# 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 CodeD243-01 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 extensionbeyond the April 1,2011 deadline, (see letter dated September 

### 2 1,20 lo), to allow Big Sandy Peaker Plant, LLC (Big Sandy) to continueusing its existing inventory of diesel fuel because it does not fully meet the requirements of 40 CFR $80.510(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, 

### “Standardsof 

### Performance for 

### Stationary Compression Ignition Internal Combustion Engines. ” One applicablerequirement of Subpart 1111is that, starting October 1,201 

### 0, the black start generatormust be fired exclusivelyby 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 compliantwith 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, slightlyhigher 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, fillingup the tank with additional ultra-low sulfur diesel will likely not reduce the overall sulfur concentration to below 15 ppm. In addition, the black startMarch 3,2011 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 deadlinebased 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 

### ofusing the fuel, which would be both a waste of fuel and unnecessarily create additional air emissions. Shouldyou 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, certifyunder penalty of law that this document and all attachmentswere prepared under my direction or supervisionin accordancewith a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry ofthe person or persons directly responsible for gathering the information, the information submittedis, 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 ofEnvironmental Protection Division ofAir Quality U.S.Environmental ProtectionAgency Region I11 Mr. Chris Crotts, Big Sandy Peaker Plant, LLC Mr. Bart Vince, NAES

## 1

Sincerely, t02/25/2011 14:54 16105834204 #1307 P.002/002

ASTM D5453 ASTM D976 SABOLT FAX 

### Fast 

### To The Point SAYBOLTLP 780B PrimosAvenue Folcroft, FA 19032 6104834460Telephone 610-583-4204 Facsimile 

### Saybolt 

## LP

A meCABORAIRLIE cnwm t 

### Certificate of Analysis Client: Saybolt, Ashland, KY ReportDate: 2/25/2alI Date 

### Sampled: 2/24/2011 Job No: allocation Product: ULSD Dyed Lab Number: 2011000289-001 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

Page I of 2