20131004IPC to Staff 62,63,65,69.pdf

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An IDACORP Company
t- - !1-
-^r': ^rrT I;!1: i t:r I - '_f i !l-|i,l :LISA D. NORDSTROM
Lead Counsel
I [e-mail]
October 4,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-16
Certificate for Public Convenience and Necessity for Jim Bridger Units 3 and
4 - ldaho Power Company's Response to Production Request Nos. 62, 63,
65, and 69 of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Response to Production Request Nos. 62, 63, 65, and 69 of the
Commission Staff ("Staff') to ldaho Power Company. ldaho Power anticipates providing
responses to Production Request Nos. 64, 66, 67, and 68 no laterthan Tuesday, October
8.
Sincerely,
4,1&;0.4^*ru^"
Lisa D. NordstromU
LDN:evp
Enclosures
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (lSB No. 7432) :,,ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70 ',
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom@ id ahopower. com
irein hardt@id a ho power. co m
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3
AND 4.
'J :l. *i: i',i ?: i !
)) CASE NO. rPC-E-13-16
)) TDAHO POWER COMPANY',S
) RESPONSE TO PRODUCTTON
) REOUEST NOS.62,63,65, AND
) 69 OF THE COMMTSSTON
) STAFF TO rDAHO POWER
) CoMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?hy"), and in
response to Production Request Nos. 62, 63, 65, and 69 of the Commission Staff
("Staff') to ldaho Power Company dated September 26, 2013, herewith submits the
following information :
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62,63,65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 62: Please provide a copy of the Air Quality Permit issued by
the Wyoming Department of Environmental Quality (WDEO) associated with the Project
that was viewed onsite under the Company's response to Production Request No. 21.
RESPONSE TO REQUEST NO. 62: A copy of the Air Quality Permit MD-13260,
issued by the WDEQ is attached to this request.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 63: Please describe in general and in detail the measures or
procedures ldaho Power has in place to ensure that PacifiCorp only incurs prudently
incurred costs in the project design and implementation of Jim Bridger Nos. 3 and 4
catalytic controls.
RESPONSE TO REQUEST NO. 63: Pursuant to the Agreement for the
Operation of the Jim Bridger Project, PacifiCorp is required to operate and maintain the
Jim Bridger plant at the lowest reasonable cost and in a prudent and skillful manner in
accordance with the standards prevailing in the utility industry and with applicable laws.
This obligation applies to the selective catalytic reduction ("SCR') project. ldaho Power
Company ("ldaho Powe/') has and will continue to monitor PacifiCorp's actions in a
variety of ways, including periodic owner meetings, document reviews, and site visits.
The periodic owner meetings between PacifiCorp and Idaho Power are
specifically geared towards informing ldaho Power about operations at the plant.
During such meetings, ldaho Power plans to place significant emphasis on the SCR
work, including budgetary items, the project schedule, outage timeframes, and other
events and issues.
As to document review, ldaho Power has and will continue to request bi-weekly
progress reports related to the SCR work. These reports provide updates on numerous
issues related to the project, including construction timelines, coordination issues, and
budgetary items. ldaho Power anticipates following up on any notable items set forth in
those reports. ldaho Power further intends to request additional documents from
PacifiCorp in the event the report does not provide a comprehensive review of the
activities at Jim Bridger plant.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Finally, ldaho Power intends to perform site visits to monitor the progress of the
work. ldaho Power will receive additional updates during those visits.
As PacifiCorp owns two-thirds of Jim Bridger plant, their interests align with ldaho
Power to complete the SCR project in the most cost effective way. ldaho Power will
continue to monitor the SCR project and continue to have discussions with PacifiCorp
on the SCR projects' progress and costs.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
TDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 65: Please provide a description, assumptions, and calculation
for the cost labeled "capital surcharge" on the spreadsheet the Company provided in
response to Staff Production Request No. 32.
RESPONSE TO REQUEST NO. 65: PacifiCorp applies an allocated capital
surcharge to capital projects to ensure that support costs that are not directly charged to
capital projects, are included into the projects. Charges that are considered capital in
nature that are included in this capital surcharge pool are primarily engineering
supervision and support, security services, administration costs, financial management,
and procurement. This capital surcharge poo! is allocated to projects based on a
percentage of the charges to the projects. To ensure that large projects are not
allocated a disproportionate amount of the capital surcharge pool, a capital surcharge
limit is set for major projects. Once a project reaches the capita! surcharge limit, then it
is no longer allocated any additional capital surcharge amounts. When charges to a
pQect reach or exceed $10,000,000, it is no Ionger allocated any additiona! capital
surcharge amounts. The maximum cost limit for calculation of capital surcharge of a
project over $10,000,000, will have an associated capital surcharge rate of 4.90
percent. Accordingly, the total capital surcharge limit anticipated to be accrued to the
project per unit is $490,000 (100 percent share basis).
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 69: Please describe the method used to ensure that each PO
and contract described in Staff Production Request No. 66 was procured prudently and
at a reasonable cost.
RESPONSE TO REQUEST NO. 69: Pursuant to the Agreement for the
Operation of the Jim Bridger Project, PacifiCorp is required to operate and maintain the
Jim Bridger plant at the lowest reasonable cost and in a prudent and skillful manner in
accordance with the standards prevailing in the utility industry and with applicable laws.
This obligation applies to the SCR project. ldaho Power has and will continue to
monitor PacifiCorp's actions in a variety of ways, including periodic owner meetings,
document reviews, and site visits.
As to document review, Idaho Power has and will continue to request bi-weekly
progress reports related to the SCR work. These reports provide updates on numerous
issues related to the project, including construction timelines, coordination issues, and
budgetary items. ldaho Power anticipates following up on any notable items set forth in
those reports. Idaho Power further intends to request additional documents from
PacifiCorp in the event the report does not provide a comprehensive review of the
activities at Jim Bridger plant.
Finally, as PacifiCorp requests funding for SCR-related project costs, Idaho
Power will review such invoices and follow-up on any notable costs that appear to be
inconsistent with the work that has been identified.
As PacifiCorp owns two-thirds of Jim Bridger plant, their interests align with ldaho
Power to complete the SCR project in the most cost effective way. Idaho Power will
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.6
continue to monitor the SCR project and continue to have discussions with PacifiCorp
on the SCR projects' progress and costs.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
DATED at Boise, ldaho, this 4th day of October 2019.
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of October 2013 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION
REQUEST NOS. 62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO
POWER COMPANY upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Industrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, ldaho 83701
Hand Delivered
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Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
q req @ richa rd sonad ams. co m
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_Hand Delivered
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FAXX Email [e-mail]
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FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
U.S. Mai!
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO PRODUCTION REQUEST NOS.
62, 63, 65, AND 69 OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I3-16
IDAHO POWER COMPANY
RESPONSE TO STAFF'S
REQUEST FOR PRODUCTION NO. 62
Department of Environmental Quality
To protect, conserue and enhance the gualily of Wyoning,s
environment for lhe benefrt of curent and future generations.
Manhew H. Mead. Governor Todd Parfitt, Dlrector
June 17,2013
Mr. Willianr I(. Lawson
Director, Envilonrnenta[ Selvices
PacitiColp Energy
1407 W. North Ternple, Suite 330
Salt Lake city, uT 84116
Re:Air Quality Pernrit MD-13260
Dear Mr. Lawson:
Enclosed is thc air quality permit to modiff operations at the Jim Blidger Plant with the installation of
selective catalytic rccluction (SCR) on Units 3 and 4. The Jirn Bridger Plant is located in Section 3,
T7-0N, Rl0lW, approxitnately four (4) miles north of Point of Rocks, in Sweetwater Counly, Wyoming,
Cornrnents received June 10, 2013 were considered in the fiual permit aud are addressed below:
Colnment:PacifiCorp Energy comnrented that Jim Bridgcr Unit 4 does utilize a mininral amount of
scrubber bypass itr order to provide clarification of the perrnit application and
accon:panylng BACT analysis,
The Division acknowledges PacifiCorp Enelgy's comments regarding clarification that a
ruinirnal arnont-rt of scrubber bypass is utilized on Unit 4. It should be noted that the
clarifisation provided by PacifiCorp Energy does not chauge'the l)ivision's BACT
analyses for sulfuric acid mist (H2SO4) and PIWPMIe/PM2.5, or arry of the conditions in
the final pennit.
PacifiCorp Errergy cotnmetrted that the draJt permit indicates tlrat compliance wittr the
30-day rolling average lb/lVIMBtu emission limits will be dernonstuated by sunrming and
then avcragirtg the individual valid hourly lb/MMBtu rates during the 30-day averaging
period. PacifiCorp Energy believes that the use of this method is inappropliate and
provicles non-r'epresentative lb/MMBtr.r emission rates, especially during periods of boiler'
staltup, shutdown, ol low-load opet'ations, PacifiCorp Energy proposes that cornpliance
lvith the lb/TvtMBtu limits be calculated by sumrning the hourly emissions reported during
the 30-boiler operating day period divided by the summatiou of ttre hoully heat input for
the same peLiod.
'l'he Division's proposed methodology for determining compliance with tlre lb/MMBtu
emission limit is identical to the methodology in air quality permit MD-I2186, which
revised the PAL language, eurissions limits, and excess emissions qalculations that were
in air quality pernrit MD-15524 fcrr the Jim Blidger Plant. The Division utilized this
methodology in order to be cousistent with the previous permi[ and in order to be
consistent with how cornpliance with the lb/MMBtu emission limit is determined across
pollutants (CO lor exanrple). Additionally, the Division does not consider PacifiCorp
EnergS/'s pt'oposed methodology to appropriately capture the intent o1' detelmining
Response:
Cornment:
Rcsponsc:
Herschler Buildlng
ADU{lNlOl, rREAC}t AIIANDOt\l[D tvl|NESt\"1a1) ll t / i5$ l)()t) 111 6115
Street Cheyenne, WY 82002
INI)USTIIIAI Ji 1II.IC LIINLI Q('\LII Y(.1{)i)/71./..j1,9 {.l4ttl,!t lttr\
. http://deg.state.wy,us
SOI.It] & IIAI, WASTE WATEII OUAI ITY
122 West 25th
All{ C)lrALrl Yt.t'l\ il ! l1\'l
r Ax 11 I .16Ir,'| ^x
'ti t .61t\2 tSlll)1il1t^1 ffi
PnciflCorp Dnergy
Air Qunlity Pcrmit MD-I3260
Response to Commentr
Pagc 2
compliance with an efficiency standard (lb/MMBtu), Thcrefore, the Division did not
revise proposed Condition 10 in the final permit
If we nray be of further assistance to you, please feel free to contact this office.
Sincerely,
st-^aCiA
Steven A. Dietlich
Administrator
Air Quality Division
cc: Tony Floyt
Department of Environmental Quality
fo protect, conserue and enhance the quality of Wyoming's
environment for the benefit of cunent and future generations.
Matlhew H. Mead, Govornor Todd Parfitt, Dlrector
Junc 17,2013
Mr. William K, Lawson
Director, Enviroumental Services
PacifiCorp Errergy
1407 W. Nolth Temple, Suite 330
Salt Lakc Ciry, UT 84116
Pennit No, MD-13260
Dear Mr', Lawson:
The Division of Air Quality of the Wyoming Departrnent of Environmental Quality has complcted final
review of PacifiCorp Energy's application to rnodiff operations at the Jim Bridger Plant with the
installation of selective catalytic reduction (SCR) on Units 3 and 4, The Jim Bridger Plant is located in
Section 3, T20N, Rl01W, approximately four (4) miles north of Point of Roc[<s, in Sweetwater County,
Wyoming.
Following this agency's proposed apploval of the request as published May 10, 2013 and in accordance
rvith Chapter 6, Section 2(m) of the Wyorning Air Quality Standards and Regulations, the public was
afforded a 30-day period in which to subrnit comrrl€nts concerning the proposed modification, and an
oppoLtunity for a public hearing. Comrnents were received and considered in tl'rc final permit. Therefore,
on the basis of the information provided to us, approval to nrodif, the Jirn Bridger Plant as described in
the application is hereby glanted pursuant to Chapter 6, Section 2 arnd 4 of thc regulations with the
Following conditions;
1, That authorized replesentatives of the Divisiou of Ail Quality be given permission to enter and
inspect any property, premise or place on ol at which an ail pollution source is located ol is being
constructed or installed for the purposo of investigating actual or potential sources of air pollution
and fcrr detelmining cornpliance or non-compliance with any rules, standarris, permits or orders.
2, That all substzurtive cornmifinents and descriptions set forth in thc application for this pernrit,
runless supclseded by aspecific condition of tlris penrrit, arc incorporatcd herein by this reference
and are enforceable as conditions of this pcrmit,
3. That all uotifications, reports and colrespondences associated with this permit shall be submitted
to the Stationary Source Compliance Prograrn Manager, Air Quality Division, 122 West 25'r'
Strect, Cheyenne, WY 82002 and a copy shall be submitted to the District Engineet', Air Quality
Division,5l0 Meadowview Drive, Lander, WY 82520.
4. That PacifiCorp Energy shall tile a complete application to rnodily lheir Operating Permit within
twelve (12) nronths of comnenciug opelatiou, in accordance with Chapter 6, Secl.ion 3(c)(i)(B) of
the WAQSR,
5, That w'itten notification of the anticipated date of initial staftup of Unit 3 and Unit 4 after
installation of selective catalytic recluction, it accordance with Chaptcr 6, Section 2(i) of the
U/AQSR, is requiled not more than sixty (60) days or less than thirty (30) days ptior to such date.
Notification of the actual date of staftup is lequired within fifteen (15) days after stzutnp.
Herschler Buildlng 122 West 25th Strset Choyenno, WY 82002 http://deq.state.wy.us
ADMIN/OIJTRIAC 1 AB;rNDONilli/rlrrL5 A'ROUAI.llY INDU:-,!lllnl jillN(; LAN0ijllAt ,Iy 5(,)Lt0&l-r\1 wA5lf wAlf:RQUA[] iyllotr/li )i\(1 (:]C7) 7//61.1i) il1lltl/t$1 (.\Ot.\t,1.l3br) t:lTtiit n5g tTttt/il1i:;' t:1.('))))li.t glFAX11].lltgi! iAX l/7-6ltj2 FAX 177.1;616 l'l\X lii lill/l FAX111.5^G^ I.,il( il;.(.1r1 F/rY ir?.AQr1
',{s
PacifiCorp INncrgy
Ait' Qunllty Permit MD-13260
Pagc 2
6,
1
That the date of commenc€nlent of construction of the selective catalytic reductioll system on
Units 3 and 4 shall be lepoded to the Adrninistrator within thifty (30) days of commencement, [n
accordance with Chapter 6, Section 2(h) of the WAQSR, approval to construct or modify shall
become invalid if construction is not commenoed witlrin twenty-four (24) months after reoeipt of
such approval or if construction is discontinued for a period of tweuty-four (24) months or more.
Thc Administrator may extend the period based on satisfactory justification of the lequested
extension,
That pertbrrnance tests be conducted, in accordance with Chapter 6, Section 2O of the WAQSR,
within thilty (30) days of achieving a rnaximum design rate but not later than ninety (90) days
l'pllowing initial startup, and a written report of the results be submitted, The operator shall
provide fifteen (15) days pdor notice of tlre test date. If a maximum design rate is not achieved
within ninety (90) days of startup, the Administrator may require testing be doue at the rate
achieved and again wheu a maxirnum rate is achieved,
Initial performance testing, as.required by Condition 7 of this permit, shall be conducted on Jim
BridgerUnits 3 and 4 upon cornpletion of the modification as follows:
NO.Eujssjons:Cornpliance with the NO* 30-day rolling avorage shall be determined
usiug a continuous emission monitodng systcm (CEMS) certified in
accordance with 40 CFR part 60 unless othelwise specified in an
applicable subpart or by the Administrator.
Ammonia Emissions: Compliance with the 30-day rolling average shall be determined using
the contintrous etnissions uronitoring systenl (CEMS) required in
Condition 12.
P M/PMrq E n i s s io r s ;
ffi :[r ii #l?;:i:'#: HJ"#Jffi T.tTllT ; ii:: li{,l [fi ::]1 ;T'l
reference lnefllods upon Division approval,
A test protocol shall be submitted for revierv and approval pricrr to testing, Notification of the test
date shall be provided to the Division fifteen (15) days prior to testing. Restrlts shall be submitted
to this Division within forty-fivc (45) days of completion.
Effective on aud after the date on which the perfonnance test is conducted for the rrcspective
emission unit, as required by Condition 7 of this pelmit, NO* and ammonia erlissions from Jirn
BLidger Unit 3 and 4 equipped with selective catalytic reduotion shall be lirnited to the emission
t'ates in the table below. These limits apply during all operating petiods.
Pollutalt lb/IvIMIJtu lb/hr tDy
NO*0.071b/MMBtu
(30-dav rolline averase)
420.0
(3O-dav rolline nverase)1 840
Amnronia 30.4 '
(3 0-dav rolling avct'age)133.2
8.
o
Bascd on l0 pprn,6 tt3VoOx
l'aclliCorp Ilncrgy
Air Qunltty Pcrmit MD-13260
Pagc 3
10. Compliance witlr the NO* limits set forth in this permit for Jim Bridgcr Units 3 and 4 shall be
determined with data from the continuous monitoring systems as follows:
A) Exceedances of the NO, limits shatl be definecl as follows:
i) Any 30-day lolling average which exceeds the lb/MMBtu NO* limits as
caloulated using the following formula:
I(oiD _h=lunuE - ,
Where:
EnvB= 30-day rolling avernge ernission rete (lb/MMBtu).
C = l-hour averago emission rate (lb/MMBm) for hour 'th"
calculated using valid data from the CEM equipment certified
and operated in accordance with 40 CFR part 75 and the
procedures in 40 CFR part 60, appendix A, Method 19, Valid
data shall meet the requiremonts of WAQS& Chapter 5, Seotion2(i). Valid data shall not include data substituted using the
missing data procedure in subpart D of 40 CFR part 75, nor shall
the data have been bias adjusted according to the proceclules of
40 CFR part 75,
The number of unit operating hours in the last 30 successive
boiler operating days with valid emissions data meeting the
requirements of WAQSR, Chapter 5, Sectiou 2O. A "boiler
operating day" shall be defined as any 24-hour peliod between
12:00 midnight and the following rnidnight during which any
fuel is combusted at any tinre at the steam generating unit.
Any 30-day rolliug average which exceeds the lb/hl N0* limits as calculated
using the following formula:
En"r =
Where:
llaus= 3O-day rclling avcrage emission Late (lb/hr'),
ii)
ZG),
h=t
PncifiCorp Enclgy
Air Quality Pcrrnit MD-13260
Pnge 4
C- l-houl avelage emissiorl rate (lb/hr) for hour "&" calculated
using valid data (output collcentlation and average hourly
volunretlic flowrate) frorn the CEM equiprnent certified and
operated in accordance with 40 CFR part 75. Valid data shall
meet the requircments of WAQSR, Chapter' 5, Section 2O.
Valid data shall not includc data sub.stihrted using the missing
data procedure in subpart D of 40 CFR part 75, nor shall the data
have been bias adjusted accolding to the procedures of 40 CFR
part 75,
I'he number of unit operating hours in the last 30 successive
boiler operating days with valid emissions data meeting the
requirernents of WAQSI! Chapter 5, Section 2O. A "boiler
operding day" shall be defined as any 24-hour period between
12:00 rnidnight and the following rnidnight during whiclr any
fuel is combusted at any time at the steam generating uuit.
B) PacifiCorp Energy shall comply with alt repofting and record keeping requirements as
specifiecl in WAQSR Chapter 5, Sectiou 2(g) and 40 CFR part 60, subpart D. All excess
ernissious shall be reported using the procedures and reporting fonnat specified iu
WAQSR Clrapter 5, Section 2(g).
11, PacifiCorp Energy shall use EPA's Clean Air Markets rcpofting program to convelt the
monitoring system data to annual cmissions, PacifiCorp F.nergy shall pLovide substituted data
according to the missing data procednres of 40 CFR paLt 75 during arry period of time that there is
trot tnonitorirrg data. All monitoring data must meet the tequirements of WAQSR, Chapter 5,
Section 2O.
12, Upon con'rplction of the modifrcation for each respective unit, Jim Bridger Units 3 and 4 shall be
equipped with contirruous ermissiorr monitoring (CF,M) equipment to demonstrate continuous
compliance with the amrnonia omission Iimit set forth in this pelrnit:
i, A CEM for arnrnonia shall be installed and certified within ninety (90) days of startup of
the selective catalytic reduction system,
ii, PacifiCorp Enelgy shall irrstall, calibrate, operate, and rnaintain a rnonitoling systern, and
record lhe output, for measuring amrnonia enrissions dischalged to the atrnosphere in
tunits ol'lb/ht, The ammonia monitoring systeln shall consist of the following:
l, Two (2) continuous emission NO* monitors: one to measule conl combustion
NO* emissions and one to measute total NO* emissions,
An anrmonia converter.
A continuous flow monitoling systenr for
dischalgecl into the atmosphere,
)
3,measuring the flow of exhaLlst gases
PncifiCorp Energy
Air Qunlity Pcrmit MD-I3260
Puge 5
4. An oxygen or carbon dioxicle lnonitor fot' measuring oxygen or carbon dioxide
contel'rt of tlle flue gas at the location NO* emissions are monitorod.
iii. Continuous rnonitor systelns listed in this corrdition shall comply with the following;
L Monitorirrg lequirenrents of WAQSR, Chapter'5, Section 2(j) including:
a. 40 CFR part 60, appendix B, Perforrnance Specilicatiou 2 for nitrogen
oxides, The NO* monitoring systems rnust demonstlate liuearity using
40 CFR part 60, Each monitor shall be certified in both concentration
(pprnJ and mess emissions, in units of lb/hr.
b. Quality Asstrlance reqnirements of 40 CFR part 60, appendix F unless
otherwise specified in an applicable subpart or by the Administrator,
c. PacifiCorp Energy shall develop and submit for the Division's approval a
Quality Assurance plan for the monitoling systenrs listed in this
condition within ninety (90) days of monitor certification.
2. The diffelential NO* concentration, as monitol'ed by two (2) certified NO^
monitors, shalI demonstrate lineality in accordance with Divisiou rcquirernents
and be certified to mouitor anrmonia soncentration (pprn,) and ammonia mass
emissions, in units of lb/hr,
13. Compliance with the ammonia lirnit sct forth in this permit shall be determined with data from
celtified NO* coutinuous monitoring systerns as follows:
i, Exceedance of the tirnit shall be definod as fo[[ows:
L Any 30-dtry rolling average which exceeds the lb/hr amrnouia lirnit as calculated
using the following folmula:
F)n" =
Where:
f{e,,
Eo,s: 30-day rolling average ernission rate (lb/hL).
C: l-hour average arnnronia emission rate (lb/hr) for hottr "fr" calculated
using valid data (output concentration arld average hourly volumetric
l'lowrate) from the CEM equipmeflt required by Condition 12. Valid data
shall meet the requirements of WAQSR, Chapter 5, Section 2O, Valid
data shall not include data substitnted uslng the misshrg data procedure
in subpart D of 40 CFR part 75, nor shall the data have been bias
adjLrsted according to the procedules of 40 CFR pat't 75,
PacitiColp Encrgy
Alr Qunlity Pcrmit MD-13260
Pngc 6
The number of unit operating hours in the last thirly (30) successive
boiler operating days with valid emissions data meeting the requirements
of WAQSR, Chapter 5, Section 2(i), A "boiler operating day" shall be
defined as any 24-hour period between 12:00 midnight and the following
midnight during which any fuel is oombusted at any time in the steam
generating unit,
ii. PacifiCorp Energry will comply with all leporting and record keeping requirements as
specified iu WAQSR, Chapter'5, Section 2(g),
14, Compliance with the conditions of this pennit supersedes tlre requiremeuts to cornply with
Chapter 3, Section 3(a)(vi) for Units 3 and 4 at the Jim Bridger Plant,
15. That the NO" emission limits in Condition 6 of MD-12186 for llnits 3 and 4 shall be superseded
upon tlre date on wlrich the initial pelformance test, required under Condition 7 or this permit, is
conducted for the respective emission unit.
16, Pac.ifiCorp Energy shall keep and maintain recolds as required by this perrnit for a period of five
(5) years from the date such records are generated and the records shall be rnade available to the
Division upon rrquest,
Revised NO. PAL Limit
ll. NO* emissions flom the Jirn Blidgel Plant shall be subject to a plantwide applicability [imit
(PAL), Compliance with the NO* PAL shall be detennined using a l2-month rolling tolal. Both
point sotrrces and fugitive sources shall be evaluatec{, This condition supersedes the NO, PAL
lirnit in Condition l0 of MD-12186, twelve (12) months after completiorr of the initial
pet'forrnancctestonUnit3. TheNO,PALshall expireApril 9,20lT,exceptesallowedunder
Chapter' 6, Section a(bXxvXI) and 4(b)(xv)(J),
i. Effectivc upou installation of SCR on Unit 3:
t" NO, PAL; 19,806 tons per yeer
a, Limit is based on a l2-month rolling total of all ernissions units.
b. Initial conrpliance shall be determined l2 monttrs fronr tlre initial
performance test lequired under this per:rnit for Unit 3.
ii. Effective upon installation of SCR on Unit 4:
1, NO* PAL: 75,379 tons pel'year
a. Lirnit is based on a 12-month rolling total of all ernissions units.
b, Initial compliance shall be detennined i2 uronths flom lhe initial
pelformance test required under this permit tbr Unit 4.
18. PacifiCorp Energy shall cornply with the molritoriug, rooordkeeping, and permitting requilements
fol the NOx PAL under MD-i2186 in order to demonstrate compliance with the NO* PAL lirnits
in this perrnit.
PnclfiCorp Energy
Air Quolity Permlt MD-13260
Pnge ?
It must be noied that this approval does not relieve you of your obligation to comply with all applicable
counfy, state, and federal standards, regulations or oldinances. Special attcntion must be given to Clrapter
6, Section 2 of the Wyoming Air Quality Standards and Regulations, which details the requircments for
compliance witlr Conditions 5, 6 and 7, Attention must be given to Chapter 6, Section 3 of the Wyoming
Air Quality Standards and Regulations, which details the requirernents for compliance with Conclition 3
(nrajor sources). Any appeal of this permit as a frnal action of the Departmeut must be made to the
Environmental Qualiry Council within sixty (60) days of permit issuance per Section 16, Chapter I,
General Rules of Practioe and Prooedure, Dcpartment of Environmental Quality.
If we may be of further assistzurce to you, please feel free to contact this office,
Sincerely,
S/,*aD,ilL
Steverr A. Dietrich
Admirristrator'
Air Quality Division
Tony Floyt
Todd Parfitt
Director'
Dept. of Environmental Quality