Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 1 of 10

Tab J

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 2 of 10

Puerto Rico

FAX MESSAGE To: Ana Rosa Rivera PR EQB, Air Quality Area Fax: (787) 756-5906

From: William Vela Date: January 19, 2004 Subject:

Tel:

(787) 866-8117 ext.239

Total Pages: 4 (including cover)

AES Puerto Rico Cogeneration Plant (AESPR), Guayama, PR Construction Permit PFE-30-0896-0860-II-C Title V Operating Permit Application PFE-TV-4911-30-0703-1130 Notification of Reportable Emissions Deviations

AES Puerto Rico is required by the facility's permits and the PR Regulations to notify the EQB if any permit limit is exceeded due to malfunction or process upset. This faxed message serves as notification. Attached are copies of the CEMS Excess Emissions Reports for Unit 2 for the period between January 15 and January 19, 2004. This is a summary of the incidents that resulted in deviations above the permit limits: 1. Unit 2 SO2 on January 16, 2004 during the 1700 to 1900 hours. This incident occurred while conducting an operational test of the emissions control device, the Circulating Dry Scrubber. It was discovered that the cause of the process upset was a plugged hydrated lime feed piping and rotary valve. The corrective action taken was to clean the piping and restore the system to service. 2. Unit 2 S02 on January 17, 2004 during the 1200 and 1300 hours. This process upset was also caused by plugged hydrated lime feed piping and rotary valve. The corrective action taken was to clean the piping and restore the system to service. 3. Unit 2 NOx on January 18, 2004 between the 0400 and 0800 hours. This was due to a process upset in the emissions control device, the Selective NOx Catalytic Reduction (SNCR) system. It was discovered that the mix of urea solution was incorrect and this was manually adjusted to restore the emissions below the permit limits. 4. Unit 2 SOx on January 18, 2004 during the 1400 hour. This occurred during testing aimed at improving the operation of the Circulating Dry Scrubber. 5. Unit 2 opacity exceedences between 1630 and 1654. These occurred due to high levels in the ash collection hoppers of the Electrostatic Precipitator causing re-entrainment of particulates in the exhaust gas stream. Corrective action taken was to restore the levels to normal. If you have any questions I can be reached at (787) 866-8117 ext. 239. William G. Vela

AESPR-076478

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 3 of 10

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 4 of 10

Puerto Rico

FAX MESSAGE To: Ana Rosa Rivera PR EQB, Air Quality Area Fax: (787) 756-5906

From: William Vela Date: January 26, 2004 Subject:

Tel:

(787) 866-8117 ext.239

Total Pages: 9 (including cover)

AES Puerto Rico Cogeneration Plant (AESPR), Guayama, PR Construction Permit PFE-30-0896-0860-II-C Title V Operating Permit Application PFE-TV-4911-30-0703-1130 Notification of Reportable Emissions Deviations

AES Puerto Rico is required by the facility's permits and the PR Regulations to notify the EQB if any permit limit is exceeded due to malfunction or process upset. This faxed message serves as notification. Attached is a copy of the CEMS Excess Emissions Reports for the following incidents: · Unit 1 start-up exceedances during start-up beginning January 22 and ending January 24. The start-up was delayed on the evening of January 22 due to a leaking boiler safety valve that required the boiler be shutdown for repairs. After restarting on January 23rd, the start-up was again delayed due to a failure of a turbine control valve. Unit 1 load passed 50% on January 24 at 2:30 p.m. and emissions returned to normal. · Unit 2 NOx exceedance during the period of January 24, 2004 between 5:00 a.m and 4:00 p.m. This incident occurred due to a failure of the urea mixing system. The operators managed to mix a batch of urea and returned the emissions control device to normal operation. If you have any questions I can be reached at (787) 866-8117 ext. 239.

William G. Vela

AESPR-076479

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 5 of 10

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 6 of 10

Puerto Rico

FAX MESSAGE To: Ana Rosa Rivera PR EQB, Air Quality Area Fax: (787) 756-5906

From: William Vela Date: February 12, 2004 Subject:

Tel:

(787) 866-8117 ext.239

Total Pages: 3 (including cover)

AES Puerto Rico Cogeneration Plant (AESPR), Guayama, PR Construction Permit PFE-30-0896-0860-II-C Title V Operating Permit Application PFE-TV-4911-30-0703-1130 Notification of Reportable Emissions Deviations

AES Puerto Rico is required by the facility's permits and the PR Regulations to notify the EQB if any permit limit is exceeded due to malfunction or process upset. This faxed message serves as notification. Attached is a copy of the CEMS Excess Emissions Report and the Daily Emissions Report for Unit 2 for February 11, 2004. This incident occurred during the 3-hour average between 1500 and 1700 hours. This was due to a process upset of the boiler temperature, air, fuel and emissions controls while increasing load at the request of the electric utility. The emissions exceedence recorded by the CEMS at 1700 hours was an SO2 3-hour average of 55.6 Ib/hour. The permit limit for this parameter is 54.1 Ib/hour on a 3-hour rolling average. The SO 2 ppm and Ib/MMBtu permit limits were not exceeded. The corrective actions taken at the time were: stabilize temperature, air and fuel mixes and increased the injection rate of the SC^sorbents limestone and hydrated lime. If you have any questions I can be reached at (787) 866-8117 ext. 239.

William G. Vela

AESPR-076481

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 7 of 10

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

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FAX MESSAGE To: Ana Rosa Rivera PR EQB, Air Quality Area Fax: (787) 756-5906

From: Marco Aresti Lead Operator, Shift B Date: 07/04/2004 Subject:

Tel:

(787) 866-8117 ext.244

Total Pages: 3 (including cover)

AES Puerto Rico Cogeneration Plant (AESPR), Guayama, PR Construction Permit PFE-30-0896-0860-II-C Title V Operating Permit Application PFE-TV^911-30-0703-1130 Notification of Reportable Emissions Deviations

AES Puerto Rico is required by the facility's permits and the PR Regulations to notify the EQB if any permit limit is exceeded due to malfunction or process upset. This faxed message serves as notification. Attached is a copy of the CEMS Excess Emissions Report and the Daily Emissions Report for Unit #1 for 07/04/2004. This incident occurred during the 0137-0143. At the time the incident occurred the unit was in normal operation. It was discovered that the cause of the process upset was the loss of the Electrostatic Precipitators Transformer Rectifiers. The excess emissions recorded by the CEMS at 0137-0143 hours were Opacity exceedances of 0137-54.8%, 0143-36.8%. The permit limits for these parameters are 20% on a 6 minutes average. The corrective action taken was to restore to service the Electrostatic Precipitators Transformer Rectifiers.

If you have any questions please contact William G. Vela at (787) 866-8117 ext. 239.

Marco Aresti Lead Operator

AESPR-076473

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 9 of 10

Case 1:04-cv-01282-JJF

Document 59-11

Filed 12/06/2005

Page 10 of 10

FAX MESSAGE To: Ana Rosa Rivera PR EQB, Air Quality Area Fax: (787) 756-5906

From: Fernando Rodriguez Lead Operator Date: July 06, 2004 Subject:

Tel:

(787) 866-8117 ext.244

Total Pages: 3

AES Puerto Rico Cogeneration Plant (AESPR), Guayama, PR Construction Permit PFE-30-0896-0860-II-C Title V Operating Permit Application PFE-TV-4911-30-0703-1130 Notification of Reportable Emissions Deviations

AES Puerto Rico is required by the facility's permits and the PR Regulations to notify the EQB if any permit limit is exceeded due to malfunction or process upset. This faxed message serves as notification. Attached is a copy of the CEMS Excess Emissions Report and the Daily Emissions Report for Unit 2 for July 06. 2004. This incident occurred during the 3-hour average between 0700 and 0900 hours. This was due to a process upset of the boiler temperature, air, fuel and emissions controls while raising load at the request of the electric utility. The emissions exceedence recorded by the CEMS at 0900 hours was an SC>2 3-hour average of 9.1 ppmvd. The permit limit for this parameter is 9.0 ppmvd on a 3-hour rolling average. The SO2 Ib/hr and Ib/MMBtu permit limits were not exceeded. The corrective actions taken at the time were: stabilize temperature, air and fuel mixes and increased the injection rate of the SC>2Sorbents, limestone and hydrated lirne. If you have any questions please contact William Vela at (787) 866-8117 ext. 239.

Fernando Rodriguez Lead Operator

AESPR-076476