Compliance at the Coolidge Generating Station (TPD1701033)

PCAQCD Air Permit

• Subject to Title V requirements due to potential for annual emissions of NOx, CO, PM1ofPM 2 _5 or VOCs to reach 100 tons.
• As an electric generating facility capable of generating more than 25 MW the facility is also subject to the Title IV Acid Rain Program.
• The facility is a synthetic minor with respect to Prevention of Significant Deterioration and has a cap of 245 tons per 12- calendar month period per pollutant.

PCAQCD Regulation 4-1-030 – Control of fugitive emissions from unpaved lots/acreage in nonattainment area for PM10.

ADEQ Aquifer Protection Permit

• Facility is zero discharge; all wastewater generated at the facility is held in double-lined evaporation ponds with a leak collection and removal system.
• Covers process wastewater generated at the facility including reverse osmosis wastewater, multi-media filter backwash and CTG evaporative cooler blowdown.

Arizona Department of Water Resources

• Permit for two groundwater wells on-site to provide all water for facility use.
• Limit of 279 acre-feet/year for this permit.
• Reporting – Annual Water Withdrawal and Use Report (Groundwater Summary)

Monitoring Requirements

• Daily monitoring of the Leak Collection Removal System (LCRS) (manually or continuous)
• Weekly and after significant storm inspect the evaporation ponds for freeboard, fluid level, liner integrity, berm integrity, evidence of overtopping, operational condition  of the LCRS and flow meter or other measuring device.
• Quarterly check the oily water separator for damage or leakage, sludge accumulation, oil sheen or odor of effluent, and piping, pumps valves and controls are operating correctly.

Reporting Requirements

• Exceeding alert levels for the LCRS: Level 1 – normal liner leakage (417 gpd) or Level 2-        Liner failure (13,124 gpd); discharge of unauthorized materials; failure of containment structure; over-topping of evaporation pond; and permit violation.
• Annual Compliance Report

Monitoring Requirements

• Continuous Emissions Monitors (CEMs) installed on each CTG stack
  • Monitor NOx and CO emissions – daily
  • Determine PM, voe and SO2 using an emission factor (lbs/MMBtu) based on annual performance testing – daily
• Inlet and Outlet air temperature – daily
• Fuel consumption (and associated sulfur content through contractual commitment) – daily
• Opacity screening –  semi-annually
• Fire pump fuel – only purchase on-highway diesel fuel (500 ppmv sulfur or less)
• Hours of operation: start-up, normal and shut-down
• Fuel flow/heat input

Testing Requirements

• Annual performance testing for NOx, CO, PM10, SO2, VOCs and opacity
• Annual Relative Accuracy Test Audits on the CEMS

Recordkeeping Requirements

• Monthly emissions of NOx, CO, PM10, voe and SO2 (monthly, 12 month rolling and a monthly emission budget report that compares 10 month rolling to 12 month rolling ensuring facility does not get close to 245 ton limit)
• Total natural gas burned
• CTG run times
• Number of start-up and shut-down cycles for each CTG
• Malfunction in operation of facility or any air pollution control equipment
• Diesel shipments received for fire pump engine
• Operational hours of fire pump engine
• Date and duration of water washes
• Projects involving abrasive blasting or spray painting
• Semi-annual compliance reporting – PCAQCD
• Annual Compliance Report to permit provisions – PCAQCD and EPA
• Annual Emissions Inventory – PCAQCD
• Quarterly Emissions Collection and Monitoring Plan System (ECMPS) used to submit monitoring plans, QA data, and emission data under the Acid Rain Program – EPA
• Annual Greenhouse Gas Reporting Program – EPA
• Any deviations from permit requirements – within 15 days to PCAQCD
• Written report for annual Relative Accuracy Test Audits and Performance tests – PCAQCD
• Excess emissions – verbally within 24 hours, written within 3 working days to PCAQCD

PCAQCD Air Permit

Article 1 – West Pinal PM10    Moderate Nonattainment Area Fugitive Dust

• Became effective on January 1, 2016.
• Requires the owner and/or operator of open areas/vacant lots shall not cause, suffer, allow, or permit fugitive dust emissions which result in opacity of the dust to exceed twenty percent (20%) as measured using an opacity method.
• CGS has approximately 60 acres of open area covered under this regulation.
• We obtained bid from three vendors for dust suppression, which included graveling areas of high traffic.
• Bid awarded to Soilworks LLC.

Map of Facility

Dust Palliative

Soilworks LLC

• Dust palliative used was Gorilla-Snot –  applied to 60 non-traffic acres, costing approximately $30,000 including material, application and removal of containers ($500 per acre).
• The product is a biodegradable, copolymer-based that is primarily engineered to control dust and erosion.
• For traffic areas CGS opted to have gravel spread 1-1.5 inches thick to provide roadways for contractor truck or site vehicles, and the site requirement is a 10 mph speed limit within the site.
• Cost of gravel and spreading was approximately $25,000.
• Project was completed by January 31, 2016.

Determining Compliance with 4-1-030

The owner and/or operator shall sign up to receive the Pinal County dust control forecast, and shall ensure the open areas/vacant lots is stabilized the day leading up to and the day that is forecast to be high risk for dust emissions.

Documentation the Dust Palliative is Functioning on High Wind Days