EXHIBIT 2

EXHIBIT 2

REDLINED VERSION OF THE PERMIT

THROUGH SECTION 8

Electronic Filing - Received, Clerk's Office, April 22, 2009

* * * * * PCB 2009-092 * * * * *

EXHIBIT 2

"RENEt"Jl\L"

AIR

ions

ronmental

ance

t~idwe

Attn:

Ri k

2828 North Monroe

Decatur,

Received:

December 17, 2007

March 19, 2009

March

9, 2014

183090AAE

~~~=.~~~_~N~o~.:

00050017

Ti ton Energy Center

80 West Fir t

Jame

6 833

This permit

elect

OPERATE an

on.

Thi

ons

s permit,

ease contact John Cashman

Edwin

Bakows

P.E.

Manager, Permit Sect on

Division a

lution Control

ECB:JRC:ps

cc:

Illinois EPA, FOS,

CES

Lotus Notes

on 3

Except as provided in Conditions 1.5 and 8.

this permit.

CONTENTS

1.0

INTRODUCTION

2.0

LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED

3.0

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

4.0

SIGNIFICANT EMISSION UNITS AT THIS SOURCE

5.0

OVERALL SOURCE CONDITIONS

(CIU\PP)

ed Ope

of Clean Air Act

ion

icable Provisions and

ions

icability of

ations of Concern

rements and vvork Practices

and Emission Limitations

rements

p,rea Des

Source-Wide

Source-vvide

0vuLvv-Wide

Source-vvide

5.8

5.9

. 0

5. 2

iance Procedures

6.0

CONDITIONS FOR EMISSIONS CONTROL PROGRAMS

6.1

Clean Air Interstate Rule (CAIR)

6.2

Acid Rain

7.0

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

ZZZZ)

to NSPS - 40 CFR

to NESHAP

40 CFR

Turbines (

7.1

8.0

GENERAL PERMIT CONDITIONS

8.1

8.2

8.3

8.4

8.5

8.6

Permit Shield

icability of Title IV

Emissions Trading Programs

}nC}r~,rional

Flexibility/Ant

Procedures

ing

rements

ing Scenarios

9.0

STANDARD PERMIT CONDITIONS

fication

and Condit ons a this

t for Cause

l\ct

9 .

9.8

9.9

.10

9.13

.14

.15

10.0 ATTACHMENTS

Manit

2-1

3-1

4-1

5-1

6-1

(CAM) Plan

a Responsible 0

culate Matter from Process Emission

Guidance

erved for Future

l\c

1.0

INTRODUCTION

cat

49 1,

c, Gas & Sanitary

on,

1.4

Midwe

Generat on,

nco

Boulevard

linois 62269

The

when

leve s

king

powe

maintenance,

demand.

rat ng

power

able from other sources, due

breakdowns, or hi

Note:

Ttlj

i ve

and i not enforceable.

ion

for informat onal purposes only

As genera ly identified be ow, thi CAAPP

t contains certain

conditions

emission uni s at this source that address the

icabili y of permitt

programs for the construction and

modification 0 sources, which programs were established pursuant to

Tit

I of the Clean Air Act (CAA) and

ions thereunder.

These

programs include PSD and MSSCAM, and are

the Illinois

EPA pursuant to Sections 9, 9.1, 39(a) and 39.5(7) (a) of the II inois

Environmental Protection Act (Act). These conditions continue in

effect, notwi

the

ration date

fied on the first page

his

r authority derives from Titles

and V of the

CAA, as weI as

II and X of the Act.

(See also Condition 8.7.)

This permit contains Title I conditions that reflect Title

s established in

ously ssued for

2.0

LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED

EPA

on (40 eFR 52.21, New

c diameter less than

microns as measured

methods

diameter less than

as measured by

icable

Tit e I New - dentj

ons that are

established in t

United States Environmenta Protection

fies

hat have been

carried over from an

Title

Revised - ident fies Tj Ie

conditions

been carried over from an existing permit and s"r,C,,"rfllPnr

revised in this permit

RMP

PSD

USEPA

VOM

Volatile

Material

3.0

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

cant Activit s

constitut

10:

II ,

activities based upon maximum

201, 210 ( ) (2) or (a) (3), as

.1.

acid

1,000

h a total

ess than

Paved Roads and Par

Lots

Act

ies that are

type or character,

(18), as follows:

ficant activities based upon their

to 35 lAC 201,210(a)

(4)

any size cont

or re-refined

condensate

fro~

natural gas

lubricat ng oil, or residual fuel oils [3

and

betvleen

pnn'"JPr) power

.210( )(16)J.

int rnal combustion

units [35

tanks of any size

exclusively soaps,

s, surfactants,

, waxes,

able oils,

greases, anima fats, sweeteners, corn syrup, aqueous salt

solutions, or aqueous caustic solutions, provided an

solvent has not been mixed with such materials [35 lAC

201.2 O(a) (17)J.

and unl

systems for railcars, tank trucks, or

wat rcraft that handle only the fol

materials,

solvent has not been mixed with such

materials: soaps, detergents, surfactants, lubricat

oi s,

waxes,

oils, greases, animal fats,

sweetener, corn syrup, aqueous salt solutions, or aqueous

caustic solut ons [35 lAC 201.210(a) (18) J.

3.1.4 Activities that are considered ins

ficant activities pursuant

to 35 lAC 201.210(b). Note: These activities are not

red

to be individual

listed.

, in

with

l1y

not

nuisance

sts, do not qua

1 a defined in 35 lAC

3.2.3

Permi

rement to

lAC 23

shall

obtain

.201,

with the

shal

rements of 35

3.2.5 For each storage tank that has a

y greater than

946 liters (250 gallons) and, i no odor nuisance exists, that

ores an

c mat

with a vapor pressure

2.5

psia at 70°F, the Permittee shall

y with the

icable

rements of 35 lAC 215.122, which

res use of a

permanent

fil , or a vapor

cove

system.

3.3

3.3.1

s EPA 0

source of a

renewa

pursuant to 3 lAC

201.212(a).

3. .2

The Permi t ee must not

the I

inois EPA of any

addition of a new insignificant activity 0 a type addressed by

3 lAC 201.210(a) and 201.2 1 other than those identified in

Condit on 3.1, pursuant to Section 39.5( 2) (b) of the Act.

4.0

SIGNIFICANT EMISSION UNITS AT THIS SOURCE

LtVJ-6000)

LM-6000)

eh with

44 IVJlrv

1999

199

ion

ystem

Burner Water

eetion

Burner Water

eet on

tern

None

5.0

OVERALL

SOURCE

CONDITIONS

rmit

ing

uni

forth in

Emission Units)

s source are

ion 7 (Unit

of this

to particular

Conditions

.3.

source are s

icability:

ect to the

grea er than

pursuant to

ow the emission 0

process, incl

is vi ible

overhead t a

unles

I'Jind

40.2 kilomet rs per hour (

miles

lAC 12.301 and 21 .3 4.

ive

materia

3 lAC 212.123(a), no person shal cause or

emission of smoke or other part culate matter,

greater than 30

, into the

from any emission unit other than those emission

units subject to the

s of 35 lAC 212.122,

as allowed by 35 lAC 212.123(b) and 212.124.

Ozone

Substances

Part 82:

Y with the standards for re

and

substances pursuant to 40

motor vehicle air

B of 40

The Permittee shall

emissions reduction of

CFR Part 82,

conditioners

Persons

ances

repa r, or disposal must

pursuant to 40 CFR 82.156.

for rna ntenance,

y with the

service,

red practices

8 .

. 4

defined in 40 CFR 68.3, become

Chemical Accident

or shal

thi

) ;

ance

5 .. 5

Fut

Standards

ource become

ect to a new or

ion under 40 CFR Parts 60, 61, 62, or 63, or

after the date issued 0 this

accordance with the

with the

icable

fied and shal certi

rements of such

iance

ion 9.8.

This

revised or

0 address such new

ions (see Condit on 9.1 .2).

This

t and the terms and condit ons herein do not

affect the Permi tee's past and/or cont

obI

ion

with respect to statutory or

atory

rements

rna or source construction or modification under

of the CAA. Further, neither the issuance of this

the terms or conditions of the

shall

he liabi

the Permittee for

any

s prior to or at the

time

uance.

Action Plan

44.143, the

and have on

action

an ( an)

ow alerts,

with safe operat

information

to 35

244.141, 244. 42,

shal maintain

the source

Illinois EPA

written

the levels of emissions

alerts, and

, consistent

The

contain the

Pursuant

Permitt

with the

for

red

which

submi

of the

hal be

ations of concern

not

for

are terms

unit

fic non-

a concern s

forth in Section 7 of this

de Control

s and Work Practices

and work practices are not set for

rements

unit

c control

forth in

ion 7 of this

-vVide

ons

.6.

The annual

s ions

, not

cant act

Section 3.0 of this

t, shall not exceed he fol

limitations. The overa

emissions shall be determined by

emissions from

on uni s.

iance with these 1

ts shall be

det

ned on a calendar year basis. Thes limitations

(Condition .6.1) are set for the purpose 0 establi

fees

and are not federally enforceable (see Section 39.5(18) of the

Act)

Permitted

Pollutant

Tons/Year

Volatile Organic Material

(VOM)

10.0

Sulfur Dioxide

(S02)

10.0

Partlculate Matter

(PM)

10.0

Nitrogen Oxides

(NO

)

197.0

HAP, not included

in VOM or PM

----

Total

227.0

.6 .

ant

. 6.

not

for this

CAA.

BO'rlever,

y be

forth in Section 7 of

.7.

of the

or:

The

inois EPA may

the emis ion source or air

to conduct such tests in

the

inois EPA, at

fied

the

linois

the owner or operator of the

lution control

All

or under the direction of a

and/or

ence in the field

s EPA shall have the

lAC

Owner or

or operator of

lution control

accordance with

onable

Test ng

The 11 noi EPA shave

the ri

to conduct such tes s at any ime at its own

expense.

Upon request 0

linois EPA, the owner or

o the emission source or a

lution control

shall

, without

to the

inois

EPA, ne

sary holes

stacks or ducts and other safe and

proper test

ities,

scaf, but

instruments and sens

devices, as may be

necessary [35 lAC 201.282(b)].

Any such tests are also

ect to the Test

Procedures

of Condition 8.5 set forth in the General Permit Conditions

of Section 8.

Status

not

cCinc)ucted

"JOuld

fede

National

ions

tandards for Hazardous Air Pollutants for Stationa

Combustion Turbines, 40 CFR 6

YYYY.

the

s detailed at 40

performance

ts section shal be

For mult

e turbines, the source owner or

or shall test

st turbine which makes the

t contributions to individual and total HAP

ma or source

records and

eted

te ing s

to the Test

Procedures

the General Permit Conditions

Source-wide moni

However, there are

Section 7 of this

rements are not set for this source.

for unit specific manit

set forth in

5.9

.9.

Annual Emission Records

The Permittee shall maintain records of total annual emissions

on a calendar year bas s for the emission units covered

Sect on

(Unit

c Conditions for

fie Emission Units)

o this

0 demonstrate

iance with Condition 5.6.1,

pursuant to Section 9.5 ( ) (b) of the Act .

. 9.

Records for HAP Emiss ons

The Permittee shall maintain records of

combined HAP emissions on a monthly and

he emiss on units covered

Sect on

Conditions for

fie Emission Units)

individual and

annua basis for

(Unit

of this

.6.

.9.

the

to 40 CFR 63,

request.

s EPA

and

t shall be

the dat of entry

ied

the

llt::L\::LlJ), shall be

readily acces ible to

USEPA, and shall be made available for

the Illinois EPA or USEPA upon

. 10

ee shal ret eve and

, on paper

ce hours, any records retained in an

c format (e.g., computer) in response to an

I linois EPA or USEPA request for records

the course

of a source

ion .

5.10.1

Icc,n,,,r"l Source

Report ng

rements

The Permit

shall promptly noti

the Illinois EPA, Air

Unit, of deviations 0 the source with the

vvithin 30 days, pursuant 0 Section 39.5(7) (f) (

)

sha

describe the

e cause of such

deviations, and any corrective actions or preventive measures

taken. There are a so report

rements for unit

fic

emiss on unit s

forth in

ion 7 of this permit.

5.10.2 Annual Emissions

5.11

The annua emissions report

red pursuant to Condition 9.7

shal contain emissions information for the

calendar

year.

Source-wide operational flexibility is not set for this source.

6.0

CONDITIONS FOR

EMISSIONS

CONTROL PROGRAMS

for purpos

of he CI

Air

and

lowing emi ion

CAl

1#4

ions.

(CI~),

the USEPA

96,

(

CAIR

Emiss ons

under

and operators 0

CAIR

from

number

these CAIR

sions.

s source shall not violate

lAC Part 22 ,

SO:

CAIR un s shall not exceed the

that the source lawfully holds

Note:

must hold CAIR

owances to

from the a fected CAIR unit .

limited authorization to emit

the

od or subsequent pe od.

The

not authorize exceedance 0

ions 0

ambient

6 .. 3

CAIR

sons

The owne

and operators of thi source shall not

cable CAIR

sons, in 35

Il',C

225,

NO"

emissions from the affected CAIR units shall not exceed the

valent number of allowances that the source lawfully holds

under

CAIR

sions.

Note:

CAIR affected sources must hold CAIR NO" allowances to

account for the emissions from the affected CAIR units. Each

CAIR NO" allowance i

imited authorization to emit

the

ive CAIR NO" annual

od.

The

poss ssion of

allowances does not authorize exceedances of

icable emission s andards or

olat ons of ambient air

standards.

the

posse

emi s

ity standards.

season

does not

ent

y \"iith

and

D and E.

Section

t, the

methods are currently

6 .. 6

owners and

rms

conditions of the

he source shall

ource's

R permit

vJi

th the

(attached) .

Note:

CAIR

t, which was ssued

pursuant 0 35 lAC Part 22 .320, 225.420 and 2 5.5 O.

CAIR

sources must be operated in

with their CAIR

This source's CArR

t is

ed into this CAAPP

with a copy 0

the current CArR

ncluded as an attachment

to this

Revisions and modifications to the CAIR permit

are

by Section 39.5 of the Act.

y, revision

or renewal of the CAIR

t may be handled

from

this CAAPP

t and a copy of the new CAIR

may be

included in this

Administrative Amendment.

6.1.7

Coordination with other

does not contain any conditions that are

ended to interfere with

modi

the

rements ef 35

lAC Part

, D, and

0 CFR Part 96; or Title IV of

he CAA.

In pa icul , this pe

does not res ri

the

exibi

y 0

owne s and ope

ors 0

this ource to

with CAIR provisions,

uding he

ity to

obtain CAIR NO

owance from Illinois' Clean Air Set

Aside (CASA) for qua i

CAl\,

and

Control, hi

emis ion uni s

ition:

the

o the CM, and other laws and

thereunder, e abl sh

rements

of emissions 0

purpos

o a

Ie IV

ions

for a fected

lutants that

sions.

6 ..2

icable Emis

ov'ine

icable

units shall not exceed

holds under Title IV

] .

the source sha

not violate

ions.

S02 emissions of the a

any llowances that

source lawfully

sons [

ion 39. (7)

(g)

and (17) (1)

uni s

Each

on 0

The

owances 0 account for

the source hat are

llowance i

S02

ssions dur

poss sion of al owances

cable

andards

tandards.

6.2.4 Acid Rain Permit

The owners and operators of the source shall

erms and condi ions

ource's Acid Ra n

( 7) ( )

] .

with the

ct on

Note:

source

ct 0 an Acid Rain permi , which was

is ued pursuant to T

ODS,

including Section

3 .5(

) 0 the Act.

feet

sources must be

ed in

iance with

Acid Rain

s. This source's Acid

Rain permit is

reference into this

and a

copy of the current Acid Rain

is included as Attachment 6

of this

t. Revisions and modifications of this Acid Rain

administrative amendments and automatic

amendments (pursuant to Sect ons 408(b) and 403(d) of the CM or

at ions thereunder) are

by Title IV

sions, as

may

copy 0

the new

adminis

not

he eM s more

of Title IV

this

owners and ope

ors 0

rements [Section

7.0

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

7.1

o NS

GG)

.1.

on uni s

demands or in

to Construction

rmi

only.

ion system.

In addi ti

electri

y, each turbine may be

that it will

when

rici y.

Note:

Thi

only and

on is for informat onal purposes

7.1.

and Air Pol

U1-6000)

GT #4

LM-6000)

ural gas fired

urbine each

v,i

nominal rat

44 [v]W

1999

Burner Water

ection

tem

Burner Water

ection

Burner Water

ection

System

7.1.3

The "affected urbines

the purpose of these unit-

fic condi ions, are turbines described in Conditions

7.1.1 and 7.1.2.

Pursuant to 35 lAC 2 2.123,

No person shall cause or allow

iculate matter,

than 30 percent, into the

emiss on unit.

the emission of smoke

th an

y greater

from any

The

on f smoke or other particulate matter

from any such emiss on unit may have an

greater than 30

but not greater than 60

percent for a period or

aggregat

8 minutes

in any 60 minute

that such opaque

emissions

tted during any 60 minute period shall

occur from

one such emission unit

within

trogen Oxides:

60.332(b), e

gas turbines with

heat

greater

107.

ga oules per

on Btu/hour) based on the lower

y with the

Pursuant to 40 CFR 60.332(a) (1),

of an a

ed turbine shal

into the

from such

which

nitrogen oxides

Whe

0.007

STO

Allowabl

NO" emiss ons

("c,r,~cn

1 percent oxygen and on

volume at

) .

Manufacturer's

heat rate at

manufacturer's rated load (ki

oules per watt

hour) or, actual measured heat rate based on

ower heat

value of fue as measured at

actual peak load for the facility. The value

of Y sha 1 not exceed 14.4 ki

oules per watt

hour.

emission a 10wance for fuel-bound nitrogen

e.-Q-Le.-u~ated

from the nitrogen cant

of the

fuel as follows:

0.1

0.04 + 0.006

ume)

0.04 (N)

0.1)

0.00

The

trogen

) determined in

.1.

8 (b) .

with Condition

SuI

Dioxide:

dat on

conduct

No owner or operator

ect to the

thi

shall cause to be dis

into the

from any stat

gas turbine any gases

which contain sulfur dioxide in excess of 0.015

5 percent oxygen and on a

to 40 CFR 60. 333 (a) .

No owner

any fue

percent

60.333(b) .

ect to the

sions of

in any stat onary gas turbine

total sulfur in excess of 0.8

(8000 ppmw), pursuant to 40 CFR

No owner or

or shall cause or allow the

emissions of NO. nto the

from the affected

urbine to exceed 0.25 Ibs/mmBtu of actua heat

each ozone control

od from May 1

30, based on a ozone control

average, for that unit [35 lAC 217.706(a)].

Y with both

rpmpnts

and that more str

[35 lAC 2 7.706(b)].

Notwithst

lA.C 2

the above emis ion limitation of 35

06(a), the affected turbine

ect to a

NO. emission limi at on pursuant to any

State or federa statute,

the Act, the

Clean Air

, or any

thereunder, shall

of 35 lAC 2 7

emission limitation

)

ii.

artup a

accordance with written

the

ttee and rna

ained

at the facility, in the control room for the each

), that are

ions from startups

hat include,

the

measures:

conduct

accordance

up of an

th the

her

The

shal t ke

to minimi

emissions result

the duration of st

ups, and

0 startups:

nC)

from

ups,

minimize the

in accordance with the

manufacturer's written

of the unit, or other written

and maintained

the source

owner or operator so as to minimize the

duration 0 startups and the emissions

associated with s artups. These

should allow for review of

parameters of the unit dur

startup, or

as neces

to make

ustments to reduce or eliminate excess

emiss ons.

units in accordance with

rocE;dures devel

and

the source owner or

!:v!a

ning

wr tten

rna

ined

operator so

startups

II .

described above shall be

st annual

make

tments and shal

made

to the Illinois EPA upon

iv.

The

and

7.1.

20 .265, an

n a

ssions during s

from

for cement

cable emi sion standard(s) that occurs

and only const utes a

facie defense to

action

that the

lly

ied with

terms and

connected with such authorization.

kdown Provisions

ion

in such

or severe

that wi

be taken

and breakdowns.

This authorization

Condit on 9.2.3 aga

rcumstances.

terms and condi ons, the

to continue ope

on of an

turb

in violation of the

icable s andards

Condition

(b) and the hourly emission

Condition 7.1.6 n the event of a malfunction or breakdown

the affected turbines. This authorizat on is

lAC 201.149, 201.161 and 201.262, as the

ied for such authorization in ts

such continued

essential service or

Thi authori

ion only allows such continued

operation as neces ary to

essent al service

risk of i ury to personne or severe

and does not extend to continued

operat on

ly for the economic benefit of the

upon occurrence of excess emissions due to

malfunction or breakdown, the Permittee shall as soon

as pract

r the turbine, remove the affected

turbine from service, or undertake other action so

that excess emissions cease.

ons, the

reasonable directives

to such incident,

not

lieve the

rmitt

obI gat ion to minimize excess

malfunction or breakdown.

lAC 201. 65, an authori t on in a

continued operation wit

ss emissions

ion and breakdown doe not shield the

olation and

provided t

with a 1 terms and

authorizat on.

ect to the New Source

Stationary Combustion

KKKK, beca

the

commence

rD"cw'0~ruction

2005

60.430 (a), and are therefore

ect

GG for Stationary Gas Turbines.

modi

on,

pursuant to 40 CFR

40 CFR Part 60,

Note: To

for this

icability, the Permittee

has certified that the turbines have not been modified or

reconstructed after

18, 2005.

The affected turbines are not

ect to the National

Emissions Standards for Hazardous Air Pollutants for

Combustion Turbines, 40 CFR Part 63,

YYYY,

because

turbines are not located at a

rna or source 0

HAP emi sons, pursuant to 40 CFR 63.6085.

The a

ed turbines are not

ect to 35 lAC 212.321 or

212.322, due to the un que

ure of such

ts, a process

wei

rate can not be set so that such rules can not

reasonably be

ied, pursuant to 35 lAC 12.323.

64,

JVIa

Stationary

and

The affect

urbines are s

fter November 15, 1990,

C FR 64. (b) (1) ( ).

to a NS

pursuant to

turbines

rements,

) .

to Acid Rain

pursuant to 40 eFR

to an

for ",hich this

nuous

ance

hod, pursuant to 40 eFR

PM, VOM, and eo because the affected turbines do

rol

eve

ssion limitation

standard.

7.1.5

k PracLLces

ail ime,

0 s

, shutdown,

and malfunction, the source owner or operator shall,

to the extent

icable, maintain and

any

affected turbine n a manner consistent with good air

lution control pract ce for minimi

emissions.

Determination of whether acceptable operating and

maintenance

are

used will be based

on nformation available to the Illinois EPA or the

USEPA which may include, but is not limited to,

monitor

results,

y observat ons, review of

operat ng and maintenance

, and

ction

of the source [40 eFR 60.11(d)]

or operator

11 operate the

n accordance with wr ten

that sha

ude at a minimum

measures:

Review f operat

parameters 0

the unit

tartup or shutdown as necessary for the

proper operation of the affected turbine with

ustments to reduce emissions.

ion of

ion and repair

for a affected turbine prior to

attempting startup following repeated trips.

emi

ion and

ated

and

i .

Combined

turbines (

#1, #2,

than 4, 50 mi lion ft

per year.

limit shall be determined from a

months

data

[Tl] .

ed, and

combustors.

fected

this

operat

1 st on

ty and operation

observed

or a member of the Permi

ar bas s to assure that the a

proper y.

The

observat ons

a semi-annua bas s.

of the affected

personnel for the

environmental s aff

fected turbines are

sha

be made on at

7.1. 6

ssion Limit ions

In addition to Condition .3.2 and the source-wide emission

tat ons in Condi on 5.6, he affected turbines are

to the fol

affected turbine shall not

imits, except

startup for NO

by Condit on 7.1.6(b) ( )) and when

c hazard

tee

Material

(Lb/Hr)

Carbon

Monoxide

(Lb/Hr)

1.0

The annua

the

ons from the

not

limitations,

emissions

malfunction, breakdown, and shutdown.

annual I

ations shall be

tota of 1 months of data.

192

vm1

ance with the above

and CO

an hour that

artup sha

be assumed to 20 percent

han the 1

s in Condition 7.1.6(a),

.g.,

Ib/hr rather than 50 Ib/hr NO

unless an

alternative determination of startup emissions s

the II inois EPA in a

iii. The above hourly and annual limits were

established

Construction Permit 98110018 pursuant

to 40 CFR 52.21, the federal rules for Prevention of

cant Deterioration of Air Qual

(PSD) .

ensure that the construction and

opera

he affected turbines do

const tute

a new maj

ource pursuant to PSD

[lR] .

emissions dur

shutdown nto

lit .

. 1.6(b) ori

e ablished

98 00 8, has been

ed to include

up, malfunct on, breakdown, and

total annual emissions limited from this

7.1. 7

The nitrogen oxides (NO

)

emissions, and the oxygen (0

)

concentration and

y of exhaus sha I be measured for

ed turbines at the source owner

test

service

inois EPA s

llows to determine

ance with

cable emission imits:

Within 120

a er a written request from the

Illinois EPA, for such

lutants

sted above as

fied by the request.

for

Methods

1 be

lJSEPA Method 9

lJSEPA Method 20

eFR 60.

5(b), the owner or

determine

with the

nitrogen oxides emi

imitation

60.332 and hal meet the performance

rements of 40 eFR 60.8 s follows:

ItJhe

(b) (1) :

(NO

)

) 0 . 5

9 (

(

8°KI

)1. 3

0.006

emis ion concentration 0

percent O

and IS0 standard ambient

conditions, ppm

volume,

bas s

mean observed

concentration, ppm

volume, dry basis, at 1

ference combustor inlet absolute

pressure at 101.3

opascals ambient

sure, mm

obs rved combustor

abs

sure at

observed humidi y of ambient

Olg

anscende,nt al

.718

ambient

) .

40 eFR

red

rement ,

red for any

CFR 60. 31),

water or

ection s used to control

with no additional pos -combust on NO.

control and the owner

operator chooses to

monit

stearn or water to fuel ratio in

accordance with 40 eFR 60.334 (a), then that

monit

must be operated concurrent

with each EPA Method 20, ASTM 06522-00

(

ference, see 40 eFR 60.17),

or EPA Method 7 run and shaJ

be used to

determine the fuel cons

ion and the steam or

fue ratio necessary to

y with

icable 40 eFR 60.332 NO

emi sion limit,

o 40 eFE 60.335(b) (4).

he owner

operator 1

s to nstall a

the performance evaluat on of the CEMS

may either be conducted separat y (a

described in 40 eFR 60.335(b) (7)) or as

the

tial performance test 0 the affected

unit, pursuant to 40 eFR 60.335(b)(6).

Pursuant to 40 CFR 60.335(b)(7), if the owner

or operator elects to install and certi

a NO.

CEMS under 40 CFE 60.334(e), then the initial

performance test

red under 40 eFR 60.8 may

be done in the fol

a ternative manner:

Perform a minimum 0

9 reference method runs,

with a minimum time per run of 21 minutes, at a

load level, between 90 and 100 percent

of peak (or the

st phys cally achievable)

load, pursuant to 40 eFR 60.335(b)(7)().

Use the test data both to demonstrate

iance with the

icable NO

emi sion

rement to

waived,

) .

additional

pursuant to 40 FR

f the

40 eFR 60.3 (b)( 0),

f the owner

red under 40 eFR

34 ( ) (1) or (3) to

odically determine

fur content of the fuel combusted in the

ULULlle,

a minimum 0

fuel

s shall

ected

the performance est.

for the ota sulfur

I , ASTM 010

0, 90

994); 03246-81, 92, 96; 04468-85

2000); or 06667-01 (all 0

which

ed by reference, see 40 eFR

60.17)

The

icable ranges of some ASTM

methods mentioned above are not

measure the evels of sulfur in some fuel

gases. Dilution of samples before analysis

(with verification of the dilution ratio) may

be used, subject to the

approva of the

Administrator, pursuant to 40 eFR

60.335(b) (10) (il).

The

ana yses

red under 40 eFR

60.33 (b) (9) and (b) (10) may be performed

owner or operator,

ce contract

ned

the owner or ope rat ,t

vendor, or any other qualified agency, pursuant

4 0 e FR 60. 3 3 (b)! 1).

Pursuant

operator

to the

to 40 eFR 60.335(c),

may use the

fol~uw~J1Y

ference methods and

ed in this section:

the owner or

as alternatives

Instead of us

the equat on in 40 eFR

60.335 (b) (1), manufacturers may develop ambient

ISO standard

60.33 ()(l).

actual

submi

shall

EPA

VJhi

ive 0

which the operaL

urbine will be tracked and

recorded.

tes

i. The

determinations of emiss ons that are

intended 0 be made,

and

monit

locations; the test method(s) that wi 1 be

us , with

fie

ys s method, if the

method can be used with different analys s methods.

The source owner or operator may also propose a

for te

across the normal operat

range 0 the

affected turbines.

The Illinois EPA

11 be notified

or to these ests to

enable the 11

s EPA to observe the

t sts.

Not

cat on of the

date of test

shall be

submitted a minimum of thirty (30) days

to the

date. Notification of the actual date and

time of test

sha

be submitted a minimum of

days

to the actual date of the test.

The

EPA may,

s discretion, accept

ions with shorter advance notice

that the

will not accept such notifications

s wi

the Illinois EPA's abil y to observe the

The Final

for these tests shall be submitted

the

I inois EPA with

60 days after the date of the tests.

The Final

shall include as a minimum:

A summary of results.

ii.

General information.

ion of es method(s),

points, s

train,

and tes schedule.

des

analysis

ion

iv.

Detailed des

ion of test conditions,

Electronic Filing - Received, Clerk's Office, April 22, 2009

* * * * * PCB 2009-092 * * * * *

u/hr) .

source

have the

the

ed turbine ()

ted

ope rat

conditions as determined

observer in accordance with USEPA Test

further

fied below,

uant to

(7)

(d) of the Act.

for

fie

the request, or

or on the date

)

are both

i .

source owner or operator shall noti

the

s EPA

in advance 0

date

ime 0 the e tests, in order 0 allow the

nois EPA to witness t st

This notification

1 include the name and

r of the

ified

•

The s

the

for

or operator shal promptly not

EPA of any

s in the ime or dat

The

owner or operator sha

its observer'

to the

de a copy of

at the

ime

linois EPA

are

pres

vi.

operator shal submit a written

within 30

the date of

shall include:

Oat and ime 0

est

Name and

ed observer.

of current certification.

Electronic Filing - Received, Clerk's Office, April 22, 2009

* * * * * PCB 2009-092 * * * * *

Des

ion

obs

ion conditions.

Des

ion 0 turbine ope rat

conditions.

Raw dat

Moni

an affected turbine is routinely operated

to con rm that the turbine wil ope

when needed, the operat on and

y of the

ed turbine shall be forma y observed by

personne for the

fe ed turbine or a

member of s

owner or operator' environmenta

sta f on

r ba

the

fected

urbine

y, wh ch observations

sha

at least every six months.

ii.

ed turbine is not routinely operated or

rcised,

.e., the time interval between ope

of an affected urbine is

cal y greater than s

months, the operation and

y of the affected

turbine shall be formal

observed as

above

each time the source owner or operator carries out a

scheduled

se of the affected turbine.

owne or operator

also conduct

rvations of operation and

upon written request

inois

the ag

of the II inois EPA, the

owne or operator may schedul these

ke place

riods when it

would

otherwise be operating the affected turbine.

The source

forma

EPA.

Not:

The forma observation

red above s not

intended

be a USEPA Test Method 9

test, nor does

the observat on

re a USEPA Test Method 9 certified

observer.

It s intended to be performed by personnel

famil ar with the operat on of the affected turbine who

would be able to make a determination based from the

observed

as to whether or not the affected turbine

was running proper

and subsequent

init ate a

corrective action f necessary.

The affected turbine shall

with the

cable

rements of 40 CFR 60.334 (h), below.

of fue nitrogen content sha

not be required

while the facility does not c aim an allowance for fue -

bound nitrogen. Monitoring for sulfur content in fuel is

not

red while natural gas is the only fuel fired in

the a fected urbine and the

rements of 40 CFR

60.334 (h)3( ) or ( i) are met.

(4000 ppmw) , ASTM

8 98, or Gas Processors As

ion

of which are

60. 7), which

sulfur

uant 040 CFR 60.334(h)(l); and

60.

4 (h) (3), not wi thstanding the

CFR 60.334 (h) (l), the owner or operator

o monit

1 sulfur content 0 the

gaseous fuel

the de

on 0

natural gas in 40

whether an

custom

the admin st tor for

The owner or operator shall use

the fol

sources of information 0 make the

demonstration:

The gas

charact

stics in a current, valid

e contract, tari

sheet or ransportation contract

for the gaseous fuel,

that the maximum total

sulfur content of the fuel is 20.0 grains/lOO scf or less,

pursuant 0 40 CFR 60.334 (3) (i); or

data which show t

the

eous fuel does not exceed 20

minimum, the amount of fuel s

on .3.1.4 or .3.2.4 0

Led, pursuant to 40 CFR

Should the operat

of the affected turbine exceed the

limitations of 7.1. 6 (b) (i) re

to the definition 0 a

gas-fired pea

in 40 CFR 75, the source owner or

shall install the

Continuous

Sys em(s) on the affected turbine

December 3

calendar year, as defined in 40 CFR 7 ,

lAC 217.7 O( ) above,

red pea

unit or oi

fined in 40

owner or

fired

determine

lAC

Notwithst

5 lAC 217.7 O( )

combustion urbine

than 3 0 hour per ozone control

the heat

and NO

emissions of

lows [3 lAC 21 .710(c)]:

, the owner

od may determine

the turbine as

Heat

fuel

shall be determined from the metered

to the turbine or the calculated

determined as the

of the

heat input and hours

recorded

operat

on the turbine 35 lAC

appropr

lAC

sha 1 be

detcL"ullC~u

, as determined

default NO

emission

1 .710(c)( )]:

as he

above, and the

actors below

Ibs/mmBtu - Natural gas

.2 Ibs/mmBtu - Fuel oil

.1.

ii.

The ffected turbine shall be

ained with

continuous

monitor and record the fuel consumption

, and

system to

fired.

7.1.9

n addi on to he

owner or operator shall

for he

fected turbi

Condi ons 5.6.1,

.3,

39.5 ( ) (b) 0

the Act:

red

Condition .9,

maintain records of the foIl

(s) to demonstrate

ance

.1.5, and .1.6, pursuant

the source

items

with

o Sect on

( ))

and report

icable to NO

emis i

od,

, but not

and (d)

[35

lAC

lAC 217.71 (a) above,

owner or

a combustion turbine for which heat

sions are determined pursuant to 5 lAC

)

(Condi ion 7.1.8(d) ( ii)) shall

fol

and report

(b) ] :

Maint in records 0

the heat input and NO

o the turbine

determined

accordance with

lAC 21 .7

O( ),

and records

metered fuel use or ope

hours used to

dete

heat

lAC 217.712(b) (1)]

owner

ope

or shall maintain records of

The three year roll ng average

factor and the

annual

n anyone 0 the three

determine t

status 0

a "gas- red pea

unit" as

Condi

on 7. 1. 6 (b) (i) .

annual

LdLIJ(~L-Lty

factor

years to

fected turbine as

detailed in

A record document

whether the

factors exceeded the imitations of Condition

7.1.6 (b) ( ) and whether Acid Rain

Continuous Monit

em(s) will be

red.

The suI

content 0

natural gas used to fire

the turbines as determined in accordance with

Condition 7.1.8(b).

i. A copy of the Final

(s) for emission test ng

conducted pursuant to Condition 7.1.7.

qual

rminations taken for the source

OSEPA Method 9.

Records

operat ng

.1.

(a).

s periodi

s as

red

review of ts

Condition

vi.

nformation for the formal observations of

conducted pursuant to Condition .1.8(a)

For

occasion on which observations are made, these

each

date, time,

the vari

whether or not the af

y, and whether

not

and was

og for

formed wi h

ed turbine,

cf /month and

hours

hr/month and

content of

turbine.

fuel

red in the affected

lutant from the affected turbine,

from st

, with

documentation on the validity of the

ton/month and ton/year.

of each

emiss ons

calculations

emi sion factors

The source owner

operator sha 1 maintain records that

dur ng which a continuous

tor

ope

iona, wi h explanation.

affected turbine was in operation

was deemed to be a traffic

hazard, the ambient condi ions existing

the date and time the water

ection system

was deactivated, and the date and time the system was

reactivated.

which emission and/or

standard

imit.

y exceeded an

The source owner or operator shall

operat

practices for

ch turbine.

records of

ch shutdolrln 0

Date

hutdown.

detailed

ten

dur

A des

operating

hutdown or

the shutdown,

ion.

The

informat on

the turbine

observed

source

when above

personnel:

, pos

and reason for being

durat on 0

above

luding a fected urbine,

norma

rat on was achieved.

time

normal operation was not

minutes, an

anation why startup

achieved wi

thi time.

within 30

could not

artup,

ion

established s artup

s could not be performed, if not

performed.

The nature 0

fol

he end of

s rtup or 30 minutes of operat on, whichever

occurs

rst, and duration of operation unt 1

achievement of normal

or shutdown.

Whethe

exceedance

of Condition 7 .1. 3 (b)

i . e. ,

percent

ty, may have occurred

during

artup, vJith

anation

quali

ied

observer

via

teo

ffi.

rds

S artup

at a

records,

Act, for each

7.1.3(b), which

The Permittee shall maintain the

fol~G'w~LLY

pursuant 0 Section 39.5(7) (b) 0

the

a fected turbine

ect to Condi on

minimum shall include:

The

information for each

affected turbine(s):

of the

up, i. e., s

not

eved within 0,

could not be

f he

rtup,

operation and whethe the

performed.

of 7.1.3(f)

could

formed.

exceedance of Condi

.2 and

.3(b) may have occurred

startup.

may have occurred, an

ion

of the nature 0

y,.,

severity and

duration,

the startup and the nature of

y at the conclusion of startup.

Whether operat

ronmenca

personnel for the turbines

s a

are on s te during

vJith date.

~Jja

ons and

kdowns

rAC

of an affected turbine

malfunctions and

shall include:

The Permitt

shall mainta

20 .263, of continued operation

ect to Condition 7.1.3(g)

breakdown, which as a

Date and durat on of malfunction or breakdown.

A deta

breakdown.

ion of the malfunction or

ion

affected turbine continued to

operate in accordance with Condition 7.1.3(g).

iv.

The measures used to reduce the

and the duration of the event.

ty of emissions

The s

taken to prevent

breakdowns or reduce heir

malfunctions or

and severity.

amount of release above

ma1funct

Ibreakdown.

cal emissions

Devi ions

The source owner

operator shal prompt

not

llinois EPA, Air

ance Unit, of deviations

turbine with the permit

rement a

pursuant to Secti

39. (7) (f) (

) 0

Act.

cribe the

cause 0

such devi

any correct ve actions

preventive mea

the

follows,

Report

ions, and

ken:

ions from the a fected turbine

s spe fied in Condi

n excess 0

the

and 7 .. 6 within

the af

ed turbine

ed in Condi

7.1.

such occurrence.

n exces

and

of the

.1.6 within

unction with the Annual Emission

red

Part 254, the source owner r operator shal prov de

hours for each affected turbine, the ota

the otal

on dur

the

and he records necessary from

ch demonst

Acid Ra n

cted urbine as a "gas- ired

six-month

Pursuant to 40 CFR 60.7(c) and 40 CFR 60.334( ), a

report shal be submitted on a semi-annual basis,

30th

the end of each

1 .

o 40 CFR 60. 7(c)

4( ),

1 be submi ted on a semi-annua bas

sha 1 contain

format on on excess

emi

ions and moni

system downtime report in

accordance wi

40 CFR 60. (c) and 40 CFR 60.334 ( )

Annual y

the turbine

2 7,

control

7.71

the heat

and NO

emissions 0

as determined in accordance with 35 lAC

for each ozone

November 30 of each year [35 lAC

Pursuant to 35 lAC 217.712(c) and (d), no later than

November 30 of each year, the source owner or

operator shall submit a

to the

lino s EPA

that demonstrates that the affected turbine has

ied with Condition 7.1.3(e). These reports

sha 1 be

by a certification statement

owner

the

each

for

urbine,

ion of

the records

each st

of the a

the date, duration and

accomp'arlied

a copy of

pursuant to Condi ion 7.1.9(

for

which

ed turbine

shall be stated in

and Breakdowns

to 35

of an

ion

Unit and

HIC 20 .263,

affected urbine

malfunction or

and

breakdown.

EPA's

Upon achievement of

iance,

rmittee

shall

a written follow-up notice

thin 15

to the I

inois EPA, Air

iance Unit

and

onal Field Office,

a detailed

ion of the event, an

anation

continued operation of the affected turbines

was necessary, the

of time

which

operat on continued under such conditions, the

measures aken

the Permittee to minimize and

correct def

encies with

and when

he a fected

wor

Illinois

Field

with the due dates in Condition 8.6.1,

Permittee shal submit semi-annual malfunction

kdown reports to the Illinois EPA pursuant 0

(7) ( )

(f) of the Act.

The

may

submitted

ong with

r semi annual

and shal

ude

fol

informat on

breakdowns

ions

kdowns, in

includes:

ime, and durat on of each

II.

identity of the affected operat on(s)

involved in

incident.

Dates of

. 10 (

notices and reports of Conditions

) (i) .

nformat

to the not

7.1.0(f)(i).

on the Permittee wishes

and reports of

on 0

all

s dur ng

no such incidents

the

this shal be stated in the

.11

rational

ona flexibility is not set for the affected turbines.

7.1.12

Procedures

iance with the PM emission limitations of Conditions

.1.3(b) is addressed

rements of Condi ion

.1.5, and the records

red in Condition 7.1.9, and the

reports

red in Condition 7.1.10.

iance with the SO] emission limitations of Conditions

7 .. 3 (c) is addressed by the

rements of Condition

Ii.

the S02 emi s on limitations a

(d) ( i) is addressed

the

Condition 7.1. , the records

, and

red n

red

ion

of Condition 7.

7.1.7, the monitor

records

n Condition 7.1.9,

red in Condition 7.1. O(a).

rement

7.1.8,

and the

rements

the

Notwi

.1.

8 (d) ,

turbine

control per od may determine

emissions of

2 .710(c)J

Condi ion

Heat

shall be determined from the metered

fuel usage to the turbine or the calculated

heat

determined as he

of the

turbine's maximum

heat

and hours

ion as recorded

operat

instrumentation on the turbine [35 lAC

217.710 (c) (1) J.

emissions shall be determined as the

, as determined above, and the

default NO

emission factors below

.7 0 (c) (2) J :

0.7 Ibs/mmBtu - Natural gas

1.2 Ibs/mmBtu - Fuel oil

iance with the fuel

ts in Condition 7.1.

addressed

the records

and

Conditions .1.9

and

7.1.10.

sion I

in Conditions 5.6

the records and

7.1.9 and 7.1.10, the

inuous NO

moni

rements in Condition

7.1.8, or from emission factors developed from the

most

stack test in accordance with

Condi ion 7.1.7 (

), standard emission factors (CO,

VOM and PM/PM

) and ana

is 0

fuel sulfur content

ctors

(S02)

7.2

ZZZ)

a proce

ra on.

ion

ed to

for informational purposes

Provisions and

ed diesel

" for the purpose of these

uni -

fie conditions, are diesel

described in

Conditions 7.2.1 and 7.2.2.

to 35 lAC 212.123,

emission of smoke

ty greater

rm""nh~re

from any

on ha

cause or allow

othe particulate matter, with

than 30 percent, into

s ion un t.

The emission of smoke or other particulate matter

from any such emission unit may have an

er than 30 percent but not greater than 60

percent for a

od or periods aggregating 8 minutes

n any 60 minute period

that such opaque

emissions

during any 60 minute period shall

occur from only one such emission unit located within

a 1000 ft radius from the center

of any other

such emission unit owned or operated

such person,

and

further that such opaque emissions

ted from each such emission unit shall be

limited to 3 times in any 24 hour period.

Pursuant to 35 lAC 214.301, no person shall cause or

allow the emission of sulfur dioxide into the

any

s ion

7. .4

Manufactured after

I 1, 2006 and

not

pump

, pursuant to 40 CFR 60.4200(a) (2) (i).

Manufactured as

certified Nationa

As ociat on (NFPA) f

pump

2006, purs

to 40 CFR 60.4200(a)

Fire Protection

fter July 1,

(2) (

Permittee

modi

ed or

11,

The affected

luded from certain

rements 0

the Nat onal Emissions Standards

Hazardous Air Pollutants for Stat

Internal Combustion

s 40 CFR

because the affected diesel

('r\mr,rpssion

ion (CI) stat

to 40

CFR 63.6590 (b) (3), and do not have to meet the

rements

hat

A, additiona

no initial

not fication is necessary.

rements necessary to

maintain the exclusion, and therefore compliance with that

Part, are found within this Section.

fical

those

rements are not

an affected source

to 40 CFR 63.6590.

The affected diesel

(used as diesel

ors) are

not

ect to the Acid Rain

40 CFR 72, because

affected diesel

s are non-uti

y units, as

40 CFR 72.6(b) (8).

Pursuant to 40 CFR 72.2,

s defined a

a unit owned or

serves a generator in any State that

fected diesel

nes are not sect to 35 lAC

.3 ,due to the unique nature of such units,

a process

can not be set so hat such rules can

not reas

ied, pursuant to 35 lAC 212.323.

The affected diesel

are not

ect to 35 lAC

216.121 because the affected diesel engines are not fuel

combustion units, as defined

35 lAC 211.2470.

470.

achieve

CFR Pa

operat

pra ices for the

nspection, rout

only

red in the

The Permi tee shall not uti i

ulfur content

llate

oil with a

be allowed to

1 fuels

7.2.6

ations

Produc

and

limi at ions

not

, there are source-wide

forth in Condit on .6 .

the affected

rr,rlllrrion and

Upon written request

Permi

shal have

the f

ed diesel

repre entat

a qual fied observer

Method 9, as furrher

ct on 39. ( ) (d) 0

rom

rmined

on the

date

later.

Such test

shall be conducted for spe fic diesel

ellYLlle(S) within 70 calendar

he request, or

date diesel

(s) next operates, or on the

upon

the Illinois EPA, whichever i

i .

i. The duration 0

y observations for each test

shall be at east 30 minutes (five 6-minute averages)

minute

both

r-r,,,,,,,,,,s in

nrnrr,ryrly not

the 11

noi

EPA

time or dat for test

copy of t

llinois EPA at the time

personnel are present.

submit a

in 5

of the date 0

include:

report

this

This

Dat

and

ime of

Name and

oye of qualified observer.

certi i

on.

observation conditions.

of diesEc;l

ing

Raw data.

Y determinations.

Conclusions.

n the event that the fuel oil

ier is unable to

the su fur content 0 the fuel oil

y for

the affected diesel

, the Permittee shall have

the sulfur content of the oi

to the affected

diese

s, in Ibs/rnrnBtu, determined from an

representative s

the oi

pursuant to Sect on 9.5(7)(d) 0

From a

taken no later than 90

after

first operat

the affected diesel

to this

however,

that if such

e is taken following

operation 0 the affected diesel

s, the

sample shall be taken

or to

more oil

to the storage tank.

Unit

(b) (2)

Program, 40 eFR

ions Data Protocol for Gas-

.g., ASTM 04057-88 and ASTM

on 7.2. (b) (

fuel tes

and s in no way intended to

ect the source to those

sions.

s routinely

affected diese

the operation and

die

shall be forma ly

ng personnel for the affected

a member 0

Permittee's

a f on a

ar bas s

tbat

is operat

be made at

I an affected

operated or

between

diesel

is not routinely

sed,

. e., the time interval

o an affected diesel

ly greater than six months, the

ion and

of the affected diesel

shall be

formally observed as

above each time the

Permittee carries out a scheduled exercise of the

affected diesel

The Permit ee shal also conduct forma observa

of operation and opacity of

ffected di s

upon written reques

the

inois PA. With the

agreement of the llinois EPA, the Permittee may

obs

to take

would otherwi

be ope rat

observation"

red above is not

be a

t Method 9

st, nor doe

ion

a USEPA Test Method 9 cert f ed

s intended to be performed

personnel

with he operat on 0 the a fected diesel

who

would be able to make a determination based from the

ed diesel

s who would be abl to make a

determinat on based from the observed

ty as to whether

of not the a fected die 1

and

a correct

red

5.9, the

items for each

demons rate

iance with Conditions

o Sect on 39.5(7) (b) of the Act:

An operat ng og

which shall include

fected diesel

information:

Informat

for each time the affected diesel

ed, with date, time, duration,

and purpos (i.e., exercise or power service)

Monthly and annual records of hours of

on of each

and total hours of

operation.

Information for the observations conducted

pursuant 0 Condition 7.2.8(a) or 7.2.7(a),

with date, time, personne , and

The Permittee shall

records for all

measurements made in accordance

with USEPA Method 9 for an affected

diesel engine that

conducts or that

are conducted on its behalf

individuals who are qualified to make

such observat ons for Condition 7.2.7(a)

For each occas on on which such

made, these records

sha

ident ty of the

observer, a des

on of the various

observations hat were made, the observed

and

raw

da~a

sheets for he observat ons.

The Permi tee shall

for al

formal observations of

y conducted

pursuant to eondi tion 7.2.8 (a). For each

occasion on which observations are made,

these records shal include the date,

any

at ion rom

ivi ie

each

i t

A maintenance and

and

ociat

with

i .

The Permitt

pract

for

Condit on

records

operat ng

s defined

usage

the affected

age 0

I oi for the affected dies

, gallons/month and

Ions/year.

records related to he sulfur content of the

y and SOz emissions of the a fected diesel

Records for each

of fuel for the affect d

engine , incl

dat ,

ier, quanti

Ions), sulfur content, and whether the

rom the burning

such fue would meet

rd n Condi ion 7.2. ( ).

he sui

a fected die

average 0 mat rial in

content of the

sulfur content in

ha 1 ma

fue

'yLllCC, based on the we

the storage tank, or the sulfur

shall be assumed to be the hi

any

in the tank.

ssions

, YOM,

support

7.2.9.

from each affected diesel

(i.e., NO

CO,

and PM) in tons/month and tons/year with

calculations and data as

red

Condition

7.2.10

o Deviations

The Permittee shal prompt y noti

the

linois EPA, Air

of deviations of an affected diesel

with the permit

s as fol ows, pursuant

to Section 39.5(7) (f) (ii) of the Act.

s shal

describe the

cause of such deviations, and any

corrective actions or preventive measures taken:

cted

ed in

fied

occurrence.

ll.

7.2.6 within 30

Scenarios

y i not

for

af cted diesel

PM emi s on limit

ons of Condit

rement a Condit on

rement in Condit on 7.2.7(al,

rements a Condition 7.2.8(al, the

in Condition 7.2.9(al, and the

ion 7 ..10(a).

the S02 emis ion 1

.3 ( ) (i)

s addre sed

Condi ion 7.

in Condition 7 .. 7 (bl,

red in Condit ons

tation of

the

and the records

.2.9(b) and (cl

For this purpose,

ete conversion of sulfur into

S02 shall be assumed, e.g., S02 emissions in Ib/mmBtu

are twice the sulfur content 0 the fuel

, in

Ib/mmBtu, us

the fol

equation:

ppm

Fuel su1

385.2 x 1 000 000

e oil with the

rcent, would

hat

s we

(

the F-factor

Note:

maximum a

below the 20

ppm

ion

only about 500 ppm, based on 10,320

for oi in USEPA'

Reference Method

iance with the emission limits in Condition 5.6 are

addressed by the records and reports

in Condit ons

.2.9 and 7.2.10 and the emission factors and formulas

1 sted below if suitable manufacture's emission rate data

s not avai able:

Emission factors for the affected diesel engines up

to 600

VOM

Fue Input

0.3

0.31

0.29

4.41

0.9

0.031

6.68

The heat

ent 0

sumed to be 137,0

42.

Fue Ojl

EXHIBIT

LETTER FROM USEPA WAIVING THE

WATER~TO~FuEL

MONITORING REQUIREMENT

OF 40 CFR

60.334W

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGIONS

77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590

APR'!

2003

Natalie E. Locke

Air Programs Group Leader

Dynegy Midwest Generation, Inc.

2828 North Monroe Street

Decatur, IL 62526-3269

REPL Y fa THE ATIENTION OF

(AE-17J)

Re: Request for Approval of a Custom Fuel Monitoring Schedule

and Utilizing CEMs for NOx Monitoring at Dynegy Midwest

Generation, Inc. - Tilton Energy Center in Tilton, Illinois.

Dear Ms. Locke:

I am writing in response to your letters dated February 26, 2003,

and June 22, 2000. Your letters request the United States

Environmental Protection Agency's (U.S. EPA's) approval of a

custom fuel monitoring schedule and alternative NOx monitoring to

demonstrate compliance with the Standards of Performance for

Stationary Gas Turbines (40 C.F.R. Part 60, Subpart GG).

Specifically, your February 26, 2003, letter makes the following

requests:

Waive the water-to-fuel monitoring requirement in 40 C.F.R.

§60. 334 (a) .

Reporting requirements in 40 C.F.R. §60.334(c) be limited to

semi-annually as stated in 40 C.F.R. §60.7(c) and that these

reporting requirements remain at semi-annual without

reverting back to quarterly as stated in 40 C.F.R.

§60 .7 (e)

(3) .

In addition, your June 22, 2000, letter makes the following

request:

An alternate fuel monitoring schedule in accordance with 40

C.F.R. Part 75, Appendix D, Section 2.3.1, instead of the

sulfur monitoring requirements of 40 C.F.R. §60.334(b) (2).

RecycledJRecyclable • Ponted with VeQetable 011 Based Inks on

500/0

Recycled Paper

120%

Postconsumer)

Based on current information, it is U.S. EPA's understanding that

the Dynegy Midwest Generation, Inc. - Tilton Energy Center

(Tilton Energy Center) has four simple-cycle combustion turbines

(CTs). Each CT is exclusively fueled with upipeline natural

gas," as defined in the most current 40 C.F.R. §72.2. Each CT is

equipped with a continuous emissions monitor (CEM) to monitor

NOx.

D~ter.minations:

After reviewing the information provided, the applicable

regulations, and previous determinations, U.S. EPA has made the

following determinations regarding the four, pipeline-quality

natural gas fueled, simple-cycle CTs at the Tilton Energy

Center.

Waive the water-to-fuel monitoring requirement in 40

C.F.R. §60.334(a).

U.S. EPA will allow Tilton Energy Center to use CEMs to monitor

NOx emissions as an alternative to monitoring the water-to-fuel

ratio to demonstrate compliance with 40 C.F.R. §60.334(a). These

CEMs can be used if the following conditions are met:

Each turbine meets the emission limitation determined

according to 40 C.F.R. §60.332. The uy" value for the

applicable equation and supporting documentation should

be provided by the applicant and the limitation for NO

emissions from pipeline quality natural gas should be

fixed assuming the UF" value equals O. The emission

limitation must be expressed in ppmv, dry, corrected to

15 percent oxygen (0

Each NO

CEMs meets the applicable requirements of 40

C.F.R. Part 60, Appendix B, Performance Specification 2,

and Appendix F for certifying, maintaining, operating and

assuring quality of the system.

Each NO

CEMs is capable of calculating NO

emissions

concentrations corrected to 15 percent O

and

International Standards Organization (ISO) standard

conditions.

Each owner or operator of the NO

CEMs shall submit an

excess emissions and monitoring systems performance

report [40 C.F.R. §60.13(h)] and/or summary report form

to the Administrator on a quarterly basis, if excess

emissions are determined, or semi-annually, if no excess

emissions are determined. The report shall be postmarked

by the 30

day following the end of each reporting

period. Written reports must include information

required at 40 C.F.R. §60.7(c-d). This report shall also

contain the content of nitrogen in fuel oil for each

reporting period when oil is fired and a clearly

calculated corresponding emission limitation.

Record-keeping requirements shall follow the requirements

specified at 40 C.F.R. §60.7.

CEMs shall be used to demonstrate compliance with the

emission limitation on a continuous basis and the

quarterly report shall include the NO

mass emissions for

the reported period as reported to the State.

Reporting requirements in 40 C.F.R. §60.334(c) be limited

to semi-annually as stated in 40 C.F.R. §60.7(c) and that

these reporting requirements remain at semi-annual

without reverting back to quarterly as stated in 40

C.F.R. §60.7(e)

(3).

U.S. EPA disapproves Tilton Energy Center's request to waive the

reporting requirements stated in 40 C.F.R. §60.7(e) (3). U.S. EPA

does not waive the requirements that are located in the 40 C.F.R.

Part 60, General Provisions. 40 C.F.R. §60.7(e) (3) states that,

"as soon as monitoring data indicate that the affected facility

is not in compliance with any emission limitation or operating

parameter specified in the applicable standard, the frequency of

reporting shall revert to the frequency specified in the

applicable standard .... "

An alternate fuel monitoring schedule in accordance with

40 C.F.R. Part 75, Appendix

Section 2.3.1, instead of

the sulfur monitoring requirements of 40 C.F.R.

§60. 334 (b) (2) .

EPA

approves your request to use the monitoring requirements for

sulfur at 40 CFR Part 75, Appendix D, Section 2.3 in lieu of fuel

monitoring requirements for sulfur at 40 CFR Part 60, Subpart GG.

These alternate monitoring requirements can only be used when

pipeline quality natural gas is the only fuel being burned and

must be in accordance with 40 CFR Part 75, Appendix D, Section

2.3.

The revised 40 C.F.R. Part 60, Subpart GG was published in the

Federal Register on April 14, 2003. The rule will go Direct

Final after the 30-day comment period is up.

If you have any

questions concerning the matters addressed in this letter, please

contact Sara Dauk, of my staff, at (312) 886-0243.

Sincerely yours,

//'J

r//

//,

)" ,

Air

Georg~'~'

Enforc~ent

\ ernia

pliance

Chief

Assurance Branch

CERTIFICATE OF SERVICE

I, the undersigned, certify that on this 22

day of April, 2009, I have served

electronically the attached

APPEARANCES OF KATHLEEN

BASSI, STEPHEN J.

BONEBRAKE, and JOSHUA

MORE and APPEAL OF CAAPP PERMIT,

upon the

following person:

John

Therriault, Assistant Clerk

Illinois Pollution Control Board

James

R. Thompson Center

Suite 11-500

100 West Randolph

Chicago, Illinois 60601

and by first class mail, postage affixed, upon the following persons:

Division

of Legal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 62794-9276

Kathleen C. Bassi

Stephen

1. Bonebrake

Joshua

R. More

SCHIFF HARDIN LLP

6600 Sears Tower

23.3 South Wacker Drive

Chicago, Illinois 60606

312-258-5567

FAX: 312-258-5600

kbassi!'2v,schit1nardin.com