1. Services
      2. Scenarios
      3. 1.4 Source Description
      4. Source Review for attainment areas)
      5. 3.1 Identification of Insignificant Activities
      6. 3.2.1 For each particulate ma,tter process emission unit, the Permittee
      7. 3.2.2 For each organic material emission unit that uses organic
      8. permit as a major source of NOx and CO emissions.
      9. 5.3 Source-Wide Applicable Provisions and Regulations
      10. No person shall cause or allow the emission of fugitive
      11. a. Persons opening appliances for maintenance, service,
      12. c. Persons performing maintenance, service, repair, or
      13. b. This permit and the terms and conditions herein do not
      14. 5.6 Source-Wide Production and Emission Limitations
      15. Other Source-Wide Production and Emission Limitations
      16. P1:l:rSl-laHt te CeFlaitieB 9.7.1 ana Ee verify oeFf\i?liaaoe 'oliER tae
      17. b. '3:'Re ealoulatien as Ee 'io:hetRer ERe 8Q% sf maj er seuree
      18. oSm£liaea IIAP omissisns sa a msathly ana aBf.I:1:lal Basis fer
      19. Source-wide operational flexibility is not set for this source.
      20. allowances does not authorize exceedances of
      21. season or subsequent season. The possession of NOx allowances
      22. a. This permit does not contain any conditions that are
      23. a. This permit doe$ not contain any conditions that are
      24. Program are referred to as budget sources.
    1. The number of NOx allowances available for budget sources is set
      1. This budget requires a substantial reduction in NOx emissions
      2. In addition to directly receiving or purchasing NOx allowances
      3. as described above, budget sources may transfer NOx allowances
      4. ii. This permit does not provide \\low-emitter status" for
      5. emissions in any control period, i.e., NOx emissions in
      6. c. Copies of all reports, compliance certifications, and other
      7. allowances listed in Appendix F, Column 9, and a pro-
      8. rata share of any NOx allowances remaining after the
  1. a. For this source, this segment of the CAAPP Permit, i.e.,
      1. c. No provision of this Budget Permit or the associated
      2. f. The Permittee, or other owner or operator of the source,
      3. a. The "affected turbines" for the purpose of these unit-
      4. ii. The emission of smoke or other particulate matter
      5. f. Startup Provisions
      6. This authorization does not relieve the Permittee
      7. I. Operating in accordance with the
      8. II. Maintaining units in accordance with
      9. g. Malfunction and Breakdown Provisions
      10. i. This authorization only allows such continued
      11. ii. Upon occurrence of excess emissions due to
      12. v. This authorization does not relieve the Permittee
      13. not use an add-on control device to achieve
      14. Control Requirements and Work Practices
      15. ii. The source owner or operator shall operate the
      16. A. Review of operating parameters of the unit
      17. B. Implementation of inspection and repair
      18. iii. The source owner or operator shall maintain the
      19. B. Repair and routine replacement of emissions-
      20. iv. The above procedures may incorporate the
      21. emissions.
      22. Production and Emission Limitations
      23. annual limitations:
      24. B. Unless an alternative factor is established for
      25. determining compliance with the annual emission
      26. ii. Any extension to these time periods that may be
      27. testing of emissions:
      28. Po =observed combustor inlet absolute
    1. analysis and their experience with similar tests.
      1. iii. The specific determinations of emissions that are
      2. i. A summary of results.
      3. ii. General information.
      4. iii. Description of test method{s), including description
      5. of sampling points, sampling train, analysis
      6. iv. Detailed description of test conditions, including:
    2. iii. The duration of opacity observations for each test
      1. iv. The source owner or operator shall notify the
      2. v. The source owner or operator shall promptly notify
      3. vi. The source owner or operator shall provide a copy of
      4. vii. The source owner or operator shall submit a written
      5. D. Description of observation conditions.
      6. E. Description of turbine operating conditions.
      7. H. Conclusions.
      8. ii. If an affected turbine is not routinelY operated or
      9. b. The source owner or operator shall maintain records of the
      10. following items:
      11. iii. Copies of opacity determinations taken for the source
      12. v. Information for the formal observations of opacity
      13. c. A maintenance and repair log for the affected turbine,
      14. j. The source owner or operator shall maintain records that
      15. i. Any periods during which a continuous monitoring
      16. system was not operational, with explanation.
      17. ii. Any period when the affected turbine was in operation
      18. operating practices for each turbine.
      19. E:sr:mal s}?aeity Jaas Beon s13serveEl: BY SSHree perssBscl.
      20. Ei. .m cJE-;t31anatisE: 'V.tf:ly esta:131isaea startup
      21. F. ':Pac Batura s£ G}?aeity fellauin§' the cBa af
      22. i. !Pao fells",Jill§, iafermatisa fer aaaa SEart1d:p af tae
      23. A. Date ana auratisB 8f tae startup, i.e., start
      24. time aBel time BoflFtal o}?cratisE: aehievea.
      25. F. WhetHer s}?eratia§ }?orssnHol fsr the tldr13ines sr
      26. iv. The measures used to reduce the quantity of emissions
      27. v. The steps taken to prevent similar malfunctions or
      28. breakdowns or reduce their frequency and severity.
      29. a. Reporting of Deviations
      30. Emissions from the affected turbine in excess of the
      31. B. Upon achievement of compliance, the Permittee
      32. ii. In accordance with the due dates in Condition 8.6.1,
      33. A. A listing of malfunctions and breakdowns, in
      34. chronological order, that includes:
      35. incident.
      36. involved in the incident.
      37. a. Compliance with the PM emission limitations of Conditions
      38. ii. Compliance with the 802 emission limitations of
      39. Turbine That Drives
      40. e. startup Provisions
      41. i. This authorization does not relieve the Permittee
      42. I. Operating in accordance with the
      43. II. Maintaining units in accordance with
      44. f. Malfunction and Breakdown Provisions
      45. i. This authorization only allows such continued
      46. ii. Upon occurrence of excess emissions due to
      47. v. This authorization does not relieve the Permittee
      48. not use an add-on control device to achieve
      49. Production and Emission Limitations
      50. testing of emissions:
      51. Po =observed combustor inlet absolute
    3. analysis and their experience with similar tests.
      1. iii. The specific determinations of emissions that are
      2. i. A summary of results.
      3. ii. General information.
      4. iii. Description of test method(s), including description
      5. of sampling points, sampling train, analysis
      6. iv. Detailed description of test conditions, including:
    4. iii. The duration of opacity observations for each test
      1. iv. The source owner or operator shall notify the
      2. vi. The source owner or operator shall provide a copy of
      3. vii. The source owner or operator shall submit a written
      4. C. _Copy of current certification.
      5. D. Description of observation conditions.
      6. E. Description of turbine operating conditions.
      7. H. Conclusions.
      8. b. The source owner or operator shall maintain records of the
      9. iii. Copies of opacity determinations taken for the source
      10. v. Information for the formal observations of opacity
      11. c. A maintenance and repair log for the affected turbine,
      12. turbine.
      13. turbine.
      14. j. The source owner or operator shall maintain records that
      15. i. Any periods during which a continuous monitoring
      16. system was not operational, with explanation.
      17. operating practices for each turbine.
      18. B. :gate aHa 91:lratisFl: sf aseve Flannal epaeity,
      19. i. ';PHe feller,dB§, iFlfsrmation fer eaea s'Ear'Eu13 of tao
      20. A. Da'EC aHa aura'Eisn ef tao startup, i.e., start
      21. iv. The measures used to reduce the quantity of emissions
      22. breakdowns or reduce their frequency and severity.
      23. a. Reporting of Deviations
      24. i. Emissions from the affected turbine in excess of the
      25. regional office by telephone as soon as
      26. B. Upon achievement of compliance, the Permittee
      27. ii. In accordance with the due dates in Condition 8.6.1,
      28. A. A listing of malfunctions and breakdowns, in
      29. incident.
      30. involved in the incident.
      31. to provide to the notices and reports of
      32. E. If there have been nO such incidents during the
      33. a. Compliance with the PM emission limitations of Conditions
      34. systems to control NOx emissions. The turbines were constructed
      35. f. Startup Provisions
      36. i. This authorization does not relieve the permittee
      37. I. Operating in accordance with the
      38. II. Maintaining units in accordance with
      39. g. Malfunction and Breakdown Provisions
      40. i. This authorization only allows such continued
      41. ii. Upon occurrence of excess emissions due to
      42. v. This authorization does not relieve the Permittee
      43. not use an add-on control device to achieve
      44. Control Requirements and Work Practices
      45. The source owner or operator shall operate the
      46. A. Review of operating parameters of the unit
      47. B. Implementation of inspection and repair
      48. iii. The source owner or operator shall maintain the
      49. B. Repair and routine replacement of emissions-
      50. iv. The above procedures may incorporate the
      51. and maintained with dry low NOx combustors to control
      52. Production and Emission Limitations
      53. For NOx t for which continuous monitoring is performed, the
      54. i. Emissions of NOx shall be determined by continuous
      55. ii. Emissions shall be determined from emission factors
      56. testing of emissions:
    5. analysis and their experience with similar tests.
      1. ii. The specific conditions under which testing shall be
      2. iii. The specific determinations of emissions that are
      3. i. A summary of results.
      4. ii. General information.
      5. iii. Description of test method(s), including description
      6. of sampling points, sampling train, analysis
      7. iv. Detailed description of test conditions, including:
    6. iii. The duration of opacity observations for each test
      1. iv. The source owner or operator shall notify the
      2. vi. The source owner or operator shall provide a copy of
      3. vii. The source owner or operator shall submit a written
      4. C. Copy of current certification.
      5. D. Description of observation conditions.
      6. E. Description of turbine operating conditions.
      7. H. Conclusions.
      8. b. The source owner or operator shall maintain records of the
      9. iii. Copies of opacity determinations taken for the source
      10. v. Information for the formal observations of opacity
      11. c. A maintenance and repair log for the affected turbine,
      12. turbine.
      13. i. Emissions of each pollutant from the affected turbine,
      14. The source owner or operator shall maintain records that
      15. i. Any periods during which a continuous monitoring
      16. system was not operational, with explanation.
    7. El1:1riE:§J ,,;aiaa iae fs§" 1: ... ao aeemea to Be a traffic
      1. operating practices for each turbine.
      2. performcEl. e per ermea, if not
      3. tae startup, i.c., st:art speratisE: aohieved.
      4. D. .."':.:Fl c3Et31aBatisa "iB.:t" ERe preeeEiures af 7.3.3(fJ
      5. F. Whether eperatiag persGHflol fer tao t1:lrsiaos sr
      6. A maiatoaaEce ana repair leg fer each affeetea
      7. iv. The measures used to reduce the quantity of emissions
      8. breakdowns or reduce their frequency and severity.
      9. a. Reporting of Deviations
      10. i. Emissions from the affected turbine in excess of the
      11. ii. Operation of the affected turbine in excess of the
      12. November 30 of each year, the source owner or
      13. B. Upon achievement of compliance, the Permittee
      14. ii. In accordance with the due dates in Condition 8.6.1,
      15. A. A listing of malfunctions and breakdowns, in
      16. chronological order, that includes:
      17. incident.
      18. involved in the incident.
      19. to provide to the notices and reports of
      20. the reporting period.
      21. a. Compliance with the PM emission limitations of Conditions
      22. b. Compliance with the S02 emission limitations of Conditions
      23. emission limitations of
      24. Bmissisa
      25. ii. 'PRe cmissiofl of sme](c or staer l?artieulate matter
  2. S1:l13Flart I7
      1. ssary . RCEfl;liremeat.s BccessarJ' to
      2. Coatrel RCEfI:liremcHts aHa t"7erk Practices
      3. B. Distillate fuel oil shall se tao ealy fuel fir-eEl ia tao
      4. affccteEl sieGel cEgiacs.
      5. stores. at tHe sourec.
    1. iii. ';Phc auratisa sf s}?aGity oBserv'atioHs fsr caGa test
      1. A. Bato ane time ef testis§,.
    2. C. Ce}?y ef Old:rrent certificatien.
      1. ceaeitieas.
      2. c. Opacity eoteHRiaatieas.
      3. as latey
      4. aftey
      5. a rOEJUcst fer SliCH a samElle is maec BY tae
      6. HOFlthly anel anr:R:ial reeares of BSldrs af
  3. iii.
      1. FHcl usage fer tho a ff catca Eliesel engines.
      2. CH§flFlCS, gallsBs/moE:1::l:l aBa galleRs/year.
      3. . lance DnlE of E1cniat=:' f ., ulr
    1. cB§"iE:es iE: eHcess of tae limiEs specifiee ia
      1. ii. OperatioB of the affoetea aiosol eBgieos in
      2. ii. For tRis parpose, complete oORvorsioE of s1:l1f1:lr iEto
      3. ii. Emissien factors fer the affeeteEl engines greater
      4. Changes Requiring Prior Notification
      5. Emissions will not exceed the emissions allowed under this
      6. iv. Provide emission calculations which demonstrate that
      7. Test Notifications
      8. and their experience with similar tests;
      9. c. The specific conditions under which testing will be
      10. d. The specific determinations of emissions and operation that
      11. are intended to be made, including sampling and monitoring locations;
      12. analyses;
      13. analyses including sample calculations:
      14. h. The name of any relevant observers present including the
      15. a. Unless otherwise specified in the particular provision of
      16. Illinois Environmental Protection Agency Bureau of Air
      17. CERTIFICATE OF SERVICE
EXHIBIT 2
REDLIEND VERSION OF THE PERMIT
THROUGH SECTION 8
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
217/782-2113
"RENEWAL"
CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT
PERMITTEE:
union Electric Company, d/b/a AmerenUE
Attn: Michael L. Menne, Vice President Environmental Services
1901 Chouteau Avenue
P.O. Box 66149, MC 602
St. Louis, Missouri 63166-6149
I.D. No.:
119105AAA
Application No.:
95090017
Date Received:
May 24, 2006
Date Issued: March 19, 2009
Expiration Date
'
:
March 19, 2014
Operation of:
Ameren UE Venice Power Plant
Source Location:
701 Main Street, Venice, Madison County, 62090
Responsible Official:
Michael L. Menne, Vice President Environmental
Services
This permit is hereby granted to the above-designated Permittee to OPERATE an
electric utility, pursuant to the above referenced permit application. This
permit is subject to the conditions contained herein.
If you have any questions concerning this permit, please contact John Cashman
at 217/782-2113.
Edwin C. Bakowski, P.E.
Manager, Permit Section
Division of Air Pollution Control
ECB:JRC:psj
cc:
Illinois EPA, FOS, Region 3
CES
Lotus Notes
Except as provided in Conditions 1.5 and 8.7 of this permit.
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
1.0
2.0
3.0
4.0
5.0
6.0
7.0
TABLE OF CONTENTS
INTRODUCTION
1.1
Source Identification
1.2
Owner/Parent Company
1. 3
Operator
1.4
Source Description
1.5
Title I Conditions
LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED
CONDITIONS FOR INSIGNIFICANT ACTIVITIES
3.1
Identification of Insignificant Activities
3.2
Compliance with Applicable Requirements
3.3
Addition of Insignificant Activities
SIGNIFICANT EMISSION UNITS AT THIS SOURCE
OVERALL SOURCE CONDITIONS
5.1
Applicability of Clean Air Act Permit Program (CAAPP)
5.2
Area Designation
5.3
Source-Wide Applicable Provisions and Regulations
5.4
Source-Wide Non-Applicability of Regulations of Concern
5.5
Source-Wide Control Requirements and Work Practices
5.6
Source-Wide Production and Emission Limitations
5.7
Source-Wide Testing Requirements
5.8
Source-Wide Monitoring Requirements
5.9
Source-Wide Recordkeeping Requirements
5.10 Source-Wide Reporting Requirements
5.11 Source-Wide Operational Flexibility/Anticipated Operating
Scenarios
5.12
Source-Wide Compliance Procedures
CONDITIONS FOR EMISSIONS CONTROL PROGRAMS
6.1
Clean Air Interstate Rule (CAIR) Program
6 . 2
Acid Rain
6.3
NO
x
Trading Program - Existing budget EGU
UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS
7.1
Turbine CT02 (Subject to NSPS - 40 CFR Subpart GG)
7.2
Turbine CT01
7.3
Turbines CT03-CT05 (Subject to NSPS - 40 CFR Subpart GG)
7.4
Engines (Subject to NESHAP - 40 CFR 63 Subpart ZZZZ)
2
4
6
7
9
10
17
31
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
8.0
9.0
GENERAL PERMIT CONDITIONS
8.1
Permit Shield
8.2
Applicability of Title IV Requirements
8.3
Emissions Trading Programs
8.4
Operational Flexibility/Anticipated Operating Scenarios
8.5
Testing Procedures
8.6
Reporting Requirements
8.7
Title I Conditions
STANDARD PERMIT CONDITIONS
9.1
9.2
9.3
9.4
9.5
9.6
9.7
9.8
9.9
9.10
9.11
9.12
9.13
9.14
9.15
Effect of Permit
General Obligations of Permittee
Obligation to Allow Illinois EPA Surveillance
Obligation to Comply with Other Requirements
Liability
Recordkeeping
Annual Emissions Report
Requirements for Compliance Certification
Certification
Defense to Enforcement Actions
Permanent Shutdown
Reopening and Reissuing Permit for Cause
Severability Clause
Permit Expiration and Renewal
General Authority for the Terms and Conditions of this
Permit
10.0
ATTACHMENTS
1
2
3
4
5
6
Example Certification by a Responsible Official
Emissions of Particulate Matter from Process Emission
Units
Compliance Assurance Monitoring (CAM) Plan
Guidance
CAIR Permit
Acid Rain Permit
3
114
119
1-1
2-1
3-1
4-1
5-1
6-1
1.0
INTRODUCTION
1.1
Source Identification
AmerenUE Venice Power Plant
701 Main Street
Venice, Illinois 62090
314/992-8032
I.D. No.:
119105AAA
County: Madison
Standard Industrial Classification: 4911, Electric Utility
1.2
Owner/Parent Company
union Electric Company, d/b/a AmerenUE
1901 Chouteau Avenue
P.O. Box 66149, MC 602
St. Louis, Missouri 63166-6149
1. 3
Operator
union Electric Company, d/b/a AmerenUE
1901 Chouteau Avenue
P.O. Box 66149, MC 602
St. Louis, Missouri 63166-6149
Steven C. Whitworth
314/554-4908
1.4
Source Description
The Venice Power Plant is located at 701 Main Street in Venice,
Illinois; Madison County. The plant currently operates natural gas-
fired and oil-fired combustion turbines to generate electricity. The
plant previously operated eight natural gas and oil-fired boilers to
generate electric power but they have been permanently shut down.
Note: This narrative description is for informational purposes only
and is not enforceable.
1.5
Title I Conditions
As generally identified below, this CAAPP permit contains certain
conditions for emission units at this source that address the
applicability of permitting programs for the construction and
modification of sources, which programs were established pursuant to
Title I of the Clean Air Act (CAA) and regulations thereunder. These
programs include PSD and MSSCAM, and are implemented by the Illinois
EPA pursuant to Sections 9, 9.1, 39(a) and 39.5(7) (a) of the Illinois
Environmental Protection Act (Act). These conditions continue in
effect, notwithstanding the expiration date specified on the first page
of this permit, as their authority derives from Titles I and V of the
CAA, as well as Titles II and X of the Act.
(See also Condition 8.7.)
4
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
a.
This permit contains Title I conditions that reflect Title I
requirements established in permits previously issued for this
source, which conditions are specifically designated as
~Tl".
5
2.0
LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED
ACMA
Alternative Compliance Market Account
Act
Illinois
Environmental Protection Act
[415 ILCS 5/1 et seq.]
AP-42
Compilation of Air Pollutant Emission Factors,
Volume
1,
Stationary Point and Other Sources
(and Supplements A
through F), USEPA, Office of Air Quality Planning and
Standards,
Research Triangle Park,
NC
27711
ATU
Allotment Trading Unit
BACT
Best Available Control Technology
BAT
Best Available Technology
CAA
Clean Air Act [42 U.S.C.
Section
7401 et
seq.]
CAAPP
Clean Air Act
Permit
Program
CAM
Compliance Assurance Monitoring
CEMS
Continuous Emission Monitoring System
CFR
Code of
Federal Regulations
CO
Carbon Monoxide
ERMS
Emissions Reduction Market
System
HAP
Hazardous Air Pollutant
lAC
Illinois Administrative Code
LD. No.
Identification Number of
Source, assigned
by Illinois EPA
ILCS
Illinois Compiled Statutes
Illinois EPA Illinois
Environmental
Protection Agency
LAER
Lowest Achievable Emission Rate
MACT
Maximum Achievable Control Technology
MSSCAM
Major Stationary Sources Construction
and Modification. (35
lAC 203,
New Source Review for non-attainment areas)
NESHAP
National
Emission Standards for Hazardous
Air Pollutants
NO,
Nitrogen Oxides
NSPS
New Source Performance Standards
PM
Particulate Matter
PM
10
Particulate matter with an aerodynamic diameter less
than or
equal
to a nominal 10 microns as measured by applicable test
or monitoring methods
PM
2
.
5
Particulate matter with an aerodynamic diameter less
than or
equal to
a nominal 2.5 microns
as measured by applicable
test
or monitoring methods
PSD
Prevention of Significant Deterioration
(40 CFR 52.21,
New
Source Review for attainment areas)
RMP
Risk Management
Plan
SO,
Sulfur Dioxide
T1
Title I
-
identifies
Title I
conditions
that have been
carried over
from an existing permit
T1N
Title I New - identifies Title I
conditions
that are being
established in this permit
T1R
Title
I Revised
identifies
Title
I
conditions
that have
been carried over from an existing
permit and subsequently
revised in this permit
USEPA
United States
Environmental
Protection Agency
VOM
Volatile Organic Material
6
3.0
CONDI~IONS
FOR INSIGNIFICANT
AC~IVI~IES
3.1
Identification of Insignificant Activities
The following activities at the source constitute insignificant
activities as specified in 35 lAC 201.210:
3.1.1 Activities determined by the Illinois EPA to be insignificant
activities, pursuant to 35 lAC 201.210(a) (1) and 201.211, as
follows:
3.1.2
3.1.3
Natural Gas Heaters
<
10.0 rnrnBtu/hr
Activities that are insignificant activities based upon maximum
emissions, pursuant to 35 lAC 201.210(a) (2) or (a) (3), as
follows:
None
Activities that are insignificant activities based upon their
type or character, pursuant to 35 lAC 201.210(a) (4) through
(18), as follows:
Storage tanks of any size containing virgin or re-refined
distillate oil, hydrocarbon condensate from natural gas pipeline
or storage systems, lubricating oil, or residual fuel oils (35
lAC 201.210 (a) (11) J •
Gas turbines and stationary reciprocating internal combustion
engines of between 112 kWand 1,118 kW (150 and 1,500
horsepower) power output that are emergency or standby units
[35 lAC 201.210(a) (16) J.
3.1.4 Activities that are considered insignificant activities pursuant
to 35 lAC 201.210(b). Note: These activities are not required
to be individually listed.
3.2
Compliance with Applicable Requirements
Insignificant activities are subject to applicable r.equirements
notwithstanding status as insignificant activities. In particular, in
addition to regulations of general applicability, such as 35 lAC
212.301 and 212.123 (Condition 5.3.2), the Permittee shall comply with
the following requirements, as applicable:
3.2.1
For each particulate ma,tter process emission unit, the Permittee
shall comply with the applicable particulate matter emission
limit of 35 lAC 212.321 or 212.322 (see Attachment 2) and 35 lAC
Part 266. For example, the particulate matter emissions from a
process emission unit shall not exceed 0.55 pounds per hour if
the emission unit's process weight rate is 100 pounds per hour
or less, pursuant to 35 lAC 266.110.
7
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
3.2.2
For each organic material emission unit that uses organic
material, e.g., a mixer or printing line, the Permittee shall
comply with the applicable VOM emission limit of 35 lAC 219.301,
which requires that organic material emissions not exceed 8.0
pounds per hour or, if no odor nuisance exists, do not qualify
as photochemically reactive material as defined in 35 lAC
211.4690.
3.2.3
For each open burning activity, the Permittee shall comply with
35 lAC Part 237, including the requirement to obtain a permit
for open burning in accordance with 35 lAC 237.201, if
necessary.
3.2.4
For each cold cleaning degreaser, the Permittee shall comply
with the applicable equipment and operating requirements of 35
lAC 219.182.
3.3
Addition of Insignificant Activities
3.3.1 The Permittee is not required to notify the Illinois EPA of
additional insignificant activities present at the source of
a
type that is identified in Condition 3.1, until the renewal
application for this permit is submitted, pursuant to 35 lAC
201.212(a) .
3.3.2
3.3.3
The Permittee must notify the Illinois EPA of any proposed
addition of a new insignificant activity of a type addressed by
35 lAC 201.210(a) and 201.211 other than those identified in
Condition 3.1, pursuant to Section 39.5(12) (b) of the Act.
The Permittee is not required to notify the Illinois EPA of
additional insignificant activities present at the source of
a
type identified in 35 lAC 201.210(b).
8
4.0
SIGNIFICANT EMISSION UNITS AT THIS SOURCE
Emission
Emission
Date
Control
Unit
Description
Constructed
Equipment
CT02
Twin Pac Natural
Gas
2002
Water
Fired Turbine with
Injection
Distillate Oil
as Back-Up
Fuel (Nominal Capacity 60
MWe)
CT01
Stationary Gas
Turbine
1967
None
That Drives a Generator
(Nominal Capacity 518
rnrnBtu/hr)
CT03 and
212
MWe Natural Gas
Fired
CT03
(May
Low NO
x
CT04
Turbine,
each
28, 2005) ,
Combustor
CT04 (May
System
24,
2005)
CT05
135 MWe
Natural
Gas
Fired
September
Low NO
x
Turbine
29, 2005
Combustor
System
Fi:FC
P"'"!l
:9iesc±
Fire Pl::lfRi?
=
NeH-e
Emer§fcacy
EmergcFlcy Diesel
=
NeH-e
€iCf.l:Cra:e8F
Geaerater
9
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
5.0
OVERALL SOURCE
COND~T~ONS
5.1
Applicability of Clean Air Act Permit Program (CAAPP)
5.1.1
This permit is issued based on the source requiring a CAAPP
permit as a major source of NO
x
and CO emissions.
5.2
Area Designation
This permit is issued based on the source being located in an area
that, as of the date of permit issuance, is designated nonattainment
for the Nation",l Ambient Air Quality Standards for ozone and PM,., and
attainment or unclassifiable for all other criteria pollutants (CO,
lead,
N0
21
PM10t and 50
2
) •
5.3
Source-Wide Applicable Provisions and Regulations
5.3.1
5.3.2
5.3.3
Specific emission units at this source are subject to particular
regulations as set forth in Section 7 (Unit-Specific Conditions
for Specific Emission Units) of this permit.
In addition, emission units at this source are subject to the
following regulations of general applicability:
a.
No person shall cause or allow the emission of fugitive
particulate matter from any
process
I
including any material
handling or storage activity, that is visible
by
an
observer looking generally overhead at a point beyond the
property __ line of the source unless the wind speed is
greater than 40.2 kilometers per hour (25 miles per hour),
pursuant to 35 lAC 212.301 and 212.314.
b.
Pursuant to 35 lAC 212.123(a), no person shall cause or
allow the emission of smoke or other particulate matter,
with an opacity greater than 30 percent, into the
atmosphere from any emission unit other than those emission
units subject to the requirements of 35 lAC 212.122, except
as allowed by 35 lAC 212.123(b) and 212.124.
Ozone Depleting Substances
The Permittee shall comply with the standards for recycling and
emissions reduction of ozone depleting substances pursuant to 40
CFR Part 82, Subpart F, except as provided for motor vehicle air
conditioners in Subpart B of 40 CFR Part 82:
a.
Persons opening appliances for maintenance, service,
repair, or disposal must comply with the required practices
pursuant to 40 CFR 82.156.
b.
Equipment used during the maintenance, service, repair, or
disposal of appliances must comply with the standards for
recycling and recovery equipment"pursuant to 40 CFR 82.158.
10
5.3.4
5.3.5
5.3.6
c.
Persons performing maintenance, service, repair, or
disposal of appliances must be certified by an approved
technician certification program pursuant to 40 CFR 82.161.
Risk Management Plan (RMP)
Should this stationary source, as defined in 40 CFR 68.3, become
subject to the federal regulations for Chemical Accident
Prevention in 40 CFR Part 68, then the owner or operator shall
submit the items below. This condition is imposed in this
permit pursuant to 40 CFR 68.215(a) (2) (i) and (ii).
a.
A compliance schedule for meeting the requirements of 40
CFR Part 68 by the date provided in 40 CFR 68.10(a); or
b.
A certification statement that the source is in compliance
with all requirements of 40 CFR Part 68, including the
registration and submission of the RMP, as part of the
annual compliance certification required by Condition 9.8.
Future Emission Standards
a.
Should this stationary source become subject to a new or
revised regulation under 40 CFR Parts 60, 61, 62, or 63, or
35 lAC Subtitle B after the date issued of this permit,
then the owner or operator shall, in accordance with the
applicable regulation(s), comply with the applicable
requirements by the date(s) specified and shall certify
compliance with the applicable requirements of such
regulation(s) as part of the annual compliance
certification, as required by Condition 9.8. This permit
may also have to be revised or reopened to address such new
or revised regulations (see Condition 9.12.2).
b.
This permit and the terms and conditions herein do not
affect the Permittee's past and/or continuing obligation
with respect to statutory or regulatory requirements
governing major source construction or modification under
Title I of the CAA. Further, neither the issuance of this
permit nor any of the terms or conditions of the permit
shall alter or affect the liability of the Permittee for
any violation of applicable requirements prior to or at the
time of permit issuance.
Episode Action Plan
a.
Pursuant to 35 IAC 244.141, 244.142, and 244.143, the
Permittee shall maintain at the source and have on file
with the Illinois EPA a written episode action plan (plan)
for reducing the levels of emissions during yellow alerts,
red alerts, and emergencies, consistent with safe operating
procedures. The plan shall contain the information
specified in 35 lAC 244.144 and is incorporated by
reference into this permit.
11
b.
The Permittee shall immediately implement the appropriate
steps described in this plan should an air pollution alert
or emergency be declared by the Director of the Illinois
EPA or his or her designated representative.
c.
If an operational change occurs at the source which
invalidates the plan, a revised plan shall be submitted to
the Illinois EPA for review within 30 days of the change,
pursuant to 35 lAC 244.143(d). Such plans shall be further
revised if disapproved by the Illinois EPA.
5.4
Source-Wide Non-Applicability of Regulations of Concern
Source-wide non-applicability of regulations of concern are not set for
this source. However, there are terms for unit specific non-
applicability of regulations of concern set forth in Section 7 of this
permit.
5.5
Source-Wide Control Requirements and Work Practices
Source-wide control requirements and work practices are not set for
this source. However, there are requirements for unit specific control
requirements and work practices set forth in Section 7 of this permit.
5.6
Source-Wide Production and Emission Limitations
5.6.1
5.6.2
Permitted Emissions for Fees
The annual emissions from the source, not considering
insignificant activities as addressed by Section 3.0 of this
permit, shall not exceed the following limitations. The overall
source emissions shall be determined by adding emissions from
all emission units. Compliance with these limits shall be
determined on a calendar year basis. These limitations
(Condition 5.6.1) are set for the purpose of establishing fees
and are not federally enforceable (see Section 39.5(18) of the
Act) .
Permitted Emissions of Regulated Pollutants
Pollutant
Tons/Year
Volatile Organic Material
(VOM)
32.8
Sulfur Dioxide
(SO,)
102.1
Particulate Matter (PM)
35.3
Nitrogen
Oxides
(NO
x
)
372.0
HAP,
not included in VOM
or PM
----
Total
542.2
Bmissioas of IIa:z;aE8:0US IdE PelluEaHEs
PUEsuaaE to SootieR
~9.
§ (7) (a) of tne
l' ..
ot, tne emissioas of IIAPs
frem the seblree shall Be less thaa 19 teas/year fer eaeh
iaaiviablal HAP aaa 2. teas/year fer all HAPs eemlaiaea as limitea
12
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
5.6.3
iF.l: CsastFl:1etisB Permit
G312GGeB.
Cemplianoe
",..ita
aflF.l:1:lal limits
shall Be eetermiaee aR a maRthly Basis fram the SBffi af the eata
far tHe eHrreRt maRth
~lHs
the
~reeeeiRg
11 maRths (rHRRiag 12
maRth tatal).
~his
eaaeitiaR is seiRg
i~asee
S9 that the
Gourse is net a maj sr SGl:lroo sf IIF .. P emissisas.
'Pae
Permittee
shall fHlfill the
a~~lieaBle
testiRg,
reear~,e~iag,
aRe
r~srtiRg
re"",iremeats sf CsneitiaRs 9.7.2, 9.9.2, ane 9.H.2.
Other Source-Wide Production and Emission Limitations
Other source-wide emission limitations are not set for this
source pursuant to the federal rules for
PSD
1
state rules for
MSSCAM, or Section 502(b) (10) of the CAA.
However, there may be
unit specific emission limitations set forth in Section 7 of
this permit pursuant to these rules.
5.7
Source-Wide Testing Requirements
5.7.1
Pursuant to 35 lAC 201.282 and Section 4(b) of the Act, every
emission source or air pollution control equipment shall be
subject to the following testing requirements for the purpose of
determining the nature and quantities of specified air
contaminant emissions and for the purpose of determining ground
level and ambient air concentrations of such air contaminants:
a.
Testing by Owner or Operator: The Illinois EPA may require
the owner or operator of the emission source or air
pollution control equipment to conduct such tests in
~accQ:r:d",nce
withproc",dures adopt",d by the Illinois EPA, at
such reasonable times as may be specified by the Illinois
EPA and at the expense of the owner or operator of the
emission source or air pollution control equipment. All
such tests shall be made by or under the direction of a
person qualified by training and/or experience in the field
of air pollution testing. The Illinois EPA shall have the
right to observe all aspects of such tests [35 lAC
201.282 (a)].
b.
Testing by the Illinois EPA: The Illinois EPA shall have
the right to conduct such tests at any time at its own
expense. Upon request of the Illinois EPA, the owner or
operator of the emission source or air pollution control
equipment shall provide, without charge to the Illinois
EPA, necessary holes in stacks or ducts and other safe and
proper testing facilities, including scaffolding, but
excluding instruments and sensing devices, as may be
necessary [35 lAC 201.282(b)].
c.
Any such tests are also subject to the Testing Procedures
of Condition 8.5 set forth in the General Permit Conditions
of Section 8.
13
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
9.7.2
HAP '3:'estiFl§" te Verify BiHer Seuree Seatl:lS
P1:l:rSl-laHt te CeFlaitieB 9.7.1 ana Ee verify oeFf\i?liaaoe 'oliER tae
re~ireffients
ef Csaaitiea 5.6.2, tHat is EHat tHis seuree is Het
a Rlaj er seuree ef HAPs, ERe feller.dB§" testiH§
re~iremeREs
are
eSl:alalisaeeL
a.
If iB tRe I3revieus ealeaaar year, emissioas ef HAPs
eJ(oeeaee 89% ef maj er seuree tl=:l:3:=esaela fer iaaivielual er
I:sl:al HAPs ("real:er I:aaa 8 I:sas sf a siB"le HAP sr "real:er
I:aaa 29 I:SBS sf I:sl:al HAPS), l:aeR I:esl:ia" fsr HAPs saaH lae
esaEluel:ea as fslls;lS.
i.
'3:'estiB§ shall lae eeneluetea USiB§" metaeas that 1deula
lae aeeeEll:alale ,maer I:ae feaeral Nal:isaal Ernissisas
Stanaaras fer IIa;z;araeus
~"dr
PellutaREs fer Statisaary
Csmla~sl:isa
Tarlaiaes,
49 CFR 63
S~laElarl:
YYYY.
SEleeifieally, I:ae I:esl:ia" Elreeea»res ael:ailea al: 49
CFR 63.6129 ef tae I3erfermaaee tesES seotiea shall Be
usee.
Fer mHltiI31e turBines, tao seuree
e~ffier
sr
sEleral:sr saall I:esl: lar"esl: I:»rlaiae .,ffiiea makes I:ae
lar"esl:
eSRl:rila~l:isas
I:s iRaiviElual aRa I:sl:al HAP
emissisas.
b.
'3:'Re ealoulatien as Ee 'io:hetRer ERe 8Q% sf maj er seuree
taresasla ;:as elEeeeaea eaall lae laasea SR reesras aaa
Elrseea~res
ia Ceaaitiea 5.9.2 aRa sftall lae eS!flJ:lletea lay
January 31 fer ERe I3rO"Jieus oaleaaar year.
If testiE:§ is
re'f"irea il: sftall lae esmElletea lay SeEll:emlaer 39.
C.
.'l\.oE:Jr such tests are aloe Sl::H3j cot te tae '3:'estin§" Preoea1:lros
sf CeRaitisR 8.5 set fsrtft iR tfte CeReral Permit Csaaitisas
ef SootisR B.
5.8
Source-Wide Monitoring Requirements
Source-wide monitoring requirements are not set for this source.
However, there are provisions for unit specific monitoring set forth in
Section 7 of this permit.
5.9
Source-Wide Recordkeeping Requirements
5.9.1
5.9.2
Annual Emission Records
The Permittee shall maintain records of total annual emissions
on a calendar year basis for the emission units covered by
Section 7 (Unit Specific Conditions for Specific Emission Units)
of this permit to demonstrate compliance with Condition 5.6.1,
pursuant to Section 39.5(7) (b) of the Act.
Reesras fer HAP Bmissieas
a.
Tfte Permittee sftall maiRtaiR reesras sf iRaiviElual aaa
oSm£liaea IIAP omissisns sa a msathly ana aBf.I:1:lal Basis fer
14
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
5.9.3
tae emissioR uBits eO'le.-ee 13y SeetioR 7 WRit Slileeifie
Consitioas fer
S~ecifie
EmissisB Units) of thio
~ermit
to
aCFROHS'Erate
oempliaace
",Jita
Conait::ioFl:
s. e.
2
I
I3urs1:1aat
te
SeetioR 39.3 (7) (13) of tae Aet.
13.
If testiRg is .-eEf\±i.-ee 13y CSReil;ioR 3.7. rl, tae PeHftittee
saall keOJil reeores of tae testiRg, iRelueiRg tae test eate,
coaeitisHS
t
metaoaelo§ies, ealoHlatioR6, test results, aHd
any Eiiser0f3anoies 13et'docE: the tOSE resl;llts anEl ferFflUlatioa
slileeifieatioRs of COBeitl0R §. 9.rl (e) 13elo".
e.
'rae PeHftittee saall keOJil a .-eeore of tae alillillieallility
determinatioN for 49 CFR
e~,
81:3:l3part
TIYY,
Na1::ioaal
Bmissioa Stanaaras fer IIa:z:;ares1:lS Air Pollutants for
Statisnary ComBustion
~UrBineS,
at the source fer a ;t3oriod
of fiyo years after the eetermiaatiofl.
'finis aet03:"miFlatioB
shall iBeluee a eetailee aBalysis that eemsRstrates
,~.
tae
permittee l301icEos tho souree is Bet sUBject te 4Q CFR 6"3,
81:l13}?art yy'{y.
Retention and Availability of Records
a.
All records and logs required by this permit shall be retained
for at least five years from the date of entry (unless a
longer retention period is specified by the particular
recordkeeping provision herein), shall be kept at a location
at the source that is readily accessible to the Illinois EPA
or USEPA, and shall be made available for inspection and
copying by the Illinois EPA or USEPA upon request.
b.
The Permittee shall retrieve and print, on paper during
normal source office hours, any records retained in an
electronic format (e.g., computer) in response to an
Illinois EPA or USEPA request for records during the course
of a source inspection.
5.10 Source-Wide Reporting Requirements
5.10.1 General Source-Wide Reporting Requirements
The Permittee shall promptly notify the Illinois EPA, Air
Compliance Unit, of deviations of the source with the permit
requirements within 30 days, pursuant to Section 39.5(7) (f) (ii)
of the Act. Reports shall describe the probable cause of such
deviations, and any corrective actions or preventive measures
taken. There are also reporting requirements for unit specific
emission units set forth in Section 7 of this permit.
5.10.2 Annual Emissions Report
The annual emissions report required pursuant to Condition 9.7
shall contain emissions information for the previous calendar year.
15
5.11 Source-Wide Operational Flexibility/Anticipated Operating Scenarios
Source-wide operational flexibility is not set for this source.
5.12 Source-Wide Compliance Procedures
5.12.1 Procedures for Calculating Emissions
Except as provided in Condition 9.1.3, compliance with the
source-wide emission limits specified in Condition 5.6 shall be
addressed by the recordkeeping and reporting requirements of
Conditions 5.9 and 5.10, and compliance procedures in Section 7
(Unit Specific Conditions for Specific Emission Units) of this
permit.
16
6.0
CONDITIONS FOR EMISSIONS CONTROL PROGRAMS
6.1
Clean Air Interstate Rule (CAIR) Program
6.1.1
6.1.2
6.1.3
Applicability
This source is an affected source for purposes of the Clean Air
Interstate Rule ('CAIR") Program and the following emission
units at the source are affected CAIR units:
Turbines CTOl through CT05
Note: Under Section 110 of the Clean Air Act (CAA) , the USEPA
adopted the Clean Air Interstate Rule or CAIR, 40 CFR Part 96,
to reduce and permanently cap emissions of sulfur dioxide (S02),
and nitrogen oxides (NO
x
)
from electric power plants that
significantly contribute to fine particulate and ozone in the
ambient air in the Eastern United States. To implement CAIR in
Illinois, the Illinois EPA adopted 35 lAC Part 225 Subparts A,
C, D and E. For purposes of this permit, these requirements are
referred to as CAIR provisions.
Applicable CAIR Requirements for SO, Emissions
The owners and operators of this source shall not violate
applicable CAIR provisions, in 35 lAC Part 225, Subpart C. SO,
emissions from the affected CAIR units shall not exceed the
equivalent number of allowances that the source lawfully holds
under these CAIR
proy~_sions.
Note: CArR affected sources must hold CAIR SO, allowances to
account for the emissions from the affected CAIR units. Each
CAIR SO, allowance is a limited authorization to emit during the
respective CAIR SO, annual period or subsequent period. The
possession of 80
2
allowances does not authorize exceedances of
applicable emission standards or violations of ambient air
quality standards.
Applicable CAIR Requirements for NO
x
Emissions
The owners and operators of this source shall not violate
applicable CAIR provisions, in 35 lAC Part 225, Subpart D. NO
x
emissions from the affected CAIR units shall not exceed the
equivalent number of allowances that the source lawfully holds
under these CArR provisions.
Note: CAIR affected sources must hold CAIR NO
x
allowances to
account for the emissions from the affected CAIR units. Each
CAIR NO
x
allowance is a limited authorization to emit during the
respective CArR NO
x
annual period or subsequent period. The
possession of NO
x
allowances does not authorize exceedances of
applicable emission standards or violations of ambient air
quality standards.
17
6.1.4
6.1.5
6.1.6
6.1.7
Applicable CAIR Requirements for NO
x
Ozone Season Emissions
The owners and operators of this source shall not violate
applicable CAIR provisions, in 35 lAC Part 225, Subpart E.
Seasonal NO
x
emissions from the affected CAIR units shall not
exceed the equivalent number of allowances that the source
lawfully holds under these CAIR provisions.
Note: CAIR affected sources must hold CAIR NO
x
ozone season
allowances to account for the emissions from the affected CAIR
units. Each CArR NO
x
ozone season allowance is a limited
authorization to emit during the respective CArR NO
x
ozone
season or subsequent season. The possession of NO
x
allowances
does not authorize exceedances of applicable emission standards
or violations of ambient air quality standards.
Monitoring, Recordkeeping and Reporting
The owners and operators of the source and, to the extent
applicable, their designated representative, shall comply with
applicable requirements for monitoring, recordkeeping and
reporting specified by 35 lAC Part 225 Subparts C, D and E.
Note: As further addressed by Section 7 of this permit, the
following emission determination methods are currently being
used for the affected CAIR units.
CAIR Permit
The owners and operators of the source shall comply with the
terms and conditions of the source's CAIR permit (attached).
Note: This source is subject to a CAIR permit, which was issued
pursuant to 35 lAC Part 225.320, 225.420 and 225.520.CAIR
sources must be operated in compliance with their CAIR permits.
This source's CAIR permit is incorporated into this CAAPP permit
with a copy of the current CAIR permit included as an attachment
to this permit. Revisions and modifications to the CAIR permit
are governed by Section 39.5 of the Act. Accordingly, revision
or renewal of the CAIR permit may be handled separately from
this CAAPP permit and a copy of the new CAIR permit may be
included in this permit by Administrative Amendment.
Coordination with other Requirements
a.
This permit does not contain any conditions that are
intended to interfere with or modify the requirements of 35
lAC Part 225 C, D, and E, 40 CFR Part 96; or Title IV of
the CAA. In particular, this permit does not restrict the
flexibility of the owners and operators of this source to
comply with CAIR provisions, including the ability to
obtain CAIR NO
x
allowances from Illinois' Clean Air Set
Aside (CASA) for qualifying projects.
18
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
b.
Where another applicable requirement of the CAA is more
stringent than an applicable requirement of 35 IAC Part
225, Subparts C, D, or E; 40 CFR Part 96; or Title IV of
the CAA, all requirements are incorporated into this permit
and are enforceable and the owners and operators of the
source shall comply with both requirements.
19
6.2
Acid Rain
6.2.1
6.2.2
6.2.3
6.2.4
Applicability
Under Title IV of the CAA, Acid Deposition Control, this source
is an affected source and the following emission units at the
source are affected units for acid deposition:
Turbines CT01 through CT05
Note: Title IV of the CAA, and other laws and regulations
promulgated thereunder, establish requirements for affected
sources related to control of emissions of pollutants that
contribute to acid rain. For purposes of this permit, these
requirements are referred to as Title IV provisions.
Applicable Emission Requirements
The owners and operators of the source shall not violate
applicable Title IV provisions. SO, emissions of the affected
units shall not exceed any allowances that the source lawfully
holds under Title IV provisions [Section 39.5(7) (g) and (17) (1)
of the Act] .
Note: Affected sources must hold SO, allowances to account for
the S02 emissions from affected units at the source that are
subject to Title IV provisions. Each allowance is a limited
authorization to emit up to one ton of S02 emissions during or
after a specified calendar year. The possession of allowances
does not authorize exceedances of applicable emission standards
or violations of ambient air quality standards.
Monitoring, Recordkeeping and Reporting
The owners and operators of the source and, to the extent
applicable, their designated representative, shall comply with
applicable requirements for monitoring, recordkeeping and
reporting specified by Title IV provisions, including 4D CFR
Part 75 [Section 39.5(7) (b) and 17(m) of the Act].
Acid Rain Permit
The owners and operators of the source shall comply with the
terms and conditions of the source's Acid Rain permit [Section
39.5(17) (1) of the Act].
Note:
The source is subject to an Acid Rain permit, which was
issued pursuant to Title IV provisions, including Section
39.5(17) of the Act. Affected sources must be operated in
compliance with their Acid Rain permits. This source's Acid
Rain permit is incorporated by reference into this permit and a
copy of the current Acid Rain permit is included as Attachment 6
of this permit. Revisions and modifications of this Acid Rain
permit, including administrative amendments and automatic
20
6.2.5
amendments (pursuant to Sections 408(b) and 403(d) of the CAA or
regulations thereunder) are governed by Title IV provisions, as
provided by Section 39.5(13) (e) of the Act. Accordingly,
revision or renewal of the Acid Rain permit may be handled
separately from this CAAPP permit and a copy of the new Acid
Rain permit may be included in this permit by administrative
amendment.
Coordination with Other Requirements
a.
This permit doe$ not contain any conditions that are
intended to interfere with or modify the requirements of
Title IV provisions. In particular, this permit does not
restrict the flexibility under Title IV provisions of the
owners and operators of this source to amend their Acid
Rain compliance plan [Section 39.5(17) (h) of the Act].
b.
Where another applicable requirement of the CAA is more
stringent than an applicable requirement of Title IV
provisions, both requirements are incorporated into this
permit and are enforceable and the owners and operators of
the source shall comply with both requirements [Section
39.5(7) (h) of the Act].
21
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
6.3
NO
x
Trading Program - Existing budget EGU
6.3.1
Description of NO
x
Trading Program
The NO
x
Trading Program is a regional "cap and trade" market
system for large sources of NO
x
emissions in the eastern United
States, including Illinois. It is designed to reduce and
maintain NO
x
emissions from the emission units covered by the
program within a budget to help contribute to attainment and
maintenance of the ozone ambient air quality standard in the
multi-state region covered by .the program, as required by
Section 110(a) (2) (D) of the CAA.
The NO
x
Trading Program
applies in addition to other applicable requirements for NO
x
emissions and in no way relaxes these other requirements.
Electrical generating units (EGU) that are subject to the NO
x
Trading Program are referred to as "budget EGU." Sources that
have one or more EGU or other units subject to the NO
x
Trading
Program are referred to as budget sources.
The NO
x
Trading Program controls NO
x
emissions from budget EGU
and other budget units during a seasonal control period from May
1 through September 30 of each year, when weather conditions are
conducive to formation of ozone in the ambient air.
(In 2004,
the first year that the NO
x
Trading Program is in effect, the
control period will be May 31 through September 30.) By
November 30 of each year, the allowance transfer deadline, each
budget source must hold "NO
x
allowances" for the actual NO
x
emissions of its budget units during the preceding control
period. The USEPA will then retire NO
x
allowances in the
source's accounts in amounts equivalent to its seasonal
emissions. If a source does not have sufficient allowances in
its accounts, USEPA would subtract allowances from the source's
future allocation for the next control period and impose other
penalties as appropriate. Stringent monitoring procedures
developed by USEPA apply to budget units to assure that actual
emissions of NO
x
emissions are accurately determined.
The number of NO
x
allowances available for budget sources is set
by the overall budget for NO
x
emissions established by USEPA.
This budget requires a substantial reduction in NO
x
emissions
from historical levels as necessary to meet air quality goals.
In Illinois, existing budget sources initially receive their
allocation or share of the NO
x
allowances budgeted for EGU in an
amount determined by rule
[35 lAC Part 217, Appendix FJ.
Between 2007 and 2011, the allocation mechanism for existing EGU
gradually shifts to one based on the actual operation of EGU in
preceding control periods. New budget EGU, for which limited
operating data may be available, may obtain NO
x
allowances from
the new source set-aside (NSSA), a portion of the overall budget
reserved for new EGU.
In addition to directly receiving or purchasing NO
x
allowances
as described above, budget sources may transfer NO
x
allowances
22
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
6.3.2
from one of their units to another. They may also purchase
allowances in the marketplace from other sources that are
willing to sell some of the allowances that they have received.
Each budget source must designate an account representative to
handle all its allowance transactions. The USEPA, in a central
national system, will maintain allowance accounts and record
transfer of allowances among accounts.
The ability of sources to transfer allowances will serve to
minimize the costs of reducing NO
x
emissions from budget units
to comply with the overall NO
x
budget. In particular, the NO
x
emissions of budget units that may be most economically
controlled will be targeted by sources for further control of
emissions. This will result in a surplus of NO
x
allowances from
those units that can be transferred to other units at which it
is more difficult to control NO
x
emissions. Experience with
reduction of sulfur dioxide emissions under the federal Acid
Rain program has shown that this type of trading program not
only achieves regional emission reductions in a more cost-
effective manner but also results in greater overall reductions
than application of traditional emission standards to individual
emission units.
The USEPA developed the plan for the NO
x
Trading Program with
assistance from affected states. Illinois' rules for the NO
x
Trading Program for EGU are located at 35 lAC Part 217, Subpart
W, and have been approved by the USEPA. These rules provide for
interstate trading, as mandated by Section 9.9 of the Act.
Accordingly, these rules refer to and rely upon federal rules at
40 CFR Part 96, which have been developed by USEPA for certain
aspects of the NO
x
Trading Program, and which an individual
state must follow to allow for interstate trading of allowances.
Note: This narrative description of the NO
x
Trading Program is
for informational purposes only and is not enforceable.
Applicabili ty
a.
i.
The following emission units at this source are
budget EGU for purposes of.the NO
x
Trading Program.
Accordingly, this source is a budget source and the
Permittee is the owner or operator of a budget source
and budget EGU. In this section of this permit,
these emission units are addressed as budget EGU.
Turbines CT01, CT02, CT03, CT04 and CTOS
ii.
This permit does not provide \\low-emitter status" for
the above emission units pursuant to 35 IAC
217.7S4(c).
b.
The following EGU that were previously operated at the
source also have been allocated certain NO
x
allowances under
the NO
x
Trading Program. Even though these units are not
23
6.3.3
6.3.4
allowed to operate by this permit, these units' allowances
may be used to demonstrate compliance under the NO
x
Trading
Program.
None
General Provisions of the NO
x
Trading Program
a.
This source and the budget EGU at this source shall comply
with all applicable requirements of Illinois' NO, Trading
Program, i.e., 35 lAC Part 217, Subpart W, and 40 CFR Part
96 (excluding 40 CFR 96.4(b) and 96.55(c), and excluding 40
CFR 96, Subparts C, E, and I), pursuant to 35 lAC
2l7.756(a) and 2l7.756(f) (2).
b.
Any provision of the NO, Trading Program that applies to a
budget source (including any provision applicable to the
account representative of a budget source) shall also apply
to the owner and operator of such budget source and to the
owner and operator of each budget EGU at the source,
pursuant to 35 lAC 2l7.756(f) (3).
c.
Any provision of the NO, Trading Program that applies to a
budget EGU (including any provision applicable to the
account representative of a budget EGU) shall also apply to
the owner and operator of such budget EGU. Except with
regard to requirements applicable to budget EGUs with a
cornmon
stack under 40 CFR 96, Subpart H, the owner and
operator and the account representative of one budget EGU
shall not be liable for any violation by any other budget
EGU of which they are not an owner or operator or the
account representative, pursuant to 35 lAC 2l7.756(f) (4).
Requirements for NO
x
Allowances
a.
Beginning in 2004, by November 30 of each year, the
allowance transfer deadline,
the,
account r.epresentative of
each budget EGU at this source shall hold allowances
available for compliance deduction under 40 CFR 96.54 in
the budget EGUs compliance account or the
source/s
overdraft account in an amount that shall not be less than
the budget EGUs total tons of NO, emissions for the
preceding control period, rounded to the nearest whole ton,
as determined in accordance with 40 CFR 96, Subpart H, plus
any number necessary to account for actual utilization
(e.g., for testing, start-up, malfunction, and shut down)
under 40 CFR 96.42(e) for the control period, pursuant to
35 IAC 2l7.756(d) (1). For purposes of this requirement, an
allowance may not be utilized for a control period in a
year prior to the year for which the allowance is
allocated, pursuant to 35 lAC 2l7.756(d) (5).
b.
The account representative of a budget EGU that has excess
emissions in any control period, i.e., NO
x
emissions in
24
6.3.5
excess of the number of NO
x
allowances held as provided
above, shall surrender allowances as required for deduGtion
under 40 CFR 96.54(d) (1), pursuant to 35 lAC 217.756(f) (5).
In addition, the owner or operator of a budget EGU that has
excess emissions shall pay any fine, penalty, or
assessment, or comply with any other remedy imposed under
40 CFR 96.54(d) (3) and the Act, pursuant to 35 lAC
217.756(f) (6). Each ton of NO
x
emitted in excess of the
number of NO
x
allowances held as provided above for each
budget EGU for each control period shall constitute a
separate violation of 35 lAC Part 217 and the Act, pursuant
to 35 lAC 217.756(d) (2).
c.
An allowance allocated by the Illinois EPA or USEPA under
the NO
x
Trading Program is a limited authorization to emit
one ton of NO
x
in accordance with the NO
x
Trading Program.
As explained by 35 lAC 217.756(d) (6), no provisions of the
NO
x
Trading Program, the budget permit application, the
budget permit, or a retired unit exemption under 40 CFR
96.5 and no provision of law shall be construed to limit
the authority of the United States or the State of Illinois
to terminate or limit this authorization. As further
explained by 35 lAC 217.756(d) (7), an allowance allocated
by the Illinois EPA or USEPA under the NO
x
Trading Program
does not constitute a property right. As provided by 35
lAC 217.756(d) (4), allowances shall be held in, deducted
from, or transferred among allowances accounts in
accordance with 35 lAC Part 217, Subpart W, and 40 CFR 96,
Subparts F and G.
Monitoring Requirements for Budget EGU
a.
The Permittee shall comply with the monitoring requirements
of 40 CFR Part 96, Subpart H, for each budget EGU and the
compliance of each budget EGU with the emission limitation
under Condition 6.3.4(a) shall be determined by the
emission measurements recorded and reported in accordance
with 40 CFR 96, Subpart H, pursuant to 35 lAC
217.756(c) (1), (c) (2) and (d) (3).
b.
The account representative for the source and each budget
EGU at the source shall comply with those sections of the
monitoring requirements of 40 CFR 96, Subpart H, applicable
to an account representative, pursuant to 35 lAC
217.756(c) (1) and (d)(3).
Note: Pursuant to 40 CFR 96.70(b), existing budget EGU
were to begin complying with applicable monitoring
requirements of 40 CFR Part 96 at least one year in advance
of the start of the first control period governed by the NO
x
Trading Program.
25
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
6.3.6
6.3.7
Recordkeeping Requirements for Budget EGU
Unless otherwise provided below, the Permittee shall keep on
site at the source each of the following documents for a period
of 5 years from the date the document is created. This 5-year
period may be extended for cause at any time prior to the end of
the 5 years, in writing by the Illinois EPA or the USEPA.
a.
The account certificate of representation of the account
representative for the source and each budget EGU at the
source and all documents that demonstrate the truth of the
statements in the account certificate of representation, in
accordance with 40 CFR 96.13, as provided by 35 lAC
217.756(e) (1) (A). These certificates and documents must be
retained on site at the source for at least 5-years after
they are superseded because of the submission of a new
account certificate of representation changing the account
representative.
b.
All emissions monitoring information, in accordance with 40
CFR 96, Subpart H, (provided that to the extent that 40 CFR
96, Subpart H, provides for a 3-year period for retaining
records, the 3-year period shall apply), pursuant to 35 lAC
217.756 (e) (1)
(B) .
c.
Copies of all reports, compliance certifications, and other
submissions and all records made or required under the NO
x
Trading Program or documents necessary to demonstrate
compliance with requirements of the NO
x
Trading Program,
pursuant to 35 lAC 217.756(e) (1) (C).
d.
Copies of all documents used to complete a budget permit
application and any other submission under the NO, Trading
Program, pursuant to 35 lAC 217.756(e) (1) (D).
Reporting Requirements for Budget EGU
a.
The account representative for this source and each budget
EGU at this source shall submit to the Illinois EPA and
USEPA the reports and compliance certifications required
under the NO, Trading Program, including those under 40 CFR
96, Subparts D and H, and 35 lAC 217.774, pursuant to 35
lAC 217.756(e) (2).
b.
Notwithstanding the provisions in Conditions 9.8 and 9.9 of
this CAAPP permit, these submittals need only be signed by
the designated representative, who may serve in place of
the responsible official for this purpose, as provided by
Section 39.5(1) of the Act, and submittals to the Illinois
EPA need only be made to the Illinois EPA, Air Compliance
section.
26
6.3.8
Allocation of NO
x
Allowances to Budget EGU
a.
As the budget EGU identified in Condition 6.3.2(a) are
'existing" EGU listed in 35 lAC Part 217, Appendix F, these
EGU are entitled to NO
x
allowances as follows.
(The portion
of Appendix
F
that applies to the Permittee is provided in
Condition 6.3.12.) The number of NO
x
allowances actually
allocated for the budget EGU shall be the number of NO,
allowances issued by USEPA pursuant to the allocation
information reported to it by the Illinois EPA, which
information may reflect adjustments to the overall
allocations to budget EGU as provided for by 35 lAC
217.760(b) and (c):
i.
In 2004 through 2006 (the first three years of the NO
x
Trading Program), an annual allocation of NO
x
allowances as specified by 35 lAC
217.7~4(a)
(1),
i.e., the number of NO
x
allowances listed in Appendix
F, Column 7, and as provided by 35 lAC 217.768(j), a
pro-rata share of any NO
x
allowances remaining in the
new source set-aside (NSSA) following the allocation
of allowances to new budget EGU.
ii.
In 2007, as provided by 35 lAC 217.764(b), an
allocation of NO
x
allowances as specified by 35 lAC
217.764(b) (1), i.e., the number of NO
x
allowances
listed in Appendix F, Column 8, and as provided by 35
lAC 217.764(b) (4), a pro-rata share of any NO,
allowances remaining after the allocation of
allowances pursuant to 35 lAC 217.764(b) (2) to budget
EGU that commence operation between January 1, 1995
and April 30, 2003.
iii. In 2008, as provided by 35 lAC 217.764(c), a specified
allocation of NO
x
allowances, i.e., the number of NO
x
allowances listed in Appendix F, Column 8, and a pro-
rata share of any NO
x
allowances remaining after the
allocation of allowances to budget EGU that commence
operation between January 1, 1995 and April 30, 2004.
iv.
In 2009, as provided by 35 lAC 217.764(d), a specified
allocation of NO
x
allowances, i.e., the number of NO
x
allowances listed in Appendix F, Column 9, and a pro-
rata share of any NO
x
allowances remaining after the
allocation of NO
x
allowances to budget EGU that
commence operation between January 1, 1995 and April
30, 2005, and as provided by 35 lAC 217.764(d) (6), a
pro-rata share of any surplus of NO
x
allowances in the
NSSA after the allocation of NO, allowances to new
budget EGU pursuant to 35 lAC 217.764(d) (5).
v.
In 2010, as provided by 35 lAC 217.764(e), a specified
allocation of NO
x
allowances, i.e., the number of NO
x
allowances listed in Appendix F, Column 9, and a pro-
27
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
6.3.9
rata share of any NO
x
allowances remaining after the
allocation of NO, allowances to budget EGU that
commence operation between January 1, 1995 and April
30, 2006, and a pro-rata share of any surplus of NO,
allowances in the NSSA following the allocation of NO,
allowances to new budget EGU.
vi.
In 2011 and annually thereafter, as provided by 35
lAC 217.764(f), an allocation of NO, allowances based
on the prior operation of the EGU during previous
control periods and a pro-rata share of any surplus
of NO, allowances in the NSSA following the allocation
of NO, allowances to new budget EGU.
Note: If the start of the NO, Trading program is shifted
because of a Court Decision, the years defining the
different control periods would be considered to be
adjusted accordingly, as provided by the Board note
following 35 lAC 217.764.
b.
In accordance with 35 lAC 217.762, the theoretical number
of NO, allowances for the budget EGU listed in Condition
6.3.2(a), calculated as the product of the applicable NO,
emissions rate and heat input as follows, shall be the
basis for determining the pro-rata share of NO
x
allowances
for the budget EGU and the allocation of NO, allowances to
the budget EGU based on their prior operation:
i.
The applicable NO, emission rate for the budget EGU
shall be 0.15 lb/mmBtu, as specified by 35 lAC
217.762 (a) (1) .
ii.
The applicable heat input (mmBtu/control period)
shall be the average of the two highest heat inputs
from the control periods four to six years prior to
the year for which the allocation is being made, as
provided by 35 lAC 217.762(b) (1).
Eligibility for NO, Allowances from the New Source Set-Aside
(NSSA)
a.
In 2004, 2005 and 2006, the budget EGU identified in
Condition 6.3.2(a) will qualify as "new" budget EGU that
commenced commercial operation prior to January 1, 2004.
As such, the Permittee may be entitled to obtain NOx
allowances from the NSSA for these EGU without charge, as
provided by 35 lAC 217.768.
b.
For the purpose of any such request for NOx allowances, the
NOx emission rate shall be the permitted emission rate of
these EGU as specified in Condition 6.3.8(b) (ii) and the
projected heat input shall not exceed the average of the
EGUs two highest seasonal heat inputs for the control
28
periods one to three years prior to the allocation year,
pursuant to 35 lAC 217.768(e).
6.3.10 Eligibility for Early Reduction Credits (ERC)
The permittee is eligible to request NO
x
allowances for the
budget EGU identified in Condition 6.3.2(a) for any early
reductions in NO
x
emissions, as provided by 35 lAC 217.770.
6.3.11 Budget Permit Required by the NO, Trading Program

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a.
For this source, this segment of the CAAPP Permit, i.e.,
Section 6.3, is the Budget Permit required by the NO,
Trading Program and is intended to contain federally
enforceable conditions addressing all applicable NO, Trading
Program requirements. This Budget Permit shall be treated
as a complete and segregable portion of the source's entire
CAAPP permit, as provided by 35 lAC 217.758(a) (2).
b.
The Permittee and any other owner or operator of this
source and each budget EGU at the source shall operate the
budget EGU in compliance with this Budget Permit, pursuant
to 35 lAC 217.756 (b) (2) .
c.
No provision of this Budget Permit or the associated
application shall be construed as exempting or excluding
the Permittee, or other owner or operator and, to the
extent applicable, the account representative of a budget
source or budget EGU from compliance with any other
regulation or requirement promulgated under the CAA, the
Act, the approved State Implementation Plan, or other
federally enforceable permit, pursuant to 35 lAC
217.756(g) .
d.
Upon recordation by USEPA under 40 CFR 96, Subpart F or G,
or 35 lAC 217.782,
every allocation,
transfer, or deduction
of an allowance to or from the budget units' compliance
accounts or to or from the overdraft account for the budget
source is deemed to amend automatically, and become part
of, this budget permit, pursuant to 35 lAC 217.756(d) (8).
This automatic amendment of this budget permit shall be
deemed an operation of law and will not require any further
review.
e.
No revision of this Budget Permit shall exCuse any
violation of the requirements of the NO
x
Trading Program
that occurs prior to the date that the revisions to this
permit takes effect, pursuant to 35 lAC 217.756(f) (1).
f.
The Permittee, or other owner or operator of the source,
shall reapply for a Budget Permit for the source as
required by 35 lAC Part 217, Subpart Wand Section 39.5 of
the Act. For purposes of the NO
x
Trading Program, the
29
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
application shall contain the information specified by 35
lAC
217.758 (b)(2) .
6 . 3 . 12
Ref erences
35 lAC Part 217 Appendix F - (provisions applicable to the Permittee)
80% of
50% of
2004,
Company
NO
x
NO,
NO
x
2005,
2007,
Name/
Generating
Budget
Budget
Budget
2006
2008
LD. No.
Unit
EGU
Allowances Allowances Allowances Allowances
Allowances
1
2
3
4
5
6
7
8
1191 0 5AAA
Turbine
Turbine
4
3
2
4
3
1191 0 5AAA
venice
1
Venice
1
10
8
5
9
8
1191 0 5AAA
Venice
2
Venice
2
13
10
7
12
10
1191 0 5AAA
venice
3
Venice
3
6
5
3
6
5
1191 0 5AAA
Venice
4
Venice
4
7
6
4
7
5
1191 0 5AAA
Venice
5
Venice
5
15
12
8
14
12
1191 0 5AAA
Venice
6
Venice
6
16
13
8
15
13
119105AAA
venice
7
venice
7
2
2
1
2
1
119105AAA
venice
8
Venice
8
2
2
1
2
2
Union Electric Total
75
60
38
71
59
30
2009,
2010
Allowances
9
2
5
6
3
4
7
8
1
1
37
7.0
UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS
7.1
Turbine CT02 (Subject to NSPS - 40 CFR Subpart GG)
7.1.1 Description
The turbine is a process emission unit used to generate
electricity. The turbine is a Pratt-Whitney FT-8 Twin Pac with
a nominal capacity of 60 MWe with two separate stacks (S-ll and
S-12). The turbine is natural gas fired with distillate oil as
back up fuel. The turbine is equipped, operated, and maintained
with water injection system to control NO
x
emissions. The
turbine was constructed pursuant to Construction Permit
01080020.
Note: This narrative description is for informational purposes
only and is not enforceable.
7.1.2
List of Emission Units and Air Pollution Control Equipment
Emission
Emission
Date
Control
unit
Description
Constructed
Equipment
CT02
Twin Pac Natural
2002
Water
Gas
Fired Turbine
Injection
with Distillate Oil
as Back-Up Fuel
(Nominal Capacity
60 MWe)
7.1.3
Applicable Provisions and Regulations
a.
The "affected turbines" for the purpose of these unit-
specific conditions, are turbines described in Conditions
7.1.1 and 7.1.2.
b.
Pursuant to 35 lAC 212.123,
i.
No person shall cause or allow the emission of smoke
or other particulate matter, with an opacity greater
than 30 percent, into the atmosphere from any
emission unit.
ii.
The emission of smoke or other particulate matter
from any such emission unit may have an opacity
greater than 30 percent but not greater than 60
percent for a period or periods aggregating 8 minutes
in any 60 minute period provided that such opaque
emissions permitted during any 60 minute period shall
occur from only one such emission unit located within
a 1000 ft radius from the center point of any other
such emission unit owned or operated by such person,
and provided further that such opaque emissions
31
permitted from each such emission unit shall be
limited to 3 times in any 24 hour period.
c.
Pursuant to 35 lAC 214.301, no person shall cause or allow
the emission of sulfur dioxide into the atmosphere from any
process emission source to exceed 2000 ppm.
d.
The affected turbine is subject to the NSPS for Sta.tionary
Gas Turbines, 40 CFR 60 Subparts A and GG, because the heat
input at peak load is equal to or greater than 10.7
gigajoules per hour (10 mmBtu/hr), based on the lower
heating value of the fuel fired and the affected turbine
commenced construction, modification, or reconstruction
after October 3, 1977. The Illinois EPA administers the
NSPS for subject sources in Illinois pursuant to a
delegation agreement with the USEPA.
i.
Standard for Nitrogen Oxides:
Pursuant to 40 CFR 60.332(b), electric utility
stationary gas turbines with a heat input at peak load
greater than 107.2 gigajoules per hour (100 million
Btu/hour) based on the lower heating value of the fuel
fired shall comply with the provisions of 40 CFR
60.332 (a) (1).
Pursuant to 40 CFR 60.332 (a)(l) , no owner
or operator of an affected turbine shall cause to be
discharged into the atmosphere from such gas turbine,
any gases which contain nitrogen oxides in excess of:
STD
~
0.0075 (14.4) + F
Y
Where:
STD
~
Allowable NO, emissions (percent by volume at 15
percent oxygen and on a dry basis) .
Y
Manufacturer's rated heat rate at manufacturer's
rated load (kilojoules per watt hour) or, actual
measured heat rate based on lower heating value
of fuel as measured at actual peak load for the
facility. The value of Y shall not exceed 14.4
kilojoules per watt hour.
F
NO
x
emission allowance for fuel-bound nitrogen
calculated from the nitrogen content of the
fuel as follows:
Fuel-bound nitrogen
F
(percent by weight)
(NO
x
percent by
volume)
N
-
<
0.015
0
0.015
<
N
<
0.1
0.04 (N)
N>
0.1
<
0.25
N
-
<
0.25
0.04 + 0.0067(N -
0.005
0.1)
32
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
e.
Where:
N
=
The nitrogen content of the fuel (percent by
weight) determined in according with Condition
7.1.8(b) .
ii.
Standard for Sulfur Dioxide:
i.
Pursuant to 40 CFR 60.333, on and after the date on
which the performance test required to be conducted
by 40 CFR 60.8 is completed, every owner or operator
subject to the provision of 40 CFR 60 Subpart GG
shall comply with one or the other of the following
conditions:
No owner or operator subject to the provisions of
this subpart shall cause to be discharged into the
atmosphere from any stationary gas turbine any gases
which contain sulfur dioxide in excess of 0.015
percent by volume at 15 percent oxygen and on a dry
basis, pursuant to 40 CFR 60.333(a).
No owner or operator subject to the provisions of
this subpart shall burn in any stationary gas turbine
any fuel which contains total sulfur in excess of 0.8
percent by weight (8000 ppmw) , pursuant to 40 CFR
60.333(b) .
No owner or operator shall cause or allow the
emissions of NO
x
into the atmosphere from the affected
turbine to exceed 0.25 lbs/mmBtu of actual heat input
during each ozone control period from May 1 through
September 3D, based on a ozone control period
average, for that unit [35 lAC 217.706(a)].
ii.
Notwithstanding the above emission limitation of 35
lAC 217.706(a), the affected turbine subject to a
more stringent NO
x
emission limitation pursuant to any
State or federal statute, including the Act, the
Clean Air Act, or any regulations promulgated
thereunder, shall comply with both the requirements
of 35 lAC 217 Subpart V and that more stringent
emission limitation [35 lAC 217.706(b)].
f.
Startup Provisions
SUBjeet te tBo
fello~lia§
terms ana eeBaiEieBs, tao
Permittee is
aHtaeri~ea
te sperate tae affeetoa tHrBiaes in
vislatisR sf tRe
~~lieaSle
staReares iR CSReitisR 7.1.](B)
aRe tRe RSHrly limits iR CSReitisR 7.1.6
eHriR~ startH~.
~Ris aHtReri~atieR
is
~revieee ~HrsHaRt
ts ]5 I1£ 291.149,
291.161 aHe 291.262, as tHe PeFffiittee Has appliee fer SHea
autfieri~atieE
is its applieatieB,
~eEcrallJr aeseriBiH~
tae
33
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
efforts tHat ,;ill Be 1:lseei " ... to miFlimi:!2e start1:lp omissioFlS,
cluratioFl of iFlaiviffiial starts, aHa frCEJ1:lCHCY of start'l;lf)s."
i.
This authorization does not relieve the Permittee
from the continuing obligation to demonstrate that
all reasonable efforts are made to minimize startup
emissions, duration of individual startups and
frequency of startups.
ii.
The Permittee shall conduct startup of the each
affected turbine(s) in accordance with written
procedures prepared by the Permittee and maintained
at the facility, in the control room for the each
affected turbine(s), that are specifically developed
to minimize emissions from startups and that include,
at a minimum, the following measures:
A.
The Permittee shall conduct startup of an
affected turbine in accordance with the
manufacturer's written instructions or other
written instructions prepared by the source
owner or operator and maintained on site.
B.
The Permittee shall take the following measures
to minimize emissions resulting from startups,
the duration of startups, and minimize the
frequency of startups:
I.
Operating in accordance with the
manufacturer's written operating and
startup procedures, including a pre-check
of the unit, or other written procedures
developed and maintained by the source
owner or operator so as to minimize the
duration of startups and the emissions
associated with startups. These
procedures should allow for review of
operating parameters of the unit during
startup, or shutdown as necessary to make
adjustments to reduce or eliminate excess
emissions.
II.
Maintaining units in accordance with
written procedures developed and
maintained by the source owner or
operator so as to minimize the duration
of startups and the frequency of
startups. These maintenance practices
shall include maintenance activities
before the unit is started up, when the
unit is in operation, and when the unit
is shut down.
34
III. The procedures described above shall be
reviewed at least annually to make
necessary adjustments and shall be made
available to the Illinois EPA upon
request.
iv.
The Pe.-",ittee shall f'dlfill "P"lieahle .-eee.-Ell<eejli,,§,
aHa reper1::iFl§J reEfl:liE-CIRoats 8 f COFlaitioFl
7.1.9
(FR) aBa
7.1.19(e) .
v.
As provided by 35 lAC 201.265, an authorization in a
permit for excess emissions during startup does not
shield a permittee from enforcement for any violation
of applicable emission standard(s) that occurs during
startup and only constitutes a prima facie defense to
such an enforcement action provided that the
Permittee has fully complied with all terms and
conditions connected with such authorization.
g.
Malfunction and Breakdown Provisions
subject to the following terms and conditions, the
permittee is authorized to continue operation of an
affected turbine in violation of the applicable standards
in Condition 7.1.3(b) and the hourly emission limits in
Condition 7.1.6 in the event of a malfunction or breakdown
of the affected turbines. This authorization is provided
pursuant to 35 lAC 201.149, 201.161 and 201.262, as the
permittee has applied for such authorization in its
application, generally explaining why such continued
operation would be required to provide essential service or
to prevent risk of injury to personnel or severe damage to
equipment, and describing the measures that will be taken
to minimize emissions from any malfunctions and breakdowns.
This authorization supersedes the general prohibition in
Condition 9.2.3 against continued operation in such
circumstances.
i.
This authorization only allows such continued
operation as necessary to provide essential service
or prevent risk of injury to personnel or severe
damage to equipment and does not extend to continued
operation solely for the economic benefit of the
Permittee.
ii.
Upon occurrence of excess emissions due to
malfunction or breakdown, the Permittee shall as soon
as practical repair the turbine, remove the affected
turbine from service, or undertake other action so
that excess emissions cease.
iii. The Permittee shall fulfill the applicable
recordkeeping and reporting requirements of
Conditions 7.1.9(n) and 7.1.10(f). For these
35
purposes, time shall be measured from the start of a
particular incident. The absence of excess emissions
for a short period shall not be considered to end the
incident if excess emissions resume.
In such
circumstances, the incident shall be considered to
continue until corrective actions are taken so that
excess emissions cease or the Permittee takes the
affected turbines out of service.
iv.
Following notification to the Illinois EPA of a
malfunction or breakdown with excess emissions, the
Permittee shall comply with all reasonable directives
of the Illinois EPA with respect to such incident,
pursuant to 35 lAC 201.263.
v.
This authorization does not relieve the Permittee
from the continuing obligation to minimize excess
emissions during malfunction or breakdown. As
provided by 35 lAC 201.265, an authorization in a
permit for continued operation with excess emissions
during malfunction and breakdown does not shield the
Permittee from enforcement for any such violation and
only constitutes a prima facie defense to such an
enforcement action provided that the Permittee has
fully complied with all terms and conditions
connected with such authorization.
7.1.4
Non-Applicability of Regulations of Concern
a.
The affected turbines are not subject to the New Source
performance Standards (NSPS) for Stationary Combustion
Turbines, 40 CFR Part 60, Subpart KKKK, because the
affected turbines did not commence construction,
modification, or reconstruction after February 18, 2005
pursuant to 40 CFR 60.4305(a), and are therefore subject to
40 CFR Part 60, Subpart GG for Stationary Gas Turbines.
Note: To qualify for this non-applicability, the Permittee
has certified that the turbines have not been modified or
reconstructed after February 18, 2005.
b.
The affected turbines are not subject to the National
Emissions Standards for Hazardous Air Pollutants for
Stationary Combustion Turbines, 40 CFR Part 63, Subpart
YYYY, because the affected turbines are not located at a
major source of HAP emissions, pursuant to 40 CFR 63.6085.
c.
The affected turbines are not subject to 35 lAC 212.321 or
212.322, due to the unique nature of such units, a process
weight rate can not be set so that such rules can not
reasonably be applied, pursuant to 35 lAC 212.323.
36
7.1. 5
d.
The affected turbines are not subject to 35 rAC 217.141 or
35 lAC 216.121 because the affected turbines are not fuel
combustion units, as defined by 35 lAC 211.2470.
e.
The affected turbines are not subject to 40 CFR Part 64,
Compliance Assurance Monitoring (CAM) for Major Stationary
Sources:
i
.
For NO
x
and 80
2
,
because:
A.
The affected turbines are subject to a NSPS
proposed after November 15, 1990, pursuant to
40 CFR 64.2(b)(1)(i).
B.
The affected turbines are subject to Acid Rain
Program requirements, pursuant to 40 CFR
64.2
(b) (1)
(iii) .
C.
The affected turbines are subject to an
emission limitation or standard for which this
CAAPP permit specifies a continuous compliance
determination method, pursuant to 40 CFR
64.2 (b) (1) (vi).
ii.
For PM, VOM, and CO because the affected turbines do
not use an add-on control device to achieve
compliance with an emission limitation or standard.
Control Requirements and Work Practices
a.
i ..
At ___ all times, including periods of startup, shutdown,
and malfunction, the source owner or operator shall,
to the extent practicable, maintain and operate any
affected turbine in a manner consistent with good air
pollution control practice for minimizing emissions.
Determination of whether acceptable operating and
maintenance procedures are being used will be based
on information available to the Illinois EPA or the
USEPA which may include, but is not limited to,
monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection
of the source [40 CFR 60.11(d)].
ii.
The source owner or operator shall operate the
affected turbines in accordance with written
operating procedures that shall include at a minimum
the following measures:
A.
Review of operating parameters of the unit
during startup or shutdown as necessary for the
proper operation of the affected turbine with
appropriate adjustments to reduce emissions.
37
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
b.
B.
Implementation of inspection and repair
procedures for a affected turbine prior to
attempting startup following repeated trips.
iii. The source owner or operator shall maintain the
affected turbines in accordance with written
procedures that shall include at a minimum the
following measures:
~.
Unless speeifies SH a more
fre~eBt
Basis BY
maFlufaeturer's ".:ritteB iastruet:isas,
aH
iBspeet:isB sf emissisBS relat:es
esm~sBeat:s
saall Be oSlTLEllet::es Et\:lart::erly.
IaspeetioHs
saall se eeailtleteil is aeeerilasee "ita
maaufaet::urer's 1JJritten inst::ruet::isas.
B.
Repair and routine replacement of emissions-
related components.
iv.
The above procedures may incorporate the
manufacturer's written instruction for operation and
maintenance of the affected turbines and associated
control systems. The source owner or operator shall
review these procedures at least every two years and
shall revise or enhance them if necessary to be
consistent with good air pollution control practice
based on the actual operating experience and
performance of the source.
i.
Natural gas and distillate fuel oil shall be the only
fuels
in~the_affected
turbine.
ii.
Distillate fuel oil with sulfur content greater than
0.05 weight percent shall not be fired in the
affected turbine.
c.
The affected turbine shall be equipped, operated, and
maintained with water injection system to control NO
x
emissions.
d.
i.
The affected turbine unit, in total, shall not fire
more than 726 million standard cubic feet of natural
gas per year. Compliance with this limit shall be
determined from a running total of 12 months of data.
ii.
The affected turbine unit, in total, shall not
operate more than 1250 hours per year. Compliance
with this limit shall be determined from a running
total of 12 months of data from the sum of operating
hours counted as set forth below:
A.
Each hour of operation for the affected turbine
fired with fuel oil shall be counted as 1.6
hours.
38
7.1. 6
B.
Each hour operation for the affected turbine
operating in other modes than identified in
Condition 7.1.5(d) (ii) (A) above shall be
counted as 1 hour.
The above limitations of Conditions 7.1.5(b), 7.1.5(c) and
7.1.5(d) were established in Permit 01080020, to address
applicability of 40 CFR 52.21, federal PSD rules and the state
rules for Major Stationary Source Construction and Modification
(MSSCAM), 35 lAC, Part 203. These limitations were intended to
ensure that the affected turbine do
not "constitute
a new major
source pursuant to PSD or MSSCAM [T1].
Production and Emission Limitations
In addition to Condition 5.3.2 and the source-wide emission
limitations in Condition 5.6, the affected turbines are subject
to the following:
a.
Hourly emissions from each affected turbine stack shall not
exceed the following limits, except during startup and
malfunction or breakdown. Compliance with these limits
shall be based on proper operation and emission testing (3-
run average) in accordance with Condition 7.1.7 or
emissions monitoring (24-hour average) in accordance with
Condition 7.1.8
[T1/T1R].
Fuel
Type
Gas
Oil
,
,
,
NO
x
2
CO
VOM
SO,
PM/PM"
(Lb/Hr)
(Lb/Hr)
(Lb/Hr)
(Lb/Hr)
(Lb/Hr)
31.2
55.4
2.6
0.37
3.0
(0.0512)'
(0.09) ,
(0.004)'
49.9
21.9
2.0
26.9
12.0'
(0.0922)'
(0.04)'
(0.004)'
lb/mmBtu, based on Higher Heating
Value (HHV) of the
fuel.
This limit
shall not apply when ice fog is deemed
a
hazard in accordance
with 40 CFR 60.332(f).
The PM/PM,o limitation during fuel oil firing revises
the limitation in Permit 01080020. The source has
requested that the Illinois EPA establish a revised
limit in this permit, consistent with the information
provided in the CAAPP application. Specifically, the
PM/PM,o limit is changed from 7.0 lb/hr to 12.0 lb/hr
to address actual emission test data for full load
operation. The original limit of 7.0 lb/hr was based
on manufacturer's data that did not accurately
represent the PM/PM,o emissions from the affected
turbine while firing fuel oil. The source has
requested this revision and has addressed the
39
b.
i.
applicability and compliance of Title I of the CAA,
specifically 35 IAC Part 203. This limit continues
to ensure that the affected turbine does not
constitute major modification for PM/PM
10
pursuant to
these rules.
The total annual emissions from the affected turbine
unit (total 2 turbines of the twin pack unit) shall
not exceed the following limitations. Compliance
with these limitations shall be determined from a
running total of 12 months of data.
Pollutant
NO
x
CO
PM/PM
SO,
"
VOM
Emissions
(Tons/yr)
39
80
12
32
20
ii.
For purpose of determining compliance with the above
annual limitations:
A.
Unless emission monitoring is performed for a
pollutant, emissions during periods other than
startup shall be determined from emission
factors developed from testing required in the
construction permit 01080020 (NO
x
,
CO, VOM and
PM/PM
,
,) and analysis of fuel sulfur content or
standard factors (SO,).
B.
Unless an alternative factor is established for
the pollutant or emissions monitoring is
performed for the pollutant, emissions of CO
and VOM during an hour that includes a startup
shall be presumed to be 110 and 125 percent
respectively of the limits in Condition
7.1.6(a), i.e. CO and VOM emissions during an
hour with a startup shall be presumed to be 61
lb/hr and 3.25 lb/hr, respectively, while
firing on natural gas, and 24.1 lb/hr and 2.5
lb/hr, respectively, while firing on fuel oil.
These presumptions are based on data in the
application describing maximum emissions during
startup of the affected turbine. Any
alternative factor for emissions during startup
of the affected turbine shall be based on
representative emission testing conducted with
USEPA Reference Test Methods identified in the
construction permit 01080020.
C.
The establishment of the above procedures for
determining compliance with the annual emission
40
7.1. 7
limits shall not shield the Permittee from
responsibility to account for all emissions
from the source, including emissions during
startup and malfunction, as other credible
information may demonstrate that the above
procedures do not adequately account for the
actual emissions of the source.
The above limitations of Conditions 7.1.6(a) and 7.1.6(b) were
established in Permit 01080020, to address applicability of 40
CFR 52.21, federal PSD rules and the state rules for Major
Stationary Source Construction and Modification (MSSCAM), 35
lAC, part 203. These limitations were intended to ensure that
the affected turbine do not constitute a new major source
pursuant to PSD or MSSCAM [Til.
Testing Requirements
a.
The nitrogen oxides (NO
x
)
emissions, and the oxygen (0
2
)
concentration and opacity of exhaust shall be measured for
the affected turbines at the source owner or operator's
expense by an independent testing service approved by the
Illinois EPA as follows to determine compliance with
applicable emission limits:
i.
Within 120 days after a written request from the
Illinois EPA, for such pollutants listed above as
specified by the request.
ii.
Any extension to these time periods that may be
provided at its discretion by the Illinois EPA shall
not alter the source owner or operator's obligation
to perform emission testing for purposes of the NSPS
in a timely manner as specified by 40 CFR 60.8.
b.
The following methods and procedures shall be used for
testing of emissions:
i.
The USEPA Reference Test Methods shall be used
including the following:
ii.
Opacity
Nitrogen Oxides
USEPA Method 9
USEPA
Method 20
A.
Pursuant to 40 CFR 60.335(b), the owner or
operator shall determine compliance with the
applicable nitrogen oxides emission limitation
in 40 CFR 60.332 and shall meet the performance
test requirements of 40 CFR 60.8 as follows:
For each run of the performance test, the mean
nitrogen oxides emission concentration (NO
xo
)
corrected to 15 percent 0, shall be corrected to
ISO standard conditions using the following
41
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
equation. Notwithstanding this
requirement
I
use of the ISO correction equation is optional
for: Lean premix stationary combustion
turbines; units used in association with heat
recovery steam generators (HRSG) equipped with
duct burners; and units equipped with add-on
emission control
devices
I
pursuant to 40 -CFR
60.335 (b) (1):
NO
x
=
(NO
xo
) (Pr/P
o)
0.5 e19 (H
o
-0.00633)
(288°K/Ta)
1. 53
Where:
NO
x
= emission concentration of NO
x
at 15
percent O2 and ISO standard ambient
conditions, ppm by volume, dry basis
NOxa = mean observed NO
x
concentration, ppm by
volume, dry basis, at 15 percent O
2
P
r
= reference combustor inlet absolute
pressure at 101.3 kilopascals ambient
pressure, rom Hg
Po
=observed combustor inlet absolute
pressure at test, rom Hg
Ho
=observed humidity of ambient air, g H2
Olg
air
e
=transcendental constant, 2.718
Ta
= ambient temperature, OK
The 3-run performance test required by 40 CFR
60.8 must be performed within ± 5 percent at
30, 50, 75, and 90-to-l00 percent of peak load
or at four evenly-spaced load points in the
normal operating range of the gas turbine,
including the minimum point in the operating
range and 90-to-l00 percent of peak load, or at
the highest achievable load point if 90-to-l00
percent of peak load cannot be physically
achieved in practice. If the turbine combusts
both oil and gas as primary or backup fuels,
separate performance testing is required for
each fuel. Notwithstanding these requirements,
performance testing is not required for any
emergency fuel (as defined in 40 CFR 60.331),
pursuant to 40 CFR 60.335(b) (2).
If water or steam injection is used to control
NO
x
with no additional post-combustion NO
x
42
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
control and the owner or operator chooses to
monitor the steam or water to fuel ratio in
accordance with 40 CFR 60.334(a), then that
monitoring system must be operated concurrently
with each EPA Method 20, ASTM D6522-00
(incorporated by reference, see 40 CFR 60.17),
or EPA Method 7E run and shall be used to
determine the fuel consumption and the steam or
water to fuel ratio necessary to comply with
the applicable 40 CFR 60.332 NO, emission limit,
pursuant to 40 CFR 60.335(b) (4).
If the owner or operator elects to install
a
CEMS, the performance evaluation of the CEMS
may either be conducted separately (as
described in 40 CFR 63.335(b) (7)) or as part of
the initial performance test of the affected
unit, pursuant to 40 CFR 60.335(b) (6).
Pursuant to 40 CFR 60.335(b) (7), if the owner
or operator elects to install and certify a NO
x
CEMS under 40 CFR 60.334(e), then the initial
performance test required under 40 CFR 60.8 may
be done
in
the following alternative manner:
Perform a minimum of 9 reference method runs,
with a minimum time per run of 21 minutes, at
a
single load level, between 90 and 100 percent
of peak (or the highest physically achievable)
load, pursuant to 40 CFR 60.335(b) (7) (i).
Use the test data both to demonstrate
compliance with the applicable NO
x
emission
limit under 40 CFR 60.332 and to provide the
required reference method data for the RATA of
the CEMS described under 40 CFR 60.334(b)
pursuant to 40 CFR 60.335(b)(7) (ii).
The requirement to test at three additional
load levels is waived, pursuant to 40 CFR
60.335(b) (7) (iii).
If the owner or operator elects under 40 CFR
60.334(f) to monitor combustion parameters or
parameters indicative of proper operation of NO
x
emission controls, the appropriate parameters
shall be continuouslY monitored and recorded
during each run of the initial performance
test, to establish acceptable operating ranges,
for purposes of the parameter monitoring plan
for the affected unit, as specified in 40 CFR
60.334(g), pursuant to 40 CFR 60.335(b) (8).
43
Pursuant to 40 CPR 60.335(b) (10), if the owner
or operator is required under 40 CFR
60.334(i) (1) or (3) to periodically determine
the sulfur content of the fuel combusted in the
turbine, a minimum of three fuel samples shall
be collected during the performance test.
Analyze the samples for the total sulfur
content of the fuel using:
Por gaseous fuels, ASTM Dl072-80, 90
(Reapproved 1994); D3246-81, 92, 96; D4468-85
(Reapproved 2000); or D6667-01 (all of which
are incorporated by reference, see 40 CFR
60.17). The applicable ranges of some ASTM
methods mentioned above are not adequate to
measure the levels of sulfur in some fuel
gases. Dilution of samples before analysis
(with verification of the dilution ratio) may
be used, subject to the prior approval of the
Administrator, pursuant to 40 CPR
60.335 (b) (10) (ii) .
The fuel analyses required under 40 CPR
63.335(b) (9) and (b) (10) may be performed by
the owner or operator, a service contractor
retained by the owner or operator, the fuel
vendor, or any other qualified agency, pursuant
to 40 CPR 60.335(b) (11).
B.
Pursuant to 40 CPR 60.335(c), the owner or
operator may use the following as alternatives
to the reference methods and procedures
specified in this section:
Instead of using the equation in CPR
60.335(b) (1), manufacturers may develop ambient
condition correction factors to adjust the
nitrogen oxides emission level measured by the
performance test as provided in 40 CPR 60.8 to
ISO standard day conditions, pursuant to 40 CPR
60.335 (c) (1) .
c.
At least 60 days prior to the actual date of testing, a
written test plan shall be submitted to the Illinois EPA
for review. This plan shall describe the specific
procedures for testing and shall include as a minimum:
i.
The person(s) who will be performing sampling and
analysis and their experience with similar tests.
ii.
The specific conditions under which testing shall be
performed including a discussion of why these
conditions will be representative of maximum
emissions and the means by which the operating
44
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
parameters for the turbine will be tracked and
recorded.
iii. The specific determinations of emissions that are
intended to be made, including sampling and
monitoring locations; the test method(s) that will be
used, with the specific analysis method, if the
method can be used with different analysis methods.
The source owner or operator may also propose a plan
for testing across the normal operating range of the
affected turbines.
d.
The Illinois EPA shall be notified prior to these tests to
enable the Illinois EPA to observe these tests.
Notification of the expected date of testing shall be
submitted a minimum of thirty (30) days prior to the
expected date. Notification of the actual date and
expected time of testing shall be submitted a minimum of
five (5) working days prior to the actual date of the test.
The Illinois EPA may, at its discretion, accept
notifications with shorter advance notice provided that the
Illinois EPA will not accept such notifications if it
interferes with the Illinois EPA'S ability to observe the
testing.
e.
The Final Report for these tests shall be submitted to the
Illinois EPA within 60 days after the date of the tests.
The Final Report shall include as a minimum:
f.
i.
A summary of results.
ii.
General information.
iii. Description of test method{s), including description
of sampling points, sampling train, analysis
equipment and test schedule.
iv.
Detailed description of test conditions, including:
A.
Fuel consumption (standard ft') .
B.
Firing rate (million Btu/hr) .
c.
Turbine/Generator output rate (MW).
v.
Data and calculations, including copies of all raw
data sheets and records of laboratory analyses,
sample calculations, and data on equipment
calibration.
i.
Upon written request by the Illinois EPA, the source
owner or operator shall have the opacity of the
exhaust from the affected turbine(s) tested during
representative operating conditions as determined by
45
a qualified observer in accordance with USEPA Test
Method 9, as further specified below, pursuant to
Section 39.5(7) (d) of the Act.
ii.
Such testing shall be conducted for specific
turbine(s) within 90 calendar days of the request, or
on the date turbine(s) next operates, or on the date
agreed upon by the Illinois EPA, whichever is later.
iii. The duration of opacity observations for each test
shall be at least 30 minutes (five 6-minute averages)
unless the average opacities for the first 12 minutes
of observations (two six-minute averages) are both
less than 10.0 percent.
iv.
The source owner or operator shall notify the
Illinois EPA at least 7 days in advance of the date
and time of these tests, in order to allow the
Illinois EPA to witness testing. This notification
shall include the name and employer of the qualified
observer(s) .
v.
The source owner or operator shall promptly notify
the Illinois EPA of any changes in the time or date
for testing.
vi.
The source owner or operator shall provide a copy of
its observer's readings to the Illinois EPA at the
time of testing, if Illinois EPA personnel are
present.
vii. The source owner or operator shall submit a written
report for this testing within 30 days of the date of
testing. This report shall include:
A.
Date and time of testing.
B.
Name and employer of qualified observer.
C.
Copy of
current certification.
D.
Description of observation conditions.
E.
Description of turbine operating conditions.
F.
Raw data.
G.
Opacity determinations.
H.
Conclusions.
46
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.1.8
Monitoring Requirements
a.
i.
If an affected turbine is routinely operated or
exercised to confirm that the turbine will operate
when needed, the operation and opacity of the
affected turbine shall be formally observed by
operating personnel for the affected turbine or a
member of source owner or operator's environmental
staff on a regular basis to assure that the affected
turbine is operating properly, which observations
shall be made at least every six months.
ii.
If an affected turbine is not routinelY operated or
exercised, i.e., the time interval between operation
of an affected turbine is typically greater than six
months, the operation and opacity of the affected
turbine shall be formally observed as provided above
each time the source owner or operator carries out a
scheduled exercise of the affected turbine.
iii.
9?l=le SS1:lreo s. .. Tfler sr eJ:3orater sl=lall ales esaEluet
fSrFFIal ssservatiess sf sJ:3era1::i9E: ase sJ:3aeit3 sf aH
affeetes. t::1:lr13iao Up9Fl "dritt::ea request:: 13
3'
t::he Illinsis
BE"...
Wit::h
ERe
agreemeFl1:: sf the IlliFleis
EPl' .. ,
t::he
SS1:lree sT .. "'fier er epera1::sr may seaee1ttle 1::hese
esser
7
,,;atisFls toe talEs plaee s.1driE:§f !3orioes T.ffies it
,,'suI a stael'\o'ise l3e slleratiR§, tae atteetea tu.-l3iRe.
Note: The formal observation required above is not
intended to be a USEPA Test Method 9 opacity test, nor does
the observation require a USEPA Test Method 9 certified
observer. It is intended to be performed by personnel
familiar with the operation of the affected turbine who
would be able to make a determination based from the
observed opacity as to whether or not the affected turbine
was running properly, and subsequently initiate a
corrective action if necessary.
b.
The affected turbine shall comply with the applicable
monitoring requirements of 40 CFR 60.334(h), below.
Monitoring of fuel nitrogen content shall not be required
while the facility does not claim an allowance for fuel-
bound nitrogen. Monitoring for sulfur content in fuel is
not required while natural gas is the only fuel fired in
the affected turbine and the requirements of 40 CFR
60.334(h)3(i) or (ii) are met.
Pursuant to 40 CFR 60.334(h), the owner or operator of any
stationary gas turbine subject to the provisions of this
subpart:
Shall monitor the total sulfur content of the fuel being
fired in the turbine, except as provided in 40 CFR
60.334(h) (3). The sulfur content of the fuel must be
47
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
determined using total sulfur methods described in 40 CFR
60.335(b) (10). Alternatively, if the total sulfur content
of the gaseous fuel during the most recent performance test
was less than 0.4 weight percent (4000 ppmw) , ASTM D4084-
82, 94, D5504-01, D6228-98, or Gas Processors Association
Standard 2377-86 (all of which are incorporated by
reference-see 40 CFR 60.17), which measure the major sulfur
compounds may be used, pursuant to 40 CFR 60.334(h) (1); and
Shall monitor the nitrogen content of the fuel combusted in
the turbine, if the owner or operator claims an allowance
for fuel bound nitrogen (i.e., if an F-value greater than
zero is being or will be used by the owner or operator to
calculate STD in 40 CFR 60.332). The nitrogen content of
the fuel shall be determined using methods described in 40
CFR 60.335(b) (9) or an approved alternative, pursuant to 40
CFR 60.334(h)(2).
Pursuant to 40 CFR 60.334(h) (3), notwithstanding the
provisions of 40 CFR 63.335(h) (1), the owner or operator
may elect not to monitor the total sulfur content of the
gaseous fuel combusted in the turbine, if the gaseous fuel
is demonstrated to meet the definition of natural gas in 40
CFR 60.331(u), regardless of whether an existing custom
schedule approved by the administrator for subpart GG
requires such monitoring. The owner or operator shall use
one of the following sources of information to make the
required demonstration:
The gas quality characteristics in a current, valid
purchase contract, tariff sheet or transportation contract
for the gaseous fuel, specifying that the maximum total
sulfur content of the fuel is 20.0 grains/100 scf or less,
pursuant to 40 CFR 60.334(3) (i); or
Representative fuel sampling data which show that the
sulfur content of the gaseous fuel does not exceed 20
grains/100 scf. At a minimum, the amount of fuel sampling
data specified in section 2.3.1.4 or 2.3.2.4 of appendix D
to part 75 of this chapter is required, pursuant to 40 CFR
60.334 (h) (3) (ii).
c.
Should the operation of the affected turbine exceed the
limitations of 7.1.6(a) relating to the definition of a
gas-fired peaking unit in 40 CFR 75, the source owner or
operator shall install the appropriate Continuous
Monitoring System(s) on the affected turbine by December 31
of the following calendar year, as defined in 40 CFR 75, in
order to remain in compliance with the provisions of the
Acid Rain Program.
d.
i.
The owner or operator of an affected turbine subject
to 35 lAC 217 Subpart V (Condition 7.1.3(e)) shall
install, calibrate, maintain and operate continuous
48
7.1.9
e.
emissions monitoring systems (CEMS) for NO, that meet
the requirements of 40 CFR 75, Subpart B [35 IAC
217.710 (a) ] .
ii.
Notwithstanding 35 IAC 217.710(a) above, the owner or
operator of a gas-fired peaking unit or oil-fired
peaking unit as defined in 40 CFR 72.2 may determine
NO
x
emissions in accordance with the emissions
estimation protocol of 40 CFR 75, Subpart E [35 IAC
217.710 (b) ] .
iii. Notwithstanding 35 IAC 217.710(a) above, the owner or
operator of a combustion turbine that operates less
than 350 hour per ozone control period may determine
the heat input and NO
x
emissions of the turbine as
follows
[35 IAC 217.710(c)]:
i.
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbinets maximum hourly heat input and hours
of operation as recorded by operating
instrumentation on the turbine [35 IAC
217.710(c) (1)].
B.
NO, emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO
x
emission factors below
[35 IAC 217.710 (c) (2)]:
0.7 lbs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
The affected turbine shall be equipped, operated, and
maintained with a continuous moni.taring system to
monitor and record the fuel consumption being fired.
Recordkeeping Requirements
In addition to the records required by Condition 5.9, the source
owner or operator shall maintain records of the following items
for the affected turbine(s) to demonstrate compliance with
Conditions 5.6.1, 7.1.3, 7.1.5, and 7.1.6, pursuant to Section
39.5(7) (b) of the Act:
a.
The owner or operator of an affected turbine subject to the
requirements of 35 IAC 217 Subpart V (Condition 7.1.3(e»
shall:
i.
Comply with the recordkeeping and reporting
requirements of 40 CFR 75 applicable to NO, emissions
during the ozone control period, including, but not
limited to, 40 CFR 75.54(b) and (d)
[35 IAC
217.712 (a) ] .
49
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
ii.
Notwithstanding 35 lAC 217.712(a) above, the owner or
operator ofa combustion turbine for which heat input
and NO
x
emissions are determined pursuant to 35 lAC
217.710(c) (Condition 7.1.8(d) (iii)) shall comply
with the following recordkeeping and reporting
requirements [35 lAC 217.712(b)]:
A.
Maintain records of the heat input and NO
x
emissions of the turbine as determined in
accordance with 35 lAC 217.710(c), and records
of metered fuel use or operating hours used to
determine heat input [35 lAC 217.712(b) (1)].
b.
The source owner or operator shall maintain records of the
following items:
i.
The sulfur content of the natural gas used to fire
the turbines as determined in accordance with
Condition 7.1.8(b).
ii.
A copy of the Final Report(s) for emission testing
conducted pursuant to Condition 7.1.7.
iii. Copies of opacity determinations taken for the source
by qualified observer(s) when using USEPA Method 9.
iv.
Records documenting its periodic review of its
operating procedures as required
by
Condition
7.1.5(a) .
v.
Information for the formal observations of opacity
conducted pursuant to Condition 7.1.8(a). For each
occasion on which observations are made, these
records shall include the date, time, identity of the
observer, a description of the various observations
that were made, whether or not the affected engine
was running properly, and whether or not corrective
action is necessary and was subsequently initiated.
c.
A maintenance and repair log for the affected turbine,
listing each activity performed with date.
d.
Reserved for Future Use
e.
Fuel consumption for the affected turbine, scf/month and
scf/year.
f.
Reserved for Future Use
g.
Operating hours for the affected turbine, hr/month and
hr/year.
50
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
h.
Heat content of the fuel being fired in the affected
turbine.
i.
Emissions of each pollutant from the affected turbine,
including emissions from startups, with supporting
calculations including documentation on the validity of the
emission factors used, ton/month and ton/year.
j.
The source owner or operator shall maintain records that
identify:
i.
Any periods during which a continuous monitoring
system was not operational, with explanation.
ii.
Any period when the affected turbine was in operation
during which ice fog was deemed to be a traffic
hazard, the ambient conditions existing during the
periods, the date and time the water injection system
was deactivated, and the date and time the system was
reactivated.
iii.
Any day in which emission and/or opacity exceeded an
applicable standard or limit.
k.
The source owner or operator shall keep records of good
operating practices for each turbine.
1.
':rhe SSldree sl .. 1'.fler sr s}?era1::sr shall maiF.l:t.aia 1::he fsllsr,dag
reesres rela1::ea ts eaan snHtaST;1B sf ERe
tHr~iaes.
i.
'Phe fslls"i,,§, i"fs"matis" fs" eaeh shutes,.." sf a
t1::lr13ine.
...
B.
Date a"e time sf shutes •• ", .
. .... eeseri}?tisF.l: sf the sootas",lTl, if ",;ritten
s}?erating }?rseeooros are BSE folls',led dHriBg
tae shHtas'ffi sr sigBifioaat
}?rs~lems
SOOHr
ooriag tho sBHtasr.ffi:, iaelHding ae1::ailee
8::'Hf)laaatisa.
ii.
';Phe fslls",dag iBfeFFflatisE: fsr tRC tHr13iaos ,."hon a13s .... To
E:sr:mal s}?aeity Jaas Beon s13serveEl:
BY
SSHree perssBscl.
A.
Name of oBserver, positisa ana reaSSE: fer Being
at site.
B.
Bate
aTla
Ei:Hratisn sf aasYe :asEFRal s'@aeity,
inell~Eling
affeeteEl tHr13ine, s1::art time
aHa
time
E:srFfI:al sI?eratisE:
""las
aeEd ex.roa..
C.
If FL8TIRal s:poratisn \laS nst aeaievee. ",V'itJ.:liB 39
miE:l::lEOS, as eH}?laaat:::isE:
".ffi}r
startu:p oeHle Bet
130 ael:liC'"vTea tdthia this time.
51
B.
A aetailea
aeseri~tieE
ef tae
start~,
iaeluEliBg reaseR fer
e~eratieB.
Ei.
.m cJE-;t31anatisE:
'V.tf:ly esta:131isaea
startup
preceaures caulEl Ret Be
perf ormes,
if aet
~erfermea.
F.
':Pac
Batura s£ G}?aeity fellauin§'
the
cBa af
start1:1-p or 39 miFH:ltes af eperatisH, ..mieaever
caCHrs first, aBe aaratisa sf sl:3cratioFl: '\:lEotil
aeaievemcat sf Bennal epaeity or
shutas'hTfl.
G.
Wfietaer ae e,weeaaeee ef CeEaitieE 7.1.3 (19),
i.eo, 39 l?Crcoflt ol?aeity, Ffb3.¥ ha-ve eeCl:lrree
a1::l:riHg start1:lfl
f
t:ita cJf!31aFlatisn
if Ef\:ialifiea
OBserver ,,:as DE: site.
ffi.
Reeeras fer
Start~
Tae Permittee shall maintain tRe £ells\:iB§' reeerEls
f
~"'rsuaBt
te SeetieE 39.§(7) (19) ef tae Aet, fer eaea
affeetea tur19iEe su19jeet te CSEaitieE 7.1.3(19),
,.~iea
at a
mil'dmum Gaall
iF.l:el1:H~le.
i.
!Pao fells",Jill§, iafermatisa fer aaaa SEart1d:p af tae
affeetea turl9iae(s).
A.
Date ana auratisB 8f tae startup, i.e., start
time aBel time BoflFtal o}?cratisE: aehievea.
B.
If normal eperatisB 'i.'as Hat: acaieveEl '.llitaiB 3 G
miBut:es, an o3Ej91aaae.isn
.....
~r
st:arEl::l:El GSHle. nst
13e acl=lievee. "lithia e.his time.
C.
A e.etailee
aeseri~tisB
sf Ehe
star6l::l:~,
incluaia§J reasaH fOl?
s~erat.isE:
aaa .... ffiether the
~reeeauFes
7.1.3 (f) .,;ere
~erferffiea.
B.
AB e,,,,laaatieE
,.~y
t;ae
~reeea..res
sf 7.1.3 (fl
ana sEfier estal31isfiea st.arEl::l:p prsccal::l:res eSl::l:le
Bet 130 perfsrmea, if Bat
~erf9rmea.
B.
WRoERer e3weeaaBce sf CsaaiEisn §. 3. 2 aaa
7.1.3(13) may have eecl::l:rroe 9.l::l:riB§J start1:lj?
If
an 03Eceeeance may have sccldrree, an o3Ej91ana1:ioB
sf tRe aatldrc sf s}?acity, i.e., severityaBa
€i:'tl:ratisfl, 8.1::lriEt§ E£O startup aaEi
tee nature sf
opacity at Ehe eonel1dsisa sf
starE~.
F.
WhetHer s}?eratia§ }?orssnHol fsr the tldr13ines sr
air eBvironmoatal staff are sa site ooriH§J
star1::u}?
52
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
ii.
." .. FRaiHeenallee aHa repair Ie§" fer eaeh affeeeeEl
tUrl9iHc, listiH§" eaeh activity !?erferFReEl ,:ith Elat:e.
n.
Records for Malfunctions and Breakdowns
The Permittee shall maintain records, pursuant to 35 lAC
201.263, of continued operation of an affected turbine
subject to Condition 7.1.3(g) during malfunctions and
breakdown, which as a minimum, shall include:
i.
Date and duration of malfunction or breakdown.
ii.
A detailed explanation of the malfunction or
breakdown.
iii. An explanation why the affected turbine continued to
operate in accordance with Condition 7.1.3(g).
iv.
The measures used to reduce the quantity of emissions
and the duration of the event.
v.
The steps taken to prevent similar malfunctions or
breakdowns or reduce their frequency and severity.
vi.
The amount of release above typical emissions during
malfunction/breakdown.
7.1.10 Reporting Requirements
a.
Reporting of Deviations
The source owner or operator shall promptly notify the
Illinois EPA, Air Compliance unit, of deviations of the
affected turbine with the permit requirements as follows,
pursuant to Section 39.5(7) (f) (ii) of the Act. Reports
shall describe the probable cause of such deviations, and
any corrective actions or preventive measures taken:
i.
Emissions from the affected turbine in excess of the
limits specified in Conditions 7.1.3 and 7.1.6 within
30 days of such occurrence.
ii.
Operation of the affected turbine in excess of the
limits specified in Conditions 7.1.5 and 7.1.6 within
30 days of such occurrence.
b.
In conjunction with the Annual Emission Report required by
35 lAC Part 254, the source owner or operator shall provide
the operating hours for each affected turbine, the total
number of startups, the total fuel consumption during the
preceding calendar year.
c.
Pursuant to 40 CFR 60.7(c) and 40 CFR 60.334(j), a report
shall be submitted on a semi-annual basis. This report
53
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
d.
shall contain information on excess emissions and
monitoring system downtime reports in accordance with 40
CFR 60.7(c) and 40 CFR 60.334(j).
i.
Annually report the heat input and NO
x
emissions of
the turbine as determined in accordance with 35 lAC
217.710(c) (Condition 7.1.8(c) (iii», for each ozone
control period, by November 30 of each year [35 lAC
217.712(b) (2)].
ii.
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 report to the Illinois EPA
that demonstrates that the affected turbine has
complied with Condition 7.1.3(e). These reports
shall be accompanied by a certification statement
signed by a responsible official for the source owner
or operator as specified by 35 lAC 217.712(c).
e.
Re~srtiR~
sf
Startu~s
THe seurce
e;.~er
er
e~eraeer
sHall susmie semi annual
starE~ ro~erts
te the Illineis BPA
~ursuant
te Seeeieas
39.5 (7) (a) aRe (f) sf tae .",st.
'Faese
re~srts
saall Be
s't:1:l3mietea alen§" -.Tith the semi al3:E:Ual r8f3erts reE;IuireEi by
CSReitieR 7.1.10 (e) aRe saall iReluee tae
fslls·.,iR~
infermatieB fer startups ef tHe affeeeeel eurbine
euriB~
tHe
r~ertiBff
peried:
i.
P. list sf tae
start~s
sf tae affestee turBiRe,
ineluelin§" tRe elate, euratien aBel aeseripeien ef eaCH
startl;l.j9, accempaBieel BY a espy ef t:fie reeerEls
pUrSuaBE te CsuelitieB 7.1.9(i) fer eaeh
start~
fsr
+, ..
,:.t:dcB. sueh reeeras T .. 'ere reEf1=lirea.
ii.
If tRoro Rave l3eea HS startups ef an affeeteel tUrBiBe
euriR~
tae
r~srtiR~ ~erise,
tais saall Be statee iR
tae
re~srt.
f.
Reporting of Malfunctions and Breakdowns
The Permittee shall provide the following notification and
reports to the Illinois EPA, Air Compliance Unit and
Regional Field Office, pursuant to 35 lAC 201.263,
concerning continued operation of an affected turbine
subject to Condition 7.1.3(g) during malfunction or
breakdown:
i.
A.
The Permittee shall notify the Illinois EPA's
regional office by telephone as soon as
possible during normal working hours, but no
later than three (3) days, upon the occurrence
of noncompliance due to malfunction or
breakdown.
54
B.
Upon achievement of compliance, the Permittee
shall give a written follow-up notice within 15
days to the Illinois EPA, Air Compliance Unit
and Regional Field Office, providing a detailed
explanation of the event, an explanation why
continued' operation of the affected turbines
was necessary, the length of time during which
operation continued under such conditions, the
measures taken by the Permittee to minimize and
correct deficiencies with chronology, and when
the repairs were completed or when the affected
turbine was taken out of service.
C.
If- compliance is not achieved within 5 working
days of the occurrence, the Permittee shall
submit interim status reports to the Illinois
EPA, Air Compliance Unit and Regional Field
Office, within 5 days of the occurrence and
every 14 days thereafter, until compliance is
achieved. These interim reports shall provide
a brief explanation of the nature of the
malfunction or breakdown, corrective actions
accomplished to date, actions anticipated to
occur with schedule, and the expected date on
which repairs will be complete or the affected
turbine will be taken out of service.
ii.
In accordance with the due dates in Condition 8.6.1,
the permittee shall submit semi-annual malfunction
and breakdown reports to the Illinois EPA pursuant to
Sections 39.5(7) (a) and (f) of the Act. These
reports may be submitted along with other semi-annual
reports and shall include the following information
for malfunctions and breakdowns of the affected
turbine during the reporting period:
A.
A listing of malfunctions and breakdowns, in
chronological order, that includes:
I.
The date, time, and duration of each
incident.
II.
The identity of the affected operation(s)
involved in the incident.
B.
Dates of the notices and reports of Conditions
7.1.10(f) (i).
C.
Any supplement information the Permittee wishes
to provide to the notices and reports of
Conditions 7.1.10(f) (i).
55
D.
The aggregate duration of all incidents during
the reporting period.
E.
If there have been no such incidents during the
reporting period, this shall be stated in the
report.
7.1.11 Operational Flexibility/Anticipated Operating Scenarios
Operational flexibility is not set for the affected turbines.
7.1.12 Compliance Procedures
a.
Compliance with the PM emission limitations of Conditions
7.1.3(b) is addressed by the requirements of Condition
7.1.5, and the records required in Condition 7.1.9, and the
reports required in Condition 7.1.10.
b.
Compliance with the 80
2
emission limitations of Conditions
7.1.3(c) is addressed by the requirements of Condition
7.1.5, and the records required in Condition 7.1.9, and the
reports required in Condition 7.1.10.
c.
d.
i.
Compliance with the NO
x
emission limitations of
Conditions 7.1.3(d) (i) is addressed by the
requirements of Condition 7.1.5, the testing
requirements of 7.1.7, the monitoring requirements of
7.1.8, and the records required in Condition 7.1.9,
and the reports required in Condition 7.1.10(a).
ii.
Compliance with the 80
2
emission limitations of
Conditions 7.1.3(d) (ii) is addressed by the
requirements of Condition 7.1.5, the records required
in Condition 7.1.9, and the reports required in
Condition 7.1.10(a).
i.
Compliance with the NO
x
emission limitations of
Conditions 7.1.3(e) is addressed by the requirements
of Condition 7.1.5, the testing requirements of
7.1.7, the monitoring requirements of 7.1.8, the
records required in Condition 7.1.9, and the reports
required in Condition 7.1.10(a).
ii.
Notwithstanding 35 lAC 217.710(a), Condition
7.1.8(d), the owner or operator of a gas-fired
peaking unit or oil-fired peaking unit as defined in
40 CFR 72.2 may determine NO
x
emissions in accordance
with the emissions estimation protocol of 40 CFR 75,
Subpart E [35 lAC 217.710(b)].
iii. Notwithstanding 35 lAC 217.710(a), Condition
7.1.8(d), the owner or operator of a combustion
turbine that operates less than 350 hour per ozone
control period may determine the heat input and NO,
56
emissions of the turbine as follows
[35 lAC
217.710(c)]:
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbine's maximum hourly heat input and hours
of operation as recorded by operating
instrumentation on the turbine [35 lAC
217.710(c) (1)].
B.
NO
x
emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO
x
emission factors below
[35 lAC 217.710(c) (2)]:
0.7 lbs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
c.
Compliaaoe ..,itfi tae emission limits ia CoaEiitioFl:s 9.6 aae
7.1.6 is aaaressee ay tae reeereis aHa ro}?orts
re~ireEl
ia
Cs"sitis"s 7.1.9 a"s 7.1.10, the ee"ti""stts NO" ffls"its"i"§f
rOEfUiremoats ia Cona.i1::ioB 7.1.8 or from emissioE: faoEsrs
sevels"es f"sffl the fflSSt "eee"t """"eves staelE test i"
aeeereanoe T.dta CoaaitioH 7.1.7 (NO*)
I
staaaara oFRission
factors (CO, 'rJOU aBEl
PH/P~!4,.Q:)
anel analysis of f'l::lol sl:llf1:ir
6s"te"t s" sta"sa"s faets"s (802).
57
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.2
Turbine CTOI
7.2.1 Description
7.2.2
7.2.3
The turbine is a process emission unit used to provide
electricity during peak power demands, emergency need, and
various on-site needs. The turbine is powered by distillate
fuel oil at a ratio of two parts Grade No. 2 to one part Grade
No. 1.
Note: This narrative description is for informational purposes
only and is not enforceable.
List of Emission Units and Air Pollution Control Equipment
Emission
Emission
Date
Control
Unit
Description
Constructed
Equipment
CTOI
Stationary Gas
1967
None
Turbine That Drives
a
Generator
(Nominal Capacity
518 mmBtu/hr)
Applicable Provisions and Regulations
a.
The "affected turbines" for the purpose of these unit-
specific conditions, are turbines described in Conditions
7.2.1 and 7.2.2.
b.
pursuant to 35 lAC 212.123,
i.
No person shall cause or allow the emission of smoke
or other particulate matter, with an opacity greater
than 30 percent, into the atmosphere from any
emission unit.
ii.
The emission of smoke or other particulate matter
from any such emission unit may have an opacity
greater than 30 percent but not greater than 60
percent for a period or periods aggregating 8 minutes
in any 60 minute period provided that such opaque
emissions permitted during any 60 minute period shall
occur from only one such emission unit located within
a 1000 ft radius from the center point of any other
such emission unit owned or operated by such person,
and provided further that such opaque emissions
permitted from each such emission unit shall be
limited to 3 times in any 24 hour period.
c.
Pursuant to 35 lAC 214.301, no person shall cause or allow
the emission of sulfur dioxide into the atmosphere from any
process emission source to exceed 2000 ppm.
58
d.
i.
No owner or operator shall cause or allow the
emissions of NO
x
into the atmosphere from the affected
turbine to exceed 0.25 lbs/mmBtu of actual heat input
during each ozone control period from May 1 through
September 30, based on a ozone control period
average, for that unit [35 lAC 217.706(a)J.
ii.
Notwithstanding the above emission limitation of 35
lAC 217.706(a), the affected turbine subject to a
more stringent NO
x
emission limitation pursuant to any
State or federal statute, including the Act, the
Clean Air Act, or any regulations promulgated
thereunder, shall comply with both the requirements
of 35 lAC 217 Subpart V and that more stringent
emission limitation [35 lAC 217.706(b)J.
e.
startup Provisions
6»133 est ts the fslls.,.iRg teERs aRe sSReitisRs, the
Permittee is aHtHerisee to
o~erate
tae affeetea tHESiHOS iB
vielatisR sf the a""liea131e staReaFes ia CSReitisR 7.2.3(13)
duriH§ startH!)'
'Pais al:ltfierisat::isFl: is wre'viElea. l?1drSuaflt to
39
I~C
2Gl.149, 291.161 aHe 291,262, as tee
Per~ittee
Ras
al?l?liea fer SHCa aHtfierisatioH in its a@l?licatisH,
geReFally eessFi13iR§" the effsFts that .,:ill 13e »see "u.te
minimi:z;c startB:p emissions, Eltlratisn of iHeliviffi:ial starts,
aRe frcEfUcncy of start1::lf3s."
i.
This authorization does not relieve the Permittee
from the continuing obligation to demonstrate that
all reasonable efforts are made to minimize startup
emissions, duration of individual startups and
frequency of startups.
ii.
The Permittee shall conduct startup of the each
affected turbine(s) in accordance with written
procedures prepared by the Permittee and maintained
at the facility, in the control room for the each
affected turbine(s), that are specifically developed
to minimize emissions from startups and that include,
at a minimum, the following measures:
A.
The Permittee shall conduct startup of an
affected turbine in accordance with the
manufacturer's written instructions or other
written instructions prepared by the source
owner or operator and maintained on site.
B.
The Permittee shall take the following measures
to minimize emissions resulting from startups,
the duration of startups, and minimize the
frequency of startups:
59
I.
Operating in accordance with the
manufacturer's written operating and
startup procedures, including a pre-check
of the unit, or other written procedures
developed and maintained by the source
owner or operator so as to minimize the
duration of startups and the emissions
associated with startups. These
procedures should allow for review of
operating parameters of the unit during
startup, or shutdown as necessary to make
adjustments to reduce or eliminate excess
emissions.
II.
Maintaining units in accordance with
written procedures developed and
maintained by the source owner or
operator so as to minimize the duration
of startups and the frequency of
startups. These maintenance practices
shall include maintenance activities
before the unit is started up, when the
unit is in operation, and when the unit
is shut down.
III. The procedures described above shall be
reviewed at I-east annually to make
necessary adjustments and shall be made
available to the Illinois EPA upon
request.
iv.
'l!fte Permittee sftall fulfill ajilji31iealale reeerelkeeji3iR9'
aBa
re~er6iB~
requiremeB6s sf Gsnsi6isn 7.2.9(m) aBe
7.2.19(el) .
v.
As provided by 35 IAC 201.265, an authorization in a
permit for excess emissions during startup does not
shield a Permittee from enforcement for any violation
of applicable emission standard(s) that occurs during
startup and only constitutes a prima facie defense to
such an enforcement action provided that the
Permittee has fully complied with all terms and
conditions connected with such authorization.
f.
Malfunction and Breakdown Provisions
Subject to the following terms and conditions, the
permittee is authorized to continue operation of an
affected turbine in violation of the applicable standards
in Condition 7.2.3(b) in the event of a malfunction or
breakdown of the affected turbine. This authorization is
provided pursuant to 35 IAC 201.149, 201.161 and 201.262,
as the Permittee has applied for such authorization in its
application, generally explaining why such continued
60
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
operation would be required to provide essential service or
to prevent risk of injury to personnel or severe damage to
equipment, and describing the measures that will be taken
to minimize emissions from any malfunctions and breakdowns.
This authorization supersedes the general prohibition in
Condition 9.2.3 against continued operation in such
circumstances.
i.
This authorization only allows such continued
operation as necessary to provide essential service
or prevent risk of injury to personnel or severe
damage to equipment and does not extend to continued
operation solely for the economic benefit of the
permittee.
ii.
Upon occurrence of excess emissions due to
malfunction or breakdown, the permittee shall as soon
as practical repair the turbine, remove the affected
turbine from service, or undertake other action so
that excess emissions cease.
iii. The Permittee shall fulfill the applicable
recordkeeping and reporting requirements of
Conditions 7.2.9(n) and 7.2.10(e). For these
purposes, time shall be measured from the star-t of a
particular incident. The absence of excess emissions
for a short period shall not be considered to end the
incident if excess emissions resume. In such
circumstances, the incident shall be considered to
continue until corrective actions are taken so that
excess emissions cease or the permittee takes the
affected turbines out of service.
iv.
Following notification to the Illinois EPA of a
malfunction or breakdown with excess emissions, the
permittee shall comply with all reasonable directives
of the Illinois EPA with respect to such incident,
pursuant to 35 lAC 201.263.
v.
This authorization does not relieve the Permittee
from the continuing obligation to minimize excess
emissions during malfunction or breakdown. As
provided by 35 lAC 201.265, an authorization in a
permit for continued operation with excess emissions
during malfunction and breakdown does not shield the
Permittee from enforcement for any such violation and
only constitutes a prima facie defense to such an
enforcement action provided that the permittee has
fully complied with all terms and conditions
connected with such authorization.
61
7.2.4
Non-Applicability of Regulations of Concern
a.
The affected turbines are not subject to the New Source
performance Standards (NSPS) for Stationary Combustion
Turbines, 40 CFR Part 60, Subpart KKKK, because the
affected turbines did not commence construction,
modification, or reconstruction after February 18, 2005
pursuant to 40 CFR 60.4305(a), and are therefore subject to
40 CFR Part 60, Subpart GG for Stationary Gas Turbines.
Note: To qualify for this non-applicability, the Permittee
has certified that the turbines have not been modified or
reconstructed after February 18, 2005.
b.
The affected turbines are not subject to the National
Emissions Standards for Hazardous Air Pollutants for
Stationary Combustion Turbines, 40 CFR Part 63, Subpart
YYYY, because the affected turbines are not located at a
major source of HAP emissions, pursuant to 40 CFR 63.6085.
c.
The affected turbines are not subject to 35 rAC 212.321 or
212.322, due to the unique nature of such units, a process
weight rate can not be set so that such rules can not
reasonably be applied, pursuant to 35 rAC 212.323.
d.
The affected turbines are not subject to 35 rAC 217.141 or
35 rAC 216.121 because the affected turbines are not fuel
combustion units, as defined by 35 rAC 211.2470.
e.
The affected turbines are not subject to 40 CFR Part 64,
Compliance Assurance Monitoring (CAM) for Major Stationary
Sources:
i.
For NO
x
and 80
2
,
because:
A.
The affected turbines are subject to a NSPS
proposed after November 15, 1990, pursuant to
40 CFR 64.2(b)(1)(i).
B.
The affected turbines are subject to Acid Rain
Program requirements, pursuant to 40 CFR
64.2 (b) (1) (iii) .
C.
The affected turbines are subject to an
emission limitation or standard for which this
CAAPP permit specifies a continuous compliance
determination method, pursuant to 40 CFR
64.2
(b) (1)
(vi) .
ii.
For PM, VOM, and CO because the affected turbines do
not use an add-on control device to achieve
compliance with an emission limitation or standard.
62
7.2.5
Control Requirements and Work Practices
a.
i.
At all times, including periods of startup, shutdown,
and malfunction, the source owner or operator shall,
to the extent practicable, maintain and operate any
affected turbine in a manner consistent with good air
pollution control practice for minimizing emissions.
ii.
The source owner or operator shall operate the
affected turbines in accordance with written
operating procedures that shall include at a minimum
the following measures:
A.
Review of operating parameters of the unit
during startup or shutdown as necessary for the
proper operation of the affected turbine with
appropriate adjustments to reduce emissions.
B.
Implementation of inspection and repair
procedures for a affected turbine prior to
attempting startup following repeated trips.
iii. The source owner or operator shall maintain the
affected turbines in accordance with written
procedures that shall include at a minimum the
following measures:
I...
Y.E:less s13eeifiea OR a more freEfUeRt Basis BY
ffiaft'dfae1z:\:lre:c's '.J:Fit'Gen iFl:st:c'tletions
I
an
iHs13ectiea of emissions relates com13oneE:ts
sHall Be eOfR13letes Ejl:larterly.
IE:s13eetioas
sHall Be eonEiuetea in aecorElanee KitH
maE:1::lfaetl:lrer's ;:rit'EoeE: iEstrl:letiofl:s.
B.
Repair and routine replacement of emissions-
related components.
iv.
The above procedures may incorporate the
manufacturer's written instruction for operation and
maintenance of the affected turbines and associated
control systems. The source owner or operator shall
review these procedures at least every two years and
shall revise or enhance them if necessary to be
consistent with good air pollution control practice
based on the actual operating experience and
performance of the source.
b.
Distillate fuel oil shall be the only fuel fired in the
affected turbine.
63
7.2.6
7.2.7
Production and Emission Limitations
Production and emission limitations are not set for the affected
turbine. However, there are source-wide production and emission
limitations set forth in Condition 5.6.
Testing Requirements
a.
The nitrogen oxides (NO
x
)
emissions, and the oxygen (0,)
concentration and opacity of exhaust shall be measured for
the affected turbines at the source owner or operator's
expense by an independent testing service approved by the
Illinois EPA as follows to determine compliance with
applicable emission limits:
i.
Within 120 days after a written request from the
Illinois EPA, for such pollutants listed above as
specified by the request.
ii.
Any extension to these time periods that may be
provided at its discretion by the Illinois EPA shall
not alter the source owner or operator's obligation
to perform emission testing for purposes of the NSPS
in a timely manner as specified by 40 CFR 60.8.
b.
The following methods and procedures shall be used for
testing of emissions:
i.
The USEPA Reference Test Methods shall be used
including the following:
ii.
Opacity
Nitrogen Oxides
USEPA Method 9
USEPA
Method 20
A.
Pursuant to 40 CFR 60.335(b), the owner or
operator shall determine compliance with the
applicable nitrogen oxides emission limitation
in 40 CFR 60.332 and shall meet the performance
test requirements of 40 CFR 60.8 as follows:
For each run of the performance test, the mean
nitrogen oxides emission concentration (NO
xo
)
corrected to 15 percent 0, shall be corrected to
ISO standard conditions using the following
equation. Notwithstanding this requirement,
use of the ISO correction equation is optional
for:
Lean premix stationary combustion
turbines; units used in association with heat
recovery steam generators (HRSG) equipped with
duct burners; and units equipped with add-on
emission control devices, pursuant to 40 CFR
60.335 (b) (1) :
64
NO
x
=
(NO
xo
)
(P
r
/P
o
)0.5 e19(H
o
-0.00633)
(288°K/Ta)1.53
Where:
NO
x
= emission concentration of NO
x
at 15
percent 0, and ISO standard ambient
conditions, ppm by volume, dry basis
NO
xo
= mean observed NO
x
concentration, ppm by
volume, dry basis, at 15 percent O
2
P
r
= reference combustor inlet absolute
pressure at 101.3 kilopascals ambient
pressure, rom Hg
Po
=observed combustor inlet absolute
pressure at test, rom Hg
Ho
=
observed humidity of ambient air, g H, O/g
air
e
=
transcendental constant, 2.718
Ta
= ambient temperature, oK
The 3-run performance test required by 40 CFR
60.8 must be performed within
±
5 percent at
30, 50, 75, and 90-to-100 percent of peak load
or at four evenly-spaced load points in the
_
normal .Dperating .range. of the gas turbine,
including the minimum point in the operating
range and 90-to-100 percent of peak load, or at
the highest achievable load point if 90-to-100
percent of peak load cannot be physically
achieved in practice. If the turbine combusts
both oil and gas as primary or backup fuels,
separate performance testing is required for
each fuel. Notwithstanding these requirements,
performance testing is not required for any
emergency fuel (as defined in 40 CFR 60.331),
pursuant to 40 CFR 60.335(b) (2).
If water or steam injection is used to control
NO
x
with no additional post-combustion NO
x
control and the owner or operator chooses to
monitor the steam or water to fuel ratio in
accordance with 40 CFR 60.334(a), then that
monitoring system must be operated concurrently
with each EPA Method 20, ASTM D6522-00
(incorporated by reference, see 40 CFR 60.17),
or EPA Method 7E run and shall be used to
determine the fuel consumption and the steam or
water to fuel ratio necessary to comply with
65
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
the applicable 40 CFR 60.332 NO, emission limit,
pursuant to 40 CFR 60.335(b) (4).
If the owner or operator elects to install a
CEMS, the performance evaluation of the CEMS
may either be conducted separately (as
described in 40 CFR 63.335(b) (7)) or as part of
the initial performance test of the affected
unit, pursuant to 40 CFR 60.335(b) (6).
Pursuant to 40 CFR 60.335(b) (7), if the owner
or operator elects to install and certify a NO
x
CEMS under 40 CFR 60.334(e), then the initial
performance test required under 40 CFR 60.8 may
be done in the following alternative manner:
Perform a minimum of 9 reference method runs,
with a minimum time per run of 21 minutes, at a
single load level, between 90 and 100 percent
of peak (or the highest physically achievable)
load, pursuant to 40 CFR 60.335(b) (7) (i).
Use the test data both to demonstrate
compliance with the applicable NO
x
emission
limit under 40 CFR 60.332 and to provide the
required reference method data for the RATA of
the CEMS described under 40 CFR 60.334(b)
pursuant to 40 CFR 60.335(b) (7) (ii).
The requirement to test at three additional
load levels is waived, pursuant to 40 CFR
60.335(b)
(7)
(iii).
If the owner or operator elects under 40 CFR
60.334(f) to monitor combustion parameters or
parameters indicative of proper operation of NO
x
emission controls, the appropriate parameters
shall be continuously monitored and recorded
during each run of the initial performance
test, to establish acceptable operating ranges,
for purposes of the parameter monitoring plan
for the affected unit, as specified in 40 CFR
60.334(g), pursuant to 40 CFR 60.335(b) (8).
Pursuant to 40 CFR 60.335(b) (10), if the owner
or operator is required under 40 CFR
60.334(i) (1) or (3) to periodically determine
the sulfur content of the fuel combusted in the
turbine, a minimum of three fuel samples shall
be collected during the performance test.
Analyze the samples for the total sulfur
content of the fuel using:
66
For gaseous fuels, ASTM D1072-S0, 90
(Reapproved 1994); D3246-S1, 92, 96; D446S-S5
(Reapproved 2000); or D6667-01 (all of which
are incorporated by reference, see 40 CFR
60.17). The applicable ranges of some ASTM
methods mentioned above are not adequate to
measure the levels of sulfur in some fuel
gases. Dilution of samples before analysis
(with verification of the dilution ratio) may
be used, subject to the prior approval of the
Administrator, pursuant to 40 CFR
60.335 (b) (10) (ii).
The fuel analyses required under 40 CFR
63.335(b) (9) and (b) (10) may be performed by
the owner or operator, a service contractor
retained by the owner or operator, the fuel
vendor, or any other qualified agency, pursuant
to 40 CFR 60.335(b) (11).
B.
Pursuant to 40 CFR 60.335(c), the owner or
operator may use the following as alternatives
to the reference methods and procedures
specified in this section:
Instead of using the equation in 40 CFR
63.335(b) (1), manufacturers may develop ambient
condition correction factors to adjust the
nitrogen oxides emission level measured by the
performance test as provided in 40 CFR 60.S to
ISO standard day conditions, pursuant to 40 CFR
60.335(c) (1).
c.
At least 60 days prior to the actual date of testing, a
written test plan shall be submitted to the Illinois EPA
for review. This plan shall describe the specific
procedures for testing and shall include as a minimum:
i.
The person(s) who will be performing sampling and
analysis and their experience with similar tests.
ii.
The specific conditions under which testing shall be
performed including a discussion of why these
conditions will be representative of maximum
emissions and the means by which the operating
parameters for the turbine will be tracked and
recorded.
iii. The specific determinations of emissions that are
intended to be made, including sampling and
monitoring locations; the test method(s) that will be
used, with the specific analysis method, if the
method can be used with different analysis methods.
The source owner or operator may also propose a plan
67
for testing across the normal operating range of the
affected turbines.
d.
The Illinois EPA shall be notified prior to these tests to
enable the Illinois EPA to observe these tests.
Notification of the expected date of testing shall be
submitted a minimum of thirty (30) days prior to the
expected date. Notification of the actual date and
expected time of testing shall be submitted a minimum of
five (5) working days prior to the actual date of the test.
The Illinois EPA may, at its discretion, accept
notifications with shorter advance notice provided that the
Illinois EPA will not accept such notifications if it
interferes with the Illinois EPA's ability to observe the
testing.
e.
The Final Report for these tests shall be submitted to the
Illinois EPA within 60 days after the date of the tests.
The Final Report shall include as a minimum:
f.
i.
A summary of results.
ii.
General information.
iii. Description of test method(s), including description
of sampling points, sampling train, analysis
equipment and test schedule.
iv.
Detailed description of test conditions, including:
A.
_fuel consumption (standard ft') .
B.
Firing rate (million Btu/hr) .
c.
Turbine/Generator output rate (MW).
v.
Data and calculations, including copies of all raw
data sheets and records of laboratory analyses,
sample calculations, and data on equipment
calibration.
i.
Upon written request by the Illinois EPA, the source
owner or operator shall have the opacity of the
exhaust from the affected turbine(s) tested during
representative operating conditions as determined by
a qualified observer in accordance with USEPA Test
Method 9, as further specified below, pursuant to
Section 39.5(7) (d) of the Act.
ii.
Such testing shall be conducted for specific
turbine(s) within 90 calendar days of the request, or
on the date turbine(s) next operates, or on the date
agreed upon by the Illinois EPA, whichever is later.
68
iii. The duration of opacity observations for each test
shall be at least 30 minutes (five 6-minute averages)
unless the average opacities for the first 12 minutes
of observations (two six-minute averages) are both
less than 10.0 percent.
iv.
The source owner or operator shall notify the
Illinois EPA at least 7 days in advance of the date
and time of these tests, in order to allow the
Illinois EPA to witness testing. This notification
shall include the name and employer of the qualified
observer(s) .
v.
The source owner or operator shall promptly notify
the Illinois EPA of any changes in the time or date
for testing.
vi.
The source owner or operator shall provide a copy of
its observer's readings to the Illinois EPA at the
time of testing, if Illinois EPA personnel are
present.
vii. The source owner or operator shall submit a written
report for this testing within 30 days of the date of
testing. This report shall include:
A.
Date and time of testing.
B.
Name and employer of qualified observer.
C.
_Copy of current certification.
D.
Description of observation conditions.
E.
Description of turbine operating conditions.
F.
Raw data.
G.
Opacity determinations.
H.
Conclusions.
7.2.8
Monitoring Requirements
a.
If an affected turbine is routinely operated or
exercised to confirm that the turbine will operate
when needed, the operation and opacity of the
affected turbine shall be formally observed by
operating personnel for the affected turbine or a
member
of source owner or operator's environmental
staff on a regular basis to assure that the affected
turbine is operating properly, which observations
shall be made at least every six months.
69
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
b.
ii.
If an affected turbine is not routinely operated or
exercised, i.e., the time interval between operation
of an affected turbine is typically greater than six
months, the operation and opacity of the affected
turbine shall be formally observed as provided above
each time the source owner or operator carries out a
scheduled exercise of the affected turbine.
iii.
~He
souree
ev.~er
SF operator snaIl also eOHauot
formal GBscr?atioBs of eperatisa aRe epaeity of aR
affeeteEl t"rleiRe ""SR '"ritteR re""est BY the IlliRsis
EPA. With the agreemeRt sf the IlliReis EPA, the
seuree o:mcr or eperater may soaoaule those
e13servatioFlS to
tahoe
I?laee Ell:1:riF.!:§"
perieas ' ..
'aca
it
' .. 's"lEl ether-dse Be s"eratiRg the affeeteEl t"rleiRe.
Note: The formal observation required above is not
intended to be a USEPA Test Method 9 opacity test, nor does
the observation require a USEPA Test Method 9 certified
observer. It is intended to be performed by personnel
familiar with the operation of the affected turbine who
would be able to make a determination based from the
observed opacity as to whether or not the affected turbine
was running properly, and subsequently initiate a
corrective action if necessary.
i.
The owner or operator of an affected turbine subject
to 35 lAC 217 Subpart V (Condition 7.2.3(e)) shall
install, calibrate, maintain and operate continuous
emissions monitoring systems (CEMS) for NO
x
that meet
the requirements of 40 CFR 75, Subpart B [35 lAC
217.710 (a) ] .
ii.
Notwithstanding 35 lAC 217.710(a) above, the owner or
operator of a gas-fired peaking unit or oil-fired
peaking unit as defined in 40 CFR 72.2 may determine
NO
x
emissions in accordance with the emissions
estimation protocol of 40 CFR 75, Subpart E [35 lAC
217.710
(b) ] .
iii. Notwithstanding 35 lAC 217.710(a) above, the owner or
operator of a combustion turbine that operates less
than 350 hour per ozone control period may determine
the heat input and NO
x
emissions of the turbine as
follows
[35 lAC 217.710(c)]:
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbine's maximum hourly heat input and hours
of operation as recorded by operating
instrumentation on the turbine [35 lAC
217.710(c) (1)].
70
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.2.9
B.
NO
x
emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO
x
emission factors below
[35 lAC 217.710 (c) (2)] :
0.7 lbs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
Recordkeeping Requirements
In addition to the records required by Condition 5.9, the source
owner or operator shall maintain records of the following items
for the affected turbine(s) to demonstrate compliance with
Conditions 5.6.1, 7.2.3, 7.2.5, and 7.2.6, pursuant to Section
39.5(7) (b) of the Act:
a.
The owner or operator of an affected turbine subject to the
requirements of 35 lAC 217 Subpart V (Condition 7.2.3(e»
shall:
i.
Comply with the recordkeeping and reporting
requirements of 40 CFR 75 applicable to NO
x
emissions
during the ozone control period, including, but not
limited to, 40 CFR 75.54 (b) and (d)
[35 lAC
217.712 (a) ] .
ii.
Notwithstanding 35 lAC 217.712(a) above, the owner or
operator of a combustion turbine for which heat input
and NO
x
emissions are determined pursuant to 35 lAC
217.710 (c) (Condition 7.2.8 (c) (iii»
shall comply
with. the following recordkeeping and reporting
requirements
[35 lAC 217.712(b)]:
A.
Maintain records of the heat input and NO
x
emissions of the turbine as determined in
accordance with 35 lAC 217.710(c), and records
of metered fuel use or bperating hours used to
determine heat input [35 lAC 217.712(b) (1)].
b.
The source owner or operator shall maintain records of the
following items:
i.
The sulfur content of the fuel oil used to fire the
turbines as determined in accordance with Condition
7.2.8(b) .
ii.
A copy of the Final Report(s) for emission testing
conducted pursuant to Condition 7.2.7.
iii. Copies of opacity determinations taken for the source
by qualified observer(s) when using USEPA Method 9.
71
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
iv.
Records documenting its periodic review of its
operating procedures as required by Condition
7.2.5(a) .
v.
Information for the formal observations of opacity
conducted pursuant to Condition 7.2.8(a). For each
occasion on which observations are made, these
records shall include the date, time, identity of the
observer, a description of the various observations
that were made, whether or not the affected engine
was running properly, and whether or not corrective
action is necessary and was subsequently initiated.
c.
A maintenance and repair log for the affected turbine,
listing each activity performed with date.
d.
The sulfur content of the fuels fired in the affected
turbine.
e.
Fuel consumption for the affected turbine for each type of
fuel, 1,000 gallon/month and 1,000 gallon/year.
f.
Reserved for Future Use
g.
Operating hours for the affected turbine, hr/month and
hr/year.
h.
Heat content of the fuel being fired in the affected
turbine.
i.
Emissions
ofeach~~pollutant
from the affected turbine,
including emissions from startups, with supporting
calculations including documentation on the validity of the
emission factors used, ton/month and ton/year.
j.
The source owner or operator shall maintain records that
identify:
i.
Any periods during which a continuous monitoring
system was not operational, with explanation.
ii.
Any day in which emission and/or opacity exceeded an
applicable standard or limit.
k.
The source owner or operator shall keep records of good
operating practices for each turbine.
1.
'PRe seuree eT.ffler sr SfJcraEsr oRall maiFlE:aiFl ERe fslls\,riFlg
reeeras relaEea te eacR SRUESetm of ERe
EHr~iFles.
i.
'±'flo
fello'.dFlg iFlformaEieE for caGa SRUESO'.ffi sf a
Euri3iEo.
1>L.
Dat=;c aHa time of sRHtss;;'n.
72
B.
A aeseriptieR ef tfie sfiuta8'o1R, if ."ritteR
8}?oratiB§" preeeE1'l:l:res are Het f0118";08: OOriB§"
tHe sfiutae:m eF
si~ifieaHt
proBlems seeur
EluriR§' tfie sfiutae,m, iReluaiB§, aetailea
OJEI31aaatisn.
ii.
'±'RC follsljda§"
iafsERatisa
fer ERG t1:lrJaiacs
T ..
'43:ca a13070
BOFmal opacity Has ECCE: oBserveS. By searce pers8HFlcl.
~
....
'HarRe af OBserver, 1?9sitisa aHa reaseR fer 13eiE:§
at site.
B.
:gate
aHa
91:lratisFl:
sf
aseve
Flannal epaeity,
ineludin§" affeeteEl turJaine, start time anEl time
nermal oI?cratien ,.:a8 acfiievceL
C.
If E:ermal eperatisa ' .. rao
Bot acfiic'i"ree
1J:itl=dn 3 9
miF.l:utes
I
aa mE!?lanat:isE:
T •• 1fly
startU:,Fl eeulEl Hst
be achieveS. ..,ithin this time.
E.
A aetailea aeseriptisB sf tfie startup,
ineluaing reaSOR fer s}?cratien.
E.
lffi
el'PlaRatisR
.,my
estaalisfiea startup
13Feccell::lres eOl:llEi Hst so performoEl,
if
net
perfeEffiea.
F.
'Pfie "ature sf epaeH:y fslls"iR§, tfie eRa sf
start1:1-p or 39 miFl:1:ltes sf eperatieH, ..ffiiehever
scours
_.fi:l?st,_
aBE3: ___ E$:ra'EipB
.ef
eI?eratieFl blB'Eil
aohievemon'E ef ne:J:'mal e13aei'EJ' er SOO'Eamo'lL
G.
W<ietfier aR elESeeaaRee ef GeBaitisR 7.2.3 (a),
i.e., 39 13ereent eI3aeity, may Rave eeoblrree
e:iHrin§' s'Eartup, Ui'ER
~Ei?laH:atisFl
if qualifiea
eeserver 1i.'as en si'Ec.
fR.
Reeeras fsr Startup
'Fho Permi'E'Eoo sftall maiBtain 'Efte feller,dB§, roeeres,
pUrS1"aBt ts BeetieR 39.9 (7)
(B)
sf tfie Ae!:, fer eaefi
affeetea turBiBe suajeet te GSBaitisB 7.2.3(a),
,.~iefi
at a
miBifflUID sHall iBcluae.
i.
';PHe feller,dB§, iFlfsrmation fer eaea s'Ear'Eu13 of tao
affeetea tuFfiiBe(s) .
A.
Da'EC aHa aura'Eisn ef tao startup, i.e., start
time aHa time Flsrmal speratioH aeaicvoEl.
B.
If RSERal eperatisB .,.,as Ret aefiievea "itfiiB 39
mif.l:l:1tes, aB c3E)?laE:asisE: u.fiy start1:lI? esuld Est
be aeaievee. r,dtaiFl 'Efiis time.
73
C.
A aetailea
aeseri~tisH
sf tRe
start~,
iBclueiH§ reason fer
9~eratieB
aBe
\.~etBeF
ERO
precea1:lres 7.2.3
(f)
",lCre 1?crfermea.
lJ.
.'ill
6l'fllaaatisH ' ..
'£:,'
tRe
~rseeEffires
sf 7.2.3 (f)
ana eU,er estaalisRea
start~ ~rseeEffires
ee"la
Bst
Be
perfoFffioe, if Hot perfermee.
E.
WbetRer 6lEeeeaaRee sf CeHaitisR §, 3.2 aRa
7.2.3(13) may Rave eee"rrea a"riR"
start~.
If
aB 03Eceeaaace may nave eeclirree, aa 0::IE};31anatio:a
sf tae
nat1:lre
of
e13aeit~:l,
i. e.,
severity
aHa
duratioH, aariBg tao
start~
aBe tao Bature of
opacity at tRe eOHcl1:lsisB of startup.
F.
WRetaer eperatiH§ personael fer tae turBiacs or
air cFl:ViroE:mcatal staff are oa site ooriF1§
8tart1:1£).
ii.
A maiatcaaace aHa
r~air
lsg fer each affeetea
tureiFlC, listiF.l:§" each activity 1?crfermeEi ",dth Elate.
n.
Records for Malfunctions and Breakdowns
The Permittee shall maintain records, pursuant to 35 IAC
201.263, of continued operation of an affected turbine
subject to Condition 7.2.3(g) during malfunctions and
breakdown, which as a minimum, shall include:
_ i .__
Date and duration of malfunction or breakdown.
ii.
A detailed explanation of the malfunction or
breakdown.
iii.
An
explanation why the affected turbine continued to
operate in accordance with Condition 7.2.3(g).
iv.
The measures used to reduce the quantity of emissions
and the duration of the event.
v.
The steps taken to prevent similar malfunctions or
breakdowns or reduce their frequency and severity.
vi.
The amount of release above typical emissions during
malfunction/breakdown.
7.2.10 Reporting Requirements
a.
Reporting of Deviations
The source owner or operator shall promptly notify the
Illinois EPA, Air Compliance Unit, of deviations of the
affected turbine with the permit requirements as follows,
74
pursuant to Section 39.5(7) (f) (ii) of the Act. Reports
shall describe the probable cause of such deviations, and
any corrective actions or preventive measures taken:
i.
Emissions from the affected turbine in excess of the
limits specified in Condition 7.2.3 within 30 days of
such occurrence.
ii.
Operation of the affected turbine in excess of the
limits specified in Condition 7.2.5 within 30 days of
such occurrence.
b.
In conjunction with the Annual Emission Report required by
35 lAC Part 254, the source owner or operator shall provide
the operating hours for each affected turbine, the total
number of startups, the total fuel consumption during the
preceding calendar year.
c.
i.
Annually report the heat input and NO, emissions of
the turbine as determined in accordance with 35 lAC
217.710(c) (Condition 7.2.8(c) (iii)), for each ozone
control period, by November 30 of each year [35 lAC
217.712 (b) (2)
l.
ii.
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 report to the Illinois EPA
that demonstrates that the affected turbine has
complied with Condition 7.2.3(e). These reports
shall be accompanied by a certification statement
signed by a responsible official for the source owner
or operator as specified by 35 lAC 217.712(c).
a.
RO]3srtiH§ af Start'l:lf3s
The
seBree
sT .. 'Bcr
SF 8fJOrater
sHall s1:i13mit semi aE:Hldal
startu]3 rC]3orts te tao Illineis EPA 131:irs1:1ant t8 ScotisHs
39.9(7) (a) aH"
(f)
sf tEe Ast. TEese F""SFtS sEall ee
sl:lEmit.tea
alGa§"
\dth tao semi
anE:l:lal
rCf30rts rOEfl:lirea lay
GSH.l.itisH 7.2.19 (e) (ii) aHa sEall iHsluae tEe fslls"iH§,
iafermatisH for
start~s
of tao affeetea tl:lr13iHo GHriH§ the
rC]3SrtiR§ ]3oriee.
i.
A list sf tEe staFtUJ?s sf tEe affeste" turniHe,
iFwl"tiais§J the Elate
I
El:B:ration aE:a. e.eseriFltien of each
startl:1.fl, aeeem};3aHiea BY a CSl?Y 9f the rceeras
pUFsuaHt ts GSHel.itisH 7.2.9(i) fSF eaSE staFtup fSF
\."hiCH Sl;;lCH receras . ... ere ret;Il;;lireeL
ii.
If tHere eave seeB Be start1::l:.J?s sf aFl affeetea E:UrSiFlO
~riB~
tae repertiFl§ perieS, tHis saall 13e 5tatea iB
tEe
"""SFt.
75
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
e.
Reporting of Malfunctions and Breakdowns
The Permittee shall provide the following notification and
reports to the Illinois EPA, Air Compliance unit and
Regional Field Office, pursuant to 35 lAC 201.263,
concerning continued operation of an affected turbine
subject to Condition 7.2.3(g) during malfunction or
breakdown:
i.
A.
The Permittee shall notify the Illinois EPA's
regional office by telephone as soon as
possible during normal working hours, but no
later than three (3) days, upon the occurrence
of noncompliance due to malfunction or
breakdown.
B.
Upon achievement of compliance, the Permittee
shall give a written follow-up notice within 15
days to the Illinois EPA, Air Compliance Unit
and Regional Field Office, providing a detailed
explanation of the event, an explanation why
continued operation of the affected turbines
was necessary, the length of time during which
operation continued under such conditions, the
measures taken by the Permittee to minimize and
correct deficiencies with chronology, and when
the repairs were completed or when the affected
turbine was taken out of service.
C.
If
cornplia~ce
is not achieved within 5 working
days _of the occurrence, the Permittee shall
submit interim status reports to the Illinois
EPA, Air Compliance Unit and Regional Field
Office, within 5 days of the occurrence and
every 14 days thereafter, until compliance is
achieved. These interim reports shall provide
a brief explanation of the nature of the
malfunction or breakdown, corrective actions
accomplished to date, actions anticipated to
occur with schedule, and the expected date on
which repairs will be complete or the affected
turbine will be taken out of service.
ii.
In accordance with the due dates in Condition 8.6.1,
the Permittee shall submit semi-annual malfunction
and breakdown reports to the Illinois EPA pursuant to
Sections 39.5(7) (a) and (f) of the Act. These
reports may be submitted along with other semi-annual
reports and shall include the following information
for malfunctions and breakdowns of the affected
turbine during the reporting period:
A.
A listing of malfunctions and breakdowns, in
chronological order, that includes:
76
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
I.
The date, time, and duration of each
incident.
II.
The identity of the affected operation(s)
involved in the incident.
B.
Dates of the notices and reports of Conditions
7.2.10(f) (i).
C.
Any supplement information the Permittee wishes
to provide to the notices and reports of
Conditions 7.2.10(f) (i).
D.
The aggregate duration of all incidents during
the reporting period.
E.
If there have been nO such incidents during the
reporting period, this shall be stated in the
report.
7.2.11 Operational Flexibility/Anticipated Operating Scenarios
Operational flexibility is not set for the affected turbines.
7.2.12 Compliance Procedures
a.
Compliance with the PM emission limitations of Conditions
7.2.3(b) is addressed by the requirements of Condition
7.2.5, and the records required in Condition 7.2.9, and the
reports required in Condition 7.2.10.
b.
Compliance with the 80
2
emission limitations of Conditions
7.2.3(c) is addressed by the requirements of Condition
7.2.5, and the records required in Condition 7.2.9, and the
reports required in Condition 7.2.10.
c.
Compliance with the NO
x
emission limitations of
Conditions 7.2.3(d) is addressed by the requirements
of Condition 7.2.5, the testing requirements of
7.2.7, the monitoring requirements of 7.2.8, the
records required in Condition 7.2.9, and the reports
required in Condition 7.2.10(a).
ii.
Notwithstanding 35 IAC 217.710(a), Condition
7.2.8(d), the owner or operator of a gas-fired
peaking unit or oil-fired peaking unit as defined in
40 CFR 72.2 may determine NO
x
emissions in accordance
with the emissions estimation protocol of 40 CFR 75,
Subpart E [35 IAC 217.710(b)].
iii. Notwithstanding 35 IAC 217.710(a), Condition
7.2.8(d), the owner or operator of a combustion
turbine that operates less than 350 hour per ozone
77
control period may determine the heat input and NO.
emissions of the turbine as follows [35 rAC
217.710(c)J:
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbine'S maximum hourly heat input and hours
of operation as recorded
by
operating
instrumentation on the turbine [35 rAC
217.710 (c) (1) J.
B.
NO. emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO. emission factors below
[35 rAC 217.710 (c) (2) ] :
0.7 lbs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
78
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.3
Turbines CT03-CT05 (Subject to NSPS - 40 CFR Subpart GG)
7.3.1 Description
The turbines are process emission unit used to generate
electricity. The turbines are natural gas fired. The turbines
are equipped, operated, and maintained with low NO
x
combustor
systems to control NO
x
emissions. The turbines were constructed
pursuant to Construction Permit 03120068.
Note: This narrative description is for informational purposes
only and is not enforceable.
7.3.2
List of Emission Units and Air Pollution Control Equipment
Emission
Emission
Control
Unit
Description
Date Constructed
Equipment
CT03
and
Nominal
212 MWe
CT03 (May 28,
Dry Low NO
x
CT04
Natural Gas Fired
2005),
CT04
(May
Combustors
Turbine, each
24,
2005)
CT05
Nominal 135 MWe
September 29, 2005 Dry Low NO
x
Natural Gas Fired
Combustors
Turbine
7.3.3
Applicable Provisions and Regulations
a.
The "affected turbines" for the purpose of these unit-
specific conditions, are turbines described in Conditions
7.3.1 and 7.3.2.
b.
Pursuant to 35 rAC 212.123,
i.
No person shall cause or allow the emission of smoke
or other particulate matter, with an opacity greater
than 30 percent, into the atmosphere from any
emission unit.
ii.
The emission of smoke or other particulate matter
from any such emission unit may have an opacity
greater than 30 percent but not greater than 60
percent for a period or periods aggregating 8 minutes
in any 60 minute period provided that such opaque
emissions permitted during any 60 minute period shall
occur from only one such emission unit located within
a 1000 ft radius from the center point of any other
such emission unit owned or operated by such person,
and provided further that such opaque emissions
permitted from each such emission unit shall be
limited to 3 times in any 24 hour period.
c.
Pursuant to 35 lAC 214.301, no person shall cause or allow
the emission of sulfur dioxide into the atmosphere from any
process emission source to exceed 2000 ppm.
79
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
d.
The affected turbine is subject to the NSPS for Stationary
Gas Turbines, 40 CFR 60 Subparts A and GG, because the heat
input at peak load is equal to or greater than 10.7
gigajoules per hour (10 mmBtu/hr), based on the lower
heating value of the fuel fired and the affected turbine
commenced construction, modification, or reconstruction
after October 3, 1977. The Illinois EPA administers the
NSPS for subject sources in Illinois pursuant to a
delegation agreement with the USEPA.
i.
Standard for Nitrogen Oxides:
Pursuant to 40 CFR 60.332(b), electric utility
stationary gas turbines with a heat input at peak
load greater than 107.2 gigajoules per hour (100
million Btu/hour) based on the lower heating value of
the fuel fired shall comply with the provisions of 40
CFR 60.332(a) (1). Pursuant to 40 CFR 60.332(a) (1),
no owner or operator of an affected turbine shall"
cause to be discharged into the atmosphere from such
gas turbine, any gases which contain nitrogen oxides
in excess of:
STD
=
0.0075 (14.4) + F
Y
Where:
STD
=
Allowable NO. emissions (percent by volume at 15
percent oxygen and on a dry basis) .
y
~
Manufacturer's rated heat rate at
manufacturer's rated load (kilojoules per watt
hour) or, actual measured heat rate based on
lower heating value of fuel as measured at
actual peak load for the facility. The value
of Y shall not exceed 14.4 kilojoules per watt
hour.
F
~
NO
x
emission allowance for fuel-bound nitrogen
calculated from the nitrogen content of the
fuel as follows:
Fuel-bound nitrogen
F
(percent by weight)
(NO. percent by volume)
N
<
0.015
0
0.015
<
N
-
<
0.1
0.04
(N)
0.1
<
N
<
0.25
0.04
+
0.0067(N - 0.1)
N>
0.25
0.005
Where:
80
e.
N
; The nitrogen content of the fuel (percent by
weight) determined in according with Condition
7.3.8 (b) .
ii.
Standard for Sulfur Dioxide:
i.
Pursuant to 40 CFR 60.333, on and after the date on
which the performance test required to be conducted
by 40 CFR 60.B is completed, every owner or operator
subject to the provision of 40 CFR 60 Subpart GG
shall comply with one or the other of the following
conditions:
No owner or operator subject to the provisions of
this subpart shall cause to be discharged into the
atmosphere from any stationary gas turbine any gases
which contain sulfur dioxide in excess of 0.015
percent by volume at 15 percent oxygen and on a dry
basis, pursuant to 40 CFR 60.333(a).
No owner or operator subject to the provisions of
this subpart shall burn in any stationary gas turbine
any fuel which contains total sulfur in excess of 0.8
percent by weight (BOOO ppmw) , pursuant to 40 CFR
60.333 (b).
No owner or operator shall cause or allow the
emissions of NO
x
into the atmosphere from the affected
turbine to exceed 0.25 lbs/rnrnBtu of actual heat input
during each ozone control period from May 1 through
September 30, based on a ozone control period
average, for that unit [35 lAC 217.706(a)].
ii.
Notwithstanding the above emission limitation of 35
lAC 217.706(a), the affected turbine subject to a
more stringent NO
x
emission limitation pursuant to any
State or federal statute, including the Act, the
Clean Air Act, or any regulations promulgated
thereunder, shall comply with both the requirements
of 35 lAC 217 Subpart V and that more stringent
emission limitation [35 lAC 217.706(b)].
f.
Startup Provisions
Sul3j est te t!>e felle,,.iR§, teEnS aRe seBeitieRS, e!>e
Permittee is
aHtBori~ee
te
o~erate
tao affeetea turBines in
vielatieR ef t!>e """lisal31e staBdards iB CeBeitieR 7.3.3(l3)
ana t:he hS1:lrly limits in COF.l:e.iBioR 7.3. € 8.-Hriag start\:lf.l.
T!>is aut!>eri"atieB is "rayided "ursuaBt te 35 IAC 291.149,
291.161 aBe 291.262, as t!>e Permittee !>as """lied fer sue!>
aHtaorisatioa in its
ap~licatiefll
general I)!
aeseriBiRg tae
effort.s taat 1idll 130 1:::l:sea " ... ts miRimi:z;o st.art1:lf) emissioE:s,
d1:lratiofl of iRaiviEffial st:art.s, aRa
fro~efley
of s1::artl:lj?s."
81
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
i.
This authorization does not relieve the permittee
from the continuing obligation to demonstrate that
all reasonable efforts are made to minimize startup
emissions, duration of individual startups and
frequency of startups.
ii.
The Permittee shall conduct startup of the each
affected turbine(s) in accordance with written
procedures prepared by the Permittee and maintained
at the facility, in the control room for the each
affected turbine(s), that are specifically developed
to minimize emissions from startups and that include,
at a minimum, the following measures:
A.
The Permittee shall conduct startup of an
affected turbine in accordance with the
manufacturer's written instructions or other
written instructions prepared
by
the source
owner or operator and maintained on site.
B.
The Permittee shall take the following measures
to minimize emissions resulting from startups,
the duration of startups, and minimize the
frequency of startups:
I.
Operating in accordance with the
manufacturer's written operating and
startup procedures, including a pre-check
of the unit, or other written procedures
developed and maintained by the source
owner or operator so as to minimize the
duration of startups and the emissions
associated with startups. These
procedures should allow for review of
operating parameters of the unit during
startup, or shutdown as necessary to make
adjustments to reduce or eliminate excess
emissions.
II.
Maintaining units in accordance with
written procedures developed and
maintained by the source owner or
operator so as to minimize the duration
of startups and the frequency of
startups. These maintenance practices
shall include maintenance activities
before the unit is started up, when the
unit is in operation, and when the unit
is shut down.
III. The procedures described above shall be
reviewed at least annually to make
necessary adjustments and shall be made
82
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
available to the Illinois EPA upon
request.
iv.
'rae Permittee saall fulfill i3fl!.'liealsle reeenlkee!.'i,,§,
alia r8J.3erti,,§,
re~iremeHts
ef CeHaitieH 7.3.9(m) aHa
7.3.19(e) .
v.
As provided by 35 lAC 201.265, an authorization in a
permit for excess emissions during startup does not
shield a Permittee from enforcement for any violation
of applicable emission standard(s) that occurs during
startup and only constitutes a prima facie defense to
such an enforcement action provided that the
Permittee has fully complied with all terms and
conditions connected with such authorization.
g.
Malfunction and Breakdown Provisions
subject to the following terms and conditions, the
permittee is authorized to continue operation of an
affected turbine in violation of the applicable standards
in Condition 7.3.3(b) and the hourly emission limits in
Condition 7.3.6 in the event of a malfunction or breakdown
of the affected turbines. This authorization is provided
pursuant to 35 lAC 201.149, 201.161 and 201.262, as the
permittee has applied for such authorization in its
application, generally explaining why such continued
operation would be required to provide essential service or
to prevent risk of injury to personnel or severe damage to
equipment, and describing the measures that will be taken
to minimize emissions from any malfunctions and breakdowns.
This authorization supersedes the general prohibition in
Condition 9.2.3 against continued operation in such
circumstances.
i.
This authorization only allows such continued
operation as necessary to provide essential service
or prevent risk of injury to personnel or severe
damage to equipment and does not extend to continued
operation solely for the economic benefit of the
Permittee.
ii.
Upon occurrence of excess emissions due to
malfunction or breakdown, the Permittee shall as soon
as practical repair the turbine, remove the affected
turbine from service, or undertake other action so
that excess emissions cease.
iii. The Permittee shall fulfill the applicable
recordkeeping and reporting requirements of
Conditions 7.3.9(n) and 7.3.10(f). For these
purposes, time shall be measured from the start of
a
particular incident. The absence of excess emissions
for a short period shall not be considered to end the
83
incident if excess emissions resume. In such
circumstances, the incident shall be considered to
continue until corrective actions are taken so that
excess emissions cease or the Permittee takes the
affected turbines out of service.
iv.
Following notification to the Illinois EPA of a
malfunction or breakdown with excess emissions, the
permittee shall comply with all reasonable directives
of the Illinois EPA with respect to such incident,
pursuant to 35 lAC 201.263.
v.
This authorization does not relieve the Permittee
from the continuing obligation to minimize excess
emissions during malfunction or breakdown. As
provided by 35 lAC 201.265, an authorization in a
permit for continued operation with excess emissions
during malfunction and breakdown does not shield the
Permittee from enforcement for any such violation and
only constitutes a prima facie defense to such an
enforcement action provided that the Permittee has
fully complied with all terms and conditions
connected with such authorization.
7.3.4 Non-Applicability of Regulations of Concern
a.
The affected turbines are not subject to the New Source
Performance Standards (NSPS) for Stationary Combustion
Turbines, 40 CFR Part 60, Subpart KKKK, because the
affected turbines did not commence construction,
modification, or reconstruction after February 18, 2005
pursuant to 40 CFR 60.4305(a), and are therefore subject to
40 CFR Part 60, Subpart GG for Stationary Gas Turbines.
Note: To qualify for this non-applicability, the Permittee
has certified that the turbines have not been modified or
reconstructed after February 18, 2005.
b.
The affected turbines are not subject to the National
Emissions Standards for Hazardous Air Pollutants for
Stationary Combustion Turbines, 40 CFR Part 63, Subpart
YYYY, because the affected turbines are not located at a
major source of HAP emissions, pursuant to 40 CFR 63.6085.
c.
The affected turbines are not subject to 35 lAC 212.321 or
212.322, due to the unique nature of such units, a process
weight rate can not be set so that such rules can not
reasonably be applied, pursuant to 35 lAC 212.323.
d.
The affected turbines are not subject to 35 lAC 217.141 or
35 lAC 216.121 because the affected turbines are not fuel
combustion units, as defined by 35 IAC 211.2470.
84
7.3.5
e.
The affected turbines are not subject to 40 CFR Part 64,
Compliance Assurance Monitoring (CAM) for Major Stationary
Sources:
i.
For NO
x
and 80
2
,
because:
A.
The affected turbines are subject to a NSPS
proposed after November 15, 1990, pursuant to
40 CFR 64.2(b)(1)(i).
B.
The affected turbines are subject to Acid Rain
Program requirements, pursuant to 40 CFR
64.2 (b) (1) (iii).
C.
The affected turbines are subject to an
emission limitation or standard for which this
CAAPP permit specifies a continuous compliance
determination method, pursuant to 40 CFR
64.2 (b) (1) (vi) .
ii.
For PM, YOM, and CO because the affected turbines do
not use an add-on control device to achieve
compliance with an emission limitation or standard.
Control Requirements and Work Practices
a.
i.
At all times, including periods of startup, shutdown,
and malfunction, the source owner or operator shall,
to the extent practicable, maintain and operate any
affected turbine in a manner consistent with good air
_ .
_pollution. _control practice for minimizing emissions.
Determination of whether acceptable operating and
maintenance procedures are being used will be based
on information available to the Illinois EPA or the
USEPA which may include, but is not limited to,
monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection
of the source [40 CFR 60.11(d)].
ii.
The source owner or operator shall operate the
affected turbines in accordance with written
operating procedures that shall include at a minimum
the following measures:
A.
Review of operating parameters of the unit
during startup or shutdown as necessary for the
proper operation of the affected turbine with
appropriate adjustments to reduce emissions.
B.
Implementation of inspection and repair
procedures for a affected turbine prior to
attempting startup following repeated trips.
85
b.
c.
iii. The source owner or operator shall maintain the
affected turbines in accordance with written
procedures that shall include at a minimum the
following measures:
A.
DRless s!3eeifies. oa a morc frcEfl:;lcat Basis BY
m.anl:ifaetlirer's ',;ritteR iRstruetioas, an
ias!3eetioR of emissieas relateS. eem.!3oacats
saall
Be
eeffi~letee ~~aFteFly.
IBs~eetieBS
shall be eeBGaetes. ia aeeers.aBce ',lith
maE:1:lfaeturer's ' .. tritteB iBstrl::1cticBS,
B.
Repair and routine replacement of emissions-
related components.
iv.
The above procedures may incorporate the
manufacturer's written instruction for operation and
maintenance of the affected turbines and associated
control systems. The source owner or operator shall
review these procedures at least every two years and
shall revise or enhance them if necessary to be
consistent with good air pollution control practice
based on the actual operating experience and
performance of the source.
i.
The Permittee shall manage the operation of the
affected turbines to minimize multiple startups of a
turbine in a single day, unless the turbine is
tripped off during startup, and to provide adequate
time for normal startup of the turbines, except for
"quick starts" that are due to requests for immediate
delivery of power, as would result from unexpected
loss of a transmission line or other generating
capacity.
ii.
Except during startup or shutdown of a affected
turbine or for the purpose of emission testing, the
Permittee shall not operate turbines below 75 percent
load, or load at which emission testing conducted in
accordance with Condition 7.3.7 has demonstrated
compliance with the applicable hourly emission limits
in Conditions 7.3.6.
i.
The only fuel fired in the affected turbines shall be
natural gas.
ii.
The Permittee shall not fire more than 5,500 million
standard cubic feet of natural gas per year
(mmscf/yr) total, in the affected turbines.
Compliance with this limit shall be determined from a
running total of 12 months of data.
iii. Each affected turbine shall be equipped, operated,
and maintained with dry low NO
x
combustors to control
86
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.3.6
NO
x
emissions.
(Dry low NO
x
operation of the burners
may be supplemented with small amounts of water to
further control emissions of NO
x
')
Production and Emission Limitations
In addition to Condition 5.3.2 and the source-wide emission
limitations in Condition 5.6, the affected turbines are subject
to the following:
a.
Hourly emissions from affected turbine CT03 and CT04 each
shall not exceed the following limitations except during
startup and malfunction or breakdown:
Lb/Hr
120.0
NO,
Lb/mmBtu
0.057*
Lb/Hr
49.0
CO
Lb/mmBtu
0.023*
YOM
Lb/Hr
3.3
PM/PM"
Lb/Hr
10.4
SO,
Lb/Hr
1.3
*
Based on Higher Heating Value (HHV) of the Fuel.
For NOx
t
for which continuous monitoring is performed, the
compliance time period is 24 hours or the portion of each
calendar day that a turbine operates. For the other
pollutants, the compliance time period is three hours
(three test) .
b.
Hourly emissions from affected turbine CT05 shall not
exceed the following limitations except during startup and
malfunction or breakdown:
Lb/Hr
83.0
NO
x
Lb/mmBtu
0.054*
LbIHr
69.0
CO
Lb/mmBtu
0.045*
YOM
Lb/Hr
3.0
PM/PM"
Lb/Hr
10.4
SO,
Lb/Hr
0.9
*
Based on Higher Heating Value (HHV) of the Fuel.
NOx, for which continuous monitoring is performed, the
compliance time period is 24 hours or the portion of each
calendar day that a turbine operates. For the other
pollutants, the compliance time period is three hours
(three test).
c.
The total annual emissions from the affected turbines shall
not exceed the following limitations. Compliance with
these limitations shall be determined as a running total of
12 months of emission data.
NO
x
Tons/Yr
172 .4
CO
Tons/Yr
96.1
YOM
Tons/Yr
14.6
PM/PM
,
•
Tons/Yr
5.0
SO,
Tons/Yr
5.0
d.
For purpose of determining compliance with the limitations
in Condition 7.3.6(c):
87
7.3.7
i.
Emissions of NO
x
shall be determined by continuous
emission monitoring in accordance with Condition
7.3.8.
ii.
Emissions shall be determined from emission factors
developed from testing in accordance with Condition
7.3.7 (CO, VOM and PM/PM
,
,) and analysis of fuel
sulfur content or standard factors (SO,), unless
emission ,monitoring is performed for a pollutant.
iii. A.
Notwithstanding the above, for affected
turbines CT03 and CT04 for CO and VOM, unless
an alternative factor is established or
emissions monitoring is performed, emissions of
CO and VOM from turbine CT03 and CT04 during an
hour that includes a startup shall be presumed
to be 1,800 and 2,600 percent respectively of
the limits in Condition 7.3.6(a), i.e. CO and
VOM emissions during an hour with a startup
shall be presumed to be 882 lb/hr and 85.8
lb/hr, respectively.
B.
Notwithstanding the above, for affected turbine
CT05 for CO and VOM, unless an alternative
factor is established or emissions monitoring
is performed, emissions of CO and VOM from
turbine CT05 during an hour that includes a
startup shall be presumed to be 625 and 1,100
percent respectively of the limits in Condition
7.3.6(b)
C.
Any alternative factor for emissions during
startup of a turbine shall be based on
representative emission testing conducted with
USEPA Reference Test Methods.
(Refer to
Condition 7.3.7)
e.
Compliance with annual limits shall be determined on a
monthly basis from the sum of the data for the current
month plus the preceding 11 months (running 12 month total)
[Tll .
f.
The above limitations were established in Permit 03120068,
pursuant to PSD. These limits ensure that the construction
and/or modification addressed in the aforementioned permit
does not constitute a new major source or major
modification pursuant to Title
I
of the CAA, specifically
the federal rules for PSD [Tll.
Testing Requirements
a.
The nitrogen oxides (NO
x
)
emissions, and the oxygen (0,)
concentration and opacity of exhaust shall be measured for
the affected turbines at the source owner or operator's
88
expense by an independent testing service approved by the
Illinois EPA as follows to determine compliance with
applicable emission limits:
i.
Within 120 days after a written request from the
Illinois EPA, for such pollutants listed above as
specified by the request.
ii.
Any extension to these time periods that may be
provided at its discretion by the Illinois EPA shall
not alter the source owner or operator's obligation
to perform emission testing for purposes of the NSPS
in a timely manner as specified by 40 CFR 60.8.
b.
The following methods and procedures shall be used for
testing of emissions:
i.
The USEPA Reference Test Methods shall be used
including the following:
ii.
Opacity
Nitrogen Oxides
. USEPA Method 9
USEPA Method 20
A.
Pursuant to 40 CFR 60.335(b), the owner or
operator shall determine compliance with the
applicable nitrogen oxides emission limitation
in 40 CFR 60.332 and shall meet the performance
test requirements of 40 CFR 60.8 as follows:
For each run of the performance test, the mean
nitrogen oxides emission concentration (NOxa)
corrected to 15 percent 0, shall be corrected to
ISO standard conditions using the following
equation. Notwithstanding this requirement,
use of the ISO correction equation is optional
for:
Lean premix stationary combustion
turbinesi units used in association with heat
recovery steam generators (HRSG) equipped with
duct burners; and units equipped with add-on
emission control devices, pursuant to 40 CFR
60.335 (b) (1) :
NO
x
= (NO
xo
) (Pr/P
o)
0.5 e19 (Ho-O. 00633)
(288°K/Ta) 1. 53
Where:
NO
x
=
emission concentration of NO
x
at 15
percent 0, and ISO standard ambient
conditions, ppm by volume, dry basis
NO
xo
=
mean observed NO
x
concentration, ppm by
volume, dry basis, at 15 percent O
2
89
P
r
= reference combustor inlet absolute
pressure at 101.3 kilopascals ambient
pressure, rnrn Hg
Po
;observed combustor inlet absolute
pressure at test, rnrn Hg
Ho
; observed humidity of ambient air, g H,
Dig
air
e
= transcendental constant, 2.718
Ta
= ambient temperature, OK
The 3-run performance test required by 40 CFR
60.8 must be performed within
±
5 percent at
30, 50, 75, and 90-to-100 percent of peak load
or at four evenly-spaced load points in the
normal operating range of the gas turbine,
including the minimum point in the operating
range and 90-to-100 percent of peak load, or at
the highest achievable load point if 90-to-100
percent of peak load cannot be physically
achieved in practice. If the turbine combusts
both oil and gas as primary or backup fuels,
separate performance testing is required for
each fuel. Notwithstanding these requirements,
performance testing is not required for any
emergency fuel (as defined in 40 CFR 60.331),
pursuant to 40 CFR 60.335(b) (2).
If water or steam injection is used to control
NO
x
with no additional post-combustion NO
x
control and the owner or operator chooses to
monitor the steam or water to fuel ratio in
accordance with 40 CFR 60.334(a), then that
monitoring system must be operated concurrently
with each EPA Method 20, ASTM D6522-00
(incorporated by reference, see 40 CFR 60.17),
or EPA Method 7E run and shall be used to
determine the fuel consumption and the steam or
water to fuel ratio necessary to comply with
the applicable 40 CFR 60.332 NO
x
emission limit,
pursuant to 40 CFR 60.335(b) (4).
If the owner or operator elects to install a
CEMS,
the performance evaluation of the CEMS
may either be conducted separately (as
described in 40 CFR 63.335(b) (7)) or as part of
the initial performance test of the affected
unit, pursuant to 40 CFR 60.335(b) (6).
Pursuant to 40 CFR 60.335(b) (7), if the owner
or operator elects to install and certify a NO
x
90
CEMS under 40 CFR 60.334(e), then the initial
performance test required under 40 CFR 60.8 may
be done in the following alternative manner:
Perform a minimum of 9 reference method runs,
with a minimum time per run of 21 minutes, at a
single load level, between 90 and 100 percent
of peak (or the highest physically achievable)
load, pursuant to 40 CFR 60.335(b) (7) (i).
Use the test data both to demonstrate
compliance with the applicable NO
x
emission
limit under 40 CFR 60.332 and to provide the
required reference method data for the RATA of
the CEMS described under 40 CFR 60.334(b)
pursuant to 40 CFR 60.335(b) (7) (ii).
The requirement to test at three additional
load levels is waived, pursuant to 40 CFR
60.335 (b) (7) (iii).
If the owner or operator elects under 40 CFR
60.334(f) to monitor combustion parameters or
parameters indicative of proper operation of NO
x
emission controls, the appropriate parameters
shall be continuously monitored and recorded
during each run of the initial performance
test, to establish acceptable operating ranges,
for purposes of the parameter monitoring plan
for the affected unit, as specified in 40 CFR
60.334(gL, pursuanLto 40 CFR 60.335(b) (8).
Pursuant to 40 CFR 60.335(b) (10), if the owner
or operator is required under 40 CFR
60.334(i) (1) or (3) to periodically determine
the sulfur content of the fuel combusted in the
turbine, a minimum of three fuel samples shall
be collected during the performance test.
Analyze the samples for the total sulfur
content of the fuel using:
For gaseous fuels, ASTM Dl072-80, 90
(Reapproved 1994); D3246-81, 92, 96; D4468-85
(Reapproved 2000); or D6667-01 (all of which
are incorporated by reference, see 40 CFR
60.17). The applicable ranges of some ASTM
methods mentioned above are not adequate to
measure the levels of sulfur in some fuel
gases. Dilution of samples before analysis
(with verification of the dilution ratio) may
be used, subject to the prior approval of the
Administrator, pursuant to 40 CFR
60.335 (b) (10) (ii).
91
The fuel analyses required under 40 CFR
63.335(b) (9) and (b) (10) may be performed by
the owner or operator, a service contractor
retained by the owner or operator, the fuel
vendor, or any other qualified agency, pursuant
to 40 CFR 60.335(b) (11).
B.
Pursuant to 40 CFR 60.335(c), the owner or
operator may use the following as alternatives
to the reference methods and procedures
specified in this section:
Instead of using the equation in 40 CFR
63.335(b) (1), manufacturers may develop ambient
condition correction factors to adjust the
nitrogen oxides emission level measured by the
performance test as provided in 40 CFR 60.8 to
ISO standard day conditions, pursuant to 40 CFR
60.335 (c) (1) .
c.
At least 60 days prior to the actual date of testing, a
written test plan shall be submitted to the Illinois EPA
for review. This plan shall describe the specific
procedures for testing and shall include as a minimum:
i.
The person(s) who will be performing sampling and
analysis and their experience with similar tests.
ii.
The specific conditions under which testing shall be
performed including a discussion of why these
conditions will be representative of maximum
emissions and the means by which the operating
parameters for the turbine will be tracked and
recorded.
iii. The specific determinations of emissions that are
intended to be made, including sampling and
monitoring locations; the test method(s) that will be
used, with the specific analysis method, if the
method can be used with different analysis methods.
The source owner or operator may-also propose a plan
for testing across the normal operating range of the
affected turbines.
d.
The Illinois EPA shall be notified prior to these tests to
enable the Illinois EPA to observe these tests.
Notification of the expected date of testing shall be
submitted a minimum of thirty (30) days prior to the
expected date. Notification of the actual date and
expected time of testing shall be submitted a minimum of
five (5) working days prior to the actual date of the test.
The Illinois EPA may, at its discretion, accept
notifications with shorter advance notice provided that the
Illinois EPA will not accept such notifications if it
92
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
interferes with the Illinois EPA's ability to observe the
testing.
e.
The Final Report for these tests shall be submitted to the
Illinois EPA within 60 days after the date of the tests.
The Final Report shall include as a minimum:
f.
i.
A summary of results.
ii.
General information.
iii. Description of test method(s), including description
of sampling points, sampling train, analysis
equipment and test schedule.
iv.
Detailed description of test conditions, including:
A.
Fuel consumption (standard f-t
3
) •
B.
Firing rate (million Btu/hr) .
c.
Turbine/Generator output rate (MW).
v.
Data and calculations, including copies of all raw
data sheets and records of laboratory analyses,
sample calculations, and data on equipment
calibration.
i.
Upon written request by the Illinois EPA, the source
owner or operator shall have the opacity of the
exhaust from the affected turbine(s) tested during
representative operating conditions as determined by
a qualified observer in accordance with USEPA Test
Method 9, as further specified below, pursuant to
Section 39.5(7) (d) of the Act.
ii.
Such testing shall be conducted for specific
turbine(s) within 90 calendar days of the request, or
on the date turbine(s) next operates, or on the date
agreed upon by the Illinois EPA, whichever is later.
iii. The duration of opacity observations for each test
shall be at least 30 minutes (five 6-minute averages)
unless the average opacities for the first 12 minutes
of observations (two six-minute averages) are both
less than 10.0 percent.
iv.
The source owner or operator shall notify the
Illinois EPA at least 7 days in advance of the date
and time of these tests, in order to allow the
Illinois EPA to witness testing. This notification
shall include the name and employer of the qualified
observer (s) .
93
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* * * * * PCB 2009-095 * * * *
v.
The source owner or operator shall promptly notify
the Illinois EPA of any changes in the time or date
for testing.
vi.
The source owner or operator shall provide a copy of
its observer's readings to the Illinois EPA at the
time of testing, if Illinois EPA personnel are
present.
vii. The source owner or operator shall submit a written
report for this testing within 30 days of the date of
testing. This report shall include:
A.
Date and time of testing.
B.
Name and employer of qualified observer.
C.
Copy of current certification.
D.
Description of observation conditions.
E.
Description of turbine operating conditions.
F.
Raw data.
G.
Opacity determinations.
H.
Conclusions.
7.3.8
Monitoring Requirements
a.
i.
If an affected turbine is routinely operated or
exercised to confirm that the turbine will operate
when needed, the operation and opacity of the
affected turbine shall be formally observed by
operating personnel for the affected turbine or a
member of source owner or operator's environmental
staff on a regular basis to assure that the affected
turbine is operating properly, which observations
shall be made at least every six months.
ii.
If an affected turbine is not routinely Dperated or
exercised, i.e., the time interval between operation
of an affected turbine is typically greater than six
months, the operation and opacity of the affected
turbine shall be formally observed as provided above
each time the source owner or operator carries out a
scheduled exercise of the affected turbine.
iii.
The S8l:lrCe sr.m.cr sr 9]?Crat::er shall aloe esnE1-1:let
fermal e13scP,ratisBS sf 9£)oratisE:
aHa
9}?aeity sf aFl:
affeetee t"r13iae ""sa ;:ritteR re'lClest 13", Ene IlliRSis
SPZ'...
,'lith the agreemcat sf tae IlliFl:sis EPA, the
sOurce 91Jffier sr 9pCra'ESr
Hl3:J:T scacelule these
94
e13servatisBS ts talEe 131aee e1:l:riH§" l?erioes 'V."heH it
'.lsHIi! staenJise Be sE'eratia!l" tae affeetei! ;;HrBiae,
Note: The formal observation required above is not
intended to be a USEPA Test Method 9 opacity test, nor does
the observation require a USEPA Test Method 9 certified
observer, It is intended to be performed by personnel
familiar with the operation of the affected turbine who
would be able to make a determination based from the
observed opacity as to whether or not the affected turbine
was running properly, and subsequently initiate a
corrective action if necessary.
b,
The affected turbine shall comply with the applicable
monitoring requirements of 40 CFR 60,334(h), below,
Monitoring of fuel nitrogen content shall not be required
while the facility does not claim an allowance for fuel-
bound nitrogen. Monitoring for sulfur content in fuel is
not required while natural gas is the only fuel fired in
the affected turbine and the requirements of 40 CFR
60,334(h)3(i) or (ii) are met,
Pursuant to 40 CFR 60,334(h), the owner or operator of any
stationary gas turbine subject to the provisions of this
subpart:
Shall monitor the total sulfur content of the fuel being
fired in the turbine, except as provided in 40 CFR
63,335(h) (3), The sulfur content of the fuel must be
determined using total sulfur methods described in 40 CFR
60,335(b) (10), Alternatively, if the total sulfur content
of the gaseous fuel during the most recent performance test
was less than 0,4 weight percent (4000 ppmw) , ASTM D4084-
82, 94, D5504-01, D6228-98, or Gas Processors Association
Standard 2377-86 (all of which are incorporated by
reference-see 40 CFR 60,17), which measure the major sulfur
compounds may be used, pursuant to 40 CFR 60,334(h) (1); and
Shall monitor the nitrogen content of the fuel combusted in
the turbine, if the owner or operator claims an allowance
for fuel bound nitrogen (i.e., if an F-value greater than
zero is being or will be used by the owner or operator to
calculate STD in 40 CFR 60,332), The nitrogen content of
the fuel shall be determined using methods described in 40
CFR 60,335(b) (9) or an approved alternative. pursuant to 40
CFR 60,334(h) (2),
Pursuant to 40 CFR 60,334(h) (3), notwithstanding the
provisions of 40 CFR 63,335(h) (1) ,the owner or operator
may elect not to monitor the total sulfur content of the
gaseous fuel combusted in the turbine, if the gaseous fuel
is demonstrated to meet the definition of natural gas in 40
CFR 60,331(u), regardless of whether an existing custom
schedule approved by the administrator for subpart GG
95
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
requires such monitoring. The owner or operator shall use
one of the following sources of information to make the
required demonstration:
The gas quality characteristics in a current, valid
purchase contract, tariff sheet or transportation contract
for the gaseous fuel, specifying that the maximum total
sulfur content of the fuel is 20.0 grains/l00 scf or less,
pursuant to 40 CFR 60.334(3) (i); or
Representative fuel sampling data which show that the
sulfur content of the gaseous fuel does not exceed 20
grains/l00 scf. At a minimum, the amount of fuel sampling
data specified in section 2.3.1.4 or 2.3.2.4 of appendix D
to part 75 of this chapter is required, pursuant to 40 CFR
60.334(h) (3) (ii).
c.
Reserved for Future Use
d.
i.
The owner or operator of an affected turbine subject
to 35 lAC 217 Subpart V (Condition 7.3.3(e)) shall
install, calibrate, maintain and operate continuous
emissions monitoring systems (CEMS) for NO
x
that meet
the requirements of 40 CFR 75, Subpart B [35 lAC
217.710(a)].
ii.
Notwithstanding 35 lAC 217.710(a) above, the owner or
operator of a gas-fired peaking unit or oil-fired
peaking unit as defined in 40 CFR 72.2 may determine
NO
x
emissions in accordance with the emissions
estimation protocol of 40 CFR 75, Subpart E [35 lAC
217.710(b)].
iii. Notwithstanding 35 lAC 217.710(a) above, the owner or
operator of a combustion turbine that operates less
than 350 hour per ozone control period may determine
the heat input and NO
x
emissions of the turbine as
follows
[35 lAC 217.710(c)]:
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbine'S maximum hourly heat input and hours
of operation as recorded by operating
instrumentation on the turbine [35 lAC
217.710(c) (1)].
B.
NO
x
emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO
x
emission factors below
[35 lAC 217.710 (c) (2)] :
0.7 lbs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
96
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7.3.9
e.
i.
The affected turbine shall be equipped, operated, and
maintained with a continuous monitoring system to
monitor and record the fuel consumption being fired.
Recordkeeping Requirements
In addition to the records required by Condition 5.9, the source
owner or operator shall maintain records of the following items
for the affected turbine(s) to demonstrate compliance with
Conditions 5.6.1, 7.3.3, 7.3.5, and 7.3.6, pursuant to Section
39.5(7) (b) of the Act:
a.
The owner or operator of an affected turbine subject t<l the
requirements of 35 lAC 217 Subpart V (Condition 7.3.3(e»
shall:
i.
Comply with the recordkeeping and reporting
requirements of 40 CFR 75 applicable to NO
x
emissions
during the ozone control period, including, but not
limited to, 40 CFR 75.54(b) and (d)
[35 lAC
217.712 (a) ] .
ii.
Notwithstanding 35 lAC 217.712(a) above, the owner or
operator of a combustion turbine for which heat input
and NO
x
emissions are determined pursuant to 35 lAC
217.710(c) (Condition 7.3.8(d) (iii» shall comply
with the following recordkeeping and reporting
requirements
[35 lAC 217.712(b)]:
A.
Maintain records of the heat input and NO
x
emissions of the turbine as determined in
accordance with 35 lAC 217.710(c), and records
of metered fuel use or operating hours used to
determine heat input [35 lAC 217.712(b) (1)].
b.
The source owner or operator shall maintain records of the
following items:
i.
The sulfur content of the natural gas used to fire
the turbines as determined in accordance with
Condition 7.3.8(b).
ii.
A copy of the Final Report(s) for emission testing
conducted pursuant to Condition 7.3.7.
iii. Copies of opacity determinations taken for the source
by qualified observer(s) when using USEPA Method 9.
iv.
Records documenting its periodic review of its
operating procedures as required by Condition
7.3.5 (a) .
97
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* * * * * PCB 2009-095 * * * *
v.
Information for the formal observations of opacity
conducted pursuant to Condition 7.3.8(a). For each
occasion on which observations are made, these
records shall include the date, time, identity of the
observer, a description of the various observations
that were made, whether or not the affected engine
was running properly, and whether or not corrective
action is necessary and was subsequently initiated.
c.
A maintenance and repair log for the affected turbine,
listing each activity performed with date.
d.
Reserved for Future Use
e.
Fuel consumption for the affected turbine, scf/month and
scf/year.
f.
Reserved for Future Use
g.
Operating hours for the affected turbine, hr/month and
hr/year.
h.
Heat content of the fuel being fired in the affected
turbine.
i.
Emissions of each pollutant from the affected turbine,
including emissions from startups, with supporting
calculations including documentation on the validity of the
emission factors used, ton/month and ton/year.
j.
The source owner or operator shall maintain records that
identify:
i.
Any periods during which a continuous monitoring
system was not operational, with explanation.
ii.
my 13erisa
~
...
beE:
the affeetea t1:lrl:dRe ",;ao ia sl3eratisa
El1:1riE:§J ,,;aiaa iae fs§" 1: ... ao aeemea to Be a traffic
ha:aara, the aHffiieHt eoaaieioHs meioeiB§J El1:1ria§J Bae
perisao, the aate aHa time tae 'ii:ater iaj eet.isa system
T.,'as aeactiv:ates., aBa the aat.e aaa time the system ",:as
reactivateS..
iii. Any day in which emission and/or opacity exceeded an
applicable standard or limit.
k.
The source owner or operator shall keep records of good
operating practices for each turbine.
1.
':Pae ssaree suner or o}?erator shall maiE:t.aiB tne fslls'ii:iE:§J
reeors.s relatea Ee easa
sH~tao~.~
of Ene E1:lrsiBes.
i.
'!'he follouiE:§J iE:fermaEioH fer each
Sh~ES.O".:rl:
of a
EursiE:c.
98
Ffl:.
ii.
A.
Date a"e ti",e ef sa"tee.,.n.
B.
l'i aeseriptisH af "Eoac SE:
.
.
.
GJ:3cratin§ proeeEi-1:lres
4:ltelO~.T£,
~f
"ii,'rlttoa
tae sa"tes"n sr .
. :-:e "et fslls',me oorin§"
..
Sl§"fll
le~
t
e1uriH§ taG sfl1d:tas
T
m
'lE: .
J:3rslalems eCCl:lr
cJEf31anatisB.
•
I
lHC UEllH§
EletaileEl
'PRC follor-lis§" iaformatioFl: for
.
nSrffial sflaeit,' aa 13
tae t"rEl"eS
A.
B.
c.
D.
E.
F.
c.
S
COB easerveEl 13'1' SGl:ircc J:3crs8Bflcl.
Name af e13ser:er, pesitisa ane reasoa fer
h
':::l
Gl:B§'
.
at site.
Date
. ±
ane
.
ooratisn sf a13
eve
n
E:9rffial
lne "el"§" affeetee t"r13ine st; t
normal operakisE: T
..
'as a
C;t-:tlCVCt:t.
h' I d
r
epaeiey,
time aBEl time
I~
florFRal 913CraEisE: ',,.as
ffllEH:ltes, aFl: c3Et31anatieH Bot
ael=deved ",lithia
~
0
.13"e>-ia",eeaB.iic€e>'oY"e"eH'.itfni'
ttlaa,ii"'i-Itolhl>l~'~
:t:f:~,~
s~"'~~~"~'
tlmo.
:s tart"fl es"l e ns t
~
inelus,lP
EletaileEl Eleser'
t'
len af tao startup
Hlg reasen fer 9];3cration.
I
An
e''fllanatis"
"Ily
esta13lisaee
performcEl.
e per ermea, if not
';Pac
startliJ.3
Ratlire
er s
f
sJ?aeity fslls"i,,§" tbe ene sf
3 9 ffiln"tes sf sfle .. at.
a'
saSHES first
aHa 9:'
,leE, 1jpl:ofiever
•
I
lira1::lsB sf s:t=Ier 1::'
aelueveFfl:eBt= sf BSI?mal
.
sflaelty
,?
sr sRlites,,'H.
a lSB 'I::lBt=il
WHetBCF
,
aB
e3EceeuaBCC
~
sf CSHeit:isB
1.
e., 3 9 flereent sflaeit,
,
7.3 .3 (13) ,
el:1TiH§" s1::aFt:1:lf3
"it:h
OF
i
mal'. aave eeeurred
s13server
! ..
las
e~
;itc. e3E:1? aBat:lSE: if Efl;lalified
Reesrds fSr SEar1::Bp
'rae Per",ittee saall mai"t .
flurs"ant ts Beetien 3'9. §
(;~713
ta: fslle"in§, reesres,
affeetee t"r13ine st!l3jeet t
)
~ ~ae
Aet, fer eaeb
at: a
i.
':Pae fellmdB§" iBfeflRat:ieE:
affeetee t"r13iae(s),
fsr eaea start"fl sf tae
Eat:e aBd
time aBd
e1uratisB sf
tiFfl:C BSflRal
99
tae startup, i.c., st:art
speratisE: aohieved.
B.
If ReEflal elileratieR "as Ret aeaieveEl '"iI,aiR 39
miH1:ltes
I
aFl:
OJl1?lana1::isa T,;.rR:l
7
starE'*El eeHle. Eet
"e aeaieveEl ',JitaiR tais time.
C.
A EletaileEl EleserililtieR ef tae
start~lil,
incl1:laiHg reaSGFl: fer eperatisn aBel
f ..
¢letaer tao
lilreeeEl'dres 7.3.3 (f) '"ere lilerfermeEl.
D.
.."':.:Fl
c3Et31aBatisa "iB.:t" ERe preeeEiures af 7.3.3(fJ
aBel
etaer esta"lisaeEl
start~lil lilreee~res ee~lEl
Het se perfermoa, if flst periormea.
E.
Wfiether cnoeeaance af Csaeie.isE: §.3.2 aHa
7.3.3(,,) may aave
eee~rreEl
El"riR!f
start~lil.
If
3:E: eneeeeanee may
l=l:a?".TC
occ!l::lrreEi, an clEl?lanatisn
sf the aatare af ol?aeity, i. e.
I
severity
aBa
auratisu, Eiuriag tne start1:lp ana tao nat1:lre of
o13aeit)r at:: tao eSF.l:cl1dsiSE: af
start'\:Z@.
F.
Whether eperatiag persGHflol fer tao t1:lrsiaos sr
air eWlirom:Rcatal s-e-aff are Ga site EltiriFl:§
start"".
ii.
A maiatoaaEce ana repair leg fer each affeetea
turl3iac, listiH§" eaea activity perfsrmce "dta Elate.
n.
Records for Malfunctions and Breakdowns
The Permittee shall maintain records, pursuant to 35 rAC
201.263, of continued operation of an affected turbine
subject
to~Condition
7.3.3(g) during malfunctions and
breakdown, which as a minimum, shall include:
i.
Date and duration of malfunction or breakdown.
ii.
A detailed explanation of the malfunction or
breakdown.
iii.
An
explanation why the affected turbine continued to
operate in accordance with Condition 7.3.3(g).
iv.
The measures used to reduce the quantity of emissions
and the duration of the event.
v.
The steps taken to prevent similar malfunctions or
breakdowns or reduce their frequency and severity.
vi.
The amount of release above typical emissions during
malfunction/breakdown.
100
7.3.10 Reporting Requirements
a.
Reporting of Deviations
The source owner or operator shall promptly notify the
Illinois EPA, Air Compliance Unit, of deviations of the
affected turbine with the permit requirements as follows,
pursuant to Section 39.5(7) (f) (ii) of the Act. Reports
shall describe the probable cause of such deviations, and
any corrective actions or preventive measures taken:
i.
Emissions from the affected turbine in excess of the
limits specified in Conditions 7.3.3 and 7.3.6 within
30 days of such occurrence.
ii.
Operation of the affected turbine in excess of the
limits specified in Conditions 7.3.5 and 7.3.6 within
30 days of such occurrence.
b.
In conjunction with the Annual Emission Report required by
35 lAC Part 254, the source owner or operator shall provide
the operating hours for each affected turbine, the total
number of startups, the total fuel consumption during the
preceding calendar year.
c.
Pursuant to 40 CFR 60.7(c) and 40 CFR 60.334(j), a report
shall be submitted on a semi-annual basis. This report
shall contain information on excess emissions and
monitoring system downtime reports in accordance with 40
CFR 60.7(c) and 40 CFR 60.334(j).
d.
i.
Annually report the heat input and NO, emissions of
the turbine as determined in accordance with 35 lAC
217.710 (c) (Condition 7.3.8 (c) (iii) ), for each ozone
control period, by November 30 of each year [35 lAC
217.712 (b)(2) J •
ii.
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 report to the Illinois EPA
that demonstrates that the affected turbine has
complied with Condition 7.3.3(e). These reports
shall be accompanied by a certification statement
signed by a responsible official for the source owner
or operator as specified by 35 lAC 217.712(c).
e.
R~srEiHg
sf SEarEups
~Re se~Fee e~.~eF
eF epeFateF shall SHEffiit semi annHal
startHP Feperts te the Illineis EPA pUFSHaat te Seetiens
39.§(7) (a) aHa (f) sf ERe ABE.
':PRese
r~9rts
sRall Be
sum.ittea alea§" ",ith the semi al3:H-'!:ial reperts rCEJUiFea Jay
CSHaitisH 7.3 .19 (f) (ii) aHa sRall iHBlua.e ERe fslls"iBg
101
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
inferffiatien fer
startu~s
ef tae affeetea tursine
aurin~
tae
reperting @oriea.
i.
A list ef tae
startu~s
ef tae affeetea tursine,
ineluain~
tae aate, auratien aHa
aeseri~tien
ef eaea
startu~,
aeeempaniea sy a
ee~y
ef tae reeeras
~urs,.aat
te CenElitien 7.3.9(i) fe" eaea
start~
fer
\.'aiea sueh records \;cre rOEfl:liree..
ii.
If taere aave seen ne
startu~s
ef an affeetea turBine
enriEg the reporting periee, tRis shall Be statee in
tae
re~ert.
f.
Reporting of Malfunctions and Breakdowns
The Permittee shall provide the following notification and
reports to the Illinois EPA, Air Compliance Unit and
Regional Field Office, pursuant to 35 lAC 201.263,
concerning continued operation of an affected turbine
subject to Condition 7.3.3(g) during malfunction or
breakdown:
i.
A.
The Permittee shall notify the Illinois EPA's
regional office by telephone as soon as
possible during normal working hours, but no
later than three (3) days, upon the occurrence
of noncompliance due to malfunction or
breakdown.
B.
Upon achievement of compliance, the Permittee
shall give a written follow-up notice within 15
days to the Illinois EPA, Air Compliance Unit
and Regional Field Office, providing a detailed
explanation of the event, an explanation why
continued operation of the affected turbines
was necessary, the length of time during which
operation continued under such conditions, the
measures taken by the Permittee to minimize and
correct deficiencies with chronology, and when
the repairs were completed or when the affected
turbine was taken out of service.
C.
If compliance is not achieved within 5 working
days of the occurrence, the Permittee shall
submit interim status reports to the Illinois
EPA, Air Compliance Unit and Regional Field
Office, within 5 days of the occurrence and
every 14 days thereafter, until compliance is
achieved. These interim reports shall provide
a brief explanation of the nature of the
malfunction or breakdown, corrective actions
accomplished to date, actions anticipated to
occur with schedule, and the expected date on
102
which repairs will be complete or the affected
turbine will be taken out of service.
ii.
In accordance with the due dates in Condition 8.6.1,
the Permittee shall submit semi-annual malfunction
and breakdown reports to the Illinois EPA pursuant to
Sections 39.5(7) (a) and (f) of the Act. These
reports may be submitted along with other semi-annual
reports and shall include the following information
for malfunctions and breakdowns of the affected
turbine during the reporting period:
A.
A listing of malfunctions and breakdowns, in
chronological order, that includes:
I.
The date, time, and duration of each
incident.
II.
The identity of the affected operation(s)
involved in the incident.
B.
Dates of the notices and reports of Conditions
7.3.10(f) (i).
C.
Any supplement information the Permittee wishes
to provide to the notices and reports of
Conditions 7.3.10(f) (i).
D.
The aggregate duration of all incidents during
the reporting period.
E.
If there have been no such incidents during the
reporting period, this shall be stated in the
report.
7.3.11 Operational Flexibility/Anticipated Operating Scenarios
Operational flexibility is not set for the affected turbines.
7.3.12 Compliance Procedures
a.
Compliance with the PM emission limitations of Conditions
7.3.3(b) is addressed by the requirements of Condition
7.3.5, and the records required in Condition 7.3.9, and the
reports required in Condition 7.3.10.
b.
Compliance with the S02 emission limitations of Conditions
7.3.3(c) is addressed by the requirements of Condition
7.3.5, and the records required in Condition 7.3.9, and the
reports required in Condition 7.3.10.
c.
i.
Compliance with the NO
x
emission limitations of
Conditions 7.3.3(d) (i) is addressed by the
requirements of Condition 7.3.5, the testing
103
d.
requirements of 7.3.7, the monitoring requirements of
7.3.8, and the records required in Condition 7.3.9,
and the reports required in Condition 7.3.10(a).
ii.
Compliance with the 80
2
emission limitations of
Conditions 7.3.3(d) (ii) is addressed by the
requirements of Condition 7.3.5, the records required
in Condition 7.3.9, and the reports required in
Condition 7.3.10(a).
i.
Compliance with the NO
x
emission limitations of
Conditions 7.3.3(e) is addressed by the requirements
of Condition 7.3.5, the testing requirements of
7.3.7, the monitoring requirements of 7.3.8, the
records required in Condition 7.3.9, and the reports
required in Condition 7.3.10(a).
ii.
Notwithstanding 35 rAC 217.710 (a), Condition
7.3.8(d), the owner or operator of a gas-fired
peaking unit or oil-fired peaking unit as defined in
40 CFR 72.2 may determine NO
x
emissions in accordance
with the emissions estimation protocol of 40 CFR 75,
Subpart E [35 rAC 217.710(b)].
iii. Notwithstanding 35 rAC 217.710(a), Condition
7.3.8(d), the owner or operator of a combustion
turbine that operates less than 350 hour per ozone
control period may determine the heat input and NO
x
emissions of the turbine as follows
[35 rAC
217.710(c)] :
A.
Heat input shall be determined from the metered
fuel usage to the turbine or the calculated
heat input determined as the product of the
turbine's maximum hourly heat input and hours
of operation as recorded by operating
instrumentation on the turbine [35 rAC
217.710 (c) (1)].
B.
NO
x
emissions shall be determined as the product
of the heat input, as determined above, and the
appropriate default NO
x
emission factors below
[35 rAC 217.710(c) (2)]:
0.7 Ibs/mmBtu - Natural gas
1.2 lbs/mmBtu - Fuel oil
104
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
lla§Jiaes (SH]sj eSE Ee HllSU.'.P
q9 CFR 63
SHls~arE
ZZZZ)
7.L1
Beseri13tisE:
'Pac -aiesel oE:giacs are precess eHli6sisn UF.l:its usee te J?re:yiEle
13aeli::1:lp pST,lor gcacratioB aHel toe arivo a fire Pl±ffii3.
:Note.
';Pais Flarratir:c aeserip1;isn is for iafermatisaal E'H::lrpeSes
aaly aHa is flot cnforeeai31e.
7.q.2
LisE ef llmissiea URiES aaa Air PellHEiea CeaErel
ll~i~meaE
Bmissisa
Emissiofl
-
CsaErel
Y&i-t;
£leseriFltisE:
CeasEr"etea
ll~i~meat
Fire
Pl±ffi~
Diesel
Fire
PH~
=
Heae
Emergency
Emcrgcacy
Diesel
=
Heae
Goaora:e:s£'
GOflcra:J::er
7. q. 3
~~liealsle
Previsieas aaa Re§HlaEieas
a.
'PHe "affeetea aiesel ea§iaes" fer tHe
~H~ese
ef EHese
1:lFlit s13ceifie esaaitisns, arc e1iesel cFlgincs Eleseril3eEl in
CsaaitisE:s 7.4.1 anEl 7.4.2.
]S.
PHrs"aHE Ee 3. lAC 212.123,
i.
No ]?crsen seall ea1:l:se sr alls:rvJ the emissisE: of
smeJce
sr etHer particulate mat::t:or, tdt::a aa 9)?aeity grea1::er
tRan 39 peroost, iats tHo atm9spfiere fram any
emissisa uait.
ii.
'PRe cmissiofl of sme](c or staer l?artieulate matter
frsm aay suca emissisE: uait may aazJ"e aH opacity
§Jreater EHaH 39
~ereeat
]sHt aet §Jreater tHaa 69
porcent for a perioe or pcrioes aggregatiHg 8 miaHtes
iH aaC>' 69 miHHEe
~eriea
Ilreviaea tHat sHeH
e~a~e
emissiOnS peEmittee euring aay 69 minHte parioe saall
occur frsm snly SHe suca emissisn uHit lseatee ",dtaiH
a 1999 ft raaiHs frem tHe seater
~eiat
ef aHY etHer
suea emissisa uait s. .. "flee sr operatee BY sues perSSH,
aaa
~reviaea
fHFEHer Eeat s"eH
e~a~e
emissieas
pOEmittee frem oaca suea emiBsisa Unit ssall 130
limitea te 3 times ia aay 24 sour perise.
a.
PurS1::l:aat ts 3 § lAC 214. 3 91, ae perseE: saall aaaBe or allsr,l
tao emisBisa sf sulfur aimEiee iEto tao atmsspsere from aHY
precess emissioa sourco te CJEcess 2999 ppm.
7. q. q
HeH
A~~liea]Si1iEY
sf Re§JH1atieas ef CeHeera
a.
'±'he affeoeee sieGel eE:§Jiacs arc ast sulsj eot te tac Nc."
SS"Fee PerfermaHee Staaaaras (HSPS) fer
Cem~ressieH
I§aitiea IHte"Ha1 Ceffi)s"stiea Ba§iHes, q9 CFR ParE 69,
105
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
la.
e.
EI.
e.
f.

Back to top

S1:l13Flart I
7
II, 13eea1:lse tae Permitttee aia Flet eeHlHl:CFlOC
eenstr1:l~t1o~
(sate tHat cOFlstruetioFl commences is tRe aate
E~e
englne.ls srElereEi lay tRe Permittee) sf tRe affeeteEi
EI~esel eng~nes
after Jul}' 11, 299. ,mere ERe affeeteEi
dlcsel
en~lnes
arc.
i.
ii.
14""",taetureEi atEer Aj;>ril 1. 2996 anEi are nst fiFe
"lliR"
engines, "uFsHant ts 49 CPR 69.4299 (a) (2) (i).
HaR1:lf~ct~roa
as a acrtifies. national Fire Protaation
Assselatlsn (I1PPA) fiFe
"lliRJ!l
engine afteF J'ttl ' 1
2996, "HFsHant ts 49 CPR 69.4299(a) (2) (ii). }
,
Nste.
'Ps.~alifY
fsr eRis nSn a""liealailieY, tRe Pennittee
Ras eertlfleEi tRat tRe Eliese1 engines Rave nst ",sElig EI
reaoBstraatca te' a'
1
.
.Clr1esa
oR~iaes
aft::er J1:l1y 11, 2995.
C or
':PRO
~ffeetee1
aiesol er.1:§'iBeS are cJwl'Heee from eertaia
reEfUlrameFlt~
of tao Uatioaal Bmissioas Staaaaras for
I1asaraotls Idr Polll:1taats for Statisaary ReeiFlrseatia§"
Internal CsmJaustisn Engines 49 CPR PaFt 63, SttB"art gggg
13eoa~se
~he ~ff7c~oa
Elicsel ea§"iacs are enistin§"
,
COFRFlrCSSlsn l€f.F.1:1tlsa (GI) statioEary RIGB, I3l:1rstlEHlt to 40
GFR 63.6599
(:e)
(3), aBa eo Bot have to meet tao reE;I1:lireHI:onts
sf
~R-:,t
S';'la"a-;t sr SH13,!,aFt A, aElElitisRally nS iRitial
Flo~lf1~atl0Fl
lS nec
7
ssar
y
.
RCEfl;liremeat.s
BccessarJ' to
malatalF.l: tae.
eJEcl~Sl?HI a~a
taorefore eSFRi?liaFlce 'Vdth taat
~art:
are fotlF.l:e '.lltalB tals Sect::ioR.
S!?ecifically, teose
ICEfU1romeRts arc Hot 13eosmiR§" aa affecteEl S01:lrce FlursuaFLt
ts 49 CPR 63.6.99.
Tac aff:ctea aiGsel cB§"iaos (usea as Eliesel gORerators) arc
FLOt
tR
SOO]oct
ff'
to tae Aois Raia
Pre~raR1
.,.
49
CFR
72
,
19
eeaHse
o.
a eetea alesel engiaes are Boa utilit:::y 1::lTl:iss, as
Elef~n~EI
lay 49 CPR 72.6 (la) (8).
PursHant ts 49 CPR 72 2
.\\l:l~l~l~Y
unit." is ecfinGa as a l:1Hit o ... '£Ga or
oFlc;ate~ ~y
a
utlllt~ ~eat
serves a geBerator in aFlY State taat }?roa1:lces
eleetrlcl1::y for sale.
'PRe affeeEeEl Eliese1 engines are nSE SttBjesE ES 3. Il£
212.321 or
2~2.322,
auo to tac
l:1Ri~e
aature of S1:l0H 1:lBits,
a
f3rooess 'V:C1§'i=it rate oaB Ret be sct so teat s1:lca rales
not reasoaaSly be
~FllieEl,
Fl1dXSBoant to 35 LAG 212.323.
ean
'rRe affeeEeEl Eliesel """ifles are nOE SttBjeeE EO 35 IAC
216.121.BeeaHse tRe affeeEeEl Eliesel engines are nSE fHe1
esmJaHSElSn
uniEs, as ElefineEi lay 35 IAC 211.2479.
i.
~He
affeotea aiesel eBgines arc Bot sUBject to 35
ParE 217, Sttl3"art Q.
SEaEisnary Reei,!,rseatiHg
IAG
IatorBal
G~m:eUStiOB
BagiB8s aRe
~urBiaes,
1geaa~sc
tae
aff~ctes a~esc~
eRgines arc not statieaary
reclFlr~eatln§"
lnternal eom19ustion engiaes listee ia
Aj;>,!,enEl:"" C of ERat ParE, "HrsHaat EO 3. I.'£ 217.386.
106
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
7. 4.9
7. 1. 6
7.4,7
ii.
~ae
affeeted diesel eagiaes are aetsHBjeet te 39
1~C
217.111 Because tao affeet:ee sieGel cegises are Rot
fHel eeml9Hstiea Haits, as defiaed BY 35 1M)
~11.2479.
g.
~ae
affeeted diesel eagiaes are aet sHBjeet te 49 CFR Part
64, Csmj3liaaee ASSl;raaee IIsaiteriag (C.'Il'!) fer lIajer
Statisaary Sm:lrees,
BCC3:1::lSe tao
affcotca Eliesel cFl:giaes
aDeS Rst \:lOC
aa aee
SH eSF.l:trel
sO'":iee
to
aeaieve eOfflj?liaace
!.oTitfi an emissioH limitatioa or staHaara.
Coatrel
RCEfI:liremcHts aHa t"7erk
Practices
a.
~ae
Permittee saall fslle',,' geed ej3eratiag j3raetiees fer tae
affeetea cEgises, iaoll:1eliH§" 13crieElie ias!?cetioE:, rSl:lEiHC
maiatcaaace aHa prompt repair of aefeets.
B.
Distillate fuel oil shall se tao ealy fuel fir-eEl ia tao
affccteEl sieGel cEgiacs.
e.
~ae
1lliaeis EPA saall Be alle',oed te samj3le all fHels
stores. at tHe sourec.
Preooetion aHa Bmissioa Limitat:isE:s
PreEluctioE aBEl emission limitatioas are Est set fer tae affcotea
diesel cHgiacs.
IIe1i,'cver, tacre arc S01;lree ."ie1e preEffietioa aBd
emissisn limiEaEisss set ferth iE CeEdities §.e.
~estia§ Rc~iremcBts
a.
i.
{}flea I.-rittea reE;!Hest By tae 1lliaeis EPA, tae
PCERittee shall aa.-ve the epaGity sf the mehaast frem
the affected siesel eB§ise(s) tested aariag
re!,3resentative s}?era1::iH§" ceHEli'EisE:s as aeteERiE:cd by
a E;!\ialified eBserver ia aeeerdaaee ;:ita I'/SEPA
~est
Hetaed 9, as furtaer sj3eeified Bele", j3HEsuaat te
Seetiea 39.9(7) (d) ef tae Aet.
ii.
SHea testiag saall Be eeadHeted feE sj3eeifie diesel
eagiae (s) ,dtaia 79 ealeadar days ef tae reE;!\iest, er
SFl the Elate Elicsel eBgiac(s) Bcnt s}?cratcs, er ss the
Elate agreed l:l-!3eB BY 'Ehe IlliE:eis EPA, T,;iaiehever is
later.
iii. ';Phc auratisa sf s}?aGity oBserv'atioHs fsr caGa test
saall Be at least 39 mifiHtes (five 6 miaHte averages)
tlBless the average o!)aeities fer the first 12 miHB:tes
of slsservatisEs (t',:s Si3E miaute a::rerages) are Bsth
less taaa 19.9 j3ereeat.
iv.
~ae
Permittee saall aetify tae 1lliaeis EPA at least
7 aays ia aElvaace of tae Elate aBEl time ef these
tests, ia sraeF ts alls
f
,,'
the Illinois BI\"' .. 'ES T,:itBess
107
13.
testing.
~fiis
astifieatien sfiall iaeluse Ese name
aaa emIllsyer sf the ""alifiea e13server (s) .
v.
'Phe Permittee shall ElreRl!ltly aetify the Illi"eis EPA
ef any cfianges ia tRe time er sate fer testia§"
vi.
'Phe Permittee shall Ilreviae a eeIlY ef its e13server's
reasiags te the Illiasis EPA at tfie time ef testia§"
if Illineis
EP~ ~ersennel
are
~resent.
vii.
q;'fie Permittee sfiall sld:l3mit a 'ii,'rittea
re~ert
fer tRis
testi,,§, ;:ithia 19 aays ef the aate ef testi,,§,. 'Phis
re.,ert shall
iael~ae.
i.
A.
Bato ane time ef testis§,.
E.
Name a"a eRl!lleyer ef ""alifiea e13server.
C.
Ce}?y ef Old:rrent certificatien.
:9.
Desori~tien
ef eEser-latiea oeasitisas.
E.
Dosori}?ties sf eiesel eagine
e~eratiag
ceaeitieas.
F.
R,..., aata.
c.
Opacity eoteHRiaatieas.
II.
Cenol1:±sieas.
I" the 8".'e"t that the
f~el
eil
s~Illier
is
~"a131e
te
~rsviee
tae sld:lfld:r oeateat sf the fld:ol eil s1:l-!3ply fer
tfie affectee aiesel engiaes, tho Permittee sRal1 fiaT.Te
the
s~lf~r
eeateat ef the eil
s~Illy
te the affeetea
sieGel engiaes, in 1l3s/HlfflBtld:, seterRliaea frsm an
aaalysis ef reElrese"tative samIlle ef the eil
s~Elly,
-
A.
as felle;:s,
Frsm a
Il~rs~a"t
sample tali.ea
te Beetie"
as latey
39.9(7)
tRaa
(a)
99 aays
ef the
aftey
first sIlerati,,§, the affeetea aiesel ea§'iaes
~l:1rsld:aat
te tfiis
~ermit,
}?rsviaee, Rm,Tever,
that if Sld:ca sample is tah.en fells'iI:iH§f
eIleratiea ef the affeetea aiesel ea§,iaes, the
sample shall se taheE: prisy te assiHg FRsre eil
te the stera§'e taR],.
B.
Frsm a sa:FRPle taleen ae
lat~r
tfiaR 39 ea.-ys after
acoeptaace ef a
sRi~meat
sf fld:el ;lfiese sld:lfl:1r
OSRtCHE uSB:le RSt FRcet GeHsitiea 7.4.3(c) l3asea
~Elea S~IlEllier
aata, Elreviaea he'.,ever, that if
tao affectee siesel engiEes are 8}?eratea
feller,dE§, aOOC]?taHcc ef SHofi a sfii1?FReat, tac
108
7. 4.8
samElle seall lae takeR ]?rier te ae,UR§" a
sulase""eRt Sei]? .. eRt ef eil te tae relevaRt
storage t:aHh::.
C.
Fre .. a samElle takeR Re later taaR 39 eays after
a rOEJUcst fer SliCH a samElle is maec BY tae
IlliReis EPA, ]?revieee, ae"ever, taat suea
sample saall Be
BalEen
}?rior te aElElisg more oil
to tae releT.raF.l:t storage
taBlE.
ii.
SamElliR§" aRe aRalysis, iRelueiR§" taat ""iea ferms tae
laasis fer tae sUJ?]?liers' eata, saall lae eeReuetee
USiR§" .. etases taat ."eule lae aee8]?talale uReer Eae
feeleral :Nero: SOl;;lree Performance StaeElarEls for
SEaEieRary Cas TurJaiRes, 49 CFR 69.33'(la) (2) aRe (e)
er tae feeeral .',eie RaiR Pre§"ram, 49 CFR 7., AJ?]?eReiJE
D, O]?EieRal
SO~
E .. issieRs Data Preteeel fer Cas Firee
aRe Oil Firee ""its e.§".,
AS~1
D4957 88
aReAS~1
D129 91.
Nete. CeReiEieR 7.4.7(la) (ii) is fsr fuel testiR§"
.. etasesle§"y eRly, aRe is iR Re . .. 'ay iRteReee los
sl±13jeet the SSl:lroc to those previsisas.
Hoaitoring RCE;[1:lirements
a.
i.
If aH affeeteEl Eliesel cngine is reutiecly operates or
C3EC390isea to COE:fi:r:ER ERat ESC affeeteel E1iescl engine
Hill operate ,d:lcE: neeaeEl, the opcratioE: aHa o!3aeity
sf Eae affeetee eiesel eR§"iRe saall lae fermally
o13serveel BY oI?CratiH§" }?orsenHel fer the affeeteEl
diesel engine or a memBer of Permittee's
caviroamcsEal staff
DE:
a regl:ilar laasis to assure
Eaa1'::
the affeeteel e1iesel Gagine is 9FlcratiR§J !?ro}?crlj(,
.... .fiieh oBsep:}atioBs shall Be maae at least every sin
FROBths.
ii.
If aB affecEea aiesel eBgiBe is HOE rouEiHely
oJ;?eratea or e:lEereisea, i. e., the time inEerval
Bet'ii:een operatioB of an affectea aiesel eHgiBe is
t:l'=.t?ieally §Teater thaH SiH FROBths, Ehe o}?eratieB aHa
s]?aeity sf tae affeetee eiesel eR§"iRe saall lae
formally el3servea as J;?roviaee a-eeve each time the
Permittee carries Slat a seheekileE1 eJECreise of the
affeetee eiesel eR§"iRe.
iii.
':Pac Permittee shall aloe COFl:duct feFFRal e13servatioBs
sf e]?eratieR aRe e]?aeiEY ef aR affeetee eiesel eR§"iRe
UfJOE: 'V.TiEoteFl: reEf1:lest BY the IlliBoio EPA.
With tfie
a§"reemeRt ef tae IlliReis EPA, tae Permittee ffiay
sofieElBle these eeservatioBs te tal::e }?laee el:t±FiB§'
]?eriees '.meR it '.,sule etae'Aoise lae eEleratiR§" tae
affeetee eiesel eR§"iRe.
109
1'loto.
IJ'ho "fo:r:mally o13sorvatiofl" rOEfl:liroel a13o ...... e is flOt
iBteBeee te lee a UBEPA 'Pest !lethee 9 el?aeity test, Ber eees
tRe o13servatiofl reEfl:lire a USBPA 'Pest Hethael 9 certifiea
o13ser ...... er.
It is iateaeea to lae 1gerformee. 13y 1gersoaHel
familiar 'dith the el?eratieB ef the affeetee eiesel eB!jiBes
u-ao "
.. To1:lIEi 130 aBle to make a aetermiaaBioa :Sasee. from tae
affeetee eiesel eB!jiBes "",e '"e"le lee aJele te ",alee a
e.eBermiaatioa Baseel from BRe oBservee. ol?aeity as to r..motRer
of FlOB tho affoetoe. e.iesol eE:giae ;;as r1::lRaiag }?ro}?erly, aae.
s1:l-1:3se~ldeE:tly
iaitiate a corrective aetioB if aecessary.
7.
4.9
Reeore.Jeccl?iFl§J ReE;fliiremeFlts
1R aeeitieB te the reeeres
re~iree
ley CeBeitieB 3.9, the
Pcr-mittee shall maiFltaiFl reeore.s of the folloT.fiRg items for each
affectee. Eiiesel en§"iae to e.cmoflstrate eOfRl?liaFlce ;dth COFlElitiofls
3.6.1 aBe 7.4.3, l?"rS"aRt te BeetieR 39.3(7) (le) ef the Aet.
a.
i.
~~
ol?eratiFlg log for each affeeteEl e.iosel eagiao,
'"hieh shall iRel;,ee the felle"iB!j iBfer",atieR.
~.
1RfermatieR fer eaeh time the affeetee eiesel
eagiFlo is ol?crateEi, ',dEh Elate, time, ooratioFl,
aad l?ldrl?OSO (i. e., enereise or j?9
T
..
T
cr service) .
HOFlthly anel
anr:R:ial reeares of BSldrs af
ol?eratioa of oach OE:giBo ane. total hSldrs of
oEJeratiofi.
B.
Iaformatisfl for Eae s13servatioas eOFloocEoa
l?"rsllaRt te CeReitieR 7.4.8(a) er 7.4.7(a),
".nth
aate, time, l?CrSOFlFlel, aaEl fiaelia§Js.
I.
';Phe Permittee shall ]eeCi? reeoras for all
o19aeiEY moaSldremoats maae iFl aecore.aaco
',oith UBEPA l!ethee 9 fer aR affeetee
eliesel ongiFlo that it eoaaldots or Ehat
are eeBe"etee eR its leehalf ley
iae1iviooals r..."fio are E;flialifiea te make
s"eh eleservatieRs fer CeReitieB 7.4.7(a).
For caoa sooasioE: OFl ;"'hieh such
o13sepJ'atioas are maEle, these reooras
shall iRelllee the ieeBtity ef the
OBserver, a aeseri}?EioFl of Eae vario1:::l:s
eleser'latieRs that '"ere ",aee, the sleseR'ee
o13acity, anel o013ies of the ra;,.. Elata
sReets for the o13ser ...... aeioas.
II.
'Phe Permittee saall leeep recores for all
fermal eleseH'atieRs ef el?aeity eeBooetee
l?"rS"aBt ts CeBeitieB 7.4.8(a). Fer eash
ocoasisn sa " .. >Rioa o13sorvatioFls are
maac
,
these reeeres shall iBel"ee the eate,
Eimo, iEleatity of tao o13seFJ'er, a
dcscriptioFl of tao variaus o13ser'VUtioFlS
110
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
B,
e,
a.
ii.

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iii.
C,
taat ',,'ere H1aae, ,,'aetaer sr RSt tae
affeeteEl Eliesel cF.!:§"inc ",Jas
F1:lBBiB§f
;Flr013crly
•
•
I
ane T
..
"Betae
r or not eerreetive
'7"e~~?fl
15
FleeeSSar~{
aHa
uas
Sl±BsoEfl:;lo:atl-
~R~t~atea,
'
IBformatisR iEientifying aey
El~:iatieR
from
CSRaitisR 7,4,5(B) ,
A
m~iF.!:teaaF.!:ee
anEl
r~air
log
f
sr eaea aEEeetea aiesel
eagles
~
aBa asseeiateEl
e~1:li13meF.!:t,
I'
10t1R"
.
aeb~T,TZ~~es
E'er~srmea
"ita aate,
~
e~ ~e~~-
'l'ae P
erm~ttee
.
saall ]<seE' reesras sE sa'
practices fer eaca affeeteEl
e'
§f ? o13cratlF.!:§f
iF.!: COF.!:aitioF.!: 7.4.3(a).
losel OF.!:§flne, as
aefiE:oEl
FHcl usage fer tho a
ff
catca Eliesel engines.
i.
'l'st~l
Hsa§'e SE EHel sil Esr tae aEEeetea
aiesel
CH§flFlCS, gallsBs/moE:1::l:l aBa galleRs/year.
:Z~ ::;im.:~E:§"
~ee9res rela~eEl
EO BRO sl±lfur eORtent sf tao
i.
ii.
aHeetea
Efl:ii3:E:tity
(~':
§'~llsRS),
SHIEH .. eSRteRt, aRa
'.'laetae~
tae
SO~
emlSS19ns from the 131:1rniH§f of s1:lca fuel
.,lOule
meet
the staE:sara ia CoaEiitioa 7.4.
~
(oJ.
- ---
'I'hOtPCrmittee GRall maintain reeerEls af ERe s1::1:lf1::1:r
-sG~,
~
rn4, aBe PH) lB eaBs (maHEn
E1 t
(
., :NO*...--G:Gt
s1:lf313srtiH§
I I'
)
aB
eBS, year Kitn
7,4.9,
ea ea
at~sHS
aRa aata as re .... irea BY CSRaitisR
7.4,19 ReE'srtiH§, Re .... iremeRts
a,
ReperEia§f s£ !)e7iatieas
CSfflFlI'
Tho Permittee
,reml?
snaIl 13-
'Eo
I
Y BeElfy
'
Ene Illiaeis BPA
71 '
. lance DnlE of E1c
niat=:'
f
.,
ulr
ofl§fiHCS '.dES
Eh~ rerm:~le~s
e
as affectee E1iesel
,
J::"
1
rCEf1:1lremoBts as felle"
.
te
Seet~eR
39,5 (7) (E) (ii)
f
a"s, E'HrsHaRt
dcsari13e tho 13ro13a131
. s
t e Act=:.
RC13erts shall
cerrcctinc act'
c catlsc sf sacS dcviat=:ioBs, aBd aBY
v
leBs er pro:r.. .. eBt=:ive measures t=:a]cOB.
111
i.
BmissioBS of opacity,
SO~,
from tae affcctea eiescl
cB§"iE:es iE: eHcess of tae limiEs specifiee ia
COEaitioEs 7.4.3
~;ithiB
3Q eays of saca occarreaoe.
ii.
OperatioB of the affoetea aiosol eBgieos in
eOEcompliaEce ;dEa tae req1;liromoats spoeifioa ia
CoaaitioB 7.4. § .,dtaia 3Q aays of sHeh ecearrOEce.
7.
~
.11 e"eratisBal Fle"il3ility/lIRtiei"ateEt e"eratiB!l" SeeBariss
e"eratisBal fle"il3ility is BSt set fsr tae affeeteEt Etiesel
eagiaes.
7.
9: .12 Compliaaco Prooos:l±res
a.
Compliaaoo .,dta tae PH omissioE limitatioas of ConaitioRs
7.9:.3(13) is aaaressea BY tao rOf:Iairements of Coneiitioa
7.~.3Ia),
tae testiB!l"
re~iremeBts
iB CSBEtitisB
7.~.7(a)
,
tae mSBitsriB!l"
re~iremeBts
sf CSBEtitisB
7.~.8Ia),
tae
recoras
re~irea
in Coaeiitioa 7.9:.9(a), aRa tae reports
re~ireEt
iB CSBEtitiSB
7.~.19Ia).
13.
i.
Com};3liaaoe ',;ita tao
50~
emission limitatioE: of
CSBEtitisB 7.4.3(8) Ii) is aEtEtresseEtl3y tae
refJUiremeRts of Coaaitioa 7.9:.9, tae testia§
re~iremeBts
iR CSBEtitisR 7.4.7(13), aREt tae reesrEts
aBet re"erts
re~ireEt
iB CSREtitisBS 7.4.9(13) aREt (e)
aBet 7.4.19 (a) .
ii.
For tRis parpose, complete oORvorsioE of s1:l1f1:lr iEto
SG.;j: saall 1so assumea, e.g., 80,* emissioBs ia l1s/mIRBEu
are t'V:iee ERe
sal far
cORtest of tae fld:ol sap}?ly, iE
l1s/fflFRBtu, ld:sin§ tae follo .. :iR§
o~atioa.
Fuel sulfur eSBteBt 1113/mmBtu) " 2 " 1/64 " 383.2 " 1,999,999
Be§iRo meflal:lst rate factor (scf/:mmBtu)
Hote.
5i::oicRiometric cOFRBusEioa of aistillate oil .,lita tao
ma3dffil:lffi availaBle sulfur oeRteat, i.e.
I
1.G peroeet, 'V;oula
resalt is ae 50,* coaooEtratiofl ia tao 03m.a1:lSt teat is 'Vwll
l3elm' tae 2999 ""m limit iR CSRElitisB
7.~.3(e)
Ii), i.e.,
sBly al3sut 399 ""m, BaseEt SB 19,329 sef/mmBtu, tae F faetsr
fer oil ia U8BP/',' s RefereBco HeERea 19.
Hoto.
50paraEo recoras aro Bst BoiR§" re(Jl:iirea for
CSBEtitisB 7.
~.3
Ie) (ii) l3eeause steieaismetrie esml3ustisB sf
sil ts emit 9.3 113
se~
"er millisR Btu (ss as ts 8l,aetly
es"",l.,. "ita CSREtitieR 7.4.3Ie) (ii)) "sulEt result iB aB
se~
eSReeBtratieB iR tae elffiaust sf sRly al3sut 169 ""m l3aseEt SR
tRO F facter fer oil iE: USBPA's Reforcace HotRes. 19
I
• ••
...aica
is "ell l3els'" tae 2999 ""m limit iR CeBEtitisB 7.4.3Ie) (ii).
112
e.
COffij?lianeo ".:itn tao omissioa limits in CoaElitioa §. (5 arO
aElElEosseEl 1:)'1" tne rocorE1s aBEl rCfJorts rCq1::lirca ia -Csnaitioas
7.4.9 ana 7.4.19 aae tao emission factors aae fOrmH1as
listeEl :8e10\: if s1:lita1sle maa1:lfaet1:lre' 5 emissisa rate Elata
is "et availaBle.
i.
Emission factors for the affeetea aiesel engines
a]?
te 699 herse"e'"er.
Emission ¥!aetors
Pe ll"taHt
( 113 "" •• IB t" l
(113 ,IfiJ?
hrl
F"el
I"!?,,t
POlder
01:ltj?ut
-¥eM
~
;l.46
3E
:],8
.-@
-
~
;l.;l8
3E
:],8
.-@
---5G~
~
;l.8§
"
:],8
.-@
-*
4-.4±
G.GH
---5G
.g....,.-9-§.
6.68 1E
:],8
.-@
The heat eeHteHt e£ eistillate £"el eil shall Be
ass_ee te Be 137,939 Bt",Igal as "er AP 42.
Emissions
Distillate F1;:lel Gil Ysa§o R Heat ContORt
of Fuel Oil
n
Emission Factor
~ne
emission factors are for Gasoliao .;ae Diesel
IHettstrial Il"gi"es £rem AP 42 Beetie" 3.3 (eatee
19/96) .
ii.
Emissien factors fer the affeeteEl engines greater
thaH (59 9 he rs e13 Of,Jer .
Pell"taHt
Emission Factors
( 113 ,I"""Bt" l
F"el I"!?,,t
-l).....l)9.
~
(l13,1h" hrl
Pouer 01;:lt13ut
7.9. 1. 19 .-
9.9997
1. 91 " S",
~
~
8.99 " 19 -.........s±
~
§. § " 19 -
Where
S~
represents the 13oreont s1:llfur is tao fHol
oil.
81
% s1:l1fur in f1:101 oil.
~ae
hoat coateat of
eistillate £"el eil shall Be ass_ee te Be 137,939
Btu,lgal as "er AP 42.
Eimissisns
Ilistillate F"el Oil Usage " Heat Ce"te"t
sf ¥!uel Oil ]( Emission ¥!aeter
~ao
omission faeters are for Largo Statienary Diesel
ABe All 8taEie"ary Ilual £"el Il"gi"es £rem AP 42
Beetie" 3.4 (eatee 19,196l.
113
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
8.0
GENERAL PERMIT CONDITIONS
8.1
Permit Shield
Pursuant to Section 39.5(7) (j) of the Act, the Permittee has requested
and has been granted a permit shield. This permit shield provides that
compliance with the conditions of this permit shall be deemed
compliance with applicable requirements which were applicable as of the
date the proposed permit for this source was issued, provided that
either the applicable requirements are specifically identified within
this permit, or the Illinois EPA, in acting on this permit application,
has determined that other requirements specifically identified are not
applicable to this source and this determination (or a concise summary
thereof) is included in this permit.
This permit shield does not extend to applicable requirements which are
promulgated after January 30, 2009 (the date of issuance of the
proposed permit) unless this permit has been modified to reflect such
new requirements.
8.2
Applicability of Title IV Requirements (Acid Deposition Control)
This source is an affected source under Title IV of the CAA and is
subject to requirements pursuant to Title IV of the CAA as specified in
Section 6.2. To the extent that the federal regulations promulgated
under Title IV of the CAA, are inconsistent with the requirements of
this permit, the federal regulations promulgated under Title IV of the
CAA shall take precedence pursuant to Section 39.5(17) (j) of the Act.
8.3
Emissions Trading Programs
No permit revision shall be required for increases in emissions allowed
under any USEPA approved economic incentives, marketable permits,
emissions trading, and other similar programs or processes for changes
that are provided for elsewhere in this permit and that are authorized
by the applicable requirement [Section 39.5(7) (0) (vii) of the Act].
8.4
Operational FlexibilitY/Anticipated Operating Scenarios
8.4.1
8.4.2
Changes Specifically Addressed by Permit
Physical or operational changes specifically addressed by the
Conditions of this permit that have been identified as not
requiring Illinois EPA notification may be implemented without
prior notice to the Illinois EPA.
Changes Requiring Prior Notification
The Permittee is authorized to make physical or operational
changes that contravene express permit terms without applying
for or obtaining an amendment to this permit, provided that
[Section 39.5(12)(a)(i) of the Act]:
a.
The changes do not violate applicable requirements;
114
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
b.
The changes do not contravene federally enforceable permit
terms or conditions that are monitoring (including test
methods), recordkeeping, reporting, or compliance
certification requirements;
c.
The changes do not constitute a modification under Title I
of the CAA;
d.
Emissions will not exceed the emissions allowed under this
permit following implementation of the physical or
operational change; and
e.
The Permittee provides written notice to the Illinois EPA,
Division of Air Pollution Control, Permit Section, at least
7 days before commencement of the change.
This notice
shall:
i.
Describe the physical or operational change;
ii.
Identify the schedule for implementing the physical
or operational change:
iii. Provide a statement of whether or not any New Source
Performance Standard (NSPS) is applicable to the
physical or operational change and the reason why the
NSPS does or does not apply;
iv.
Provide emission calculations which demonstrate that
the physical or operational change will not result in
a modif.ication; and
v.
Provide a certification that the physical or
operational change will not result in emissions
greater than authorized under the Conditions of this
permit.
8.5
Testing Procedures
Tests conducted to measure composition of materials, efficiency of
pollution control devices, emissions from process or control equipment,
or other parameters shall be conducted using standard test methods if
applicable test methods are not specified by the applicable regulations
or otherwise identified in the conditions of this permit.
Documentation of the test date, conditions, methodologies,
calculations, and test results shall be retained pursuant to the
recordkeeping procedures of this permit. Reports of any tests
conducted as required by this permit or as the result of a request by
the Illinois EPA shall be submitted as specified in Conditions 8.6.3
and 8.6.4.
115
8.6
Reporting Requirements
8.6.1
Monitoring Reports
8.6.2
Reports summarizing required monitoring as specified in the
conditions of this permit shall be submitted to the Illinois EPA
every six months as follows, unless more frequent submittal of
such reports is required in Sections 5 or 7 of this permit
[Section 39.5(7) (f) of the Act]:
Monitoring Period
Report Due Date
January - June
September 1
July - December
March 1
All instances of deviations from permit requirements must be
clearly identified in such reports. All such reports shall be
certified in accordance with Condition 9.9.
Test Notifications
Unless otherwise specified elsewhere in this permit, a written
test plan for any test required by this permit shall be
submitted to the Illinois EPA .for review at least 60 days prior
to the testing pursuant to Section 39.5(7) (a) of the Act. The
notification shall include at a minimum:
a.
The name and identification of the affected unit(s);
b.
The person(s) who will be performing sampling and analysis
and their experience with similar tests;
c.
The specific conditions under which testing will be
performed, including a discussion of why these conditions
will be representative of maximum emissions and the means
by which the operating parameters for the source and any
control equipment will be determined;
d.
The specific determinations of emissions and operation that
are intended to be made, including sampling and monitoring
locations;
e.
The test method(s) that will be used, with the specific
analysis method, if the method can be used with different
analysis methods;
f.
Any minor changes in standard methodology proposed to
accommodate the specific circumstances of testing, with
justification; and
g.
Any proposed use of an alternative test method, with
detailed justification.
116
8.6.3
8.6.4
Test Reports
Unless otherwise specified elsewhere in this permit, the results
of any test required by this permit shall be submitted to the
Illinois EPA within 60 days of completion of the testing. The
test report shall include at a minimum [Section 39.5(7) (e) (i)
of the Act] :
a.
The name and
identification of
the affected unit(s);
b.
The date and
time of the sampling or measurements;
c.
The date
any
analyses were performed;
d.
The
name
of the company that performed the tests and/or
analyses;
e.
The test and analytical methodologies used;
f.
The results of the tests including raw data, and/or
analyses including sample calculations:
g.
The operating conditions at the time of the sampling or
measurements; and
h.
The name of any relevant observers present including the
testing company's representatives, any Illinois EPA or
USEPA representatives, and the representatives of the
source.
Reporting Addresses
a.
Unless otherwise specified in the particular provision of
this permit or in the written instructions distributed by
the Illinois EPA for particular reports, reports and
notifications shall be sent to the Illinois EPA - Air
Compliance Unit with a copy sent to the Illinois EPA - Air
Regional Field Office.
b.
As of the date of issuance of this permit, the addresses of
the offices that should generally be utilized for the
submittal of reports and notifications are as follows:
i.
Illinois EPA - Air Compliance Unit
Illinois Environmental Protection Agency
Bureau of Air
Compliance & Enforcement Section (MC 40)
P.O. Box 19276
Springfield, Illinois 62794-9276
117
ii.
Illinois EPA - Air Quality Planning Section
Illinois Environmental Protection Agency
Bureau of Air
Air Quality Planning Section (MC 39)
P.o. Box 19276
Springfield, Illinois 62794-9276
iii. Illinois EPA - Air Regional Field Office
Illinois Environmental Protection Agency
Division of Air Pollution Control
2009 Mall Street
Collinsville, Illinois 62234
iv.
USEPA Region 5 - Air Branch
USEPA (AR - 17J)
Air & Radiation Division
77 West Jackson Boulevard
Chicago, Illinois 60604
c.
Permit applications should be addressed to the Air Permit
Section. As of the date of issuance of this permit, the
address of the Air Permit Section is as follows:
8.7
Title I Conditions
Illinois Environmental Protection Agency
Division of Air Pollution Control
Permit Section (MC 11)
P.O. Box 19506
Sprirtgfield, Illinois 62794-9506
Notwithstanding the expiration date on the first page of this CAAPP
permit, Title I conditions in this permit, which are identified by a
Tl, T1N, or TIR designation, remain in effect until such time as the
Illinois EPA takes action to revise or terminate them in accordance
with applicable procedures for action on Title I conditions. This is
because these conditions either: (a) incorporate conditions of earlier
permits that were issued by the Illinois EPA pursuant to authority that
includes authority found in Title I of the CAA (Tl conditions), (b)
were newly established in this CAAPP permit pursuant to authority that
includes such Title I authority (T1N conditions), or (c) reflect a
revision or combination of conditions established in this CAAPP permit
(T1R conditions).
(See also Condition 1.5.)
118
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *
CERTIFICATE OF SERVICE
I, the undersigned, certifY that on this 23
rd
day of April, 2009, I have served electronically
the attached
APPEARANCES OF RENEE CIPRIANO, and JOSHUA R. MORE and
APPEAL OF CAAPP PERMIT,
upon the following person:
John T. 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
Renee Cipriano
Joshua R. More
SCHIFF HARDIN LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
312-258-5567
FAX: 312-258-5600
jmore@schiffhardin.com
Electronic Filing - Received, Clerk's Office, April 23, 2009
* * * * * PCB 2009-095 * * * *

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