee shall operate the low-NOx burners(LNB) in accordance 

with manufacturer’s specifications and good engineering practices to 

minimize emissions. [Significant Revision #46236, Condition II.D.2.c; A.A.C. R18-2-331.A.3.d & e]

[Material Permit Conditions are defined by underline and italics] 

b. The Permittee shall install a Selective Catalytic Reduction (SCR) system 

on Unit 2 no later than June 1, 2014. At all times during the operation of 

Unit 2, the Permittee shall operate the SCR in accordance with 

manufacturer’s specifications and good engineering practices to 

minimize emissions. 

 [Significant Revision #46236, Condition II.D.2.d; A.A.C. R18-2-331.A.3.d & e] 

 [Material Permit Conditions are defined by underline and italics] 

c. The Permittee shall continuously operate each NOx control at all times 

the unit it serves is in operation consistent with technological limitations, 

manufacturer’s specifications, and good engineering and maintenance 

practices for minimizing emissions to the extent practicable [Significant Revision #46236, Condition II.D.2.e; A.A.C. R18-2-331.A.3.e]

 [Material Permit Conditions are defined by underline and italics] 

3. Monitoring & Recordkeeping Requirements 

 a. Continuous Emissions Monitoring System (CEMS) 

The Permittee shall calibrate, maintain, and operate a continuous

emissions monitoring system for measuring nitrogen oxides emissions. 

 [40 CFR 60.45(a); A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

b. The CEMS for NOx, shall meet the following requirements: 
 

TV Permit Renewal Number 52639 Page 33 of 79 December 06, 2011 

SRP – Coronado Generating Station 

i. 40 CFR Part 75, Appendix A, Specification and Test Procedures 

(1) Installation and measurement location 

(2) Equipment specifications 

(3) Performance specifications 

(4) Data acquisition and handling systems 

(5) Calibration gas 

(6) Certifications tests and procedures 

(7) Calculations 

ii. 40 CFR Part 75, Appendix B, Quality Assurance and Quality 

Control Procedure 

(1) Quality control program 

(2) Frequency of testing 

iii. Data Reduction 

Permittee shall comply with the data reduction requirements of 

40 CFR Part 75.10(d)(1). 

c. Monitoring of NOx Emission Rate 

The Permittee shall determine the 30-day rolling average NOx emission 

rate for Unit 1 and Unit 2 using CEMS in accordance with the 

procedures of 40 CFR Part 75, with the following exceptions: 

 (1) NOx emissions data need not be bias adjusted 

 (2) For CEMS with a span less than 100 parts per million (ppm), the 

calibration drift and out-of-control criteria in Procedure 1, 

Section 4.3 of 40 CFR Part 60 Appendix F shall apply in lieu of 

the low emitter specifications in 40 CFR Part 75, Appendix B, 

Section 2.1. 

 (3) For CEMS with a span less than or equal to 30 ppm, the 

exemption from the 40 CFR Part 75 linearity check will not 

apply and either the 40 CFR Part 75 linearity check or the 

cylinder gas audit described in Procedure 1, Section 5.1.2 of 40 

CFR Part 60, Appendix F must be performed on a quarterly 

basis. 

 (4) After installing and commencing operation on the SCR system, 

for Unit 2, an annual relative accuracy test (RATA) audit shall 

meet, at a minimum, a relative accuracy of less than 20 percent 

or an accuracy of less than 0.016 lb/MMBtu (expressed as the 

difference between the monitor mean and the reference value 

mean). [Significant Revision #46236, Condition II.D.3.c] 
 

TV Permit Renewal Number 52639 Page 34 of 79 December 06, 2011 

SRP – Coronado Generating Station 

d. Determining the 30-Day Rolling Average NOx Emission Rate 

 

(1) The Permittee shall calculate the 30-day rolling average NOx

emission rate in accordance with the following procedure: 

 (a) Sum the total pounds of NOx emitted from each Unit 

during the current Unit Operating Day and the previous 

29 Unit Operating Days. 

 (b) Sum the total heat input to the unit in million British 

thermal units (MMBtu) during the current Unit 

Operating Day and the previous 29 Unit Operating Days. 

 (c) Divide the total number of pounds of NOx emitted 

during the 30 Unit Operating Days by the total heat input 

during the 30 Unit Operating Days. [Significant Revision #46236, Condition II.D.3.d] 

(2) A new 30-day rolling average NOx emission rate shall be 

calculated for each new Unit Operating Day. Each 30-day 

rolling average NOx emission rate will include all emissions that 

occur during all periods within any Unit Operating Day, 

including emissions from startup, shutdown, and malfunction. 

e. Determining the 365-Day Plant-Wide Rolling NOx Emission Rate 

(1) The 365-day plant-wide rolling NOx emission rate shall be 

determined using CEMS, in accordance with the procedures 

specified in 40 CFR Part 75. 

[Significant Revision #46236, Condition II.D.3.e(1)]

(2) The 365-day plant-wide rolling NOx emission rate means the 

total number of tons of NOx emitted from Units 1 and 2 during a 

365-day period beginning on June 1, 2014, and continuing each 

day thereafter, and shall include all emissions during startup, 

shutdown, and malfunction, unless the malfunction is determined 

to be a Force Majeure event as defined in Section XIV of the 

EPA Consent Decree (Civil Action No. 2:08-cv-1479-JAT). [Significant Revision #46236, Condition II.D.3.e(2)] 

4. Reporting Requirements [A.A.C. R18-2-306.A.5.a]

The Permittee shall maintain records of the 30-day rolling average NOx emission 

rate and the 365-day plant-wide rolling total. Summary records of these shall be 

submitted along with the Compliance certifications required in Condition VII of the 

Attachment “A”. Detailed reports shall be made available, upon request, to 

Department inspectors in a reasonable time. 
 

TV Permit Renewal Number 52639 Page 35 of 79 December 06, 2011 

SRP – Coronado Generating Station 

5. Permit Shield 

Compliance with this Section shall be deemed compliance with 40 CFR 60.43(c), 

40 CFR 60.44(a)(2), 40 CFR 60.44(a)(3), 40 CFR 60.44(b), 40 CFR 60.45(a), 40 

CFR 60.45(g)(3), 40 CFR 75 Appendix “A” and “B”, 40 CFR 75.10(d)(1), and 

Significant Revision #46236 Condition II.C.1.e through g., II.C.2.a through e., 

II.C.3.c through f. 

[A.A.C. R18-2-325] 

F. Carbon Dioxide (CO2) 

1. Monitoring, Recordkeeping & Reporting Requirements 

a. Continuous Emissions Monitoring System (CEMS) 

The Permittee shall calibrate, maintain, and operate a continuous

emissions monitoring system for measuring carbon dioxide (CO2) gas. 

 [40 CFR 60.45(a); A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

b. The continuous emission monitoring systems for CO2 shall meet the 

following requirements: 

i. 40 CFR Part 75, Appendix A, Specification and Test Procedures 

(1) Installation and measurement location 

(2) Equipment specifications 

(3) Performance specifications 

(4) Data acquisition and handling systems 

(5) Calibration gas 

(6) Certifications tests and procedures 

(7) Calculations 

ii. 40 CFR Part 75, Appendix B, Quality Assurance and Quality 

Control Procedure 

(1) Quality control program 

(2) Frequency of testing 

iii. Data Reduction 

 Permittee shall comply with the data reduction requirements of 

40 CFR Part 75.10(d)(1). 

2. Permit Shield 

Compliance with this Section shall be deemed compliance with 40 CFR 60.45(a), 

40 CFR 75 Appendix “A” and “B”, and 40 CFR 75.10(d)(1). 

[A.A.C. R18-2-325] 
 

TV Permit Renewal Number 52639 Page 36 of 79 December 06, 2011 

SRP – Coronado Generating Station 

G. Sulfur Dioxide (SO2) 

1. Emission Limitations/Standards 

a. Coal 

i. Permittee shall not cause to be discharged into the atmosphere 

from the stack of each unit any gases which contain sulfur 

dioxide in excess of 340 nanograms per joule heat input (0.8 

pounds per million Btu) derived from coal. 

 [A.A.C. R18-2-903.1] 

ii. Beginning on January 1, 2012, for Unit 2, and continuing 

thereafter, the Permittee shall achieve and maintain a 30-day 

rolling average SO2 removal efficiency of at least 95.0 percent or 

a 30-day rolling average SO2 emission rate no greater than 0.080 

lb/MMBtu. 

[Significant Revision #46236, Condition II.F.d] 

iii. Beginning on January 1, 2013, for Unit 1, and continuing 

thereafter, the Permittee shall achieve and maintain a 30-day 

rolling average SO2 removal efficiency of at least 95.0 percent or 

a 30-day rolling average SO2 emission rate no greater than 0.080 

lb/MMBtu. [Significant Revision #46236, Condition II.D.2.e] 

b. Fuel Oil and Used Oil Fuel 

i. Permittee shall not cause to be discharged into the atmosphere 

from the stack of each unit any gases which contain sulfur 

dioxide in excess of 340 nanograms per joule heat input (0.8 

pounds per million Btu) derived from used oil fuel. 

 [40 CFR 60.43(a)(1)] 

ii. Compliance shall be based on the total heat input from all fossil 

fuels burned, including gaseous fuels. [40 CFR 60.43(c)] 

c. Excess Emissions 

i. Excess emissions for Unit 1 and Unit 2 are defined as any threehour period during which the average emissions (arithmetic 

average of three contiguous one-hour periods) of sulfur dioxide 

as measured by a continuous monitoring system exceeds the 

applicable standard in Conditions II.G.1 of this Attachment. 

ii. Beginning January 1, 2012 for Unit 2 and beginning January 1, 

2013 for Unit 1, excess emissions are defined as any 30-day 

rolling average emissions of sulfur dioxide as measured by a 

continuous monitoring system exceeds the applicable standard in 

Conditions II.G.1.a.ii. or II.G.1.a.iii of this Attachment. 

 
 

TV Permit Renewal Number 52639 Page 37 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2. Air Pollution Control Requirement 

a. Prior to the installation of FGD systems on Unit 1 and Unit 2, the 

Permittee shall at all times, including periods of startup, shutdown, and 

malfunction, to the extent practicable, maintain, and operate the Pullman 

Kellogg SO2 scrubber in a manner consistent with good air pollution 

control practices for minimizing SO2 emissions. [40 CFR 60.11(d) and A.A.C. R18-2-331.A.3.e] 

[Material Permit Conditions are defined by underline and italics] 

b. No later than January 1, 2012, for Unit 2 and no later than January 1, 

2013, for Unit 1, the Permittee shall install, maintain, and continuously 

operate the FGD system on each unit at all times that the unit it serves is 

in operation, consistent with the technological limitations, 

manufacturer’s specifications, and good engineering and maintenance 

practices for the FGDs for minimizing emissions to the extent 

practicable. 

 [Significant Revision #46236, Condition II.F.2.b;A.A.C. R18-2-306.A.2 and 331.A.3.d & e] 

[Material Permit Conditions are defined by underline and italics] 

3. Monitoring, Recordkeeping, & Reporting Requirements 

a. The Permittee shall calibrate, maintain, and operate continuous

emissions monitoring system (CEMS) for measuring sulfur dioxide 

emissions.

 [40 CFR 60.45(a); A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

b. The CEMS for SO2 shall meet the following requirements: 

i. 40 CFR Part 75, Appendix A, Specification and Test Procedures 

(1) Installation and measurement location 

(2) Equipment specifications 

(3) Performance specifications 

(4) Data acquisition and handling systems 

(5) Calibration gas 

(6) Certifications tests and procedures 

(7) Calculations 

ii. 40 CFR Part 75, Appendix B, Quality Assurance and Quality 

Control Procedure 

(1) Quality control program 

(2) Frequency of testing 

iii. The Permittee shall comply with the data reduction requirements 

of 40 CFR Part 75.10(d)(1). 

iv. The Permittee shall comply with all applicable recordkeeping 

and reporting requirements of 40 CFR Part 75 Subparts F and G 
 

TV Permit Renewal Number 52639 Page 38 of 79 December 06, 2011 

SRP – Coronado Generating Station 

respectively 

c. Monitoring of SO2 Emission Rate 

 

The Permittee shall determine the 30-day rolling average SO2 emission 

rate and the 30-day rolling average SO2 removal efficiency for Unit 1 

and Unit 2 using CEMS in accordance with the procedures of 40 CFR 

Part 75, with the following exceptions: 

(1) SO2 emissions data need not be bias adjusted. 

(2) For any CEMS with a span less than 100 ppm, the calibration 

drift and out-of-control criteria in Procedure 1, Section 4.3 of 40 

CFR Part 60 Appendix F shall apply in lieu of the low emitter 

specifications in 40 CFR Part 75, Appendix B, Section 2.1. 

(3) For any CEMS with a span less than or equal to 30 ppm, the 

exemption from the 40 CFR Part 75 linearity check will not 

apply and either the 40 CFR Part 75 linearity check or the 

cylinder gas audit described in Procedure 1, Section 5.1.2 of 40 

CFR Part 60, Appendix F shall be performed on a quarterly 

basis. 

(4) An annual relative accuracy test audit shall meet, at a minimum, 

a relative accuracy of less than 20 percent or an accuracy of less 

than 0.016 lb/MMBtu (expressed as the difference between the 

monitor mean and the reference value mean). 

(5) In lieu of installing an inlet flow monitor, the inlet pounds of SO2

will be calculated as described in Condition II.G.3.d.i.(2). 

 [Significant Revision #46236, Condition II.F.3.b] 

d. Determining the 30-Day Rolling Average SO2 Removal Efficiency 

 

i. If necessary, the Permittee shall calculate the 30-day rolling 

average SO2 removal efficiency in accordance with the following 

procedure: 

 

(1) Sum the total pounds of SO2 emitted as measured at the 

outlet of the FGD system for the unit during the current 

Unit Operating Day and the previous 29 Unit Operating 

Days as measured at the outlet of the FGD system for 

that unit. 

(2) Sum the total pounds of SO2 delivered to the inlet of the 

FGD system for the unit during the current Unit 

Operating Day and the previous 29 Unit Operating Days 

as measured at the inlet to the FGD system for that unit 

(this shall be calculated by measuring the ratio of the 

lb/MMBtu SO2 inlet to the lb/MMBtu SO2 outlet and 

multiplying the outlet pounds of SO2 by that ratio). 
 

TV Permit Renewal Number 52639 Page 39 of 79 December 06, 2011 

SRP – Coronado Generating Station 

(3) Subtract the outlet SO2 emissions calculated in 

Condition II.G.3.d.i.(1) from the inlet SO2 emissions 

calculated in Condition II.G.3.d.i.(2). 

(4) Divide the remainder calculated in Condition 

II.G.3.d.i.(3) by the inlet SO2 emissions calculated in 

Condition II.G.3.d.i(2). 

(5) Multiply the quotient calculated in Condition 

II.G.3.d.i(4) by 100 to express as a percentage of 

removal efficiency. 

ii. A new 30-day rolling average SO2 removal efficiency shall be 

calculated for each new Unit Operating Day and shall include all 

emissions that occur during all periods within each Unit 

Operating Day, including emissions from startup, shutdown, and 

malfunction. 

 [Significant Revision #46236, Condition II.F.3.c] 

e. Determining the 30-Day Rolling Average SO2 Emission Rate [Significant Revision #46236, Condition II.F.3.d] 

i. The Permittee shall calculate the 30-day rolling average SO2

emission rate in accordance with the following procedure: 

(a) Sum the total pounds of SO2 emitted from each Unit 

during the current Unit Operating Day and the previous 

29 Unit Operating Days. 

(b) Sum the total heat input to each Unit in MMBtu during 

the current Unit Operating Day and the previous 29 Unit 

Operating Days. 

(c) Divide the total number of pounds SO2 emitted during 

the 30 Unit Operating Days by the total heat input during 

the 30 Unit Operating Days. 

ii. A new 30-day rolling average SO2 emission rate shall be 

calculated for each Unit Operating Day. Each 30-day rolling 

average SO2 emission rate shall include all emissions that occur 

during all periods within any Unit Operating Day, including 

emissions from startup, shutdown, and malfunction. 

f. Reporting Requirements 

The Permittee shall maintain records of the SO2 removal efficiency or 

SO2 emission rate. These records shall be submitted along with the 

Compliance certifications required in Condition VII of the Attachment 

“A”. These reports shall be made available, upon request, to Department 

inspectors in a reasonable time. [A.A.C. R18-2-306.A.5.a] 
 

TV Permit Renewal Number 52639 Page 40 of 79 December 06, 2011 

SRP – Coronado Generating Station 

4. Permit Shield 

Compliance with this Section shall be deemed compliance with 40 CFR 

60.43(a)(1), 40 CFR 60.43(c), 40 CFR 60.45(a), 40 CFR 60.45(g)(2), 40 CFR 75 

Subpart F and G, 40 CFR 75 Appendix “A” and “B”, 40 CFR 75.10(d)(1), 

A.A.C. R18-2-903.1 and Significant Revision Permit #30732 Condition 

II.F.1.d,e; Condition II.F.2.a & b; Condition II.F.3]. [A.A.C. R18-2-325] 

H. Carbon Monoxide (CO) 

1. Emission Limitations/Standards 

a. The Permittee shall not cause to be discharged into the atmosphere from 

the stack of each unit any gases which contain CO in excess of 0.50 

lb/MMBtu on a 30-day rolling average, excluding periods of start-up, 

shutdown, and malfunction. 

 [A.A.C. R18-2-406.A.4] 

b. The Permittee shall not cause to be discharged into the atmosphere from 

the stack of each unit any gases which contains CO in excess of 3.6 

lb/MMBtu on a 1-hour average. [A.A.C. R18-2-406.A.5] 

2. Monitoring, Recordkeeping & Reporting Requirements 

a. Beginning on the earlier of 90 Unit Operating Days or 180 calendar 

days after the low-NOx burners are installed and commence operating 

on each unit, the Permittee shall calibrate, maintain, and operate 

continuous emission monitoring systems (CEMS) for measuring 

emissions of CO. [A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

b. The Permittee shall calibrate, maintain, and operate continuous

emissions monitoring system (CEMS) for measuring carbon monoxide 

emissions.

 [40 CFR 60.45(a); A.A.C. R18-2-331.A.3.c] 

[Material Permit Conditions are defined by underline and italics] 

c. The CEMS for CO shall meet the following requirements: 

i. 40 CFR Part 60, Appendix B, Performance Specifications, 

Performance Specification 4, Specifications and Test Procedures 

for Carbon Monoxide Continuous Monitoring Systems in 

Stationary Sources. 

ii. 40 CFR Part 60, Appendix F, Quality Assurance Procedures. 

iii. The Permittee shall check the zero (or low-level value between 0 

and 20 percent of span value) and span (50 to 100 percent of 

span value) calibration drifts at least once daily in accordance 
 

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SRP – Coronado Generating Station 

with a written procedure. The zero and span shall, at a minimum, 

be adjusted whenever the 24-hour zero drift or 24-hour span drift 

exceeds two times the limits of the applicable performance 

specifications in 40 CFR Part 60 Appendix B. The system must 

allow the amount of excess zero and span drift to be recorded 

and quantified, whenever specified. 

iv. Except for system breakdowns, repairs, calibration checks, and 

zero and span adjustments required under Condition II.H.2.c.iii, 

the Permittee shall operate the CO CEMS continuously and shall 

complete a minimum of one cycle of operation (sampling, 

analyzing, and data recording) for each successive 15-minute 

period. [A.A.C.R18-2-306.A.3.c] 

d. Carbon Monoxide Excess Emissions 

i. Excess emissions for Unit 1 and Unit 2 are defined as any 30 

day period, excluding periods of start-up, shutdown and 

malfunction during which the average emissions of CO as 

measured by a continuous monitoring system exceeds the 

applicable standard in Conditions II.H.1 of this Attachment. 

 Excess emissions for Unit 1 and Unit 2 are defined as any onehour period during which the average emissions of CO as 

measured by a continuous monitoring system exceeds the 

applicable standard in Conditions II.H.2 of this Attachment. [A.A.C.R18-2-312.H.3] 

ii. The Permittee shall submit excess emissions and monitoring 

systems performance reports to the Director semiannually. All 

reports shall be submitted along with the compliance 

certifications required by Condition VII of Attachment “A”. 

Written reports of excess emissions shall include the following 

information: 

 

(1) The magnitude of excess emissions computed in 

accordance with 40 CFR 60.13(h), any conversion 

factor(s) used, the date and time of commencement and 

completion of each time period of excess emissions, and 

the process operating time during the reporting period. 

(2) Specific identification of each period of excess 

emissions that occurs during startups, shutdowns, and 

malfunctions of Unit 1 and Unit 2, the nature and cause 

of any malfunction (if known), and the corrective action 

taken or preventive measures adopted. 

(3) The date and time identifying each period during which 

the CO CEMS was inoperative, except for zero and span 

checks, and the nature of the system repairs or 

adjustments. 
 

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 (4) When no excess emissions have occurred or the CO 

CEMS have not been inoperative, repaired, or adjusted, 

such information shall be stated in the report. [A.A.C.R18-2-306.A.4] 

iii. The summary report form shall contain the information and be in 

the format shown in Figure 1 of 40 CFR 60.7(d) unless otherwise 

specified by the Director. One summary report form shall be 

submitted for CO emissions monitored at Unit 1 and Unit 2. [A.A.C.R18-2-306.A.4] 

(1) If the total duration of excess emissions for the reporting 

period is less than 1 percent of the total operating time 

for the reporting period and CO CEMS downtime for the 

reporting period is less than 5 percent of the total 

operating time for the reporting period, only the 

summary report form shall be submitted and the excess 

emissions report described in 40 CFR 60.7(c) need not 

be submitted unless requested by the Department. 

(2) If the total duration of excess emissions for the reporting 

period is 1 percent or greater of the total operating time 

for the reporting period or the total CO CEMS downtime 

for the reporting period is 5 percent or greater of the total 

operating time for the reporting period, the summary 

report form and the excess emission report described in 

40 CFR 60.7 (c) shall both be submitted. 

3. Permit Shield 

 Compliance with this Section shall be deemed compliance with Significant 

Revision # 46236 Condition II.G of Attachment “B”. 

 [A.A.C. R18-2-325] 

I. Sulfuric Acid (H2SO4) Mist 

1. Beginning on June 1, 2014, and continuing thereafter, the Permittee shall not 

cause to be discharged into the atmosphere from Unit 2 any gases which contain 

H2SO4 in excess of 0.012 lb/MMBtu, excluding periods of start-up, shutdown, 

and malfunction. 

2. Within 180 days of commencement of operation of the SCR on Unit 2, the 

Permittee shall complete performance tests, conducted using EPA Conditional 

Test Method 13 (CTM-13) or an alternate test method, to determine if the H2SO4 

emissions from Unit 2 are consistently less than or equal to 0.006 lb/MMBtu. If 

the Permittee requests an alternate test method, the Permittee must submit this 

request at least 60 days prior to commencing the test program. If the Permittee 

does not receive a response within 30 days of submitting such a request, the 

proposed alternative test method shall be considered to be approved by the 

Director and the Administrator. The Permittee must notify the Director and the 
 

TV Permit Renewal Number 52639 Page 43 of 79 December 06, 2011 

SRP – Coronado Generating Station 

Administrator at least 30 days prior to commencing the test program and shall 

submit the test report to the Director and the Administrator within 60 days of 

completing the test program. 

3. If the test report demonstrates that Unit 2 can consistently achieve an emission 

rate of 0.006 lb/MMBtu, including a compliance margin, then this will become 

the enforceable H2SO4 emission limit. This limit shall be effective on the date 

that the test report required in Condition II.I.2 is submitted to the Director and the 

Administrator. Subsequent H2SO4 performance tests shall be conducted annually 

thereafter. 

4. H2SO4 Minimization Analysis 

a. If the test results from Condition II.I.2 demonstrate that Unit 2 emissions 

of H2SO4 exceed 0.006 lb/MMBtu, the Permittee shall prepare an H2SO4

minimization analysis that evaluates further options, including but not 

limited to reagent/sorbent injection, to reduce emissions to 0.005 

lb/MMBtu or less while maintaining PM emissions within 80 percent of 

the limit set forth in Condition II.D.1.c. The minimization analysis will 

not be required to include an assessment or require the use of any 

additional PM control equipment. The Permittee shall: 

i. Submit the incremental minimization analysis within 30 days of 

submitting the test report required by Condition II.I.2; 

ii. Identify all available control technologies for reducing H2SO4 

emissions; 

iii. Include an analysis of the filterable PM control effectiveness of 

the scrubber based on data available through stack test, PM 

CEMS, and the PM CEMS/PM correlation and RATA testing; 

iv. Include an evaluation of the energy, environmental, economic, 

and other impacts associated with each alternative technology 

and the benefit of reduced emissions that the technology would 

bring. For the purposes of this evaluation, it is presumed that 

hydrated lime injection is economically reasonable. 

v. Include a proposed emission limit and control technology 

configuration based on the above evaluation. Any new control 

technology required by the minimization analysis would be 

installed as soon as practicable, but no later than 2 years after the 

Director issues an installation permit unless the Director agrees 

to a longer implementation schedule. 

b. The Director will assess and determine an appropriate H2SO4 emission 

limit based on the test results collected during the testing program 

required by Condition II.I.2 and the minimization analysis. The 
 

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SRP – Coronado Generating Station 

assessment will take into consideration the statistical variability of the 

test results, the different coal supplies utilized at the facility during the 

test period, and will include a reasonable margin of safety for compliance 

with both the PM and the H2SO4 emission limits. 

c. The new limit will become effective upon issuance of a final significant 

revision to the Permittee’s operating permit, which incorporates the new 

H2SO4 emission limit. Permittee shall submit a significant revision 

application within 30 days of the Director’s determination to incorporate 

the new limits into the permit. [A.A.C. R18-

2-406.A.4] 

5. Permit Shield [A.A.C. R18-2-325] 

Compliance with this Section shall be deemed compliance with Significant 

Revision # 46236 Condition II.H of Attachment “B”. 

J. Surrender of SO2 Allowances 

1. For the purposes of this section, “surrender” means, with regard to SO2

Allowances, permanently surrendering so that such SO2 Allowances can never be 

used to meet any compliance requirement under the Clean Air Act or the Arizona 

SIP. [Significant Revision #46236, Condition II.I.1] 

2. Except as provided in II.J.9, the Permittee shall not sell, trade, or transfer any 

SO2 Allowances allocated to CGS that would otherwise be available for sale, 

trade, or transfer as a result of the actions taken by the Permittee to comply with 

the requirements of this Permit. [Significant Revision #46236, Condition II.I.2] 

3. Beginning with calendar year 2012, the Permittee shall surrender to EPA, or 

transfer to a non-profit third party selected by the Permittee for purposes of 

surrender, all SO2 Allowances that have been allocated to CGS in excess of the 

amount needed to meet its own federal and/or state Clean Air Act regulatory 

requirements at CGS and Springerville Unit 4, which is located at the 

Springerville Generating Station. [Significant Revision #46236, Condition II.I.3] 

4. If the Permittee commences operation of one or more new coal-fired units that it 

owns in whole or in part in the Western Electricity Coordinating Council Region 

no earlier than five years and no later than fourteen years from the date the 

Consent Decree (Civil Action No. 2:08-cv-1479-JAT) is entered by the Court, 

then the Permittee may also use SO2 Allowances, as limited by this condition, 

allocated to CGS to meet the federal and/or state Clean Air Act regulatory 

requirements for certain SO2 emissions from such new coal-fired unit(s). 

a. The Permittee may only use such SO2 Allowances pursuant to this 

condition if such new coal-fired unit(s) is equipped with the Best 

Available Control Technology (if the new coal-fired unit(s) will be 

emitting any of the pollutants set forth at 40 CFR 52.21(b)(50) and the 

new coal-fired unit(s) will be located in an attainment area for those 

pollutants) and/or the Lowest Achievable Emission Rate (if the new coalfired unit(s) will be emitting any of the pollutants set forth at 40 CFR 
 

TV Permit Renewal Number 52639 Page 45 of 79 December 06, 2011 

SRP – Coronado Generating Station 

51.165(a)(xxxvii) and the new coal-fired unit(s) will be located in a 

nonattainment area for those pollutants). 

b. The Permittee may only use SO2 Allowances for the SO2 emissions 

associated with a total of 400 megawatts that it owns at such new coalfired unit(s), whether at one new coal-fired unit (e.g., the Permittee owns 

a total of at least 400 MW at one new coal-fired unit) or in the aggregate 

at multiple new coal-fired units (e.g., the Permittee owns 100 MW at 

four new coal-fired units for an aggregate total of 400 MW). 

c. To determine the number of SO2 Allowances the Permittee may use 

pursuant to this condition, the Permittee may use no more than the 

number of SO2 Allowances that cover the same percentage of total SO2

emissions from such new coal-fired unit(s) as the percentage of the 

Permittee’s ownership in such new coal-fired unit(s), on a MW basis. 

Thus, for example, if the Permittee owns 400 MW of a new 800 MW 

coal-fired unit that otherwise meets the requirements of this condition, 

the Permittee may use excess SO2 Allowances allocated to CGS to cover 

no more than fifty percent of the total SO2 emissions from such new 

coal-fired unit. This reduction in the amount of SO2 Allowances 

surrendered by or on behalf of the Permittee would start with the year 

this new unit(s) commences operation. 

 [Significant Revision #46236, Condition II.I.4] 

5. The Permittee shall make its surrender of SO2 Allowances, annually, within 

forty-five days of its receipt from EPA of the Annual Deduction Reports for SO2. 

Any surrender need not include the specific SO2 Allowances that were allocated 

to CGS, so long as the Permittee surrenders SO2 Allowances that are from the 

same year and that are equal to the number required to be surrendered under 

Condition II.J. 

 [Significant Revision #46236, Condition II.I.5] 

6. If any SO2 Allowances are transferred directly to a non-profit third party for 

surrender to EPA, the Permittee shall include a description of such transfer in the 

next report submitted to EPA pursuant to Section XI (Periodic Reporting) of the 

Consent Decree (Civil Action No. 2:08-cv-1479-JAT). Such report shall: 

a. Provide the identity of the non-profit third-party recipient(s) of the SO2

Allowances and a listing of the serial numbers of the transferred SO2

Allowances; and 

b. Include a certification by the non-profit third-party recipient(s) stating 

that the recipient(s) will not sell, trade, or otherwise exchange any of the 

SO2 Allowances and will not use any of the SO2 Allowances to meet any 

obligation imposed by any environmental law. 

 [Significant Revision #46236, Condition II.I.6] 

7. No later than the third periodic report due after the transfer of any SO2

Allowances, the Permittee shall include a statement that the non-profit third-party 

recipient(s) surrendered the SO2 Allowances for permanent surrender to EPA in 

accordance with the provisions of II.J.8 within 1 year after the Permittee 
 

TV Permit Renewal Number 52639 Page 46 of 79 December 06, 2011 

SRP – Coronado Generating Station 

transferred the SO2 Allowances to them. The Permittee shall not have complied 

with the SO2 Allowance surrender requirements of Condition II.J until all nonprofit third-party recipient(s) shall have actually surrendered the transferred SO2

Allowances to EPA. 

 [Significant Revision #46236, Condition II.I.7] 

8. For all SO2 Allowances surrendered to EPA, the Permittee or the non-profit 

third-party recipient(s) (as the case may be) shall first submit an SO2 Allowance 

transfer request form to EPA’s Office of Air and Radiation’s Clean Air Markets 

Division directing the transfer of such SO2 Allowances to the EPA Enforcement 

Surrender Account or to any other EPA account that EPA may direct in writing. 

As part of submitting these transfer requests, the Permittee or the non-profit 

third-party recipient(s) shall irrevocably authorize the transfer of these SO2

Allowances and identify – by name of account and any applicable serial or other 

identification numbers or station names – the source and location of the SO2

Allowances being surrendered. [Significant Revision #46236, Condition II.I.8] 

9. Provided that the Permittee is in compliance with the SO2 emission limitations 

established in Conditions II.G.1.a.ii and II.G.1.a.iii, nothing shall preclude the 

Permittee from using, selling, or transferring Super-Compliance SO2 Allowances 

that may arise as a result of achieving and maintaining SO2 emission rates or 

removal efficiencies at Unit 1 and Unit 2 below the emission limits required in 

Conditions II.G.1.a.ii and II.G.1.a.iii, so long as the Permittee timely reports the 

generation of such Super-Compliant SO2 Allowances in accordance with Section 

XI (Periodic Reporting) of the Consent Decree (Civil Action No. 2:08-cv-1479-

JAT). 

 [Significant Revision #46236, Condition II.I.9] 

10. The Permittee shall not use SO2 Allowances to comply with any requirement of 

the Permit, including by claiming compliance with any emission limitation 

required by the Permit by using, tendering, or otherwise applying SO2

Allowances to offset any excess emissions (i.e., emissions above the limits 

specified in Conditions II.G.1.a.ii and II.G.1.a.iii). 

 [Significant Revision #46236, Condition II.I.10] 

11. Nothing in this Section shall prevent the Permittee from purchasing or otherwise 

obtaining SO2 Allowances from another source for purposes of complying with 

state or federal Clean Air Act requirements to the extent otherwise allowed by 

law. [Significant Revision #46236, Condition II.I.11] 

12. Permit Shield [A.A.C. R18-2-325]

Compliance with this Section shall be deemed compliance with Significant 

Revision # 46236 Condition II.I of Attachment “B”. 

 K. Mercury Emissions Control 

[State Enforceable Only] 

 [Consent Order #A-17-09, & A.A.C. R 18-2-306.A.2] 

1. The State Standards of Performance for Mercury Emissions from Coal-Fired 

Electric Steam Generating Units set forth in A.A.C. R18-2-734 shall not be apply 

to the Permittee until December 31, 2015. 
 

TV Permit Renewal Number 52639 Page 47 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2. The Permittee shall implement the Operation and Maintenance (O&M) plan 

specified in Condition II.K.3 at all times beginning on January 1, 2012, and 

continue until December 31, 2015. The O&M plan does not impose any 

enforceable mercury emission limitations or require any commitments to achieve 

any mercury emission reductions.

3. Mercury Control Strategy O&M Plan 

[A.A.C. R 18-2-306.A.2, 306.A.3.c, and 331.A.3.c ] [Material Permit Conditions is defined by underline and italic] 

a. On or before January 1, 2012, the Permittee shall install, maintain, and 

operate on Unit 1 and Unit 2, mercury control technology by injecting a 

chemical oxidizer in the feed coal, designed to achieve a minimum of 70 

percent reduction of total inlet mercury on a facility-wide annual basis

where “inlet mercury” means the average concentration of mercury in 

coal burned at the CGS facility, as determined by ASTM methods, EPA 

approved methods or an alternative method approved by the Director. 

 [A.A.C. R 18-2-331]

b. To the extent possible the Permittee shall, at all times after January 1, 

2012, and until December 31, 2015, ensure that the mercury control 

system is operational when coal is combusted in Unit 1 and Unit 2. [A.A.C. R 18-2-306.A.2]

c. The Permittee shall feed the chemical oxidizer at a rate that is within the 

range established in accordance with Condition II.K.4.l. In the event that 

the rate of feeding of chemical oxidizer decreases below the minimum 

injection rates determined by Condition II.K.4.l, the Permittee shall 

submit a permit deviation report in accordance with Condition XII of 

Attachment “A”. [A.A.C. R 18-2-306.A.2]

d. In the event of change of the chemical oxidizer, the Permittee shall reestablish the range of injection rates of the new chemical oxidizer to 

achieve 70 percent reduction as per Condition II.K.4.l. [A.A.C. R 18-2-306.A.2]

e. In order to minimize the effect of emissions of entrained mercury from 

the wet scrubbers, the Permittee may inject one or more chemical 

additives to the scrubbers. [A.A.C. R 18-2-306.A.2]

f. The Permittee shall install and operate a flow meter or an equivalent 

device to measure the chemical oxidizer feed rate. [A.A.C. R 18-2-306.A.2]

g. The Permittee shall monitor the instantaneous volumetric flow rate of the 

chemical oxidizer once every twelve hours. [A.A.C. R 18-2-306.A.3.c]

 

h. The Permittee shall monitor the operation of chemical oxidizer feed 

pumps once every twelve hours when coal is combusted in the boilers. [A.A.C. R 18-2-306.A.3.c]
 

TV Permit Renewal Number 52639 Page 48 of 79 December 06, 2011 

SRP – Coronado Generating Station 

i. The Permittee shall monitor the chemical oxidizer solution tank level 

once every twelve hours when coal is combusted in the boilers. [A.A.C. R 18-2-306.A.3.c]

j. The Permittee shall maintain vendor documentation showing quality 

(concentration of chemical oxidizer) of each delivery of the reagent. [A.A.C. R 18-2-306.A.3.c]

k. The Permittee shall maintain an adequate inventory of chemical oxidizer 

solution to support continuous feed. [A.A.C. R 18-2-306.A.3.c]

l. The Permittee shall maintain an inventory of critical spare parts for the 

chemical oxidizer feed pumps on site. [A.A.C. R 18-2-306.A.3.c]

m. The Permittee shall follow maintenance requirements according to the 

frequency indicated below: 

Equipment Maintenance Activity Frequency 

Distribution header Inspect for plugging Once per 

operating week 

Clean strainers Once per 

operating week 

Strainers 

Replace gaskets Annually

Metering pumps Calibrate Annually 

Storage tank Drain and inspect Annually 

Pressure gauges Calibrate Annually 

Distribution piping Visual inspection for 

defects 

Annually 

 [A.A.C. R 18-2-306.A.3.c]

4. Monitoring, Recordkeeping, and Reporting for O & M Plan

[A.A.C. R18-2-306.A.3.c and -331.A.3.c] 

[Material Permit Conditions are indicated by underline and italics]

In order to demonstrate proper operation of the mercury control technology, the 

Permittee shall implement the following monitoring, recordkeeping, and 

reporting measures: 

a. Perform coal analysis to determine the concentration of mercury in 

pounds per ton of coal from a representative sample of coal delivered to 

the facility. As an alternative to performing the coal analysis, data from 

the coal supplier may be used. The data shall be logged and averaged on 

a monthly basis. The monthly average inlet mercury concentration will 

be multiplied by the total monthly coal feed rate to determine a monthly 

inlet mercury mass. 

 

b. Monitor and record the rate of chemical oxidizer solution feed to the coal 
 

TV Permit Renewal Number 52639 Page 49 of 79 December 06, 2011 

SRP – Coronado Generating Station 

feed during operation of the Unit 1 and Unit 2 once every twelve hours. 

c. Install and maintain the mercury sorbent trap system in the stack of each 

unit in accordance with vendor specifications. 

d. Sample the stack gas at a rate proportional to the stack gas volumetric 

flow rate. The Permittee shall, by using the sample volume measured by 

the dry gas meter and the result of the analyses of the sorbent traps, 

determine the average mercury concentration in the stack gas in units of 

micrograms per dry standard cubic meter. 

e. Analyze the sorbent traps on-site or at a qualified off-site laboratory 

using an Ohio-Lumex desorption analyzer. When an appropriate 

protocol is provided by EPA, the Permittee shall calibrate the analyzer by 

using National Institute of Standards and Technology (NIST) traceable 

mercury standards. 

f. Calculate the mercury outlet mass emissions for each hour by using the 

average mercury concentration for that period, in conjunction with 

hourly measurement of the stack flow rate, corrected for the stack gas 

moisture content. 

g. A monthly outlet mercury mass will be calculated by summing the 

mercury emission rates determined for each hour. 

h. At the end of every month, calculate and record monthly facility-wide 

mercury reduction based on inlet and outlet mercury data from 

Conditions II.K.4.a and II.K.4.f above. 

i. Report facility-wide annual mercury removal percentage by January 31st

of each year and shall contain the results for the preceding year. The 

first report for the calendar year 2012 shall be submitted by January 31, 

2013. 

j. Keep records of the monitoring conditions pursuant to Condition II.K3.g, 

h, and i. 

k. The Permittee shall conduct the annual certification of the monitoring 

systems in accordance with the applicable Quality Assurance/Quality 

Control (QA/QC) standard in effect at the time of certification. 

l. Within 30 days of January 1, 2012 (the date on which the O & M Plan 

becomes enforceable) and within 30 days of change of chemical oxidant, 

the Permittee shall notify the Director with the following information: 

i. Name and composition of the chemical oxidizer; 

ii. Range of injection rates of the chemical oxidizer necessary to 

target a design mercury reduction of 70 percent; and 

iii. Documentation of any pilot-scale tests demonstrating the 

efficacy of the alternative chemical oxidizers, as applicable. 
 

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 L. Application for Significant Permit Revision incorporating State Mercury Standards 

[Significant Permit Revision #46236 Condition II.K] 

The Permittee shall submit an application for a significant permit revision pursuant to 

A.A.C. R 18-2-734 (F) by no later than January 1, 2014, and to include the following 

elements: 

1. The State Mercury Standard and any amendments adopted by ADEQ to ensure 

that the State Mercury Standard is compatible with a MACT standard 

promulgated by EPA. 

2. A control strategy for meeting the State Mercury Standard and any amendments 

thereto; 

3. A demonstration that the control strategy is designed to meet the State Mercury 

Standard and any amendment thereto; 

4. A proposal to comply with the State Mercury Standard by December 31, 2015, 

except as provided in A.A.C. R 18-2-734 (H), under the following conditions: 

a. For the purposes of applying exception established in A.A.C. R 18-2-734 

(H), each date specified in that provision shall be increased by three 

calendar years; 

b. The exception in A.A.C. R 18-2-734 (G) shall not apply. 

III. AUXILIARY BOILER 

A. Applicability 

This section applies to the Auxiliary Boiler as described in Attachment “C” of this 

permit. 

 

B. Fuel and Operational Requirements 

1. Permittee shall burn only Number 2 fuel oil and used oil in the auxiliary boiler. 

 [A.A.C. R18-2-302.A.2] 

2. Permittee shall not fire high sulfur oil (fuel sulfur content 0.9% by weight) as a 

fuel unless the Permittee demonstrates to the satisfaction of the Director that 

sufficient quantities of low sulfur oil are not available for use by the source and 

that it has adequate facilities and contingency plans to insure that the sulfur 

dioxide ambient air quality standards set forth in A.A.C. R18-2-202 will not be 

violated. [A.A.C. R18-2-724.G] 

3. Permittee shall not operate the auxiliary boiler at an annual average capacity 

factor greater than 10%. The annual average capacity factor shall be defined as 

ratio between the actual heat input to the auxiliary boiler from the fuels burning 

during a calendar year, and the potential heat input to the auxiliary boiler had it 

been operating for 8,760 hours during a year at the maximum steady state design 

heat input capacity. 
 

TV Permit Renewal Number 52639 Page 51 of 79 December 06, 2011 

SRP – Coronado Generating Station 

[A.A.C. R18-2-306.01.A, 306.01, and 331.A.3] 

 [Material Permit Conditions are defined by underline and italics] 

4. Monitoring, Reporting, and Recordkeeping 

a. Permittee shall maintain records of the daily fuel usage for the auxiliary 

boiler. [A.A.C. R18-2-306.A.3.c]

b. At the end of each calendar year, the Permittee shall calculate and record 

the heat input in million Btu per year and the annual capacity factor. [A.A.C. R18-2-306.A.3.c] 

c. Permittee shall keep on record the contractual agreement with the liquid 

fuel vendor indicating the following information concerning the liquid 

fuel being fired for each shipment of fuel oil: 

i. The name of the fuel oil supplier; 

ii. The heating value of the fuel oil; 

iii. The density of the fuel oil; 

iv. The ash content of the fuel oil; 

v. The sulfur content of the fuel oil from which the shipment came; 

vi. The method used to determine the ash content of the fuel oil; and 

vii. The method used to determine the sulfur content of the fuel oil. [A.A.C. R18-2-306.A.3.b] 

d. The Permittee shall notify the Director within 30 days of any change in 

the contractual agreement. 

 [A.A.C. R18-2-306.A.3.c] 

5. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

724.G, and Permit #30732, Attachment B, Condition I.B.2. 

[A.A.C. R18-2-325] 

C. Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. Particulate Matter & Opacity 

Permittee shall not cause, allow or permit the emission of particulate 

matter, caused by combustion of fuel, from the auxiliary boiler in excess 

of the amount calculated by the following equation: 

E = 1.02 Q0.769 

Where: 

E = the maximum allowable particulate emissions rate in pounds-mass 

per hour. 

Q = the heat input in million Btu per hour. 

[A.A.C. R18-2-724.C.1] 
 

TV Permit Renewal Number 52639 Page 52 of 79 December 06, 2011 

SRP – Coronado Generating Station 

For the purposes of condition III.C.1.a of this Attachment, heat input is 

defined as the aggregate heat content of all fuels whose products of 

combustion pass through a stack or other outlet. 

 [A.A.C. R18-2-724.B] 

b. Permittee shall not cause, allow or permit to be emitted into the 

atmosphere from the auxiliary boiler, smoke which exceeds 15 percent 

opacity measured in accordance with EPA Reference Method 9. 

[A.A.C. R18-2-724.J] 

2. Monitoring, Recordkeeping & Reporting 

a. Permittee shall report all six-minute periods in which the opacity of any 

plume or effluent exceeds 15 percent from the auxiliary boiler. [A.A.C. R18-2-724.J] 

b. Permittee shall conduct weekly opacity monitoring of visible emissions. 

If the opacity of the emissions observed appears to exceed the relevant 

opacity standard, the observer shall conduct a certified EPA Reference 

Method 9 observation. The Permittee shall keep records of the initial 

survey and any EPA Reference Method 9 observations performed. 

These records shall 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 relevant opacity standard, the Permittee shall initiate 

appropriate corrective action to reduce the opacity below the standard. 

The Permittee shall keep a record of the corrective action performed. [A.A.C. R18-2-306.A.3.c] 

3. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

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

Operating Permit #30732 Condition III.B.1. 

 [A.A.C. R18-2-325] 

D. Sulfur Dioxide 

1. Emission Limitations/Standards 

a. Permittee shall not cause, allow, or permit emission of more than 1.0 

pounds of sulfur dioxide per million Btu heat input. [A.A.C. R18-2-724.E] 

b. For the purposes of Condition III.D.1.a of this Attachment, “heat input” 

is defined as the aggregate heat content of all fuels whose products of 

combustion pass through a stack or other outlet. 

 [A.A.C. R18-2-724.B]

2. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

724.B, and A.A.C. R18-2-724.E. [A.A.C. R18-2-325] 
 

TV Permit Renewal Number 52639 Page 53 of 79 December 06, 2011 

SRP – Coronado Generating Station 

IV. INTERNAL COMBUSTION ENGINES (ICE) 

A. Applicability

This section applies to the emergency generator identified in Attachment “C” of this 

permit. 

B. Operational Limitation 

1. Permittee shall only burn diesel fuel in the ICE located at the facility. [A.A.C. R18-2-306.A.2] 

2. The Permittee shall record the hours of operation of the emergency generator and 

at the end of each month calculate and record a 12 month rolling total. 

 [A.A.C. R18-2-306.A.3] 

C. Existing Source Requirements 

1. Particulate Matter and Opacity 

 a. Emissions Limitations/Standards 

i. The Permittee shall not cause or allow to be discharged into the 

atmosphere from the internal combustion engines any gases in 

which exhibit greater than 40% opacity. 

 [A.A.C. R18-2-719.E] 

ii. The Permittee shall not cause, allow or permit the emission of 

particulate matter, caused by combustion of fuel, from the 

internal combustion engines having a heat input rate of 4200 

million Btu per hour or less, in excess of the amounts calculated 

by the following equation: 

 E = 1.02*Q0.769 

 where: 

E = the maximum allowable particulate emissions rate in 

pounds-mass per hour 

 Q = the heat input in million BTU per hour. 

 [A.A.C. R18-2-719.C.1] 

iii. For the purposes of Condition IV.C.1.b above, the heat input 

shall be the aggregate heat content of all fuels whose products of 

combustion pass through a stack or other outlet. Compliance 

tests shall be conducted during operation at the normal rated 

capacity of each unit. The total heat input of all operation 

generators and internal combustion engines on a plant or 

premises shall be used for determining the maximum allowable 

amount of particulate matter which may be emitted. [A.A.C. R18-2-719.B] 
 

TV Permit Renewal Number 52639 Page 54 of 79 December 06, 2011 

SRP – Coronado Generating Station 

b. Monitoring, Recordkeeping and Reporting Requirements 

i. The Permittee shall monitor the lower heating value of the fuel 

being combusted in the internal combustion engines. The 

Permittee shall maintain records of the lower heating value of the 

fuel fired in the internal combustion engines. This may be 

accomplished by maintaining on record a copy of fuel supplier 

certifications that specify the lower heating value of the fuel. 

[A.A.C. R18-2-306.A.3.c and A.A.C. R18-2-719.I] 

 

ii. For the internal combustion engines listed in Attachment “C”, 

Permittee shall conduct opacity monitoring in accordance with 

Condition I.B of this Attachment while the engine is in 

operation. [A.A.C. R18-2-306.A.3.c] 

c. Permit Shield 

 

Compliance with the conditions of this Section shall be deemed 

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

R18-2-719.E and A.A.C. R18-2-719.I. 

[A.A.C. R18-2-325] 

2. Sulfur Dioxide 

a. Emissions Limitations/Standards 

 The Permittee shall not burn high sulfur fuel only fuel which limits the 

emission of sulfur dioxide to 1.0 pound per million Btu heat input. [A.A.C. R18-2-719.F and H] 

 

b. Monitoring, Recordkeeping and Reporting Requirements 

 

i. The Permittee shall monitor the sulfur content of the fuel being 

combusted in the internal combustion engines. The Permittee 

shall maintain records of the daily sulfur content and lower 

heating value of the fuel fired in the internal combustion engines. 

This may be accomplished by maintaining on record a copy of 

fuel supplier certifications that specify the sulfur content and 

lower heating value of the fuel. 

 [A.A.C. R18-2-306.A.3.c and A.A.C. R18-2-719.I] 

ii. The Permittee shall report to the Director any daily period during 

which the sulfur content of the fuel being fired in the machine 

exceeds 0.8%. 

 [A.A.C. R18-2-719.J and 306.A.3]

c. Permit Shield 

 Compliance with the conditions of this Section shall be deemed 

compliance with A.A.C. R18-2-719.I, A.A.C. R18-2-719.J, A.A.C. R18-

2-719.H, and A.A.C. R18-2-719.F. [A.A.C. R18-2-325]
 

TV Permit Renewal Number 52639 Page 55 of 79 December 06, 2011 

SRP – Coronado Generating Station 

D. National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

Requirements for Engines Less than 500 Horsepower 

1. Applicability 

a. This section is applicable to the emergency fire pump engine identified 

in Attachment “C”. 

b. The requirements of Condition IV.D shall become effective on May 3, 

2013. 

2. Operating Requirements [40 CFR 63.6605] 

a. The Permittee shall operate and maintain the emergency fire pump 

engine and monitoring equipment, in a manner consistent with safety and 

good air pollution control practices for minimizing emissions. The 

general duty to minimize emissions does not require the Permittee to 

make any further efforts to reduce emissions if levels required by this 

standard have been achieved. Determination of whether such operation 

and maintenance procedures are being used will be based on information 

available to the Administrator and the Director which may include, but is 

not limited to, monitoring results, review of operation and maintenance 

procedures, review of operation and maintenance records, and inspection 

of the source. [40 CFR 63.6605(b)] 

b. The Permittee shall minimize the engine's time spent at idle during 

startup and minimize the engine's startup time to a period needed for 

appropriate and safe loading of the engine, not to exceed 30 minutes, 

after which time the emission standards applicable to all times other than 

startup in Table 2c to 40 CFR Part 63 subpart ZZZZ apply. 

c. The Permittee shall operate each ICE according to the requirements in 

following paragraphs IV.D.2.c.i and IV.D.2.c.ii of this section. If the 

engine is not operated according to the requirements in paragraphs 

IV.D.2.c.i and IV.D.2.c.ii of this Condition, the engine will not be 

considered an emergency engine and shall meet all requirements for nonemergency engines. [40 CFR 63.6640 (f)]

i. The Permittee may operate the emergency engines for the 

purpose of maintenance checks and readiness testing, provided 

that the tests are recommended by Federal, State, or local 

government, the manufacturer, the vendor, or the insurance 

company associated with the engine. Maintenance checks and 

readiness testing of the engine is limited to no more than 100 

hours per year. The Permittee may petition the Administrator 

and the Director for approval of additional hours to be used for 

maintenance checks and readiness testing, but a petition is not 

required if the Permittee maintains records indicating that the 

Federal, State, or local standards require maintenance and testing 

beyond 100 hours per year. Copies of records shall be made 
 

TV Permit Renewal Number 52639 Page 56 of 79 December 06, 2011 

SRP – Coronado Generating Station 

available to ADEQ upon request. 

ii. The Permittee may operate the emergency engines for up to 50 

hours per year in non-emergency situations, but those 50 hours 

are counted towards the 100 hours per year provided for 

maintenance and testing. The 50 hours per year for nonemergency situations cannot be used for peak shaving or to 

generate income for a facility to supply power to an electric grid 

or otherwise supply power as part of a financial arrangement 

with another entity; except that the Permittee may operate the 

emergency engine for a maximum of 15 hours per year as part of 

a demand response program if the regional transmission 

organization or equivalent balancing authority and transmission 

operator has determined there are emergency conditions that 

could lead to a potential electrical blackout, such as unusually 

low frequency, equipment overload, capacity or energy 

deficiency, or unacceptable voltage level. The engine may not be 

operated for more than 30 minutes prior to the time when the 

emergency condition is expected to occur, and the engine 

operation must be terminated immediately after the facility is 

notified that the emergency condition is no longer imminent. The 

15 hours per year of demand response operation are counted as 

part of the 50 hours of operation per year provided for nonemergency situations. The supply of emergency power to 

another entity or entities pursuant to financial arrangement is not 

limited by this paragraph, as long as the power provided by the 

financial arrangement is limited to emergency power. 

e. The Permittee shall install a non-resettable hour meter on the emergency 

fire pump engine. [40 CFR 63.6625(f), R18-2-331.A.3.a] 

 [Material Permit Conditions are indicated by underline and italics] 

f. The Permittee shall change oil and filter every 500 hours of operation or 

annually, whichever comes first. If the Permittee prefers to extend the 

oil change requirement, an oil analysis program as described in 40 CFR 

63.6625(i) shall be completed. [40 CFR 63.6603(a); Table 2d of Subpart ZZZZ; 63.6625(i)] 

g. The Permittee shall inspect air cleaner every 1,000 hours of operation or 

annually, whichever comes first; 

 [40 CFR 63.6603(a); Table 2d of Subpart ZZZZ]

h. The Permittee shall inspect all hoses and belts every 500 hours of 

operation or annually, whichever comes first, and replace as necessary. [40 CFR 63.6603(a); Table 2d of Subpart ZZZZ] 

i. The Permittee shall operate and maintain the emergency fire pump 

engine according to the manufacturer's emission-related written 

instructions or develop a maintenance plan which must provide to the 

extent practicable for the maintenance and operation of the engine in a 

manner consistent with good air pollution control practice for 
 

TV Permit Renewal Number 52639 Page 57 of 79 December 06, 2011 

SRP – Coronado Generating Station 

minimizing emissions. [40 CFR 63.6625(e)]. 

3. Recordkeeping Requirements 

a. The Permittee shall keep records of the hours of operation of each 

emergency engine that is recorded through the non-resettable hour meter. 

Records shall include the date, start and stop times, hours spent for 

emergency operation, including what classified the operation as 

emergency and how many hours are spent for non-emergency operation. [40 CFR 63.6655(f)] 

 

b. If the Permittee elects to implement the oil analysis program described in 

40 CFR 63.6625(i), the Permittee shall keep records of the parameters 

that are analyzed and the results of the oil analysis and the oil changes 

for the engine. [40 CFR 63.6625(i)] 

c. The Permittee shall keep records of the maintenance conducted on the 

emergency fire pump that demonstrates operation and maintenance in 

accordance with the maintenance plan. [40 CFR 63.6655(e)] 

d. The Permittee shall document the hours spent for emergency operation, 

including what classified the operation as emergency and how many 

hours are spent for non-emergency operation. If the engines are used for 

demand response operation, the Permittee shall keep records of the 

notification of the emergency situation, and the time the engine was 

operated as part of demand response. [40 CFR 63.6655(f)] 

4. Permit Shield 

Compliance with the conditions of this Section shall be deemed compliance with 

40 CFR Part 63.6605(b); 63.6640(f); 63.6625(i) & (f); 63.6603(a), 63.6655(e) & 

(f), Table 2d of 40 CFR subpart ZZZZ, 63.6655. [A.A.C. R18-2-325]

V. COAL HANDLING 

A. Applicability 

This section applies to the Coal Handling and the Coal Mixing systems as described in 

Attachment “C” of this permit. 

B. Opacity 

1. Emission Limitations/Standards 

The Permittee shall not cause to be discharged into the atmosphere from any coal 

processing and conveying equipment including breakers and crushers, coal 

storage systems, and coal transfer and loading systems, any emissions greater 

than 20 percent opacity. [A.A.C. R18-2-702.B.3] 
 

TV Permit Renewal Number 52639 Page 58 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2. Monitoring, Recordkeeping & Reporting [A.A.C. R18-2-306.A.3.c] 

Permittee shall conduct opacity monitoring in accordance with Condition I.E of 

this Attachment. This weekly survey shall include observation of all exposed 

transfer points, enclosed transfer points, the coal storage pile, and baghouses. 

3. Permit Shield 

Compliance with this section shall be deemed compliance with 702.B. 

[A.A.C. R18-2-325]

C. Particulate Matter 

1. Emission Limitations/Standards 

a. Permittee shall not cause, allow or permit the discharge of particulate 

matter into the atmosphere in any one hour from any coal handling 

operation in total quantities in excess of the amounts calculated by the 

following equation: 

 

E = 55.0 P 0.11 - 40 

 Where: 

 E = the maximum allowable particulate emissions rate in poundsmass per hour. 

 P = the process weight rate in tons-mass per hour. The total process 

weight from all similar units employing a similar type process shall be 

used in determining the maximum allowable emission of particulate 

matter. [A.A.C. R18-2-716.B.2]

b. The total process weight rate from all similar units employing a similar 

type process shall be used in determining the maximum allowable 

emission of particulate matter. [A.A.C. R18-2-716.B.2]

2. Air Pollution Controls 

When the coal handling and mixing system is operational, Permittee shall

maintain and operate the appropriate baghouses used to capture particulate 

matter emissions associated with coal handling in accordance with 

manufacturer’s specification and in a manner consistent with good air pollution 

control practices. Wet dust suppression shall be maintained and operated at the 

rotary car dumper during train unloading, at conveyor transfer points in the yard 

area, and at the stacking-reclaiming area. [A.A.C. R18-2-306.A.2 and 331.A.3.e]

 [Material Permit Conditions are defined by underline and italics] 

3. Monitoring, Recordkeeping & Reporting 

a. The manufacturer’s specifications shall be on file and shall be readily 
 

TV Permit Renewal Number 52639 Page 59 of 79 December 06, 2011 

SRP – Coronado Generating Station 

available for inspection by the Department. [A.A.C. R18-2-306.A.2]

b. Permittee shall maintain records of emissions related maintenance 

performed on the baghouses. [A.A.C. R18-2-306.A.3.c]

4. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C R18-2-

716.E, A.A.C. R18-2-716.B, and A.A.C. R18-2-716.D. [A.A.C. R18-2-325] 

VI. LIMESTONE HANDLING 

A. Applicability 

This Section applies to the Upgraded Belt Conveyors (BC-101, BC101A), New Belt 

Conveyors (BC-101B and B), Upgraded Transfer Tower (TT-1), New Transfer Tower 

(TT-2), New Limestone Storage Bins A, B, & C, Wet Dust Extractors (DC-12 and DC13), and Bin Vent Dust Collectors (DC-14, DC-15, and DC-16) in the Limestone 

Handling Plant. 

B. Particulate Matter and Opacity 

1. Emission Limitations/Standards 

a. Particulate Matter 

i. The Permittee shall not cause to be discharged into the 

atmosphere from any transfer point on belt conveyors or from 

any other affected facility any stack emissions (DC-12 and DC13) that contain PM in excess of 0.032 grams per dry standard 

cubic meter (0.014 gr/dscf). Bin vent filters (DC-14, DC-15, and 

DC-16) are exempt from this PM stack limit since these 

individually control emissions from the associated storage bin. [40 CFR 60.672(a) & 60.672 (f)]

ii. The Permittee shall not cause to be discharged into the 

atmosphere from DC-12, DC-13, DC-14, DC-15, and DC-16 any 

stack emissions that contain filterable PM/PM10 in excess of 

0.005 grains per actual cubic feet. [A.A.C. R18-2-406.A.4] 

b. Opacity 

 

i. The Permittee shall not cause to be discharged into the 

atmosphere from any storage bin any stack emissions that 

exhibit opacity greater than 7 percent opacity.

[40 CFR 60.672(a) and A.A.C. R18-2-331.A.3.f] 

[Material Permit Conditions is defined by underline and italics] 

ii. On and after the sixtieth day after achieving the maximum 

production rate at which the affected facility will be operated, 

but not later than 180 days after initial startup as required under 

40 CFR §60.11, the Permittee shall not cause to be discharged 
 

TV Permit Renewal Number 52639 Page 60 of 79 December 06, 2011 

SRP – Coronado Generating Station 

into the atmosphere from any transfer point on belt conveyors or 

from any other affected facility any fugitive emissions which 

exhibit opacity greater than 7 percent. [40 CFR 60.672(b) and A.A.C. R 18-2-331.A.3.f] 

[Material Permit Conditions is defined by underline and italics] 

2. Air Pollution Control Equipment 

At all times, including periods of startup, shutdown, and malfunction, the 

Permittee shall, to the extent practicable, install, maintain, and operate Wet Dust 

Extractors {DC-12 on Transfer Tower (TT-1), DC-13 on Transfer Tower (TT-2)}, 

and Bin Vent Filters (DC-14,DC-15, and DC-16 on Limestone Storage Bins A, B, 

& C) in a manner consistent with good air pollution control practice for 

minimizing PM emissions. [40 CFR 60.11(d), A.A.C. R 18-2-306.01.A and -331.A.3.d & e] 

[Material Permit Conditions are defined by underline and italics] 

3. Monitoring Requirements 

 

a. The Permittee shall install, calibrate, maintain, and operate the following 

monitoring devices on the wet dust extractors (DC-12 and DC-13):

i. A device for the continuous measurement of the pressure loss of 

the gas stream through the scrubber. The monitoring device 

must be certified by the manufacturer to be accurate within ±250 

pascals ±1 inch water gauge pressure and must be calibrated on 

an annual basis in accordance with manufacturer's instructions.

ii. A device for the continuous measurement of the scrubbing liquid 

flow rate to the wet scrubber. The monitoring device must be 

certified by the manufacturer to be accurate within ±5 percent of 

design scrubbing liquid flow rate and must be calibrated on an 

annual basis in accordance with manufacturer's instructions [A.A.C. R 18-2-331.A.3.c and 40 CFR 60.674(a)] 

 [Material Permit Conditions are defined by underline and italics] 

b. The Permittee shall 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). The Method 

22 (40 CFR part 60, Appendix A-7) test shall be conducted while the 

baghouse is operating. The test is successful if no visible emissions are 

observed. If any visible emissions are observed, the owner or operator of 

the affected facility must initiate corrective action within 24 hours to 

return the baghouse to normal operation. The owner or operator must 

record each Method 22 (40 CFR part 60, Appendix A-7) test, including 

the date and any corrective actions taken, in the logbook required under 

Condition VI.B.4.a. [40 CFR 60.674(c)] 

4. Recordkeeping and Reporting Requirements 

a. The Permittee shall record each periodic inspection required under 

Condition VI.B.3.b, including dates and any corrective actions taken, in a 
 

TV Permit Renewal Number 52639 Page 61 of 79 December 06, 2011 

SRP – Coronado Generating Station 

logbook (in written or electronic format). The Permittee shall keep the 

logbook onsite and make hard or electronic copies available to the 

Administrator upon request. [40 CFR 60.676(b)] 

b. During the initial performance test of the wet dust extractors (DC-12 and 

DC-13), and daily thereafter, the owner or operator shall record the 

measurements of both the change in pressure of the gas stream across the 

scrubber and the scrubbing liquid flow rate. [40 CFR 60.676(c)] 

c. After the initial performance test of the wet dust extractors (DC-12 and 

DC-13), the owner or operator shall submit semiannual reports to the 

Administrator of occurrences when the measurements of the scrubber 

pressure loss and liquid flow rate decrease by more than 30 percent from 

the average determined during the most recent performance test. [40 CFR 60.676(d)] 

d. The reports required under Condition VI.B.4.c shall be postmarked 

within thirty days following end of second and fourth calendar quarters. 

 [40 CFR 60.676(e)] 

e. The Permittee shall submit written reports of the results of all 

performance tests conducted to demonstrate compliance with the 

emission limit in Condition VI.B.1.a.i, including reports of opacity 

observations made using Method 9 to demonstrate compliance with 

Condition VI.B.1.b.i. [40 CFR 60.676(f)] 

5. Notification Requirements 

 [40 CFR 60.676(h), 40 CFR 60.7.a (3)] 

The Permittee shall furnish to the Director and the EPA written notification or, if 

acceptable, electronic notification of the actual date of initial startup of an 

affected facility postmarked within 15 days after such date. 

6. Testing Requirements 

a. 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 shall conduct an initial performance 

test for PM & PM10 for wet dust extractors (DC-12 and DC-13). The 

performance test shall be used to demonstrate compliance with the limits 

in Condition VI.B.1.a..i and ii. [40 CFR 60.8(A), A.A.C. R18-2-312] 

b. 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 shall conduct an initial 

performance test for opacity for bin vent filters (DC-14, DC-15 and DC16). The performance test shall be used to demonstrate compliance with 

the opacity limit in Condition VI.B.1.b.i. [40 CFR 60.672(f), 60.675.(C)(2)] 
 

TV Permit Renewal Number 52639 Page 62 of 79 December 06, 2011 

SRP – Coronado Generating Station 

VII. FLY ASH HANDLING 

A. Applicability 

This section applies to the Fly Ash Handling Facility as described in Attachment “C” of 

this permit. 

B. Opacity 

1. Emission Limitations/Standards 

The Permittee shall not cause to be discharged into the atmosphere from the Fly 

Ash Handling System any emissions greater than 20 percent opacity. 

[A.A.C. R18-2-702.B.3] 

2. Monitoring, Recordkeeping & Reporting 

The Permittee shall conduct opacity monitoring in accordance with Condition I.E 

of this Attachment. This weekly observation shall include observation of all 

exposed transfer points, enclosed transfer points, the baghouses, and the mixer 

unloader. [A.A.C. R18-2-306.A.3.b] 

3. Permit Shield

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

702.B. [A.A.C. R18-2-325]

C. Particulate Matter 

1. Permittee shall not cause, allow or permit the discharge of particulate matter into 

the atmosphere in any one hour from any fly ash handling operation in total 

quantities in excess of the amounts calculated by the following equation: 

 

 E = 55.0 P 0.11 - 40 

Where: 

E = the maximum allowable particulate emissions rate in pounds-mass per 

hour. 

P = the process weight rate in tons-mass per hour. The total process weight 

from all similar units employing a similar type process shall be used in 

determining the maximum allowable emission of particulate matter. [A.A.C. R18-2-730.A.1.b] 

2. Air Pollution Controls 

When the fly ash handling system is operational, Permittee shall maintain and 

operate the associated Flex-Kleen baghouses, the Scientific baghouse, water 

spray header, pugmill and the mixer unloader used to minimize particulate 

matter emissions associated with fly ash handling in accordance with 

manufacturer’s specification and in a manner consistent with good air pollution 
 

TV Permit Renewal Number 52639 Page 63 of 79 December 06, 2011 

SRP – Coronado Generating Station 

control practices. [A.A.C. R18-2-306.A.2 and 331] 

 [Material Permit Conditions are defined by underline and italics] 

3. Monitoring, Recordkeeping & Reporting 

a. The manufacturer’s specifications shall be on file and shall be readily 

available for inspection by the Department. [A.A.C. R18-2-306.A.2] 

 

b. Permittee shall maintain records of emissions related maintenance 

performed on the baghouses and mixer unloader. 

 [A.A.C. R18-2-306.A.3.c] 

4. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

730.A.1.b. [A.A.C. R18-2-325] 

D. Odorous Materials 

1. Permittee shall not emit gaseous or odorous materials from equipment, 

operations or premises in such quantities or concentrations as to cause air 

pollution. [A.A.C. R18-2-730.D] 

2. Where a stack, vent or other outlet is at such a level that fumes, gas mist, odor, 

smoke, vapor or any combination thereof constituting air pollution is discharged 

to adjoining property, the Director may require the installation of abatement 

equipment or the alteration of such stack, vent, or other outlet by the Permittee 

thereof to a degree that will adequately dilute, reduce or eliminate the discharge 

of air pollution to adjoining property. [A.A.C. R18-2-730.G] 

3. Permit Shield 

Compliance with this section shall be deemed compliance with A.A.C. R18-

730.D, and A.A.C. R18-2-730.G. [A.A.C. R18-2-325] 

VIII. COOLING TOWERS 1 AND 2 

A. Applicability 

This Section applies to Cooling Towers 1 and 2 as described in Attachment “C” of this 

permit. 

B. Opacity

1. Emissions Standards/ Limitations 

The Permittee shall not cause to be discharged into the atmosphere from the 
 

TV Permit Renewal Number 52639 Page 64 of 79 December 06, 2011 

SRP – Coronado Generating Station 

cooling towers any emissions greater than 20 percent opacity. 

[A.A.C. R18-2-702.B.3] 

2. Monitoring, Recordkeeping & Reporting 

The Permittee shall conduct opacity monitoring for the cooling towers in 

accordance with Condition I.B of this Attachment. 

 [A.A.C. R18-2-306.A.3.b] 

3. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

702.B. [A.A.C. R18-2-325] 

C. Particulate Matter 

1. Permittee shall not discharge particulate matter into the atmosphere in any one 

hour from the cooling towers in total quantities in excess of the amounts 

calculated by the following equation: [A.A.C. R18-2-730.A.1] 

E = 55.0 P 0.11 - 40 

Where: 

E = the maximum allowable particulate emissions rate in pounds-mass per 

hour. 

P = the process weight rate in tons-mass per hour. The total process weight 

from all similar units employing a similar type process shall be used in 

determining the maximum allowable emission of particulate matter. 

2. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-

730.A.1. [A.A.C. R18-2-325] 

D. Odorous Materials 

1. Permittee shall not emit gaseous or odorous materials from equipment, 

operations or premises in such quantities or concentrations as to cause air 

pollution. [A.A.C. R18-2-730.D] 

2. Where a stack, vent or other outlet is at such a level that fumes, gas mist, odor, 

smoke, vapor or any combination thereof constituting air pollution is discharged 

to adjoining property, the Director may require the installation of abatement 

equipment or the alteration of such stack, vent, or other outlet by the Permittee 

thereof to a degree that will adequately dilute, reduce or eliminate the discharge 

of air pollution to adjoining property. [A.A.C. R18-2-730.G] 

3. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-
 

TV Permit Renewal Number 52639 Page 65 of 79 December 06, 2011 

SRP – Coronado Generating Station 

730.D, A.A.C. and R18-2-730.G. [A.A.C. R18-2-325] 

IX. USED OIL SPECIFICATIONS 

A. Emission Limitations/Standards 

1. Permittee may burn used oil or used oil fuel if the following conditions are met: 

 

a. The flash point of the oil does not fall below 100o F; 

b. The oil does not have following contaminants in excess of the following 

levels: 

(1) Arsenic 5 ppm 

(2) Cadmium 2 ppm 

(3) Chromium 10 ppm 

(4) Lead 100 ppm 

(5) PCBs 2 ppm 

(6) Total Halogens 1000 ppm [A.R.S. 49-426.G.1] 

c. Used oil or used oil fuel blended with virgin fuel oil does not exceed 5% 

of the total fuel in any fuel storage tank. 

 [Operating Permit #30732, Attachment B, Condition IX.A.1.c] 

2. Limitations 

a. Permittee shall not burn Hazardous Waste or Hazardous Waste Fuel as 

defined by A.R.S. 49-921 at the Coronado Generating Facility. [Operating Permit #30732, Attachment B, Condition IX.A.2.a] 

b. The amount of used oil consumed shall not exceed 350 barrels annually. [Operating Permit #30732, Attachment B, Condition IX.A.2.b] 

B. Monitoring/Recordkeeping/Reporting

1. All tests conducted pursuant to Condition IX.C of this Attachment shall be 

documented and a report submitted to the Department along with the semi-annual 

compliance certification. 

2. Permittee shall maintain such records as required to document the use of the 

above fuel including the following: 

a. Dates on which used oil or used oil fuel was burned; 

b. Hours of usage of the used oil or used oil fuel; and 

c. The quantity of used oil or used oil fuel burned. 

d. Amount of used oil burned in each boiler. 

C. Testing Requirements [A.R.S. 49-426.G.2] 

1. All used oil or used oil fuel samples shall be tested prior to burning for 

chlorinated solvents by EPA Method 9077. 
 

TV Permit Renewal Number 52639 Page 66 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2. A representative sample from each source of used oil or used oil fuel shall be 

tested annually for Arsenic, Cadmium, Chromium, and Lead using approved 

EPA methods prior to burning. 

D. Permit Shield 

Compliance with this Section shall be deemed compliance with A.R.S. 49-426.G.1, 

Permit #30732, Attachment B, Condition IX.A.1.c, Condition IX.A.2.a, and Condition 

IX.A.2.b. 

 [A.A.C. R18-2-325] 

X. FUGITIVE EMISSIONS 

A. Emission Limitations/Standards 

1. Open Areas, Roadways & Streets, Storage Piles, and Material Handling 

a. Permittee shall not cause, allow or permit visible emissions from open 

areas, roadways and streets, storage piles or material handling in excess 

of 40 percent opacity measured in accordance with the Arizona Testing 

Manual, Reference Method 9. [A.A.C. R18-2-612] 

b. Permittee shall employ one or more of the following reasonable 

precautions to prevent excessive amounts of particulate matter from 

becoming airborne: 

i. Use approved dust suppressants, adhesive soil stabilizer, paving, 

covering, detouring, or wetting agents on, or bar access to open

areas during construction operations, repair operations, 

demolition activities, clearing operations, and leveling 

operations, or when any earth is moved or excavated; 

[A.A.C. R18-2-604.A] 

ii. Use approved dust suppressants, adhesive soil stabilizer, or 

paving on, or bar access to driveways, parking areas, and vacant 

lots where motor vehicular activity occurs; 

 [A.A.C. R18-2-604.A and B] 

iii. Use approved dust suppressants, temporary paving, detouring or 

wetting agents when a roadway is repaired, constructed, or 

reconstructed; [A.A.C. R18-2-605.A] 

(4) Use dust suppressants, wetting agents, or cover the load 

adequately when transporting material likely to give rise to 

airborne dust; [A.A.C. R18-2-605.B] 

iv. Use spray bars, hoods, wetting agents, dust suppressants, or 

cover when crushing, screening, handling, transporting, or 

conveying material that is likely to give rise to airborne dust; 

 [A.A.C. R18-2-606] 
 

TV Permit Renewal Number 52639 Page 67 of 79 December 06, 2011 

SRP – Coronado Generating Station 

v. Adequately cover, or use wetting agents, chemical stabilization, 

or dust suppressants when stacking, piling, or otherwise storing 

organic or inorganic dust producing material; 

 [A.A.C. R18-2-607.A] 

vi. Operate stacking and reclaiming machinery utilized at storage 

piles at all times with a minimum fall of material and with the 

use of spray bars and wetting agents; 

 [A.A.C. R18-2-607.B] 

vii. Use wetting agents or dust suppressants before the cleaning of 

site, roadway, or alley. Earth or other material shall be removed 

from paved streets onto which earth or other material has been 

transported by trucking or earth moving equipment, erosion by 

water or by other means; or 

 [A.A.C. R18-2-804.B] 

viii. Any other method as proposed by the Permittee and approved by 

the Director. [A.A.C. R18-2-325] 

B. Monitoring, Recordkeeping & Reporting 

1. Open Areas, Roadways & Streets, Storage Piles, and Material Handling 

a. Bi-Weekly Monitoring Requirements 

A certified EPA Reference Method 9 observer shall conduct a bi-weekly 

(once every two weeks) survey of visible emissions. If the opacity of the 

emissions observed appears to exceed the relevant opacity standard, the 

observer shall conduct a certified EPA Reference Method 9 opacity 

reading. The Permittee shall keep records of the initial survey and any 

EPA Reference Method 9 opacity readings performed. These records 

shall include the emission point observed, location of observer, name of 

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

If the Method 9 opacity reading shows in excess of the relevant opacity 

standard, the Permittee shall initiate appropriate corrective action to 

reduce the opacity below the standard. The Permittee shall keep a record 

of the corrective action performed. 

b. Permittee shall maintain records of the dates on which any of the 

activities listed in condition X.A.1.b.i through ix of this Attachment were 

performed and control measures employed. [A.A.C. R18-2-306.A.3.b] 

2. Open Burning 

The Permittee shall maintain copies of all open burning permits on file. 

C. Permit Shield 

Compliance with the conditions of this part shall be deemed compliance with 
 

TV Permit Renewal Number 52639 Page 68 of 79 December 06, 2011 

SRP – Coronado Generating Station 

A.A.C.R18-2-602, -604.A,-604.B, -605.A, -605B, -606, -607.A, -607.B, -612, and 

A.A.C.R18-2-804.B. [A.A.C. R18-2-325] 

XI. OTHER PERIODIC ACTIVITIES 

A. Emission Limitations/Standards 

1. Abrasive Blasting 

a. The Permittee shall not cause or allow sandblasting or other abrasive 

blasting without minimizing dust emissions to the atmosphere through 

the use of good modern practices. Good modern practices include: 

(1) Wet blasting; 

(2) Effective enclosures with necessary dust collecting equipment; 

or 

(3) Any other method as approved by the Director. [A.A.C. R18-2-726] 

b. The Permittee shall not cause to be discharged into the atmosphere from 

sandblasting or other abrasive blasting operations any emissions greater 

than 20 percent opacity. 

 [A.A.C. R18-2-702.B.3]

2. Use of Paints 

While performing spray painting operations the Permittee shall comply with the 

following requirements: 

a. The Permittee shall not conduct any spray painting operation without 

minimizing organic solvent emissions. Such operations other than 

architectural coating and spot painting shall be conducted in an enclosed 

area equipped with controls containing no less than 96 percent of the 

overspray. [A.A.C. R18-2-727.A] 

b. The Permittee shall not either: 

(1) Employ, apply, evaporate or dry any architectural coating 

containing photochemically reactive solvents for industrial or 

commercial purposes; or 

(2) Thin or dilute any architectural coating with a photochemically 

reactive solvent. [A.A.C. R18-2-727.B] 

 

c. For the purposes of part b. and e. of this condition, a photochemically 

reactive solvent shall be any solvent with an aggregate of more than 20 

percent of its total volume composed of the chemical compounds 

classified in paragraphs (1) through (3) of this subsection, or which 

exceeds any of the following percentage composition limitations, 

referred to the total volume of solvent: 

(1) A combination of the following types of compounds having an 
 

TV Permit Renewal Number 52639 Page 69 of 79 December 06, 2011 

SRP – Coronado Generating Station 

olefinic or cyclo-olefinic type of unsaturation - hydrocarbons, 

alcohols, aldehydes, esters, ethers, or ketones: five percent 

(2) A combination of aromatic compounds with eight or more 

carbon atoms to the molecule except ethylbenzene: eight percent 

(3) A combination of ethylbenzene, ketones having branched 

hydrocarbon structures, trichloroethylene or toluene: twenty 

percent. [A.A.C. R18-2-727.C] 

d. Whenever any organic solvent or any constituent of an organic solvent 

may be classified from it’s chemical structure into more than one of the 

groups or organic compounds described in subsection c(1) through c(3) 

of this condition, it shall be considered to be a member of the group 

having the least allowable percent of the total volume of solvents. 

 [A.A.C. R18-2-727.D] 

3. Surface Coating Operation 

a. The Permittee shall not operate any surface coating application systems 

that emits volatile organic compounds in excess of the following: 

(1) 4.3 pounds per gallon (0.5 kilograms per liter) of coating, 

excluding water, delivered to a coating applicator that applies 

clear coatings. 

(2) 3.5 pounds per gallon (0.42 kilograms per liter) of coating, 

excluding water, delivered to a coating applicator in a coating 

application system that is air dried or forced warm air dried at 

temperatures up to 194 o

F (90 oC). 

(3) 3.5 pounds per gallon (0.42 kilograms per liter) of coating, 

excluding water, delivered to a coating applicator that applies 

extreme performance coatings. 

(4) 3.0 pounds per gallon (0.36 kilograms per liter) of coating, 

excluding water, delivered to a coating applicator for all other 

coatings and application systems. 

b. If more than one emission limitation in paragraph XI.A.3.a above applies 

to a specific coating, then the least stringent emissions limitation shall be 

applied. 

c. All VOC emissions from solvent washings shall be considered in the 

emissions limitations listed in paragraph XI.A.3.a above, unless the 

solvent is directed to containers that prevent evaporation to the 

atmosphere. [A.A.C R18-2-730.L] 

4. Vapor Extractors 

Materials including solvents or other volatile compounds shall be processed, 
 

TV Permit Renewal Number 52639 Page 70 of 79 December 06, 2011 

SRP – Coronado Generating Station 

stored, used and transported in such a manner and by such means that they will 

not evaporate, leak, escape or be otherwise discharged into the ambient air so as 

to cause or contribute to air pollution. Where means are available to reduce 

effectively the contribution to air pollution from evaporation, leakage or 

discharge, the installation and use of such control methods, devices, or equipment 

shall be mandatory. 

 [A.A.C. R18-2-730.F] 

5. Landfill Operations 

Permittee shall not emit gaseous or odorous materials from the landfill operations 

in such quantities or concentrations to cause air pollution. 

 [A.A.C. R18-2-730.D] 

6. Mobile Sources 

a. Classification 

The requirements of this condition are applicable to mobile sources 

which either move while emitting air contaminants or are frequently 

moved during the course of their utilization but are not classified as 

motor vehicles, agricultural vehicles, or are agricultural equipment used 

in normal farm operations. Mobile sources shall not include portable 

sources as defined in A.A.C. R18-2-101.84. [A.A.C. R18-2-801] 

 

b. Roadway and Site Cleaning Machinery 

Permittee shall not cause, allow or permit to be emitted into the 

atmosphere from any roadway and site cleaning machinery smoke or 

dust for any period greater than ten consecutive seconds, the opacity of 

which exceeds 40 percent. Visible emissions when starting cold 

equipment shall be exempt from this requirement for the first ten 

minutes. [A.A.C. R18-2-804.A] 

7. Demolition/Renovation 

Permittee shall comply with the applicable requirements of 40 CFR 61 Subpart 

M (National Emissions Standards for Hazardous Air Pollutants - Asbestos). 

 [A.A.C. R18-2-1101.A.8]

B. Monitoring, Recordkeeping, and Reporting [A.A.C. R18-2-306.A.3.c]

1. Abrasive Blasting 

Each time an abrasive blasting project is conducted, the Permittee shall maintain 

records of the following: 

a. The date the project was conducted; 

b. The duration of the project; and 

c. Type of control measures employed. 
 

TV Permit Renewal Number 52639 Page 71 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2. Use of Paints 

a. Each time a spray painting project is conducted, the Permittee shall log 

in ink or in an electronic format, a record of the following: 

 

(1) The date the project was conducted; 

(2) The duration of the project; 

(3) Type of control measures employed; and 

(4) Material Safety Data Sheets for all paints and solvents used in 

the project. 

b. Architectural coating and spot painting projects shall be exempt from the 

recordkeeping requirements of part a. above. 

3. Mobile Sources 

Permittee shall keep a record of all emissions related maintenance activities 

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

manufacturer’s specifications. 

4. Demolition/Renovation 

Permittee shall keep all required records in a file. The required records include 

the ANESHAP Notification for Renovation and Demolition Activities form and 

all supporting documents. 

5. Surface coating activities [A.A.C R18-2-306.A.3.c] 

a. The Permittee shall log in ink or keep in an electronic format a records of 

the following: 

(1) The date the project was conducted; 

(2) the duration of the project; 

(3) type of control measures employed 

(4) amount of surface coating used for the project 

(5) copies of the material safety and data sheets (MSDS) for each 

surface coating applied. 

b. Permittee shall use vendor provided information to ensure that the 

surface coating materials being used satisfy the standards in Section 

XI.A.3.a of Attachment B. In the absence of vendor provided 

information, Permittee shall perform engineering calculations using the 

density and VOC content of the surface coating in order to compare 

against the standards set forth in Section XI.A.3.a of Attachment B. 

C. Permit Shield 

Compliance with this Section shall be deemed compliance with A.A.C. R18-2-702.B.C, 

R18-2-702.B.3, R18-2-726, R18-2-727.A, R18-2-727.B, R18-2-727.C, R18-2-727.D, 

R18-2-730.D, R18-2-730.F, and R18-2-730.L, andR18-2-1101.A.8. 

[A.A.C. R18-2-325] 
 

TV Permit Renewal Number 52639 Page 72 of 79 December 06, 2011 

SRP – Coronado Generating Station 

XII. COAL ADDITIVE SODA ASH SILO 

A. Applicability 

This section applies to the Coal Additive Soda Ash Silo as described in Attachment “C” 

of this permit. 

B. Opacity 

1. Emission Limitation/Standards [A.A.C. R 18-2-702.B.3]

The Permittee shall not cause, allow or permit the opacity of any plume or 

effluent from the coal additive soda ash silo to exceed 20 percent. 

2. Monitoring/Recordkeeping/Recording [A.A.C. R 18-2-306.A.3.c] 

Permittee shall conduct weekly opacity monitoring of the baghouse associated 

with the coal additive soda ash silo in accordance with Condition I.B of this 

Attachment when the coal additive soda ash silo is operational. 

C. Particulate Matter 

1. Emission Limitation/Standards 

a. Permittee shall not cause, allow or permit the discharge of particulate 

matter into the atmosphere in any one hour from the coal additive soda 

ash silo in total quantities in excess of the amounts calculated by the 

following equation: 

E = 4.10 P0.67

Where: 

E = the maximum allowable particulate emissions rate in poundsmass per hour. 

P = the process weight rate in tons-mass per hour. 

[A.A.C. R18-2-730.A.1.a] 

b. The total process weight from all similar units employing a similar type 

process shall be used in determining the maximum allowable emission of 

particulate matter. 

[A.A.C. R18-2-730.B] 

2. Air Pollution Controls 

When the coal additive soda ash silo is operational, Permittee shall maintain and 

operate the baghouse used to capture particulate matter emissions associated 

with the coal additive soda ash silo in accordance with manufacturer’s 
 

TV Permit Renewal Number 52639 Page 73 of 79 December 06, 2011 

SRP – Coronado Generating Station 

specification and in a manner consistent with good air pollution control 

practices. [A.A.C. R18-2-306.A.2 and 331.A.3.e]

 [Material Permit Conditions are defined by underline and italics] 

3. Monitoring/Recordkeeping/Reporting 

a. The manufacturer’s specifications shall be on file and shall be readily 

available for inspection by the Department. 

 [A.A.C. R18-2-306.A.2] 

b. Permittee shall maintain records of emissions related maintenance 

performed on the coal additive soda ash silo baghouse. [A.A.C. R18-2-306.A.3.c] 
 

TV Permit Renewal Number 52639 Page 74 of 79 December 06, 2011 

SRP – Coronado Generating Station 

ATTACHMENT “C”: EQUIPMENT LIST 

Air Quality Control Permit No. 52639 

for 

Salt River Project -Coronado Generating Station 

EQUIPMENT TYPE MAX. 

CAPACITY

QUANTITY MODEL SERIAL # / 

EQUIPMENT #

INSTALLED

/MFG DATE

Steam Generation

Unit 1 Boiler 4719 MMBtu/hr 1 Riley Stoker 

Corporation 

3901 7/25/1974 

Unit 2 Boiler 4719 MMBtu/hr 1 Riley Stoker 

Corporation 

3902 7/25/1974 

Auxiliary Boiler 157 

MMBtu/hr 

1 Combustion 

Engineering 

CFAABOIL 7/25/1974 

Coal Pulverizers 145,000 lb/hr 6 Riley Stoker 

Corporation 

1BAFMILLA,B,C 

2BAFMILLA,B,C 

7/25/1974 

Pulverizer Feeder 

Unit 1 

145,000 lb/hr 6 Riley Stoker 

Corporation 

1BAFFDR1A1,1A2,

1B1,1B2,1C1,1C2

7/25/1974 

Pulverizer Feeder 

Unit 2 

145,000 lb/hr 6 Riley Stoker 

Corporation 

2BAFFDR2A1,2A2,

2B1,2B2,2C1,2C2

7/25/1974 

Cooling Tower 1 179900 gpm 1 Marley Company 

664-4-14 

1DABSTRU 7/25/1974 

Cooling Tower 2 179900 gpm 1 Marley Company 

664-4-14 

2DABSTRU 7/25/1974 

Hot Side 

Electrostatic 

Precipitators 

2,800,000 acfm 4 Joy-Western 1JPAPREC0002, 

1JPAPREC0005, 

2JPAPREC0080, 

2JPAPREC0082 

7/25/1974 

Sulfur Dioxide 

Scrubbers 

378,000 scfm 4 Pullman Kellog 1JSAMODUA, 

1JSAMODUB 

7/25/1974 

Sulfur Dioxide 

Absorbers 

2,028,184 acfm 

Design flow/unit 

2 Alstom 1WRAABS 

2WRAABS 

TBD 

5/20/2011 

Low-NOx Burners 4719 MMBtu/hr 

(total/boiler) 

24/boiler Babcock Power 1BAEBURNNFR 

2BAEBURNNFR 

5/19/2009 

5/20/2011 

Selective Catalytic 

Reduction System 

TBD 1 TBD TBD TBD 

Calcium Bromide 

Injection System 

TBD 2 Alstom TBD TBD 

Coal Handling System

Rotary Car Dumper 100,000 lbs 1 Heyl & Patterson CJKADUMPRCD 7/24/1974 

Track Hopper 500 tons 1 Heyl & Patterson CJKAHOPP 7/24/1974 

Coal Crusher 1200 tph 2 Pennsylvania Crusher CJKACRUSACL, 

CJKACRUSBCL, 

7/24/1974 

Track Hopper Feeder 750 tph 4 FMC CJKAFDRV1,2, 3, 4 7/24/1974 
 

TV Permit Renewal Number 52639 Page 75 of 79 December 06, 2011 

SRP – Coronado Generating Station 

Belt Conveyor BC-2A 3000 tph 1 FMC CJKCONVB2A 7/24/1974 

Belt Conveyor BC-4 3000 tph 1 FMC CJKCONVBC4 7/24/1974 

Belt Conveyor BC-5 1200 tph 1 FMC CJKCONVBC5 7/24/1974 

Belt Conveyor BC-6 1200 tph 1 FMC CJKCONVBC6 7/24/1974 

Belt Conveyor BC-7A & 

BC-7B 

1200 tph 2 FMC CJKCONVB7A, 7B 7/24/1974 

Belt Conveyor BC-8A & 

BC-8B 

1200 tph 2 FMC 2JKCONVB8A, 8B 7/24/1974 

Belt Conveyor BC-9A, 

BC-9B, BC-10A, & BC-10B 

1200 tph 4 FMC 1JKCONVB9A, 9B 

2JKCONV10A, 10B

7/24/1974 

Emergency Hopper 280 tons 1 FMC CJKAHOPPRCL 7/24/1974 

Emergency Hopper Feeder 1000 tph 2 FMC CJKAFDRAER 

CJKAFDRBER

7/24/1974 

Crusher Surge Bin 345 tons 1 FMC CJKABINBNC 7/24/1974 

Surge Bin Feeder 1200 tph 2 FMC CJKAFDRASB 

CJKAFDRBSB

7/24/1974 

Coal Sampling System N/A 1 FMC HP-76-134 7/24/1974 

Sampling Building Dust 

Collector 

7200 cfm 1 FMC 

Coal Silos 825 tons 6 FMC 1JKASILO1A, 1B, 

1C 2JKASILO2A, 

2B, 2C

7/24/1974 

Dust Extractor 2 17,000 CFM 1 Engart CJKABACDC2 1/12/2008 

Dust Extractor 3 22,000 CFM 1 Engart 1JKACOLLDC3 2/15/2009 

Dust Extractor 4 22,000 CFM 1 Engart 2JKACOLLDC4 4/17/2007 

Dust Extractor 5 6,000 CFM 6 Engart 1JKACOLLDC5 2/5/2009 

Coal Mixing System

Belt Conveyor BC-3A 3000 tph 1 Continental Conveyor 

and Equip. 

CJKACONVB3A 7/24/1974 

Belt Conveyor BC-3B 1200 tph 1 Continental Conveyor 

and Equip 

CJKAFCONVB3B 7/24/1974 

Belt Conveyor BC-3C 1200 tph 1 Continental Conveyor 

and Equip 

CJKAFCONVB3C 7/24/1974 

Belt Feeder CM1 1200 tph 1 N/A CJKACONVCM1 7/24/1974 

Transfer Hopper CM1 40 tons 1 N/A CJKAHOPPXFR 7/24/1974 

Coal Storage Piles 1200 tph 2 

Rotary Plow Feeders 600 tph 3 Continental Conveyor 

and Equip 

CJKAFDRCMI, M2, 

M3, M4

7/24/1974 

Coal Crusher 1200 tph 1 
 

TV Permit Renewal Number 52639 Page 76 of 79 December 06, 2011 

SRP – Coronado Generating Station 

Traveling Boom Stacker 3000 tph 1 Stephens-Adamson CJKASTACCL 7/24/1974 

Fly Ash Handling System

Fly Ash Storage Silos 62,800 ft3 2 Allen-Sherman-Hoff 1JNASILOFAS 

2JNASILOFAS

7/24/1974 

Fly Ash Storage Silos Dust 

Collectors 

2375 CFM 10 Flex-Kleen 1JNAFLTRAEBA, 

B,...E 

2JNAFLTRAEBA, 

B,...E 

7/24/1974 

Fly Ash Receiving Silos 

Dust Collectors 

15,000 CFM 1 Scientific CJNAMRTDC1 2002 

Limestone Handling System

Limestone Truck Unloading 

Hopper 

30 tons 1 McNally Pittsburgh CJSAHOPPTUL 7/24/1974 

Limestone Truck Unloading 

Hopper Feeder 

200 tph 1 Marathon Electric 

Mfg. 

C-M-JS-R-5910 6/23/2009 

Limestone Belt Conveyor 

BC-101 

200 tph 1 Varo C-M-JS-R-5911 6/23/2009 

Limestone Belt Conveyor 

BC-101A 

200 tph 1 Varo C-M-JS-R-5914 6/23/2009 

Limestone Belt Conveyor 

BC-101B 

200 tph 1 Varo TBD TBD 

Limestone Belt Conveyor B 200 tph 1 TBD TBD TBD 

Limestone Ball Mill 18 tph 1 TBD TBD TBD 

Limestone Transfer Tower 

TT-1 Wet Dust Collector, 

DC-12 

17,000 cfm 1 Engart/Benetech 211021 6/23/2009 

Limestone Transfer Tower, 

TT-2 Wet Dust Collector, 

DC-13 

13,000 cfm 1 Engart/Benetech 211022 6/23/2009 

Limestone Storage 

Bin A 

73 tons 1 - C-M-JS-R-5917 6/23/2009 

Limestone Storage 

Bin B 

73 tons 1 - C-M-JS-R-5921 6/23/2009 

Limestone Storage Bin C 250 tons 1 - - - 

Limestone Storage Bin Vent 

Filter, DC-14 

600 scfm 1 Met-Pro Flex Kleen 

Division 

11918 6/23/2009 

Limestone Storage Bin Vent 

Filter, DC-15 

600 scfm 1 Met-Pro Flex Kleen 

Division 

11918 6/23/2009 

New Limestone Storage Silo 

Bin Vent Filter, DC-16 

1,000 

ACFM 

1 TBD TBD TBD 

Soda Ash Handling System 
 

TV Permit Renewal Number 52639 Page 77 of 79 December 06, 2011 

SRP – Coronado Generating Station 

Coal Additive Soda Ash Silo 3,000 cubic 

feet 

1 CHEMCO Systems, 

L.P. 

SILO-12 2003 

Other Control Equipment 

Sandblast Building 

Baghouse 

N/A 1 N/A CZHACOLLDC001 2001 

Lime Silo Baghouse 300 CFM 1 Peabody CARACOLL135 7/24/1974 

Soda Ash Silo Baghouse 300 CFM 1 Peabody CARACOLL134 7/24/1974 

Weld Shop Baghouse N/A 2 Torit UNIT1 IG569313 

UNIT2 IG569313

N/A 

Paint Booth Filter N/A 1 N/A CZAAFLTR0001 N/A 

Coal Additive Soda Ash Silo 

Baghouse 

750 CFM 1 CHEMCO Systems, 

L.P. 

DC-12 2003 

Internal Combustion Engines

Fire Booster Pump 800 hp 1 Cummins 10644000 1977 

Emergency Generator 938 hp 1 Detroit Diesel 501681 1978 

Emergency Fire Pump 266 hp 1 Caterpillar 64Z09303 1977 

N/A = Not applicable 

Continuous Monitoring Equipment for Units 1 and 2 

Steam Unit NOx Monitor SO2 Monitor CO2 Monitor Opacity 

Monitor 

Flow Monitor 

Unit 1 TECO 42C TECO 43C TECO 41C EMS 1304 Panametrics Model 

CEM 68-29-2201-0 

Serial #225 

Unit 2 TEI 43i TEI 43i TEI 410i TML 

Lighthawk – 

560 

EMRC DP-75 

EMRC DP-75 

Steam Unit CO Monitor Hg Sampler PM Monitor 

Unit 1 TEI 48i Environmental Supply Company 

Hg-324K Automated Mercury 

Sampler 

Unit 2 TEI 48i Environmental Supply Company 

Hg-324K Automated Mercury 

Sampler 

Sick Maihak FWE 200 
 

TV Permit Renewal Number 52639 Page 78 of 79 December 06, 2011 

SRP – Coronado Generating Station 

ATTACHMENT “D”: PHASE II ACID RAIN PROVISIONS 

Air Quality Control Permit No. 52639 

for 

Salt River Project, Coronado Generating Station 

I. Statement of Basis

Statutory and Regulatory Authorities: In accordance with Arizona Revised Statutes, Title 49, 

Chapter 3, Article 2, Section 426.N, and Titles IV and V of the Clean Air Act, the Arizona 

Department of Environmental Quality issues this Phase II Acid Rain Permit pursuant to Arizona 

Administrative Code, Title 18, Chapter 2, Article 3, Section 333 ( A.A.C. R18-2-333), “Acid 

Rain”. 

II. SO2 Allowance†

 Allocations and NOx Requirements for Each Affected Unit

2011 2012 2013 2014 2015 2016 2017

Unit 1

SO2

allowances 

under Tables 

2, 3, or 4 of 

40 CFR part 

73

5,332* 5,332* 5,332* 5,332* 5,332* 5,332* 5,332*

NOx limit Pursuant to 40 CFR 76.8(d)(2), Arizona Department of Environmental 

Quality approves a NOx early election compliance plan for Unit 1. The 

compliance plan is effective for calendar year 2000 through calendar year 

2007. Under the compliance plan, the unit’s annual average NOx 

emission rate for each year, determined in accordance with 40 CFR Part 

75, shall not exceed the applicable emission limitation, under 40 CFR 

76.5(a)(2) of 0.50 lb/MMBtu for wall fired boilers. If the unit is in 

compliance with its applicable emission limitation for each year of the 

plan, then the unit shall not be subject to the applicable emission 

limitation, under 40 CFR 76.7(a)(2), of 0.46 lb/MMBtu until calendar 

year 2008. 

In addition to the described NOx compliance plan, this unit shall comply 

with all other applicable requirements of 40 CFR Part 76, including the 

duty to reapply for NOx compliance plan and requirements covering 

excess emissions.
 

TV Permit Renewal Number 52639 Page 79 of 79 December 06, 2011 

SRP – Coronado Generating Station 

2011 2012 2013 2014 2015 2016 2017

Unit 2 SO2

allowances 

under Tables 

2, 3, or 4 of 

40 CFR part 

73

5,332* 5,332* 5,332* 5,332* 5,332* 5,332* 5,332*

NOx limit Pursuant to 40 CFR 76.8(d)(2), Arizona Department of Environmental 

Quality approves a NOx early election compliance plan for Unit 2. The 

compliance plan is effective for calendar year 2000 through calendar year 

2007. Under the compliance plan, the unit’s annual average NOx 

emission rate for each year, determined in accordance with 40 CFR Part 

75, shall not exceed the applicable emission limitation, under 40 CFR 

76.5(a)(2) of 0.50 lb/MMBtu for wall fired boilers. If the unit is in 

compliance with its applicable emission limitation for each year of the 

plan, then the unit shall not be subject to the applicable emission 

limitation, under 40 CFR 76.7(a)(2), of 0.46 lb/MMBtu until calendar 

year 2008. 

In addition to the described NOx compliance plan, this unit shall comply 

with all other applicable requirements of 40 CFR Part 76, including the 

duty to reapply for NOx compliance plan and requirements covering 

excess emissions.

†

 As defined under 40 CFR §72.2, “Allowance” means an authorization by the Administrator under the 

Acid Rain Program to emit up to one ton of sulfur dioxide during or after a specified calendar year. 

* The number of allowances actually held by an affected source in a unit account may differ from the 

number allocated by U.S. EPA. Neither of the aforementioned conditions necessitate a revision to the 

unit SO2 allowance allocations identified in this permit (See 40 CFR 72.84). 

III. Comments, Notes and Justifications

SRP has early-elected for NOx requirements on Units 1 and 2. 

IV. Permit Application

The Permittee, and any other owners or operators of the units at this facility, shall comply with 

the requirements contained in the attached acid rain permit application (OMB No. 2060-0258) 

signed by the Designated Representative Kara M. Montalvo on 5/18/10.