1

Tucson Electric Power 

Irvington Generating Station 

Air Quality Permit # 1052 

TECHNICAL SUPPORT DOCUMENT (TSD) 

May 18, 2007

I. General Comments:

A. Company Information

 1. Tucson Electric Power – Irvington Generating Station 

 2. Source Address: 3950 East Irvington Road, Tucson, AZ 85714. 

 Mailing Address: 1 South Church Ave, P.O. Box 711, Tucson, AZ 85702. 

 B. Background

 Tucson Electric Power – Irvington Generating Station (TEP-IGS) produces electricity by fossil fuel 

combustion (coal, natural gas, liquid fuel, and landfill gas). Originally, TEP-IGS did not have the 

capacity to fire coal and was regulated by Pima County Health Services. 

 However, in 1980 the Department of Energy promulgated regulations that required certain large 

power plants to convert their operations to additionally have the capacity to burn coal. TEP applied 

for and received an installation permit for the coal conversion project (see Appendix C for the 

Arizona Department of Health Services Installation Permit #1156). The Arizona Department of 

Environmental Quality (ADEQ) issued this permit and assumed oversight from Pima County (as ARS 

49-402.A.4 provides original jurisdiction to the State for Coal fired electrical generating stations). 

 Although the initial plan was to convert all four fossil fuel-fired steam generating units (I1 – I4), only 

Unit I4 was converted. Since this change was mandated by a government order, NSR requirements 

were not applicable [PCC 17.16.340.A, “major modification” – c.ii & AAC R18-2-101 “major 

modification” – c.ii]. The NSPS definition for “modification” also exempts mandatory coal 

conversion projects [40 CFR 60.14(e)(4) and CAA Sec 111(a)(8)]. Therefore, NSPS (Subpart D) 

requirements are not applicable to Unit I4. This exemption also applied to the coal preparation plant 

as it was constructed during the coal conversion project. 

 In the late 1990’s TEP requested that jurisdiction over TEP-IGS be returned to Pima County 

Department of Environmental Quality, (PDEQ); the transfer was completed shortly after ADEQ 

issued a 5-year Class I permit to TEP IGS (issue date July 26, 1999). PDEQ issued a significant 

revision on May 15, 2001 for the installation of a new, simple cycle combustion turbine to be added 

as a peaking unit. Via emission limitations this did not qualify as a major modification. This renewal 

permit is the first to be drafted and issued by PDEQ. 

 C. Attainment Classification 

 TEP-IGS is located in a region that is designated as attainment for all criteria pollutants. 
2

II. Source Description

 A. Process Description 

TEP-IGS generates electricity using two fossil fuel fired processes: (1) Steam Turbine Cycle and (2) 

Combustion Turbine Cycle. In addition to these, there are several support facilities, some of which 

contain applicable requirements that are addressed by the permit. 

1. Steam Turbine Cycle 

 There are three distinct units in this process: (1) Boiler; (2) Turbine; and (3) Generator. 

 a. Boiler 

Water is converted to steam via combustion of fuel and heat transfer. Steam is routed to 

turbines while the exhaust gasses and pollutants produced during combustion are released 

to the ambient atmosphere after passing though air pollution controls (if required). The 

concentrations of pollutants released into the atmosphere depend on the fuel fired. 

Typical pollutants are Particulate Matter (PM), Sulfur Dioxides (SO2), Nitrogen Oxides 

(NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC). Specific 

pollutant emission rates are provided in Section IV of this document. 

 b. Turbine 

Steam exiting the boilers enters a turbine unit. The high-pressure steam passes through 

rotating blades which cause the turbine shaft to rotate converting the thermal energy of 

the steam into mechanical energy. After passing through the turbine, the steam is sent 

through a condenser and is recirculated to the boiler. The only process material used by 

the turbine unit is steam; thus there are no emissions. 

 c. Generator 

The turbine drives the generator which, in turn, produces electrical energy. There are no 

process materials and no emissions from these units. 

 2. Combustion Turbine Cycle 

 There are two distinct units in this process: (1) Combustion Turbine; and (2) Generator 

 a. Combustion Turbine, 

Fuel and air are mixed and injected into a combustion chamber where they are ignited. 

The hot combustion gases pass over the turbine blades. The resulting movement of the 

blades causes the shaft to rotate. Exhaust gasses and pollutants produced during 

combustion are released to the ambient atmosphere after passing through air pollution 

controls (if required). Emissions resulting from combustion typically include PM, SO2 , 

NOx, CO and VOC. Representative emission rates are provided in Section IV of this 

document. 
3

 b. Generator. 

The turbine drives the generator which, in turn, produces electrical energy. There are no 

process materials and no emissions from these units. 

 3. Support Facilities 

Other equipment, operations and process that function as support facilities are turbine starter 

engines, other smaller boilers, cooling towers, the coal preparation plant and the fly-ash 

handling systems. Pollutants include PM, SO2, NOx, CO, and VOC. 

 B. Operating Capacity and Schedule 

TEP-IGS requires the flexibility to operate 24 hours a day, 365 days a year. The net capacity of each 

power production unit is as follows: 

1. Fossil Fuel Fired Steam Generating Units: 

 a. UNIT I1 – 81.02 MW 

 b. UNIT I2 – 80.53 MW 

 c. UNIT I3 – 104.45 MW 

 d. UNIT I4 – 156.1 MW 

2. Stationary Combustion Turbines: 

 a. UNIT IGT1 – 23.9 MW 

 b. UNIT IGT2 – 24.5 MW 

 c. UNIT IGT3 – <25 MW 

 C. Applicability Categories

The following categories are addressed by the permit: 

 1. Fossil Fuel Fired Steam Generators (Steam Turbine Cycle Boilers)

 2. Stationary Rotating Machinery (Stationary Combustion Turbines & Diesel Turbine Starter 

Engines). 

 3. Auxiliary Boiler 

 4. Cooling Towers 

 5. Coal Preparation Plant & Fly-Ash Handling Systems 

 6. Open Areas, Roadways, & Streets 

 7. Alternate Operating Scenario for Stationary Rotating Machinery (Stationary Combustion 

Turbines & Diesel Turbine Starter Engines (IGT3)). 
4

 D. Air Pollution Control Equipment 

Air Pollution Control Equipment is required for four pieces of equipment and processes: (1) UNIT I4; 

(2) UNIT IGT3; (3) the Coal Preparation Plant; and (4) the Fly-Ash Handling Plant. 

1. UNIT I4 

The Permittee is required to install and maintain a baghouse on UNIT I4 to capture PM 

emissions when coal is fired (exclusively or in combination with other fuels). 

2. UNIT IGT3 

Upon purchasing the unit, the Permittee is required to install and operate a water injection 

system or its equivalent to control NOx emissions. 

 3. The Coal Preparation Plant 

The Permittee is required to install and operate various enclosures, dust collectors, and other 

fugitive dust controls to limit PM emissions. 

 4. The Fly-Ash Handling Systems 

The Permittee is required to install and operate various enclosures, dust collectors, and other 

fugitive dust controls to limit PM emissions. 

III. Regulatory History 

 TEP is currently in compliance with permit and regulatory requirements. 

 A. Testing & Inspections 

Inspections have been conducted regularly since PDEQ took over jurisdiction from ADEQ. The last 

completed inspection was concluded in 2006. 

 B. Excess Emissions 

There have been no Notices of Violations for any excess emissions. 

IV. Emission Estimates 

The following emission estimates have been carried over from previous TSDs. Actual emissions are 

provided by Continuous Emissions Monitoring System (CEMS) data. These values may be used for the 

following purposes: 

 (i). Ascertaining “major source” status of IGS pursuant to CAA Sec 501 (2); 

 (ii). Comparing source potential-to-emit with emission rates allowable by relevant standards; and 

 (iii). Comparing source potential-to-emit with emissions inventory and test data. 
5

This comparison serves as a summary of existing information on emissions from TEP-IGS. These emission 

calculations are not meant to establish any baseline emission levels. These emission figures (except for the 

ALLOWABLE emissions) are not meant to be emission limitations of any form. The following tables 

summarize the potential to emit (PTE), allowable emissions, test results, and the emissions inventory (EI) 

data. The emission factors used to calculate the potential to emit are from AP-42 (1/95 ed.). 

A. Fossil Fuel Fired Steam Generators 

1. UNITS I1 & I2 Boilers (each) 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM 4 17.5 172 lb/hr1

(753 tpy) 

NOx 220 963.5 NA 

SOx 0.5 2.1 NA 

CO 32 140 NA 

VOC 1.4 6 NA 

Natural Gas 

THAP 0.4 1.84 NA 

PM 7 31 172 lb/hr2

(753 tpy) 

NOx 220 963.5 NA 

SOx 3.4 15 NA 

CO 34.0 149 NA 

VOC 1.4 6 NA 

Co-Firing Natural Gas 

with Landfill Gas 

THAP 0.4 1.84 NA 

PM 61 269 172 lb/hr3

(753 tpy) 

NOx 224 982 NA 

SOx 754 3303 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)4

CO 26.7 117 NA 

VOC 4.1 18 NA 

Liquid Fuel 

(#6 Fuel Oil) 

THAP 0.8 3.3 NA 

PM 61 269 172 lb/hr5

(753 tpy) 

NOx 224 982 NA 

SOx 754 3303 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)6

CO 26.7 117 NA 

Co-Firing Liquid Fuel 

(#6 Fuel Oil) with 

Landfill Gas 

VOC 4.1 18 NA 

 

1

 17.16.160.C 

2

 17.16.160.C 

3

 17.16.160.C 

4

 17.16.160.D.1 

5

 17.16.160.C. 

6

 17.16.160.D.1 
6

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

THAP 0.8 3.3 NA 

 2. UNIT I3 Boiler 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM 5.3 23 213 lb/hr7

(933 tpy) 

NOx 287 1257 NA 

SOx 0.6 2.7 NA 

CO 41.5 182 NA 

VOC 1.8 7.8 NA 

Natural Gas 

THAP 0.54 2.37 NA 

PM 80 350 213 lb/hr8

(933 tpy) 

NOx 292 1280 NA 

SOx 983 4307 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)9

CO 34.7 152 NA 

VOC 5.3 23 NA 

Liquid Fuel 

(#6 Fuel Oil) 

THAP 1.0 4.3 NA 

 3. UNIT I4 Boiler 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM 8.5 37 311 lb/hr10 

(1362 tpy) 

NOx 468 2050 

0.7 lb NO2/MMTU 

– 

3 hr average 

(5218 tpy)11

SOx 1.0 4.5 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)12

CO 68 298 NA 

VOC 3.0 13 NA 

Natural Gas 

THAP 0.9 3.85 NA 

Liquid Fuel 

(#6 Fuel Oil) PM 80 350 311 lb/hr13 (1362 tpy) 

 

7

 17.16.160.C 

8

 17.16.160.C 

9

 17.16.160.D.1. 

10 17.16.160.C 

11 Installation Permit #1156 Condition 5. 

12 Installation Permit #1156 Condition 5. 

13 17.16.160.C 
7

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

NOx 477 2090 

0.7 lb NO2/MMTU 

– 

3 hr average 

(5218 tpy)14

SOx 1604 7029 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)15

CO 56.8 249 NA 

VOC 8.0 35 NA 

THAP 1.6 7 NA 

PM 41.1 18116 223 lb/hr 

(977 tpy)17

NOx 883 3866 

0.7 lb NO2/MMTU 

– 

3 hr average 

(5218 tpy)18

SOx 1164 5099 

1 lb SO2/MMBtu – 

3 hr average 

(3504 tpy)19

CO 30.6 134 NA 

VOC 3.7 16 NA 

Solid Fuel 

(Coal) 

THAP 15 65.7 NA 

 B. Stationary Rotating Machinery 

 1. UNITS IGT1, IGT2, & IGT3 (each, except for IGT3 see note under fuel below)) 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM 7.8 34 103 lb/hr 

(450 tpy)20

NOx 176 771 NA 

SOx 0.23 1.01 NA 

CO 43.8 192 NA 

VOC 9.6 42 NA 

Natural Gas 

(UNIT IGT3 limited to 

natural gas exclusively, 

40 tpy for NOx, SOx & 

VOC, 100 tpy CO and 

15 tpy PM10. NOx limit 

indirectly lows other 

pollutants.) THAP 0.2 0.7 NA 

PM 15 66 103 lb/hr 

(450 tpy)21

Liquid Fuel 

(#2 Fuel Oil) 

NOx 273 1196 NA 

 

14 Installation Permit #1156 Condition 5. 

15 Installation Permit #1156 Condition 5. 

16 With baghouse. Without controls, 36235 tpy PM. 

17 17.16.160.C 

18 Installation Permit #1156 Condition 5. 

19 Installation Permit #1156 Condition 5. 

20 17.16.340.C. 

21 17.16.340.C. 
8

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

SOx 158 692 1 lb/MMBtu 

(1712 tpy)22

CO 18.9 83 NA 

VOC 6.6 29 NA 

THAP 1.1 5 NA 

 2. UNITS IGT1A, IGT2A, & IGT3A (each) 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM Negligible 0.02 103 lb/hr 

(450 tpy)23

NOx Negligible 1.1 NA 

SOx Negligible 0.02 1 lb/MMBtu 

(7 tpy)24

CO Negligible 0.01 NA 

VOC Negligible 0.03 NA 

Diesel Fuel 

THAP Negligible 0.00017 NA 

 C. Auxiliary Boiler 

Fuel Pollutant PTE (lb/hr) PTE (TPY) Allowable 

PM 0.5 2 28 lb/hr25

(125 tpy) 

NOx 10 44 NA 

SOx 0.04 0.18 NA 

CO 2.6 11.4 NA 

VOC 0.4 1.8 NA 

Natural Gas 

THAP 0.04 0.17 NA 

PM 0.9 4 28 lb/hr26

(125 tpy) 

NOx 11.0 48 NA 

SOx 30.0 131 

1 lb SO2/MMBtu – 

3 hr average 

(320 tpy)27

CO 2.7 12 NA 

VOC 0.1 0.61 NA 

Liquid Fuel 

(#2 Fuel Oil) 

THAP 0.03 0.15 NA 

 

22 17.16.340.F. 

23 17.16.340.C. 

24 17.16.340.F. 

25 17.16.165.C 

26 17.16.165.C 

27 17.16.160.E. 
9

 D. Cooling Towers 

Unit Pollutant PTE (lb/hr) PTE (TPY) Allowable 

I1E PM 8.35 36 108 lb/ht 

(474 tpy)28

I2D PM 8.35 36 108 lb/ht 

(474 tpy)29

I3D PM 11.6 51 114 lb/ht 

(497 tpy)30

I4E PM 16 69 119 lb/ht 

(521 tpy)31

 E. Coal Preparation Plant & Fly-Ash Handling Systems 

Unit Pollutant PTE (lb/hr) PTE (TPY) Allowable 

Coal Preparation Plant PM 53 232 62 lb/hr 

(272 tpy)32

Fly-Ash Handling 

Systems PM 27 119 65 lb/hr 

(285 tpy)33

V. Applicable Requirements 

 A. Standards addressed by the permit: 

 1. Pima County State Implementation Plan (SIP): 

 

 Rule 315 Roads and Streets 

 Rule 318 Vacant Lots and Open Spaces 

 Rule 321 Standards and Applicability 

 Rule 343 Visibility Limiting Standard 

 2. Code of Federal Regulations Title 40: 

 Part 60 Subpart KKKK Standards of Performance for Stationary Combustion Turbines (IGT3) 

 Part 60 Subpart GG Standards of Performance for Stationary Gas Turbines (IGT3) 

 Part 60 Appendix B Performance Specifications 

 Part 64 Compliance Assurance Monitoring 

 Part 75 Subpart F Conversion Procedures 

 Part 75 Subpart G Determination of CO Emissions 

 Part 75 Appendix A Specifications and Test Procedures 

 Part 75 Appendix B Quality Assurance and Quality Control 

 

28 PCC 17.16.430.A.1. 

29 PCC 17.16.430.A.1. 

30 PCC 17.16.430.A.1. 

31 PCC 17.16.430.A.1. 

32 PCC 17.16.310.B.2. 

33 PCC 17.16.430.A.1. 
10

 3. Pima County Code (PCC) Title 17, Chapter 17.16: 

 17.16.020 Noncompliance with Applicable Standards 

 17.16.030 Odor Limiting Standards 

 17.16.050 Visibility Limiting Standards 

 17.16.060 Fugitive Dust Producing Activities 

 17.16.080 Vacant Lots and Open Spaces 

 17.16.090 Roads and Streets 

 17.16.100 Particulate Materials 

 17.16.110 Storage Piles 

 17.16.130 Applicability 

 17.16.160 Standards of Performance for Fossil-Fuel Fired Steam Generators and 

General Fuel Burning Equipment 

 17.16.165 Standards of Performance for Fossil-Fuel Fired Industrial and Commercial 

Equipment 

 17.16.310 Standards of Performance for Coal Preparation Plants 

 17.16.340 Standards of Performance for Stationary Rotating Machinery 

 17.16.430 Standards of Performance for Unclassified Sources 

 17.16.590 Permit Requirements for Sources Located in Attainment and Unclassifiable 

Areas 

 4. Installation Permit #1156 – October 14, 1981 by Arizona Department of Health Services 

 B. Standards that are applicable, but have not been addressed by the permit: 

 Code of Federal Regulations Title 40: 

 1. Part 63 Subpart YYYY National Emission Standards for Hazardous Air Pollutants for 

Stationary Combustion Turbines. 

 2. Part 63 Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines. 

These standards have not been included in this renewal permit. In an email dated 08/16/2006 

TEP-IGS stated that as an existing source it is not subject to notification requirements for 

NESHAP Subpart ZZZZ. After reviewing the applicability requirements PDEQ has confirmed 

this finding. TEP-IGS has also stated that pursuant to 40 CFR 63.6090(b)(4) – (subcategories 

with limited requirements), none of the present turbines are subject to the notification 

requirements of Subpart YYYY. After reviewing the applicability requirements, it was not 

initially clear if the current turbines would fall into the subcategories outlined in the 

applicability of 40 CFR 63 Subpart YYYY. Only four subcategories are described in the 

applicability of subpart YYYY none of which apply to TEP-IGS. The federal register for the 

final rule however has 4 other subcategories and the TEP-IGS’ turbines are covered under one 

of them. PDEQ therefore does agree that the turbines fall into the subcategory defined under 40 

CFR 63.6090(b) and pursuant to 40 CFR 63.6090(b)(4), no notification is required and TEPIGS does not have to meet the requirements of this subpart and of subpart A. 
11

 C. Standards which are not applicable: 

 1. PSD/NSR 

 UNIT I4 (manufactured in 1964) was originally designed to fire natural gas and oil. This was 

permitted by Pima County till the early ‘80s. In 1980 the Department of Energy promulgated 

regulations that required certain large power plants to convert their operations to additionally 

have the capacity to burn coal. TEP applied for an installation permit for the coal conversion 

project. Although the initial plan was to convert all four fossil fuel-fired steam-generating units 

(I1 – I4), only UNIT I4 was converted. Since this change was mandated by a government order, 

NSR requirements are not applicable [PCC 17.16.340.A, “major modification” – c.ii & AAC 

R18-2-101”major modification” – c.ii]. 

 2. Code of Federal Regulations, Title 40 

 a. Part 60 Subpart D Standards of Performance For Fossil Fuel Fired Steam 

Generators for Which Construction Commenced After August 

17,1971. 

 b. Part 60 Subpart Da Standards of Performance For Fossil Fuel Fired Steam 

Generators for Which Construction Commenced After 

September 18, 1978. 

 c. Part 60 Subpart Y Standards of Performance for Coal Preparation Plants. 

The NSPS definition for “modification” exempts mandatory coal conversion projects [40 

CFR 60.14(e)(4) and CAA Sec 111(a)(8)]. Therefore, NSPS Subparts D & Da 

requirements are not applicable to Unit I4, nor is Subpart Y applicable to the coal 

preparation plant. 

 d. Part 60 Subpart OOO Standards of Performance for Nonmetallic Mineral Processing 

Plants. 

Subpart OOO specifically identifies the applicable substances of which fly-ash is not a 

part. 

 D. Promulgated standards which will be or may be applicable: 

 1. 40 CFR 63 Subpart DDDDD – NESHAPs for Industrial, Commercial, and Institutional Boilers 

and Process Heaters. 

 a. Applicable Unit: IAUX. Applicability includes boilers under 25 MW at Major Sources of 

HAP (63.7485, 63.7491(c)). TEP-IGS is a major source of HAPs (PTE: ~81.8 tpy). At 

73MMBtu, this unit has a capacity of 21.4 MW. 

 b. The promulgation date was Sept 13, 2004. 

 c. The initial notification date was February 12, 2005. 

 d. The compliance date is Sept 13, 2007. 
12

 e. TEP submitted an initial notification on December 13, 2004. 

 In an email dated September 08, 2006, TEP indicated that there were no other requirements to include 

in the draft permit. 

 2. 40 CFR 63, Subpart YYYY – NESHAPs for Stationary Combustion Turbines. 

 a. Potentially Applicable Units: IGT1, IGT2, & IGT3. Applicability includes stationary 

combustion turbines at major sources of HAP (63.6085). 

 b. The promulgation date was March 5, 2004. 

 c. The initial notification date was June 5, 2004. 

 d. The compliance date is March 5, 2007. 

 e. No initial notification is required for the existing turbines at TEP-Irvington. 

 3. 40 CFR 63, Subpart ZZZZ – NESHAPs for Reciprocation Internal Combustion Engines. 

 a. Potentially Applicable Units: IGT1A, IGT2A, IGT3A (may be introduced with IGT3). 

Applicability includes stationary rotating machinery >500hp at major sources of HAP 

(63.6585). Emergency and Limited use units are exempt (63.6590(b)). 

 b. The promulgation date was June 15, 2004. 

 c. The initial notification date was September 15, 2004. 

 d. The compliance date is June 15, 2007. 

 e. No initial notification is required for the existing turbines at TEP-Irvington. 

VI. Permit Contents

 A. Applicability: 

1. Fossil Fuel Fired Steam Generators - UNITS I1, I2, I3, & I4 of the previous permit – main PCC 

standard: 17.16.160. 

2. Stationary Rotating Machinery (including Stationary Turbines) - UNITS IGT1, IGT2, IGT1A, & 

IGT2A of the previous permit – main PCC standard: 17.16.340. 

3. Auxiliary Boiler - Unit IAUX of the previous permit – main PCC standard: 17.16.165. 

4. Cooling Towers - Units I1E, I2D, I3D, & I4E of the previous permit – main PCC standard: 

17.16.430. 

5. Coal Preparation Plant - Coal Preparation Plant, and Emergency Coal Storage Pile of previous 

permit – main PCC standards: 17.16.310. 
13

 6. Fly-Ash Handling Systems - Fly-ash Handling System of previous permit – main PCC 

standards: 17.16.430 

 6. Open Areas, Roadways, & Streets – main PCC standards: 17.16.080 & 17.16.090. 

 7. All Operations

 B. Emission Limits/ Standards: 

 1. Fossil Fuel Fired Steam Generators: 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.A.1. I1, I2, I3, & 

I4 

Particulate 

Matter 

Standard 

Hourly limit for PM 

emissions. 

Requirement taken directly 

from PCC 17.16.160.C.1. 

II.A.2.a. I1, I2, & I3 

Sulfur 

Dioxide 

Standard 

3-hour limit for SOx 

emissions when firing 

liquid fuel. 

Requirement taken directly 

from PCC 17.16.160.D.1 

II.A.2.b. I4 

Sulfur 

Dioxide 

Standard 

3-hour limit for SOx 

emissions regardless of 

fuel fired. 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 5. 

II.A.3. I4 

Nitrogen 

Oxides 

Standard 

3-hour limit for NOx 

emissions. 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 5. 

II.A.4. I4 Opacity 

Standard Opacity limit. 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 5. 

II.A.5.a. I1, I2, I3, & 

I4 

Fuel 

Limitation 

Low sulfur fuel 

requirement. 

Requirement taken directly 

from PCC 17.16.160.G 

II.A.5.b 

& c.i. 

I1, I2, & I3; 

I4 

Fuel 

Limitation Allowable fuels. 

17.12.190 requirement 

established to allow TEP-IGS 

to switch fuels without 

applying for a revision. 

II.A.5.c. 

ii. I4 Fuel 

Limitation 

Coal sulfur content 

limitation. 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 4. 

 2. Stationary Rotating Machinery (including Stationary Turbines) 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.B.1 IGT1,2 & 

IGT1A,2A 

Particulate 

Matter 

Standard 

Hourly limit for 

PM emissions. 

Requirement taken directly from 

PCC 17.16.340.C. 
14

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.B.2 IGT1,2 & 

IGT1A,2A 

Sulfur 

Dioxide 

Standard 

Hourly limit for 

SOx emissions 

when firing liquid 

fuels. 

Requirement taken directly from 

PCC 17.16.340.F. 

II.B.3 IGT1,2 & 

IGT1A,2A 

Opacity 

Standard Opacity limit. Requirement taken directly from PCC 17.16.340.E & SIP 321. 

II.B.4.a IGT1,2 & 

IGT1A,2A 

Fuel 

Limitation 

Low sulfur fuel 

requirement. 

Requirement taken directly from 

PCC 17.16.340.H. 

II.B.4.b IGT1 & 2 Fuel 

Limitation Allowable fuels. 

PCC 17.12.190 requirement 

established to allow TEP-IGS to 

switch fuels without applying for a 

revision. 

II.B.4.c IGT1A,2A Fuel 

Limitation 

Diesel fuel 

requirement. 

PCC 17.12.190 requirement 

established to avoid potential issues 

with fuel switching. 

 3. Auxiliary Boiler 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.C.1 IAUX 

Particulate 

Matter 

Standard 

Hourly limit for PM 

emissions. 

Requirement taken directly from 

PCC 17.16.165.C. 

II.C.2 IAUX 

Sulfur 

Dioxide 

Standard 

Hourly limit for SOx 

emissions when firing 

liquid fuel. 

Requirement taken directly from 

PCC 17.16.165.E. 

II.C.3.a IAUX Fuel 

Limitations

Low sulfur fuel 

requirement. 

Requirement taken directly from 

PCC 17.16.165.G. 

II.C.3.b IAUX Fuel 

Limitations Allowable fuels. 

PCC 17.12.190 requirement 

established to avoid potential issues 

with fuel switching. 

 4. Cooling Towers 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.D.1 I1E, I2D, 

I3D, & I4E 

Particulate 

Matter 

Standard 

Hourly limit for PM 

emissions. 

Requirement taken directly 

from PCC 17.16.430.A.1.b 

II.D.2 I1E, I2D, 

I3D, & I4E 

Odor 

Limiting 

Standard 

Prohibition from emitting 

gasses and odor as to 

cause air pollution. 

Requirement taken directly 

from PCC 17.16.430.D. 

II.D.3 I1E, I2D, 

I3D, & I4E 

Property 

Line 

Prohibition of 

discharging pollutants to 

Requirement taken directly 

from PCC 17.16.430.G. 
15

Citation Applicable 

Units 

Standard 

Title Description Discussion 

Standard adjoining property. 

II.D.4 I1E, I2D, 

I3D, & I4E 

Chemical 

Limitation. 

Prohibition of using 

chromium based water 

treatments. 

PCC 17.12.190 requirement 

established to avoid 40 CFR 63 

Subpart Q – Industrial Process 

Cooling Towers. 

 5. Coal Preparation Plant 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.E.1. 

CPP and 

associated 

equip 

Particulate 

Matter 

Standards 

Hourly limits for PM 

emissions. 

Requirements taken directly from 

PCC 17.16.310.B 

II.E.2 

CPP and 

associated 

equip 

Material 

Handling 

Standard 

Handling requirements. Requirements taken directly from 

PCC 17.16.100.A & 17.16.310.E. 

II.E.3 

CPP and 

associated 

equip 

Stacking 

Standard Stacking requirements. Requirements taken directly from PCC 17.16.110.A & 17.16.310.E. 

II.E.4 

CPP and 

associated 

equip 

Storage 

Pile 

Standards 

Storage pile 

requirements. 

Requirements taken directly from 

PCC 17.16.110.B & 17.16.310.E. 

II.E.5 

CPP and 

associated 

equip 

Control 

Measures 

Standards 

Control measure 

requirements. 

Requirements taken directly from 

PCC 17.16.100, 17.16.110.A, & 

17.16.110.B 

 6. Fly-Ash Handling Systems 

Citation Applicable 

Units Standard Title Description Discussion 

II.F.1. FAHS 

Particulate 

Matter 

Standards 

Hourly limits for 

PM emissions. 

Requirements taken directly from 

PCC 17.16.430.A.1. 

 7. Open Areas, Roadways, & Streets 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.G.1 Various 

Construction 

Limitation 

Standard 

Control measure 

requirements. 

Requirements taken directly from 

PCC 17.16.080.A & SIP 318.A. 

II.G.2 Various Cleared land Dust suppression Requirement taken directly from 
16

Citation Applicable 

Units 

Standard 

Title Description Discussion 

Standard. requirements. PCC 17.16.080.B & SIP 318.B. 

II.G.3 Various 

Motor 

Vehicle 

Standard 

Vehicular traffic 

limitations. 

Requirement taken directly from 

PCC 17.16.080.C & SIP 318.C. 

II.G.4 Roadways 

Roadway 

Maintenance 

Standard 

Roadway 

maintenance 

requirements. 

Requirement taken directly from 

PCC 17.16.090.A. 

II.G.5 Roadways Asbestos 

Standard Asbestos prohibition. Requirement taken directly from PCC 17.16.090.F & SIP 315. 

 8. All Operations 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.H.1 All units & 

processes 

Opacity 

Standards Opacity limitations. Requirements taken directly from 

PCC 17.16.050.B & 17.16.130.B.3. 

II.H.2 All fuel fired 

units 

Definition of 

Heat Input 

Heat input 

determination for 

use in other 

formulas. 

Standard taken directly from PCC 

17.16.160.B, 17.16.165.B, & 

17.16.340.B. 

II.H.3 All units & 

processes 

Odor 

Limiting 

Standard 

Odor limiting 

requirement. 

Requirement taken directly from 

PCC 17.16.030. 

II.H.4 All units & 

processes 

Visible 

Emission 

Standard 

Visible emissions 

requirements. 

Requirement taken directly from 

PCC 17.16.050.D & SIP 343. 

 C. Air Pollution Controls: 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

III.A I4 

Air Pollution 

Control 

Standard 

Baghouse requirement 

when firing coal (PM). 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 8. 

III.B.1 Coal Prep 

Plant 

Air Pollution 

Control 

Standard 

Use of spray bars and 

other equipment to 

prevent fugitive dust 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 7. 

III.B.2 Coal Prep 

Plant 

Air Pollution 

Control 

Standards 

Minimize emissions 

when equipment listed 

is operated 

Control Officer requirements 

for good modern practices to 

operate and maintain air 

pollution control equip. 

III.C.1 

Fly-Ash 

Handling 

Systems 

Air Pollution 

Control 

Standards 

Use of spray bars and 

other equipment to 

prevent fugitive dust 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 7. 
17

Citation Applicable 

Units 

Standard 

Title Description Discussion 

III.C.2 

Fly-Ash 

Handling 

Systems 

Air Pollution 

Control 

Standards 

Minimize emissions 

when equipment listed 

is operated 

Control Officer requirements 

for good modern practices to 

operate and maintain air 

pollution control equip. 

III.C.3, 4 

Fly-Ash 

Handling 

Systems 

Air Pollution 

Control 

Standards 

Various pieces of 

equipment (PM). 

Control officer requirements 

and Preconstruction 

Requirements retained from 

Installation Permit #1156, 

Conditions 10 & 11. 

III.D.1 I4, CPP, 

FAHS 

Air Pollution 

Control 

Standards 

Control officer may 

require further controls 

if so deemed necessary. 

Preconstruction Requirement 

retained from Installation 

Permit #1156, Condition 13. 

III.D.2 Other 

equipment 

Air Pollution 

Control 

Standards 

Control officer may 

require further controls 

if so deemed necessary. 

Authority from PCC 

17.12.180.A.15 

 D. Monitoring Requirements34: 

 1. Fossil Fuel Fired Steam Generators 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

IV.A1.a I1, I2, & I3 

Opacity 

Monitoring 

Standard 

Weekly opacity 

monitoring 

schedule when 

firing liquid 

fuel. 

PCC 17.12.180 based requirement to 

demonstrate compliance with II.H.1 

as it pertains to Units I1, I2, & I3. 

IV.A.1.b I4 

Opacity 

Monitoring 

Standard 

Continuous 

Opacity 

Monitoring 

System 

requirements. 

Preconstruction Requirement retained 

from Installation Permit #1156, 

Condition 6. Other pertinent 

standards include: 17.12.060 & 40 

CFR 60 – Appendix B. 

IV.A.2 I4 

Compliance 

Assurance 

Monitoring 

CAM 

Requirements. 

These standards were proposed by 

TEP-IGS, verified by PDEQ against 

the requirements of 40 CFR 64.3(d) 

and 64.6. EPA had additional input on 

baghouse inspection requirements for 

CAM and PDEQ modified the CAM 

based on Appendix B Illustration No. 

1a of the CAM Illustrations guidance 

document January 2005 Revision 1. 

IV.A.3 I4 

SOx, NOx 

Monitoring 

Standards 

CEMS 

requirements 

for NOx & 

Preconstruction Requirement retained 

from Installation Permit #1156, 

Condition 6. 

 

34 For ADEQ discussion on Periodic Monitoring see Appendix A. 
18

Citation Applicable 

Units 

Standard 

Title Description Discussion 

SOx. 

IV.A.4 I4 

Coal 

Monitoring 

Standard 

Coal sampling 

required for 

each train load 

received. 

Preconstruction Requirement retained 

from Installation Permit #1156, 

Condition 3. 

 2. Stationary Rotating Machinery (Including Stationary Turbines) 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

IV.B.1 IGT1,2 & 

IGT1A,2A 

Opacity 

Monitoring 

Standard 

Weekly opacity 

monitoring schedule 

when firing liquid fuel. 

PCC 17.12.180 based requirement 

to demonstrate compliance with 

II.B.3 & II.H.1. 

IV.B.2 IGT1,2,&3 

Fuel Sulfur 

Monitoring 

Standard 

Sulfur content 

monitoring of liquid 

fuels. 

Adapted from PCC 17.16.340.I. 

IV.B.3 IGT1&2 

Hours of 

Operation 

Monitoring 

Standard 

Monthly monitoring of 

hours of operation. 

Adopted in conjunction with 

testing requirements in VII.A.1. 

 3. Coal Preparation Plant 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

IV.C.1 CPP 

Opacity 

Monitoring 

Standard 

Weekly opacity monitoring 

schedule. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the CPP. 

IV.C.2 CPP 

Opacity 

Monitoring 

Standard 

Method 9 required when 

excess emissions suspected. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the CPP. 

IV.C.3 CPP 

Opacity 

Monitoring 

Standard 

Required action subsequent 

to performing Method 9. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the CPP. 

IV.C.4 CPP 

Opacity 

Monitoring 

Standard 

Required action subsequent 

to performing Method 9. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the CPP. 
19

 4. Fly-Ash Handling Systems 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

IV.D.1 FAHS 

Opacity 

Monitoring 

Standard 

Weekly opacity 

monitoring schedule. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the FAHS. 

IV.D.2 FAHS 

Opacity 

Monitoring 

Standard 

Method 9 required 

when excess emissions 

suspected. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the FAHS. 

IV.D.3 FAHS 

Opacity 

Monitoring 

Standard 

Required action 

subsequent to 

performing Method 9. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the FAHS. 

IV.D.4 FAHS 

Opacity 

Monitoring 

Standard 

Required action 

subsequent to 

performing Method 9. 

Monitoring to demonstrate 

compliance with II.G.1 as it 

pertains to the FAHS. 

 E. Recordkeeping Requirements:

 1. Fossil Fuel Fired Steam Generators 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.A.1 I1, I2, & I3 

PM 

Recordkeeping 

Standard. 

Requirement to keep 

records of liquid fuel 

specs. 

Recordkeeping to 

demonstrate compliance 

with II.A.1. 

V.A.2 I1, I2, & I3 

SOx 

Recordkeeping 

Standard. 

Requirement to records of 

liquid fuel specs. 

Recordkeeping to 

demonstrate compliance 

with II.A.2.a. & II.A.5.a. 

V.A.3 I1, I2, I3 & 

I4 

Fuel 

Recordkeeping 

Standard. 

Requirement to record 

fuel switching. 

Recordkeeping to 

demonstrate compliance 

with II.A.5. 

V.A.4 I1, I2, & I3 

Hours of 

Operation 

Recordkeeping 

Standard. 

Requirement to record 

hours of operation and 

hours during which liquid 

fuel is fired. 

Recordkeeping to 

demonstrate testing 

requirements per VII.A.1. 

 2. Stationary Rotating Machinery (Including Stationary Turbines) 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.B.1 IGT1,2,& 

IGT1A,2A 

PM 

Recordkeeping 

Standard. 

Requirement to keep 

records of liquid fuel 

specs. 

Recordkeeping to demonstrate 

compliance with II.B.1. 

V.B.2 IGT1,2,& 

IGT1A,2A 

SOx 

Recordkeeping 

Standard. 

Requirement to keep 

records of liquid fuel 

specs. 

Recordkeeping to demonstrate 

compliance with II.B.2. 
20

 3. Auxiliary Boiler 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.C IAUX 

Fuel 

Recordkeeping 

Standard 

Requirement to keep records 

of changes to fuels fired. 

Recordkeeping to 

demonstrate compliance 

with II.C.3. 

 4. Coal Preparation Plant 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.D.1 CPP 

Best Modern 

Practices 

Recordkeeping 

Standard 

Requirement to record best 

modern specifications onsite. 

Recordkeeping to 

demonstrate compliance 

with II.E.2, 3, 4, & 5. 

V.D.2 CPP 

Maintenance 

Recordkeeping 

Standard 

Requirement to record 

maintenance actions 

performed on air pollution 

control equipment. 

Recordkeeping to 

demonstrate compliance 

with III.B. 

 5. Fly-Ash Handling Systems 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.E.1 FAHS 

Best Modern 

Practices 

Recordkeeping 

Standard 

Requirement to record best 

management specifications 

on-site. 

Recordkeeping to 

demonstrate compliance 

with II.F.2, 3, 4, & 5. 

V.E.2 FAHS 

Maintenance 

Recordkeeping 

Standard 

Requirement to record 

maintenance actions 

performed on air pollution 

control equipment. 

Recordkeeping to 

demonstrate compliance 

with III.C. 

 6. Open Areas, Roadways, & Streets 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

V.F Various 

Control 

Measure 

Recordkeeping 

Standard 

Requirement to keep records 

of control measures adopted. 

Recordkeeping to 

demonstrate compliance 

with II.G.1, 2 & 4. 
21

 F. Reporting Requirements:

 1. Fossil Fuel Fired Steam Generators 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VI.A.1 I4 

CAM 

Reporting 

Standard 

Reporting required in 

conjunction with 

Compliance Assurance 

Monitoring. 

Requirement taken from 

40 CFR 64.7(d). 

VI.A.2 I4 Fuel Reporting 

Standard 

Requirement to report 

results of coal analyses. 

Preconstruction 

Requirement retained 

from Installation Permit 

#1156, Condition 3. 

 2. Stationary Gas Turbines (Including Stationary Turbines) 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VI.B IGT1,2 & 

IGT1A,2A 

Fuel Reporting 

Standard 

Reporting when sulfur 

content of fuels fired 

exceeds 0.8%. 

Requirement taken 

directly from 17.16.340.J. 

 3. Auxiliary Boiler 

 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VI.C IAUX 

Opacity 

Reporting 

Standard 

Requirement to report 6-

minute periods where 

visible emissions exceed 

15% opacity. 

Requirement taken 

directly from PCC 

17.16.165.J. 

 4. All Operations 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VI.D All units & 

processes 

Special 

Reporting 

Standard 

Requirement for prompt 

reporting or permit 

deviations. 

Requirement taken from 

PCC 17.12.180.A.5.a, 

A.R.S. §49-480.B, & 

A.A.C. 18-2-310.01. 

VI.E I4 

CEMS/COMS 

Reporting 

Standard 

Requirement for quarterly 

reporting re: CEMS/COMS. 

Requirement taken from 

PCC 17.12.060.E.4, 

A.R.S. §49-480.B, & 

A.A.C. 18-2-310. 
22

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VI.F All units & 

processes 

Semiannual 

Reports of 

Required 

Monitoring 

Requirement for semiannual 

reports of all permit 

deviations and exceedances. 

Requirement taken from 

PCC 17.12.180.A.5. 

VI.G All units & 

processes 

Compliance 

Certification 

Reporting 

Requirement for annual 

compliance certification. 

Requirement taken from 

PCC 17.12.220. 

VI.H All units & 

processes 

Emissions 

Inventory 

Reporting 

Requirement for annual 

emissions inventory. 

Requirement taken from 

PCC 17.12.320. 

 G. Testing Requirements35:

 1. Fossil Fuel Fired Steam Generators 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VII.A.1 I1, I2, & I3 SOx Testing 

Standard 

Requirement to conduct 

performance test on units 

that fire liquid fuel 

greater than 1300 hours 

per 12-month period. 

Requirement carried over 

from previous permit to 

determine compliance with 

II.A.2.a which used 40 CFR 

72.2 as a GUIDELINE. It 

requires units that fire liquid 

fuel as their primary fuel to 

conduct an annual 

performance test. These units 

are NOT subject to 40 CFR 

72. The 1300-hour limitation 

comes from 72.2’s definition 

that firing liquid fuel 15% of 

the time shall be considered 

firing liquid fuel as the 

primary fuel. 1300 is ~15% of 

8760. The bases for this 

requirement are PCC 

17.12.180.A.3.a & 17.12.050. 

VII.A.2 I4 

Criteria 

Emissions 

Testing 

Standard 

Requirement for annual 

performance test for 

Opacity, PM, SOx, and 

NOx when firing coal. 

Requirement carried over 

from previous permit to 

determine compliance with 

II.A.1, II.A.2.b, II.A.3, & 

II.A.4. 

 

35 For ADEQ discussion on Testing Requirements see Appendix A. 
23

 2. Stationary Rotating Machinery (Including Stationary Turbines) 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VII.B.1 IGT1&2 SOx Testing 

Standard 

Requirement to conduct 

performance test on units 

that fire liquid fuel greater 

than 1300 hours per 12-

month period. 

Requirement carried over 

from previous permit to 

determine compliance 

with II.B.2 which used 40 

CFR 72.2 as a 

GUIDELINE. It requires 

units that fire liquid fuel 

as their primary fuel to 

conduct an annual 

performance test. These 

units are NOT subject to 

40 CFR 72. The 1300 

hour limitation comes 

from 72.2’s definition 

that firing liquid fuel 15% 

of the time shall be 

considered firing liquid 

fuel as the primary fuel. 

1300 is ~15% of 8760. 

The bases for this 

requirement are PCC 

17.12.180.A.3.a & 

17.12.010. 

VII.B.2 IGT1&2 CO Testing 

Standard 

Requirement to conduct 

performance test on units 

that exceed 4500 hours in a 

12-month period. 

Requirement carried over 

from previous permit. 

The basis for this 

requirement is ARS 49-

422. 

 3. All Operations 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

VII.C All units & 

processes 

General 

Testing 

Standard 

Requirement to contact 

control officer for applicable 

test methods when testing is 

required or requested. 

Standard PDEQ 

requirement. 
24

 H. Acid Rain Permit 

Citation Applicable 

Units 

Standard 

Title Description Discussion 

II.A I1 

SOx & NOx 

Emission 

Standards 

Annual limitations of 

respective pollutants. 

Limitations taken directly 

from 40 CFR Part 73 

Table 2. 

II.B I2 

SOx & NOx 

Emission 

Standards 

Annual limitations of 

respective pollutants. 

Limitations taken directly 

from 40 CFR Part 73 

Table 2. 

II.C I3 

SOx & NOx 

Emission 

Standards 

Annual limitations of 

respective pollutants. 

Limitations taken directly 

from 40 CFR Part 73 

Table 2. 

II.D I4 

SOx & NOx 

Emission 

Standards 

Annual limitations of 

respective pollutants. 

Limitations taken directly 

from 40 CFR Part 73 

Table 2. 

 I. Alternate Operating Scenario #1 

Citation Applicable 

Units Standard Title Description Discussion 

II IGT3 Notification & 

Recordkeeping 

Notification 

Requirements upon 

installation, startup 

and performance 

testing of unit IGT3. 

Various general applicable 

requirements taken directly from 

40 CFR 60 Subpart A and 40 

CFR 60 subpart KKKK, includes 

notification and recordkeeping 

requirements for TEP-IGS to 

notify PDEQ concerning IGT3. 

III.A IGT3 Operational 

Limitation 

Limited to use of 

natural gas. 

Use of any other fuels might 

cause IGT3 to trigger other 

applicable requirements. 

III.B.1.a IGT3 

Nitrogen 

Dioxide 

Standard 

NOx concentration 

based on 4-hour 

rolling average. 

Limitations taken directly from 

40 CFR 60.4320, Table 1, 

60.4325 and 60.4380.b.1. 

III.B.1.b IGT3 

Nitrogen 

Dioxide 

Limitation 

Annual TPY 

limitation on NOx. 

Limitation of 40 TPY to prevent 

triggering a significant 

modification under attainment 

NSR. 

III.B.2 IGT3 

Air Pollution 

Control 

Equipment 

Minimizing NOx 

emissions at all times 

Requirements taken directly 

from 40 CFR 60.4333.a 

III.B.3.a IGT3 Monitoring and 

recordkeeping 

Installation and 

certification of each 

NOx diluent CEMS. 

Requirements taken directly 

from 40 CFR 60.4345.a 

III.B.3.b IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with NOx 

concentration 

limitation. 

Requirements taken directly 

from 40 CFR 60.4335 
25

Citation Applicable 

Units Standard Title Description Discussion 

III.B.3.c IGT3 Monitoring and 

recordkeeping 

Flow meter 

installation. 

Requirements taken directly 

from 40 CFR 60.4345 

III.B.3.d IGT3 NOx limit 

monitoring 

Demonstrate 

compliance with the 

40 TPY annual limit 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to use CEMS to 

demonstrate emissions from unit 

are under 40 TPY and thus not 

trigger a significant modification 

under PSD. 

III.B.4 IGT3 Performance 

Testing 

Requirements taken directly 

from 40 CFR 60.4405, 60.4400.a 

III.C.1.a IGT3 Sulfur Dioxide 

Standard 

Fuel sulfur content 

limit. 

Limitations taken directly from 

40 CFR 60.4365 and use of PCC 

17.12.190.B. 

III.C.1.b IGT3 Sulfur Dioxide 

Standard 

Annual TPY 

limitation on SO2. 

Limitation of 40 TPY to prevent 

triggering a significant 

modification under attainment 

NSR. 

III.C.2.a IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with 

sulfur content limit 

Exemption from monitoring total 

sulfur content of fuel if TEP-IGS 

keeps current records of valid 

purchase contract, tariff sheet or 

transportation contract for the 

fuel showing required 

information. 

III.C.2.b IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with the 

40 TPY annual limit 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to use CEMS to 

demonstrate emissions from unit 

are under 40 TPY and thus do 

not trigger a significant 

modification under attainment 

NSR 

III.D.1 IGT3 

Carbon 

Monoxide 

Standard 

Annual TPY 

limitation on CO. 

Limitation of 100 TPY to 

prevent triggering a significant 

modification under attainment 

NSR. 

III.D.2 IGT3 Monitoring and 

recordkeeping 

Installation and 

certification of 

CEMS for CO 

emissions and diluent 

from IGT3. 

Requirements taken directly 

from 40 CFR 60.4345.c and use 

of PCC 17.12.180.A.3, A.4 & 

A.5 to require TEP-IGS to use 

CEMS to demonstrate emissions 

from unit are under 100 TPY and 

thus do not trigger a significant 

modification under PSD. 
26

Citation Applicable 

Units Standard Title Description Discussion 

III.E.1 IGT3 CEMS Installation of CEMS 

Requirements specifying how 

CEMS and DAHS should be 

installed, calibrated maintained 

and operated. In a meeting on 

10/10/06 TEP requested that 

with PDEQ approval, pursuant to 

40 CFR 60.4345, Procedure 1 in 

appendix F to this part is not 

required if the option to use a 

NOx CEMS is chosen. PDEQ 

approved the request to use the 

NOx CEMS and not Procedure 

1. 

III.E.2 IGT3 

Monitoring 

recordkeeping 

and reporting. 

Annual requirements 

for NOx, SO2 and CO 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to follow specific 

procedures in demonstrating 

compliance with the annual 

limits of NOx, SO2 and CO. 

J. Alternate Operating Scenario #2 

Citation Applicable 

Units Standard Title Description Discussion 

II IGT3 Notification & 

Recordkeeping 

Notification 

Requirements upon 

installation, startup 

and performance 

testing of unit IGT3. 

Various general applicable 

requirements taken directly from 

40 CFR 60 Subpart A and 40 

CFR 60 Subpart GG, includes 

notification and recordkeeping 

requirements for TEP-IGS to 

notify PDEQ concerning IGT3. 

III.A IGT3 Operational 

Limitation 

Limited to use of 

natural gas. 

Use of any other fuels might 

cause IGT3 to trigger other 

applicable requirements. 

III.B.1.a IGT3 

Nitrogen 

Dioxide 

Standard 

NOx concentration 

emission limit. 

Limitations taken directly from 

40 CFR 60.332.a. 

III.B.1.b IGT3 

Nitrogen 

Dioxide 

Limitation 

Annual TPY 

limitation on NOx. 

Limitation of 40 TPY to prevent 

triggering a significant 

modification under PSD. 

III.B.2 IGT3 

Air Pollution 

Control 

Equipment 

Minimizing NOx 

emissions at all times 

Requirements taken directly 

from 40 CFR 60.11.d. 
27

Citation Applicable 

Units Standard Title Description Discussion 

III.B.3.a IGT3 Monitoring and 

recordkeeping 

Installation and 

certification of each 

NOx diluent CEMS. 

Proposed requirement by TEP -

IGS to install, certify, maintain 

and operate CEMS. Authority 

from 17.12.180.A.2 proposed by 

TEP-IGS on 10/31/06. 

III.B.3.b IGT3 Monitoring and 

recordkeeping 

Flow meter 

installation. 

Proposed requirement by TEP -

IGS to install, certify, maintain 

and operate fuel flow rate 

monitoring system. Authority 

from 17.12.180.A.2 proposed by 

TEP-IGS on 10/31/06. 

III.B.3.c IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with NOx 

concentration 

limitation. 

Requirements taken directly 

from 40 CFR 60.334 

III.B.3.d IGT3 NOx limit 

monitoring 

Demonstrate 

compliance with the 

40 TPY annual limit 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to use CEMS to 

demonstrate emissions from unit 

are under 40 TPY and thus not 

trigger a significant modification 

under PSD. 

III.B.4 IGT3 Performance 

Testing 

Requirements taken directly 

from 40 CFR 60.4405, 60.4400.a 

III.C.1.a IGT3 Sulfur Dioxide 

Standard 

Fuel sulfur content 

limit. 

Limitations taken directly from 

40 CFR 60.333.b and use of PCC 

17.12.190.B. 

III.C.1.b IGT3 Sulfur Dioxide 

Standard 

Annual TPY 

limitation on SO2. 

Limitation of 40 TPY to prevent 

triggering a significant 

modification under PSD. 

III.C.2.a IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with 

sulfur content limit 

Exemption from monitoring total 

sulfur content of fuel if TEP-IGS 

keeps current records of valid 

purchase contract, tariff sheet or 

transportation contract for the 

fuel showing required 

information. 

III.C.2.b IGT3 Monitoring and 

recordkeeping 

Demonstrate 

compliance with the 

40 TPY annual limit 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to use CEMS to 

demonstrate emissions from unit 

are under 40 TPY and thus do 

not trigger a significant 

modification under PSD. 

III.D.1 IGT3 

Carbon 

Monoxide 

Standard 

Annual TPY 

limitation on CO. 

Limitation of 100 TPY to 

prevent triggering a significant 

modification under PSD. 
28

Citation Applicable 

Units Standard Title Description Discussion 

III.D.2 IGT3 Monitoring and 

recordkeeping 

Installation and 

certification of 

CEMS for CO 

emissions and diluent 

from IGT3. 

Proposed requirement by TEP -

IGS to install, certify, maintain 

and operate CEMS. Authority 

from 17.12.180.A.2 proposed by 

TEP-IGS on 10/31/06. Use of 

PCC 17.12.180.A.3, A.4 & A.5 

to require TEP-IGS to use CEMS 

to demonstrate emissions from 

unit are under 100 TPY and thus 

do not trigger a significant 

modification under PSD. 

III.E.1 IGT3 CEMS Installation of CEMS 

Requirements specifying how 

CEMS and DAHS should be 

installed, calibrated maintained 

and operated. Pursuant to 40 

CFR 60.334 Procedure 1 in 

appendix F to this part is not 

required. 

III.E.2 IGT3 

Monitoring 

recordkeeping 

and reporting. 

Annual requirements 

for NOx, SO2 and CO 

Authority from PCC 

17.12.180.A.3, A.4 & A.5 for 

TEP-IGS to follow specific 

procedures in demonstrating 

compliance with the annual 

limits of NOx, SO2 and CO. 

VII. Previous Permit Conditions

The following standards were removed from the permit [citations refer to the previous permit (See Previous 

Permit – Appendix D)]: 

 A. Standards pertaining to the IGT3 NOx limitation that have been made unnecessary by the requirement 

to install and operate CEMS: I.C.7, III.C.2.c, d, e, f, g, h, i, j, k, l, m, & n. IV.D.9.c, and IV.E.1 & 2. 

 B. Standards which are not based in an applicable rule: I.D.1. 

 C. Standards which pertain to insignificant activities: I.I, I.L, & I.M, III.J, and III.K. 

 D. Standards which pertain to equipment removed from TEP-IGS: I.N, and III.L. 

 E. Standards which have been made unnecessary by CAM requirements: III.B.2.a. 

 F. Standards which reference/are based upon nonexistent permit requirements: III.D.3. 

 G. Requirements for IGT3 have been removed from the main permit and replaced by the Alternate 

Operating Scenario in Attachment G. 
29

 H. Testing for NOx on I3, CO on I1, I2 and I3 has been completed. Conditions removed were; IV.A.2 

and 3. Testing for NOx and CO on IGT1 and IGT2 has been completed. Conditions removed were; 

IV.C. The justification is that once the initial testing was completed there was no underlying 

regulation to continue requiring testing for the pollutants. There is also no need to test because the 

current equipment is not limited to any type of emission rates for the above pollutants. TEP-IGS is a 

grandfathered source and unless NSR is triggered through a significant modification or other 

requirements specify some form of regular testing, PDEQ deems it unnecessary to require TEP-IGS 

to test for NOx or CO.