BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

)

COMPANY and ELGIN ENERGY CENTER,

)

)

Petitioner,

)

)

v.

)

PCB

09-

)

(Permit Appeal- Air)

)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

)

Respondent.

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 the

APPEARANCE OF RENEE CIPRIANO,

the

APPEARANCE

OF JOSHUA

R.

MORE

and

APPEAL OF CAAPP PERMIT,

copies of which are herewith

served upon you.

Joshua

f)o---

R. More

Dated: April 24, 2009

Renee Cipriano

Joshua

R. More

SCHIFF HARDIN LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5567

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

)

COMPANY

and ELGIN ENERGY CENTER, )

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

)

)

)

)

)

)

)

)

)

)

APPEARANCE

PCB

09-

--

(Permit Appeal- Air)

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

Company and Elgin Energy Center.

Dated: April 24, 2009

2\7234362

oshua R. More

Schiff Hardin LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

(312) 258-5500

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMEREN

ENERGY GENERATING

)

COMPANY and ELGIN ENERGY CENTER,

)

)

Petitioner,

)

)

v.

) PCB 09-

)

(Permit

Appeal- Air)

)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

)

Respondent.

)

APPEARANCE

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

Company and Elgin Energy Center.

Dated: April 24, 2009

2\7234362

Renee Cipriano

Schiff Hardin LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

(312) 258-5500

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

COMPANY

and ELGIN ENERGY CENTER,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

)

)

)

)

)

)

)

)

)

)

)

)

PCB 09-

--

(Permit Appeal- Air)

APPEAL OF CAAPP PERMIT

NOW COMES Petitioner, Ameren Energy Generating Company and Elgin Energy

Center ("Petitioner" or "Ameren"), pursuant to Section 40.2

of the Illinois Environmental

Protection Act ("Act") (415 ILCS

5/40.2)

and 35 Ill.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

1

(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 1. 35 Ill.Adm.Code

§§ 105.210(a) and (b).

See

Exhibit 1. Pursuant to Section 40.2(a) of the Act and 35

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

In support

of its Petition to appeal Conditions 5.6.2, 5.7.2(b), 5.9.2, 5.10.2, 7.1.3(f),

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

7.1.8(a)(iii), 7.1.9(l)(i), 7.1.9(l)(ii), 7.1.9(l)(iii), 7.1.10(e) and

7.1.12(e) and its request to stay these Conditions, Petitioner states as follows:

I

Application No. 03080009; J.D. No. 031438ABC.

1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

I. BACKGROUND

(35 III.Adm.Code § 105.304(.))

1.

The Elgin Energy Center ("Elgin Energy"), Illinois Environmental Protection

Agency ("Agency") LD. No. 031438ABC, is an electric generating station owned and operated

by Ameren Energy Generating Company. Elgin Energy operates as a peaking station, generating

electric power when sufficient electric power is not available from other sources. Elgin Energy

electrical generating units ("EGUs") are combustion turbines and subject

to the CAAPP (415

ILCS 5/39.5). Elgin Energy is located at 1559 Gifford Road, Elgin, Cook County, Illinois

60120. Cook County is in nonattainment for both Ozone (8-hour, Moderate) and PM-2.5

is in

attainment for all other National Ambient Air Quality Standards. The Agency issued the permit

on March 20, 2009.

II.

REOUEST

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 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

2

---

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 5.6.2, 5.7.2(b), 5.9.2, 5.10.2, 7.1.3(f),

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

7.1.8(a)(iii), 7.1.9(l)(i), 7.1.9(l)(ii), 7.1.9(l)(iii), 7.1.10(e) and

7 .1.12(

e) during the pendency of this appeal.

III. ISSUES ON APPEAL

(351lI.Adm.Code §§ 105.304(a) (2)-(4»

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

4.

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. The source is not a major source for hazardous air pollutant

emissions and the permit was not issued based on the source being a major 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.

5.

Condition 5.7.2(b) - HAP Testing to Verify Minor Source Status

Petitioner objects to this Condition because it is unnecessary 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,

3

---

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

deleted and stayed during the pendency of this appeal.

6.

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.

7.

Condition 5.10.2 - Annual Emission Report

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

by

law to the extent it requires annual emissions reporting for HAP emissions. The source is not a

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

source being a major source for hazardous air pollutant emissions. This Condition is, therefore,

in excess of the Agency's authority, unauthorized by law, arbitrary, capricious and unreasonable.

Accordingly, this Condition should

be modified and stayed during the pendency of this appeal.

8.

Condition 7.1.3(f) - Startup Provisions

Petitioner objects to this Condition because

it is unauthorized by law, arbitrary and

capricious. This Condition incorrectly fails to incorporate certain limitations or provisions from

the current CAAPP permit, which are applicable requirements. Accordingly, this provision

should be modified and stayed during the pendency

of this appeal.

9.

Condition 7. 1.3 (3)(f)(iv) - Startup Provisions

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

law and unreasonable.

This Condition requires the source to fulfill the recordkeeping

4

---

requirements of Condition 7.1.10(e), which for the reasons set forth below should be deleted.

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

of this appeal.

10.

Condition 7.1.5(a)(iii)(A) - Control Requirements and Work Practices

Petitioner objects to this Condition because it unreasonable, 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, this Condition is

arbitrary and capricious, unauthorized

by law and unreasonable. Accordingly, this Condition

should be modified and stayed during the pendency

of this appeal.

11.

Condition 7.1.8(a)(iii) - Monitoring Requirements

Petitioner objects

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

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, this Condition

should be modified and stayed during the pendency

of this appeal.

12.

Condition 7.1.9(1)(i) Recordkeeping Requirements - Startups

Petitioner objects

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

vague, redundant, arbitrary and capricious to the extent it requires the source

to maintain records

that

go beyond those necessary to ensure compliance with applicable requirements.

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. There

is no basis for requiring the

source to provide the Agency with information regarding whether persOlmel are on-site during

startup. Therefore, this Condition is unauthorized by law, unreasonable, vague, redundant,

5

---

arbitrary and capricious. Accordingly, this Condition should be modified and stayed during the

pendency

of this appeal.

13.

Condition 7.1.9(l)(ii) Recordkeeping Requirements - Shutdowns

Petitioner objects to this Condition because it is 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 this Condition are redundant and not

necessary to ensure compliance with applicable requirements. Accordingly, this Condition

should be modified and stayed during the pendency

of this appeal.

14.

Condition 7 .1.9(l)(iii) Recordkeeping Requirements - Opacity

Petitioner objects to this Condition because it is unauthorized

by law, unreasonable,

redundant, arbitrary and capricious. This Condition is 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.

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. Furthermore, the requirement that the unit achieve

"normal operation"

within thirty minutes does not reflect current operating conditions. The additional records

required

by this Condition are redundant and not necessary to ensure compliance with applicable

requirements. Accordingly, this Condition should be modified and stayed during the pendency

of this appeal.

15.

Condition 7.1.10(e) - Reporting Startups

Petitioner objects to this Condition because it is unauthorized

by law, redundant,

unreasonable, arbitrary and capricious.

Several other Conditions, including 7.1.IO(a) and

7 .1.1O(b), require the necessary reporting to ensure compliance with applicable requirements.

6

---

The infonnation required by this Condition is not necessary to ensure compliance with

applicable requirements.

Therefore, this Condition is unauthorized by law, redundant,

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

during the pendency

of this appeal.

16.

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 is duplicative of the reporting requirements in

Condition 7.1.10(a) and conflicts with the compliance obligations in the original construction

pennit and Condition 7.1.6(b). Accordingly, this Condition should be deleted and stayed during

the pendency

of this appeal.

17.

The Company has met with the Agency and believes the majority, ifnot 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 pennit

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

WHEREFORE, for the reasons set forth above, Ameren appeals Conditions 5.6.2,

5.7.2(b), 5.9.2, 5.10.2, 7.1.3(t), 7.1.3(t)(iv), 7.1.5(a)(iii)(A), 7.l.S(a)(iii), 7.1.9(1)(i), 7.1.9(1)(ii),

7.1.9(1)(iii), 7.1.10(e) and 7.1.12(e)

of the CAAPP renewal pennit issued March 20, 2009 for the

Elgin Energy Center 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

5.6.2, 5.7.2(b), 5.9.2, 5.10.2, 7.1.3(t),

7. 1.3 (t)(iv), 7.1.5(a)(iii)(A), 7.l.S(a)(iii), 7.1.9(l)(i),

7.1.9(1)(ii), 7.1.9(1)(iii), 7.1.10(e), and 7.1. 12(e) during the pendency

of this appeal as set forth in

Exhibit 2. Ameren will extend its current practices under the CAAPP pennit replaced by this

7

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

permit issued March 20, 2009, where the Board stays Conditions appealed herein and will, of

course, comply with all requirements of the Board's regulations applicable to Elgin Energy

Center during the

pendency of this appeal.

Dated: April 24, 2009

Renee Cipriano

Joshua R. More

SCHIFF

HARDIN LLP

6600 Sears

Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5500

Fax: 312-258-2600

jmore@schiffhardin.com

CH2\7233965.1

By:

Respectfully submitted,

Ameren Energy Generating Company and

Elgin Energy Center

One

ofIts Attorneys

8

---

EXHIBIT 1

CAAPP PERMIT ISSUED

(MARCH 19, 2009)

---

217/782-2113

RENEWAL

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

PERMITTEE:

Ameren Energy Generating Company

Attn: Michael L. Menne, Vice President Environmental Services

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

I.D. No.:

031438ABC

Application No.:

03080009

Date Received: January 15, 2008

Date Issued: March 20, 2009

Expiration Date

1

:

March 20, 2014

Operation of: Ameren Energy Generating Company, Electric Generation

Source Location: Elgin Energy Center! 1559 Gifford Road, Elgin, Cook County,

60120

Responsible Official:

Michael L. Menne, Vice President Environmental

Services

This permit is hereby granted to the above-designated Permittee to OPERATE an

electric power generation plant, 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 Ross Cooper

at 217/782-2113.

Edwin C. Bakowski, P.E.

Manager, Permit Section

Division of Air Pollution Control

ECB:RWC:psj

cc:

Illinois EPA, FOS, Region 1

CES

Lotus Notes

Except as provided in Condition 8.7 of this permit.

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

TABLE OF CONTENTS

INTRODUCTION

1.1

Source Identification

1.2

Owner/Parent Company

1.3

Operator

1.4

Source Description

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

Emissions Reduction Market System (ERMS)

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

7.1

Turbines (Subject to NSPS - 40 CFR Subpart GG)

GENERAL PERMIT CONDITIONS

8.1

Permit Shield

2

4

6

7

9

10

17

24

50

---

9.0

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

Effect of Permit

9.2

General Obligations of Permittee

9.3

Obligation to Allow Illinois EPA Surveillance

9.4

Obligation to Comply with Other Requirements

9.5

Liability

9.6

Recordkeeping

9.7

Annual Emissions Report

9.8

Requirements for Compliance Certification

9.9

Certification

9.10 Defense to Enforcement Actions

9.11

Permanent Shutdown

9.12 Reopening and Reissuing Permit for Cause

9.13 Severability Clause

9.14 Permit Expiration and Renewal

9.15 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

Clean Air Interstate Rule (CAIR) Permit

Acid Rain Program Permit

3

55

1-1

2-1

3-1

4-1

5-1

6-1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

1.0

INTRODUCTION

1.1

Source Identification

Elgin Energy Center

1559 Gifford Road

Elgin, Illinois 60120

314/554-2816

1.0. No.:

031438ABC

County:

Cook

Standard Industrial Classification: 4911, Electric Utility

1.2

Owner/Parent Company

Arneren Energy Generating Company

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

1.3

Operator

Ameren Energy Generating Company

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

Michael L. Menne, Vice President Environmental Services

314/554-2816

1.4

Source Description

Elgin Energy Center is located at 1559 Gifford Road, Elgin. The source

utilizes four natural gas turbines to generate electricity. In

addition, the turbines control NO

x

with dry low NO

x

combustors.

Note: This narrative description is for informational purposes only

and is not enforceable.

1.5

Title I Conditions

As generally identified below, this CAAPP permit contains certain

conditions for emission units at this source that address the

applicability of permitting programs for the construction and

modification of sources, which programs were established pursuant to

Title I of the Clean Air Act (CAA) and regulations thereunder. These

programs include PSD and MSSCAM, and are implemented by the Illinois

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

Environmental Protection Act (Act). These conditions continue in

effect, notwithstanding the expiration date specified on the first page

of this permit, as their authority derives from Titles I and V of the

CAA, as well as Titles II and X of the Act.

(See also Condition 8.7.)

4

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

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

"TIt!.

5

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

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

lLCS

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

10

Particulate matter with an aerodynamic diameter less than or

equal to a nominal 10 microns as measured by applicable

test

or monitoring methods

PM

2

.

5

Particulate matter with an aerodynamic diameter less

than or

equal to a nominal 2.5 microns as measured by applicable

test or monitoring methods

PSD

Prevention of Significant Deterioration (40 CFR 52.21,

New

Source Review for attainment areas)

RMP

Risk Management

Plan

SO,

Sulfur Dioxide

T1

Title

I

-

identifies Title

I

conditions that have been

carried over from an existing permit

T1N

Title I New

identifies Title

I

conditions that are

being

established in this permit

T1R

Title

I Revised -

identifies Title

I

conditions that have

been carried over from an existing permit and subsequently

revised in this permit

USEPA

United States Environmental

Protection Agency

YOM

Volatile Organic Material

6

---

3.0

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

3.1

Identification of Insignificant Activities

The follow:j..ng activities at the source constitute_ insignOificant

activities as specified in 35 lAC 201.210:

3.1.1

Activities determined

by

the Illinois EPA to be

insignific~nt

activities, pursuant to 35 lAC 201.210 (a) (1) and 201.211, as

follows :"

Indirect Heaters < 10 mmBtu/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:

None

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:

None

3.1.4

Activities. that are considered insignificant activities pursuant

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

to be individually listed.

3.2

Compliance with Applicable Requirements

Insignificant activities are subject to applicable 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

partic~late

matter emission

limit of 35 lAC 212.321 or 212.322 (see Attachment 2) and 35 lAC

Part 266. For example, the particulate matter emissions from

~

process emission unit shall not exceed 0.55 pounds p.er hour." if

the emission unit's process weight rate is 100 pounds peT hour

or less, pursuant to 35 lAC 266.110.

.

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 lAG 218.301;

which requires that organic material emissions not exceed "8..0

pounds per hour or, if no odor nuisance exists, do not

qua~ify

as photochemically reactive material as defined. in 35 lAC.

211.4690.

7

---

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.

3.3

Addition of Insignificant Activities

3.3.1 The Permittee is not required to notify the Illinois EPA of

additional insignificant activities present at the source of a

type that is identified in Condition 3.1, until the renewal

application for this permit is submitted, pursuant to 35 lAC

201.212 (a) .

3.3.2

The Permittee must notify the Illinois EPA of any proposed

addition of a new insignificant activity of a type addressed by

35 lAC 201.210(a) and 201.211 other than those identified in

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

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).

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4.0

. SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

Natural Gas Turbine

CT01

Nominal 135 MW

September

Dry Low NO

x

(1,472 Nominal mmBtu/hr)

2001

Combustors

Natural Gas Turbine

CT03

Nominal 135 MW

September

Dry Low. NO

x

(1,472 Nominal mmBtu/hr)

2001

Combustors

Natural Gas

Turbine

CT02

Nominal

135 MW

September

Dry Low NO

x

(1,472

Nominal mmBtu/hr)

2001

Combustors

Natural Gas Turbine

September

Dry Low NO

x

CT04

Nominal

135 MW

(1,472 Nominal mmBtu/hr)

2001

Combustors

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5.0

OVERALL SOURCE CONDITIONS

5.1

Applicability of Clean Air Act Permit Program (CAAPP)

5.1.1

5.1.2

This permit is issued based on the sO,urce requiring a CAAPP

permit as a major source of NO

x

and CO emissions.

This permit is issued based on the source requiring a CAAPP

permit as an "affected source" for the purposes of Acid

Deposition Control, Title IV of the Clean Air Act, pursuant to

40 CFR 70.3(a) (4).

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 (moderate

nonattainment) and PM

Z

•

5

and attainment or unclassifiable for all other

criteria pollutants (CO, lead,

N0

2f

PM

10

, 8°

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 lAC 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 IAC 212.122, except

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

Ozone Depleting Substances

The Permittee shall comply with the standards for recycling and

emissions reduction of ozone depleting substances pursuant to 40

CFR Part 82, Subpart -F, except as provided for motor vehicle air

conditioners in Subpart B of 40 CFR Part 82:

a.

Persons opening appliances for maintenance, service,

repair, or disposal must comply with the -required practices

pursuant to 40 CFR 82.156.

10

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5.3.4

5.3.5

5.3.6

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.

c.

Persons performing maintenance, service, repair, or

disposal of appliances must be certified

by

an approved

technician certification program pursuan't 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 qompliance.

with all requirements of 40 CFR Part 68, including the

registration and submission of the RMP, as part of. the

annual compliance certification required by Condition 9.8.

Future Emission Standards

a.

Should this stationary source become subject to a new or

revised regulation under 40 CFR Parts 60, 61, 62, or 63, or

35 lAC Subtitle B after the date issued of this permit,

then the owner or operator shall, in accordance with the

applicable regulation(s), comply with the applicable

requirements by the date(s) specified and shall certify

compliance with the applicable requirements of such

regulation(s) as part of the annual compliance

certification, as required by Condition 9.8. This permit.

may also have to be revised or reopened to address such new

or revised regulations (see Condition 9.12.2).

b.

This permit and the terms and conditions herein do not

affect the Permittee's past and/or continuing obligation

with respect to statutory or regulatory requirements

governing major source construction or modification" under

Title I of the CAA. Further, neither the issuance of this

permi t nor any of the terms or conditions of. the. permit..

shall alter or affect the liability of the Permittee for

any violation of appl.icable requirements prior to or. .'at the

time of permit issuance.

Episode Action Plan

a.

Pursuant to 35 IAC 244.141, 244.142, and 244.143, the

Permittee shall maintain at the source and have on file

with the Illinois EPA a written episode action plan (plan.)

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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.

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.l43(d). Such plans shall be further

revised if disapproved by the Illinois EPA.

d.

Any subsequent revisions of the plan shall also be sent to

the Cook County Department of Environmental Control.

5.4

Sourc.e-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

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)

11. 7

Sulfur Dioxide (SO,)

2.9

Particulate Matter (PM)

42.2

Nitrogen Oxides

(NO

x)

235.5

12

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5.6.2

5.6.3

Pollutant

Tons/Year

HAP,

not included in VOM or PM

----

Total

292.3

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.

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 and the requirements of 40 CFR Part 63, Subpart YYYY,

National Emission Standards for Hazardous Air Pollutants for

Stationary Combustion Turbines, do not apply to the source. 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 s-hall 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 E.PA, at

such reasonable times as may be specified by the Illinois

EPA and at the expense of the owner or operator of the

emission source or air pollution control equipment. All

such tests shall be made by or under the direction of a

person qualified by training and/or experience in the field

of air pollution testing. The Illinois EPA shall have the

right to observe all aspects of such tests [35 lAC

201.282 (a) 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 .c?ntrol

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5.7.2

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 rAC 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.

HAP Testing to Verify Minor Source Status

P.ursuant 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 Pollu.tants for S1:.atic:mary

Combustion Turbines, 40 CFR 63 Subpart YYY.Y.

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

testi~g

is

required it shall be completed by May 1st.

c.

Any such tests are also subject to the Testing

Procedur~s

of Condition 8.5 set forth in the General Permit Conditions

of Section 8.

5.8

Source-Wide Monitoring Requirements

Source-wide monitoring requirements are not set for this source.

However, there are provisions for unit specific monitoring set forth in

Section 7 of this permit.

14

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5.9

Source-Wide Recordkeeping Reguirements

5.9.1

5.9.2

5.9.3

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

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

Stat"ionary 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

[40 CFR 63.10 (b) (3) J.

Retention and Availability of Records

a.

All records and logs required by this permit shall"be

retained for at least five years from the date "of entry

(unless a longer retention period is specified by the

particular recordkeeping provision herein), shall be kept

at a location at the source that is readily accessible to

the Illinois EPA or USEPA, and shall be made available for

inspection and copying by the Illinois EPA or USEPA upon

request.

b.

The Permittee shall retrieve and print, on paper during

normal source office hours, any records retained in an"

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

Illinois EPA or USEPA request for records during the course

of a source inspection.

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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, including HAP emissions,

for the previous calendar year.

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

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6.0

CONDITIONS FOR EMISSIONS CONTROL PROGRAMS

6.1

Clean Air Interstate Rule (CAIR) Program

6.1.1

6.1.2

6.1. 3

Applicability

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

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

units at the source are affected CAIR units:

Turbines CT01-04

Note:

Under Section 110 of the Clean Air Act (CAA) , the USEPA

adopted the Clean Air Interstate Rule or CArR, 40 CFR Part 96,

to reduce and permanently cap emissions of sulfur dioxide (80

2

),

and nitrogen oxides (NO

x

)

from electric power plants that

significantly contribute to fine particulate and ozone -in the

ambient air in the Eastern United States. To implement CAIR in

Illinois, the Illinois EPA adopted 35 lAC Part 225 Subparts A,

C, D and E. For purposes of this permit, these requirements are

referred to as CAIR provisions.

Applicable CAIR Requirements for 80

2

Emissions

The owners and operators of this source shall not violate

applicable CAIR provisions, in 35 rAC Part 225, Subpart C. 80

2

emissions from the affected CArR 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 30

2

-allowances to

account for the emissions from the affected CAIR units. Each

CAIR 802 allowance is a limited authorization to emit during the

respective CAIR 80

2

annual period or subsequent period. The

possession of 80

2

allowances does not authorize exceedances of

applicable emission standards or violations of ambient air

quality standards.

Applicable CAlR Requirements for NO

x

Emissions

The owners and operators of this source shall not violate

applicable CAlR provisions, in 35 lAC Part 225, Subpart D. NO

x

emissions from the affected CAIR units shall not exceed the

equivalent number of allowances that the source lawfully holds

under these CAlR provisions.

Note: CAIR affected sources must hold CAIR NO

x

allowances to

account for the emissions from the affected CAIR units. Each

CAIR NO

x

allowance is a limited authorization to emit during the

respective CAIR 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.

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6.1. 4

6.1. 5

6.1. 6

6.1. 7

Applicable CArR Requirements for NO

x

Ozone Season Emissions

The owners and operators of this source shall not violate

applicable CArR provisions, in 35 lAC Part 225, Subpart E.

Seasonal NO

x

emissions from the affected CArR units shall not

exceed the equivalent number of allowances that the source

lawfully holds under these CAIR provisions.

Note:

CAIR affected sources must hold CAIR NO

x

ozone season

allowances to account for the emissions from the affected CArR

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 e'xtent

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 CArR 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 res.trict 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 (CASAl for qualifying projects.

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b.

Where another applicable requirement of the CAA is more

stringent than an applicable requirement of 35 lAC Part

225, Subparts C, D, or E; 40 CFR Part 96; or Title IV of

the CAA, all requirements are incorporated into this permit

and are enforceable and the owners and operators of the

source shall comply with both requirements.

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6.2

Acid Rain Program

6.2.1

6.2.2

6.2.3

6.2.4

Applicabili ty

Under Title IV of the

eAA,

Acid Deposition Control, this -source

is an affected source and the following emission units at the

source are affected units for acid deposition:

Turbines CT01-04

Note: Title IV of the eAA, 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. 80

2

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

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6.3

Emissions Reduction Market System (ERMS)

6.3.1

6.3.2

Description of ERMS

The ERMS is a "cap and trade" market systein for major stationary

sources located in the Chicago ozone nonattainment area. It is

designed to reduce YOM emissions from stationary sources to

contribute to reasonable further progress toward attainment, as

required by Section l82(c) of the CAA.

The ERMS addresses YOM emissions during a seasonal _allotment

period from May 1 through September 30. Participating sources

must hold "allotment trading units" (ATUs) for their actual

seasonal YOM emissions. Each year participating sources are

issued ATUs based on allotments set in the sources' CAAPP

permits. These allotments are established from historical YOM

emissions or "baseline emissions" lowered to provide the

emissions reductions from stationary sources required for

reasonable further progress.

By December 31 of each year, the end of the reconciliation

period following the seasonal allotment period, each source

shall have sufficient ATUs in its transaction account to cover

its actual VOM emissions during the preceding season. A

transaction account's balance as of December 31 will include any

valid ATU transfer agreements entered into as of December 31 of

the given year, provided such agreements are promptly submitted

to the Illinois EPA for entry into the transaction account

database. The Illinois EPA will then retire ATUs in sources'

transaction accounts in amounts equivalent to their seasonal

emissions. When a source does not appear to have sufficient

ATUs in its transaction account, the Illinois EPA will issue a

notice to the source to begin the process for Emissions

Excursion Compensation.

In addition to receiving ATUs pursuant to their allotments,

participating sources may also obtain ATUs from the market,

including ATUs bought from other participating sources and

general participants in the ERMS that hold ATUs (35 lAC 205.630)

and ATUs issued by the Illinois EPA as a consequence of VOM

emissions reductions from an Emissions Reduction Generator or an

lntersector Transaction (35 lAC 205.500 and 35 lAC 205.510) .

During the reconciliation period, sources may also buy ATUs from

a secondary reserve of ATUs managed by the Illinois EPA, the

"Alternative Compliance Market Account" (ACMA) (35 lAC 205.710) .

Sources may also transfer or sell the ATUs that they hold to

other sources or participants (35 lAC 205.630).

Applicability

This permit is issued based on this source not being a

participating source in the Emissions Reduction Market System

(ERMS) , 35 lAC Part 205, pursuant to 35 lAC 205.200.

This is

based on the source's actual VOM emissions during the seasonal

22

---

6.3.3

allotment period from May 1 through Septernbe;r: 30 of ea.ch. year

being less than 10 tons and the sourcels baseline emissions also

being less than 10 tons.

Recordkeeping and Reporting

a.

The Permittee shall maintain the following records to allow

the confirmation of actual VOM emissions during the

seasonal allotment period:

i.

Records of operating data and other information for

each individual emission unit or group 6f related

emission units at the source, as specified in

Sections 5 and 7 of this permit, as appropriate, to

determine actual VOM emissions during the seasonal

allotment period;

ii.

Records of the VOM emissions, in tons, during the

seasonal allotment period, with supporting

calculations, for each individual emission unit or

group of related emission units at the source,

determined in accordance with the procedures'

specified in Sections 5 and 7 of this permit; and

iii. Total VOM emissions from the source, in tons, during

each seasonal allotment period, which .shall be

compiled by November 30 of each year.

b.

In the event that the source's VOM emissions during. the

seasonal allotment period equal or exceed

,10

tons, the

source shall become a participating source in the ERMS and

beginning with the following seasonal allotment period,

shall comply with 35 rAC Part 205, by. holding allotment

trading units (ATUs) for its VOM emissions during each

seasonal allotment period, unless the source obtains

exemption from the ERMS by operating with seasonal VOM

emi.ssions of no more than 15 tons pursuant to a limitation

applied for and established in its CAAPP permit.

23

---

7.0

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

7.1

Natural Gas-Fired Turbine (Subject to NSPS - 40 CFR Subpart GG)

7.1.1

Description

The turbines are process emission units used to generate

electricity. The turbines are powered by natural gas., NO

x

emissions are controlled with dry low NO

x

combustors.

Note: This narrative description is for informational purposes

only and is not enforceable.

7.1.2

List of Emission Units and Air Pollution Control Equipment

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

Natural Gas

Turbine

CT01

Nominal

135 MW

September

Dry Low NO

x

(1,472 Nominal

2001

Combustors

mmBtu/hr)

Natural Gas Turbine

CT03

Nominal

135 MW

September

Dry Low NO

x

(1,472 Nominal

2001

Combustors

mmBtu/hr)

Natural Gas Turbine

CT02

Nominal 135 MW

September

Dry Low NO

x

(1,472 Nominal

2001

Combustors

mmBtu/hr)

Natural Gas Turbine

CT04

Nominal 135 MW

September

Dry Low NO

x

(1,472 Nominal

2001

Combustors

mmBtu/hr)

7.1.3

Applicable Provisions and Regulations

a.

The "affected turbines" for the purpose of these unit-

specific conditions, are turbines described in Conditions

7 . 1. 1 and 7.1. 2 .

b.

Pursuant to 35 lAC 212.123,

i.

No person shall cause or allow the emission of smoke

or other particulate matter, with an opacity greater

than 30 percent, into the atmosphere from any

emission unit.

ii.

The emission of smoke or other particulate matter

from any such emission unit may have an opacity

greater than 30 percent but not greater than 60

percent for a period or periods aggregating 8 minutes

in any 60 minute period provided that such opaque

emissions permitted during any 60 minute period shall

24

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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 excess 2000 ppm.

d.

The affected turbines are" subj ect to the NSPS for

Stationary Gas Turbines, 40 CFR 60 Subparts A and GG,

because the heat input at peak load is equal to pr greater

than 10.7 gigajou1es 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:

25

---

e.

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:

N

The nitrogen content of the fuel (percent by

weight) determined in according with Condition

7.1.S(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 (SOOO 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 217.706(a)].

ii.

Notwithstanding the above emission limitation of 35

IAC 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 IAC 217 Subpart V and that more stringent

emission limitation [35 IAC 217.706(b)].

26

---

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)

during startup, and the hourly emissions limits in

Condition 7.1.6 (b) (i) 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:

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

27

---

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 7.1.9(1) and

7.1.10(e) .

v.

As provided by 35 lAC 201.265, an authorization' in a

permit for excess emissions during startup does not

shield a Permittee from enforcement for any violation

of applicable emission standard(s) that occurs during

startup and only constitutes a prima facie 'defense to

such an enforcement action provided that the

Permittee has fully complied with all terms and

conditions connected with such authorization.

g.

Malfunction and Breakdown Provisions

Subject to the following terms and conditions, the

Permittee is authorized to continue operation of an

affected turbine in violation of the applicable standards

in Condition 7.1.3(b) and the hourly emission limits in

Condition 7.1.6 in the event of a malfunction or breakdown

of the affected turbines. This authorization is provided

pursuant to 3.5 IAC 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.

28

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7.1.4

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(m) and 7.1.10(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

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.

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

29

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7.1. 5

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 IAC 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 IAC 212.323.

d.

The affected turbines are not subject to 35 IAC 217.141 or

35 IAC 216.121 because the affected turbines are not fuel

combustion units, as defined by 35 IAC 211.2470.

e.

The affected turbines are not subject to 40 CFR Part 64,

Compliance Assurance Monitoring (CAM) for Major Stationary

Sources:

i.

For NO

x

and

80

21

because:

A.

The affected turbines are subject to a NSPS

proposed after November 15, 1990, pursuant to

40 CFR 64.2 (b)(l) (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

30

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

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operating procedures that shall .include at a minimum

the following measures:

A.

Review of operating parameters of the uhit

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.

Natural gas shall be the only fuel in the affected

turbines.

c.

The affected turbines shall be equipped, operated, and

maintained with dry low NO

x

combustors to control NO

x

emissions.

d.

The affected turbines, in total, shall not operate more

than 5,744 hours per year [TIl.

i.

Each hour of operation for an affected turbine

operating with wet compression on for power

augmentation shall be counted as 1.55 hours. For

this purpose, wet

compression

for power augmentation

means introducing water into the inlet air duct

immediately before the compressor section of the.

affected turbine following achievement of base power

31

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7.1. 6

output to increase power output from the affected

turbine.

ii.

Each startup hour for an affected turbine shall be

counted as 1.2 hours.

iii. Each hour of operation for an affected turbine

operating in other modes than identified in Condition

7.1.S(d) (i) and (ii) shall be counted as 1 hour.

iv.

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)

[T11 .

v.

The above limitations were established in Permit

00100065, 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

[T11.

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.

The affected turbines, in total, shall not fire more than

8,220 million standard cubic feet of natural gas per year

[T1l .

b.

i.

Hourly emissions from each turbine shall not exceed

the following limits except during startup and

shutdown as addressed by Condition 7.1.3(f) and when

wet compression is on. Compliance with the hourly

limits shall be determined from emission testing (3-

run average) or emission monitoring in accordance

with 7.1.8 (c) (24-hour average)

[T11.

Pollutant

NO,

CO

VOM

SO,

PM/PM,o

(Lb/Hour)

82.0

66.0

2.8

0.9

10.0

ii.

Not withstanding the NO

x

limit above, during operation

of an affected turbine with wet compression on -for

power augmentation, NO

x

emissions shall not'exceed 127

lb/hr (0.087 Ib/mmBtu (HHV))

[T11.

32

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7.1. 7

iii. The annual emissions from the affected turbines

(total 4 turbines) shall not exceed the following

limitations [T1J:

Pollutant

(Ton/Year)

NO,

235.5

CO

237.0

VOM

11. 7

PM/PM

,O

42.2

SO,

2.9

c.

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)

[T1J.

d.

The above limitations were established in Permit 00100065,

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 [T1J.

e.

Unless emission monitoring is performed for a pollutant,

emissions during periods other than startup shall be

determined from emission factors developed from testing in

accordance with Permit 00100065 (NO)(f CO, YOM and PM/PM

10

)

and analysis of fuel sulfur content or standard factors

(SO,) .

f.

For- purpose of determining compliance with the annual

limitations in Condition

7.1.6

(b) (iii), unless an

alternative factor is established for the pollutant or

emissions monitoring is performed for the pollutant,

emissions of NO

x

,

CO and YOM during an hour that includes a

startup shall be presumed to be 120, 700 and 1200 percent

respectively of the limits in Condition 7.1.6(b), i.e. NO

x

,

CO and YOM emissions during an hour with a startup shall be

presumed to be 98.4 lb/hr, 462 lb/hr and 33.6 lb/hr,

respectively. These presumptions are based on data in the

application describing maximum emissions during startup of

an affected turbine. Any alternative factor for emissions

during startup of an affected turbine shall be based on

representative emission testing conducted with USEPA

Reference Test Methods

[T1J.

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

expense by an independent testing service approved by the

33

---

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) :

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

34

---

Pr

= reference combustor inlet absolute

pressure at 101.3 kilopascals ambient

pressure, rom Hg

Po

= observed combustor inlet absolute

pressure at test, rom Hg

Ho

= observed humidity of ambient air, 9 H2 0/ 9

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

3D, 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-100 percent of peak load, or at

the highest achievable load point if 90-to-l00

percent of peak load cannot be physically

achieved in practice. If the turbine combusts

both oil and gas, as primary or backup fuels,

separate performance testing is required for

each fuel. Notwithstanding these requirements,

performance testing is not required for any

emergency fuel (as defined in 40 CFR 60.331),

pursuant to 40 CFR 60.335 (b) (2).

If water or steam injection is used to control

NO

x

with no additional post-combustion NO

x

control and the owner or operator chooses to

monitor the steam or water to fuel ratio in

accordance with 40 CFR 60.334(a), then that

monitoring system must be operated concurrently

with each EPA Method 20, ASTM D6522-00

(incorporated by reference, see 40 CFR 60.17),

or EPA Method 7E run and shall be used to

determine the fuel consumption and the steam or

water to fuel ratio necessary to comply with

the applicable 40 CFR 60.332 NO

x

emission limit,

pursuant to 40 CFR 60.335(b) (4).

If the owner or operator elects to install a

CEMS, the performance evaluation of the CEMS

may either be conducted separately (as

described in paragraph (b) (7)of this section)

or as part of the initial performance test of

the affected unit, pursuant to 40 CFR

60.335(b) (6).

35

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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(£) 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:

For gaseous fuels, ASTM D1072-80, 90

(Reapproved 1994); D3246-81, 92, 96; D4468-85

(Reapproved 2000); or D6667-0l (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

36

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Administrator, pursuant to 40 CFR

60.335 (b) (10) (ii) .

The fuel analyses required under paragraphs

(b) (9) and (b) (10) of this section 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 paragraph

(b) (1) of this section, 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.

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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) .

G.

Turbine/Generator output rate (MW).

v.

Data and calculations, including copies of all raw

data sheets and records of laboratory analyses,

sample calculations, and data on equipment

calibration.

i.

Upon written request by the Illinois EPA, the source

owner or operator shall have the opacity of the

exhaust from the affected turbine(s) tested during

representative operating conditions as determined by

a qualified observer in accordance with USEPA Test

Method 9, as further specified below, pursuant to

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

ii.

Such testing shall be conducted for specific

turbine(s) within 90 calendar days of the request, or

on the date turbine(s) next operates, or on the date

agreed upon by the Illinois EPA, whichever is later.

iii. The duration of opacity observations for each test

shall be at least 30 minutes (five 6-minute_ averages)

unless the average opacities for the first 12 minutes

of observations (two six-minute averages) are both

less than 10.0 percent.

iv.

The source owner or operator shall notify the

Illinois EPA at least 7 days in advance of the date

and time of these tests, in order to allow the

Illinois EPA to witness testing. This notification

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7.1. 8

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 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

39

---

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 paragraph

(h) (3) of this section. The sulfur content of the fuel must

be determined using total sulfur .methods described in 4.0

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, 05504-01, 06228-98, or Gas

Processors Association Standard 2377-86 (all of which are

incorporated by reference-see 40 CFR 60.17), which measure

the major sulfur compounds may be used, pursuant to 40 CFR

60.334 (h) (1); and

Shall monitor the nitrogen content of the fuel combusted in

the turbine, if the owner or operator claims an allowance

for fuel bound nitrogen (i.e., if an F-value greater than

zero is being or will be used by the owner or operator to

calculate STD in 40 CFR 60.332). The nitrogen content of

the fuel shall be determined using methods described in 40

CFR 60.335(b) (9) or an approved alternative, pursuant to 40

CFR 60.334 (h) (2) .

Pursuant to 40 CFR 60.334 (h) (3), notwithstanding the

provisions of paragraph (h) (I) of this section, the owner

or operator may elect not to monitor the total sulfur

40

---

content of the gaseous fuel combusted in the turbine, if

the gaseous fuel is demonstrated to meet the definition of

natural gas in 40 CFR 60.331(u), regardless of whether an

existing custom schedule approved by the administrator for

subpart GG requires such monitoring. The owner- or operator

shall use one of the following sources of information to

make the required demonstration:

The gas quality characteristics in a current, valid

purchase contract, tariff sheet or transportation contract

for the gaseous fuel, specifying that the maximum total

sulfur content of the fuel is 20.0 grains/IOO 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/IOO scf. At a minimum, the amount of fuel sampling

data specified in section 2.3.1.4 or 2.3.2.4 of appendix D

to part 75 of this chapter is required, pursuant to 40" CFR

60.334 (h) (3)

(ii) .

c.

Intentionally left blank.

d.

i.

The owner or operator of an affected turbine subject

to 35 lAC 217 Subpart V (Condition 7.1.3(e»

shall

install, calibrate, maintain and operate continuous

emissions monitoring systems (CEMS) for NO

x

that meet

the requirements of 40 CFR 75, Subpart B [35 lAC

217.710 (a) J •

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 lAC

217 .

71

0 (b)

J •

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 lAC 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 IAC

217.710

(e)

(1) J •

B.

NO

x

emissions shall be determined as the product'

of the heat input, as determined ,above, and the

41

---

e.

i.

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

Recordkeeping Requirements

In addition to the records required by Condition 5.9, the source

owner or operator shall maintain records of the following items

for the affected turbine(s) to demonstrate compliance with

Conditions 5.6.1, 7.1.3, 7.1.5, and 7.1.6, pursuant to Section

39.5 (7) (b) of the Act:

a.

The owner or operator of an affected turbine subject to the

requirements of 35 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)].

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)]:

A.

Maintain records of the heat input and

NO

x

emissions of the turbine as determined in

accordance with 35 lAC 217.710 (c), .and records

of metered fuel use or operating hours used to

determine heat input

[35 lAC 217.712 (b) (1)] .

b.

The source owner or operator shall maintain records of the

following items:

i.

The sulfur content of the natural gas used to fire

the turbines as determined in accordance with

Condition 7.1.8(b).

ii.

A copy of the Final Report(s) for emission testing

conducted pursuant to Condition 7.1.7.

iii. Copies of opacity determinations taken for the source

by qualified observer(s) using USEPA Method 9.

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iv.

Records documenting its periodic review of its

operating procedures as required by Condition

7.l.S(a) .

v.

Information for the formal observations of opacity

conducted pursuant to Condition 7.1.8(a). For each

occasion on which observations are made, these

records shall include the date, time, identity of the

observer, a description of the various observations

that were made, whether or not the affected engine

was running properly, and whether or not .c,9rrective

action is necessary and was subsequently initiated.

c.

A maintenance and repair log for the affected turbine,

listing each activity performed with date.

d.

Intentionally left blank.

e.

Fuel consumption for the affected turbine, scf/month and

scf/year.

f.

g.

i.

Ratio of water to fuel being fired in the affected

turbine.

ii.

Period of time when wet compression is used for power

augmentation.

i.

Actual and effect"ive operating hours for the affected

turbines (total hours, hours for startup, and hours

with wet compression on) .

ii.

Facility operating hours on a daily basis. For this

purpose, the Permittee shall consider the facility to

operate for one hour if one or more turbines are

operated during an hour. For example, if one turbine

or four turbines operate from 12:00 noon to 6:00 PM

on a day, in both cases, this shall count as six

operating hours.

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.

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ii.

If a water injection system is used, any period when

the affected turbine was in operation during which

ice fog was deemed to be a traffic hazard, the

ambient conditions existing during the periods, the

date and time the water injection system was

deactivated, and the date and time the system was

reactivated.

iii. Any day in which emission and/or opacity exceeded an

applicable standard or limit.

k.

The source owner or operator shall keep records of good

operating practices for each turbine.

1.

The source owner or operator shall maintain the following

records related to each startup and shutdown of the

turbines:

i.

The following information for each startup of the

turbines:

A.

Date and time of startup.

B.

Whether operating personnel for the turbines or

air environmental staff are on site during

startup.

C.

A description of the startup, if written

operating procedures are not followed during

the startup or significant problems occur

during the startup, including detailed

explanation.

ii.

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.

iii. The following information for the turbines when above

normal opacity, as defined in Condition 7.1.8, 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.

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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 7.1.3(b),

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

during startup, with explanation if qualified

observer was on site.

m.

Records for Malfunctions and Breakdowns

The Permittee shall maintain records, pursuant to 35 lAC

201.263, of continued operation of an affected turbine

subject to Condition 7.1.3(g) during malfunctions and

breakdown, which as a minimum, shall include:

i.

Date and duration of malfunction or breakdown.

ii.

A detailed explanation of the malfunction or

breakdown.

iii. An explanation why the affected turbine continued to

operate in accordance with Condition 7.1.3(g).

iv.

The measures used to reduce the quantity of emissions

and the duration of the event.

v.

The steps taken to prevent similar malfunctions or

breakdowns or reduce their frequency and severity.

vi.

The amount of release above typical emissions during

malfunction/breakdown.

7.1.10 Reporting Requirements

a.

Reporting of Deviations

The source owner or operator shall promptly notify the

Illinois EPA, Air Compliance Unit, of deviations of the

affected turbine with the permit requirements as follows,

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

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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

shall contain information on excess emissions and

monitoring system downtime reports in accordance with 40

CFR 60.7(c) and 40 CFR 60.334(j).

d.

i.

Annually report the heat input and NO

x

emissions of

the turbine as determined in accordance with 35 lAC

217.710 (c) (Condition 7.1. 8 (c) (iii)), for each ozone

control period, by November 30 of each year

[35 lAC

217.712 (b) (2) J •

ii.

Pursuant to 35 lAC 2l7.7l2(c) and (d), no later than

November 30 of each year, the source owner or

operator shall submit a report to the Illinois EPA

that demonstrates that the affected turbine has

complied with Condition 7.1.3(e). These reports

shall be accompanied by a certification statement

signed by a responsible official for the source owner

or operator as specified by 35 lAC 2l7.7l2(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.l0(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.l0(f) (ii) for each startup

for which such records were required.

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ii.

If there have been no startups of an affected turbine

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 lAC 201.263,

concerning continued operation of an affected turbine

subject to Condition 7.l.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

47

---

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 af.fected 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) .

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 opacity limitations of Conditions

7.1.3(b) 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.

b.

Compliance with the S02 emission limitations of Conditions

7.1.3(c) is addressed by the requirements of Condition

7.1.5, the monitoring requi-rements of 7.1.8, the records

required in Condition 7.1.9, and the reports.required in

Condition 7.1.10.

c.

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

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d.

e.

i.

requirements of Condition 7.1.5, the monitoring

requirements of 7.1.8, the records required in

Condition 7.1.9, and the reports required in

Condition 7.1.10(a).

Compliance with the NO

x

emission limitations of

Conditions 7.1.3(e) is addressed by the requirements

of Condition 7.1.5, the testing requirements of

7.1.7, the monitoring requirements of 7.1.8, the

records required in Condition 7.1.9, and the reports

required in Condition 7.1.10(a).

ii.

Notwithstanding 35 IAC 217.710(a), Condition

7.1.B(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

emissions of the

turbine as follows

[35 IAC 217.710(c)]:

i.

A.

Heat input shall be determined from the metered

fuel usage to the turbine or the calculated

heat input determined as the product of the

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 IAC 217.710 (c) (2)] :

0.7 lbs/mmBtu - Natural gas

1.2 Ibs/mmBtu - Fuel oil

Compliance with the fuel limits in Condition 7.1.6(a)

is addressed by the records and reports required in

Conditions 7.1.9 and 7.1.10.

ii.

Compliance with the emission limits in Conditions 5.6

and 7.1.6(b) is addressed by the records and reports

required in Conditions 7.1.9 and 7.1.10, the

continuous NO

x

monitoring requirements in Condition

7.1.B and from emission factors developed from the

most recent approved stack test in accordance with

Condition 7.1. 6 (e) for NO., CO, YOM and PM/PM" and

7.1.7, and analysis of fuel sulfur content or

standard factors (80

2

),

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8.0

GENERAL PERMIT CONDITIONS

8.1

Permit Shield

Pursuant to Section 39.5(7) (j) of the Act, the Permittee has requested

and has been granted a permit shield. This permit shield provides. that

compliance with the conditions of this permit shall be deemed

compliance with applicable requirements which were applicable as of the

date the proposed permit for this source was issued, provided that

either the applicable requirements are specifically identified within

this permit, or the Illinois EPA, in acting on this permit application,

has determined that other requirements specifically identified are not

applicable to this source and this determination (or a concise summary

thereof) is included in this permit.

This permit shield does not extend to applicable requirements which are

promulgated after January 30, 2009 (the date of issuance of the

proposed permit) unless this permit has been modified to reflect such

new requirements.

8.2

Applicability of Title IV Requirements (Acid Deposition Control)

This source is an affected source under Title IV of the CAA and is

subject to requirements pursuant to Title IV of the CAA as specified in

Section 6.6. To the extent that the federal regulations promulgated

under Title IV of the CAA, are inconsistent with the requirements of

this permit, the federal regulations promulgated under Title IV of the

CAA shall take precedence pursuant to Section 39.5(17) (j) of the Act.

8.3

Emissions Trading Programs

No permit revision shall be required for increases in emissions allowed

under any USEPA approved economic incentives, marketable permits,

emissions trading, and other similar programs or processes for changes

that are provided for elsewhere in this permit and that are authorized

by the applicable requirement [Section 39.5 (7)

(0)

(vii) of the Act].

8.4

Operational Flexibility/Anticipated Operating Scenarios

8.4.1

8.4.2

Changes Specifically Addressed by Permit

Physical or operational changes specifically addressed by the

Conditions of this permit that have been identified as not

requiring Illinois EPA notification may be implemented without

prior notice to the Illinois EPA.

Changes Requiring Prior Notification

The Permittee is authorized to make physical or operational

changes that contravene express permit terms without applying

for or obtaining an amendment to this permit, provided that

[Section 39.5(12) (a) (i) of the Act]:

a.

The changes do not violate applicable requirements;

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b.

The changes do not contravene federally enforceable permit

terms or conditions that are monitoring (including test

methods), recordkeeping, reporting, or compliance

certification requirements;

c.

The changes do not constitute a modification under Title I

of the CAA;

d.

Emissions will not exceed the emissions allowed under this

permit following implementation of the physical or

operational change; and

e.

The Permittee provides written notice to the Illinois EPA,

Division of Air Pollution Control, Permit Section, at least

7 days before commencement of the change.

This notice

shall:

i.

Describe the physical or operational change;

ii.

Identify the schedule for implementing the physical

or operational change;

iii. Provide a statement of whether or not any New Source

Performance Standard (NSPS) is applicable to the

physical or operational change and the reason why the

NSPS does or does not apply;

iv.

Provide emission calculations which demonstrate that

the physical or operational change will not result in

a modification; and

v.

Provide a certification that the physical or

operational change will not result in emissions

greater than authorized under the Conditions of this

permit.

8.5

Testing Procedures

Tests conducted to measure composition of materials, efficiency of

pollution control devices, emissions from process or control equipment,

or other parameters shall be conducted using standard test methods if

applicable test methods are not specified by the applicable regulations

or otherwise identified

in

the conditions of this permit.

Documentation of the test date, conditions, methodologies,

calculations, and test results shall be retained pursuant to the

recordkeeping procedures of

this

permit. Reports of any tests

conducted as required by this permit or as the result of a request by

the Illinois EPA shall be submitted as specified in Conditions 8.6.3

and 8.6.4.

51

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8.6

Reporting Reguirements

8.6.1

8.6.2

Monitoring Reports

Reports summarizing required monitoring as specified in the

conditions of this permit shall be submitted to the Illinois EPA

every six months as follows, unless more frequent submittal of

such reports is required in Sections 5 or 7 of this permit

[Section 39.5(7) (f) of the Act]:

Monitoring Period

Report Due Date

January - June

September 1

July - December

March 1

All instances of deviations from permit requirements must be

clearly identified in such reports. All such reports shall be

certified in accordance with Condition 9.9.

Test Notifications

Unless otherwise specified elsewhere in this permit, a written

test plan for any test required by this permit shall be

submitted to the Illinois EPA for review at least 60 days prior

to the testing pursuant to Section 39.5 (7) (a) of the Act. The

notification shall include at a minimum:

a.

The name and identification of the affected unit(s);

b.

The person(s) who will be performing sampling and analysis

and their experience with similar tests;

c.

The specific conditions under which testing will be

performed, including a discussion of why these conditions

will be representative of maximum emissions and the means

by which the operating parameters for the source and any

control equipment will be determined;

d.

The specific determinations of emissions and operation that

are intended to be made, including sampling and monitoring

locations;

e.

The test method(s) that will be used, with the specific

analysis method, if the method can be used with different

analysis methods;

f.

Any minor changes in standard methodology proposed to

accommodate the specific circumstances of testing, with

justification; and

g.

Any proposed use of an alternative test method, with

detailed justification.

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8.6.3

8.6.4

Test Reports

Unless otherwise specified elsewhere in this permit, the results

of any test required

by

this permit shall be submitted to the

Illinois EPA within 60 days of completion of the testing. The

test report shall include at a minimum [Section 39.5 (7) (e) (i)

of the Act] :

a.

The name and identification of the affected unit(s);

b.

The date and time of the sampling or measurements;

C.

The date any analyses were performed:

d.

The name of the company that performed the tests and/or

analyses;

e.

The test and analytical methodologies used;

f.

The results of the tests including raw data, and/or

analyses including sample calculations;

g.

The operating conditions at the time of the sampling or

measurements; and

h.

The name of any relevant observers present including the

testing company's representatives, any Illinois EPA or

USEPA representatives, and the representatives of the

source.

Reporting Addresses

a.

Unless otherwise specified in the particular provision of

this permit or in the written instructions distributed by

the Illinois EPA for particular reports, reports and

notifications shall be sent to the Illinois EPA - Air

Compliance Unit with a copy sent to the Illinois EPA - Air"

Regional Field Office.

b.

As of the date of issuance of this permit, the" addresses of

the offices that should generally be" utilized for the

submittal of reports and notifications are as follows:

i.

Illinois EPA - Air Compliance Unit

Illinois Environmental Protection Agency

Bureau of Air

Compliance & Enforcement Section (MC 40)

P.O. Box 19276

Springfield, Illinois 62794-9276

53

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ii.

Illinois EPA - Air Quality Planning Section

Illinois Environmental Protection Agency

Bureau of Air

Air Quality Planning Section (MC 39)

P.o. Box 19276

Springfield, Illinois 62794-9276

iii. Illinois EPA - Air Regional Field Office

Illinois Environmental Protection Agency

Division of Air Pollution Control

9511 West Harrison

Des Plaines, Illinois 60016

iv.

USEPA Region 5 - Air Branch

USEPA (AR -

17J)

Air & Radiation Division

77 West Jackson Boulevard

Chicago, Illinois 60604

c.

Permit applications should be addressed to the Air Permit

Section. As of the date of issuance of this permit, the

address of the Air Permit Section is as follows:

8.7

Title I Conditions

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section (MC 11)

P.O. Box 19506

Springfield, Illinois 62794-9506

Notwithstanding the expiration date on the first page of this CAAPP

permit, Title I conditions in this permit, which are identified by a

TI, TIN, or TIR designation, remain in effect until such time as the

Illinois EPA takes action to revise or terminate them in accordance

with applicable procedures for action on Title I conditions. This is

because these conditions either:

(a) incorporate conditions of earlier

permits that were issued by the Illinois EPA pursuant to authority that

includes authority found in Title I of the CAA (T1 conditions), (b)

were newly established in this CAAPP permit pursuant to authority that

includes such Title I authority (TIN conditions), or (c) reflect a

revision or combination of conditions established in this CAAPP permit

(T1R conditions).

(See also Condition 1.5.)

54

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9.0

STANDARD PERMIT CONDITIONS

9.1

Effect of Permit

9.1.1

9.1.2

9.1. 3

The issuance of this permit does not release the Permittee from

compliance with State and Federal regulations which are part of

the Illinois State Implementation Plan, as well as with other

applicable statutes and regulations of the United States or the

State of Illinois or applicable ordinances, except as

specifically stated in this permit and as allowed

by

law and

rule.

In particular, this permit does not alter or affect the

following [Section 39.5 (7) (j) (iv) of the Act]:

a.

The provisions of Section 303 (emergency powers) of the

CAA, including USEPA's authority under that Section;

b.

The liability of an owner or operator of a source for any

violation of applicable requirements prior to or at, the

time of permit issuance;

c.

The applicable requirements of the acid rain program

consistent with Section 408(a) of the CAA; and

d.

The ability of USEPA to obtain information from a source

pursuant to Section 114 (inspections, monitoring, and

entry) of the CAA.

Notwithstanding the conditions of this permit specifying

compliance practices for applicable requirements, pursuant to

Section 39.5(7)(j) and (p) of the Act, any person (including the

Permittee) may also use other credible evidence to establish

compliance or noncompliance with applicable requirements.

9.2

General Obligations of Permittee

9.2.1

Duty to Comply

The Permittee must comply with al.l terms and- conditions of this

permit. Any permit noncompliance constitutes a violation of the

CAA and the Act, and is grounds for any or all of the following:

enforcement action; permit termination, revocation and

reissuance, or modification; or denial of a permit renewal

application [Section 39.5 (7)

(0)

(i) of the Act].

The Permittee shall meet applicable requirements that become

effective during the permit term in a timely manner unless an

alternate schedule for compliance with the applicable

requirement is established.

55

---

9.2.2

9.2.3

9.2.4

9.2.5

Duty to Maintain Equipment

The Permittee shall maintain all equipment covered under this

permit in such a manner that the performance or operation of

such equipment shall not cause a violat'ion of applicable

requirements.

Duty to Cease Operation

NO person shall cause, threaten or allow the continued operation

of any emission unit during malfunction or breakdown of the

emission unit or related air pollution control equipment if such

operation would cause a violation of an applicable"emission

standard, regulatory requirement, ambient air quality standard

or permit limitation unless this permit provides for such

continued operation consistent with the Act and applicable

Illinois Pollution Control Board regulations [Section

39.5 (6) (c) of the Act] .

Disposal Operations

The source shall be operated in such a manner that the disposal

of air contaminants collected by the equipment operations, or

activities shall not cause a violation of the Act or regulations

promulgated there under.

Duty to Pay Fees

The Permittee must pay fees to the Illinois EPA consistent with

the fee schedule approved pursuant to Section 39.5(18) of the

Act, and submit any information relevant thereto [Section

39.5 (7)

(0)

(vi) of the Act]. The check should be payable to

"Treasurer, State of Illinois" and sent to: Fiscal Services

Section, Illinois Environmental Protection Agency, P.O. Box

19276, Springfield, Illinois 62794-9276.

9.3

Obligation to Allow Illinois EPA Surveillance

Upon presentation of proper credentials and other documents as may be

required by law and in accordance with constitutional limitations, the

Permittee shall allow the Illinois EPA, or an authorized representative

. to perform the following

[Sections 4 and 39.5(7) (a) and (p) (ii) of the

Act] :

a.

Enter upon the Permittee's premises where an actual or potential

emission unit is located; where any regulated equipment,

operation, or activity is located or where records must be kept

under the conditions of this permit;

b.

Have access to and copy, at reasonable times, any records that

must be kept under the conditions of this permit;

c.

Inspect during hours of operation any sources, equipment

(including monitoring and air pollution control equipment),

56

---

practices, or operations regulated or required under this

permit;

d.

Sample or monitor any substances or parameters at any location:

i.

At reasonable times, for the purposes of assuring permit

compliance or applicable requirements; or

ii. As otherwise authorized by the CAA, or the Act.

e.

Obtain and remove samples of any discharge or emission of

pollutants authorized by this permit; and

f.

Enter and utilize any photographic, recording, testing,

monitoring, or other equipment for the purposes of preserving,

testing, monitoring, or recording any regulated activity,

discharge or emission at the source authorized by this permit.

9.4

Obligation to Comply with Other Requirements

The issuance of this permit does not release the Permittee from

applicable State and Federal laws and regulations, and applicable "local

ordinances addressing subjects other than air pollution control.

9.5

Liability

9.5.1

9.5.2

9.5.3

9.5.4

9.5.5

Title

This permit shall not be considered as in any manner affecting

the title of the premises upon which the permitted source is

located.

Liability of Permittee

This permit does not release the Permittee from any liability

for damage to person or property caused by or resulting from the

construction, maintenance, or operation of the sources.

Structural Stability

This permit does not take into consideration or attest to the

structural stability of any unit or part of the source.

Illinois EPA Liability

This permit in no manner implies or suggests that the Illinois

EPA (or its officers, agents or employees) assumes any

liability, directly or indirectly, for any loss due to damage,

installation, maintenance, or operation of the source.

Property Rights

This permit .does not convey any property rights of any sort," or

any exclusive privilege [Section 39.5(7) (0) (iv) of the ActJ ..

57

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9.6

Recordkeeping

9.6.1

9.6.2

9.6.3

Control Equipment Maintenance Records

A maintenance record shall be kept on the premises for each item

of air pollution control equipment. At a minimum, this record

shall show the dates o.f performance and nature of preventative

maintenance activities.

Records of Changes in Operation

A record shall be kept describing changes made at the source

that result in emissions of a regulated air pollutant subject to

an applicable requirement, but not otherwise regulated under

this permit, and the emissions resulting from those changes

[Section 39.5(12) (b) (iv) of the Act].

Retention of Records

a.

Records of all monitoring data and support information

shall be retained for a period of at least 5 years from the

date of the monitoring sample, measurement, report, or

application. Support information includes all calibration

and maintenance records, original strip-chart recordings

for continuous monitoring instrumentation, and copies of

all reports required by this permit [Section

39.5 (7) (e) (ii) of the Act].

b.

Other records required by this permit including any logs,

plans, procedures, or instructions required to be kept by

this permit shall be retained for a period of at least 5

years from the date of entry unless a longer period

is

specified by a particular permit provision.

9.7

Annual Emissions Report

The Permittee shall submit an annual emissions report to the Illinois

EPA, Air Quality Planning Section no later than May 1 of the following

year, as required by 35 lAC Part 254.

9.8

Requirements for Compliance Certification

Pursuant to Section 39.5 (7)

(p)

(v) of the Act, the Permittee shall

submit annual compliance certifications. The compliance certifications

shall be submitted no later than May 1 or more frequently as specified

in the applicable requirements or by permit condition. The compliance

certifications shall be submitted to the Air Compliance Unit, Air

Regional Field Office, and USEPA Region 5 - Air Branch. The addresses

for the submittal of the compliance certifications are provided in

Condition 8.6.4 of this permit.

a.

The certification shall include the identification of each term

or condition of this permit that is the basis of the

58

---

certification; the compliance status; whether compliance was

continuous or intermittent; the method(s) used for determining

the compliance status of the source, both currently and over the

reporting period consistent with the conditions of this permit.

b.

All compliance certifications shall be submitted to USEPA Region

5 in Chicago as well as to the Illinois EPA.

c.

All compliance reports required to be submitted shall include a

certification in accordance with Condition 9.9".

9.9

Certification

Any document (including reports) required to be submitted by this

permit shall contain a certification by a responsible official of the

Permittee that meets the requirements of Section 39.5(5) of the Act and

applicable regulations [Section 39.5(7) (p) (i) of the Act]. An example

Certification by a Responsible Official is included as Attachment 1 to

this permit.

9.10 Defense to Enforcement Actions

9.10.1 Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an enforcement

action that it would have been necessary to halt or reduce the

permitted activity in order to maintain compliance with the

conditions of this permit [Section 39.5 (7)

(0)

(ii) of the Act].

9.10.2 Emergency Provision

a.

An emergency shall be an affirmative defense to an action

brought for noncompliance with the technology-based

emission limitations under this permit if the following

conditions are met through properly signed, contemporaneous

operating logs, or other relevant evidence

[Sectio~

39.5 (7) (k) of the Act] :

i~

An emergency occurred as provided in Section

39.5(7) (k) of the Act and the Permittee can identify

the cause(s) of the emergency.

Note: For this purpose, emergency means a situation

arising from sudden and -reasonably unforeseeable

events beyond the control of the source, as further

defined by Section 39.5(7) (k) (iv) of the Act.

ii.

The permitted source was at the time being properly

operated;

iii. The Permittee submitted notice of the emergency to

the

Illinois

EPA within two working days of the time

when emission limitations were exceeded due. to the

emergency. This notice must contain a detailed

59

---

description of the emergency, any steps taken to

mitigate emissions, and corrective actions taken; and

iv.

During the period of the emergency the Permittee took

all reasonable steps to minimize levels of emissions

that exceeded the emission limitations, standards,. or

regulations in this permit.

b.

This provision is in addition to any emergency or upset

provision contained in any applicable requirement. This

provision does not relieve a Permittee of any reporting

obligations under existing federal or state laws or

regulations [Section 39.5 (7) (k) (iv) of the Act].

9.11 Permanent Shutdown

This permit only covers emission units and control equipment while

physically present at the indicated source location(s). Unless this

permit specifically provides for equipment relocation, this permit is

void for the operation or activity of any item of equipment on the date

it is removed from the permitted location(s) or permanently shut down.

This permit expires if all equipment is removed from the permitted

location(s), notwithstanding the expiration date specified on this

permit.

9.12 Reopening and Reissuing Permit for Cause

9.12.1 Permit .Actions

This permit may be modified, revoked, reopened and reissued, or

terminated for cause in accordance with applicable provisions of

Section 39.5 of the Act. The filing of a'request by the

Permittee for a permit modification, revocation and reissuance,

or termination, or of a notification of planned changes or

anticipated noncompliance does not stay any permit condition

[Section 39.5 (7)

(0)

(iii) of the Act].

9.12.2 Reopening and Revision

This permit must be reopened and revised if any of the following

occur [Section 39.5(15) (a) of the Act]:

a.

Additional requirements become applicable to the equipment

covered by this permit and three or more years remain

before expiration of this permit.

b.

Additional requirements become applicable to an affected

source for acid deposition under the acid rain program.

c.

The Illinois EPA or USEPA determines that this permit

contains a material mistake or that inaccurate statement

were made in establishing the emission standards or

limitations, or other terms or conditions of this permit.

60

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d.

The Illinois EPA or USEPA determines that this permit must

be revised or revoked to ensure compliance with the

applicable requirements.

9.12.3 Inaccurate Application

The Illinois EPA has issued this permit based upon the

information submitted by the Permittee in the permit

application. Any misinformation, false statement or

misrepresentation in the application shall be grounds for

revocation and reissuance under Section 39.S{1S) of the Act,

pursuant to Sections 39.5(5)(e) and (i) of the Act.

9.12.4 Duty to Provide Information

The Permittee shall furnish to the Illinois EPA, within a

reasonable time specified by the Illinois EPA any information

that the Illinois EPA may request in writing to determine

whether cause exists for modifying, revoking and reissuing, or

terminating this permit, or to determine compliance with this

permit. Upon request, the Permittee shall also furnish to the

Illinois EPA copies of records required to be kept by this

permit, or for information claimed to be confidential, the

Permittee may furnish such records directly to USEPA along with

a claim of confidentiality [Section 39.5 (7)

(0)

(v) of the Act].

9.13 Severability Clause

The provisions of this permit are severable. In the event of a

challenge to any portion of the permit, other portions of the permit

may continue to be in effect. Should any portion of this permit be

determined to be illegal or unenforceable, the validity of the other

provisions shall not be affected and the rights and obligations of the

Permittee shall be construed and enforced as if this permit did not

contain the particular provisions held to be invalid and the applicable

requirements underlying these provisions shall remain in force

[Section 39.5 (7) (i) of the Act].

9.14 Permit Expiration and Renewal

Upon the expiration of this permit, if the source is operated, it shall

be deemed to be operating without a permit unless a timely and complete

CAAPP application has been submitted for renewal of this permit.

However, if a timely and complete application to renew this CAAPP

permit has been submitted, the terms and all conditions of this CAAPP

permit will remain in effect until the issuance of a renewal permit

[Section 39.5 (5) (1) and

(0)

of the Act] .

Note:

Pursuant to Sections 39.5(5) (h) and (n) of the Act, upon

submittal of a timely and complete renewal application, the permitted

source may continue to operate until final action is taken by the

Illinois EPA on the renewal application, provided, however, that this

protection shall cease if the applicant fails to submit any additional

information necessary to evaluate or take final action on the renewal

61

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* * * * * PCB 2009-097 * * * * *

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application as requested by the Illinois EPA in writing. For a renewal

application to be timely, it must be submitted no later than 9 months

prior to the date of permit expiration.

9.15 General Authority for the Terms and Conditions of this Permit

The authority for terms and conditions of this permit that do not

include a citation for their authority is Section

39~5(7)

(a) of the

Act, which provides that the Illinois EPA shall include.such provisions

in a CAAPP permit as are necessary to accomplish th.e purposes of the

Act and to assure compliance with all applicable requirements. Section

39.5 (7) (a) of the Act is also another basis of authority for terms and

conditions of this permit that do include a specific citation for their

authority.

Note: This condition is included in this permit pursuant to Section

39.5 (7) (n) of the Act.

62

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10.0 ATTACHMENTS

Attachment 1 Example Certification by a Responsible Official

I certify under penalty of law that this document and all attachments

were prepared under my direction or supervision in accordance with a

system designed to assure that qualified personnel properly gather and

evaluate the information submitted. Based on my inquiry of the person

or persons directly responsible for gathering the information, the

information submitted is, to the best of my knowledge and belief, true,

accurate, and complete. I am aware that there are significant

penalties for submitting false information, including the possibility

of fine and imprisonment for knowing violations.

Signature:

Name:

,

Official Title:

Telephone No.:

Date Signed:

1-1

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Attachment 2 Emissions of Particulate Matter from Process Emission Units

a.

New Process Emission Units for Which Construction or

Modification Commenced On or After April 14, 1972

[35 IAC

212.321].

i.

No person shall cause or allow the emission of particulate

matter into the atmosphere in anyone hour period from any

new process emission unit which, either alone or in

combination with the emission of particulate matter from

all other similar process emission units for which

construction or modification commenced on or after

April 14, 1972, at a source or premises, exceeds the

allowable emission rates specified in subsection (c) of 35

lAC 212.321

[35 IAC 212.321(a)].

ii. Interpolated and extrapolated values of the data in

subsection (c) of 35 lAC 212.321 shall be determined by

using the equation [35 lAC 212.321(b)]:

E

A(P)B

where:

P

Process weight rate; and

E

Allowable emission rate; and,

A.

Up to process weight rates of 408 Mg/hr (450 T/hr):

Metric

English

p

Mg/hr

T/hr

E

kg/hr

lb/hr

A

1.214

2.54

B

0.534

0.534

B.

For process weight rate greater than or equal to 408

Mg/hr (450 T/hr):

Metric

English

p

Mg/hr

T/hr

E

kg/hr

lb/hr

A

11. 42

24.8

B

0.16

0.16

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* * * * * PCB 2009-097 * * * * *

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iii. Limits for Process Emission Units For Which Construction or

Modification Commenced On or After April 19, 1972

[35 lAC

212.321

(c)] :

Metric

p

Mg/hr

0.05

0.1

0.2

0.3

0.4

0.5

0.7

0.9

1.8

2.7

3.6

4.5

9.0

13.0

18.0

23.0

27.0

32.0

36.0

41. 0

45.0

90.0

140.0

180.0

230.0

270.0

320.0

360.0

408.0

454.0

E

kg/hr

0.25

0.29

0.42

0.64

0.74

0.84

1. 00

1.15

1. 66

2.1

2.4

2.7

3.9

4.8

5.7

6.5

7.1

7.7

8.2

8.8

9.3

13.4

17.0

19.4

22.0

24.0

26.0

28.0

30.1

30.4

English

p

T/hr

0.05

0.10

0.2

0.30

0.40

0.50

0.75

1. 00

2.00

3.00

4.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

45.00

50.00

100.00

150.00

200.00

250.00

300.00

350.00

400.00

450.00

500.00

E

Ib/hr

0.55

0.77

1.10

1. 35

1.58

1:75

2.40

2.60

3.70

4.60

5.35

6.00

8.70

10.80

12.50

14.00

15.60

17.00

18.20

19.20

20.50

29.50

37.00

43.00

48.50

53.00

58.00

62.00

66.00

67.00

iv. For process weight rates of less than 100 pounds per hour,"

the allowable rate is 0.5 pounds per hour [35 lAC

266.110].

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b.

Existing Process Emission Units for Which Construction or

Modification Prior to April 14, 1972

[35 IAC 212.322J.

i.

No person shall cause or allow the emission of particulate

mat-ter into the atmosphere in anyone hour pe:t:'iod from any

process emission unit for which construction or

modification commenced prior to April 14, 1972, which,

either alone or in combination with the emission of

particulate matter from all other similar process emission

units at a source or premises, exceeds the allowable

emission rates specified in subsection (c) of 35 lAC

212.322

[35 IAC 212.322 (a) J .

ii. Interpolated and extrapolated values of the data in

subsection (c) of 35 IAC 212.321 shall be determined by

using the equation [35 IAC 212.322(b)J:

E

C + A (P) B

where:

P

Process weight rate; and

E

Allowable emission rate; and,

A.

Up to process weight rates up to 27.2 Mg/hr (30

T/hr) :

Metric

English

P

Mg/hr

T/hr

E

kg/hr

1b/hr

A

1. 985

4.10

B

0.67

0.67

C

0

0

B.

For process weight rate

in

excess

of 27.2 Mg/hr

T/hr) :

Metric

English

P

Mg/hr

T/hr

E

kg/hr

lb/hr

A

25.21

55.0

B

0.11

0.11

C

-

18.4

-

40.0

2-3

(30

---

iii. Limits for Process Emission Units

For

Which Construction

or

Modification Commenced Prior to April

14, 1972

[35 lAC

212.322(c)]:

Metric

English

p

E

P

E

Mg/hr

kg/hr

T/hr

1b/hr

0.05

0.27

0.05

0.55

0.1

0.42

0.10

0.87

0.2

0.68

0.2

1. 40

0.3

0.89

0.30

1. 83

0.4

1. 07

0.40

2.22

0.5

1.25

0.50

2.58

0.7

1.56

0.75

3.38

0.9

1. 85

1. 00

4.10

1.8

2.9

2.00

6.52

2.7

3.9

3.00

8.56

3.6

4.7

4.00

10.40

4.5

5.4

5.00

12.00

9.0

8.7

10.00

19.20

13.0

11.1

15.00

25.20

18.0

13.8

20.00

30.50

23.0

16.2

25.00

35.40

27.2

18.15

30.00

40.00

32.0

18.8

35.00

41. 30

36.0

19.3

40.00

42.50

41. 0

19.8

45.00

43.60

45.0

20.2

50.00

44.60

90.0

23.2

100.00

51.20

140.0

25.3

150.00

55.40

180.0

26.5

200.00

58.60

230.0

27.7

250.00

61. 00

270.0

28.5

300.00

63.10

320.0

29.4

350.00

64.90

360.0

30.0

400.00

66.20

400.0

30.6

450.00

67.70

454.0

31.3

500.00

69.00

iv. For process weight rates of less

than 100

pounds per hour,

the allowable

rate

is 0.5 pounds

per hour

[35 lAC

266.110] .

2-4

---

Attachment 3 Compliance Assurance Monitoring (CAM) Plan

There are no specific emission units that require a CAM plan as

identified in the Monitoring Requirements of Subsection 8 for each

Section 7, Unit Specific Conditions for Specific Emission Units.

3-1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

Attachment 4 Guidance

The Illinois has prepared guidance for sources on the Clean Air Act

Permit Program (CAAPP) that is available on the Internet site

maintained by the Illinois EPA, www.epa.state.il.us.This guidance

includes instructions on applying for a revision or renewal of the

CAAPP permit.

Guidance On Revising A CAAPP Permit:

www.epa.state.il.us/air/caapp/caapp-revising.pdf

8

Guidance On Renewing A CAAPP Permit:

www.epa.state.il.us/air/caapp/caapp-renewing.pdf

The application forms prepared by the Illinois EPA for the CAAPP are

also available from the Illinois EPA's Internet site:

www.epa.state.il.us/air/caapp/index.html

These CAAPP application forms should also be used by a CAAPP source

when it applies for a construction permit. For this purpose, the

appropriate CAAPP application forms and other supporting information,

should be accompanied by a completed Application For A Construction

Permit form (199-CAAPP) and Fee Determination for Construction Permit

Application form (197-FEE):

www.epa.state.il.us/air/caapp/199-caapp.pdf

www.epa.state.il.us/a

i

r/permits/197-fee.pdf

4-1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

Attachment 5 Clean Air Interstate Rule (CAIR)Permit

217-782-2113

CAIR PERMIT

Arneren Energy Generating Company

Attn: Michael L. Menne, Designated Representative

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

Oris No.:

IEPA

I.

D. No.:

Source/Unit:

Date Received:

Date Issued:

Expiration Date:

55438

031438ABC

Elgin Energy Center

December 27, 2007

March 20, 2009

March 20, 2014

STATEMENT OF BASIS:

In accordance with the Clean Air Act Interstate Rule (CArR) 80

2

Trading

Program, the CArR NO

x

Annual Trading Program and the CArR NO

x

Ozone Season

Trading Program, and 35 lAC Part 225, Subparts C, 0, and E, respectively, the

Illinois Environmental Protection Agency is issuing this CAIR permit to

Ameren Energy Generating Company for the affected units at its Elgin Energy

Center located at 1559 Gifford Road, Elgin, 60120, i.e., CT01 - CT 04.

ALLOCATION OF SULFUR DIOXIDE (S02) ALLOWANCES, NITROGEN OXIDE (NO.)

ALLOWANCES, AND NO. OZONE SEASON ALLOWANCES FOR THE AFFECTED UNITS:

Program

Allocation of Allowances

CAIR SO,

These units

are not entitled to an allocation of CAIR SO,

Allowances

allowances pursuant

to 40 CFR Part

96.

CArR NO

x

Annual

These units are eligible to an allocation of CArR NO

x

Annual

Allowances

Allowances pursuant to

35 lAC 225.430, 225.435 and 225.440.

CAIR NO

x

Ozone These units are eligible to an allocation of CAIR NO

x

Ozone

Season

Season Allowances pursuant to 35

lAC 225.530, 225.535

and

Allowances

225.540.

PERMIT APPLICATION:

The permit application, which includes CArR S02 Trading

Program requirements, CArR NO

x

Annual Trading Program requirements, CArR NO

x

Ozone Season Trading Program requirements, and other standard requirements,

is attached and incorporated as part of this permit. The owners and

operators, and designated representative of this source must comply with the

standard requirements and special provisions set forth in the application.

COMMENTS, NOTES AND JUSTIFICATIONS:

This permit contains provisions related

to 80

2

emissions and NO

x

emissions and requires the owners and operators to

hold CArR S02 allowances to account for 80

2

emissions, CArR NO

x

annual

allowances to account for annual NO

x

emissions, and CArR NO

x

ozone season

allowances to account for ozone season NO

x

emissions from the CArR units. An

allowance is a limited authorization to

emit

80

2

or NO

x

emissions during or

5-1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

after a specified control period. The transfer of allowances to and from the

applicable compliance or general account does not necessitate a revision to

this permit.

As related to seasonal emissions of NO

x

,

CArR NO

x

Ozone Season Trading Program

supersedes the NO

x

Trading Budget, beginning on the effective date of this

permit. Accordingly, effective January 1, 2009, the provisions of this

permit effectively supersede Section 6.1 of the CAAPP permit, which relate to

compliance with NO

x

Trading Program for Electric Generating Units (EGU).

This CAIR permit does not affect the source's responsibility to meet all

other applicable local, state and federal requirements.

If you have any questions regarding this permit, please contact Ross Cooper

at 217-782-2113.

Edwin C. Bakowski, P.E.

Manager, Permit Section

Division of Air Pollution Control

ECB:RWC:psj

Date Issued:

cc:

Beth Valenziano, Region V - USEPA

FOS - Region 1, Illinois EPA

5-2

---

iU.1i'lo;S EWIRON"EN'I AL PROTECTION AGENCY

OM51Q!N OF AlR "Ol.UfflO'" CONTROL -

t'"KMff

SECTION

P,O, BOX laliOO

SPRINGFIELD, IlUIIOIS

'l279<-~SOO

Application For CArR

10 NUMBFH;

Permit

For

PFfi.MJi

Nf).~

Electrical Generatina Units jEGUJ

DATE:

I{~~iar

#:

_.~.

iht'<l:!:

__ 1_

f

"''' ,,--'"

~RA~NCY~ECNtY

'"'AP''''''"''' rU'in it. M

bel..~

t.)

,p.:~1

~~

(;\(tr !lilt Ael,

1~.tt,~M"

Rut"'tCJllRt

~"t'lII t44~

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t'"'

('.AiR so:

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kI~

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~

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WIlC '--'

·!!~t:~.;t

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eTO.

03143SABC

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.

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cydt!-rlll!YMI~F~f.

CDmbustiollllJrlllrll;

r::J

Fxjl'ti·~;

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o

NowEGU

Ex.isting EGU

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o

ElIir.ling

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o

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NO)'''f'l1wat tl3()iogprogmm

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~

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:'h/"ilt'iblt>lbetl";I~M~t~IW''l$"F~C?~r

APPLICATION PAGE

?rirrecQf Re';'yCWd

P~t

67()-C!..A?P

5-3

FOR Al'PliCAm"$

use

---

~

1

,

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CFR 75

AppemiltlJ)

$

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"

10) -oETERMlNATtON OF NO;::EtJ'SSIONS:

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iii

nqt c;urrur.Uy C9tJippod WlUl

ij

"Pdf115 AttP!fM?O'-conlltlUOuS- e:mi:ssk)fl$ m(.lliiklr"q

~v!;~m

CEMS for

NO

It) EGUs

for

which No.. CEM8 Itl!';l'.al

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H CERTI'ICATIO'"

(aJ

Has a oomplett: CMiW!t.l \.If

I{v£lfliiUl'ltatMJn

for Ihq dlJSi[jled l'flprol;l$entI;l1iv6e for II\{! sOUtOO bOoli llfuDmillIJd to USEPA. 'l\'i1h

a-c;cpYproVidedrO~h(}niltl(jlieF1AY

'" GJYIiI:ii

~

No

'._

(0)

l

i3m

authdfi:md

to matu!

rtUs

$lJbrr',fs~\ru)

Oft behalf

l!J

thv owners and oper3tNS

oj'

tnt:!: :l:ouftl)

t.)f

vtlitu. let which Uu!

iubm~ion

is

~

1

mrtifr

urtdm petuiHy m 1a.'W rtmll nil'll: pelflQrtal1V

~amlfle:il,

and am lamillar

with.

II'!.

tl!at~f4 3n~

!nform."fon

suhrnHkld in

'ihi!.

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its

0tlt!~hmtflt'5.

Baslild an my inqlliry(lf

Ihos;n.

frtItMduiili!$

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ptitf1Qty

r.sporn;ibili;y

for

{lMarl~ lI'te~.

t

'QrtifyNt.the:

Md'M'J#~

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Iflfolm\100n.are tc lhe: bsst of m.y k.oOVo'!ljWjge

~fld

b-eli(:lf 1rull,

2'"'~.

and~.

I

ilt'i Q'Mlrc

I"1lil

~

i:/I'E

~njflCant

penalties

for

submil::bn{)

hil'SQ bwh.'ttlltl1t!s

ant!lf'lfurfMUoo 0'

.critlt!g

~md 1li~tHt ~ h~~.

i~j~"9he-

po5s~!LoI

fmeot

1f't'IP!1P}l.)tl.~nr,

,

...

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(Alt,,~e

DesI9!'.aled

Rep'''''''''t~II''')

:-1;: 4. "",'

P'l/-._

I/'"'

of:?

/cv

.-.

SIG""TURE !!J< __ " .. ___

t

DAn, / /"

APPLICATION PAGE __ _

P"nnw.d on R€<C'ICiec p.apcr

670.CAAPP

5-4

fOR APPUCANT'S USE

P~c2of8

---

(al AWl qat f!EC!.!!,AllOl!S,

Tho "'GuIre_ C!

:10 lAC pm 22'. $_ C OM '"lCfRQ6,

,_tt"""' •

..coo'"

<0

CfR 96,204. aoo 00,200).

'SU~~..s.

~

FFF.

~

COO'no'

Mptlt:: HliH

u iucofporaWG

by~

n 35 fA.C 225.140.

(1Jl

CAI'R

f'C.RM!I I!FQI !Rl511E/:m\:

1~

rr.e

~otO.netatcr'f)(61dt

~

w.1h ()(j04(

\"!kH

CAlR

~1'

uri'~

ill

the~!rulJZed

tlJ 3S

IAC~"

225.

Sobp •• C _1

""ply

1M3 _It .......

"l''''''~-

...... IOy_ .... _"""""",!ItO CAlR SO;,

rradJog!'rogrom

('<:AU<

_n

1Mt __ "'"".". "" ......

,.."'01'35'''"

l!1!=O

2~

TtM:!'

~·or ~Wt

of

~

CAlR SO,jl$QU'ICitilt\1dfith C.4JR SO:tClfli;ill!

&1eSOO!'ra~

ml5lAC P&-t

226.

Ii_rt

c """"

"P" .... VIe

CAIR 00,

""'~'"

"""",._ WI, """ CiUR """"',

10J

MQrilIOO1Ny lmgulRtiMENIS-

1}

The WIl!Jf«oll@l'3t4l'otGtJ"dl CAlR,

S~J.Qtr.mOlmifi!m

CAJ,R

SOr~~

n-soor:te:

It'.t.1$lctJ~WMt

til'?

monllocmo. foPCtOtll) Gnd

r.col'4/u}opillQ

'e11tlir.::ments:

o1.4{\

CFR $6,

$tJ~

HHH. lhl!t CAIR

d8:stgnI~

rUp'nacnlative of un-e:t\ CA1R 00/

~

and mu::hCAm SO; unit at the

CA!R~

'SOUrC2 mtlStoornply

with

f'tt12

5f&C11()(j$.

(It

th~

monilomg.

rnllOOlng

~nd

rewdkeepiJ1lJ

feQUi~

W <40 CFR 96, Subpart HHl-t 1PJliie:R*

lOR

CAlf{ dQ$i9fW1Md 11\1lI'CI<l'ntaUYI},

2}

Too

~pn

..

ntft fif

ead, CAIR SO; source w'iin li'JeemissiOf)S.limitaHort

ptJI'SlJ~~

10 35 tAC US_jitJ{d) wih M

dcturmihoo

b~

1M

~ml$(lIUl'~

fflOO5\JfC;m(rltt.

record~

s:n4

replX'ted

in

.aa:::tlro~Qe

witn<O CFR 00,

.$1.1bt:i~1t

HHI,

I1t'!d 40CFH

'lb.

(d)

GM!$$IQN

IlEalJIREM~

1 f

Byt!ll!t Sil(iWtH1Ql11lmn$kir (10fl13I1fle, midnight

pf

M ...

dt

1. 2Dl1,

~nd.by

munigl1l of Mfil!;h 1

or~dl

tu:bsettl,;lCfl! YE',r

ir Mwch 1

is a

bU$iU'l:$$

ij~y,

jhe cwner Of IJpel1l10f of each CA!R SO) 'SOurct ard .aCh CAIA' SOil

tmit at

ttnt JOUrt:.e

Inuft.llmld a Wflnhge

e~lJ"akmt

if! CAIR Be);;: .UQWilnooB .;l'orailabl.e fMcompliante deductions.

pU~ij.('n.

to

410 eFR

OO,2.54(n}

~fld

(tI) In the CAIR

$OII.iOvrec's:

CAIR so. .. oomplhllflc:e- account. arMarCh 1 it nOt3 bUSlneS'l uav,

tt1e:

,alluw_nC(1lr~ltimt

duadhne

m,,~n$

by midrtghf '"

th& fin.! bl.l!linen (jay

ihereafter. Tt>.t!

hLJlftD+r of :;l!owal1Cils liftld

QI11ne a!kf;fflI;rrcn lratmfer (/I]IWllne may n;R De-le5S tNn me total tonnage equl'llllcni Qf

the

.on~

of SO} eml50siorlt '1)1

N tttnttQf pt}riQd.

"<lm

all CAiR SO) unitt:

at

the CAlF;: SO" SQUfte, 3&

t!~t'n'IirWlI:f

11'1

~ar'lt@

wiit't

4() CFR 00,

.... "",,>1>*1.

2)

EMh -too

(1)( mit:e§$

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~

lit

CAn'~

SO:!

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for Ii!,acb rjay of cnA1tt'1t

ptrlo<l,

$~r1;In9

In :iO 1 0

wilt

0'l1WitutR

iii $il1Rlttrte' Vltllatiott or.35 rAe

Patt

225, SUDpatt c. the Cle.an Air

Ar.:r,..

ant'

~Me-

Act.

3)

~.lI<'b

CAIR

SO"lJtl~""l'"

oubJe<;ttc'tt'\e

rtql,lf(~t5

01 3C tAe 225.:J1D{d)i11 fQr\he: t:(ltlIi'QlIHtriQtt

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Ol1th,

ftttl(ot JaoUiity 1,201 () Of

the

(Jea<Jlinefor

ms.lf~

tbe

unit's rnOrlilDr\rv ce!1Mcatlnn- r&QulremMl&;

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it; a limited

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to

amit~.in a:~

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SO:

~

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t<f

tii¢CAlR

S(:h

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p{~~

N CAlf( pennt ,\iJlP!b1iun, fte CAIR

perM. 0« «re:hd mit

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00 PJrM5iQn

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pa!1 01, all}' CAlR

pemU1cfthOCAlR

SO:S<Mm. This. iL1om.aticamnndnMml 01

~

CAiR wmi-1

will

Il£t de-emed <ill

{l~r~fii;41

oflaw

"nd

'Volll flol require a-:y

funbefrL'~tw

APPLICATION PAGE :::.,3 __

Prinlea (In Rleyclid

Paper

611l-CAAPP

5-5

EQRBfl.ll;Ai&s USE

I

"~.3

of8

---

eo)

BECQR!JKfEP!NGAr~D

HEPQRT!NG REQbJIREMENTS:

l}

Unless. Otllt}i'w/oM pn]'iided,

tho

tlWller m qper.jltQJ

~r

\hI;! CAIR

SO,

SQUfCe all:.i -each Q\JR

-50-1'

unit m the sourw

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at

any

tilfl(!

prior to 100 t;:nd oj

rl~ ~(U:W!

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DA.ICA1'KlN PAGE

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5-10

---

Attachment 6 Acid Rain Program Permit

217-782-2113

ACID RAIN PROGRAM

PERMIT

Ameren Energy Generating Company

Attn: Daniel F. Cole, Designated Representative

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

Oris No.:

IEPA

I.

D. No.:

Source/Unit:

Date Received:

Date Issued:

Effective Date:

Expiration Date:

55438

031438ABC

Elgin Energy Center

May 29, 2008

March 20, 2009

January I, 2009

December 31, 2014

STATEMENT OF BASIS:

In accordance with Section 39.5 (17) (b) of Illinois Environmental Protection

Act and Titles IV and V of the Clean Air Act, the Illinois Environmental

Protection Agency is issuing this Acid Rain Program permit to Ameren Energy

Generating Company for Elgin Energy Center.

SULFUR DIOX_IDE (SO,) ALLOCATIONS AND NITROGEN OXIDE (NO

x

)

RE_QUIREMENTS FOR

EACH AFFECTED UNIT:

These units are not entitled to an

S02 Allowances

allocation of S02 allowances pursuant

to 40 CFR Part 73.

CT01 - CT04

These units are not subject to a NO

x

NO

x

limit

emissions

limitation pursuant

to 40

CFR Part 76.

PERMIT APPLICATION:

The permit application, which includes S02 allowance

requirements and other standard requirements, is attached and incorporated as

part of this permit. The owners and operators of this source must comply

with the standard requirements and special provisions set forth in the

application

COMMENTS, NOTES AND JUSTIFICATIONS:

This permit contains provisions related

to S02 emissions and requires the owners and operators to hold S02 allowances

to account for S02 emissions from the affected units. An allowance is a

limited authorization to emit up to one ton of S02 during or after a specified

calendar year. Although this plant is not eligible for an allowance allocated

by USEPA, the owners or operators may obtain S02 allowances to cover emissions

from other sources under a marketable allowance program. The transfer of

allowances to and from a unit account does not necessitate a revision to the

unit SO, allocations denoted in this permit (See 40 CFR 72.84) .

6-1

---

This permit contains provisions related to NO

x

emissions and requires the

owners and operators to monitor NO

x

emissions from affected units in

accordance with applicable provisions of 40 CFR Part 75. These units are not

subject to a NO

x

emission limitation because USEPA has not adopt,ed such

limitation for simple cycle turbines.

This Acid Rain Program permit does not authorize the construction and operation

of the affected units as such matters are addressed by Titles I and V of the

Clean Air Act. This permit also does not affect the source's responsibility to

meet all other applicable local, state and federal requirements, including 35

lAC Part 225, Subparts C, 0, and E.

If you have any questions regarding this permit, please contact Ross Cooper

at 217/782-2113.

Edwin C. Bakowski, P.E.

Manager, Permit Section

Division of Air Pollution Control

DES:RWC:psj

cc:

Cecilia Mijares, USEPA Region V

Illinois EPA Region 1

6-2

---

.oEPA

STEP 1

la.olily the source by

plont

1i~''''L

Slale, ""U

ORIS code.

STEP 2

Enler the ",>it 1011

for every

.Heeled

unit

at

Ille affected

source In column ""s."

For new unlls, enter lhe

requested information in

columns

~r.:"

and "d.'"

United States

Ef'iviran~l.e1

Protocdott

~tmc:y

Acid Rain Permit Application

ThiS submis!h:1Il1.s;

c:

New

I I

b:~

Stale 11.

Unit ID#

eTOl

CT02

'f,,,

CTIB

CTM

v ..

v ••

d

~----~~-----+------~~--~

,.

~;

"

..

6-3

)

---

STEP 3

ReOOlhe

SIMOa,d

mqu!romenls

Acid Rain. Page

:2

Planl

Nr:tm~

(rom Steo 1

£1gtll ElIl!fgy

Center

Permit ReqJ)irements

(1) The designated representative of each affected source and each affected unit at

the

source shall:

(ii

Submit a complete Acid Rain permit application (i neluding a compliance Pia. n) under

40 CFR part 72 in accordance with the deadlines specified 11140 CFR 72.30; and

(ii) Submit in atimelymannerany supplemental information that the permiltlng authority

determines

is necessary in order to review an Acid Rain permit application and issue

or deny an Acid Rain permit;

(2) The owners and operators of each affected source and each affected unit al the

source shall:

lil Operate the unit in ('.ompliance with a complete ACid Rain permit application or a

superseding Add

~in

oermit issued by the permiUiog authority; and

(Ii) Have an ACld Ram Penmll,

Mopi!oring Requirf!!lli!!l.1!

(1) The owners and operators and, to the extent applicable, designaled representative of

each affected source

and

each affeoted unital the source shaH cornplywith the monlloring

requirements

as provided In 40 CFR part 75.

(21 The emiSSions measureml)nts recorded and reported In accordance with 40 CFR part

,5

shall

be

used to determine compliance

by

the unit with the Acid Rain emissions

limitations and emissions reduction requirements for sulfur dioxide

and nitrogen oxides

under the Acid Rain Program.

(3) The requirements of 40 CPR part 15 shall nol affect. the responsibility of tne owners

and

operators to monilor emi"'5ions of other pollutants or othcr emissions characteristics

at the unit under other appticable requirements of the Act and

ot~1fJ"

provisions of the

opera!ing permit

fOr the source.

Sulfur Dioxide

Reguirqments

(1) The owners and operators of each source and each affected uoll at the source shall:

(i) Hold allowances, as of the allowance transfer deadline. in the unll's compliance

subaccount (after ded uellons under 40CFR 73.34 (e)), orin the compliance subaccount

01 another affected unit at the same source 10 the extent provided in 40 CFR

73.35(b)(3), not less than tho total annual emissions of sulfur dioxide for the previous

calendar year from the lInit; lind

(n) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.

(2) Each

ton of SUlfur diOXide emitted in excess of the Acid Rain emissions limitationS for

sulfur dioxide shall constitute a separate

violation of the Act.

(alAn

affected unit shall

be

subject to the requirements under paragraph (1) of the sulfur

dioxide !'e9uiremenfS as foltows:

(i) Starirng January 1. 2000.

an

affected unit under 40 CFR 72.6(a)(2); or

(ii' Starting on the later of January 1, 2000

Or

lhe deadline for monitor certification

Under 40

CFR

pan 15,

an affected onil ooder 40 CFR 72.6(a)(3).

(4)

Allowances shall

be

held in. deducted from. or transfened among AJfowance Tracking

System accounts in accordance with the Acid Rain Program.

(5)

An allowance shall not be deducted in order 1O comply with the requirements under

paragraph (1) of the sulfur dioxide requirements prior to

the

calendar yearfdr which the

allowance was allocated.

(6) An allowance allocated by the Administrator under the Acid Rain Program is a limited

authorization 10 emit SUlfur dioxide in accordance with the Acid Rain Program. No

provision of Ihe Acid Rain Program. IheAcid Rain permi! appncallon. the Acid Rain permit,

or an exemption under 40 eFR 72.7 or 12.8 and no provision of law shall

be

Q)nslrued

10 limi! the authority of the United States to terminate or limit such authorizaUon.

(7)

An allowance allocated by the Adminislrator under 11)1') Acid Rain Program does not

constitute a properly

right

6-4

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

STEP

~,

Cont'd.

Acid Rain. Page 3

Nitrogc_n Oxides RequirellliIDJs The

OW/1llNl

and operators of the source and each

affected unit

al

the

source shall cempty with

tho

applicable Acid Rain emisSions IImitaijon

for nitrogen Oliides.

Exgess Emissions Requirements

(1)

The designated representative of an affected unit that has excess emissions in any

calendar year shall submit

a

proposed offset plan, as required under

40 CFf!

part

77.

(2) The owners and uperators of a n affected unit lhat has excess emissions

In

any

calendar yearshall:

(i)

Pavwitl10ut demand the penally required, and pay upon demand the Interest on thai

Renalty, as required

by 40

CFR part

17;

and

(iiI Complywilh the terms of an approved offset plan, as required

by

40 CFR part

77.

~!,mlkeepi"g

and Reoortil19 Requirements

(1) Unless otherwise provided, the owners and uperators oflhe sOLlrce and each affected

unit at the source shall keep on site at

!he source eacb of the following documents for a

period of 5 years from

me date the document is created. This period may De extended

lor cause, at any time prlor

to the end of 5 years. in writing by

tho

AdmiF'!l$trator or

permitting

authority:

(i)

The certificate of (epresentalion forthedesignated reprGSGmaliveforthesource and

each affected unit at the source and all documents that demonstrate the Irulh of the

statements in the cerlificate of represenlJ3tion, in accordance wilh 40 CFR 12.24;

provided

tilat the certificate and documents shall

be

retained on sUe at t'he source

beyond such 5.year period until such documents are superseded because

of the

submission

of a new certificate of representation Changing the designated

(epresentattve:

(ii)

Al! emissions monitoring information. in accordance with 40 CPR part 75, provided

lnat to the extent

Ihal40 CFR part 75 provides for a

a.year

period for record keeping,

t'he 3-year period shall apply.

(Iii) Copies

of

all reports, compliance certifications, and other submissions and all

records made or required under !he Acid Rain Program: and.

(iv) Copies

of all documents used to complete an Acid Rain permit appllootlon and any

other submisSion under

the

Acid Rain Program or to demonstratll compliance

with

the

requirements

of

the Acid Rain Program.

(2)

The designated representative of an affecled source aOll each affected unit at the

source shall submit the reports and compliance certifications required undertheAoidRain

Program, including those under

40 CFR part 72 subpart I and 40 CFR part

75.

!.labllity

(1) Any person

whc

knowingly violates any requirement or prohibition of the Acid Rain

Program, a complete Acid Rain permit applicatjon,

an Acid Rain permit, or an exemption

under 40 CFR 12.7

or

72.8,

including any requirement for the payment of any penalty

owed to the United States. shall

be

subject to enforcement purslJant to section 113(e) of

the Act.

(2)

Any person whO knowingly makes a false, material statement in any record,

submission,

or report under the Acid Rain Program shaU be subJect to criminal

enforcement pursuant to section 113(0)

of the Act and 18 U.S.C. 1001.

(3) No permil revision shan excuse any violation

of the

requirements of tile Acid Rain

Program that occurs prior

10 the date that the revision takes effect.

..

(4) Each affected source and each affected unit shall meel the requirements of the Acid

Rain Program,

6-5

---

Acid Rai 11 • Page 4

I' n1 Name lrom Sle 1

IeI' 3,

j.illlbility, Conrd.

Mrd.

rrEP4

!GOO Ihe

edification

latemoot,

ign,aM

atn

(5) Any

provision of the Acid Rain Program that applies to an affected source (inCluding

a provision applicable to the designated representative of an affected source) shall also

apply

to the owners and operators of such source amI of theaffeC:led units althe source.

(6)

Any

provision of the Acid Rain Program Iha! appHes

to

an affected unit (including a

provision applicable

to the deSignated representative of an affected unil) shall also apply

tolhe owners

and operators of such unit. Except as provided under40 Cf:'R72.44 {Phase

II ropowering extension plans) and 4(1 CFR 76.11 (NO, averaging pltms), and except with

regard

to

the requirements applicable to units with a common stack under 40 CFR part 75

(including 40 CFR 75.16, 7fL 11. and 15.18l.lheownersand operators and Ihe designated

(&.~pre.

senlalive 01 one affected unit lihall

not

be liable ror any ViO.lalion. by an. yother

l!ft~cled

unit of which they are nol owners or operators or the d&signated represenlative

<>nd that is located at a 'SOurce of which they are not owners or operators or the

designaled representatlvu.

(7)

Each Violation of a provision of 40 CFR paris 72. 73, 74. 75. 76, 77, and 78 by an

affected source or affected unit, or by an owner

or operator or designated representative

of such source or

unit, Shall be a

sflpara~

violation of the Act.

Effect on

Other Authorilles

No prollision

of the Acid Rain Program, an Acid Rain permit <>pplication. an Acid Rain

permit.

or ar. exemption under 40 eFR 72.7 or 72.8 shall be construed as:

{ll Except as expressly provided In title IV of the Act.

e~empting

or excluding the owners

and operators and,

to the eXlenl applicable. the designated representative of an affected

source

or affected unit from compliance with any other provision of the Act, InCluding the

provisions

of title I of the Act rel!lUng to applicable National AmbientAir Quality Standards

or Stale Implementation Plans;

(21 Limiting the number of allUWlilnces a unit can hold; provided, that the number of

allowances held by

the unit shall not affect the source's obligation to cornply with any

other provisions of the Act;

(3) Requi ring a change of any kind in any SIaIe law regulatlng electric utility rates and

charges, affecting any Stale law regarding such Slate regulatiOn. or limiting such Slate

regulation, including any prudence review requirements under

such State law;

(41 Modifying the

.Fe~eral

Power Act or affecting the authority of the Federal Energy

Regulatory CommiSSIon under the Federal Power Act; or.

.

(51

Interfering with or impairing any prowam for competitive bidding fOf power supply in

a Sla!e in which such program Is established.

.

Certification

I am authorized

10 make this submission on behalf of the owners and operators of .the

affected sou«:e or

affec~d

units for

which

the submission

IS

made. I certify under penalty

of law that I have personally examined.

and am fammar with. the statements ana

information submilled in !his document and all ilS attachments. Based on my inquiry of

those individuals wilh primary responsibility for oblarning

Ine inlorma(lon.1 certify that the

statements and information are

to

Ihe

best of my knowledge and belief true, accurate, and

complete. I am aware that lMre are significant penallies

for

submitting false statements

and information or om ifling required statements and informa!ion, Inctuding the possibility

of fine or imprisonment.

6-6

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

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Page 1

6-1

---

EXHIBIT 2

REDLIEND VERSION OF THE PERMIT

THROUGH SECTION 8

---

217/782-2113

RENEWAL

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

PERMITTEE:

Ameren Energy Generating Company

Attn:

Michael L. Menne, Vice President

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

I.D. No.:

031438ABC

Application No. :

03080009

Environmental Services

Date Received:

January 15, 2008

Date Issued:

March 20, 2009

Expiration Date

1

:

March 20, 2014

Operation of: Ameren Energy Generating CompanYI Electric Generation

Source Location:

Elgin Energy Center, 1559 Gifford Road, Elgin, Cook County,

60120

Responsible Official:

Services

This permit is hereby granted to the above-designated Permittee to OPERATE an

electric power generation plant

t

application. This permit is subject to the conditions contained herein.

If you have any questions concerning this permit, please contact Ross Cooper

at 217/782-2113.

Edwin C. Bakowski, P.E.

Manager, Permit Section

Division of Air Pollution Control

ECB:RWC:psj

cc:

Illinois EPA, FOS, Region 1

CES

Lotus Notes

Except as provided in Condition 8.7 of this permit.

---

1.0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

TABLE OF CONTENTS

INTRODUCTION

1.1

Source Identification

1.2

Owner/Parent Company

1.3

Operator

1.4

Source Description

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

5.2

5.3

5.4

5.5

5.6

5.7

5.8

5.9

5.10

5.11

5.12

Applicability of Clean Air Act Permit Program (CAAPP)

Area Designation

Source-Wide Applicable Provisions and Regulations

Source-Wide Non-Applicability of Regulations of Concern

Source-Wide Control Requirements and Work Practices

Source-wide Production and Emission Limitations

Source-Wide Testing Requirements

Source-Wide Monitoring Requirements

Source-Wide Recordkeeping Requirements

Source-Wide Reporting Requirements

Source-Wide Operational Flexibility/Anticipated Operating

Scenarios

Source-Wide Compliance Procedures

CONDITIONS FOR EMISSIONS CONTROL PROGRAMS

6.1

Clean Air Interstate Rule (CAIR) Program

6.2

Acid Rain

6.3

Emissions Reduction Market System (ERMS)

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

7.1

Turbines (Subject to NSPS - 40 CFR Subpart GG)

GENERAL PERMIT CONDITIONS

8.1

Permit Shield

2

4

6

7

9

10

17

24

50

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

9.0

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

Clean Air Interstate Rule (CAIR) Permit

Acid Rain Program Permit

3

55

1-1

2-1

3-1

4-1

5-1

6-1

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

1.0

INTRODUCTION

1.1

Source Identification

Elgin Energy Center

1559 Gifford Road

Elgin, Illinois 60120

314/554-2816

I.D. No.:

031438ABC

County:

Cook

Standard Industrial Classification: 4911, Electric utility

1.2

Owner/Parent Company

Ameren Energy Generating Company

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

1.3

Operator

Arneren Energy Generating Company

1901 Chouteau Avenue (MC 602)

Post Office Box 66149

St. Louis, Missouri 63166-6149

Michael L. Menne, Vice President Environmental Services

314/554-2816

1.4

Source Description

Elgin Energy Center is located at 1559 Gifford Road, Elgin.

The source

utilizes four natural gas turbines to generate electricity. In

addition, the turbines control NO

x

with dry low NO

x

combustors.

Note: This narrative description is for informational purposes only

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

I

which programs were established pursuant to

Title I of the Clean Air Act (CAA) and regulations thereunder. These

programs include PSD and

MSSCAM

1

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

I

notwithstanding the expiration date specified on the first page

of this

permit

I

as their authority derives from Titles I and V of the

CAA, as well as Titles II and X of the Act.

(See also Condition 8.7.)

4

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

a.

This permit contains Title I conditions that reflect Title I

requirements established in permits previously issued for this

source, which conditions are specifically designated as \\Tl/l.

5

Electronic Filing - Received, Clekr's Office, April 24, 2009

* * * * * PCB 2009-097 * * * * *

---

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. J

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. J

CAAPP

Clean Air Act Permit Program

CAM

Compliance Assurance Monitoring

CEMS

Continuous Emission Monitoring