Bureau of Air 

Curtis State Office Building 

1000 SVI! Jackson. Suite 310 

Topeka, KS 66612 

Rob~n Moser, lv1D, Secretary 

Source ID No. 0210002 

Mr. Jeff Burkett 

Senior Environmental Coordinator 

The Empire District Electric Company 

P.O. Box 127 

Joplin, Missouri 64802 

Department ofllealth & Environment 

July 11,2013 

RE: Air Emission Source PSD Construction Permit- Riverton Power Station 

Dear Mr. Burkett: 

Phone: 785-296-6281 

Fax: 785-291-3953 

llowry@kdheks.gov 

www. kd heks. gov/bar 

Sam BroWI1hl-lck, Cfovcrnor 

Enclosed is the Air Emission Source PSD Construction Permit for the conversion of Unit 12 from 

simple cycle to combined cycle operation at The Empire District Electric Company facility located in Riverton, 

Kansas. Also enclosed is a copy of the Responsiveness Summary. Please review the enclosed Air Emission 

Source Construction Permit carefully, since it obligates The Empire District Electric Company to certain 

requirements. The source ID number listed above should be included in all communications with the Kansas 

Department of Health and Environment (KDHE) in reference to this approval. 

As provided for in K.S.A. 65-3008b(e), an owner or operator may request a hearing within 15 days after 

affirmation, modification or reversal of a permit decision pursuant to subsection (b) ofK.S.A. 65-3008a. In the 

Request for Hearing, the owner or operator shall specify the provision of this act or rule and regulation 

allegedly violated, the facts constituting the alleged violation and secretary's intended action. Such request must 

be submitted to: Director, Office of Administrative Hearings, 1020 S. Kansas Avenue, Topeka, Kansas 66612-

1327. Failure to submit a timely request shall result in a waiver of the right to hearing. 

If you have any questions about the enclosed amendment to the construction permit, or need any 

additional information, please contact me at (785) 296-6281. 

LDL:lv 

Enclosures 

c: Doug Cole, SEDO 

C-10913 

Sincerely, 

~.owr;,~ En 1ronmental Engineer 

Air Permitting Section 
Bureau of Air 

Curtis State Office Building 

1000 SW Jackson, Suite 310 

Topeka, KS 66612-1366 

Robert Moser, MD, Secretary 

Source ID No.: 

Effective Date: 

Depm1ment of llealth & Environment 

AIR EMISSION SOURCE 

CONSTRUCTION PERMIT 

0210002 

July 11, 2013 

Phone: 785-296-6281 

Fax: 785-291-3953 

llowry@kdheks.gov 

www.kdheks.gov/bar 

Sam Brownback, Governor 

Source Name: The Empire District Electric Co. -Riverton Generating Station 

SIC Code: 

NAICS Code: 

Source Location: 

Mailing Address: 

Contact Person 

4911, Electric Services 

221112, Fossil fuel power generation 

7240 Southeast Highway 66 

Riverton, Kansas 66770 

P.O. Box 127 

Joplin, Missouri 64802 

Mr. Jeff Burkett 

Sr. Environmental Coordinator 

Telephone Number (417) 625-4236 

This permit is issued pursuant to K.S.A. 65-3008 as amended. 

I. Description of Activity Subject to Air Pollution Control Regulations 

The Empire District Electric Company (Empire), Riverton Unit 12, a Siemens V84.3A(2) natural gasfired combustion turbine, nominally rated at 150 MW, was originally issued a construction permit on 

October 18,2005 (amended on August 18,2006 and February 5, 2009) and began operation in 2007. 

Empire plans to convert the existing Riverton Unit 12 simple cycle combustion turbine to a combined 

cycle unit, with a nominal capacity of 250 MW (1963 MMBtu/hr). The proposed combined cycle unit 

will replace the capacity and energy provided by coal fired boilers Unit 7 ( 426 MMBtu/hr) and Unit 8 

(600 MMBtu/hr), which will both be retired in conjunction with the completion of this project. Empire 

plans to complete this conversion by June, 2016. 

Page 1 of 16 
Modifications will include a heat recovery steam generator (HRSG) with supplemental natural gas duct 

firing (duct burners) and a condensing steam turbine generator. A selective catalytic reduction (SCR) 

system will control oxides of nitrogen (NOx). A carbon monoxide catalyst will control carbon monoxide 

(CO) and volatile organic compound (VOC) emissions from the turbine and HRSG. Other equipment 

will include a cooling tower, an 18.6 MMBtu/hr natural gas-fired auxiliary boiler with the capacity to 

produce 15,000 pounds of steam per hour (approximately 18.6 MMBtulhr), a 1102 HP (750 Kw) 

emergency diesel engine and two (2) sulfuric hexafluoride (SF6) insulated circuit breakers. Except in 

the case of an actual emergency, Empire will not operate the emergency diesel engine more than 100 

hours per year in a non-emergency capacity to accommodate maintenance and readiness testing. 

Emissions increases of NOx, sulfur dioxide (S02), carbon monoxide (CO), volatile organic compounds 

(VOC), particulate matter (PM), PM with a diameter less than 10 microns (PM10), PM with a diameter 

less than 2.5 microns (PM25), lead, sulfuric acid mist (SAM), hydrogen fluoride (HF), and carbon 

dioxide equivalent (C02e) were evaluated for this review. This is a major modification of a major 

stationary source for at least one regulated pollutant emitted in excess of the PSD significant emission 

levels. Since there is an increase in PM, PM10, PM2.5, and C02e emissions in excess of the significant 

thresholds, the proposed modification will be subject to the requirements of 40 CFR 52.21, Prevention 

of Significant Deterioration (PSD) as adopted under K.A.R. 28-19-350. 

This project is subject to K.A.R. 28-19-300 (Construction permits and approvals; applicability) because 

the increase in potential-to-emit of PM exceeds 25 tons per year and PM 1 o exceeds 15 tons per year. 

The combined cycle unit (CT+HRSG) is an affected source subject to Title IV of the Federal Clean Air 

Act, Acid Deposition Control. The emergency diesel engine is subject to the requirements of 40 CFR 

60, Subpart IIII, Standards of Performance for Stationary Compression Ignition (CI) Internal 

Combustion Engines. 

An air dispersion modeling impact analysis, an additional impact analysis, and a Best Available Control 

Technology (BACT) determination were conducted as a part of the construction permit application 

process. 

II. Significant Applicable Air Pollution Control Regulations 

The following significant Kansas air quality regulations were determined to be applicable to this source: 

A. K.A.R. 28-19-11, Exceptions due to breakdown or scheduled maintenance - as applied to state 

regulations K.A.R. 28-19-30 through 32 and K.A.R. 28-19-650. 

B. K.A.R. 28-19-30 through 32, Indirect heating equipment emissions. 

C. K.A.R. 28-19-275, Special provisions; acid rain deposition. 

D. K.A.R. 28-19-300, Construction permits and approvals; applicability. 

E. K.A.R. 28-19-350, which adopts by reference 40 CFR 52.21, Prevention of significant 

deterioration of air quality. 

Page 2 of 16 
F. K.A.R. 28-19-650, Emissions opacity limits. 

G. K.A.R. 28-19-720, which adopts by reference 40 CFR Part 60, New Source Performance 

Standards. 

H. K.A.R. 28-19-750, which adopts by reference 40 CFR Part 63, National Emission Standards for 

Hazardous Air Pollutants. 

I. 40 CFR Part 60, Subpart A, General Provisions. 

J. 40 CFR Part 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition 

Internal Combustion Engines. 

K. 40 CFR Part 63, Subpart A, General Provisions. 

L. 40 CFR Part 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines. 

M. 40 CFR Part 63 Subpart YYYY, National Emission Standards for Hazardous Air Pollutants from 

Stationary Combustion Turbines. Subpart YYYY, 63.6145 requires initial notification. Owners 

or operator of lean premix gas-fired stationary combustion turbines or diffusion flame gas-fired 

turbines must comply with the initial notification requirements set forth in 40 CFR 63.6145 but 

need not comply with any other requirement of 40 CFR Part 63 Subpart YYYY until EPA takes 

final action to require compliance and publishes a document in the Federal Register. [40 CFR 

63.6095(d)] As of the date on this application, the EPA has not published such a document in 

the Federal Register. 

N. 40 CFR Part 60 Subpart KKKK, Standards of Performance for Stationary Gas Turbines, applies 

to stationary combustion turbines with a heat input at peak load equal to or greater than 10 

MMBtu/hr, based on the higher heating value of the fuel, which commenced construction, 

modification, or reconstruction after February 18, 2005. 

0. 40 CFR Part 60 Subpart De, Standards of Performance for Small Industrial CommercialInstitutional Steam Generating Units applies to the auxiliary boiler. Since the auxiliary boiler 

will fire solely natural gas it is subject to the Reporting and Recordkeeping requirements of 40 

CFR Part 60, Subpart De [40 CFR 60.48(c)]. 

P. 40 CFR Part 63 Subpart 40 CFR Part 63 Subpart DDDDD Industrial, Commercial, and 

Institutional Boilers and Process Heaters (Boiler MACT) apply to the auxiliary boiler. Since the 

auxiliary boiler will fire solely natural gas it will not be subject to any emissions limits, but 

rather will be subject to a work practice standard that requires an annual tune-up in lieu of 

emission limits. 

Page 3 of 16 
Q. 40 CFR Part 72 through Part 78, Acid Rain Program (ARP), applies to utility units. A utility unit 

is defined as a unit owned or operated by a utility that serves a generator in any state that 

produces electricity for sale. Unit 12, when converted to a combined cycle operation, will 

continue to be subject to the ARP. The ARP requires various pollutant monitors in addition to 

possession of S02 allowances for each ton of S02 emitted. The current ARP permit, under 

which unit 12 currently operates will be modified as the project is completed. 

III. Air Emission Unit Technical Specifications 

The following equipment or equivalent is approved. 

A. Combined cycle combustion unit (CT+HRSG)- Conversion of one (I) Siemens Westinghouse 

Model V84.3A(2) simple cycle combustion turbine/generator, known as emission Unit 12, 

equipped with dry low NOx burners, to a combined cycle operation, burning natural gas. The 

manufacturer's estimated performance is 250 MW. The combined cycle unit includes a heat 

recovery steam generator (HRSG) with supplemental natural gas duct firing (duct burners) and a 

condensing steam turbine generator with SCR and CO catalyst 

B. One mechanical draft cooling tower with high efficiency drift eliminator to reduce aerosol and 

particulate emissions from the tower. 

C. One 750 Kw emergency diesel engine. 

D. One 18.6 Mm Btu/hr natural gas-fired auxiliary boiler with the capacity to produce 15,000 

pounds of steam per hour. The auxiliary boiler is designed to operate when the combined cycle 

unit is in a brief period of shutdown and for startup. 

E. Two (2) Sulfur Hexafluoride (SF6)-insulated circuit breakers. 

IV. Air Emissions Estimates from the Proposed Activity 

The air emissions estimates are shown below: 

Baseline Actual Emissions and Projected Actual Emissions 

(tons per year) 

Units 7 Total Projected Actual Unit 12 I· Baseline Unit 12 &8 Baseline Actual Emissions PSD Pollutant Baseline Actual (Unit 12 Actual Units 7, 8 Increase Significance Type Actual (before & Unit 12 After Combined Cycle Threshold 

Project) (before Project) Project minus 

Project) Total Baseline) 

NOx 1120 34 1154 67 -1087 40 

Page 4 of 16 
so2 5004 1 5005 12 -4993 40 

co 90 3 93 60 -33 100 

voc 10 0.3 10.3 47.3 37 40 

Lead 0.5 -- 0.5 4.lx10-5 -0.5 0.6 

SAM 2 0.1 2.1 6.93 4.83 7 

HF 25 -- 25 1.69x10·5 -25 3 

PM 91 7 98 132 34 25 

PM to 66 7 73 132 59 15 

PM2.s 26 7 33 132 99 10 

C02e 640,234 123,604 763,838 1,020,590 256,752 75,000 

V. Air Emission Limitations 

A. The BACT emission limitations established in this permit apply to the combined cycle unit 

(CT+HRSG) at all times, including startup, shutdown and malfunction, except as provided in 

Section VII. Performance Testing and Compliance, H. Malfunction, of this permit. 

B. K.A.R. 28-19-650 (a)(3): Opacity of visible emissions from all emission units shall not exceed 

20 percent. 

C. Particulate matter emissions from all indirect heating equipment are limited to the amount 

determined by the following equation [K.A.R. 28-19-3l(a)]: 

A = 1. 026 II0233 

Where: A= the allowable emission rate in lb I I 06 Btn 

I =the total heat input of all boilers in 106 Btu 

D. The NO, emissions from the combined cycle unit (CT+HRSG) shall meet the applicable 

emission limits specified in 40 CFR 60.4320(a). NO, emission limits shall not exceed the limits 

specified in Table 1 to Subpart KKKK of Part 60-Nitrogen Oxide Emission Limits for New 

Stationary Combustion Turbines. The NO, emission limit specified in 40 CFR 60.4350(h) is 15 

ppm@ 15% 0 2 on a 30 unit operating day rolling average. 

E. The S02 emissions from the combined cycle unit (CT +HRSG) shall meet the applicable 

emission limits specified in 40 CFR 60.4330(a) which is 110 Nanogram/joule (0.90 lb/gross 

MW-hr). 

Page 5 of 16 
F. The BACT PM/PM10/PM2.s emissions shall not exceed: 

1. 30.2 lb per hour (front+ back half) for the combined cycle unit (CT + HRSG). 

2. 0.005 lb/MMBtu for the auxiliary boiler. 

3. 0.15 g/bhp-hr for the diesel engine 

4. drift rate of0.0005 percent of inlet flow for the mechanical draft cooling tower 

G. The BACT Greenhouse Gas emissions shall not exceed: 

1. For the combined cycle combustion turbine and duct burners. 

a. C02 emissions are limited to 1,021,770 tons C02/year on a 12-month rolling 

basis, 

and the following equation (Equation G-4 of Section 2.3 of 40 CFR Part 75, 

Appendix G, Revised March 19, 2012): 

(Eq. G-4) 

Where: 

W c02 ~ C02 emitted from combustion, tons/hr. 

MW C02 ~Molecular weight of carbon dioxide, 44.0 lbllb-mole. 

F, ~Carbon based F-factor, 1040 scf/mmBtu for natural gas; 1,420 scf/mmBtu 

for crude, residual, or distillate oil; and calculated according to the procedures in 

section 3.3 .5 of appendix F of 40 CFR, Part 75 for other gaseous fuels. 

H ~Hourly heat iuput in MMBtu, as calculated using the procedures in Section 5 

of Appendix F of 40 CFR, Part 75. 

u,~ 1/385 scf C02 /lb-mole at 14.7 psia and 68 °F. 

b. BACT emission limits are required for C02, only, since it is 99.9% of emissions. 

2. For the Auxiliary boiler. 

a. C02 emissions are limited to 9,512 tons C02/year on a 12-month rolling basis 

and the following equation: 

C02 (lb/MMBtu) ~ Efx (2.20462lb/kg) 

Page 6 of 16 
Where: 

Ef =Emission Factor for C02 in kg C02/MMBtu using specified values for 

natural gas fuel from Table C-1 of 40 CFR Part 98, Subpart C, Revised May 31, 

2013) 

b. BACT emission limits are required for C02, only, since it is 99.9% of emissions. 

3. For the Emergency generator. 

C02 emissions are limited to 59.3 tons C02/year on a 12-month rolling basis and 

the following equation: 

C02 (lb/MMBtu) = Efx (2.20462lb/kg) 

Where: 

Ef =Emission Factor for C02 in lb/MMBtu using specified values for Distillate 

Fuel Oil No.2 from Table C-1 of 40 CFR Part 98, Subpart C, Revised May 31, 

2013) 

b. BACT emission limits are required for C02, only, since it is 99.9% of emissions 

4. Sulfur hexafluoride (SF6l Electrical Breakers. 

a. Maintain fugitive emissions below 0.5% (by weight) of SF6 with state-of-the-art 

SF6 circuit breakers with leak detection and implementation of an LDAR 

program and density monitor alarm set to 4 psi drop. 

H. Pursuant to 40 CFR 60.4205(b ), the owner or operator of the emergency diesel engine, shall 

comply with the applicable emission standards. In accordance with 40 CFR 60.4205(b ), which 

references 40CFR 89.112 and 40 CFR 89.113, the emergency diesel engine's NMHC+ NOx 

emissions shall not exceed 6.4 g!kW-hr (4.8 g/hp-hr), CO emissions shall not exceed 3.5 g/kWhr (2.6 g!hp-hr), and PM emissions shall not exceed 0.2 g/kW-hr (0.15 g/hp-hr) over the life of 

the engine. The emergency diesel engine shall be certified by the manufacturer to meet these 

emission limits per 40 CFR 60.4202(a)(2). The owner or operator shall also meet the 

requirements of 40 CFR 60.4206. 

I. The facility shall comply with applicable requirements of 40 CFR Part 63 Subpart ZZZZ (refer 

to 40 CFR 63.6590(c)). If a conflict exists between the federal rule and the permit, requirements 

of the federal rule shall take precedent. 

J. Applicability of Federal Rule General Provisions. For the emergency diesel engine, 40 CFR 

60.4218 identifies the Subpart A requirements that are applicable. Empire shall also comply 

with Subpart A, as applicable, for Subparts KKKK and De. 

Page 7 of 16 
VI. Permit Conditions 

A. Startup and shutdown are defined as follows: 

1. Startup: The period from when the combined cycle unit (CT +HRSG) is started until 

reaching 50% of the combustion turbine (CT) load. The startup periods will be readily 

identifiable by the monitoring system. Such periods shall not exceed 8 hours. 

2. Shutdown: The period when the combined cycle unit (CT +HRSG) is shutting down from 

50% of combustion turbine (CT) load to 0% of combustion turbine (CT) load. The 

shutdown periods shall be readily identifiable by the monitoring system. Such periods 

shall not exceed 2 hours. 

B. The combined cycle unit (CT +HRSG) shall operate at load conditions between 50% of 

combustion turbine (CT) load and 100% of combined cycle unit (including HRSG and maximum 

duct burner firing capacity except during startup and shutdown. 

C. The combined cycle unit (CT +HRSG) shall use only natural gas as a fuel. 

D. The high efficiency drift eliminators for the Mechanical Draft Cooling Tower are an integral part 

of the design and shall function any time the cooling tower is in operation. 

E. Compliance with the PM/PM10PM25 BACT limit for the Mechanical Draft Cooling Tower shall 

be demonstrated by maintaining records of the vendor-guaranteed drift rate of 0.0005 percent of 

inlet flow. No chromium-based water treatment chemicals shall be used in the circulating water 

system and thus the requirements of 40 CFR Part 63, Subpart Q shall not apply. 

F. The emergency diesel engine shall burn only low sulfur diesel fuel oil that is ::S (less than or equal 

to) 15 ppm sulfur in accordance with 40 CFR 60.4207(b). 

G. Compliance with the PM/PM10/PM2.5 and C02e BACT limit for the emergency diesel engine is 

established by the BACT analysis and emissions calculations submitted with the permit 

application. 

H. The auxiliary boiler shall use only natural gas as a fuel. 

I. Compliance with the PM/PM101PM2 5 BACT limit for the auxiliary boiler is established by the 

BACT analysis and emissions calculations submitted with the permit application. 

J. Compliance with the C02e BACT limit for the combined cycle unit, including the combustion 

turbine and duct burners shall be demonstrated with an oxygen (02) concentration monitor in 

accordance with C02 calculations provided in 40 CFR Part 75. Calculations shall consist of C02 

emissions only, which account for 99.9% of total C02e emissions. 

K. Compliance with the PM/PM101PM25 BACT limit for the combined cycle unit shall be 

demonstrated with a performance test. 

Page 8 of 16 
L. Compliance with the C02e BACT limit for the auxiliary boiler shall be demonstrated by 

recording fuel usage and using emissions factors from Tables C-1 and C-2 of 40 CFR Part 98, 

Subpart C along with the Global Warming Potential Factors from Table A-1 of 40 CFR Part 98, 

Subpart A (as published in 74 FR 56374 on October 30, 2009) to determine resulting emissions 

on a monthly basis. Reports of excess emissions shall be submitted semi-annually. 

M. The SF6 Insulated Circuit Breakers shall continuously use a density (leak detection) alarm 

system on the SF 6 circuit breakers with a threshold of 10 percent. In the event of an alarm, the 

owner or operator shall immediately investigate the event and take an necessary corrective action 

to address any problems. 

N. Compliance with the C02e BACT limit for the SF 6 Insulated Circuit Breakers shall be 

demonstrated by calculating the annual mass emissions of SF 6 from the electrical breakers using 

an annual SF6 leak rate of 0.5% by weight and the Global Warming Potential Factor for SF6 from 

Table A-1 of 40 CFR Part 98, Subpart A (as published in 74 FR 56374 on October 30, 2009) to 

determine resulting emissions on a monthly basis. Reports of excess emissions shall be submitted 

semi-annually. 

0. 40 CFR Part 60 Subpart IIII- Requirements for the emergency diesel engine: 

1. For the emergency diesel engine, 40 CFR 60.4218 identifies the Subpart A requirements 

that are applicable. 

2. The owner or operator shall comply with applicable diesel fuel requirements of 40 CFR 

60.4207(b ). 

3. For the emergency diesel engine, the provisions of 40 CFR 60.4211(£) apply. 

Maintenance checks and readiness testing is limited to 100 hours per year, of which up to 

50 hours per year may be for non-emergency situations. There is no time limit on the use 

of the emergency diesel engine in emergency situations. 

4. The owner or operator shall comply with applicable requirements of 40 CFR Part 60 

Subpart IIII. If a conflict exists between the federal rule and the permit, the requirements 

of the federal rule shall take precedence. 

P. In accordance with 40 CFR Part 63 Subpart 40 CFR Part 63 Subpart DDDDD Industrial, 

Commercial, and Institutional Boilers and Process Heaters, the auxiliary boiler, firing solely 

natural gas, is subject to a work practice standard that requires an annual tune-up in lieu of 

emission limits. 

Q. Monitoring Requirements for Emergency Diesel Engine - If the emergency diesel engine does 

not meet the standards applicable to non-emergency engines, the owner or operator must install a 

non-resettable hour meter prior to startup of the engine, as specified in 40 CFR 60.4209. 

R. Empire shall permanently remove Unit 7 and Unit 8 from service when the Unit 12 combined 

cycle unit (CT +HRSG) begins commercial operation. 

Page 9 of 16 
VII. Performance Testing and Compliance 

A. Within 60 days after achieving a maximum production rate at which the combined cycle unit 

(CT +HRSG) will be operated, but not later than 180 days after initial start-up of the combined 

cycle unit, and every 5 years thereafter, the owner or operator shall conduct performance test(s) 

for PM, PM10, PM2.5 to demonstrate compliance with the applicable conditions and limitations 

set forth in this permit and furnish KDHE a written report of the results of such performance 

test(s). 

B. Within 60 days after achieving a maximum production rate at which the combined cycle unit 

(CT +HRSG) will be operated, but not later than 180 days after initial start-up of the combined 

cycle unit, the owner or operator shall conduct performance test for Sulfuric Acid Mist to 

demonstrate compliance with the estimated emission rates supplied in the permit application and 

furnish KDHE a written report of the results of such performance test 

C. In accordance with 40 CFR Part 60, Subpart KKKK, all continuous monitoring systems and 

monitoring devices required shall be installed and operational prior to conducting performance 

tests under 40 CFR 60.8. Verification of operational status, at a minimum, includes completion 

of the manufacturer's written requirements or recommendations for installation, operation, and 

calibration of the device as required by 40 CFR 60.13. 

D. In conducting the performance tests required by this permit, the reference test methods and 

procedures outlined in K.A.R. 28-19-212 and approved by KDHE, shall be used to demonstrate 

compliance with the limitation and conditions set forth in this permit 

D. For the emergency diesel engine, the owner or operator must install, configure, operate, and 

maintain the engine and control device according to the manufacturer's emission-related written 

instructions. The owner or operator must not change emission-related settings in a way that is not 

permitted by the manufacturer, or thereafter demonstrate compliance as specified at 40 CFR 

60.42ll(g)(3). 

E. Compliance with NOx emJssJon limits for the combined cycle unit (CT + HRSG) shall be 

demonstrated with a NOx continuous emission monitor (CEM) that follows the requirements 

listed in 40 CFR 60.4340(b). 

F. The N Ox CEM shall be installed, certified, operated, maintained, and quality assured m 

accordance with 40 CFR 60.4345. 

G. Compliance with S02 emission limits shall be demonstrated in accordance with the requirements 

in 40 CFR 60.4330 and 40 CFR 60.4360. 

Page 10 of 16 
H. Malfunction: The Owner or Operator must notify KDHE by telephone, facsimile, or electronic 

mail transmission within two (2) working days following the discovery of any failure of air 

pollution control equipment, process equipment, or of the failure of any process to operate in a 

normal manner which results in an increase in emission above the allowable emission limit stated 

in section "V. Air Emission Limitations" of this permit, a written notification shall be submitted 

within ten (10) days of the event. 

The written notification shall include 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 "Air Emission Limitations," and the methods utilized to mitigate emissions 

and restore normal operations. Compliance with this malfunction notification shall not 

automatically absolve the owner or operator of liability for the excess emissions resulting from 

such event. 

The following criteria will be used by KDHE to evaluate whether emissions from a malfunction 

are excluded in determining compliance with the emission rate contained herein: 

1. The excess emission were caused by a sudden, unavoidable breakdown of technology, 

beyond the control of the owner or operator; 

2. The excess emissions did not stem from any activity or event that could have been 

foreseen and avoided, or planned for, and could not have been avoided by better 

operation and maintenance practices; 

3. To the maximum extent practicable, the air pollution control equipment or processes 

were maintained and operated in a manner consistent with good practices for minimizing 

em!SS!Ons; 

4. Repairs were made in an expeditious fashion when the operator knew or should have 

known that applicable emission limitations were being exceeded. Off-shift labor and 

overtime must have been utilized, to the extent practicable, to ensure tbat such repairs 

were made as expeditiously as practicable. 

5. The amount and duration of the excess emissions (including any bypass) were minimized 

to the maximum extent practicable during periods of such emissions; 

6. All possible steps were taken to minimize tbe impact of the excess emissions on ambient 

air quality; 

7. All emission monitoring systems were kept in operation if at all possible; 

8. The owner or operator's actions in response to the excess emissions were documented by 

properly signed, contemporaneous operating logs, or other relevant evidence; 

9. The excess emissions were not part of a recurring pattern indicative of inadequate design, 

operation, or maintenance; and 

10. The owner or operator properly and promptly notified the appropriate regulatory 

authority. 

Page 11 of 16 
I. Stack parameters for all equipment listed under Section III, Air Emissions Unit Technical 

Specifications, which may include, but not limited to stack heights, stack diameters, exhaust 

temperatures, emission rates, and exit velocities, shall be consistent with data provided for the 

dispersion modeling analysis. Actual operational conditions shall be consistent with data 

provided for the dispersion modeling analysis. 

VIII. Recordkeeping 

A. The owner or operator of the combined cycle unit (CT +HRSG) shall maintain records of the 

occurrence and duration of any start-up, shut-down, or malfunction in the operation of the 

combined cycle unit (CT +HRSG); any malfunction of the air pollution control equipment; or any 

periods during which a continuous monitoring system or monitoring device is inoperative. These 

requirements are described in 40 CFR 60.7(b). 

B. As required under 40 CFR 60.7 (f), the owner or operator shall maintain a file of all 

measurements, including continuous monitoring system, monitoring device, and performance 

testing measurements; all continuous monitoring system performance evaluations; all continuous 

monitoring system or monitoring device calibration checks; adjustments and maintenance 

performed on these systems or devices; and all other information required by this part recorded 

in a permanent form suitable for inspection. The file shall be retained for at least two years 

following the date of such measurements, maintenance, reports, and records, with certain 

exceptions specified under 40 CFR 60.7(f). 

C. Reports of excess emissions shall be submitted semi-annually m accordance with the 

requirements in 40 CFR 60.7(c). 

D. Records shall be kept on site for two (2) years in accordance with 40 CFR 60.7(f). 

E. For the emergency diesel engine, the owner or operator must keep records of the emergency and 

non-emergency operations of the engine through a non-resettable hour meter if it does NOT meet 

the standards applicable to the non-emergency engines in the applicable model year. The times 

of operation and the reasons for operation must be recorded, as specified in 40 CFR 60.4214(b). 

F. A record shall be maintained demonstrating that the auxiliary boiler is in compliance with the 

particulate matter emission rate limit of Section V.C. Air Emission Limitations of this permit. 

After the initial evaluation, the particulate emission rate limitation shall be re-evaluated when 

either the process changes or an emission factor increases. 

G. In accordance with 40 CFR 60.7(b), the owner/operator shall keep records of the occurrence and 

duration of any start-up, shutdown or malfunction in the operation ofthe auxiliary boiler. 

H. In lieu of the daily record keeping requirements of 40 CFR 60.48c(g), the owner or operator shall 

record and maintain records of the amount of fuel combusted in the auxiliary boiler on a 

monthly basis. The records of the amounts of fuel burned can be maintained in the form of 

monthly fuel bills or meter readings, or other records that adequately document fuel usage. 

Page 12 of16 
I. In accordance with 40 CFR 60.48c(i), all of the required records shall be maintained by the 

owner or operator of the auxiliary boiler for a period of two years following the date of record. 

IX. Reporting 

Reports demonstrating compliance shall be submitted to the KDHE in the same units as stated in the 

applicable requirements. 

A. Items required to be reported semi-annually shall be submitted to KDHE and postmarked by the 

30th day following the end of each calendar half. 

B. Items required to be reported annually shall be submitted to KDHE and postmarked by the 30th 

day following the end of each calendar year. 

C. The combined cycle combustion unit (CT+HRSG) excess emissions and monitoring systems 

performance report and/or a summary report shall be submitted to the KDHE as required by 40 

CFR 60.7(c) on a semi-annual basis. The sunnnary report form shall contain the information and 

be in the format as specified in 40 CFR 60.7(d). One summary report form for NOx and one 

summary report form for the sulfur content of the fuel shall be submitted. Written reports of 

excess emissions shall include the following information: 

1. The magnitude of excess emissions computed in accordance with 40 CFR 60.13(h), any 

conversion factor( s) used, the date and time of commencement and completion of each 

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

period. 

2. Specific identification of each period of excess emissions that occurs during start-ups, 

shut-downs, and malfunctions, the nature and cause of any malfunction (if known), the 

corrective action taken or preventative measures adopted. 

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

system was inoperative except for zero span checks and the nature of the system repairs 

and adjustments. 

4. When no excess emissions have occurred or the continuous monitoring system(s) have 

not been inoperative, repaired, or adjusted, such information shall be stated in the report. 

D. Reports required under Section IX. Reporting, Item C of this permit, periods of excess emissions 

as defined in 40 CFR 60.4350 shall be reported accordingly. 

E. The compliance demonstration for Section V. Air Emission Limitations, Item D, of this permit, 

shall be reported on an annual basis. 

Page 13 of 16 
F. If significant changes are made, or modeling parameters are not representative of site conditions, 

the owner or operator shall document compliance with the applicable NAAQS and allowable 

PSD increment consumption and submit documentation of compliance to KDHE prior to making 

the change(s). KDHE has final authority in determining what constitutes a significant change. If 

modeling indicates a potential NAAQS or increment exceedance, then mitigation shall be 

required. 

X. Notification 

A. The Air Quality Representative in the Southeast District Office shall be notified within 30 days 

of when installation of the equipment is complete so an evaluation may be conducted to verify 

compliance with applicable regulations. 

B. K.A.R. 28-19-720 (40 CFR 60.7(a) and 60.8(d) reqmres that written notifications of the 

following be submitted to KDHE: 

I. The date construction of the combined cycle unit (CT+HRSG), the auxiliary boiler and 

the emergency diesel generator are commenced. The notification is to be postmarked no 

less than 30 days after such date. 

2. The actual date of initial startup of the combined cycle unit (CT+HRSG), auxiliary boiler 

and emergency diesel generator. The notification is to be postmarked within 15 days 

after such date. 

3. The actual date the combined cycle unit (CT+HRSG) enters commercial operation and 

the date(s) Unit 7 and Unit 8 are removed from serv1ce. The notification is to be 

postmarked within 15 days after such date(s). 

4. The date when the initial performance testing of the combined cycle unit (CT +HRSG) is 

to commence. The notification is to be postmarked no less than 30 days prior to such 

date. 

5. The date upon which demonstration of the continuous monitoring system performance 

commences in accordance with 40 CFR 60.13(c). Notification shall be postmarked no 

less than 30 days prior to such date. 

C. Notification of the performance test shall include a performance test protocol which includes a 

description of the test and applicable test methods. Notification of the date(s) for performance 

testing shall be submitted to KDHE, postmarked at least 30 days prior to such date(s). 

Performance testing shall also be coordinated with the KDHE Bureau of Air, Compliance and 

Enforcement Section at 785-296-0243 at least 30 days prior to the date(s) of the test. 

Page 14 of 16 
D. At the time of permit issuance, the turbines are subject to 40 CFR Part 63, Subpart YYYY, 

however pursuant to 40 CFR 63.6095(d) there has been a stay of standards for gas-fired 

subcategories. Owners or operator of lean premix gas-fired stationary combustion turbines and 

diffusion flame gas-fired turbines must comply with the initial notification requirements set forth 

in 40 CFR 63.6145 but need not comply with any other requirement of 40 CFR Part 63 Subpart 

YYYY until EPA takes final action to require compliance and publishes a document in the 

Federal Register. [40 CFR 63.6095(d)] 

XI. General Provisions 

A. This document shall become void if construction, installation or modification to convert the 

existing Riverton 12 simple cycle combustion turbine to a combined cycle unit has not 

commenced within 18 months of the effective date of this permit, or if the construction, 

installation or modification to convert the simple cycle combustion turbine to a combined cycle 

unit is interrupted for a period of 18 months or longer. 

B. A construction permit or approval must be issued by KDHE prior to commencing any 

construction or modification of equipment or processes which result in an increase in potentialto-emit equal to or greater than the thresholds specified at K.A.R. 28-19-300. 

C. Upon presentation of credentials and other documents as may be required by law, the permittee 

shall allow a representative of the KDHE (including authorized contractors of the KDHE) to: 

I. enter upon the permittee's premises where a regulated facility or activity is located or 

conducted or where records must be kept under conditions of this document; 

2. have access to and copy, at reasonable times, any records that must be kept under 

conditions of this document; 

3. inspect at reasonable times, any facilities, equipment (including monitoring and control 

equipment), practices or operations regulated or required under this document; and 

4. sample or monitor, at reasonable times, for the purposes of assuring compliance with this 

document or as otherwise authorized by the Secretary of the KDHE, any substances or 

parameters at any location. 

D. The emission unit or stationary source which is the subject of this document shall be operated in 

compliance with all applicable requirements of the Kansas Air Quality Act and the Federal Clean 

Air Act. 

E. This document is subject to periodic review and amendment as deemed necessary to fulfill the 

intent and purpose of the Kansas Air Quality Statutes and Regulations and rules promulgated in 

accordance therewith. 

Page 15 of 16 
F. This document does not relieve the permittee of the obligation to obtain other approvals, permits, 

licenses or documents of sanction which may be required by other federal, state or local 

government agencies. 

G. Issuance of this document does not relieve the owner or operator of any requirement to obtain an 

air quality operating permit under any applicable provision ofK.A.R. 28-19-500. 

Permit Engineer 

$:::&= 

Environmental Engineer 

Air Permits Section 

LDL:lv 

c: SEDO 

C-10913 

Date Signed 

Page 16 of 16 
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