Compliance at the Coolidge Generating Station

Presented: Kim Myers, Environmental Specialist

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Coolidge Generating Station (CGS)

• CGS is an electric generation facility located 3 miles

south of Coolidge, owned and operated by Coolidge

Power LLC.

• The facility is a natural gas-fired, simple cycle, with a

total of 575 MW of generation from 12 GE LM6000

combustion turbine generators (CTGs).

• Each unit has selective catalytic reduction and CO

catalyst system to reduce NOx and CO.

• Facility also has a diesel-fired emergency fire pump

engine.

• The original air permit was issued in March of 2010.

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CGS

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Permits

PCAQCD Air Permit

• Subject to Title V requirements due to potential for annual

emissions of NOx, CO, PM10/PM2.5 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.

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Permits

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)

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Aquifer Permit

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

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PCAQCD Air Permit

Monitoring Requirements• Continuous Emissions Monitors (CEMs) installed on each CTG stack

o Monitor NOx and CO emissions - daily

o Determine PM, VOC 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

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PCAQCD Air Permit

Recordkeeping Requirements

• Monthly emissions of NOx, CO, PM10, VOC 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

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PCAQCD Air Permit

Reporting Requirements

• 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

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PCAQCD Regulation 4-1-030

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.

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Map of Facility

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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.

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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.

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Determining Compliance with 4-1-030

Documentation the Dust Palliative is Functioning on High

Wind Days