CP-200901052, Permit Renewal Application for Comanche Peak Steam Electric Station Auxiliary Boiler

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Permit Renewal Application for Comanche Peak Steam Electric Station Auxiliary Boiler
ML092180107
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/19/2004
From: Hansen C
TXU Energy
To: Turner B
Office of New Reactors, TXU Energy
References
+reviewedsrm2, CP-200901052, TXNB-09027
Download: ML092180107 (22)
v • d • e


Text

Office TXU Memorandum TXU Energy Environmental Services Date: February 19, 2004 To: Bruce Turner From: Chris Hansen cc: Teresa Harrison Randy Morrison Paul Coon Larry Sexson David Lamb Dick Robertson

Subject:

Permit Renewal Application for Comanche Peak Steam ;Electric Station Auxiliary Boiler

Dear Bruce:

Attached please fmd a draft permit renewal application for the renewal of Texas Commission on Environmental Quality (TCEQ) Air Permit No. 19225 for the auxiliary boiler at the Comanche Peak Steam Electric Station. TCEQ Air Permit No. 19225 will expire on April 28, 2004.

The permit renewal application was originally due on January 28,2004. As you remember, TXU requested an extension to this due date and was granted an extension until March 15,2004.

The only thing that we are proposing to add to Permit No. 19225 is lead emissions from the auxiliary b.oiler. TCEQ guidance usually requires that all criteria pollutants be added to a permit if they were not originally included. Lead is considered to be a criteria pollutant and was not included in the original construction permit application for the auxiliary boiler. We could leave the lead emissions out of the application and let the TCEQ request them if you would prefer.

The following are the main assumptions that were the basis for the preparation of the enclosed application for the auxiliary boiler:

Firing rate = 92.08 MMBtuIhr (assumes an 87.7 MMBtulhr design he"at input with an additional 5% capacity above the design heat input)

Annual operating hours =500 hrs/year

Emission factors:

co = 0.161blMMBtu (vendor supplied)

NOx = 0.16lblMMBtu (vendor supplied)

PM = 0.09 lblMMBtu (vendor supplied)

VOC = 0.005 IblMMBtu (vendor supplied) 0. S %

Pb = 9 IbllOI\ 12 Btu (AP-42) /

As before, sulfur dioxide (S02) emissions were calculated assuming atf% by weight sulfur content of the fuel oil, a heat content of the fuel oil of 18,000 Btullb, and the assumption that 100% of the sulfur is converted into S02.

The Maximum Allowable Emission Rate (MAER) table for Permit No. 19225 also lists six emergency generators and two diesel frre pumps. These sources are currently authorized under old Standard Exemption 5 and are included in the permit in order to establish federally enforceable limitations on hours of operation and restrict site-wide emission rates to below Title V, and Prevention of Significant Deterioration major source levels. No calculations for these sour~es are included as part of this permit renewal application.

The plot plan and area map have not been included in the attached draft application. If 'you .need to see them before the final is sent out I can get copies to you for your review.

Please review the attached application and contact me at 214-812-5401 with any questions or comments that you might have by March 1,2004 if possible.

  • February _ , 2004 Ms. Margaret Hoffman Executive Director Texas Commission on Environmental Quality Attention:

Permits Administrative Review (PAR) Section TCEQ MC 161 P.O. Box 13087 Austin, Texas 78711-3087

Subject:

TXU Generation Company LP Comanche Peak Steam Electric Station Permit Renewal Application for Auxiliary Boiler TCEQ Air Permit Number 19225 TCEQ Account No. SL-0009-E CN6001355111RNI03044053

Dear SirlMadam:

On behalf of TXU Generation Company LP, enclosed please fmd a permit renewal application for Texas Conunission on Environmental Quality (TCEQ) Air Permit No. 19225.

The application is being submitted to authorize the continued operation of the Auxiliary Boiler at the Comanche Peak. Steam Electric Station near Glen Rose in SomervelI County, Texas.

In a letter from Mr. David Howell dated 1122/04, the deadline for submittal of this permit renewal application was extended until 3115/04.

The following information is included in this Permit Renewal Application.

  • Form PI-1R - Air Quality Permit Renewal Application
  • Process/Project Description
  • Process Flow Diagram
  • AreaMap
  • Plot Plan
  • Table l(a) - Emission Sources
  • Table 2 - Material Balance
  • Table 30-R - Estimated Emissions and Fee Certificationfor Permit Renewals
  • Emission Rate Calculations
  • Copy of current Maximum Allowable Emission Rate table for TCEQ Air Permit No.

19225 (dated October 28, 1996)

The permit renewal application fee of $1,240.50 for the application has been sent in a separate submittal to the TCEQ cashier.

If you have any questions regarding the information presented in the enclosed permit renewal application, please contact Paul Coon at (214) 812-8409.

Sincerely, Gerald R. Johnson Generation Environmental Manager cc: Mr. Tony Walker TCEQ Region 4, Dallas-Fort Worth

bee: Dick Robertson Paul Coon (~ Air Staff)

Randy Morrison Bruce Turner File: Comanche Peak Steam Electric Station Auxiliary Boiler 2004 Permit Renewal Application TCEQ Account No. SL-0009-E; Permit No. 19225

,r' ~exas Commission on Environmenta* "'llality Form PI-IR .'

II General Application for Air Permit Renewals Update: The TCEQ requires that a Core Data Form be submitted on all incoming. applications unless a Regulated Entity and Customer Reference Number has been issued by the TCEQ and no core data information has changed. For more information regarding the Core Data call 239*5115 or to the Web site at "

A. Company or Other Legal Name: TXU Generation Company LP Texas Secretary of State CharterlRegistration Number (if applicable):

B. Company Official Contact Name and

Title:

Gerald R. Johnson, Generation Environmental Manager Mailing Address: Energy Plaza, 1601 Bryan Street City: Dallas State: Texas Zip Code: 75201 Telephone: 214-812-8476 Fax: 214-812-4395 E*mail:

C. Technical Contact Name and

Title:

Paul H. Coon, Air Permitting Coordinator Company: TXU Energy Mailing Address: Energy Plaza, 1601 Bryan Street City: Dallas State: Texas Zip Code: 75201 Telephone: 214-812-8409 Fax: 214-812-4395 E-mail: p.coon@txu.com D. Facility Location Information:

Street Addfess: FM 56, 4.5 l11illPGiFrn1m If no street address, provide (in writing) clear driving directions to the site:

City: Glen Rose County: Somervell Zip Code: 76043 E. TCEQ Account Identification Number: SL-0009-E F. Is a TCEQ Core Data Form (TCEQ Form No. 10400) attached? DYES 181 NO G. TCEQ Customer Reference Number (leave blank ifunknown): CN600135511 H. TCEQ Regulated Entity Number (leave blank ijunknown): RN103044053 A. Is confidential information submitted with this application? DYES 181 NO If YES, is each "confidential" page marked "CONFIDENTIAL" in large red letters? DYES DNO B. Name of State Senator and district number for this facility site: Senator Kip Averitt, Senate District 22 Name of State Representative and district numher for this facility site: Representative Arlene Wohlgemuth, Bouse District 58 I-OI![,-'L:(:\(nll/ltfh" ,:~i':rlJ)::Jt.'~1;1J}1t-~::):IHJ~~"i~G,i~~I;,.;.:,'.'fr(f*rY1'1 . _. . .' , ~. :: :-:]

I .., . > - " *

  • _ * - _ _ , * * ,.1 A. Site Name: Comanche Peak Steam Electric Station B. Area NamefType of Facility: Auxiliary Boiler 181 PERMANENT o PORTABLE

. C. Principal Company Product or Business: Electric Power Generation Standard Industrial Classification Code: 4911 Page 1 of 5

  • n '~exas Commission on Environmenta1 ""'uality

, FormPI*lR General Application for Air Permit Renewals I,"" , ~)~i'~~~~~~Nt~~~i~~~;~~0}~;r~I'II<<~~~:c~~~~~- - --- .- . -~*,._~*~*-_~?*~1 I

A. Penrrrit~uDlber: 19225 Permit Expiration Date: 4128104 B. Permit Type (check all that apply):

~ State Permit o Electric Generati~g Facility Permit o Flexible Permit o Voluntary Emission Reduction Permit o Multiple Plant Permit o Grandfathered Facility Permit o Special Permit o Other:

C. Have permit revisions or alterations occurred since originally issued or last renewed? ~ YES 0 NO If "YES," list dates of approval: Permit Alteration* 10/28/96 D. Have permit amendments occurred since originally issued or last renewed? r81YES DNO If "YES," list dates of approval: 7/25/89 E. Are there any permit alterations or amendments pending before the TCEQ? o YES ~ NO If "YES," list actions and dates of submittals:

F. Are there other actions associated with facilities covered under this permit? DYES ~ NO If "YES," list actions and dates of submittals or approvals:

G. Are there any associated federal Prevention of Significant Deterioration (PSD). Nonattainment (NA) or major source hazardous pollutants Federal Clean Air Act § 112(g) permits? DYES ~NO If "YES," list all associated federal permit numbers and issue or modification dates:

H. Are there any Permits by Rule (PBR) or standard permits associated with this permit? DYES 181 NO If YES, list all associated registration numbers and issue dates:

I. Are there any grandfathered facilities to be incorporated into this permit? DYES 1&1 NO If "YES," attach information on any changes to emissions under this permit:

J.. Is this facility located at a site required to obtain a federal operating permit under 30 TAC Chapter 1227 If "NO," go to Section V. DYES 181 NO Is a site operating permit (SOP) or general operating permit (GOP) review pending for this source, area, or site? DYES 1&1 NO Is an SOP or GOP issued for this source, area, or site? DYES 181 NO List SOP or GOP number(s):

Fee Paid for this application: $ 1,240.50 Is a Table 30-R entitled, "Estimated Emissions and Fee Certification" attached? 1&1 YES ONO Is a copy of the required fee based on annual emission rates attached to the original submittal of this application? ~YES DNO Page 2 of 5

II

. "'I1!xas Commission on EnvironmentaT \lality FormPI-lR General Application for Air Permit Renewals A. Responsible Person:

Name and

Title:

Christopher B. Hansen, Environmental Specialist Staff Mailing Address: Energy Plaza, 1601 Bryan Street City: DaUas State: Texas Zip Code: 75201 Telephone: 214-812-5401 Fax: 214-812-4395 E-mail: chris.hansen@txu.com B. Technical

Contact:

Name and

Title:

Paul H. Coon, Air Permitting Coordinator Mailing Address: Energy Plaza, 1601 Bryan Street City: Dallas State: Texas Zip Code: 75201 Telephone: 214-812-8409 Fax: 214-812-4395 E-mail: p.coon@txu.com C. Application in Public Place:

Name of public place: Somervell County Courthouse Physical Address: 107 NE Vernon Street City: Glen Rose County: Somervell Has the public place granted authorization to place the ~pplication for public viewing and copying? . ~ YES 0 NO D. Small Business Classification:

Does this company (including parent companies and subsidiary companies) employ 100 DYES 181 NO or fewer persons?

Is the site a major source under 30 TAC Chapter 122, Federal Operating Permit Program? DYES DNO Are the site emissions of any individual air contaminant greater than 50 tpy? DYES DNO Are the site emissions of all air contaminants combined greater than 75 tpy? DYES DNO E. Bilingual notice confIrmation:

Is a bilingual program required by the Texas Education Code in the School District? DYES ~NO Are the children who attend either the elementary school or the middle school nearest to DYEfiNO the facility eligible to be enrolled in a bilingual program provided by the district?

If "YES," which language is required by the bilingual program?

A. Is a current area map attached? r2$lYES DNO Are any schools located within 3,000 feet of this facility? DYES 181 NO B. Is a plot plan of the facility property attached? 181 YES DNO C. Is a process flow diagram and a process description attached? 181 YES DNO D .. Maximum Operating Schedule: Hour~ay -1i.... DayslWeek _7_ WeeksfYear ~~_

DYES 181 NO If "YES," please describe:

Page 3 of 5

~exas Commission on Environmenta" lIality

, . Form.PI*lR .

II General Application for Air Permit Renewals E. Are maximum emissions data and calculations attached? r&1 YES 0 NO

1. Is a Table l(a) entitled, "Emission Point Summary Table," attached? r&1 YES ONO
2. Is a Table 2 entitled, Material Balance Table," attached? r&1 YES 0 NO
3. Are equipment, process, or control device tables attached? DYES r&1 NO
4. Are routi~e maintenance, start-up, or shutdown emissions included? DYES r&1 NO A. Is the facility being operated in accordance with all requirements, limits, and conditions r&1 YES 0 NO of the current permit, including representations in the initial application and any subsequent alterations, amendments, or other authorizations?

Describe potential or pending authorizations(s):

B. Is the facility able to measure emissions of significant air contaminants? DYES r&1 NO Are details attached? DYES r&1 NO C. Are all facility emission controls economically reasonable and technically practicable r&1 YES 0 NO considering the age of the facility?

D. Is the facility subject to any requirements of 30 TAC Chapter lIS? ,DYES r&1 NO If YES, attach documentation and list the rules.

E. Is the facility subject to any requirements in 30 TAC Chapter 117? DYES r&1 NO If YES, attach required compliance documentation and list the rules.

F. Is this facility located at a site within the Houston/Galveston nonattainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties)? 0 YES 181 NO Does the facility at this site have an uncontrolled design capacity to emit 10 tpy or more of NO x? 0 YES r&1 NO Is this site subject to 30 TAC Chapter 101, Subchapter H, Division 3 (Mass Emissions Cap and Trade)? 0 YES 181 NO Does this action make the site subject to 30 TAC § 101[H][3]? 0 YES r&1 NO Does this action require the site to obtain additional emission allowances? 0 YES r&1 NO A. Does a Title 40 Code of Federal Regulations Part 60, (40 CFR Part 60) New Source Performance Standard (NSPS) apply to the facility in this application? DYES r&1 NO B. Does 40 CPR Part 61, National Emissions Standard for Hazardous Air Pollutants (NESHAP) apply to the facility in this application? DYES 181 NO C. Does a 40 CPR Part 63, Maximum Achievable Control Technology (MACT) standard apply to the in this  ? DYES 181 NO Page 4 of 5

  • r, ~.exas Commission on Environmental ~ality FormPI*1R Genera) Application for Air Permit Renewals A. Has the required fee been sent separately with a copy of this Form PI-1R to the TCEQ Revenue Section? (MC 214, P.O. Box 13088, Austin, Texas 78711-3088). 181 YES 0 NO B. Is the Core Data Form, Form PI-IR, and all attachments being sent to the TCEQ in Austin? DYES 181 NO OPTIONAL: Has an extra copy of the Core Data Form, Form PI-IR and all attachments been sent to the TCEQ in Austin? DYES 181 NO If "YES," please mark this application as "COPY."

C. Is a copy of the Core Data Form, the Form PI-1R, and all attachments being sent to the appropriate TCEQ regional office? (Excluding Core Data Form) 181 YES DNO D. Is a copy of the Core Data Form, the Form PI-IR, and all attachments being sent to each appropriate local air pollution control program(s)? N/A DYES DNO List all local air pollution control program(s):

'The signature below confirms that I have knowledge of the facts included in this application and that these facts are true and correct to the best ofm)

'knowledge and belief. Ifurther state that to the best of my knowledge and belief, the projectforwhich application is made will not in any way ViolatE any provision of the Texas Water Code (1WC), Chapter 7, Texas Clean Air Act (TCAA), as amended, or any of the air quality rules a1!d regulation.!

of the Texas Commission on Environmental Quality or any local governmental ordinance or resolution enacted pursuant to the TCAA. I further statf tthat I understand my signature indicates that this application meets all applicable nonattainment, prevention of significant deterioration, or majOl

~ource of hazardous air pollutant pennitting requirements. I further state that I have read and understand TWC § § 7.177-7.183,* which defineJ CRIMINAL OFFENSES for certain violations, including intentionally or lawwingly making or causing to be made false materiaL statements 01 representations in this application, and 1WC § 7.187, pertaining to CRIMINAL PENALTIES.

NAME: Gera1d R * .Johnson SIGNATURE:_ _ _ _ _ _ _ _ _ _ __ DATE: _ _ _ __

Ori£inal Si~nature R~uired Page 5 of 5

PROCESSIPROJECT DESCRIPTION TXU operates an auxiliary boiler at the Comanche Peak Steam Electric Station (SES) near Glen Rose, Somervell County, Texas. The auxiliary boiler is used to supply steam on a backup basis for startup of either the main or auxiliary steam turbines. Operation of the auxiliary boiler is currently authorized under Texas Commission on Environmental Quality (TCEQ) Air Permit No. 19225.

The auxiliary boiler has an approximate fIring rate of 93 MMBtulhr and is fIred on No.2 diesel fuel. The auxiliary boiler is .currently authorized to emit carbon monoxide (CO),

oxides of nitrogen (NOx) , particulate matter (PM), sulfur dioxide (S02), and volatile organic compounds (VOCs). Lead is the only criteria pollutant not currently listed in the Maximum Allowable Emission Rate (MAER) Table for Permit No. 19225, and is therefore being added as part of this permit renewal application.

The auxiliary boiler is equipped with 10w-NOx burners that limit NOx emissions to 0.16 IblMMBtu. The 10w-NOx burners along with the firing of high quality No. 2 diesel fuel and proper combustion techniques will continue to be employed as Best Available Control Technology (BACT).

It should be noted that the MAER table for Permit No. 19225 also lists six (6) emergency generators and two (2) diesel fIre pumps. These eight sources are currently authorized under old Standard Exemption 5 and are listed in the MAER table in order to establish federally enforceable limitations on hours of operation and to document that emission levels are below major source levels that trigger prevention of significant deterioration and Title V requirements.

COMJ.\ptCHE PEAK STEAM ELECTRIC S1 ATION PROCESS FLOW DIAGRAM EPN CP-AB1S I

CO, NOx' PM, S02,VQC, and Pb I

I I

Boiler Feed ...

Water Auxiliary CD Boiler ...... Steam to Plant (FIN CP-AB1)

No. 2 Diesel Fuel Boiler Slowdown CD Circled numbers correspond to numbers on Table 2 - Material Balance.

~--

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Table l(a) Emission Point Summary RN103044053 CP-AB1S Auxiliary Boiler VOC 0.5 <1.0 NOx 14.8 3.7 SOz 51.2 12.8 PM 8.3 2.1 CO 14.8 3.7 Pb 0.001 0.004 EPN = Emission Point Number FIN = Facility Identification Number TCEQ-I01S3 (Revised 06-30-O~)

Table l(a)-Emission Point Summary-These fonns are for use by sources subject to the New Source Review Program and may be revised [ANSRG95A:7026.v3] Page 2 of3

,-, TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

" Table 1(a) Emission Point Summary CP-AB1S Awdllary Boller 14 614,173 3,573,898 30 3.95 42 371 EPN = Emission Point Number FIN = Facility Identification Number TCEQ-I0153 (Revised 06-30-03)

Table 1(a)-Emission Point Summary-These fonns are for use by sources ~ubject to the New Source Review Program and may be revised [ANSRG95A:7026.v3] Page 3 0(3

TABLE 2 MATERIAL BALANCE This material balance table is used to quantify possible emissions of air contaminants and special emphasis should be placed on potential air contaminants, for example: If feed contains sulfur,show distribution to all products, Please relate each material (or group of materials) listed to its respective location in the process flow diagram by assigning point numbers (taken from the flow diagram) to each material.

LIST EVERY MATERIAL INVOLVED IN EACH OJ Point No. Process Rate (lbslhr orSCFM)

THEFOLLO~GGROUPS

. from Flow Diagram standard conditions: 70°F 14.7 PSIA. Check appropriate

+'

c::

Gl E c:: c::

column at right for each process. Gl 0 0

p

~ '+:i

J It! It!

UJ E  :;

It! 0 Q) '+:i UJ iO

~ W (,)

1, Raw Materials - Input Boiler Feed Water 1 75,000 lhlhr X

2. Fuels - Input No.2 Diesel Fuel 2 5,1161blhr X (710.5 gallhr)
3. Products & By-Products - Output Steam 3 75,0001hlhr X
4. Solid Wastes - Output
5. Liquid Wastes - Output Boiler Blowdown 4 750lhlhr X (90 gallhr) 6, Airborne Waste (Solid) - Output

~--....

PM 5 8.31blhr ~ X Ph 5 0.OO1lblhr I~

X

~

D

7. Airborne Wastes (Gaseous) - Output VOC 5 0.5 X X NO x SOz CO 5

5 5

14.8 51.2 14.8 1X X X

X lUJ')j

Texas Commission on Environmental Quality Table 30-R Estimated Emissions and Fee Certification for Permit Renewals Title 30 Texas Administrative Code § 116.313 Renewal Fees - Each permit renewal requires an application fee that is based upon the amount of annual allowable emissions represented in the application. The total emissions must include those represented in any permit by rule (PBR) Or standard permits rolled into the renewal. The following table may be used to calculate renewal fees.

1 To 'calculate the fee, multiply the number of tons in excess of the minimum limit of the appropriate category by the incremental fee, then add this amount to the base fee. For example, if total emissions of all air contaminants are 50 tons per year, the total fee would be $1,993 (base fee of $1,265, plus incremental fee of $28 x 26 tons or $728).

RENEWAL FEE TABLE tpy is equal to.or less than 5 tpy N/A $600 tpy is greater than 5 tpy but less than or equal to 24 tpy $35/ton 23.3 $600 1,240.50 tpy is greater than 24 but less than or equal to 99 tpy $28/ton $1,2651 tpy is greater than 99 tpy but less than or equal to 651 tpy $ 12/ton $3,365 N/A

($ 35 x 18.3 + $._~6=0=0__ =' $._ _-=1;Z,:,24:..:.0=.s~0~_

(Incremental Fee) (Number of tpy over the (Base Fee) (Total Fee) minimum limit)

The signature below confirms that I have knowledge of the facts included in this application and that these facts' are true and correct to the best of my knowledge and belief. I further state that to the best of my knowledge and belieJ, the project for which this application is made will not in any way violate any provision of the Texas Water Code (TWC), Chapter 7, Texas Clean Air Act (TCAA), as amended, or any of the air quality rules and regulations of the Texas Commission on Environmental Quality or any local governmental ordinance or resolution enacted pursuant to the TCAA. I further state that I understand my signature indicates that this application meets all applicable nonattainment, prevention of significant deterioration, or major source of hazardous air pollutant perrriitting requirements.

I further state that I have read and understand TWC §§ 7.177-7.183, which defines CRIMINAL OFFENSES for certain violations, including intentionally or knowingly making or causing to be made false material statements or representations in this application, and TWC § 7.187, pertaining to CRIMINAL PENALTIES Signature:_ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Title:

Generation Environmental Manager Company: TXU Generation Company LP Date: _ _ _ _ _ _ _ _ _ _ _ __

Permit renewal application fee (from table above) = $ 1.240.50 TCEQ - 20065 [Revised [08-15-03]

This form for use by facilities subject to air quality permit requirements and may be revised periodically. (NSRG:7623 v2) Page 1 of 1

TXU GENERATION COMPANY LP

SUMMARY

OF HOURLY AND ANNUAL CO, NOx, PM, S02, VOC AND Pb EMISSION RATES FOR THE AUXILIARY BOILER AT THE COMANCHE PEAK STEAM ELECTRIC STATION

~ NOy f.M. ~ VOC Pb Hourly Annual Hourly Annual Hourly Annual Hourly Annual Hourly Annual Hourly Annual Unit EPN FIN (Iblhr) (T/Yr) (Iblhr) (T/yr) (Iblhr) (T/yr) (lblhr) (T/Yr) (Iblhr) (T/Yr) (Iblhr) (T/yr)

Auxiliary Boller CP-AB1 S CP-AB 1 14.73 3.68 14.73 3.68 8.29 2.07 51.16 12.79 0.46 0.12 0.001 0.0002

.; ,f~

ComanchePeakrenewalCalculations.xls 2/11/2004Calculation Summary

TXU GENERATION COMPANY LP Calculation of CO, HOx, PM, S02, voe, and Pb Emission Retes for the Auxiliary Boller at the Comanche Peak Steam Electric Station (SES)

~ Calculate the maximum hourly and annual average CO, NOx, PM, S02. VOC, and Pb emission rates for the Auxilary Boller at the Comanche Peak SES.

Inputs/At*umotion,;

The firing rate (FA) of the auxiliary boiler: 92.08395 MMBtulhr The aooual ooerating hours tAOH) of the boiler: 500 hrslyear Emission rates lER):

CO 0.16 IblMMBtu (Vendor)

NOx 0.161b1MMBtu (Vendor)

PM 0.09 IblMMBtu (Vendor)

VOC 0.005 IblMMBtu (Vendor)

Lead (Pb) 9 Ibl1 0"12 Btu (AP-42, Section 1.3. Table 1.3-10, 9198)

SlAfU!" content (6) pf fuel oil 0.5 (% by weight)

Heal coote"' (H) of fuel oil 18,000 Btullb Calculation.;

1 Calculate the maximum hourly and annual CO emission rates for the Auxiliary Boller:

ECOH= FR MMBtufhr x ER Ib/MMBtu EQOH= 92.08395 MMBtulht x 0.16 IblMMBlu

'Eoott = 14.73 Ib CO/hr AD!nm!

~= EcoH Iblhr x AOH hrsIyear 2000 IblTon EcoA::: 14.73 Iblhr x 500 hrs/year 2000 IblTon Eco...= 3.68 Tons CO/yr

2. Calculate the maximum hoyrly and BMual NOv emission rates for the Alpdliary Boller:

EHQX/I= FR MMBtulhr x ER IblMMBtu Et4oX/l= 92.08395 MMBtulhr x 0.16 IblMMBtu Et.o)Clf= 14.73 Ib NOx/hr AIlmm!

E..oXA= ~ IbIhr x AOH hrsIyear 2000 IblTon Et4oXA= 14.73 Iblhr x 500 hrslyear 2000 IblTon EooXA= 3.68 Tons NOx/yr 3 CalClAate the maximum hourly and annual PM emission roles for lhe Auxiliary Boiler:

~= FR MMBtulhr x ER IblMMBtu

~= 92.08395 MMBtulhr x 0.09 IbIMMBtu

~= 8.29 Ib PMlhr

~

E,...,.::: ~ Jblhr x AOH hrslyear 2000 IblTon EPIM ::: 8.29 Iblhr x 500 hrsIyear 2000 IblTon E""",= . 2.07 Tons PMlyr

  • Annual emission rates are based upon 500 full load operating hours per year, or 46,042 MMBIu'yr. Actual operating hours may exceed 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />, provided total heat Input does not exceed 46,042 MMBtulhr during any 12-month period.

ComanchePeakrenewalCalruations.lCis 2/1912004 Boller CO, NOX, PM, S02, VOC Page 1 of2

TXUGENERAnONCOMPANYLP Calculation of CO, NOx. PM, SOa, voe, and Pb Emiaeion Rates for the Auxiliary Boiler at the Comanche Peak Steam Electric S1ation (SES)

Calculations (continued):

4 Calculate the maximum hourly and annual VOC emission rates for the Auxiliary Boller:

J:1mm CYOCH= FR MMBtulhr X cR IblMMBtu EVOCH= 92.08395 MMBtulhr X 0.005 IblMMBtu EyOCH= 0.46 Ib VOCfnr

&!m!Bl EYOCA= J:VOCH IbJhr X AOH hrs/year 2000 Ibffon EYOCA= 0.46 Iblhr X 500 hrsIyear 2000 Ibffon EYOCA= 0.12 Tons VOClyr

~. Q~I~m~ IIlf.! m~l!iml.!!ll bQw:!y aDS! !moual SQ2 gl!li!UIIQ[! !:Il!i!1i mr IIlli! 6ul!ili/'\rl( aml!i!r:

Hourly E802H= FR*1Q116 BtuIhr X S (%) H Btullb X 2 moles SO;Imoie S ES02H = 92,083,950 Btulhr X 0.005 (%) 18,000 Btullb X 2 moles SO;Imole S EB02H= 51.16 Ib SOihr

~

ES02A= E§02H Iblhr X AOH hrsIyear 2000 IblTon ES02A= 51.16 Iblhr X 500 hrsIyear 2000 I!:flOD' ES02A= 12.79 Tons SO.)yr

§ Qlll!a.!lm!i! b D:lIDim!.!lIl1:!21.!!:lY m;! annual ~b gmiyiQ[! 1ll1ili mr Il!~ aUl!!lilJrl( ~21li[:

t!2l.!!1v

~= FRI1Q116 1Q1\12Blulhr X ER Ibl1Q1\12Btu EPbH= 0.00009 1Q1\12Btulhr X 9 Ibl1Q1\12Btu

~= 0.001 Ib Pblhr

~

Ef'bII= ~ Iblhr X AOH hrslyear 2000 IblTon

~= 0.001 Iblhr X 500 hrsIyear 2000 IblTon CPbA= 0.0002 Tons PbIyr ComanchePeakrenewaiCaiculations.xls 2/1912004 Boller CO, NOX, PM, 802, VOC Page 2 of2

EMISSION SOURCES - MAXIMUM ALLOWABLE EMISSION RATES Permit No. 19225 This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant's property covered by this pennit. The emission rates shown are those derived from infonnation submitted as part of the application for permit and are the maximum rates allowed for these facilities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit.

AIR CONTAMINANTS DATA Emission Source . Air Contaminant Emission Rates

  • Point No. 0) Name (2) Name (3) Ib/hr TPY Case I: Auxiliary Boiler CP-AB1S Auxiliary Boiler voc 0.5 < 1.0 NOx 14.8 3.7 S02 51.2 12.8 PM 8.3 2.1 eo 14.8 3.7 Case II: Emergency Generators (4)(~) .

CP-EDGIS Emergency Generator No.1 voc 1.3 < 1.0 NOx 278.5 20.9 S02 36.2 2.8 PM 4.3 < 1.0 CO 23.6 1.8 CP-EDG2S Emergency Generator No. 2 voe 1.3 <1.0 NOx 278.5 20.9 S02 36.2 2.8*

PM 4.3 < 1.0 CO 23.6 1.8 CP-EDG3S Emergency Generator No. 3 voe 1.3 < 1.0 NOx 278.5 20.9 SOl 36.2 2.8 PM 4.3 < 1.0 CO 23.6 1.8 CP-EDG4S Emergency Generator No.4 VOC 1.3 < 1.0 NOx 278.5 20.9 S02 36.2 2.8 PM 4.3 < 1.0 CO 23.6 1.8

Pennit No. 19225 Page 2 EMISSION SOURCES - MAXIMUM ALLOWABLE EMISSION RATES AIR CONTAMINANTS DATA Emission Source Air Contaminant Emission Rates

  • Point No. (ll Name (2) Name (3) Ib/hr TPY Case In: Emergency Generators (4)

CP-EDGSS Emergency Generator No. 5 voe 0.1 < 1.0 NOx 9.1 1.2 S~ 2.7 < 1.0 PM 0.6 <1.0 CO 2.1 < 1.0 CP-EDG6S Emergency Generator No. 6 VOC 0.4 < 1.0 NQx S.2 < 1.0 SOl 0.8 < 1.0 PM 0.4 < 1.0 CO 1.2 < 1.0 Case IV: Emergency Fire Pumps (4)(6)

CP-DFP1S Diesel Fire Pump No. 1 voc 1.6 < 1.0 NOx 19.1 1.0 SOl 3.0 < 1.0 PM 1.4 < 1.0 CO 4.2 < 1.0 CP-DFP2S Diesel Fire Pump No. 2 voc 1.6 < 1.0 NOx 19.1 1.0 S01 3.0 < 1.0 PM 1.4 < 1.0 CO 4.2 < 1.0 (1) Emission point identification - either specific equipment designation or emission point number from plot plan.

(2) Specific point source name. For fugitive sources use area name or fugitive source name.

(3) VOC - volatile organic compounds as defuied in General Rule 101.1 NO x - total oxides of nitrogen S02 - sulfur dioxide PM - paniculate matter CO carbon monoxide

Pennit No. 19225 Page 3 EMISSION SOURCES - MAXIMUM ALLOW ABLE EMISSION RATES (4) 'These emergency generators are exempt under Texas Natural Resource Conservation Commission Standard Exemption S. Inclusion of these emissioJU sources is to establish federally enforceable limitations on hours of operation and to docwnent that emission levels are below significance levels for prevention of significant deterioration.

(5) The four Emergency Generators (EPNs CP-EDGlS, CP-EDG2S, CP-EDG3S, and- CP-EDG4S) will operate no more than a combined total of 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per year. Annual emissions shown for each of the subject emergency generators are based upon 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of oper~tion per year, but could vary according to load distribution.

- (6) The two Diesel Fire Pumps (EPNs CP-DFPlS and CP-DFP2S) will operate not more than a combined total of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per year. Annual emissions shown for each of the subject rue pumps are based on 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of operation per year, but could vary. -

III Emission rates are based on and the facilities are limited by the following maximum operating schedule:

Case I:

_Hrs/day _Days/week _Week!Jyear or 2Q!l. Hrs/year Case U:

_Hrs/day _Days/week _Weeks/year or ~ Hrs/year (cembined total for four units)

Case ill:

_Hrs/day _Days/week _ Weeks/year or ~ Hrs/year Case IV:

_Hrs/day _Days/week _Weeks/year or ..1QQ.. Hrs/year (combined total for two units)

Dated 10-28-96

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