PERl\1liTTEE: El Paso Electric Company 

1 00 North Stanton 

El Paso, TX 79901 

FACILITY NAME: Montana Power Station 

FACILITY LOCATION: Section 25, Block 79, Township 2 

Dl n..,,_,. TV "700'l Q Ll 1 (l;)V, I ..fl.. I 77JO 

Pursuant to the provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. Section 

7 4 70, et. Seq.), and the Code ofF ederal Regulations (CFR) Title 40, Section 52.21, and the 

Federal Implementation Plan at 40 CFR § 52.2305 (effective May 1, 2011 and published at 76 FR 

25178), the U.S. Environmental Protection Agency, Region 6 is issuing a Prevention of Significant 

Deterioration (PSD) permit to El Paso Electric Company for Greenhouse Gas (GHG) emissions 

from its proposed Montana Power Statiion. The Permit applies to the addition of four natural gasfired simple cycle combustion turbines, firewater pump engine, circuit breakers and associated 

natural gas piping at its new facility located in El Paso County, Texas. 

El Paso Electric Company is authorized to construct the Montana Power Station, including four 

new natural gas-fired simple cycle combustion turbines, firewater pump engine, circuit breakers 

and natural gas piping as described her,ein, in accordance with the permit application (and plans 

submitted with the permit application), the federal PSD regulations at 40 CFR § 52.21, and other 

terms and conditions set forth in this PSD permit in conjunction with the corresponding Texas 

Corrunission on Environmental Quality (TCEQ) permit No. PSDTX1290 and 102294. Failure to 

comply with any condition or term set forth in this PSD Permit may result in enforcement action 

pursuant to Section 113 of the Clean Air Act (CAA). This PSD Permit does not relieve El Paso 

Electric Company of the responsibility to comply with any other applicable provisions of the CAA 

(including applicable implementing regulations in 40 CFR Parts 51, 52, 60, 61,72 through 75, and 

98) or other federal and state requirements (including the state PSD program that remains under 

approval at 40 CFR § 52.2303). 

In accordance with 40 CFR § 124.15(b ), this PSD Permit becomes effective 30 days after the 

service of notice of this final decision tmless review is requested on the permit pursuant to 40 CFR 

§124.19. g ' za/r 

wrrn Steng Date f!'- Multimedia Planning and Permitting Division 
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County, Texas, using four (4) GE LMSlOO simple cycle combustion turbines. In addition, the 

project also includes the installation of ancillary equipment that may emit GHG, including a 

firewater pump engine, circuit breakers and associated natural gas piping. The primary object of 

the proposed project is to meet peak and intermediate load requirements. 

EQUIPMENT LIST 

The following devices are subject to this GHG PSD permit. 

FIN EPN Description 

GT-1 GT-1 

GT-2 GT-2 Four 100 MW (each, nominal gross) Natural Gas Fired-Simple Cycle Turbines 

GT-3 GT-3 (GE Model LMS I 00). 

GT-4 GT-4 

Diesel fire pump engine (design output not to exceed 327 hp). ln addition to 

FWP-1 FWP-1 emergency frre suppression activities, the unit is limited to 1 hr per week; 52 hrs 

per 12-monllh rolling basis of operation for maintenance and testing. 

CTBR-SF-6 CTBR-SF-6 SF6 Circuit Breaker Emissions 

FUG-1 FUG-1 Natural Gas. Piping Components 

I. GENERAL PERMIT CONDtiTIONS 

A. PERMIT EXPIRATION 

As provided in 40 CFR §52.21(r), this PSD Permit shall become invalid if construction: 

I. is not commenced (as defined .in 40 CFR §52.21(b)(9)) within 18 months after the 

approval takes effect; or 

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

3. is not completed within a reasonable time. 

Pursuant to 40 CFR §52.21(r), EPA may extend the 18-month period upon a written satisfactory 

showing that an extension is justified. 

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3. date upon which initial perfom1ance tests will commence, in accordance with the 

provisions of Section V, postmarked not less than 30 days prior to such date. Notification 

may be provided with the submittal of the performance test protocol required pursuant to 

Condition V.B. 

C. FACILITY OPERATION 

At nll t;....., .. s :n,.l .. tt: ... n ........ ;,.,.,t .. nf' co+<:n+nn .. 1-. .. ttlnu'" onA rna;nt .. noni"P P .. rrn1tt .... ch<>ll tn thP rl.L. a11 I.U.!!'\,1 ) .111VJ.UUlllf) }'~J..J.V\.1- VJ.. .:1"'"-' .. '"".}J' .:.J.u,.u.uvv,u, U..UU .U .J. U .U.'-' (..U..a.'-'"") A ""A.&.u.&'-"'""'"" to.J.4.a.""u' • '-' ... u ,....., 

extent practicable, maintain and opera1te the facility including associated air pollution control 

equipment in a manner consistent with good air pollution control practice for minimizing 

emissions. Determination of whether acceptable operating and maintenance procedures are being 

used will be based on information available to the EPA, which may include, but is not limited to, 

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

D. MALFUNCTION REPORTING 

1. Permittee shall notify EPA by mail, or other means identified by EPA, within 48 hours 

following the discovery of any failure of air pollution control equipment, process 

equipment, or of a process to operate in a normal manner, which results in an increase in 

GHG emissions above the allowable emission limits stated in Section II and III of this 

permit. 

2. Within 10 days of the discovery of any GHG emissions above the allowable emission 

limits resulting from malfunctions as described in I.D.l., Permittee shall provide a written 

supplement to the initial notification that includes a description of the malfunctioning 

equipment or abnormal operation, the date of the initial malfunction, the period of time 

over which emissions were increased due to the failure, the cause of the failure, the 

estimated resultant emissions in excess of those allowed in Section II and III, and the 

methods utilized to mitigate emissions and restore normal operations. 

3. Compliance with this malfunction notification provision shall not excuse or otherwise 

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

malfunction may cause. 

E. RIGHT OF ENTRY 

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

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Permit; and, 

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

F. TRANSFER OF OWNERSHIP 

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

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

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

copy of the letter shail be forwarded to• EPA Region 6 within thirty days of the letter signatlll'e. 

G. SEVERABILITY 

The provisions of this PSD Permit are severable, and, if any provision of the PSD Permit is held 

invalid, the remainder of this PSD Permit shall not be affected. 

H. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS 

Permittee shall construct this project in compliance with this PSD Permit, the application on 

which this permit is based and all other applicable federal, state, and local air quality regulations. 

This PSD permit does not release the Permittee from the obligation to obtain a PSD permit for 

other pollutants emitted in significant ;amounts or from any liability for compliance with other 

applicable federal, state and local environmental laws and regulations, including the Clean Air 

Act. 

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C02 C02e 

dscf 

EF EPN FIN 

FR 

GCV GHG 

gr 

GWP 

HHV 

hr 

lb 

MMBtu 

MSS 

N20 NSPS 

PSD 

QA/QC 

SCFH SCR SF6 

TAC 

TCEQ TPY 

u.s.c. 

Carbon Dioxide Carbon Dioxide Equivalent 

Dry Standlard Cubic Foot 

Emission Factor Emission Point Number 

Facility Identification Number 

Federal Register 

Gross Calorific Value Greenhouse Gas Grains 

r.lnh<>l W<>nnino PntAnti<>l 

"-J.&VVWI. YJ' \4&a&& .. I.&C) .,1. V"'"".I&\.U , ..... 

High Hea1ting Value Hour Pound Million British Thermal Units Maintenance, Start-up and Shutdown 

Nitrous Oxides 

New Source Performance Standards 

Preventio111 of Significant Deterioration 

Quality Assurance and/or Quality Control 

Standard Cubic Feet per Hour 

Selective Catalytic Reduction 

Sulfur hexafluoride 

Texas Administrative Code Texas Co1mmission on Environmental Quality 

Tons per Year · 

United States Code 

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262,305.79

GT-3 GT-3 Cycle 12-month rolling basis per 

GT-4 GT-4 Turbine, each NzO 0.463 turbine. 

-See permit condition 

Ill.A.2 and 4. 

C0 2 8.66 

- Not to exceed 52 hours 

No of non-emergency 

CH4 

Numerical operation on a 12-month 

Firewater Limit rolling basis 

FWP-i FWP-i Established5 Q .0::0 Pump Engine b.U7 - Use of Good 

No Combustion Practices. 

N20 

Numerical See permit condition 

Limit lll.B. 

Established5 

Fugitive SF6 

Circuit SF6 0.015 342.00 Work Practices. See CTBR-SF-6 CTBR-SF-6 Breaker permit condition lJJ.C. 

Emissions 

Components Implementation of AVO 

Fugitive FUG-1 FUG-1 Leak CH4 0. 15 3.75 Program. See permit 

Emissions 

condition lll.D. 

C02 I ,048,154.66 

CH~ 

21.50 

Totals6 1,049,577.60 

N20 1.82 

SF6 0.02 

.. 

I. The TPY emtsston ltmtts specified m tht:s table are not to be exceeded for thts factltty and mclude emtsstons 

from the facility during all operations and include MSS activities. All emissions are expressed in terms of short 

tons. 

2. Global Warming Potentials (GWP): C02.= I, C~ = 25, N20 = 298, SF6=22,800 

3. The GHG Mass Basis TPY limit and the C02e TPY limit for the natural gas fired simple cycle turbines applies 

to each turbine and is not a combined limit. 

4 . Annual C02e emissions, in tons per year (TPY) are based on 365-day rolling basis. 

5. All values indicated as "No Numerical Limit Established" are less than 0.0 I TPY with appropriate rounding. 

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

6. Total emissions include the PTE for fugitive emissions. Totals are given for informational purposes only and do 

not constitute emission limits. 

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a. The limit of 1,100 lbs ofC02/MW-hr gross output is based on each turbine's 

daily average of C02 emissions measured using a Continuous Emissions 

Monitoring System (C:EMS) and divided by each turbines measured gross 

electrical output. The .Permittee shall calculate each day a combustion turbine 

operates, C02 emissions over the rolling 5,000 hours of operation basis divided 

by gross electrical output over the same period for comparison to the limit for 

each combustion turbine. 

b. The permittee shall calculate, on a daily basis, the amount of C02e emitted from 

each turbine in tons per year on a 365-day rolling basis based on the 

measurement of the C02 CEMS and the procedures and Global Warming 

Potentials (GWP) contained in the Greenhouse Gas Regulations, 40 CFR Part 98, 

Subpart A, Table A-I, as published on November 29,2013 (78 FR 71948) for 

CH4 and N20. Compliance shall be based on a 365-day rolling basis. 

c. The annual quantity of fuel used by each turbine (EPNs GT-1, GT-2, GT-3 and 

GT-4) shall not exceed 4,136,000 MMBtu (HHV). The permittee shall calculate, 

each day a combustion turbine operates, the quantity of fuel used by each turbine 

over the trailing 365-day rolling basis by multiplying the gross calorific value of 

the fuel combusted by volume of fuel metered for comparison to the annual fuel 

limit for each combustion turbine. 

d. Each turbine (EPNs GT-1, GT-2, GT-3 and GT-4) is limited to 5,000 operational 

hours on a 12-month wiling basis which shall include periods of startup and 

shutdown. 

3. Turbine Work Practice and Operational Requirements: 

a. The pennittee shall measure the pounds of C02 emitted hourly from each turbine 

from the procedure provided in 40 CFR 75.1 O(a)(3)(i) (direct emission 

measurement using CEMS). The CEMS required by this permit shall be 

installed, calibrated, operated, audited, tested and maintained in accordance with 

the manufacturer's recommendations and the appropriate perfonnance standards 

and quality assurance :requirements in the appendices of either 40 CFR Part 60 or 

40 CFR Part 75. 

b. For each turbine, a C02 CEMS and volumetric stack gas flow monitoring system 

with an automated data acquisition and handling system for measuring and 

recording C<h emissions discharged to the atmosphere shall be installed and 

operated for all operating hours, including startup and shutdown. The 

measurement from each turbine's C02 CEMS shall be used to show compliance 

with the emission limit in Table I. 

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iii. RAT A test plarts and reports of test results. 

e. The permittee shall ensure compliance with the specifications and test 

procedures for C02 emission monitoring system at stationary sources, 40 CFR 

Part 75, or 40 CFR Patt 60, Appendix B, Performance Specification numbers 1 

through 9, as applicable. 

f. The permittee shall calculate the pounds of CH4 and N20 emitted each calendar 

day by using the default C~ and N20 emission factors contained in Table C-2 of 

40 CFR 98, as in effect as of the date of permit issuance, and the measured actual 

hourly heat input (HHV). 

g. For each turbine, fuel metering shall include: 

i. Measurement and recording of the natural gas flow rate using an 

operational non-resettable elapsed flow meter installed at each turbine 

inlet. 

ii. Recording the total amount of fuel com busted for each turbine on a 

hourly basis. 

iii. The fuel gross •calorific value (GCV) [high heat value (HHV)], carbon 

content and, if applicable, semi-annually by the procedures contained in 

40 CFR Part 98.34(b)(3). Records of the fuel GCV shall be maintained 

for a minimum period of five years. Upon request, permittee shall 

provide a sarnple and/or analysis of the fuel that is fired in any unit 

covered by this permit at the time of the request, or shall allow a sample 

to be taken by IEP A for analysis. 

h. Permitee shall calibrat·e and perform preventative maintenance check of the fuel 

gas flow meters and document annually. 

1. The gross energy output [MWh (gross)] for each turbine shall be measured and 

recorded on an hourly basis. 

j. Permittee shall substitute data per the Missing Data Substitution Procedures 

specified under 40 CFR Part 75, Subpart D. 

4. Startup and Shutdown Requirements for Turbines: 

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

operating and maintaining the facility and associated air pollution control 

equipment in accordance with good air pollution control practices, safe operating 

practices, and protection of the facility. 

i. A startup of each turbine is defined as the period that begins when there 

is measureable fuel flow to the turbine and ends when the turbine load 

reaches 50 percent. A startup time is limited to 10 minutes. 

ii. A shutdown of each turbine is defined as the period that begins when the 

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rolling basis. 

B. Requirements for the FirewateJr Pump Engine (EPN: 

1. Fuel Specification: The fuel £or the firewater pump is limited to No.2 fuel oil. 

2. Firewater Pump Work Practiice and Operational Requirements: 

a; The firewater pu..tnp shall not exceed 52 hours of non-emergency operation on a 

12-month rolling basis. and shall be operated and maintained in accordance with 

the manufacturer's recommendations. 

b. The permitee shall ins1tall and maintain an operational non-resettable run time 

meter for the firewater pump. 

c. The permittee shall install and maintain a non-resettable elapsed flue flow meter 

for the firewater pump. 

d. The engine shall meet the applicable monitoring and recordkeeping requirements 

as required in 40 CFR Part 60 Subpart IIII, Standards of Performance for 

Stationary Compressietn Ignition Internal Combustion Engines. 

C. Requirements for Minimizing F'ugitive Emissions from SF6 Circuit Breaker (EPN: 

CTBR-SF6) 

Fugitive SF 6 Circuit Breaker Work. Practice and Operational Requirements: 

a. For EPN CTBR-SF6, SF6 emissions shalJ be calculated annually (calendar year) 

in accordance with the mass balance approach provided in equation DD-1 of the 

Mandatory Greenhouse Gas Reporting Rule for Electrical Transmission and 

Distribution Equipment Use, 40 CFR Part 98, Subpart DO. The total SF6 

inventory of the circuit breakers shall not exceed 6,180 lb with leak detection. 

b. The circuit breakers shall be equipped with a low pressure alarm and low pressure 

lockout. 

D. Requirements for Minimizing Fugitive Leaks from Natural Gas Components (EPN: 

FUG-1) 

Components Fugitive Leaks Work .Practice and Operational Requirements: 

a. The permittee shall impllement an auditory/visual/olfactory (AVO) monitoring 

program for detecting leaking in recovered process fuel gas and natural gas piping 

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A. Records 

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

permittee will monitor the following parameters and summarize the data as specified in 

Special Conditions III. A, B, C and D. 

a. Operating hours for all air emission sources authorized by this permit; 

b. Records of the fuel consumed by each source authorized by this permit; 

c. Records of n.ni time meter and fuel flow met

er measurements fer the fire pu...'Tip 

engme; 

d. The fueJ usage for all turbines, and engine, using continuous fuel flow monitors (a 

group of equipment can utilize a common fuel flow meter, as long as actual fuel 

usage is allocated to the individual equipment based upon actual operating hours 

and maximum firing rate) A computer that collects, sums, and stores electronic 

data from continuous fuel flow meters is an acceptable totalizer; 

e. Semi-annual fuel sampling for natural gas or other frequencies as allowed by 40 

CFR Part 98 Subpart C §98.34(b)(3). 

2. Permittee shall maintain records of the following for the Equipment List: all final records 

or reports pertaining to significant maintenance performed; duration of startup, shutdown; 

the initial startup period for the emission units; malfunctions that couJd affect the 

Equipment's ability to meet the limits in this permit; all records relating to performance 

tests, calibrations, checks, and monitoring of combustion equipment required by this 

permit; duration of an inoperative monitoring device and emission units with the required 

corresponding emission data; and all other information required by this permit recorded 

in a permanent form suitable fi::>r inspection. These records may be maintained in 

electronic databases. The rec01rds must be retained for not less than five years following 

the date of their creation. 

3. Permittee shall maintain records of all GHG emission units and C02 emission 

certification tests and monitoring and compliance information required by this permit. 

4. Permittee shall maintain reports and documents pertaining to the maintenance performed 

and compliance with the Monitoring and Quality Assurance and Quality Control 

(QA/QC) procedures outlined in 40 CFR 98.304 for SF6 circuit breakers. 

5. Permittee shall maintain records and submit a written report of all excess emissions to 

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

applicable subpart; or the Administrator or authorized representative, on a case-by-case 

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

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

each semi-annual period and shall include the following: 

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activities; and 

e. Any violation of limitations on operation, including but not limited to restriCtions 

on hours of operation of the emergency generator or fire pump. 

6. Excess emissions shall be defined as any period in which the facility emissions exceed a 

maximum emission limit set forth in this permit, a malfunction occurs of an emission unit 

listed in the Equipment List that results in excess GHG emissions, or any other 

unauthorized GHG emissions occur. 

7. Excess emissions indicated by GHG emission source certification testing or comp!ia.11ce 

monitoring shall be considered violations of the applicable emission limit for the purpose 

of this permit. 

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

following the date of such measurements, maintenance, and reporting. 

V. Initial Performance Testing ]R-equirements: 

A. The Permittee shaH perform stack sampling and other testing to establish the actual pattern 

and quantities of C02 emissions bdng emitted into the atmosphere from the four turbines 

(EPN GT-1, GT-2, GT-3 and GT-4) and to determine the initial compliance with the C02 

emission limits established in this permit. Sampling shall be conducted in accordance with 40 

CFR § 60.8 and EPA Method 3A or 3B for the concentration of C02. 

The stack test shall consist of thre:e separate runs at or above 90% of maximum load 

operations and three separate runs below 70% but above 50% load operation. Stack gas 

flow rate measurements, as well ats moisture measurements (if needed), shall be made 

during each test run. The electrical generation (gross megawatts) during each test run shall 

also be recorded. The C02 emiss:ion rate shall be calculated as defined below and recorded 

for each test run in lb C02/MWh {gross) and lb C02/hr. The arithmetic mean for the three 

test runs at or above 90% of maximum load operation and the arithmetic mean for the three 

test runs below 70% but above SCI% load operation shall also be calculated and recorded. 

1. The C02 hourly average emission rate determined by the three runs at or above 90% 

of maximum load by 5,000 hours. 

2. If the above calculated C02 emission total does not exceed the (TPY) specified on 

Table 1, no compliance st:Jrategy needs to be developed. 

3. If the above calculated C02 emission total exceeds the (TPY) specified in Table 1, 

the facility shall; 

a. Document the exce:edance in the test report; and 

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C. Permittee shall submit a performance test protocol to EPA no later than 30 days p

test to allow review of the test plan and to arrange for an observer to be present at the test. 

The performance test shall be conducted in accordance with the submitted protocol, and any 

changes required by EPA. 

D. Performance tests must be conduct1ed under such conditions to ensure representative 

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

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

E. The owner or operator must provide the EPA at least 30 days' prior notice of any 

performance test, except as specified under other subparts, to afford the EPA the opportunity 

to have an observer present and/or to attend a pre-test meeting. If there is a deiay in the 

original test date, the facility must provide at least 7 days prior notice of the rescheduled date 

of the performance test unless EPA approves an earlier rescheduled date due to unforeseen 

events, such as delays that are caused by weather. 

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

follows: 

1. Sampling ports adequate for test methods applicable to this facility, 

2. Safe sampling platform(s), 

3. Safe access to sampling pl.atform(s), and 

4. Utilities for sampling and testing equipment. 

G. To verify continued performance at permitted emission limits, the permittee shall conduct its 

initial and annual C02 CEMS relative accuracy test audit (RAT A), in accordance with 40 

CFR Part 60, Appendix F, Procedure 1, and 40 CFR 75, Appendix B, Section 2.3 .l to 

evaluate compliance of each turbine with the emission standards on a continuous basis. The 

initial C02 CEMS RAT A shall be on or before the earlier of 90 unit days or 180 calendar 

days after the date the unit commences operation. 

VI. Agency Notifications 

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

permit information to: 

Multimedia Planning and Pem1itting Division 

EPA Region 6 

1445 Ross Avenue (6PD-R) 

Dallas, TX 75202 

Email: Group R6AirPermits@EP A.gov 

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

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