NSR Permit No. 0063-M6R1 Page 2 of 33 

Rev. 12/15/05

This permit authorizes the modification and/or operation of the San Juan Generating Station. The 

function of the facility is to generate electricity by combusting coal. This facility is located in 

Township 30 north, Range 15 west, Sections 16 – 21, 29, and 30, approximately 3 miles north 

northeast of Waterflow, New Mexico in San Juan County. 

Modification History: 

0063-M6R1 

Adding two bag houses, one each for Units 1 and 2 fly ash silos and disconnecting (not 

removed) the Electrostatic Precipitators (ESP) from each unit. 

0063-M6 

Adding four activated carbon silos and associated control equipment. 

0063-M5 

Permit Application No. 0063-M5 was withdrawn. 

0063-M4 

Modification No. 0063-M4 consists of adding fabric filters to each boiler, replacing the existing 

boiler burners with low-NOx burners, and increasing the control efficiency of the wet limestone 

scrubber. 

This permit supersedes and replaces all portions of Air Quality Permit No. 0063-M6, issued April 

22, 2008, except the portion requiring compliance tests. Compliance test conditions from previous 

permits are still in effect, in addition to compliance test requirements contained in this permit. 

The Department has reviewed the permit application for the proposed modification and has 

determined that the provisions of the Act and ambient air quality standards will be met. Conditions 

have been imposed in this permit to assure continued compliance. 20.2.72.210.D NMAC, states that 

any term or condition imposed by the Department on a permit is enforceable to the same extent as a 

regulation of the Environmental Improvement Board. 

Pursuant to 20.2.75.11 NMAC, the Department will assess an annual fee for this facility. This 

regulation set the fee amount at $1,500 through 2004 and requires it to be adjusted annually for the 

Consumer Price Index on January 1. The current fee amount is available by contacting the 

Department or can be found on the Department’s website. The AQB will invoice the permittee for 

the annual fee amount at the beginning of each calendar year. This fee does not apply to sources 

which are assessed an annual fee in accordance with 20.2.71 NMAC. For sources that satisfy the 

definition of “small business” in 20.2.75.7.F NMAC, this annual fee will be divided by two. 

All fees shall be remitted in the form of a corporate check, certified check, or money order made 

payable to the “NM Environment Department, AQB” mailed to the address shown on the invoice 

and shall be accompanied by the remittance slip attached to the invoice. 
NSR Permit No. 0063-M6R1 Page 3 of 33 

Rev. 12/15/05

TOTAL EMISSIONS

The total potential emissions from this facility, excluding exempted activities, are shown in the 

following table. The emissions limitations for individual units are shown in Specific Condition 2. 

Total Potential Criteria Pollutant Emissions from Entire Facility (for information only, not an 

enforceable condition):

Pollutant Emissions (tons per year) 

Nitrogen Oxides (NOx) 24,710.00 

Carbon Monoxide (CO) 39,427.00 

Total Suspended Particulate (TSP) 1,816.00 

Particulate Matter Less Than 10 Microns (PM10) 1,549.00 

Volatile Organic Compounds (VOC) 249.00 

Sulfur Dioxide (SO2) 16,043.00 

Total Potential HAPS that exceed one ton per year (for information only, not an enforceable 

condition):

Pollutant Emissions (tons per year) 

Hydrogen Chloride 15.8 

Hydrogen Fluoride 48.1 

SECTION I: SPECIFIC CONDITIONS

Pursuant to 20.2.72 NMAC, and the specific regulatory citations in parenthesis, the Facility is 

subject to the following Specific Conditions. 

Fee Requirement: This permit is not effective until the Department receives the permit fee specified 

in the attached invoice. Pursuant to 20.2.75.12 NMAC, the Permittee shall pay this invoice no later 

than thirty (30) days after the date of the invoice, unless the Department has granted an extension. 

The permit fee must be paid by this date regardless of the Permittee’s intended use or non-use of the 

permit or of the Department’s cancellation of the permit. The Permittee’s failure to pay this fee 

when due will automatically void the permit and the Department may initiate enforcement action to 

collect the fee and assess a civil penalty for non-payment. The Permittee shall not construct the 

equipment or implement the operation specified in Specific Conditions 1.j until the Department 

acknowledges receipt of the fee by letter or electronic mail. The Department may initiate 

enforcement action for injunctive relief and civil penalties for any construction or operation 

specified in Specific Conditions 1.j prior to the date of the Department’s written acknowledgment of 

receipt of the fee. 
NSR Permit No. 0063-M6R1 Page 4 of 33 

Rev. 12/15/05

1. Construction / Modification / Revision and Operation

(20.2.72 NMAC; NSPS 40 CFR 6060, Subparts A, D, and OOO) 

a. The facility shall consist of the equipment identified in Table 1.1. 

Table 1.1: Regulated Equipment List 

Unit No. 1 Description Manufacture Manufacture 

Date 

Model 

No. 

Serial 

No. Capacity Control Equipment 

S301/E301 

Unit 1 Coal 

Boiler 

Begin 

Commercial 

Operation 

12/1976 

Foster 

Wheeler -- 08-1266 -- 

3707 

MM 

Btu/hr 4

Fabric Filter 

ESP 

SO2 Scrubber 

S302/E302 

Unit 2 Coal 

Boiler 

Begin 

Commercial 

Operation 

11/1973 

Foster 

Wheeler -- 08-1266 -- 

3688 

MM 

Btu/hr 4

Fabric Filter 

ESP 

SO2 Scrubber 

S303/E303 

Unit 3 Coal 

Boiler 

Begin 

Commercial 

Operation 

12/1979 

Babcock & 

Wilcox -- RB-544 -- 

5758 

MM 

Btu/hr 4

Fabric Filter 

ESP 

SO2 Scrubber 

S304/E304 

Unit 4 Coal 

Boiler 

Begin 

Commercial 

Operation 

4/1982 

Babcock & 

Wilcox -- RB-545 -- 

5649 

MM 

Btu/hr 4

Fabric Filter 

ESP 

SO2 Scrubber

S508/E501 Unit 1 Duct 

Leaks -- -- -- -- --

good air 

pollution control 

practices

S509/E502 Unit 2 Duct 

Leaks -- -- -- -- --

S510/E503 Unit 3 Duct 

Leaks -- -- -- -- --

S511/E504 Unit 4 Duct 

Leaks -- -- -- -- --

S111/E101 Coal Pile A 

Maintenance -- -- -- -- -- TBD 

S112/E102 Coal Pile A 

Maintenance -- -- -- -- -- TBD 

S113/E103 Coal Pile A 

Maintenance -- -- -- -- -- TBD 

S114/E104 Coal Pile A 

Maintenance -- -- -- -- -- TBD 
NSR Permit No. 0063-M6R1 Page 5 of 33 

Rev. 12/15/05

Unit No. 1 Description Manufacture Manufacture 

Date 

Model 

No. 

Serial 

No. Capacity Control Equipment 

S201/E202 Coal Silo 

Transfer Point -- -- -- -- -- Enclosure 

S203/E203 

Coal Belt to 

Pulverizers 

transfer Point 

-- -- -- -- -- Enclosure 

S204/E201 Coal 

Pulverizers Multiple Multiple Multiple Multiple 8,200,000 

tpy 3 Building Enclosure 

S425/E406 Unit 1 Cooling 

Tower Marley Note 2 D52 6615-5-

11 

170,000 

gpm 

Drift 

Eliminators/Design 

S426E407 Unit 2 Cooling 

Tower Marley Note 2 D52 6615-5-

11 

165, 000 

gpm 

S427/E408 Unit 3 Cooling 

Tower Marley Note 2 Model 2 644-12-

333-75 

220, 000 

gpm 

S428/E409 Unit 4 Cooling 

Tower Marley Note 2 Model 2 6616-12-

113-80 

227,500 

gpm 

S429/E410 Aux #1 

Cooling Tower Marley 1978 600 

series TBD 5,000 gpm 

S430/E411 Aux # 2 

Cooling Tower Marley 1978 TBD TBD 30,000 

gpm 

S518/E518 Unit 1 Fly Ash 

Silo Vent W.W. Sly TBD JM3586 TBD TBD Fabric Filter 

Baghouse 

S519/E519 Unit 2 Fly Ash 

Silo Vent W.W. Sly TBD JM3586 TBD TBD Fabric Filter 

Baghouse 

S512/E505 Unit 3 Fly Ash 

Silo Vent W.W. Sly TBD JM3586 TBD TBD Fabric Filter 

Baghouse 

S513/E506 Unit 4 Fly Ash 

Silo Vent W.W. Sly TBD JM3586 TBD TBD Fabric Filter 

Baghouse 

S514/E507 Unit 1 Fly Ash 

Silo Unloading -- -- -- -- TBD Moisture Control 

(Bulk Unloading) 

S515/E508 Unit 2 Fly Ash 

Silo Unloading -- -- -- -- TBD 

S516/E509 Unit 3 Fly Ash 

Silo Unloading -- -- -- -- TBD 

S517/E510 Unit 4 Fly Ash 

Silo Unloading -- -- -- -- TBD 

S738/E704 

Front End 

Loader 

(Around Coal 

Piles) 

-- -- -- -- -- Watering 

S753/E707 

Front End 

Loader (Around 

Gypsum Piles)

-- -- -- -- -- Watering 

E702, 

E703, 

E704-B, 

and E706 

Un-Paved 

Haul Roads -- -- -- -- -- Watering 

E701, 

E705, and 

E708 

Paved Road 

Emissions -- -- -- -- -- Water Truck Street 

Sweeper 
NSR Permit No. 0063-M6R1 Page 6 of 33 

Rev. 12/15/05

Unit No. 1 Description Manufacture Manufacture 

Date 

Model 

No. 

Serial 

No. Capacity Control Equipment 

S804/E802 

Lime Stone 

Pile 

Maintenance 

-- -- -- -- -- TBD 

E801 

Limestone 

Truck 

Unloading 

__ __ __ __ __ None 

S806/E803 Limestone Silo 

loading __ __ __ __ __ Baghouse 

S901 Activated 

Carbon Silo -- TBD -- -- 45,000 lb Dedicated Baghouse 

(E901) 

S902 Activated 

Carbon Silo -- TBD -- -- 45,000 lb Dedicated Baghouse 

(E902) 

S903 Activated 

Carbon Silo -- TBD -- -- 72,000 lb Dedicated Baghouse 

(E903) 

S904 Activated 

Carbon Silo -- TBD -- -- 72,000 lb Dedicated Baghouse 

(E904) 

1 Unit number designations starting with an “S” indicate Source and “E” Designations indicate emissions points 

2 The manufacture date for the boilers (Units E301 – E304), the boiler specific cooling towers (Units 406 – 409), and 

the coal pulverizes (Unit E201) is assumed to be the “begin commercial operations” date for the respective boilers. 

3 The coal pulverizers have a capacity of 1,600,000 tons per year of coal for each emissions units E301 and E302. The 

coal pulverizers have a capacity of 2,500,000 tons per year of coal for each emissions units E303 and E304. These 

capacity values are rounded to the nearest 100,000 tons per year. These values are based on historical coal use, scaled 

up to 100 percent unit utilization (i.e 100 percent load at 8760 hours per year).” 

4 The Btu/hr value listed in Table 1.1 Includes a 6% safety factor added to nominal rated capacity of the boilers 

existing at the time of permit issuance. 

b. This facility is authorized to operate on a continuous basis. 

c. This facility is subject to all applicable requirements including, but not limited to, the 

following regulations: 

Table 1.2: applicable requirements 

Citation Title 

40 CFR Part 60, Subpart A General Provisions 

40 CFR Part 60 Subpart D Standards of Performance for Fossil Fuel Fired Steam Generators 

for Which Construction is Commenced After August 17, 1971 

40 CFR Part 60 Subpart 

OOO 

Standards of Performance for Nonmetallic Mineral Processing 

Plants 

20.2.3 NMAC Ambient Air Quality Standards 

20.2.5 NMAC Source Surveillance 

20.2.7 NMAC Excess Emissions 

20.2.14 NMAC Particulate Emissions From Coal Burning Equipment 

20.2.31 NMAC Coal Burning Equipment - Sulfur Dioxide 

20.2.32 NMAC Coal Burning Equipment - Nitrogen Dioxide 
NSR Permit No. 0063-M6R1 Page 7 of 33 

Rev. 12/15/05

Citation Title 

20.2.61 NMAC Smoke and Visible Emissions 

20.2.70 NMAC Operating Permits 

20.2.71 NMAC Operating Permit Fees 

20.2.72 NMAC Construction Permits 

20.2.73 NMAC NOI & Emissions Inventory Requirements 

20.2.75 NMAC Construction Permit Fees 

20.2.77 NMAC New Source Performance 

20.2.84 NMAC Acid Rain Permit 

d. Units E301, E303, and E304 are subject to federal new source performance standards 

(NSPS) found in CFR Title 40, Part 60, Subpart A - General Provisions, and Subpart 

D and shall comply with both the notification requirements in Subpart A and with the 

specific requirements of Subpart D. 

e. New Source Performance Standards (NSPS) found in 40 CFR 60, Subpart A - 

General Provisions, and Subpart OOO applies to certain pieces of equipment in the 

limestone handling system. Affected units shall comply with both the notification 

requirements in Subpart A and with the specific requirements of Subpart OOO. 

f. Units E301, E302, E303, and E304 are subject to the applicable requirements of 

20.2.14, 20.2.31, 20.2.32 NMAC. Table 1.3 identifies whether the boiler unit is a 

new or existing unit including its vintage designation. 

Table 1.3: Boiler Designation (NMAC) Information 

Unit Vintage 

Number 20.2.31 20.2.32 

20.2.14, 20.2.31, and 20.2.32 NMAC 

E301 1 -- New Coal Burning Equipment 

E302 -- D Existing Coal Burning Equipment 

E303 2 -- New Coal Burning Equipment 

E304 3 -- New Coal Burning Equipment 

g. PNM shall comply with the Opacity, PM, SO2, and NOx emission limitations in 

Table 2.3 in accordance with the schedule listed below: 

(i) For Unit E304, no later than ninety (90) days after completion of 

construction of PM, NOx, and SO2 controls, or by December 31, 2007, 

whichever date is earlier. 

(ii) For Unit E303, no later than ninety (90) days after completion of 

construction of PM, NOx, and SO2 controls, or by June 30, 2008, 

whichever date is earlier. 

(iii) For Unit E301, no later than ninety (90) days after completion of 

construction of PM, NOx, and SO2 controls, or by December 31, 2008, 
NSR Permit No. 0063-M6R1 Page 8 of 33 

Rev. 12/15/05

whichever date is earlier. 

(iv) For Unit E302, no later than ninety (90) days after completion of 

construction of PM, NOx, and SO2 controls, or by May 31, 2009, 

whichever date is earlier. 

h. For each unit, until the baghouses become operational, the permittee shall operate the 

ESPs to control particulate emissions in accordance with ESP applicable conditions 

of the Title V operating permit P062R1 that specify operating, monitoring, 

recordkeeping, and reporting requirements for the ESPs. 

i. Emission Units E701, E702, E703, E704, E705, E706, E707, and E708 (road areas) 

shall comply with the operational requirements specified in Table 1.4. 

Table 1.4, Operational Requirements for Road Areas 

Emission Unit No. Operational Requirements 

E701, E705, and E708 Unit shall be paved, and swept and watered as necessary, to minimize 

emissions of TSP and PM-10 

E702, E703, E704, 

E706, and E707 

Unit shall be watered as necessary to minimize emissions of TSP and 

PM-10 

j. The fly ash silo loading (E505, E506, E518, and E519) and limestone silo loading 

(E803) shall be equipped and operated with fabric filters. The fabric filters shall be 

equipped and operated with devices to monitor the differential pressure drop across 

the filters. The control devices shall be operated and maintained in accordance with 

manufacturer’s specifications, including specifications for pressure drop, in order to 

achieve a minimum 99.5% control of TSP, PM-10, and PM emissions. 

k. The coal pulverizers (E201) shall be entirely enclosed in a structure that is 

maintained and operated in accordance with good air pollution control practices in 

order to minimize particulate emissions. 

l. The emergency generators shall burn only No. 2 Diesel Fuel Oil. 

m. Except for maintenance and testing activities, the emergency generators shall only be 

operated during the unavoidable loss of commercial utility power. Each emergency 

generators shall not operate more than 500 hours per year. 

n. The facility shall not process more than the quantities of raw materials specified in 

Table 1.5 below. 

Table 1.5, Facility-Wide Operational Limits on Raw Materials 

Material Annual Limit 
NSR Permit No. 0063-M6R1 Page 9 of 33 

Rev. 12/15/05

Material Annual Limit 

Coal 8,200,000 tons 

No. 2 Diesel Fuel Oil 2,912,500 gallons 

Limestone 227,000 tons 

o. Coal pile maintenance (E101, E102, E103, and E104), fly ash silo unloading to 

trucks (E507, E508, E509, E510), limestone delivery system(E705), and limestone 

pile maintenance (E802) shall be operated in accordance with good air pollution 

control practices to minimize emissions. 

p. Each boiler (Units E301, E302, E303, and E304) shall be equipped and operated with 

a baghouse in accordance with the schedule in condition 1.g, to meet the emission 

limits specified in Table 2.3, except as otherwise allowed under the applicable 

provisions of 20.2.7 NMAC and 40 CFR 60 Subpart A (E301, E303, and E304 

only). In addition, Control Devices associated with Emission Units E301, E303, and 

E304 are subject to the requirements of 40 CFR 60.11(d). 

Each baghouse associated with the boilers shall be maintained and operated in 

accordance with good air pollution control practices for minimizing emissions. 

Individual boilers shall only be operated when its associated baghouse is achieving a 

control efficiency sufficient to ensure compliance with all applicable particulate 

emission limits listed in this permit. 

q. Prior to the proposed baghouses becoming fully operational, each of the boilers 

(E301, E302, E303, and E304) shall be equipped and operated with an ESP, except 

as otherwise allowed under the applicable provisions of 20.2.7 NMAC and 40 CFR 

60 Subpart A (E301, E302, and E304 only). In addition, Control Devices associated 

with Emission Units E301, E303, and E304 are subject to the requirements of 40 

CFR 60.11. 

Each ESP associated with the boilers shall be maintained and operated in accordance 

with good air pollution control practices for minimizing emissions. Individual 

boilers shall only be operated when their respective ESP is achieving a control 

efficiency sufficient to ensure compliance with all applicable particulate emission 

limits in Table 2.1 and 2.2. 

r. The boilers (E301, E302, E303, and E304) shall be equipped and operated with 

limestone scrubbers. PNM shall not exceed the emission limits in Specific Condition 

2. To the extent necessary to meet the SO2 emission limits and the SO2 control 

efficiency requirements of this permit (Table 2.3), PNM shall add dibasic acid to the 

limestone slurry feed of each scrubber. The limestone scrubbers (E301, E302, E303, 

and E304) shall be maintained and operated in accordance with good air pollution 

control practices for minimizing emissions, except as otherwise allowed under the 
NSR Permit No. 0063-M6R1 Page 10 of 33 

Rev. 12/15/05

applicable provisions of 20.2.7 NMAC and 40 CFR 60 Subpart A (E301, E302, and 

E304 only). 

s. PNM shall implement a duct leak management program on Units E501, E502, E503, 

and E504. The Duct leak management program shall conducted in accordance with 

good air pollution control practices for minimizing emission. All remaining 

combustion gasses shall be exhausted through the primary stack of each unit. 

t. Unit number E301, E302, E303, and E304 shall be equipped with a continuous 

emissions monitoring system (CEMS) for nitrogen dioxide to meet the requirements 

of the acid rain program and the CEMS shall be maintained in accordance with all 

applicable provisions of the acid rain program under 40 CFR 75. 

u. Heat input to these boilers shall not increase as a result of installation of the lowNOx burners. Compliance with this condition shall be provided upon request of the 

Department. Boiler heat input used in this calculation shall be the data submitted in 

accordance with Specific Condition 5.b and 5.c . An increase in heat input solely 

due to an increase in demand is authorized. 

v. Each of the activated carbon silos shall be equipped with a baghouse operated 

according to manufacturer’s guidelines and specification. The baghouse shall have a 

design PM emission rate of 0.0092 grains/scf or less and a design baghouse exhaust 

flow of rate of 578 scfm or less. 

w. The activated carbon shall be introduced into the exhaust stream prior to the 

baghouse used to control particulate matter from the respective boilers. 

x. Each activated carbon baghouse shall be equipped and operated with a device to 

continuously monitor the pressure differential across the baghouse to insure 

continued compliance. 

y. The permittee shall install, maintain, and operate mercury CEMS in accordance with 

the manufacturer’s recommendations. 

z. The next significant revision (0063-M7) shall include condensable emissions and 

PM2.5 emissions, not included in this permit, unless otherwise allowed by the 

Department, in writing, prior to the application being submitted for review. 

2. Emission Limits (20.2.72.210 NMAC, paragraphs A and B.1.; NSPS 40 CFR 60, Subparts 

A, D, and OOO)

a. Table 2.1 contain the maximum allowable emission rates for units E301 (1), E302 

(2), E303 (3), and E304 (4). The emissions from any individual piece of equipment 

shall not exceed the limits listed in the table. 
NSR Permit No. 0063-M6R1 Page 11 of 33 

Rev. 12/15/05

Table 2.1, Maximum Allowable Emission Rates for Units E301 (1), E302 (2), E303 (3), and E304 (4) 

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement 

Compliance 

Method 

1, 2, 3, & 

4 CO 

E301 – 3000 lb/hr 

E302 – 2000 lb/hr 

E303 – 2000 lb/hr 

E304 – 2000 lb/hr 

Per Compliance Method 

20.2.3 NMAC, 40 

CFR 50, 

NSR No. 63-M2 

Quarterly Testing 

1, 2, 3, & 

4 NOx 

E301 – 1,573.7 lb/hr 

E302 – 2,435.3 lb/hr 

E303 – 2,444.4 lb/hr 

E304 – 2,398.1 lb/hr 

24-Hour Average NSR No. 63-M2 

20.2.32 NMAC, CEMS 

1, 2, 3, & 

4 NOx 

E301 – 6892.6 tons/yr 

E302 – 10666.6 

tons/yr 

E303 – 10706.5 

tons/yr 

E304 – 10503.5 

tons/yr 

Daily rolling 365-day Total NSR No. 63-M2 

20.2.32 NMAC, CEMS 

1, 3, & 4 NOx 0.70 lb/MMBtu 3-Hour Average, Rolled Hourly 40 CFR 60.44(a)(3) CEMS 

2 NOx 0.70 lb/MMBtu 3-Hour Average, Rolled Hourly 20.2.32.110.C NMAC CEMS 

1, 3, & 4 NOx 0.45 lb/MMBtu 3-Hour Average, Rolled Hourly 20.2.32.109 NMAC CEMS 

1, 3, & 4 Opacity 20% 6-Minute Average 40 CFR 60.42(a)(2) COMS 

1, 2, 3, & 

4 

TSP4

(Filterable)

E301 – 174.8 lb/hr 

E302 – 173.9 lb/hr 

E303 – 271.6 lb/hr 

E304 – 266.5 lb/hr 

Per Compliance Method NSR No. 63-M2 Quarterly Testing 

1, 2, 3, & 

4 

TSP4

(Filterable)

E301 – 765.8 tons/yr 

E302 – 761.9 tons/yr 

E303 – 1,189.6 

tons/yr 

E304 – 1,167.1 

tons/yr 

Per Compliance Method NSR No. 63-M2 Quarterly Testing 

1, 3, & 4 PM4

(Filterable)

0.1 lb/MMBtu Per Compliance Method 40 CFR 60.42(a)(1) Quarterly Testing 

1, 3, & 4 PM4

(Filterable)

0.05 lb/MMBtu Per Compliance Method 20.2.14.201.A NMAC Quarterly Testing 

2 PM4

(Filterable)

0.05 lb/MMBtu Per Compliance Method 20.2.14.202.A NMAC Quarterly Testing 

1, 2, 3, & 

4 

PM-104

(Filterable)

E301 – 174.8 lb/hr 

E302 – 173.9 lb/hr 

E303 – 271.6 lb/hr 

E304 – 266.5 lb/hr 

Per Compliance Method NSR No. 63-M2 Quarterly Testing 

1, 2, 3, & 

4 

PM-104

(Filterable)

E301 – 765.8 tons/yr 

E302 – 761.9 tons/yr 

E303 – 1,189.6 

tons/yr 

E304 – 1,167.1 

tons/yr 

Per Compliance Method NSR No. 63-M2 Quarterly Testing 
NSR Permit No. 0063-M6R1 Page 12 of 33 

Rev. 12/15/05

Unit 

No.(s) Pollutant Maximum Allowable Emission Rate Averaging Period Applicable Requirement 

Compliance 

Method 

1, 3, & 4 PM-24

(Filterable)

0.02 lb/MMBtu Per Compliance Method 20.2.14.201.B NMAC Note 2 

2 PM-24

(Filterable)

0.04 lb/MMBtu Per Compliance Method 20.2.14.202.B NMAC Note 2 

1, 2, 3, & 

4 SO2

E301 – 7045.8 tpy 

E302 – 7009.5 tpy 

E303 – 10944.4 tpy 

E304 – 10736.9 tpy 

Per Compliance Method 20.2.3 NMAC, 

40 CFR 50 CEMS 

1, 3, & 4 SO2 1.2 lb/MMBtu 3-Hour Average, 

Rolled Hourly 40 CFR 60.43(a)(2) CEMS 

1, 3, & 4 SO2 1.2 lb/MMBtu 3-Hour Average, Rolled Hourly 20.2.31.109.B NMAC CEMS 

2 SO2

Minimum 

72% Control 30-Day Average, Rolled Daily 20.2.31.110.A NMAC CEMS 

1, 2, 3, & 

4 VOC 

E301 – 11.1 lb/hr 

E302 – 11.1 lb/hr 

E303 – 17.3 lb/hr 

E304 – 17.0 lb/hr 

Per Compliance Method NSR No. 63-M2 Note 3 

1 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2

2 PNM shall show compliance either the PM or PM2 limits as required in 20.2.14 NMAC. 

3 Test results that demonstrate compliance with CO emission limits shall also be considered to demonstrate compliance 

with VOC emission limits for the subject emission unit. 

4 The particulate emission limits in this permit (0063M6) only include filterable particulate emissions. Future permitting 

actions shall change the allowable emission limits to include condensable emissions. 

b. Table 2.2 contains the maximum allowable emission rates for Units E301, E302, 

E303, and E304 combined. 

Table 2.2, Maximum Allowable Emission Rates for Units E301-E304 Combined 

Pollutant 

Maximum 

Allowable 

Emission Rate 

Averaging Period Applicable 

Requirement 

Compliance 

Method 

NOx 9,000 lb/hr 24-Hour Average, 

Rolled Hourly 

NSR No. 63-M2, 

40 CFR Part 50 

CEMS 

SO2 13,000 lb/hr 3-Hour Average, 

Rolled Hourly 20.2.31.109.C NMAC 

CEMS 

SO2 0.55 lb/MMBtu 30-Day Average, 

Rolled Daily 20.2.31.109.C NMAC 

CEMS & Process 

Records 

SO2 0.46 lb/MMBtu Annual Average NSR No. 63-M2 

CEMS & Process Records 

1

 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2 

c. Table 2.3 contain additional individual maximum allowable emission rates for Units 

E301, E302, E303, E304 Each After Effective Dates of Condition 1.g. The 

emissions from any individual piece of equipment shall not exceed the limits listed in 

the tables. 
NSR Permit No. 0063-M6R1 Page 13 of 33 

Rev. 12/15/05

Table 2.3: Additional Individual Maximum Allowable Emission Rates for Each Boiler (Units 

E301, E302, E303, E304) After Effective Dates of Condition 1.g.

Pollutant 

Maximum 

Allowable 

Emission Rate 

Averaging Period Applicable 

Requirement 

Compliance 

Method 

NOx 1, 2 0.30 lb/MMBtu 30 day rolling average1 0063-M4 CEMS & Process 

Records 

SO2 90% removal Annual Average 0063-M4 CEMS 

SO2

3 0.250 lb/MMBtu 7-day block average 0063-M4 CEMS & Process 

Records 

PM 6 

(Filterable) 0.015 lb/MMBtu Per Compliance Method 0063-M4 Quarterly Testing 

Opacity 5 20% Six-minute average2 0063-M4 COMS 

PM-2.56

(Filterable) 

E301 – 55.6 lb/hr 

E302 – 55.3 lb/hr 

E303 – 86.4 lb/hr 

E304 – 84.7 lb/hr 

Per Compliance Method 0063-M6 Quarterly Testing 

PM-2.56

(Filterable) 

E301 – 243.5 tons/yr 

E302 – 242.2tons/yr 

E303 – 378.4 tons/yr 

E304 – 371.0 tons/yr 

Per Compliance Method 0063-M6 Quarterly Testing 

1

 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2 2

 For purposes of calculating the thirty (30) day rolling average, NOx emissions for the first three (3) hours of a cold 

startup after coal is fed to the boiler shall be capped at 0.30 lb/MMBtu. Cold startup is defined as a startup when the 

boiler is at ambient indoor temperature measured at the time fuel is first fed to the boiler. 3

 The seven (7) day average emission rate of SO2 at San Juan Units E301, E302, E303, and E304 shall not exceed 

0.250 lb-SO2/MMBtu for each unit, calculated as a block average as measured by SO2 CEMS located downstream of 

the scrubber outlet and any scrubber by-pass return. For purposes of calculating the block average, SO2 emissions 

for the first three (3) hours of a cold startup after coal is fed to the boiler shall be capped at 0.250 lb./MMBtu. Cold 

startup is defined as a startup when the boiler is at ambient indoor temperature measured at the time fuel is first fed 

to the boiler. 4

 The PM average emission rate for each of Units E301, E302, E303, and E304 shall not exceed 0.015 lb-PM/MMBtu, 

as measured by EPA Reference Method 5 stack tests, conducted at least once each calendar quarter at times and 

conditions specified by the Department, and according to test protocols approved by the Department, but in all cases 

under conditions and in a manner no less stringent than described in EPA’s 2004 Clean Air Act National Stack 

Testing Guidance. 5 The opacity limit for San Juan Units E301, E303, and E304 as required by 40 CFR 60.D and E301, E302, E304, and 

E304 as required by this permit shall be twenty (20) percent, averaged over any six (6) minute period except for one 

six (6) minute average per hour of up to twenty-seven (27) percent opacity. This limit shall apply at all times when 

air pollutants are being discharged into the atmosphere, unless PNM demonstrates that any excess opacity reading: 

(a) was caused by a startup, shutdown, malfunction, or emergency, or (b) occurred when both the boiler and all fans 

that move flue gas in the unit were off. Load changes, poor coal quality, air heater cleaning, sootblowing, and high 

ash hoppers shall not excuse any excess opacity reading. Opacity shall be measured in the stack or, if approved by 

EPA, after the outlet of the baghouse and corrected to stack exit. 6

 The particulate emission limits in this permit (0063M6) only include filterable particulate emissions. Future 

permitting actions shall change the allowable emission limits to include condensable emissions. 
NSR Permit No. 0063-M6R1 Page 14 of 33 

Rev. 12/15/05

d. Table 2.4 list the allowable emissions from duct leaks. Compliance with Condition 

Specific Condition 2.d shall be determined by implementation of a duct leak 

management program. 

Table 2.4, Maximum Allowable Emission Rates for Duct Leaks After the Effective Dates of 

Condition 1.g 

Maximum Allowable Emission Rates

in Pounds per Hour (pph) and Tons per Year (tpy) 

TSP PM-10 NOx CO SO2

Emission 

Unit No. 

pph tpy Pph tpy pph tpy pph tpy pph tpy 

E501 11.3 45.0 4.5 18.1 0.3 0.8 0.5 2.0 1.1 4.5 

E502 12.4 50.0 4.9 20.0 0.4 0.8 0.4 1.5 1.2 4.9 

E503 12.6 50.4 5.0 20.1 -- 0.8 0.2 1.0 1.3 5.0 

E504 14.5 58.3 5.8 23.3 0.3 1.0 0.3 1.1 1.5 5.8 

e.Table 2.5 lists the allowable emission limits for non-boiler emission units. The emissions 

from any individual piece of equipment shall not exceed the limits listed in the table. 

Table 2.5, Maximum Allowable Emission Rates for Non-Boiler Emission Units

Maximum Allowable Emission Rates

in Pounds per Hour (pph) and Tons per Year (tpy) 

TSP PM-10 

Emission 

Unit No. 

pph tpy pph tpy 

E101 1.6 7.0 -- 1.6 

E102 1.6 7.0 -- 1.6 

E103 1.6 7.0 -- 1.6 

E104 1.6 7.0 -- 1.6 

E201 7.3 32.0 2.8 12.3 

E202 -- 0.6 -- -- 

E203 -- 0.6 -- -- 

E406 9.4 41.0 9.4 41.0 

E407 9.1 39.8 9.1 39.8 

E408 9.1 39.8 9.1 39.8 

E409 12.5 54.9 12.5 54.9 

E410 -- 1.0 -- 1.0 

E411 1.3 5.8 1.3 5.8 

E505 -- 0.5 -- -- 

E506 -- 0.5 -- -- 

E507 0.6 2.4 -- 1.1 

E508 0.6 2.4 -- 1.1 

E509 0.9 3.7 -- 1.8 

E510 0.8 3.7 -- 1.7 
NSR Permit No. 0063-M6R1 Page 15 of 33 

Rev. 12/15/05

Maximum Allowable Emission Rates

in Pounds per Hour (pph) and Tons per Year (tpy) 

TSP PM-10 

Emission 

Unit No. 

pph tpy pph tpy 

E518 -- -- -- -- 

E519 -- -- -- -- 

E704A 0.9 3.9 -- 1.2 

E707 2.3 10.3 0.8 3.3 

Paved Roads 

(E701, E705, E708) 12.2 53.5 2.4 10.4 

Unpaved Roads 

(E702, E703, 

E704B, ,E706) 9.0 39.5 2.7 6.8 

E801 0.7 3.1 -- 1.5 

E802 2.4 10.4 -- 1.6 

E803 -- -- -- -- 

S901 -- -- -- -- 

S902 -- -- -- -- 

S903 -- -- -- -- 

S904 -- -- -- -- 

Note: E704A is the front end loader emissions from travel around the coal piles. E704Bis front end 

loader emissions on unpaved roads. 

 “--“ indicates that the emissions are less than 0.5 pph or 0.5 tpy and emission limits are not required for this permit.

f. Unless otherwise required by this permit or another applicable regulation, 

compliance with the NOx emission limits shall be determined on a unit-specific basis 

using data from NOx CEMS that have been installed, calibrated, and operated in 

accordance with 40 CFR. 75 and any other applicable requirement. 

g. Unless otherwise required by this permit or another applicable regulation, 

compliance with the SO2 emission limits shall be determined on a unit-specific basis 

using data from SO2CEMS that have been installed, calibrated, and operated in 

accordance with 40 CFR 75 and any other applicable requirement. 

h. Each affected facility as defined in 40 CFR 60 Subpart OOO of the limestone 

handling system, including the limestone silo, shall meet the standards for particulate 

matter specified in 40 CFR 60.672. 

i. In accordance with 20.2.61.109. NMAC, the owner or operator of stationary 

combustion equipment shall not permit, cause, suffer or allow visible emissions from 

the stationary combustion equipment to equal or exceed an opacity of 20 percent; 

provided, however, stationary combustion equipment which is regulated by Parts 
NSR Permit No. 0063-M6R1 Page 16 of 33 

Rev. 12/15/05

20.2.10 NMAC through 20.2.18 NMAC, 20.2.37 NMAC, and 20.2.42 NMAC, and 

any other Part of Chapter 2 which specifically limits particulate emissions is 

exempted from this Part. The emergency generators are subject to 20.2.61.109 

NMAC. 

j. Emission Units E406, E407, E408, E409, E410, and E411 (cooling towers) shall be 

maintained and operated according to manufacturer’s recommendations and good 

engineering practices. The pump’s circulating water rate, the water’s total dissolved 

solids (TDS) content, and the cooling tower’s drift rate shall not exceed the values 

specified in Table 2.6 below. 

Table 2.6, Circulating Rate, TDS, and Drift Rate Operational Limits for Cooling Towers 

Emission 

Unit No. 

Circulating Water Rate 

(gallons/minute)

TDS Content 

(lb/gallon)

Drift Rate 

(%) 

E406 170,000 0.0459 0.002 

E407 165,000 0.0459 0.002 

E408 220,000 0.0459 0.0015 

E409 227,500 0.0459 0.002 

E410 5,000 0.03756 0.002 

E411 30,000 0.0292 0.002 

k. The Activated carbon baghouse silos shall be designed and operated so there are no 

visible emissions. 

3. Monitoring

(20.2.72.210.C NMAC, NSPS 40 CFR 60, Subparts A, D, and, OOO) 

a. Table 3.1 identifies the affected units and applicable monitoring requirements. 

Table 3.1 - 

Effected Units Applicable Monitoring Requirements 

E301, E303 and E304 40 CFR 60.45, Subpart D 

E301, E302, E303 and E304 20.2.31.112 NMAC 

The limestone handling system Applicable monitoring requirements in 40 CFR 

60.676. Subpart OOO 

E301, E302, E303, and E304 40 CFR Part 75(NOx, SO2, and CO2 CEMS) 

E301, E303, and E304 40 CFR 60 Subpart A (COMS) 

b. Units E301, E303, and E304 are subject to 40 CFR 60 Subpart D and PNM shall 

operate the COMS for units E301, E303, and E304 as required in 40 CFR 60 Subpart 

D. Although Unit 302 is not an affected unit for purposes of NSPS 40 CFR 60, 

Subpart D, PNM shall install, calibrate, maintain, and operate COMs on Unit E302 
NSR Permit No. 0063-M6R1 Page 17 of 33 

Rev. 12/15/05

per the procedures specified in 40 CFR 60 Subpart D. For units E301, E302, E303, 

and E304 the permittee shall determine compliance with the opacity limits of the 

permit on a continuous basis, using date from the current COMS or an EPA approved 

COMs and an alternative location. All COMs shall be certified or recertified per the 

procedures in 40 CFR Part 60. 

c. The COMS for Unit E302 shall be installed in a location comparable to the COMS 

location of Units E301, E303, and E304, unless otherwise approved by the 

Department. 

d. PNM shall monitor the pressure drop across each fly ash silo baghouse (Units 505 

and 506). 

e. For baghouse associated with the Units E301, E302, E303, and E304, PNM shall 

monitor the pressure drop across each baghouse with a continuous monitoring 

device. The continuous monitoring device shall be designed with an alarm that 

records and signal to the operator any excursion outside the normal operating range 

of the baghouse. The normal operating range of the baghouse shall be determined by 

the manufacture or another Department approved method. 

f. PNM shall monitor the pressure drop across each activated carbon silo baghouse 

(Units E901, E902, E903, and E904) whenever the silos are loaded. The data capture 

rate shall be no less than once every six minutes. At a minimum the record shall 

include the silo designation, date, time, pressure differential, and in the event that the 

pressure differential is not continually monitored, the silo loading status (fan on or 

off). 

g. No less than once per calendar year, PNM shall inspect the coal pulverizers to insure 

they meet the requirements of Specific Condition 1.k 

h. No less than once each calendar year, PNM shall inspect the coal pile maintenance, 

fly ash silo unloading to trucks, limestone delivery, and limestone pile maintenance 

to ensure that the meet the requirements of Specific Condition 1.o of this permit. 

i. PNM shall monitor the operating hours of the emergency generators. 

j. PNM shall monitor the quantities of coal, diesel fuel, and limestone processed. 

k. No less than once each calendar quarter, PNM shall measure the TDS concentration 

of each cooling tower. 

l. For each 24-hour period, the permittee shall monitor the coal flows in each boiler. 
NSR Permit No. 0063-M6R1 Page 18 of 33 

Rev. 12/15/05

m. The permittee shall continually monitor the mercury emissions using CEMS that are 

installed and maintained in accordance with the CEMS manufacturer’s 

recommendations. 

n. For baghouse associated with the Units E505, E506, E518, E519 and E803, PNM 

shall monitor the differential pressure drop across the fabric filters daily. 

4. Recordkeeping 

(20.2.72.210.E NMAC, NSPS 40 CFR 60, Subparts A, D, and OOO) 

a. All records required by this permit shall be maintained on-site for a minimum of five 

(5) years from the time of recording and shall be made available to Department 

personnel upon request, 

b. Table 4.1 identifies the affected units and applicable recordkeeping requirements. 

Table 4.1 – Applicable Record Keeping Requirements 

Affected Units Applicable Recordkeeping Requirements 

E301, E303, and E304 CFR Title 40, Part 60.45. 

E301, E303 and E304 20.2.31.113.B NMAC 

E302 20.2.31.113.A NMAC 

E301, E303, and E304 20.2.32.115 NMAC 

limestone handling system 40 CFR 60.676 

E301, E302, E303 and E304 40 CFR 75 

c. The Permittee shall keep the following haul road (Units E701, E702, E704, E705, 

E706, and E707) records 

1) the times and location of water application, 

2) the times and location of sweeping, 

3) amount of water applied to the haul road 

4) occurrences of visual inspections. 

d. PNM shall keep records of the pressure drop across each fly ash silo baghouse (Units 

505 and 506). 

e. For baghouse associated with the Units E301, E302, E303, and E304, PNM shall 

record the pressure drop across each baghouse with a continuous monitoring device. 

The continuous monitoring device shall be designed with an alarm that records and 

signals to the operator any excursion outside the normal operating range of the 

baghouse. The normal operating range of the baghouse shall be determined by the 

manufacture or another Department approved method. 
NSR Permit No. 0063-M6R1 Page 19 of 33 

Rev. 12/15/05

f. PNM shall keep records of the pressure drop across each activated carbon silo 

baghouse (Units E901, E902, E903, and E904). 

g. PNM shall keep the manufacturer’s documentation onsite that indicates the proper 

range that the pressure drop should be during normal operations of each activated 

carbon silo baghouse (Units E901, E902, E903, and E904). 

h. PNM shall keep manufacturer’s documentation onsite indicting that each activated 

carbon silo baghouse (Units E901, E902, E903, and E904) was designed to control 

PM emissions 0.0092 grains/scf or less and design baghouse exhaust flow rate is 578 

scfm or less. 

i. PNM shall record the results of the inspections required in Specific Condition 3.g for 

the coal pulverizes. 

j. PNM shall record the results of the inspection required by Specific Condition 3.h for 

the coal pile maintenance, fly ash silo unloading to trucks, limestone delivery, and 

limestone pile maintenance. 

k. PNM shall record the monthly and 12 month total operating hours of each emergency 

generator. 

l. PNM shall maintain quarterly records of the quantities of coal, diesel fuel, and 

limestone processed. 

m. No less than once each calendar quarter, the permittee shall record the TDS 

concentration of each cooling tower. The permittee shall then calculate the 

individual cooling tower emissions, based on the maximum capacity of the 

circulating water pump(s) for each unit, the actual TDS content, and the units 

specific drift rate. The circulating water rate and drift rate for each unit is included in 

Table 2.6. 

n. The duct leak management practices shall be reviewed to insure that PNM is meeting 

good air pollution control practices requirements. 

o. For each boiler, the 24-hour heat input value shall be calculated by multiplying the 

24-hour coal flow rate with the 7-day rolling average Btu content of the coal. The 7-

day rolling average Btu content of the coal shall be derived from as delivered coal 

sample analysis. In the event no coal is delivered for 7 or more days, the last 7-day 

rolling average will be used. 

p. PNM shall keep records of the “as-delivered” heat content of the coal. The heat 

content of the coal shall be analyzed using an appropriate ASTM method, in 

accordance with the requirements of the coal contract. 
NSR Permit No. 0063-M6R1 Page 20 of 33 

Rev. 12/15/05

q. For each boiler, the 365-day rolling total heat input shall be calculated as a 

summation of the 24-hour heat input value calculated in condition 4.o. 

r. For the first twelve (12) months of operation after the low-NOx burners are installed, 

for each Unit, PNM shall maintain records detailing the operational parameters 

implemented to achieve the NOx emission limits. 

s. The permittee shall keep records of the mercury CEMS outputs, calculations, and 

any CEMS maintenance activity necessary to show accurate and continual mercury 

emission rates were recorded. 

t. For baghouse associated with the Units E505, E506, E518, E519 and E803, PNM 

shall keep records of the differential pressure drop across the fabric filters. 

5. Reporting

(20.2.72 NMAC, Sections 210 and 212; NSPS 40 CFR 60, Subparts A, D, and OOO) 

a. Table 5.1 identifies the affected units and applicable reporting requirements. 

Table 5.1: 

Affected Units Applicable Reporting Requirements 

E301, E303 and E304 CFR Title 40, Part 60, Subpart D 

E301, E303 and E304 20.2.31 NMAC, Section 113.B 

E302 20.2.31 NMAC, Section 113.A 

E301, E303, and E304 20.2.32.115 NMAC 

The limestone handling system 

(E801, E802, E803) 

Applicable reporting requirements in 40 

CFR 60.676. 

E301, E302, E303 and E304 40 CFR 75 

b. Within 90 days of permit issuance the permittee shall calculate and report to the 

Department the historical 12-month rolling total heat input rate for each boiler for the 

time period of July 1, 2001 through September 30, 2006. The historical 12-month 

rolling total heat input rate for each boiler shall be calculated in accordance with 

Specific Condition 4.p and 4.q. 

c. Upon written request by the Department, PNM shall summarize and report the 365-

day rolling total heat input values calculated in Specific Condition 4.q. 
NSR Permit No. 0063-M6R1 Page 21 of 33 

Rev. 12/15/05

6. Compliance Test 

(20.2.72 NMAC Sections 210.C and 213; NSPS 40 CFR 60, Subparts A, D, and OOO) 

a. No additional initial compliance testing is required for Permit No. 0063-M6. The 

quarterly testing already required by Specific Condition 6.b is sufficient to insure 

compliance with the applicable standards. 

b. PNM shall conduct quarterly testing on the boilers (E301, E302, E303, and E304) for 

each pollutant listed in Table 6.1 in accordance with their respective testing methods. 

Table 6.1: Quarterly testing Requirements 

Pollutant Reference Method 

CO 1 Methods 1-4 and 10 

PM 

TSP 

PM10 2

PM2.5 2

Method 1-5 

1 Test results that demonstrate compliance with CO emission limits shall also be considered to 

demonstrate compliance with VOC emission limits for the subject emission unit.

2 PNM may use Method 5 testing to demonstrate compliance with the PM10 and PM 2.5 standards. 

c. PM10 and PM2.5 particulate emissions include condensable particulates. Particulate 

testing shall include testing for condensable emissions when appropriate. 

Condensable testing is waived until an appropriate method is established by the 

USEPA. 

d. Once every 5th calendar quarter, PNM shall conduct compliance testing to determine 

actual emissions for PM10 and PM2.5 (if a test method has been established) from 

each unit. The initial test shall be conducted prior to January 1, 2010, and different 

units may be tested during different calendar quarters. Testing for actual emissions 

is waived if an appropriate test method has not been established by USEPA. 

If testing is waived beyond January 1, 2010, the test shall be performed with in 6-

months of being notified by the Department of an available EPA method test or 

within 1-year of the EPA method test becoming available, whichever is sooner. 

e. PM10 testing is waived until an appropriate test method is established by the 

USEPA. 

f. PM2.5 testing is waived until an appropriate test method is established by the 

USEPA. 

g. PNM shall maintain, calibrate, and operate CEMS at San Juan Units E301, E303, and 

E304 to measure accurately and continuously opacity and the emissions of SO2, 
NSR Permit No. 0063-M6R1 Page 22 of 33 

Rev. 12/15/05

NOx, and the exhaust flow rate from each unit in full compliance with the 

requirements of 40 CFR Parts 60 and 75, including requirements for heat input rate 

measurements. Although Unit 302 is not an affected unit for purposes of NSPS 40 

CFR 60, Subpart D, PNM shall maintain, calibrate, and operate CEMS at San Juan 

Unit E302 to measure continuously opacity and the emissions of SO2, NOx, and the 

exhaust flow rate from each unit in accordance with the requirements of 40 CFR 

Parts 60 and 75, including requirements for heat input rate measurements. 

h. Compliance test requirements from previous permits (if any) are still in effect, unless 

the tests have been satisfactorily completed. 

i. Additional compliance tests may be imposed if it is deemed necessary by the 

Department to determine whether the source is in compliance with applicable 

regulations or permit conditions. 

j. These tests shall be conducted within sixty (60) days after the unit(s) achieve the 

maximum normal production. If the maximum normal production rate does not 

occur within one hundred twenty (120) days of source startup, then the tests must be 

conducted no later than one hundred eighty (180) days after initial startup of the 

source. 

k. For all periodic monitoring events, except when a federal or state regulation is more 

stringent , three test runs shall be conducted at 90% or greater of the full normal load 

as stated in this permit, or in the permit application if not in the permit, and at 

additional loads when requested by the Department. If 90% load cannot be achieved, 

the monitoring will be conducted at the maximum achievable load under prevailing 

operating conditions. 

l. The compliance tests required shall be performed in accordance with EPA Reference 

Methods 1 through 4, Method 5 (for demonstrating compliance with PM, TSP, and 

PM10), Method 10 for CO and contained in CFR Title 40, Part 60, Appendix A, and 

with the requirements of Subpart A, General Provisions, 60.8(f). If allowed under 

U.S.EPA policy and approved by the Department in advance, PNM may demonstrate 

compliance with PM10 using an alternative method. 

m. Within 10 days of a request by the Department, PNM shall provide temporary Teflon 

lines adjacent to the sampling ports in the stacks at the time of any required 

compliance tests. PNM shall provide adequate access to all required locations to the 

Department personnel during the time of compliance tests and inspections. The 

sampling line shall be made clear of all blockages during compliance tests and 

inspections. 

If you have questions about this permit please call Joe Kimbrell of the AQB New Source Review 

(NSR) Unit in Santa Fe at (505) 476-4347. 
NSR Permit No. 0063-M6R1 Page 23 of 33 

Rev. 12/15/05

cc: Ralph Williams, Class One Services, Inc., 3500 Comanche Rd. NE, Albuquerque, NM 87107

Enclosure: Industry/Consultant Feedback Questionnaire with envelope 
NSR Permit No. 0063-M6R1 Page 24 of 33 

Rev. 12/15/05

SECTION II: GENERAL CONDITIONS

1. Reporting

(20.2.72 NMAC Sections 210 and 212) 

The Permittee shall notify the Department in writing of, or provide the Department with: 

a. the anticipated date of initial startup of each new or modified source not 

less than thirty (30) days prior to the date; 

b. the equipment serial number and the actual date of initial startup of each 

new or modified source within fifteen (15) days after the startup date; 

c. the date when each new or modified emission source reaches the maximum 

production rate at which it will operate within fifteen (15) days after that 

date; 

d. any change of operators within fifteen (15) days of such change; 

e. any necessary update or correction no more than sixty (60) days after the 

operator knows or should have known of the condition necessitating the 

update or correction of the permit. 

2. Records Retention 

Except as provided in the Specific Conditions, records shall be maintained on-site for a 

minimum of two (2) years from the time of recording and shall be made available to 

Department personnel upon request. Sources subject to 20.2.70 NMAC “Operating Permits” 

shall maintain records on-site for a minimum of five (5) years from the time of recording. 

3. Posting/Retention of the Permit 

The Permittee shall post a copy of this permit in plain view at the Facility at all times. If it is 

not possible to post a copy of the permit because the Facility is unmanned, a copy of this 

permit shall be kept at the nearest business office and the Permittee shall post a notice in a 

conspicuous place at the Facility. The notice must state the Facility name and ownership, the 

air quality permit number, address and phone number of the office where the permit is 

located, and the Air Quality Bureau address and phone number in Santa Fe. A copy of this 

permit shall be made available to Department personnel for inspection upon request. 
NSR Permit No. 0063-M6R1 Page 25 of 33 

Rev. 12/15/05

4. Right to Access Property and Review Records

(NMSA 1978, Section 74-2-13) 

The Department shall be given the right to enter the Facility at all reasonable times to verify 

the terms and conditions of this permit. The company, upon either a verbal or written 

request from an authorized representative of the Department, shall produce any records or 

information necessary to establish that the terms and conditions of this permit are being met. 

5. Contents of Permit Application 

(20.2.72.210.A NMAC) 

Pursuant to 20.2.72.210 A NMAC, the contents of a permit application specifically identified 

by the Department shall become the terms and conditions of the permit or permit revision. 

Unless modified by conditions of this permit, the Permittee shall construct or modify and 

operate the Facility in accordance with all representations of the application and 

supplemental submittals that the Department relied upon to determine compliance with 

applicable regulations and ambient air quality standards. If the Department relied on air 

quality modeling to issue this permit, any change in the parameters used for this modeling 

shall be submitted to the Department for review. Upon the Department’s request, the 

Permittee shall submit additional modeling for review by the Department. Results of that 

review may require a permit modification. 

6. Asbestos Demolition

Before any asbestos demolition or renovation work, the Permittee shall determine whether 

40 CFR 61 Subpart M, National Emissions Standards for Asbestos applies. If required, the 

Permittee shall notify the Department using forms furnished by the Department. 

7. Revisions and Modifications

(20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4) 

a. Any future physical changes or changes in the method of operation may constitute a 

modification as defined by 20.2.72 NMAC, Construction Permits. Unless the source 

or activity is exempt under 20.2.72.202 NMAC, no modification shall begin prior to 

issuance of a permit. 

b. Changes in plans, specifications, and other representations stated in the application 

documents shall not be made if they cause a change in the method of control of 

emissions or in the character of emissions, or will increase the discharge of 

emissions. Any such proposed changes shall be submitted as a revision or 

modification. 
NSR Permit No. 0063-M6R1 Page 26 of 33 

Rev. 12/15/05

c. Modifications or revisions to this permit shall be processed in accordance with 

20.2.72 NMAC. 

8. Notification to Subsequent Owners

(20.2.72 NMAC Sections 7.P.1 and 212.C) 

a. The permit and conditions apply in the event of any change in control or ownership 

of the Facility. No permit modification is required in such case. However, in the 

event of any such change in control or ownership, the Permittee shall notify the 

succeeding owner of the permit and conditions and shall notify the Department of the 

change in ownership within fifteen (15) days of that change. 

b. Any new owner or operator shall notify the Department, within thirty (30) days of 

assuming ownership, of the new owner’s or operator’s name and address. 

9. Permit Cancellations

(20.2.72 NMAC) 

a. The Department shall automatically cancel any permit for any source which ceases 

operation for five (5) years or more, or permanently. Reactivation of any source 

after the five (5) year period shall require a new permit. 

b. The Department may cancel a permit if the construction or modification is not 

commenced within two (2) years from the date of issuance or if, during the 

construction or modification, work is suspended for a total of one (1) year. 

10. Emissions Limit Averaging Times and Energy Input Limits

Emissions limits associated with the energy input of a Unit, i.e. lb/MMBtu, shall apply at all 

times unless stated otherwise in a Specific Condition of this permit. The averaging time for 

each emissions limit, including those based on energy input of a Unit (i.e. lb/MMBtu) is one 

(1) hour unless stated otherwise in a Specific Condition of this permit or in the applicable 

requirement that establishes the limit. 

11. Testing and Records for Engines and Turbines Equipped with Emissions Controls

For engines or turbines equipped with catalytic converters and/or air-fuel ratio (AFR) 

controllers, or similar device which performs the same function of maintaining appropriate 

air and fuel ratios, records shall be made and maintained of the following requirements. The 

Permittee shall retain these records for a period of at least two (2) years from the date of 

generation and the records shall be made available to Department personnel upon request. 
NSR Permit No. 0063-M6R1 Page 27 of 33 

Rev. 12/15/05

a. For each AFR controlling type device, demonstrate that the manufacturer's or 

supplier's recommended maintenance is performed, including replacement of oxygen 

sensor as necessary for oxygen-based controllers. Verification of proper operation of 

the controller shall be demonstrated at least quarterly by measuring and recording 

exhaust oxygen or NOx concentrations with a properly calibrated portable analyzer 

as specified in the most current version of the SOP for "Use of Portable Analyzers in 

Performance Tests". 

b. For any engine equipped with a non-selective catalytic converter, demonstrate the 

maintenance of the NOx and CO reduction efficiency across the catalyst bed. This 

test shall be performed within ninety (90) days following initial startup and on a 

quarterly basis thereafter, unless an alternative testing schedule is specified by the 

Department. Properly calibrated portable analyzers are acceptable for this 

demonstration. The test shall be conducted at ninety percent (90%) or greater of full 

load and shall include the exhaust volume flow rate (dscf) and the NOx and CO 

emission rate (lb/hr). (20.2.72 NMAC, Section 210.B(4)). 

c. For any engine equipped with a selective catalytic converter, demonstrate the 

maintenance of the CO reduction efficiency across the catalyst bed. This test shall be 

performed within ninety (90) days following initial startup and on a quarterly basis 

thereafter, unless an alternative testing schedule is specified by the Department. 

Properly calibrated portable analyzers are acceptable for this demonstration. The test 

shall be conducted at ninety percent (90%) or greater of full load and shall include 

the exhaust volume flow rate (dscf) and the NOx and the CO emission rate (lb/hr). 

(20.2.72 NMAC, Section 210.B(4)). 

12. Operation of Engines Equipped with Catalytic Converters

a. For engines equipped with catalytic converters, the engine shall not be operated 

without the catalytic converter, specifically including catalyst maintenance periods. 

During periods of catalyst maintenance, the Permittee shall either (1) shut down the 

engine(s); or (2) replace the catalyst with a functionally equivalent spare to allow the 

engine to remain in operation. 

b. Any engine equipped with a catalytic converter shall also have an AFR controlling 

device, or similar device that performs the same function of maintaining an 

appropriate air-fuel ratio. Engines equipped with oxidation catalysts are not required 

to operate with an AFR. 

13. Flares 

a. Flares used as control devices to comply with any NSPS (40 CFR Part 60) or 

NESHAP (40 CFR Part 61) requirement shall be tested in accordance with the 
NSR Permit No. 0063-M6R1 Page 28 of 33 

Rev. 12/15/05

requirements contained in 40 CFR 60, Subpart A, General Provisions, paragraph 60.8 

(performance tests) and 60.18 (general control device requirements). Flares used as 

control devices to comply with any MACT requirement (40 CFR Part 63) shall be 

tested in accordance with the requirements contained in 40 CFR 63, Subpart A, 

General Provisions, Section 63.7 (performance tests) and 63.11 (general control 

device requirements). 

b. Any flares that are operated at this Facility are authorized to have emissions resulting 

only from the pilot flame, unless otherwise approved by Specific Conditions of this 

permit. 

14. Compliance Testing Procedures

If this permit requires any compliance testing, the Permittee shall notify the Department at 

least thirty (30) days before the test date and allow a representative of the Department to be 

present at the test. The Permittee shall submit a testing protocol to the Department at least 

thirty (30) days before the test date and shall observe the following testing procedures: 

a. The test protocol and compliance test report shall conform to the standard format 

specified by the Department. The most current version of the format may be 

obtained from the Enforcement and Compliance Section of the Air Quality Bureau. 

b. All compliance tests required by this permit, unless otherwise specified by Specific 

Conditions of this permit, shall be conducted in accordance with the requirements of 

CFR Title 40, Part 60, Subpart A, General Provisions, and the following EPA 

Reference Methods as specified by CFR Title 40, Part 60, Appendix A: 

i. Methods 1 through 4 for stack gas flowrate 

ii. Method 5 for TSP 

iii. Method 7E for NOX (test results shall be expressed as nitrogen dioxide (NO2) 

using a molecular weight of 46 lb/lb-mol in all calculations (each ppm of NO/NO2 

is equivalent to 1.194 x 10-7 lb/SCF) 

iv. Method 9 for opacity 

v. Method 10 for CO 

vi. Method 6C for SO2

vii. Method 29 for metals 

viii. Method 201 for filterable PM10 

ix. Method 202 for condensable PM10 

x. Method 320 for organic Hazardous Air Pollutants (HAPs) 

xi. Method 25A for VOC reduction efficiency. 

Alternative test method(s) may be used if the Department approves the change.
NSR Permit No. 0063-M6R1 Page 29 of 33 

Rev. 12/15/05

Emission limit test results for each pollutant (except opacity) shall be reported in 

pounds per hour (unless otherwise specified) and tons per year. Opacity shall be 

reported in percent. Test result numerical values shall not be truncated or rounded, 

and shall be recorded and reported to the number of significant figures corresponding 

to the full accuracy inherent in the testing instrument or Method test used to obtain 

the data. 

c. Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval 

of the Department. A justification for this proposal must be provided along with a 

contemporaneous fuel gas analysis (preferably on the day of the test) and a recent 

fuel flow meter calibration certificate (within the most recent quarter). 

d. Unless otherwise indicated by Specific Conditions or regulatory requirements, the 

default time period for each test run shall be 60 minutes and each performance test 

shall consist of three separate runs using the applicable test method. For the purpose 

of determining compliance with an applicable emission limit, the arithmetic mean of 

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 must be discontinued because of 

forced shutdown, failure of an irreplaceable portion of the sample train, extreme 

meteorological conditions, or other circumstances, beyond the owner or operator's 

control, compliance may, upon the Department approval, be determined using the 

arithmetic mean of the results of the two other runs. 

e. Testing of emissions shall be conducted with the emissions unit operating at 90 to 

100 percent of the maximum operating rate allowed by the permit. If it is not 

possible to test at that rate, the source may test at a lower operating rate, subject to 

the approval of the Department. 

i. Testing performed at less than 90 percent of permitted capacity will limit 

emission unit operation to 110 percent of the tested capacity until a new test is 

conducted. 

ii. If conditions change such that unit operation above 110 percent of tested 

capacity is possible, the source must submit a protocol to the Department 

within 30 days of such change to conduct a new emissions test. 

f. Pursuant to 20.2.72.210.C NMAC, for combustion sources with stacks, the Permittee 

shall also provide a one-quarter (1/4) inch stainless steel sampling line adjacent to 

the sampling ports and extending down to within four (4) feet above ground level to 

provide access for future audits. The line shall extend into the stack a distance of 1/4 

the stack diameter, but not less than one inch from the stack wall. The sampling line 

shall be maintained clear of blockage at all times. This line shall be in place at the 

time of any required compliance tests. For any source for which compliance tests are 
NSR Permit No. 0063-M6R1 Page 30 of 33 

Rev. 12/15/05

not required or for previously existing sources this line shall be installed no later than 

one hundred and eighty (180) days from the date of this permit. 

g. As an alternative, the Permittee may provide a portable sampling line that is readily 

available which allows the Department to safely obtain representative stack gas 

samples at the time of compliance audits or site inspections. 

h. A physical configuration of the Facility that conforms to the emissions testing 

requirements of 20.2.72.210.C NMAC and of 40 CFR 60.8(e), which is imposed 

under the authority of 20.2.72.210.C.4 NMAC. 

15. Compliance Test Submittals

Unless otherwise specified by a Specific Condition of this permit, all compliance test reports 

that are required by Specific Condition 6 Compliance Testing shall be submitted to the 

Department as follows. 

a. Initial compliance test reports shall be submitted to the Department’s Program 

Manager, Compliance and Enforcement within thirty (30) days from the test 

completion date. Additionally, a copy of each initial compliance test report that is 

submitted to the Department shall be retained by the Permittee as long as the 

Permittee owns and operates the tested unit. 

b. Periodic compliance test reports shall be retained at the Facility, or if the Facility is 

unmanned, at the nearest business office closest to the Facility, for no less than two 

(2) years from the date that the periodic compliance test was completed. Periodic 

compliance test reports shall be made available to Department personnel upon 

request. 

16. General Monitoring/Compliance Testing Requirements 

These requirements do not supersede or relax requirements of federal regulations. 

a. The following monitoring and/or testing requirements shall be used to determine 

compliance with applicable requirements and emission limits. Any sampling, 

whether by portable analyzer or EPA reference method, that measures an emission 

rate over the applicable averaging period greater than an emission limit in this permit 

constitutes noncompliance with this permit. The Department may require, at its 

discretion, additional tests pursuant to EPA Reference Methods at any time, 

including when sampling by portable analyzer measures an emission rate greater than 

an emission limit in this permit; but such requirement shall not be construed as a 

determination that the sampling by portable analyzer does not establish 

noncompliance with this permit and shall not stay enforcement of such 

noncompliance based on the sampling by portable analyzer. 
NSR Permit No. 0063-M6R1 Page 31 of 33 

Rev. 12/15/05

b. If the emission unit is shutdown at the time when periodic monitoring is due to be 

accomplished, the Permittee is not required to restart the unit for the sole purpose of 

performing the monitoring. Using electronic or written mail, the Permittee shall 

notify the Department’s Enforcement Section of a delay in emission tests prior to the 

deadline for accomplishing the tests. Upon recommencing operation, the Permittee 

shall submit any pertinent pre-test notification requirements set forth in the current 

version of the Department’s Standard Operating Procedures For Use Of Portable 

Analyzers in Performance Test, and shall accomplish the monitoring. 

c. The requirement for monitoring during any monitoring period is based on the 

percentage of time that the unit has operated as follows: 

i. If the emission unit has operated for more than 25% of a monitoring period, then 

the Permittee shall conduct monitoring during that period. 

ii. If the emission unit has operated for 25% or less of a monitoring period then the 

monitoring is not required. After two successive periods without monitoring, the 

Permittee shall conduct monitoring during the next period regardless of the time 

operated during that period, except that for any monitoring period in which a unit 

has operated for less than 10% of the monitoring period, the period will not be 

considered as one of the two successive periods. 

iii. A minimum of one of each type of monitoring activity shall be conducted during 

any five-year period for sources not subject to 20.2.70 NMAC, Operating Permits. 

d. For all periodic monitoring events, except when a federal or state regulation is more 

stringent, three test runs shall be conducted at 90% or greater of the full normal load 

as stated in this permit, or in the permit application if not in the permit, and at 

additional loads when requested by the Department. If the 90% load cannot be 

achieved, the monitoring will be conducted at the maximum achievable load under 

prevailing operating conditions except when a federal or state regulation requires 

more restrictive test conditions. The load and the parameters used to calculate it shall 

be recorded to document operating conditions and shall be included with the 

monitoring report that is required to be furnished to the Department. 

e. When requested by the Department, the Permittee shall provide schedules of testing 

and monitoring activities. Compliance tests from previous NSR and Title V permits 

may be re-imposed if it is deemed necessary by the Department to determine whether 

the source is in compliance with applicable regulations or permit conditions. 

f. Monitoring shall become effective 120 days after the date of permit issuance if the 

monitoring is new or in addition to monitoring imposed by an existing applicable 

requirement. Any pre-existing monitoring requirements incorporated in this permit 

shall continue to be in force from the date of permit issuance. 
NSR Permit No. 0063-M6R1 Page 32 of 33 

Rev. 12/15/05

g. Startup, Shutdown and Malfunction Conditions: For operations and equipment 

subject to an NSPS standard pursuant to 40 CFR 60, excess emissions, or operations 

under startup, shutdown, or malfunction shall be addressed in accordance with the 

requirements of 40CFR60.7(c) or 40CFR60.8(c), as appropriate. A Facility subject 

to a NESHAP standard pursuant to 40 CFR 63 shall comply with the requirement for 

a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR 63.6(e)(3). This 

condition is pursuant to 20.2.72.210 NMAC. 

17. Definitions 

a. Natural gas is defined as a naturally occurring fluid mixture of hydrocarbons that 

contains 20.0 grains or less of total sulfur per 100 standard cubic feet (SCF) and is 

either composed of at least 70% methane by volume or has a gross calorific value of 

between 950 and 1100 Btu per standard cubic foot. 

b. “Daylight” is defined as the time period between sunrise and sunset, as defined by 

the Astronomical Applications Department of the U.S. Naval Observatory. (Data for 

one day or a table of sunrise/sunset for an entire year can be obtained at 

http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a Farmers 

Almanac or from http://www.almanac.com/rise/). 

SUBMITTALS TO THE DEPARTMENT

Applications for permit revisions and modifications shall be submitted to: 

Program Manager, Permits Section 

New Mexico Environment Department 

Air Quality Bureau 

1301 Siler Road, Building B 

Santa Fe, New Mexico 87507-3113 

Compliance test protocols, regularly scheduled reports, a copy of test results, and excess emission 

reports, shall be submitted to: 

Program Manager, Compliance and Enforcement Section 

New Mexico Environment Department 

Air Quality Bureau 

1301 Siler Road, Building B 

Santa Fe, New Mexico 87507-3113 
NSR Permit No. 0063-M6R1 Page 33 of 33 

Rev. 12/15/05

REVOCATION

The Department may revoke this permit if the applicant or Permittee has knowingly and willfully 

misrepresented a material fact in the application for the permit. Revocation will be made in writing, 

and an administrative appeal may be taken to the Secretary of the Department within thirty (30) 

days. Appeals will be handled in accordance with the Department's Rules Governing Appeals From 

Compliance Orders. 

APPEAL PROCEDURES

20.2.72.207.F. NMAC provides that any person who participated in a permitting action before the 

Department and who is adversely affected by such permitting action, may file a petition for hearing 

before the Environmental Improvement Board. The petition shall be made in writing to the 

Environmental Improvement Board within thirty (30) days from the date notice is given of the 

Department's action and shall specify the portions of the permitting action to which the petitioner 

objects, certify that a copy of the petition has been mailed or hand-delivered and attach a copy of the 

permitting action for which review is sought. Unless a timely request for hearing is made, the 

decision of the Department shall be final. The petition shall be copied simultaneously to the 

Department upon receipt of the appeal notice. If the petitioner is not the applicant or Permittee, the 

petitioner shall mail or hand-deliver a copy of the petition to the applicant or Permittee. The 

Department shall certify the administrative record to the board. Petitions for a hearing shall be sent 

to: 

Environmental Improvement Board 

1190 St. Francis Drive, Runnels Bldg. 

P.O. Box 26110 

Santa Fe, New Mexico 87502