BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

COMPANY and VENICE POWER PLANT

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Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

PCB 09-

(Permit

Appeal- Air)

NOTICE OF FILING

To:

John

T. Therriault, Assistant Clerk

Illinois Pollution Control Board

James

R. Thompson Center, Suite 11-500

100 West Randolph

Chicago, Illinois 60601

Division

of Legal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 62794-9276

PLEASE TAKE NOTICE that we have today filed with the Office

of the Clerk of

the Pollution Control Board

APPEARANCES RENEE CIPRIANO and JOSHUA R. MORE

and APPEAL

OF CAAPP PERMIT,

copies of which are herewith served upon you.

Joshua

R.

More

Dated: April 23, 2009

Renee Cipriano

Joshua

R. More

SCHIFF HARDIN LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5567

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Petitioner,

v.

ILLINOIS ENVIRONMENTAL

Respondent.

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PCB 09-__

APPEARANCE

I hereby file my appearance

in

this proceeding, on behalf of Amerenpner

gy

Generating

Company and Venice Power Plant.

v:;-::?

:7/

~

Dated: April 23, 2009

__________ .

p'

r-----~-

R ee Cipriano

Schiff Hardin LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

(312) 258-5500

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Petitioner,

ILLINOIS ENVIRONMENTAL

Respondent.

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PCB

APPEARANCE

I hereby file my appearance in this proceeding, on behalf of Ameren Energy Generating

Company and Venice Power Plant.

Dated: April 23, 2009

oshua R. More

Schiff Hardin LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

(312) 258-5500

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

UNION ELECTRIC COMPANY d/b/a

)

AMERENUE

and AMERENUE VENICE

)

POWER PLANT

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

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PCB 09-

--

(Permit Appeal- Air)

APPEAL OF CAAPP PERMIT

NOW COMES Petitioner, Union Electric Company d/b/a AmerenUE or AmerenUE

Venice Power Plant ("Petitioner" or "Ameren"), pursuant to Section 40.2 of the Illinois

Environmental Protection Act ("Act") (415 ILCS 5/40.2) and 35 IlI.Adm.Code § 105.300

et seq.,

and requests a hearing before the Board to contest certain conditions contained in the Clean Air

Act Permit Program ("CAAPP") renewal permit! (the "permit") issued on March 19, 2009,

pursuant to Section 39.5

of the Act (415 ILCS 5/39.5) and attached hereto as Exhibit

I.

35

Ill.Adm.Code §§ 105.210(a) and (b).

See

Exhibit

I.

Pursuant to Section 40.2(a) of the Act and

35 IIl.Adm.Code §§ 105.302(e), this Petition is timely filed with the Board.

In support of its Petition to appeal Conditions 4.0, 5.6.2, 5.7.2, 5.9.2, 7.1.3(f), 7.2.3(e),

7.3.3(f), 7.1.3(f)(iv), 7 .2.3( e )(iv), 7.3.3(f)(iv), 7.1.5(a)(iii)(A), 7.2.5(a)(iii)(A), 7.3.5(a)(iii)(A),

7.1.8(a)(iii), 7.2.8(a)(iii), 7.3.8(a)(iii), 7.1.9(1), 7.2.9(1), 7.3.9(1), 7.1.9(m), 7.2.9(m), 7.3.9(m),

I

Application No. 95090017; J.D. No. 119105AAA

-1-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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7. 1.1 O(e), 7.2.10(d), 7.3.l0(e), 7.1.12(e), 7.3.9(j)(ii), and 7.4 and its request to stay these

Conditions, Petitioner states

as follows:

I.

BACKGROUND

(35 III.Adm.Code § 105.304(a))

1.

The Venice Power Plant, Illinois Environmental Protection Agency ("Agency")

J.D. No. 119105AAA is an electric generating station owned and operated by Union Electric

Company d/b/a AmerenUE. The Venice Power Plant operates

as a peaking station, generating

electric power when sufficient electric power is not available from other sources. The Venice

Power Plant electrical generating units ("EGUs") are combustion turbines and subject to the

CAAPP (415 ILCS 5/39.5). The Venice Power Plant is located

at 701 Main Street, Venice,

Illinois, Madison County, 62090. Madison County

is attainment for all National Ambient Air

Quality Standards except for ozone and

PM2.s. The Agency issued the permit on March 19,

2008.

II. REQUEST FOR PARTIAL STAY OF THE PERMIT

2.

Historically, the Board has granted partial stays in permit appeals where a

petitioner has

so requested.

See, e.g., Midwest Generation, LLC, Will County Generating Station

v. Illinois Environmental Protection Agency,

PCB 06-156 (July 20, 2006) (granted stay of the

effectiveness

of contested conditions of a construction permit);

Dynegy Midwest Generation, Inc.

(Vermilion Power Station) v. Illinois Environmental Protection Agency,

PCB 06-194 (October

19, 2006) (granted stay "of the portions of the permit Dynegy contests");

Dynegy Midwest

Generation,

Inc. (Havana Power Station) v. Illinois Environmental Protection Agency,

PCB 07-

115 (October 4, 2007) (same);

Hartford Working Group v. Illinois Environmental Protection

Agency,

PCB 05-74 (November 18,2004) (granted stay of the effectiveness of Special Condition

2.0

of an air construction permit);

Community Landfill Company and City of Morris v. Illinois

-2-

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Environmental Protection Agency,

PCB 01-48 and 01-49 (Consolidated) (October 19, 2000)

(granted stay

of effectiveness of challenged conditions for two permits of two parcels of the

landfill);

Allied Tube

&

Conduit Corp. v. Illinois Environmental Protection Agency,

PCB 96-108

(December 7, 1995) (granted stay

of the effectiveness of Conditions 4(a), 5(a), and 7(a) of an air

permit).

3.

Ameren requests in this instance that the Board exercise its inherent discretionary

authority to grant a partial stay of the CAAPP permit, staying only those conditions or portions

of conditions indicated in Exhibit 2,

i.e.,

Conditions 3.2.1, 4.0, 5.6.2, 5.7.2, 5.9.2, 7.1.3(f),

7.2.3( e), 7.3.3(f), 7.1.3(f)(iv), 7 .2.3( e )(iv), 7.3.3(f)(iv), 7.1.5(a)(iii)(A), 7.2.5(a)(iii)(A),

7.3.5(a)(iii)(A), 7.1.8(a)(iii), 7.2.8(a)(iii), 7.3.8(a)(iii), 7.1.9(1), 7.2.9(1),

7.3 .9(1), 7.1.9(m),

7.2.9(m), 7.3.9(m),

7. 1.1O(e), 7.2.IO(d), 7.3.10(e), 7.1.12(e), 7.3.9(j)(ii), and 7.4, during the

pendency

of this appeal.

III. ISSUES ON

APPEAL

(35 IIl.Adm.Code §§ 105.304(a) (2)-(4»

Following are the issues that Ameren appeals and seeks a stay for, presented sequentially.

4.

Condition 4.0 Significant Emission Units

Petitioner objects to this Condition because it is arbitrary, capricious, and unauthorized

by law to the extent it imposes conditions on sources that are not significant emission units.

As

set forth in Condition 3.1.3, the emergency diesel fire pump and the emergency diesel generator

are listed as insignificant activities under Section 3.1.3 and thus inappropriate for listing in the

table in Condition

4.0 as a significant emission unit. This condition is, therefore, in excess

of the

Agency's authority, unauthorized by law, arbitrary and capricious, and unreasonable.

Accordingly, this Condition should be deleted and stayed during the pendency

of this appeal.

-3-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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5.

Condition 5.6.2 Emissions of Hazardous Air Pollutants

Petitioner objects

to this Condition because it is arbitrary, capricious, and unauthorized

by law to the extent it imposes an emission limit to ensure that the source is not a major source

of

hazardous air pollutant emissions. As set forth in Condition 5.l.I, the source is not a major

source for hazardous air pollutant emissions and the permit was not issued based on the source

being a

maj or source for hazardous air pollutant emissions. This condition is, therefore, in

excess

of the Agency's authority, unauthorized by law, arbitrary and capricious, and

unreasonable. Accordingly, this Condition should be deleted and stayed during the pendency

of

this appeal.

6.

Condition 5.7.2 HAP Testing to Verify Minor Source Status

Petitioner objects

to this Condition because it is urmecessary given the fuel and emission

limitations contained within the permit and therefore is arbitrary, capricious, unauthorized by law

and unreasonable. This Condition requires the source to verify compliance with Condition 5.6.2,

which for the reasons set forth above should be deleted. Accordingly, this Condition should be

deleted and stayed during the pendency

of this appeal.

7.

Condition 5.9.2 Records for HAP Emissions

Petitioner objects to this Condition because

is it arbitrary, capricious, unauthorized by

law and unreasonable. This Condition requires the source to record emissions

to demonstrate

compliance with Condition 5.6.2, which for the reasons set forth above should be deleted.

Accordingly, this Condition should be deleted and stayed during the pendency

of this appeal.

8.

Conditions 7. 1.3 (f), 7.2.3(e); 7.3.3(f) Startup Provisions

Petitioner objects to these Conditions because they are unauthorized by law, arbitrary and

capricious. These Conditions incorrectly fail to incorporate certain limitations or provisions

-4-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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from the current CAAPP permit, which are applicable requirements.

Accordingly, these

provisions should be modified and stayed during the pendency

of this appeal.

9.

Conditions 7. 1.3 (f)(iv); 7.2.3(e)(iv); 7.3.3(f)(iv) Startup Provisions

Petitioner objects to these Conditions because they are arbitrary, capricious, unauthorized

by law and umeasonable. These Conditions require the source to fulfill the record keeping

requirements

of Condition 7. 1.1O(e), 7.2.10(d), and 7.3.l0(e), respectively, which for the reasons

set forth below should be deleted. Accordingly, these Conditions should be modified and stayed

during the pendency

of this appeal.

10.

Conditions 7.1.5(a)(iii)(A); 7.2.5(a)(iii)(A); 7.3.5(a)(iii)(A) Control Requirements

and Work Practices

Petitioner objects to these Conditions because they are umeasonable, arbitrary and

capricious.

The permit contains a quarterly inspection requirement

of emission related

components that is not reflective

of actual operating conditions. The units do not operate on a

regular schedule, thus the imposed schedule may require inspections on a non-operating unit.

Therefore, these Conditions are arbitrary and capricious, unauthorized by law and unreasonable.

Accordingly, these Conditions should be modified and stayed during the pendency

of this appeal.

II.

Conditions 7. 1. 8 (a)(iii); 7.2.8(a)(iii); 7.3.8(a)(iii) Monitoring Requirements

Petitioner objects to these Conditions because they are unauthorized by law,

umeasonable, redundant, arbitrary and capricious. The Agency may not require a source

to

operate a unit when the unit is otherwise not operating in order to assess compliance.

Accordingly, these Conditions should be modified and stayed during the pendency ofthis appeal.

-5-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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12.

Conditions 7.1.9(1); 7.2.9(1); 7.3.9(1) Recordkeeping Requirements - Shutdowns

Petitioner objects

to these Conditions because they are unauthorized by law,

unreasonable, redundant, arbitrary and capricious. The source maintains records

of the date,

time and duration

of the shutdown. The additional records required by these Conditions are

redundant and not necessary to ensure compliance with applicable requirements. Accordingly,

these Condition should

be modified and stayed during the pendency ofthis appeal.

13.

Conditions 7.1.9Cm); 7.2.9Cm); 7.3.9Cm) Recordkeeping Requirements - Start Ups

Petitioner objects to these Conditions because they are unauthorized

by law,

unreasonable, vague, redundant, arbitrary and capricious to the extent they require the source to

maintain records that

go beyond those necessary to ensure compliance with applicable

requirements. These Conditions

are not limited to maintaining records for startups resulting in

an opacity exceedance and requires records that are not necessary to ensure compliance with

applicable requirements. The requirement that the unit achieve "normal operation" within thirty

minutes does not reflect current operating conditions.

It

is unclear what information must be

included when describing the startup and there is no basis for requiring the source to provide the

Agency with a reason for the startup. The requirement to maintain a maintenance and repair log

is duplicative of the requirements in Condition 7.1.9(c), 7.2.9(c), and 7.3.9(c), respectively.

Furthermore, records related to exceedances

of limitations during startups should not be required

unless conditions exist which could result in a deviation from the applicable requirements.

Therefore, these Conditions are unauthorized by law, unreasonable, vague, redundant, arbitrary

and capricious. Accordingly, these Conditions should

be modified and stayed during the

pendency

of this appeal.

-6-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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14.

Conditions 7.1.10(e); 7.2.l0(d); 7.3.l0(e) Reporting Startups

Petitioner objects to these Conditions because they are unauthorized by law, redundant,

unreasonable, arbitrary and capricious. Several other Conditions, including

7.l.l0(a) and

7.1.10(b), 7.2.IO(a) and 7.2.l0(b), and 7.3.l0(a) and 7.3.IO(b), respectively, require the

necessary reporting to ensure compliance with applicable requirements. The information

required by these Conditions are not necessary to ensure compliance with applicable

requirements. Therefore, these Conditions are unauthorized by law, redundant, unreasonable,

arbitrary and capricious. Accordingly, these Conditions should be deleted and stayed during the

pendency of this appeal.

15.

Condition 7 .1.12( e) Compliance Procedures

Petitioner objects to this Condition because it is unauthorized by law, unreasonable,

redundant, arbitrary and capricious to the extent it conflicts with the compliance obligations in

the original construction permit and Condition 7.1.6(b)(ii)(A). According, this Condition should

be modified and stayed during the pendency ofthis appeal.

16.

Condition 7.3.9(j)(ii) Recording Keeping Requirements

Petitioner objects to this Condition because is it arbitrary, capricious, unauthorized by

law and unreasonable. This Condition requires the source to maintain records related to the

deactivation and activation of the water injection system. This condition is inapplicable,

arbitrary and capricious because combustion turbines eT03, CT04 and CT05 do not utilize water

injection systems.

Accordingly, this Condition should be deleted and stayed during the

pendency of this appeal.

-7-

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17.

Condition 7.4 Engines

Petitioner objects to this Condition because it is arbitrary, capricious, and unauthorized

by law to the extent it imposes an emission limit or conditions on sources that are not significant

emission units. For the reasons set forth above, the emergency diesel fire pump and the

emergency diesel generator are listed as insignificant activities under Section 3.1.3 and thus are

not subject

to the conditions and limitations of "affected diesel engines" under Condition 7.4.

This condition is, therefore, in excess

of the Agency's authority, unauthorized by law, arbitrary

and capricious, and unreasonable. Accordingly, this Condition should be deleted and stayed

during the pendency

ofthis appeal.

18.

The Company has met with the Agency and believes the majority, if not all, of the

above issues and conditions can be resolved. However, any such resolution could not occur

within the time frame required for appeal.

So that the parties have sufficient time to resolve

issues and conditions in dispute, including

if necessary the filing of an amended CAAPP permit

application, Ameren requests that the conditions set forth herein be stayed.

WHEREFORE, for the reasons set forth above, Ameren appeals Conditions 3.2.1,

4.0,

5.6.2, 5.7.2, 5.9.2, 7.1.3(f), 7.2.3(e), 7.3.3(f),

7. 1.3 (f)(iv), 7.2.3(e)(iv), 7.3.3(f)(iv),

7.1.5(a)(iii)(A), 7.2.5(a)(iii)(A), 7.3.5(a)(iii)(A), 7.1.8(a)(iii), 7.2.8(a)(iii), 7.3.8(a)(iii), 7.1.9(1),

7.2.9(1), 7.3.9(1), 7.1.9(m), 7.2.9(m), 7.3.9(m),

7. 1.1O(e), 7.2.10(d), 7.3.10(e), 7.1.12(e),

7.3.9(j)(ii), and 7.4

of the CAAPP renewal permit issued March 19,2009, for the Venice Power

Plant and requests that the Board order the Agency to delete or modify the conditions as set forth

above. Additionally, Ameren requests that the Board stay Conditions 3.2.1, 4.0, 5.6.2, 5.7.2,

5.9.2, 7.1.3(f), 7.2.3(e), 7.3.3(f),

7. 1.3 (f)(iv), 7.2.3(e)(iv), 7.3.3(f)(iv), 7.1.5(a)(iii)(A),

7.2.5(a)(iii)(A), 7.3.5(a)(iii)(A), 7.1.8(a)(iii), 7.2.8(a)(iii), 7.3.8(a)(iii), 7.1.9(1), 7.2.9(1), 7.3.9(1),

-8-

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7.1.9(m). 7.2.9(m), 7.3.9(m), 7. 1.1O(e), 7.2.10(d), 7.3.10(e), 7.1.12(e), 7.3.9G)(ii), and 7.4 during

the pendency of this appeal as set forth in Exhibit 2. Ameren will extend its current practices

under the CAAPP permit replaced by this permit issued March

19, 2009, where the Board stays

Conditions appealed herein and will,

of course, comply with all requirements of the Board's

regulations applicable to Venice Power Plant during the pendency of this appeal.

Dated: April 22, 2009

Renee Cipriano

Kathleen

C. Bassi

Joshua R. More

SCHIFF HARDIN, LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5500

Fax: 312-258-2600

kbassi@schiffhardin.com

CH2\

7229488.1

by:

Respectfully submitted,

Union Electric Company d/b/a AmerenUE and

Venice Power Plant

One

of Its Attorneys

-9-

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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EXHIBIT 1

CAAPP PERMIT ISSUED

(MARCH 19, 2009)

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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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

1

:

March 19, 2014

Operation of: Arneren 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 * * * *

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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.S

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.S

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, 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 * * * *

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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

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1.0

INTRODUCTION

1.1

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 ArnerenUE

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

---

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 "T1".

5

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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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

I.D. 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

x

Nitrogen Oxides

NSPS

New Source Performance Standards

PM

Particulate Matter

PM

lO

Particulate matter with an aerodynamic diameter less

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

YOM

Volatile Organic Material

6

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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3.0

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

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 201.2ll, as

follows:

Natural Gas Heaters

<

10.0 rnmBtu/hr

3.1.2

Activities that are insignificant activities based upon maximum

emissions, pursuant to 35 lAC 201.210 (a) (2) or (a) (3), as

follows:

3.1.3 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) (ll) 1.

Gas turbines and stationary reciprocating internal combustion

engines of between 112 kW and 1,118 kW (150 and 1,500

horsepower) power output that are emergency or standby

units

[35 lAC 201.210 (a) (16) 1.

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 Reguirements

Insignificant activities are subject to applicable requirements

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 matter process emission unit, the Permittee

shall comply with the applicable particulate matter emission

limit of 35 rAC 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

---

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

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

appli_cation for this permit is submitted, pursuant to 35 lAC

201.212 (a) .

3.3.2

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

Condi tion 3.1, pursuant to Section 39.5 (12) (b) of the Act.

3.3.3

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

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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4.0

SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Emission

Date

Control

Unit.

Description

Constructed

Equipment

CT02

Twin Pac Natural

Gas

2002

Fired Turbine with

Injection

Distillate Oil as Back-Up

Fuel

(Nominal Capacity

60

MWe)

CTOI

Stationary Gas

Turbine

1967

None

That Drives a Generator

(Nominal Capacity 518

mmBtu!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

l35 MWe

Natural Gas Fired

September

Low NO

x

Turbine

29, 2005

Combustor

System

Fire Pump

Diesel Fire Pump

2002

Emergency

Emergency Diesel

2002

None

Generator

Generator

9

---

5.0

OVERALL SOURCE CONDITIONS

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 National Ambient Air Quality Standards for ozone and PM

2

.

5

and

attainment or unclassifiable for' all other criteria pollutants (CO,

lead,

N0

21

PM

10

, and 30

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, 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 IAC 212.301 and 212.314.

b.

Pursuant to 35 IAC 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 IAC 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 CM. 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 lAC 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,)

372.0

HAP, not included in VOM or PM

----

Total

542.2

Emissions of Hazardous Air Pollutants

Pursuant to Section 39.5(7) (a) of the Act, the emissions of HAPs

from the source shall be less than 10 tons/year for each

individual HAP and 25 tons/year for all HAPs combined as limited

12

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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5.6.3

in Construction Permit 03120068. 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). This condition is being imposed so that the

source is not a major source of HAP emissions. The Permittee

shall fulfill the applicable testing, recordkeeping, and

reporting requirements of Conditions 5.7.2, 5.9.2, and 5.10.2.

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, 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

accordance with procedures adopted 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 IAC

201.282 (a)

1 •

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)

l.

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

---

5.7.2

HAP Testing to Verify Minor Source Status

Pursuant to Condition 5.7.1 and to verify compliance with the

requirements of Condition 5.6.2, that is that this source is not

a major source of HAPs, the following testing requirements are

established:

a.

If in the previous calendar year,

emissions

of HAPs

exceeded 80% of major source threshold for individual or

total HAPs (greater than 8 tons of a single HAP or greater

than 20 tons of total HAPs), then testing for HAPs shall be

conducted as follows:

i.

Testing shall be conducted using methods that would

be acceptable under the federal National Emissions

Standards for Hazardous Air Pollutants for Stationary

Combustion Turbines, 40 CFR 63 Subpart YYYY.

Specifically, the testing procedures detailed at 40

CFR 63.6120 of the performance tests section shall be

used. For multiple turbines, the source owner or

operator shall test largest turbine which makes the

largest contributions to individual and total HAP

emissions.

b.

The calculation as to whether the 80% of major source

threshold was exceeded shall be based on records and

procedures in Condition 5.9.2 and shall be completed

by

January 31 for the previous calendar year. If testing is

required it shall be completed by September 30.

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.

5.8

Source-Wide Monitoring Reguirements

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.

Records for HAP Emissions

a.

The Permittee shall maintain records of individual and

combined HAP emissions on a monthly and annual basis for

14

---

5.9.3

the emission units covered by Section 7 (Unit Specific

Conditions for Specific Emission Units) of this permit to

demonstrate compliance with Condition 5.6.2, pursuant to

Section 39.5 (7) (b) of the Act.

b.

If testing is required by Condition 5.7.2, the Permittee

shall keep records of the testing, including the test date,

conditions, methodologies, calculations, test results, and

any discrepancies between the test results and formulation

specifications of Condition 5.9.2(c) below.

c.

The Permittee shall keep a record of the applicability

determination for 40 CFR 63, Subpart YYYY, National

Emission Standards for Hazardous Air Pollutants for

Stationary Combustion Turbines, at the source for a period

of five years after the determination. This determination

shall include a detailed analysis that demonstrates why the

Permittee believes the source is not subject to 40 CFR 63,

Subpart yyyy.

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 OSEPA, 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

Applicabili ty

This source is an affected source for purposes of the Clean Air

Interstate Rule ("CArR") Program and the following emission

units at the source are affected CArR units:

Turbines CT01 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 CArR 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 CArR provisions.

Applicable CArR Requirements for 80

2

Emissions

The owners and operators of this source shall not violate

applicable CArR provisions, in 35 rAC Part 225, Subpart C. S02

emissions from the affected CArR units shall not exceed the

equivalent number of allowances that the source lawfully holds

under these CArR provisions.

Note: CArR affected sources must hold CArR S02 allowances to

account for the emissions from the affected CArR units. Each

CArR S02 allowance is a limited authorization to emit during the

respective CArR S02 annual period or subsequent period. The

possession of S02 allowances does not authorize exceedances of

applicable emission standards or violations of ambient air

quality standards.

Applicable CArR 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,

emissions from the affected CArR units shall not exceed the

equivalent number of allowances that the source lawfully holds

under these CArR provisions.

Note: CArR affected sources must hold CArR NO

x

allowances to

account for the emissions from the affected CArR units. Each

CArR 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 CArR provisions.

Note:

CAIR affected sources must hold CAIR NO

x

ozone season

allowances to account for the emissions from the affected CAIR

units. Each CAIR NO

x

ozone season allowance is a limited

authorization to emit during the respective CAIR 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 lAC Part

225, Subparts C, 0, 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 CTOl 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. S02 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 S02 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 40 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 does 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, 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 EGO." 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 rAC Part 217, Appendix F].

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

---

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 eTOS

ii.

This permit does not provide "low-emitter status" for

the above emission units pursuant to 35 lAC

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

x

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

217.756 (a) and 217.756 (f) (2) .

b.

Any provision of the NO

x

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 217.756(f) (3).

c.

Any provision of the NO

x

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

common 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 217.756 (f) (4) .

Requirements for NO

x

Allowances

a.

Beginning in 2004, by November 30 of each year, the

allowance transfer deadline, the account representative 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

x

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 lAC 217.756 (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 217.756 (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

---

excess of the number of NO

x

allowances held as provided

above, shall surrender allowances as required for deduction

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 2l7.756(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.

6.3.5

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 S-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 OSEPA.

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

x

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

x

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

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

---

6.3.8

Allocation of NO, 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,

Trading Program), an annual allocation of NO

x

allowances as specified by 35 lAC 217.764 (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 2l7.764(b), an

allocation of NO

x

allowances as specified by 35 IAC

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 pr6-

rata share of any NO

x

allowances remaining after the

allocation of allowances to budget EGU that commence

operation between January I, 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

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

x

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

---

6.3.9

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, 2006, and a pro-rata share of any surplus of NO

x

allowances in the NSSA following the allocation of NO

x

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

x

allowances in the NSSA following the allocation

of NO

x

allowances to new budget EGO.

Note: If the start of the NO

x

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

x

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

x

allowances to

the budget EGU based on their prior operation:

i.

The applicable NO

x

emission rate for the budget EGU

shall be 0.15 1b/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

x

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 rAC 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

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

---

periods one to three years prior to the allocation year,

pursuant to 35 lAC 2l7.768(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

a.

For this source, this segment of the CAAPP Permit, i.e.,

Section 6.3, is the Budget Permit required by the NO

x

Trading Program and is intended to contain federally

enforceable conditions addressing all applicable NO

x

Trading

Program requirements. This Budget Permit shall be treat.ed

as a complete and segregable. portion of the source's entire

CAAPP permit, as provided by 35 lAC 2l7.758(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 2l7.756(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 rAC 2l7.756(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 2l7.756(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

---

Company

Name/

1.D. No.

1

119105AAA

119105AAA

119105AAA

119105AAA

119105AAA

119105AAA

119105AAA

119105AAA

119105AAA.

Union

application shall contain the information specified by 35

lAC 217.758 (b) (2) .

6.3.12 References

35 lAC Part 217 Appendix F - (provisions applicable to the Permittee)

80% of

50% of

2004,

NO,

NO.

NO.

2005,

2007,

Generating

Budget

Budget

Budget

2006

2008

Unit

EGU

Allowances Allowances Allowances Allowances Allowances

2

3

4

5

6

7

8

Turbine

Turbine

4

3

2

4

3

Venice

1

Venice

1

10

8

5

9

8

Venice

2

venice

2

13

10

7

12

10

Venice

3

Venice

3

6

5

3

6

5

Venice

4

Venice

4

7

6

4

7

5

Venice

5

venice

5

15

12

8

14

12

Venice

6

Venice

6

16

13

8

15

13

Venice

7

Venice

7

2

2

1

2

1

Venice

8

Venice

8

2

2

1

2

2

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

7.1.2

7.1. 3

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 (8-11 and

8-12). 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.

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)

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

~paque

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

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

---

permitted from each such emission unit shall be

limited to 3 times in any 24 hour period.

c.

Pursuant to 35 rAe 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 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)(l).

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

x

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)

0.1

< N

-

<

0.25

0.04

+

0.0067(N - 0.1)

N > 0.25

0.005

32

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

---

e.

Where:

N

The nitrogen content of the fuel

(per~ent

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 oper-ator shall cause or allow the

emissions of NO

x

into the atmosphere from the affected

turbine to exceed 0.25 Ibs/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

Subject to the following terms and conditions, the

Permittee

is

authorized to operate the affected turbines in

violation of the applicable standards in Condition 7.1.3(b)

and the hourly limits in Condition 7.1.6 during startup.

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 describing

th.e

33

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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efforts that will be used " ... to minimize startup emissions,

duration of individual starts, and frequency of startups."

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

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* * * * * PCB 2009-095 * * * *

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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 Permittee shall fulfill applicable recordkeeping

and reporting requirements of Condition 7.1.9(m) and

7.1.10(e) .

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.

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

---

7.1. 4

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 Penni ttee 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 operation1with 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.

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 lAC 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 802, 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

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* * * * * PCB 2009-095 * * * *

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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:

A.

Unless specified on a more frequent basis by

manufacturer's written instructions, an

inspection of emissions-related components

shall be completed quarterly. Inspections

shall be conducted in accordance with

manufacturer's written instructions.

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

---

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 IAC, 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.

7.1.6

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 [TI/TIRl.

Fuel

~

Gas

Oil

,

,

NO

x

2

CO

VOM

SO,

PM/PM

lO

(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)'

Ib/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

10

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 Ib/hr was based

on manufacturer's data that did not accurately

represent the PM/PM

10

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,

CO

PM/PM,o

50

2

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

10

) and analysis of fuel sulfur content or

standard factors (S02)'

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

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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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

[T1J.

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

sp~cified

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 O

2

shall be corrected to

ISO standard conditions using the following

41

Electronic Filing - Received, Clerk's Office, April 23, 2009

* * * * * PCB 2009-095 * * * *

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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 stearn generators (HRSG) equipped with

duct 9urners; 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 O

2

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, nun Hg

Po

=observed combustor inlet absolute

pressure at test, nun Hg

Ho

=observed humidity of ambient air, g H2 O/g

air

e

=

transcendental constant, 2.718

Ta

= ambient tempera'ture, 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-IOO 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-lOO percent of peak load, or at

the highest achievable load point if 90-to-IOO

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 * * * *

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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 s.eparately (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) Ii).

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 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 01072-80, 90

(Reapproved 1994); 03246-81, 92, 96; 04468-85

(Reapproved 2000); or 06667-01 (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 CFR

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 CFR 60.8 to

ISO standard day conditions, pursuant to 40 CFR

60.335

(e)

(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.

analysis and their experience with similar tests.

ii.

performed including a discussion of why these

conditions will be representative of maximum

emissions and the means by which the operating

44

---

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

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

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

---

7.1. 8

Monitoring Reguirements

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. The source owner or operator shall also conduct

formal observations of operation and opacity of an

affected turbine upon written request by the Illinois

EPA. With the agreement of the Illinois EPA, the

source owner or operator may schedule these

observations to take place during periods when it

would otherwise be operating the affected turbine.

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

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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 04084-

82, 94, D5504-01, D6228-98, or Gas Processors Association

Standard 2377-86 (all of which are incorporated by

reference-see 40 CFR 60.l7), 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 60.33l(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/lOO 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/lOO scf. At a minimum, the amount of fuel sampling

data specified in section 2.3.1.4 or 2.3.2.4 of appendix 0

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 rAC 217 Subpart V (Condition 7.1.3(e»

shall

install, calibrate, maintain and operate continuous

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e.

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)] :

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

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

The affected turbine shall be equipped, operated, and

maintained with a continuous monitoring system to

monitor and record the fuel consumption

being

fired.

7.1.9

Recordkeepinq

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 lAC 217 Subpart V (Condition 7.1.3(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) ] .

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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 7.1. 8 (d) (iii)) shall comply

with the following recordkeeping and reporting

requirements

[35 lAC 217 .. 712 (b)

1 :

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)

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.l.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

---

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

~uring

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.

The source owner, or operator shall maintain the following

records related to each shutdown of the turbines:

i.

The following information for each shutdown of a

turbine:

A.

Date and time of shutdown.

B.

A description of the shutdown, if written

operating procedures are not followed during

the shutdown or significant problems occur

during the shutdown, including detailed

explanation.

ii.

The following information for the turbines when above

normal opacity has been observed by source personnel:

A.

Name of observer, position and reason for being

at site.

B.

Date and duration of above normal opacity,

including affected turbine, start time and time

normal operation was achieved.

c.

If normal operation was not achieved within 30

minutes, an explanation why startup could not

be achieved within this time.

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D.

A detailed description of the startup,

including reason for operation.

E.

An explanation why established startup

procedures could not be performed, if not

performed.

F.

The nature of opacity following the end of

startup or 30 minutes of operation, whichever

occurs first, and duration of operation until

achievement of normal opacity or shutdown.

G.

Whether an exceedance of Condition 7.1.3(b),

i.e., 30 percent opacity, may have occurred

during startup, with explanation if qualified

observer was on site.

m.

Records for Startup

The Permittee shall maintain the following records,

pursuant to Section 39.5(7) (b) of the Act, for each

affected turbine subject to Condition 7.1.3(b), which at a

minimum shall include:

i.

The following information for each startup of the

affected turbine(s) :

A.

Date and duration of the startup, i.e., start

time and time normal operation achieved.

B.

If normal operation was not achieved within 30

minutes, an explanation why startup could not

be achieved within this time.

C.

A detailed description of the startup,

including reason for operation and whether the

procedures 7.1.3(f) were performed.

D.

An explanation why the procedures of 7.l.3(f)

and other established startup procedures could

not be performed, if not performed.

E.

Whether exceedance of Condition 5.3.2 and

7.l.3(b) may have occurred during startup. If

an exceedance may have occurred, an explanation

of the nature of opacity, i.e., severity and

duration, during the startup and the nature of

opacity at the conclusion of startup.

F.

Whether operating personnel for the turbines or

air environmental staff are on site during

startup.

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ii.

A maintenance and repair log for each affected

turbine, listing each activity performed with date.

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.l.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.l.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 Reguirements

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

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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 rAC

217.712(b) (2)].

ii.

Pursuant to 35 rAC 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 rAC 217.712(c).

e.

Reporting of Startups

The source owner or operator shall submit semi-annual

startup reports to the

Illinois

EPA pursuant to Sections

39.5 (7) (a) and (f) of the Act. These reports shall be

submitted along with the semi-annual reports required by

Condition 7.1.10(c) and shall include the following

information for startups of the affected turbine during the

i.

A list of the startups of the affected turbine,

including the date, duration and description of each

startup,

accompanied

by a copy of the records

pursuant to Condition 7.1.9(i) for each startup for

which such records were required.

ii.

during the reporting period, this shall be stated in

the report.

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 rAC 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.

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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 S02 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 S02 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

requi~ed

in Condition 7.1.9, and the reports.

required in Condition 7.1.10(a).

ii.

Notwithstanding 35 IAC 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 IAC 217.710(b)].

iii. Notwithstanding 35 IAC 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

x

56

---

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 lAC

217.710(c) (l)J.

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) J :

0.7 Ibs/mmBtu - Natural gas

1.2 lbs/mmBtu- Fuel oil

e.

Compliance with the emission limits in Conditions 5.6 and

7.1.6 is addressed by the records and reports required in

Conditions 7.1.9 and 7.1.10, the continuous NOx monitoring

requirements in Condition 7.1.8 or from emission factors

developed from the most recent approved stack test in

accordance with Condition 7.1.7 (NO

x

) ,

standard emission

factors (CO, VOM and PM/PM,o) and analysis of fuel sulfur

content or standard factors (302).

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7.2

Turbine CT01

7.2.1

7.2.2

7.2.3

Description

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

CT01

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 IAC 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 Ibs/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)].

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)].

e.

Startup Provisions

Subject to the following terms and conditions, the

Permittee is authorized to operate the affected turbines in

violation of the applicable standards in Condition 7.2.3(b)

during startup. 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 describing the efforts that will be used " ... to

minimize startup emissions, duration of individual starts,

and frequency of startups."

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:

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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

available to the Illinois EPA upon

request.

iv.

The Permittee shall fulfill applicable recordkeeping

and reporting requirements of Condition 7.2.9(m) and

7.2.10(d) .

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.

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 lAC 201.149, 201.161 and 201.262,

as the Permittee has applied for such authorization in its

application, generally explaining why such continued

60

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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 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.

61

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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 Combust'ion

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 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 S02, 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.

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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:

A.

Unless specified on a more frequent basis by

manufacturer's written instructions, an

inspection of emissions-related components

shall be completed quarterly. Inspections

shall be conducted in accordance with

manufacturer's written instructions.

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

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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

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 O

2

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

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* * * * * PCB 2009-095 * * * *

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NO,

(NO

xo

) (Pr/p

o)

0.5 e19 (Ho-O. 00633)

(288 oK/Tal 1.53

Where:

NO

x

"'" emission concentration of

NO

x

at

15

percent O

2

and ISO standard ambient

conditions, ppm

by

volume, dry basis

NOXa "'" mean observed NO

x

concentration, ppm by

volume, dry basis, at 15 percent 02

P

r

= reference combustor inlet absolute

pressure at 101.3 kilopascals ambient

pressure, rrun Hg

Po

=

observed combustor inlet absolute

pressure at test, mm Hg

Ho

= observed humidity of ambient air,

9 H2 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 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-lOO

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

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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 01072-80, 90

(Reapproved 1994); 03246-81, 92, 96; 04468-85

(Reapproved 2000); or 06667-01 (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 60.8 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

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

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.

68

---

7.2.8

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.

Monitoring Requirements

a.

i.

If an affected turbine is routinely operated or

exercised to confirm that the turbine will operat-e

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

---

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. The source owner or operator shall also conduct

formal observations of operation and opacity of an

affected turbine upon written request by the Illinois

EPA. With the agreement of the Illinois EPA, the

source owner or operator may schedule these

observations to take place during periods when it

would otherwise be operating the aff€cted turbine.

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 IAC 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 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)]:

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

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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

7.2.9

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

Condi tions 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 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 fuel oil used to fire the

turbines as determined in accordance with Condition

7.2.8 (b) .

ii.

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

---

iv.

Records documenting its periodic review of its

operating procedures as required by Condition

7.2.S(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 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 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.

The source owner or operator shall maintain the following

records related to each shutdown of the turbines:

i.

The following information for each shutdown of a

turbine:

A.

Date and time of shutdown.

72

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B.

A description of the shutdown, if written

operating procedures are not followed during

the shutdown or significant problems occur

during the shutdown, including detailed

explanation.

ii.

The following information for the turbines when above

normal opacity has been observed by source personnel:

A.

Name of observer, position and reason for being

at site.

B.

Date and duration of above normal opacity,

including affected turbine, start time and time

normal operation was achieved.

C.

If normal operation was not achieved within 30

minutes, an explanation why startup could not

be achieved within this time.

D.

A detailed description of the startup,

including reason for operation.

E.

An explanation why established startup

procedures could not be performed, if not

performed.

F.

The nature of opacity following the end of

startup or 30 minutes of operation, whichever

occurs first, and duration of operation until

achievement of normal opacity or shutdown.

G.

Whether an exceedance of Condition 7.2.3(b),

i.e., 30 percent opacity, may have occurred

during startup, with explanation if qualified

observer was on site.

m.

Records for Startup

The Permittee shall maintain the following records,

pursuant to Section 39.5(7) (b) of the Act, for each

affected turbine subject to Condition 7.2.3(b), which at a

minimum shall include:.

i.

The following information for each startup of the

affected turbine(s):

A.

Date and duration of the startup, i.e., start

time and time normal operation achieved.

B.

If normal operation was not achieved within 30

minutes, an explanation why startup could not

be achieved within this time.

73

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* * * * * PCB 2009-095 * * * *

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C.

A detailed description of the startup,

including reason for operation and whether the

procedures 7.2.3(f) were performed.

D.

An explanation why the procedures of 7.2.3(f)

and other established startup procedures could

not be performed, if not performed.

E.

Whether exceedance of Condition 5.3.2 and

7.2.3(b) may have occurred during startup. If

an exceedance may have occurred, an explanation

of the nature of opacity, i.e., severity and

duration, during the startup and the nature of

opacity at the conclusion of startup.

F.

Whether operating personnel for the turbines or

air environmental staff are on site during

startup.

ii.

A maintenance and repair log for each affected

turbine, listing each activity performed with date.

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 7.2.3(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

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---

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

25~,

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

x

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) J.

ii.

Pursuant to 35 rAC 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 f"or the source owner

or operator as specified by 35 rAC 217.712(c).

d.

Reporting of Startups

The source owner or operator shall submit semi-annual

startup reports to the Illinois EPA pursuant to Sections

39.5(7) (a) and (f) of the Act. These reports shall be

submitted along with the semi-annual reports required by

Condition 7.2.10(e) (ii) and shall include the following

information for startups of the affected turbine during the

i.

A list of the startups of the affected turbine,

including the date, duration and description of each

startup, accompanied by a copy of the records

pursuant to Condition 7.2.9(i) for each startup for

which such records were required.

ii.

during the reporting period, this shall be stated in

the report.

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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 rAC 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 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:

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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 S02 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.

i.

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 lAC 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 lAC 217.710(b)].

iii. Notwithstanding 35 lAC 217.710(a), Condition

7.2.8(d), the owner or operator of a combustion

turbine that operates less than 350 hour per ozone

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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

78

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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

fir~d.

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 l35 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 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 pers-on,

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 IAC 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

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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

x

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)

0.1

<

N

<

0.25

-

0.04

+

0.0067 (N - 0.1)

N > 0.25

0.005

Where:

80

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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 60.8 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 30, based on a ozone control period

average, for that unit [35 IAC 2l7.706(a)].

ii.

Notwithstanding the above emission limitation of 35

IAC 2l7.706(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 IAC 217 Subpart V and that more stringent

emission limitation

[35 IAC 217.706(b)].

f.

Startup Provisions

Subject to the following terms and conditions, the

Permittee is authorized to operate the affected turbines in

violation

of the applicable standards

in Condition

7.3.3(b)

and the hourly limits in Condition 7.3.6 during startup.

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 describing the

efforts that will be used " ... to minimize startup emissions,

duration of individual starts, and frequency of startups."

81

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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

---

available to the Illinois EPA upon

request.

iv.

The Permittee shall fulfill applicable recordkeeping

and reporting requirements of Condition 7.3.9(m) and

7.3.10(e) .

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.

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 rAC 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

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7.3.4

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 rAC 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 rAC 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 ail terms and conditions

connected with such authorization.

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.

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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

21

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 inspecti.on

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.

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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.

Unless specified on a more frequent basis by

manufacturer's written instructions, an

inspection of emissions-related components

shall be completed quarterly. Inspections

shall be conducted in accordance with

manufacturer's written instructions.

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

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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

x

Lb/mrnBtu

0.057*

Lb/Hr

49.0

CO

Lb/mrnBtu

0.023*

VOM

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, 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 CTOS shall not

exceed the following limitations except during startup and

malfunction or breakdown:

Lb/Hr

83.0

NO,

Lb/mmBtu

0.054*

Lb/Hr

69.0

CO

Lb/mmBtu

0.045*

VOM

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,

Tons/Yr

l72.4

CO

Tons/Yr

96.1

VOM

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,o) and analysis of fuel

sulfur content or standard factors (502), unless

emission monitoring is performed for a pollutant.

iii. A.

Notwithstanding the above, for affected

turbines eT03 and CT04 for CO and YOM, 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

YOM emissions during an hour with a startup

shall be presumed to be 882 lb/hr and 85.8

lb/hr, respectively.

B.

CTOS for CO and VOM, unless an alternative

factor is established or emissions monitoring

is performed, emissions of CO and VOM from

turbine CTOS 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)

[TIl.

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 [T1l.

Testing Requirements

a.

The nitrogen oxides (NO

x

)

emissions, and the oxygen

(02)

concentration and opacity of exhaust shall be measured for

the affected turbines at the source owner or operator's

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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 O

2

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) :

NOx = (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 O

2

and ISO standard ambient

conditions, ppm by volume, dry basis

NO

xo

= mean observed NOx concentration, ppm by

volume, dry basis, at 15 percent O

2

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P

r

=

reference combustor inlet absolute

pressure at 101.3 kilopascals ambient

Po

=

observed combustor inlet absolute

pressure at test, rom Hg

Ho

=observed humidity of ambient air, g H2

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 operating range of the gas turbine,

including the minimum point in the operating

range and 90-to-IOO 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 stearn 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, 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

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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 4D 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 D1072-80, 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).

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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

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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

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(?) 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 fo"r 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) .

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7.3.8

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.

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. The source owner or operator shall also conduct

formal observations of operation and opacity of an

affected turbine upon written request by the Illinois

EPA. With the agreement of the Illinois EPA, the

source owner or operator may schedule these

94

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observations to take place during periods when it

would otherwise be operating the affected turbine.

Note:

The formal observation required above is not

intended to be a USEPA T.est Method 9 opacity test, nor does

the observation require a USEPA Test Method 9 certi'fied

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-