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 pr omulgated regulations that required certain large power plants to convert their operations to additi onally 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 Insta llation Permit #1156). The Arizona Department of Environmental Quality (ADEQ) issued this perm it 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 th is 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 ex emption also applied to the coal preparation plant as it was constructed during the coal conversion project.

In the late 1990’s TEP requested that juri sdiction over TEP-IGS be returned to Pima County Department of Environmental Quality, (PDEQ); th e 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 ne w, simple cycle combustion turbine to be added as a peaking unit. Via emission limitations this di d 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 desi gnated 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, th ere 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 thou gh 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 (SO 2 ), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Vola tile Organic Compounds (VOC). Specific pollutant emission rates are provided in Section IV of this document.

b. Turbine

Steam exiting the boilers enters a turbine un it. 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 p assing 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 tu rn, 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 pr ocess: (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 turbin e blades. The resulting movement of the blades causes the shaft to rotate. Exha ust gasses and pollutants produced during combustion are released to the ambient atmosphere after passing through air pollution controls (if required). Emissions resulti ng from combustion typically include PM, SO 2 , 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 tu rn, 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, SO 2 , 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 Sta tionary Rotating Machinery (Stationary Combustion Turbines & Diesel Turbine Starter Engines (IGT3)).4 D. Air Pollution Control Equipment

Air Pollution Control Equipment is required for f our pieces of equipment and processes: (1) UNIT I4; (2) UNIT IGT3; (3) the Coal Preparation Pl ant; and (4) the Fly-Ash Handling Plant.

1. UNIT I4

The Permittee is required to install and ma intain 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 require d 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 PD EQ 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 emi ssion 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 in formation on emissions from TEP-IGS. These emission calculations are not meant to establish any baseline em ission levels. These emission figures (except for the ALLOWABLE emissions) are not meant to be emissi on limitations of any form. The following tables summarize the potential to emit (PTE), allowable emissi ons, 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/hr 1 (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/hr 2 (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/hr 3 (753 tpy) NOx 224 982 NA

SOx 754 3303 1 lb SO 2 /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/hr 5 (753 tpy) NOx 224 982 NA

SOx 754 3303 1 lb SO 2 /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.16 

### 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/hr 7 (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/hr 8 (933 tpy) NOx 292 1280 NA

SOx 983 4307 1 lb SO 2 /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/hr 10 (1362 tpy)

NOx 468 2050 0.7 lb NO 2 /MMTU

– 3 hr average (5218 tpy) 11

SOx 1.0 4.5 1 lb SO 2 /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/hr 13 (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.C7 

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

NOx 477 2090 0.7 lb NO 2 /MMTU

– 3 hr average (5218 tpy) 14

SOx 1604 7029 1 lb SO 2 /MMBtu – 3 hr average (3504 tpy) 15
CO 56.8 249 NA VOC 8.0 35 NA THAP 1.6 7 NA

PM 41.1 181 16 223 lb/hr (977 tpy) 17

NOx 883 3866 0.7 lb NO 2 /MMTU

– 3 hr average (5218 tpy) 18

SOx 1164 5099 1 lb SO 2 /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 PM 10 . 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. U NITS IGT 1A, IGT 2A, & IGT 3A (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/hr 25 (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/hr 26 (125 tpy) NOx 11.0 48 NA

SOx 30.0 131 1 lb SO 2 /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 Federa l Regulations Title 40:

Part 60 Subpart KKKK Standards of Perform ance 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 Dete rmination 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 fo r Fossil-Fuel Fired Steam Generators and General Fuel Burning Equipment 17.16.165 Standards of Performance fo r Fossil-Fuel Fired Industrial and Commercial Equipment 17.16.310 Standards of Perform ance for Coal Preparation Plants 17.16.340 Standards of Performance for Stationary Rotating Machinery 17.16.430 Standards of Pe rformance 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 De partment 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 presen t turbines are subject to the notification requirements of Subpart YYYY. After reviewi ng 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 appl y 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 turb ines fall into the subcategory defined under 40CFR 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

U NIT I 4 (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 plan ts to convert their ope rations 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 U NIT I 4 was converted. Since this change w as 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 Constr uction 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 applicab le substances of which fly-ash is not a part.

D. Promulgated standards whic h will be or may be applicable:

1. 40 CFR 63 Subpart DDDDD – NESHAPs for Indu strial, 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 majo r 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 notificati on date was Febr uary 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 – NESHAP s for Stationary Combustion Turbines.

a. Potentially Applicable Units: IGT 1, IGT 2, & IGT 3. Applicability includes stationary combustion turbines at major sources of HAP (63.6085).

b. The promulgation date was March 5, 2004.

c. The initial notifica tion 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: IGT 1A, IGT 2A, IGT 3A (may be introduced with IGT 3). Applicability includes stationary rotating machinery >500hp at major sources of HAP (63.6585). Emergency and Limited us e 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 - U NITS I 1, I 2, I 3, & I 4 of the previous permit – main PCC standard: 17.16.160.

2. Stationary Rotating Machinery (including Stationary Turbines) - U NITS IGT 1, IGT 2, IGT 1A, &
IGT 2A of the previous permit – main PCC standard: 17.16.340.

3. Auxiliary Boiler - Unit IAUX of the prev ious 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 Plan t, 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 from16 

### 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 Requirements 34 :

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 Machin ery (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 Machin ery (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 bestmodern 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 Requirements 35 :

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 Machin ery (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 60.433525 

### 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 SO 2 . 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, SO 2 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, SO 2 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 SO 2 . 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, SO 2 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, SO 2 and CO.

VII. Previous Permit Conditions

The following standards were removed from the permit [c itations refer to the previous permit (See Previous Permit – Appendix D)]:

A. Standards pertaining to the IGT3 NOx limitati on 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 fro m 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 h as 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 pollu tants. There is also no n eed 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 triggere d 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.