BIGSANDY 

PEAKER 

Big Sandy Peaker Plant, LLC 

1044 N. 115 Street, Suite 400 I Omaha, Nebraska 68154-4446 

402-691 -9500 I FAX: 402-691 -9526 

March 3,201 1 

Ms. Melanie King 

Energy Strategies Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Mail Code D243-01 

Research Triangle Park, NC 2771 1 

Via Email & Overnight Courier 

RE: 40 CFR 560.4207(c) Petition 

Big Sandy Peaker Plant, LLC 

Kenova, West Virginia 

WV Title V Permit No. NO-09900080-2009 

Dear Ms. King: 

The purpose of this correspondence is to request a six-month extension beyond the April 1,201 1 

deadline, (see letter dated September 2 1,20 lo), to allow Big Sandy Peaker Plant, LLC (Big 

Sandy) to continue using its existing inventory of diesel fuel because it does not fully meet the 

requirements of 40 CFR $80.5 10(b) for non-road diesel fuel. Background information and 

justification for this request is provided below. 

Big Sandy operates a 330 Megawatt natural gas-fired electric generating peaking station in 

Kenova, WV. The facility includes a 1,135 Bhp black start generator fired by No. 2 diesel fuel 

that is subject to 40 CFR Part 60, Subpart 1111, “Standards of Performance for Stationary 

Compression Ignition Internal Combustion Engines. ” One applicable requirement of Subpart 

1111 is that, starting October 1,201 0, the black start generator must be fired exclusively by fuel 

meeting the requirements of 40 CFR $80.5 1 O(b), including: 1) a maximum sulfur content of 15 

ppm, and 2) minimum Cetane Index of 40. Although Big Sandy purchased “ultra-low sulfur” 

diesel fuel that is compliant with the standard for the only refill of the fuel tank that was ever 

performed since initial installation of the black start generator in 2007, the results of a recent 

sample analysis indicate that the sulfur concentration of fuel currently in the generator tank is 20 

ppm, slightly higher than the maximum allowable concentration. It should be noted that the 

Cetane index in that same sample was 44.4, which is above the minimum of 40 specified by the 

standard. 

The fuel tank for the black start diesel engine has a capacity of 1,300 gallons. Because the tank 

is currently about 75 percent full, filling up the tank with additional ultra-low sulfur diesel will 

likely not reduce the overall sulfur concentration to below 15 ppm. In addition, the black start 
March 3,201 1 

Ms. Melanie King 

Page 2 

diesel engine is used infrequently-it operated a total of 27 hours during all of 2009, 18.25 hours 

during all of 2010 and consumed only 600 gallons of fuel in its first two years of operation- so 

the facility cannot use the existing fuel supply prior to the deadline based on the normal 

operating schedule. Big Sandy believes that an extension is justified in this case because to use 

the existing inventory of fuel prior to the deadline the facility would need to operate the black 

start generator for an extended period of time solely for the purpose of using the fuel, which 

would be both a waste of fuel and unnecessarily create additional air emissions. 

Should you have questions about this request, please contact me at cmcouvillion@tenaska.com 

or (402) 691 -9598 or Christopher Crotts, Plant Manager, at (304) 75 1-02 19. 

Sincerely, 

BIG SANDY PEAKER PLANT, LLC 

a Maryland limited liability company 

By: &A&dLL kY-Z-----+-- 

Christie Couvillion 

Environmental Specialist 

Certification 

I, Todd S. Jonas, certify under penalty of law that this document and all attachments were prepared under my 

direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and 

evaluate the information submitted. Based on my inquiry of the person or persons directly responsible for gathering 

the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. 

I am aware that there are significant penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violation. 

cc: WV Department of Environmental Protection Division of Air Quality 

U.S. Environmental Protection Agency Region I11 

Mr. Chris Crotts, Big Sandy Peaker Plant, LLC 

Mr. Bart Vince, NAES 
1 

Sincerely, 

t 
02/25/2011 14:54 16105834204 #1307 P. 002/002 

ASTM D5453 

ASTM D976 

SABOLT FAX 

Fast To The Point SAYBOLT LP 

780B Primos Avenue 

Folcroft, FA 19032 

6104834460 Telephone 

6 10-583-4204 Facsimile Saybolt LP A me CABORAIRLIE cnwm t 

Certificate of Analysis 

Client: Saybolt, Ashland, KY 

Report Date: 2/25/2alI Date Sampled: 2/24/2011 

Job No: allocation Product: ULSD Dyed 

Lab Number: 201 1000289-001 Sampfe ID: Big Sandy Peaker Plant Upper 

Client Ref: Generator Location: Ashland, WV 

Test Method Result Units 

Gravity, API @ 60 "F ASTM D287 35.0 Q 60 OF 

Distillation ASTM 086 

I BP 355.2 "F 

10% Rec 407.8 "F 

50% Rec 490.1 "F 

90% Rec 600.9 "F 

End Paint 659.5 *F 

Recovery 98.5 . Vol% 

Residue 1.3 VOl% 

Loss 0.20 Vol% 

20 PPm Sulfur Content 

Cetane Jndex 44.4 

Approved By: "d+ - 

Simon Kleynman 

Laboratory Manager 

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