BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

UNION ELECTRIC

COMPANY d/b/a

)

AMERENUE and GOOSE CREEK POWER

)

PLANT

Petitioner,

v.

ILLINOIS

ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

)

)

)

)

)

)

)

)

)

)

PCB 09-

(Permit

Appeal- Air)

NOTICE OF FILING

To:

John T. Therriault, Assistant Clerk

Illinois Pollution Control Board

James

R. Thompson Center, Suite 11-500

100 West Randolph

Chicago, Illinois 60601

Division

of Legal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 62794-9276

PLEASE TAKE NOTICE that we have today filed with the Office

ofthe Clerk of

the Pollution Control Board

APPEARANCES RENEE CIPRIANO and JOSHUA

R.

MORE

and APPEAL

OF CAAPP PERMIT,

copies of which are herewith served upon you.

Joshua

R. More

Dated: April 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

UNION ELECTRIC COMPANY

d/b/a

)

AMERENUE and GOOSE CREEK POWER

)

PLANT

Petitioner,

v.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

)

)

)

)

)

)

)

)

)

)

PCB 09-

(permit

Appeal- Air)

APPEARANCE

I hereby file my appearance in this proceeding, on behalf of Union Electric Company

d/b/a AmerenUE and Goose Creek Power Plant.

Dated: April 24, 2009

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

UNION

ELECTRIC COMPANY d/b/a

)

AMERENUE and GOOSE

CREEK POWER

)

PLANT

Petitioner,

v.

PCB 09-

)

)

)

)

)

)

)

)

)

)

(permit Appeal- Air)

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

APPEARANCE

I hereby file my appearance in this proceeding, on behalf of Union E;rtric Company

d/b/a AmerenUE and Goose Creek Power Plant.

f

Dated: April 24, 2009

Renee Cipnano

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 2009-099 * * * * *

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

UNION ELECTRIC COMPANY d/b/a

)

AMERENUE and GOOSE CREEK POWER

)

Petitioner,

v.

Respondent.

)

)

)

)

)

)

)

)

)

)

PCB 09-__

APPEAL OF CAAPP PERMIT

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

Goose Creek Power Plant ("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

y

Act Permit Program ("CAAPP") renewal permit! (the "permit") issued on March 20, 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 3.1.3, 4.0, 5.6.2, 5.7.2, 5.9.2, 5.10.2,

7.1.3(f)(iv), 7.1.5(a)(iii)(A), 7.1.6(e), 7.1.8(a)(iii), 7.1.9(1)(i), 7.1.9(1)(ii), 7.1.9(l)(iii), 7.1.l0(e),

7.1.12( e )(ii), 7.2 and its request to stay these Conditions, Petitioner states as follows:

I

Application No. 03080011; J.D. No. 147803AAC

-1-

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

* * * * * PCB 2009-099 * * * * *

---

I. BACKGROUND

(35 II1.Adm.Code § 105.304(a))

I.

The Goose Creek Power Plant ("Goose Creek"), Illinois Environmental Protection

Agency ("Agency") I.D.

No. l47803AAC is an electric generating station owned and operated

by Ameren. Goose Creek Power Plant operates as a peaking station, generating electric power

when sufficient electric power

is not available from other sources. The Goose Creek Power

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

to the CAAPP

(415 ILCS 5/39.5). The Goose Creek Power Plant

is located at 760 E 2150 N Road, Piatt

County, Monticello, Illinois. Piatt County

is attainment for all 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 parcels of the

landfill);

Allied Tube

&

Conduit Corp.

v.

Illinois Environmental Protection Agency,

PCB 96-108

-2-

---

(December 7, 1995) (granted stay of the effectiveness of Conditions 4(a), 5(a), and 7(a) of an air

permit).

3.

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

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

of conditions indicated in Exhibit 2,

i.e.,

Conditions 3.1.3, 4.0, 5.6.2, 5.7.2, 5.9.2, 5.10.2,

7.1.3(f)(iv), 7.1.5(a)(iii)(A), 7.1.6(e), 7.1.8(a)(iii), 7.1.9(1)(i), 7.1.9(l)(ii), 7.1.9(l)(iii), 7.1.10(e),

7.1.12(e)(ii), 7.2 during the pendency

of this appeal.

III. ISSUES ON APPEAL

(35

III.Adm.Code §§ l05.304(a)

(2)-(4»

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

4.

Condition 3.1.3 Insignificant Activities

Petitioner objects to this Condition because it is arbitrary and capricious to the extent that

it fails to include all activities that are insignificant based upon their type or character.

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

of this appeal.

5.

Condition 4.0 Significant Emission Units

Petitioner objects to this Condition because it

is arbitrary, capricious, and unauthorized

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

As

set forth in Condition 3.1.3, the emergency diesel fire pump is listed as an insignificant activity

under Section 3.1.3 and thus inappropriate for listing in the table in Condition 4.0

as a significant

emission unit. This condition is, therefore, in excess

of the Agency's authority, unauthorized by

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

and stayed during the pendency ofthis appeal.

-3-

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

* * * * * PCB 2009-099 * * * * *

---

6.

Condition 5.6.2 Emissions of Hazardous Air Pollutants

Petitioner objects to this Condition because it

is arbitrary, capricious, and unauthorized

by law to the extent it imposes

an emission limit to ensure that the source is not a major source of

hazardous air pollutant emissions. As set forth in Condition 5.1.1, 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.

7.

Condition 5.7.2 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,

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

be

deleted and stayed during the pendency of this appeal.

8.

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.

9.

Condition 5.10.2 Annual Emission Report

Petitioner objects to this Condition because

is it arbitrary, capricious, unauthorized by

law and unreasonable. This Condition requires the source to report emissions to demonstrate

-4-

---

compliance with Condition 5.6.2 as part of its annual emissions report. The source is not a major

source

of hazardous air pollutant emissions and for the reasons set forth above should be deleted.

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

ofthis appeal.

10.

Condition 7. 1.3 (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 reporting 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.

11.

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.

12.

Condition 7.1.6(e) Emission Limitations - Determination

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

and vague to the extent it fails to permit the use

of alternate data sources to determine emission

factors necessary for compliance with this Condition. Accordingly, this Condition should be

modified and stayed during the pendency

of this appeal.

13.

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

-5-

---

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.

14.

Condition 7.1. 9(l)(i) Recordkeeping Requirements - Startups

Petitioner objects

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

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 personnel are on-site during

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

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

pendency of this appeal.

15.

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

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

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 ofthis appeal.

16.

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

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

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

-6-

---

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.

17.

Condition 7.1.10Ce) Reporting Startups

Petitioner objects to this Condition because it

is unauthorized by law, redundant,

unreasonable, arbitrary and capricious.

Several other Conditions, including 7.1.10(a) and

7.l.l0(b) require the necessary reporting to ensure compliance with applicable requirements.

The information 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

ofthis appeal.

18.

Condition 7.1.12Ce)(ii) Compliance Procedures

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

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

the original construction permit and Condition 7.1.6. According, this Condition should be

modified and stayed during the pendency of this appeal.

19.

Condition 7.2 Engines

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

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

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

as an

-7-

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

* * * * * PCB 2009-099 * * * * *

---

insignificant activity under Section 3.1.3 and thus is not subject to the conditions and limitations

of "affected diesel engine" under Condition 7.2. 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.

20.

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

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

within the time frame required for appeal. So that the parties have sufficient time to resolve

issues and conditions in dispute, including if necessary the filing

of an amended CAAPP permit

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

WHEREFORE, for the reasons set forth above, Ameren appeals Conditions 3.1.3, 4.0,

5.6.2, 5.7.2, 5.9.2, 5.10.2, 7.1.3(t)(iv), 7.1.5(a)(iii)(A), 7.1.6(e), 7.1.8(a)(iii), 7.1.9(l)(i),

7.1.9(l)(ii), 7.1.9(l)(iii), 7.1.10(e), 7.1.12(e)(ii), 7.2

of the CAAPP renewal permit issued March

19, 2009, for the Goose Creek Power Plant and requests that the Board order the Agency to

delete or modify the conditions

as set forth above. Additionally, Ameren requests that the Board

stay Conditions 3.1.3, 4.0, 5.6.2, 5.7.2, 5.9.2, 5.10.2, 7.1.3(t)(iv), 7.1.5(a)(iii)(A), 7.1.6(e),

7.1.8(a)(iii), 7.1.9(1)(i), 7.1.9(l)(ii), 7.1.9(l)(iii), 7.1.10(e), 7.1.12(e)(ii), 7.2 during the pendency

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

CAAPP permit replaced by this permit issued March 20, 2009, where the Board stays Conditions

appealed herein and will,

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

applicable to Goose Creek Power Plant during the pendency

of this appeal.

-8-

---

Dated: April 24, 2009

Renee Cipriano

Kathleen C. Bassi

Joshua

R. More

SCHIFF HARDIN, LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5500

Fax: 312-258-2600

imore@schiffuardin.com

CH2\

7233238.1

by:

Respectfully submitted,

Union Electric Company d/b/a AmerenUE and

Goose Creek Power Plant

One

of Its Attorneys

-9-

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EXHIBIT 1

CAAPP PERMIT ISSUED

(MARCH 19, 2009)

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

* * * * * PCB 2009-099 * * * * *

---

217/782-2113

RENEWAL

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

PERMITTEE:

Union Electric Company d/b/a Ameren UE

Attn:

Michael L. Menne, Vice President

1901 Chouteau Avenue

Post Office Box 66149; MC 602

St. Louis, Missouri 63166-6149

1.0. No.:

147803AAC

Application No.:

03080011

Environmental Services

Date Received:

February 19, 2008

Date Issued: March 20, 2009

Expiration Date

1

:

March 20, 2014

Operation of:

Goose Creek Power Plant, Electric Generation

Source Location:

760 E 2150 N Road, Monticello, Piatt County, Illinois,

61856

Responsible Official: Mark C. Birk, Vice President Power Operations

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 3

CES

Lotus Notes

Except as provided in Conditions 1.5 and 8.7 of this permit.

---

1.0

2.0

3.0

4.0

5.0

6.0

7.0

TABLE OF CONTENTS

INTRODUCTION

1.1

Source Identification

1.2

Owner/Parent Company

l.

3

Operator

1.4

Source Description

1.5

Title I Conditions

LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

3.1

Identification of Insignificant Activities

3.2

Compliance with Applicable Requirements

3.3

Addition of Insignificant Activities

SIGNIFICANT EMISSION UNITS AT THIS SOURCE

OVERALL SOURCE CONDITIONS

5.1

Applicability of Clean Air Act Permit Program (CAAPP)

5.2

Area Designation

5.3

Source-Wide Applicable Provisions and Regulations

5.4

Source-Wide Non-Applicability of Regulations of Concern

5.5

Source-Wide Control Requirements and Work Practices

5.6

Source-Wide Production and Emission Limitations

5.7

Source-Wide Testing Requirements

5.8

Source-Wide Monitoring Requirements

5.9

Source-Wide Recordkeeping Requirements

5.10

Source-Wide Reporting Requirements

5.11 Source-Wide Operational Flexibility/Anticipated Operating

Scenarios

5.12

Source-Wide Compliance Procedures

CONDITIONS FOR EMISSIONS CONTROL PROGRAMS

6.1

Clean Air Interstate Rule (CAIR) Program

6.2

Acid Rain

UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS

7.1

Natural Gas-Fired Turbine (Subject to NSPS - 40 CFR

Subpart GG)

7.2

Diesel Engines (Subject to NESHAP - 40 CFR 63 Subpart

ZZZZ)

2

4

6

7

9

10

17

22

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

* * * * * PCB 2009-099 * * * * *

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8.0

9.0

GENERAL PERMIT CONDITIONS

8.1

Permit Shield

8.2

Applicability of Title IV Requirements

8.3

Emissions Trading Programs

8.4

Operational Flexibility/Anticipated Operating Scenarios

8.5

Testing Procedures

8.6

Reporting Requirements

8.7

Title I Conditions

STANDARD PERMIT CONDITIONS

9.1

9.2

9.3

9.4

9.5

9.6

9.7

9.8

9.9

9.10

9.11

9.12

9.13

9.14

9.15

Effect of Permit

General Obligations of Permittee

Obligation to Allow Illinois EPA Surveillance

Obligation to Comply with Other Requirements

Liability

Recordkeeping

Annual Emissions Report

Requirements for Compliance Certification

Certification

Defense to Enforcement Actions

Permanent Shutdown

Reopening and Reissuing Permit for Cause

Severability Clause

Permit Expiration and Renewal

General Authority for the Terms and Conditions of this

Permit

10.0 ATTACHMENTS

1

2

3

4

5

6

Example Certification

by

a Responsible Official

Emissions of Particulate Matter from Process Emission

Units

Compliance Assurance Monitoring (CAM) Plan

Guidance

Clean Air Interstate Rule (CAIR) Permit

Acid Rain Program Permit

3

57

62

1-1

2-1

3-1

4-1

5-1

6-1

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

* * * * * PCB 2009-099 * * * * *

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1.0

INTRODUCTION

1.1

Source Identification

Union Electric Company d/b/a Ameren VE

760 E 2150 N Road

Monticello, Illinois 61856

314/554-2089

I.D. No.:

147803AAC

County: Piatt

Standard Industrial Classification: 4911, Electric Generation

1.2

Owner/Parent Company

Union Electric Company d/b/a Ameren

VE

1901 Chouteau Avenue

Post Office Box 66149; MC 602

St. Louis, Missouri 63166-6149

1.3

Operator

Union Electric Company d/b/a Ameren DE

1901 Chouteau Avenue

Post Office Box 66149; MC 602

St. Louis, Missouri 63166-6149

Michael L. Menne, Vice President Environmental Services

314/554-3647

1.4

Source Description

Ameren UE Goose Creek Power Plant is located at 760 E 2150 N Road.

The

source utilizes

six

natural gas fired turbines to generate electricity.

In addition, the turbines control NO

x

with dry low NO

x

combustion

systems.

Note: This narrative description is for informational purposes only

and is not enforceable.

1.5

Title I Conditions

As generally identified below, this CAAPP permit contains certain

conditions for emission units at this source that address the

applicability of permitting programs for the construction and

modification of sources, which programs were established pursuant to

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

These

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

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

Environmental Protection Act (Act). These conditions continue in

effect, notwithstanding the expiration date specified-on the first page

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

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

(See also Condition 8.7.)

4

---

a.

This permit contains Title I conditions that reflect Title I

requirements established in permits previously issued for this

source, which conditions are specifically designated as "Tl".

5

---

2.0

LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED

ACMA

Alternative Compliance Market Account

Act

Illinois Environmental

Protection Act [415 ILCS 5/1 et

seq.]

AP 42

Compilation of Air Pollutant Emission Factors, Volume

1,

Stationary Point and Other Sources (and Supplements A

through F),

USEPA,

Office of Air Quality Planning and

Standards, Research Triangle Park, NC 27711

ATU

Allotment Trading Unit

BACT

Best Available Control Technology

BAT

Best Available

Technology

CAA

Clean Air Act [42 U.S.C. Section 7401 et seq.]

CAAPP

Clean Air Act Permit Program

CAM

Compliance Assurance Monitoring

CEMS

Continuous Emission Monitoring System

CFR

Code of Federal Regulations

CO

Carbon Monoxide

ERMS

Emissions Reduction Market System

HAP

Hazardous Air Pollutant

lAC

Illinois Administrative Code

1.0. 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,

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

Tl

Title

I

- identifies Title

I

conditions

that have been

carried over from an existing permit

TIN

Title I New

identifies

Title

I

conditions

that are being

established in this permit

TIR

Title I Revised - identifies

Title

I

conditions that have

been carried over from an existing permit and subsequently

revised in this permit

USEPA

United States Environmental Protection Agency

VOM

Volatile Organic Material

6

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

* * * * * PCB 2009-099 * * * * *

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3.0

CONDITIONS FOR INSIGNIFICANT ACTIVITIES

3.1

Identification of Insignificant Activities

The following activities at the source constitute insignificant

3.1.1

Activities determined by the Illinois EPA to be insignificant

activities, pursuant to 35 rAC 201.210 (a) (1) and 201.2ll, as

follows:

Natural Gas Fired Heater < 10 mmBtu/hr

3.1.2

Activities that are insignificant activities based upon maximum

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

follows:

3.1.3 Activities that are insignificant activities based upon their

type or character, pursuant to 35 rAC 201.210 (a) (4) through

(18), as follows:

Direct combustion units designed and used for comfort heating

purposes and fuel combustion emission units as follows:

(A)

Units with a rated heat input capacity of less than 2.5 mmBtu/hr

that fire only natural gas, propane, or liquefied petroleum gas;

(B) Units with a rated heat input capacity of less than 1.0

mmBtu/hr that fire only oil or oil in combination with only

natural gas, propane, or liquefied petroleum gas; and (C) Units

with a rated heat input capacity of less than 200,000 Btu/hr

which never burn refuse, or treated or chemically contaminated

wood

[35 rAC 201.210 (a) (4)

l.

Storage tanks of organic liquids with a capacity of less than

10,000 gallons and an annual throughput of less than 100,000

gallons per year, provided the storage tank is not used for the

storage of gasoline or any material listed as a HAP pursuant to

Section ll2 (b) of the CAA [35 rAC 201.210 (a)

(10)

l.

Storage tanks of any size containing virgin or re-refined

distillate oil, hydrocarbon condensate from natural gas pipeline"

or storage systems, lubricating oil, or residual fuel oils [35

rAC 201.210 (a) (ll)

1 •

3.1.4 Activities that are considered insignificant activities pursuant

to 35 rAC 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

7

---

212.301 and 212.123 (Condition 5.3.2), the Permittee shall comply with

the following requirements, as applicable:

3.2.1

3.2.2

3.2.3

3.2.4

For each particulate matter process emission unit, the Permittee

shall comply with the applicable particulate matter emission

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

Part 266. For example, the particulate matter emissions from a

process emission unit shall not exceed 0.55 pounds per hour if

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

or less, pursuant to 35 IAC 266.110.

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 IAC 215.301,

which requires that organic material emissions not exceed 8.0

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

as photochemically reactive material as defined in 35 lAC

211. 4690.

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.

For each storage tank that has a storage capacity greater than

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

stores an organic material with a vapor pressure exceeding 2.5

psia at 70°F, the Permittee shall comply with the applicable

requirements of 35 rAC 215.122, which requires use of a

permanent submerged loading pipe, submerged fill, or a vapor

_

3.3

Addition of Insignificant Activities

3.3.1

3.3.2

3.3.3

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) .

The Permittee must notify the Illinois EPA of any proposed

addition of a new insignificant activity of a type addressed by

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

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

The Permittee is not required to notify the Illinois EPA of

additional insignificant activities present at the source of a

type identified in 35 lAC 201.210(b).

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4.0

SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

94.5

MW Natural

Gas

Fired

November

Dry Low NO

x

CT01

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

94.S MW Natural Gas

Fired

. November

Dry Low NO

x

CT02

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

94.5 MW Natural Gas

Fired

November

Dry Low NO

x

CT03

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

94. S MW Natural Gas

Fired

November

Dry Low NO

x

CT04

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

94.5 MW Natural Gas

Fired

November

Dry Low NO

x

CTOS

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

94.S MW Natural

Gas

Fired

November

Dry Low NO

x

CT06

Turbines

(1,082 mmBtu/hr)

2002

Combustion

Systems

Diesel Firepump

January

Engine

U

Distillate:

160 Hp,

0.41

2003

None

mmBtu/hr

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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 source 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 attainment or

unclassifiable for the National Ambient Air Quality Standards for all

criteria pollutants (CO, lead, N0

21

ozone, PM

2

•

S1

PM1o, 80

2

),

5.3

Source-Wide APplicable Provisions and Regulations

5.3.1

5.3.2

5.3.3

Specific emission units at this source are subject to particular

regulations as set forth in Section 7 (Unit-Specific Conditions

for Specific Emission Units) of this permit.

In addition, emission units at this source are subject to the

following regulations of general applicability:

a.

No person shall cause or allow the emission of fugitive

particulate matter from any process, including any material

handling or storage activity, that is visible by an

observer looking generally overhead at a point beyond the

property line of the source unless the wind speed is

greater than 40.2 kilometers per hour (25 miles per hour),

pursuant to 35 IAC 212.301 and 212.314.

b.

Pursuant to 35 IAC 212.123(a), no person shall cause or

allow the emission of smoke or other particulate matter,

with an opacity greater than 30 percent, into the

atmosphere from any emission unit other than those emission

units subject to the requirements of 35 lAC ?12.122, except

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

Ozone Depleting Substances

The Permittee shall comply with the standards for recycling and

emissions reduction of ozone depleting substances pursuant to 40

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

conditioners in Subpart B of 40 CFR Part 82:

a.

Persons opening appliances for maintenance, service,

repair, or disposal must comply with the required practices

pursuant to 40 CFR 82.156.

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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 pursuant to 40 CFR 82.161.

Risk Management Plan (RMP)

Should this stationary source, as defined in 40 CFR 68.3, become

subject to the federal regulations for Chemical Accident

Prevention in 40 CFR Part 68, then the owner or operator shall

submit the items below. This condition is imposed in this

permit pursuant to 40 CFR 68.215 (a) (2) (i) and (ii).

a.

A compliance schedule for meeting the requirements of 40

CFR Part 68 by the date provided in 40 CFR 68.10(a); or

b.

A certification statement that the source is in compliance

with all requirements of 40 CFR Part 68, including the

registration and submission of the RMP, as part of the

annual compliance certification required by Condition 9.8.

Future Emission Standards

a.

Should this stationary source become subject to a new or

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

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

then the owner or operator shall, in accordance with the

applicable regulation(s), comply with the applicable

requirements by the date(s) specified and shall certify

compliance with the applicable requirements of such

regulation(s) as part of the annual compliance

certification, as required by Condition 9.8. This permit

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

or revised regulations (see Condition 9.12.2).

b.

This permit and the terms and conditions herein do not

affect the Permittee's past and/or continuing obligation

with respect to statutory or regulatory requirements

governing major source construction or modification under

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

permit nor any of the terms or conditions of the permit

shall alter or affect the liability of the Permittee for

any violation of applicable requirements prior to or at the

time of permit issuance.

Episode Action Plan

a.

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

Permittee shall maintain at the source and have on file

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

for reducing the levels of emissions during yellow alerts,

11

---

red alerts, and emergencies, consistent with safe operating

procedures. The plan shall contain the information

specified

in

35 rAC 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 rAC 244.143(d). Such plans shall be further

revised if disapproved by the Illinois EPA.

5.4

Source-Wide Non-Applicability of Regulations of Concern

Source-wide non-applicability of regulations of concern are not set for

this source. However, there are terms for unit specific non-

applicability of regulations of concern set forth in Section 7 of this

permit.

5.5

Source-Wide Control Reguirements 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)

49.1

Sulfur Dioxide

(S~)

10.1

Particulate Matter (PM)

49.1

Nitrogen Oxides

(N~)

245.0

HAP,

not included in VOM or PM

4.0

Total

357.3

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5.6.2

5.6.3

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 Reguirements

5.7.1

Pursuant to 35 lAC 201.282 and Section 4(b) of the Act, every

emission source or air pollution control equipment shall be

subject to the following testing requirements for the purpose of

determining the nature and quantities of specified air

contaminant emissions and for the purpose of determining ground

level and ambient air concentrations of such air contaminants:

a.

Testing by Owner or Operator: The Illinois EPA may require

the owner or operator of the emission source or air

pollution control equipment to conduct such tests in

accordance with procedures adopted by the Illinois EPA, at

such reasonable times as may be specified by the Illinois

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

emission source or air pollution control equipment. All

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

person qualified by training and/or experience in the field

of air pollution testing. The Illinois EPA shall have the

right to observe all aspects of such tests [35 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 pollutiori control

equipment shall provide, without charge to the Illinois

EPA, necessary holes in stacks or ducts and other safe and

proper testing facilities, including scaffolding, but

13

---

5.7.2

excluding instruments and sensing devices, as may be

necessary

[35 lAC 201.282 (b) J •

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

Pursuant to Condition 5.7.1 and to verify compliance with the

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

a major source of HAPs, the following testing requirements are

established:

a.

If in the previous calendar year, emissions of HAPs

exceeded 80% of major source threshold for individual or

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

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

conducted as follows:

i.

Testing shall be conducted using methods that would

be acceptable under the federal National Emissions

Standards for Hazardous Air Pollutants for Stationary

Combustion Turbines, 40 CFR 63 Subpart YYYY.

Specifically, the testing procedures detailed at 40

CFR 63.6120 of the performance tests section shall be

used. For multiple turbines, the source owner or

operator shall test largest turbine which makes the

largest contributions to individual and total HAP

emissions.

b.

The calculation as to whether the 80% of major source

threshold was exceeded shall be based on records and

procedures

in

Condition 5.9.2 and shall be completed by

January 31 for the previous calendar year. If testing

is

required it shall be completed by September 30

th

•

c.

Any such tests are also subject to the Testing Procedures

of Condition 8.5 set forth in the General Permit Conditions

of Section 8.

5.8

Source-Wide Monitoring Reguirements

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

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

Section 7 of this permit.

5.9

Source-Wide Recordkeeping Reguirements

5.9.1

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)

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5.9.2

5.9.3

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

Stationary Combustion Turbines, at the source for a period

of five years after the determination. This determination

shall include a detailed analysis that demonstrates why the

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

Subpart YYYY (40 CFR 63.10(b)(3)].

Retention and Availability of Records

a.

All records and logs required by this permit shall be

retained for at least five years from the date of entry

(unless a longer retention period is specified by the

particular recordkeeping provision herein), shall be kept

at a location at the source that is readily accessible to

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

inspection and copying by the Illinois EPA or USEPA upon

request.

b.

The Permittee shall retrieve and print, on paper during

normal source office hours, any records retained in an

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

Illinois EPA or USEPA request for records during the course

of a source inspection.

5.10 Source-Wide Reporting Requirements

S.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

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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.

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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

Applicabili ty

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

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

units at the source are affected CArR units:

Turbines CT-01 - CT-06

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 CArR in

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

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

referred to as CArR provisions.

Applicable CArR Requirements for 80

2

Emissions

The owners and operators of this source shall not violate

applicable CAlR provisions, in 35 lAC Part 225, Subpart C. S02

emissions from the affected CAlR units shall not exceed the

equivalent number of allowances that the source lawfully holds

under these CAlR provisions.

Note:

CAIR affected sources must hold CAlR S02 allowances to

account for the emissions from the affected CAlR units. Each

CAlR S02 allowance is a limited authorization to emit during the

respective CAlR S02 annual period or subsequent period. The

possession of S02 allowances does not authorize exceedances of

applicable emission standards or violations of ambient air

quality standards.

Applicable CAlR Requirements for NO

x

Emissions

The owners and operators of this source shall not violate

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

emissions from the affected CAIR units shall not exceed the

equivalent number of allowances that the source lawfully holds

under these CAlR provisions.

Note: CAlR affected sources must hold CAlR NO

x

allowances to

account for the emissions from the affected CAlR units. Each

CAlR NO

x

allowance is a limited authorization to emit during the

respective CAlR 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 CAIR Requirements for NO

x

Ozone Season Emissions

The owners and operators of this source shall not violate

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

Seasonal NO

x

emissions from the affected CAIR units shall not

exceed the equivalent number of allowances that the source

lawfully holds under these CAIR provisions.

Note: CArR affected sources must hold CArR NO

x

ozone season

allowances to account for the emissions from the affected CAIR

units. Each CArR NO

x

ozone season allowance is a limited

authorization to emit during the respective CAIR NO

x

ozone

season or subsequent season. The possession of NO

x

allowances

does not authorize exceedances of applicable emission standards

or violations of ambient air quality standards.

Monitoring, Recordkeeping and Reporting

The owners and operators of the source and, to the extent

applicable, their designated representative, shall comply with

applicable requirements for monitoring, recordkeeping and

reporting specified by 35 lAC Part 225 Subparts C, D and E.

Note: As further addressed by Section 7 of this permit, the

following emission determination methods are currently being

used for the affected CAIR units.

CAIR Permit

The owners and operators of the source shall comply with the

terms and conditions of the source's CAIR permit (attached).

Note: This source is subject to a CAIR permit, which was issued

pursuant to 35 lAC Part 225.320, 225.420 and 225.520. CAIR

sources must be operated in compliance with their CAIR permits.

This source's 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 CArR permit may be

included in this permit by Administrative Amendment.

Coordination with other Requirements

a.

This permit does not contain any conditions that are

intended to interfere with or modify the requirements of 35

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

the CAA. In particular, this permit does not restrict the

flexibility of the owners and operators of this source to

comply with CAIR provisions, including the ability to

obtain CAIR NO

x

allowances from Illinois' Clean Air Set

Aside (CASA) for qualifying projects.

18

---

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.

19

---

6.2

Acid Rain Program

6.2.1

6.2.2

6.2.3

6.2.4

Applicability

Under Title IV of the CAA, Acid Deposition Control, this source

is an affected source and the following emission units at the

source are affected units for acid deposition:

Turbines CT-01 - CT-06

Note: Title IV of the CAA, and other laws and regulations

promulgated thereunder, establish requirements for affected

sources related to control of emissions of pollutants that

contribute to acid rain. For purposes of this permit, these

requirements are referred to as Title IV provisions.

Applicable Emission Requirements

The owners and operators of the source shall not violate

applicable Title IV provisions. 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 80

2

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

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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].

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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

combustion systems.

Note: This narrative description is for informational purposes

only and is not enforceable.

7.1.2

List of Emission Units and Air Pollution Control Eguipment

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

94.5 MW Natural

Gas

November

Dry Low NO

x

CT01

Fired Turbines

2002

Combustion

(1,082 mrnBtu/hr)

Systems

94.5 MW Natural Gas

November

Dry Low NO

x

CT02

Fired Turbines

2002

Combustion

(1,082 mrnBtu/hr)

Systems

94.5 MW Natural Gas

November

Dry Low NO

x

CT03

Fired Turbines

2002

Combustion

(1,082 mrnBtu/hr)

Systems

94.5 MW Natural Gas

November

Dry Low NO

x

CT04

Fired Turbines

2002

Combustion

(1,082 mrnBtu/hr)

Systems

94.5 MW Natural Gas

November

Dry Low NO

x

CT05

Fired Turbines

2002

Combustion

(1,082 mrnBtu/hr)

Systems

94.5 MW Natural Gas

November

Dry Low NO

x

CT06

Fired Turbines

2002

Combustion

(1,082 mmBtu/hr)

Systems

7.1.3

a.

H

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

22

---

in any 60 minute period provided that such opaque

emissions permitted during any 60 minute period shall

occur from only one such emission unit located within

a 1000 ft radius from the center point of any other

such emission unit owned or operated by such person,

and provided further that such opaque emissions

permitted from each such emission unit shall be

limited to 3 times in any 24 hour

period.

c.

Pursuant to 35 IAC 214.301, no person shall cause or allow

the emission of sulfur dioxide into the atmosphere from any

process emission source to excess 2000 ppm.

d.

The affected turbines are subject to the NSPS for

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

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

than 10.7 gigajoules per hour (10 mmBtu/hr), based on the

lower heating value of the fuel fired and the affected

turbine commenced construction, modification, or

reconstruction after October 3, 1977. The Illinois EPA

administers the NSPS for subject sources in Illinois

pursuant to a delegation agreement with the USEPA.

i.

Standard for Nitrogen Oxides:

Pursuant to 40 CFR 60.332(b), electric utility

stationary gas turbines with a heat input at peak

load greater than 107.2 gigajoules per hour (100

million Btu/hour) based on the lower heating value of

the fuel fired shall comply with the provisions of 40

CFR 60.332 (a) (1).

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

no owner or operator of an affected turbine shall

cause to be discharged into the atmosphere from such

gas turbine, any gases which contain nitrogen oxides

in excess of:

STD = 0.0075 (14.4)

+

F

Y

Where:

STD = Allowable NO

x

emissions (percent by volume at 15

percent oxygen and on a dry basis) .

Y

Manufacturer's rated heat rate at

manufacturer's rated load (kilojoules per watt

hour) or, actual measured heat rate based on

lower heating value of fuel as measured at

actual peak load for the facility. The value

of Y shall not exceed 14.4 kilojoules per watt

hour.

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e.

F

NO

x

emission allowance for fuel-bound nitrogen

calculated from the nitrogen content of the

fuel as follows:

Fuel-bound nitrogen

F

(percent by weight)

(NO

x

percent

by

volume)

N < 0.015

0

0.015 < N

<

0.1

0.04 (N)

0.1

< N

-

<

0.25

0.04

+

0.0067(N - 0.1)

N

>

0.25

0.005

Where:

N

The nitrogen content of the fuel (percent by

weight) determined in according with Condition

7.1.8(b) .

ii.

Standard for Sulfur Dioxide:

i.

Pursuant to 40 CFR 60.333, on and after the date on

which the performance test required to be conducted

by 40 CFR 60.8 is completed, every owner or operator

subject to the provision of 40 CFR 60 Subpart GG

shall comply with one or the other of the following

conditions:

No owner or operator subject to the provisions of

this subpart shall cause to be discharged into the

atmosphere from any stationary gas turbine any gases

which contain sulfur dioxide in ex'cess of 0.015

percent by volume at 15 percent oxygen and on a dry

basis, pursuant to 40 CFR 60.333(a).

No owner or operator subject to the provisions of

this subpart shall burn in any stationary gas turbine

any fuel which contains total sulfur in excess of 0.8

percent by weight (8000 ppmw) , pursuant to 40 CFR

60.333(b) .

No owner or operator shall cause or allow the

emissions of NO

x

into the atmosphere from the affected

turbine to exceed 0.25 lbs/mmBtu of actual heat input

during each ozone control period from May 1 through

September 30, based on a ozone control period

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

ii.

Notwithstanding the above emission limitation of 35

rAC 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 rAC 217 Subpart V and that more stringent

emission limitation [35 rAC 217.706(b)].

24

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f.

Startup Provisions

Subject to the following terms and conditions, the

Permittee is authorized to operate the affected turbines in

violation of the applicable standards in Condition 7.1.3(b)

and the hourly limits in Condition 7.1.6 during startup.

This authorization is provided pursuant to 35 lAC 201.149,

201.161 and 201.262, as the Permittee has applied for such

authorization in its application, generally describing 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

25

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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 IAC 201.265, an authorization in a

permit for excess emissions during startup does not

shield a Permittee from enforcement for any violation

of applicable emission standard(s) that occurs during

startup and only constitutes a prima facie defense to

such an enforcement action provided that the

Permittee has fully complied with all terms and

conditions connected with such authorization.

g.

Malfunction and Breakdown Provisions

Subject to the following terms and conditions, the

Permittee is authorized to continue operation of an

affected turbine in violation of the applicable standards

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

Condition 7.1.6 in the event of a malfunction or breakdown

of the affected turbines. This authorization is provided

pursuant to 35 lAC 201.149, 201.161 and 201.262, as the

Permittee has applied for such authorization in its

application, generally explaining why such continued

operation would be required to provide essential service or

to prevent risk of injury to personnel or severe damage to

equipment, and describing the measures that will be taken

to minimize emissions from any malfunctions and breakdowns.

This authorization supersedes the general prohibition in

Condition 9.2.3 against continued operation in such

circumstances.

i.

This authorization only allows such continued

operation as necessary to provide essential service

or prevent risk of injury to personnel or severe

damage to equipment and does not extend to continued

operation solely for the economic benefit of the

Permittee.

26

---

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 rAC 201.263.

v.

This authorization does not relieve the Permittee

from the continuing obligation to minimize excess

emissions during malfunction or breakdown. As

provided by 35 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

27

---

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 lAC 212.321 or

212.322, due to the unique nature of such units, a process

weight rate can not be set so that such rules can not

reasonably be applied, pursuant to 35 lAC 212.323.

d.

The affected turbines are not subject to 35 lAC 217.141 or

35 lAC 216.121 because the affected turbines are not fuel

combustion units, as defined by 35 lAC 211.2470.

e.

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

Compliance Assurance Monitoring (CAM) for Major Stationary

Sources:

i.

For NO

x

and

80

21

because:

A.

The affected turbines are subject to a NSPS

proposed after November 15, 1990, pursuant to

40 CFR 64.2(b)(1)(i).

B.

The affected turbines are subject to Acid Rain

Program requirements, pursuant to 40 CFR

64.2 (b) (1) (iii).

C.

The affected turbines are subject to an

emission limitation or standard for which this

CAAPP permit specifies a continuous compliance

determination method, pursuant to 40 CFR

64.2 (b) (1) (vi).

ii.

For PM, VOM, and co because the affected turbines do

not use an add-on control device to achieve

Control Reguirements 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.

affected turbines in accordance with written

28

---

operating procedures that shall include at a minimum

the following measures:

A.

Review of operating parameters of the unit

during startup or shutdown as necessary for the

proper operation of the affected turbine with

appropriate adjustments to reduce emissions.

B.

Implementation of inspection and repair

procedures for a affected turbine prior to

attempting startup following repeated trips.

iii. The source owner or operator shall maintain the

affected turbines in accordance with written

procedures that shall include at a minimum the

following measures:

A.

Unless specified on a more frequent basis by

manufacturer's written instructions, an

inspection of emissions-related components

shall be completed quarterly. Inspections

shall be conducted in accordance with

manufacturer's written instructions.

B.

Repair and routine replacement of emissions-

related components.

iv.

The above procedures may incorporate the

manufacturer's written instruction for operation and

maintenance of the affected turbines and associated

control systems. The source owner or operator shall

review these procedures at least every two years and

shall revise or enhance them if necessary to be

consistent with good air pollution control practice

based on the actual operating experience and

performance of the source.

b.

Natural gas shall be the only fuel in the affected turbines

[TIJ

c.

The affected turbines shall be equipped, operated, and

maintained with Dry low NO

x

burners

[TIl

d.

The above limitations were established in Permit 00090082,

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 [TIJ.

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7.1. 6

Production and Emission Limitations

In addition to Condition 5.3.2 and the source-wide emission

limitations in Condition 5.6, the affected turbines are subject

to the following:

a.

The total natural gas consumption of the affected turbines

shall not exceed 8,400 million standard cubic feet per year

[T1l .

b.

i.

Hourly emissions from each affected turbine shall not

exceed the following limits, except during startup

and shutdown. Compliance with the hourly limit shall

be determined on a 24-hour average basis [Tl):

Pollutant

(Lb/Hour)

NO,

59.0

CO

59.0

PM/PM"

10.0'

YOM

10.0

SO,

2.6

* -

Limit does not include PM/PM

10

associated with

evaporative cooler blow down, which may be

introduced into and exhausted through the

turbine stack.

ii.

Not withstanding the above, when the operating load

of an affected turbine is 101 percent or more of the

manufacturer's nominal rated output (rated output) or

50 percent or less than the rated output, NO

x

emissions from each affected turbine shall not exceed

107 lbs/hour [T1l.

iii. The total annual emissions from the affected turbines

shall not exceed the following limits [T1l:

Pollutant

(Ton/Yr)

NO,

243.7

CO

244.0

PM/PM"

95.0

YOM

49.0

SO,

15.0

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)

[T1l .

d.

The above limitations were established in Permit 00090082,

pursuant to PSD. These limits ensure that the construction

and/or modification addressed in the aforementioned permit

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7.1. 7

does not constitute a new major source or major

modification pursuant to Title I of the CAA, specifically

the federal rules for PSD [TIl.

e.

Unless emission monitoring is performed for a pollutant,

emissions shall be determined from emission factors

developed from testing

in

accordance with Permit 00090082

(NO

xt

CO, VOM and PM/PM

10

)

and analysis of fuel sulfur

content or standard emission factors (80

2

)

[Tl] .

f.

For the purpose of determining compliance with the annual

limitations of Condition 7.1.6(b) (iii), unless an

alternative factor is established for the pollutant or

emission monitoring is performed for the pollutant,

emissions of NO

x1

CO and VOM during an hour that includes a

startup shall be presumed to be at the applicable hourly

limit in Condition 7.1.6(b) multiplied by a startup factor

(S):

SNO

x

~

1, seo

~

2 and SVOM

~

2.

For example, the CO

emissions during an hour that includes a startup shall be

assumed to be 118 pounds per hour (2 x 59

~

118).

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 [TIl.

g.

The establishment of the above procedures for determining

compliance with the annual emission limits shall not shield

the Permittee from responsibility for all emissions from

the source, including emissions during startup or upset

conditions, as other credible information may demonstrate

that the above procedures do not adequately account for the

actual emissions of the source [T1].

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

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.

31

---

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

P

r

= reference combustor

inlet

absolute

pressure at 101.3 kilopascals ambient

pressure, mrn Hg

Po

= observed combustor inlet absolute

pressure at test, mm Hg

Ho

=

observed humidity of ambient air, g

H2 0/

g

air

e

= transcendental constant, 2.718

Ta

=

ambient temperature, OK

32

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The 3-run performance test required by 40 CFR

60.8 must be performed within ±.5 percent at

30, 50, 75, and 90-to-100 percent of peak load

or at four evenly-spaced load points in the

normal operating range of the gas turbine,

including the minimum point in the operating

range and 90-to-IOO percent of peak load, or at

the highest achievable load point if 90-to-100

percent of peak load cannot be physically

achieved in practice. If the turbine combusts

both oil and gas as primary or backup fuels,

separate performance testing is required for

each fuel. Notwithstanding these requirements,

performance testing is not required for any

emergency fuel (as defined in 40 CFR 60.331),

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

If water or 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 or as part

of the initial performance test of the affected

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

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

or operator elects to install and certify a NO

x

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

performance test required under 40 CFR 60.8 may

be done in the following alternative manner:

Perform a minimum of 9 reference method runs,

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

single load level, between 90 and 100 percent

of peak (or the highest physically achievable)

load, pursuant to 40 CFR 60.335 (b) (7) (i) .

Use the test data both to demonstrate

compliance with the applicable NO

x

emission

limit under 40 CFR 60.332 and to provide the

required reference method data for the RATA of

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

(Reapproved 2000); or 06667-01 (all of which

are incorporated by reference, see 40 CFR

60.17). The applicable ranges of some ASTM

methods mentioned above are not adequate to

measure the levels of sulfur in some fuel

gases. Dilution of samples before analysis

(with verification of the dilution ratio) may

be used, subject to the prior approval of the

Administrator, pursuant to 40 CFR

60.335 (b) (10) (ii).

The fuel analyses required under 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

34

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develop ambient condition correction factors to

adjust the nitrogen oxides emission level

measured by the performance test as provided in

40 CFR 60.8 to ISO standard day conditions,

pursuant to 40 CFR 60.335 (c) (1) .

c.

At least 60 days prior to the actual date of testing, a

written test plan shall be submitted to the Illinois EPA

for review. This plan shall describe the specific

procedures for testing and shall include as a minimum:

i.

The person(s) who will be performing sampling and

analysis and their experience with similar tests.

ii.

The specific conditions under which testing shall be

performed including a discussion of why these

conditions will be representative of maximum

emissions and the means by which the operating

parameters for the turbine will be tracked and

recorded.

iii. The specific determinations of emissions that are

intended to be made, including sampling and

monitoring locations; the test method(s) that will be

used, with the specific analysis method, if the

method can be used with different analysis methods.

The source owner or operator may also propose a plan

for testing across the normal operating range of the

affected turbines.

d.

The Illinois EPA shall be notified prior to these tests to

enable the Illinois EPA to observe these tests.

Notification of the expected date of testing shall be

submitted a minimum of thirty (30) days prior to the

expected date. Notification of the actual date and

expected time of testing shall be submitted a minimum of

five (5) working days prior to the actual date of the test.

The Illinois EPA may, at its discretion, accept

notifications with shorter advance notice provided that the

Illinois EPA will not accept such notifications if it

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:

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.

35

---

f.

iv.

Detailed description of test conditions, including:

A.

Fuel consumption (standard ft

3

) •

B.

Firing rate (million Btu!hr) .

c.

Turbine/Generator output rate (MW).

v.

Data and calculations, including copies of all raw

data sheets and records of laboratory analyses,

sample calculations, and data on equipment

calibration.

i.

Upon written request by the Illinois EPA, the source

owner or operator shall have the opacity of the

exhaust from the affected turbine(s) tested during

representative operating conditions as determined by

a qualified observer in accordance with USEPA Test

Method 9, as further specified below, pursuant to

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

ii.

Such testing shall be conducted for specific

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

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

agreed upon by the Illinois EPA, whichever is later.

iii. The duration of opacity observations for each test

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

unless the average opacities for the first 12 minutes

of observations (two six-minute averages) are both

less than 10.0 percent.

iv.

The source owner or operator shall notify the

Illinois EPA at least 7 days in advance of the date

and time of these tests, in order to allow the

Illinois EPA to witness testing. This notification

shall include the name and employer of the qualified

observer(s) .

v.

The source owner or operator shall promptly notify

the Illinois EPA of any changes in the time or date

for testing.

vi.

The source owner or operator shall provide a copy of

its observer's readings to the Illinois EPA at the

time of testing, if Illinois EPA personnel are

present.

vii. The source owner or operator shall submit a written

report for this testing within 30 days of the date of

testing. This report shall include:

A.

Date and time of testing.

36

---

7.1.8

B.

Name and employer of qualified observer.

C.

Copy of current certification.

D.

Description of observation conditions.

E.

Description of turbine operating conditions.

F.

Raw data.

G.

Opacity determinations.

H.

Conclusions.

Monitoring Requirements

a.

i.

If

an

affected turbine is routinely operated or

exercised to confirm that the turbine will operate

when needed, the operation and opacity of the

affected turbine shall be formally observed by

operating personnel for the affected turbine or a

member of source owner or operator's environmental

staff on a regular basis to assure that the affected

turbine is operating properly, which observations

shall be made at least every six months.

ii.

If

an

affected turbine is not routinely operated or

exercised, i.e., the time interval between operation

of an affected turbine is typically greater than six

months, the operation and opacity of the affected

turbine shall be formally observed as provided above

each time the source owner or operator carries out a

scheduled exercise of the affected turbine.

iii. The source owner or operator shall also conduct

formal observations of operation and opacity of an

affected turbine upon written request by the Illinois

EPA. With the agreement of the Illinois EPA, the

source owner or operator may schedule these

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.

37

---

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 40

CFR 60.335 (b) (10). Alternatively, if the total sulfur

content of the gaseous fuel during the most recent

performance test was less than 0.4 weight percent (4000

ppmw), ASTM 04084-82, 94, 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 cornbusted 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 STO 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) (1) of this section, the owner

or operator may elect not to monitor the total sulfur

content of the gaseous fuel cornbusted

in

the turbine,

if

the gaseous fuel

is

demonstrated to meet the

definition

of

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

existing

custom schedule approved by the administrator for

subpart GG requires such monitoring. The owner or operator

shall use one of the following sources of information to

make the required demonstration:

The gas quality characteristics in a current, valid

purchase contract, tariff sheet or transportation contract

for the gaseous fuel, specifying that the maximum total

sulfur content of the fuel is 20.0 grains/100 scf or less,

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

Representative fuel sampling data which show that the

sulfur content of the gaseous fuel does not exceed 20

38

---

grains/100 scf. At a mlnlmum, 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.

e.

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)].

ii.

Notwithstanding 35 lAC 217.710(a) above, the owner or

operator of a gas-fired peaking unit or oil-fired

peaking unit as defined in 40 CFR 72.2 may determine

NO

x

emissions in accordance with the emissions

estimation protocol of 40 CFR 75, Subpart

E

[35 lAC

217.710(b)].

iii. Notwithstanding 35 lAC 217.710(a) above, the owner or

operator of a combustion turbine that operates less

than 350 hour per ozone control period may determine

the heat input and NO

x

emissions of the turbine as

follows

[35 lAC 217.710(c)]:

i.

A.

Heat input shall be determined from the metered

fuel usage to the turbine or the calculated

heat input determined as the product of the

turbine's maximum hourly heat input and hours

of operation as recorded by operating

instrumentation on the turbine [35 lAC

217.710(c) (1)].

B.

NO

x

emissions shall be determined as the product

of the heat input, as determined above, and the

appropriate default NO

x

emission factors below

[35 lAC 217.710 (c) (2)] :

0.7 Ibs/mmBtu - Natural gas

1.2 Ibs/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:

39

---

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.

Intentionally left blank.

ii.

The sulfur content of the natural gas used to fire

the turbines as determined in accordance with

Condition 7.1.8(b).

conducted pursuant to Condition 7.1.7.

iv.

Copies of opacity determinations taken for the source

by qualified observer(s) using USEPA Method 9

v.

Records documenting its periodic review of its

operating procedures as required by Condition

7.1.5(a) .

vi.

Information for the formal observations of opacity

conducted pursuant to Condition 7.1.8(a). For each

occasion on which observations are made, these

records shall include the date, time, identity of the

observer, a description of the various observations

that were made, whether or not the affected engine

was running properly, and whether or not corrective

action is necessary and was subsequently initiated.

40

---

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

scflyear.

f.

Intentionally left blank.

g.

i.

Operating hours for the affected turbine, hr/month

and hr/year.

ii.

Any period of time when an affected turbine operates

at 101 percent or more of rated output.

h.

Heat content of the fuel being fired in the affected

turbine.

i.

Emissions of each pollutant from the affected turbine,

including emissions from startups, with supporting

calculations including documentation on the validity of the

emission factors used, ton/month and ton/year.

j.

The source owner or operator shall maintain records that

identify:

i.

Any periods during which a continuous monitoring

system was not operational, with explanation.

ii.

Any day in which emission and/or opacity exceeded an

applicable standard or limit.

k.

The source owner or operator shall keep records of good

operating practices for each turbine.

1.

The source owner or operator shall maintain the following

records related to each 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.

41

---

ii.

The followirig information for each shutdown of a

turbine:

A.

Date and time of shutdown.

B.

A description of the

shu~down,

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.

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.

ffi.

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.

42

---

ii.

A detailed explanation of the malfunction or

breakdown.

iii. An explanation why the affected turbine continued to

operate in accordance with Condition 7.1.3(g).

iv.

The measures used to reduce the quantity of emissions

and the duration of the event.

v.

The steps taken to prevent similar malfunctions or

breakdowns or reduce their frequency and severity.

vi.

The amount of release above typical emissions during

malfunction/breakdown.

7.1.10 Reporting Requirements

a.

Reporting of Deviations

The source owner or operator shall promptly notify the

Illinois EPA, Air Compliance Unit, of deviations of the

affected turbine with the permit requirements as follows,

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

shall describe the probable cause of such deviations, and

any corrective actions or preventive measures taken:

i.

Emissions from the affected turbine in excess of the

limits specified in Conditions 7.1.3 and 7.1.6 within

30 days of such occurrence.

ii.

Operation of. the affected .turbine in excess of the

limits specified in Conditions 7.1.5 and 7.1.6 within

30 days of such occurrence.

b.

In conjunction with the Annual Emission Report required by

35 lAC Part 254, the source owner or operator shall provide

the operating hours for each affected turbine, the total

number of startups, the total fuel consumption during the

preceding calendar year.

c.

i.

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).

ii.

The Permittee shall notify the Illinois EPA within 10

days if NO

x

or CO emissions exceed 150 tons/ year.

iii. The Permittee shall notify the Illinois EPA within 10

days if a turbine is operated at 101 percent or more

of rated output as related to Condition 7.1. 6 (b) (ii),

with duration of operation and explanation.

43

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

* * * * * PCB 2009-099 * * * * *

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d.

iv.

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).

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

2l7. 712 (b) (2)

1 •

ii.

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

November 30 of each year, the source owner or

operator shall submit a report to the Illinois EPA

that demonstrates that the affected turbine has

complied with Condition 7.1.3(e). These reports

shall be accompanied

by

a certification statement

signed

by

a responsible official for the source owner

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

e.

Reporting of Startups

The source owner or operator shall submit semi-annual

startup reports to the Illinois EPA pursuant to Sections

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

submitted along with the semi-annual reports required by

Condition 7.1.10(f) (ii) and shall include the following

information for startups of the affected turbine during the

i.

A list of the startups of the affected turbine,

including the date, duration and description of each

startup, accompanied by a copy of the records

pursuant to Condition 7.1.9(i) for each startup for

which such records were required.

ii.

during the reporting period, this shall be stated in

the report.

f.

Reporting of Malfunctions and Breakdowns

The Permittee shall provide the following notification and

reports to the Illinois EPA, Air Compliance Unit and

Regional Field Office, pursuant to 35 lAC 201.263,

concerning continued operation of an affected turbine

subject to Condition 7.1.3(g) during malfunction or

breakdown:

i.

A.

The Permittee shall notify the Illinois EPA's

regional office by telephone as soon as

possible during normal working hours, but no

later than three (3) days, upon the occurrence

44

---

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 achi€ved within 5 working

days of the occurrence, the Permittee shall

submit interim status reports to the Illinois

EPA, Air Compliance Unit and Regional Field

Office, within 5 days of the occurrence and

every 14 days thereafter, until compliance is

achieved. These interim reports shall provide

a brief explanation of the nature of the

malfunction or breakdown, corrective actions

accomplished to date, actions anticipated to

occur with schedule, and the expected date on

which repairs will be complete or the affected

turbine will be taken out of service.

ii.

In accordance with the_due dates in Condition 8.6.1,

the Permittee shall submit semi-annual malfunction

and breakdown reports to the Illinois EPA pursuant to

Sections 39.5 (7) (a) and (f) of the Act. These

reports may be submitted along with other semi-annual

reports and shall include the following information

for malfunctions and breakdowns of the affected

turbine during the reporting period:

A.

A listing of malfunctions and breakdowns, in

chronological order, that includes:

I.

The date, time, and duration of each

incident.

II.

The identity of the affected operation(s)

involved in the incident.

B.

Dates of the notices and reports of Conditions

7.1.10(f) (i).

C.

Any supplement information the Permittee wishes

to provide to the notices and reports of

Conditions 7.1.10 (f) (i) .

45

---

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 requirements of 7.1.8, the records

required in Condition 7.1.9, and the reports required in

Condition 7.1.10.

c.

d.

i.

Compliance with the NO

x

emission limitations of

Conditions 7.1.3(d) (i) is addressed by the

requirements of Condition 7.1.5, the testing

-requirements of 7.1 .. 7, the monitoring requirements of

7.1.8, and the records required in Condition 7.1.9,

and the reports required in Condition 7.1.10(a).

ii.

Compliance with the S02 emission limitations of

Conditions 7.1.3(d) (ii) is addressed by the

requirements of Condition 7.1.5, the monitoring

requirements of 7.1.8, the records required in

Condition 7.1.9, and the reports required in

Condition 7.1.10(a).

i.

Compliance with the NO

x

emission limitations of

Conditions 7.1.3(e) is addressed by the requirements

of Condition 7.1.5, the testing requirements of

7.1.7, the monitoring requirements of 7.1.8, the

records required in Condition 7.1.9, and the reports

required in Condition 7.1.10(a).

ii.

Notwithstanding 35 IAC 217.710(a), Condition

7.1.8(d), the owner or operator of a gas-fired

peaking unit or oil-fired peaking unit as defined in

40 CFR 72.2 may determine NO

x

emissions in accordance

with the emissions estimation protocol of 40 CFR 75,

Subpart E [35 IAC 217.710(b)].

46

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

* * * * * PCB 2009-099 * * * * *

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e.

iii. Notwithstanding 35 lAC 217.710(a), Condition

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

turbine that operates less than 350 hour per ozone

control period may determine the heat input and NO

x

emissions of the turbine as follows

[35 lAC

217.710(e)]:

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 (e) (1)].

B.

NO

x

emissions shall be determined as the product

of the heat input, as determined above, and the

appropriate default NO

x

emission factors below

[35 lAC 217.710 (e) (2)] :

0.7 lbs/mmBtu - Natural gas

1.2 lbs/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.l.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 7.1.8 and from

emission factors developed from the most recent

approved stack test in accordance with

Condition 7.1.6(e) and (f) for NO" CO, VOM and

PM/PM

10

and 7.1.7, and analysis of fuel sulfur

content or standard factors (S02)'

47

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7.2

Diesel Engines (Subject to NESHAP - 40 CFR 63 Subpart ZZZZ)

7.2.1

7.2.2

7.2.3

Description

The diesel engines are process emission units used to drive a

fire pump. The Permittee operates one (1) 160 Hp diesel fire

pump.

Note: This narrative description is for informational purposes

only and is not enforceable.

List of Emission Units and Air Pollution Control Equipment

Emission

Emission

Date

Control

Unit

Description

Constructed

Equipment

Diesel Firepump

Engine

#1

Distillate: 160

January 2003

None

Hp, 0.41 mmBtu/hr

Applicable Provisions and Regulations

a.

The "affected diesel engines

U

for the purpose of these

unit-specific conditions, are diesel engines described in

Conditions 7.2.1 and 7.2.2.

b.

Pursuant to 35 lAC 212.123,

c.

i.

No person shall cause or allow the emission of smoke

or other particulate matter, with an opacity greater

than 30 percent, into the atmosphere from any

emission unit.

ii.

The emission of smoke or other particulate matter

from any such emission unit may have an opacity

greater than 30 percent but not greater than 60

percent for a period or periods aggregating 8 minutes

in any 60 minute period provided that such opaque

emissions permitted during any 60 minute period shall

occur from only one such emission unit located within

a 1000 ft radius from the center point of any other

such emission unit owned or operated by such person,

and provided further that such opaque emissions

permitted from each such emission unit shall be

limited to 3 times in any 24 hour period.

i.

Pursuant to 35 rAC 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.

48

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

* * * * * PCB 2009-099 * * * * *

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7.2.4

Non-Applicability of Regulations of Concern

a.

The affected diesel engines are not subject to the New

Source Performance Standards (NSPS) for Compression

Ignition Internal Combustion Engines, 40 CFR Part 60,

Subpart 1111, because the Permittee did not commence

construction (date that construction commences is the date

the engine is ordered

by

the Permittee) of the affected

diesel engines after July 11, 2005 where the affected

diesel engines are:

i.

Manufactured as a certified National Fire Protection

Association (NFPA) fire pump engine after July I,

2006, pursuant to 40 CFR 60.4200 (a) (2) (ii) .

Note: To qualify for this non-applicability, the Permittee

has certified that the diesel engines have not modified or

reconstructed their diesel engines after July II, 2005.

b.

The affected diesel

engines

are excluded from certain

requirements of the

National Emissions

Standards for

Hazardous Air Pollutants for Stationary Reciprocating

Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ,

because the affected diesel engines are existing

compression ignition (CI) stationary RICE, pursuant to 40

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

of that Subpart or Subpart A, additionally no initial

notification is necessary. Requirements necessary to

maintain the exclusion, and therefore compliance with that

Part, are found within this Section. Specifically, those

requirements are not becoming an affected source pursuant

to 40 CFR 63.6590.

c.

The affected diesel engines (used as diesel generators) are

not subject to the Acid Rain Program, 40 CFR 72, because

the affected diesel engines are non-utility units, as

defined by 40 CFR 72.6 (b) (8).

Pursuant to 40 CFR 72.2,

"utility unit" is defined as a unit owned or operated by a

utility that serves a generator

in

any State that produces

electricity for sale.

d.

The affected diesel engines are not subject to 35 lAC

212.321 or 212.322, due to the unique nature of such units,

a process weight rate can not be set so that such rules can

not reasonably be applied, pursuant to 35 lAC 212.323.

e.

The affected

diesel

engines are not subject to 35 lAC

216.121 because the affected diesel engines are not fuel

combustion units, as defined by 35 lAC 211.2470.

f.

i.

The affected diesel engines are not subject to 35 lAC

Part 217, Subpart Q: Stationary Reciprocating

Internal Combustion Engines and Turbines, because the

affected diesel engines are not stationary

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7.2.5

7.2.6

7.2.7

reciprocating internal combustion engines listed in

Appendix G of that Part, pursuant to 35 lAC 217.386.

ii.

The affected diesel engines are not subject to 35 lAC

217.141 because the affected diesel engines are not

fuel combustion units, as defined by 35 lAC 211.2470.

g.

The affected diesel engines are not subject to 40 CFR Part

64, Compliance Assurance Monitoring (CAM) for Major

Stationary Sources, because the affected diesel engines

does not use an add-on control device to achieve compliance

with an emission limitation or standard.

Control Reguirements and Work Practices

a.

The Permittee shall follow good operating practices for the

affected diesel engines, including periodic inspection,

routine maintenance and prompt repair of defects.

b.

Distillate fuel oil shall be the only fuel fired in the

affected diesel engines.

c.

The Illinois EPA shall be allowed to sample all fuels

stored at the source.

Production and Emission Limitations

Production and emission limitations are not set for the affected

diesel engines. However, there are source-wide production and

emission limitations set forth in Condition 5.6.

Testing Reguirements

a.

i.

Upon written request by the Illinois EPA, the

Permittee shall have the opacity of the exhaust from

the affected diesel engine(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 diesel

engine(s) within 70 calendar days of the request, or

on the date diesel engine(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.

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b.

iv.

The Permittee shall notify the Illinois EPA at least

7 days in advance of the date and time of these

tests, in order to allow the Illinois EPA to witness

testing. This notification shall include the name

and employer of the qualified observer(s) .

v.

The Permittee shall promptly notify the Illinois EPA

of any changes in the time or date for testing.

vi.

The Permittee 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 Permittee shall submit a written report for this

testing within 15 days of the date of testing. This

report shall include:

i.

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 diesel engine operating

conditions.

F.

Raw data.

G.

Opacity determinations.

H.

Conclusions.

In the event that the fuel oil supplier is unable to

provide the sulfur content of the fuel oil supply for

the affected diesel engines, the Permittee shall have

the sulfur content of the oil supply to the affected

diesel engines, in lbs/mmBtu, determined from an

analysis of representative sample of the oil supply,

as follows, pursuant to Section 39.5(7) (d) of the

Act:

A.

From a sample taken no later than 90 days after

first operating the affected diesel engines

pursuant to this permit, provided, however,

that if such sample is taken following

operation of the affected diesel engines, the

sample shall be taken prior to adding more oil

to the storage tank.

B.

From a sample taken no later than 30 days after

acceptance of a shipment of fuel whose sulfur

content would not meet Condition 7.2.3(c) based

51

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7.2.8

upon supplier data, provided however, that if

the affected

diesel

engines are operated

following acceptance of such a shipment, the

sample shall be taken prior to adding a

subsequent shipment of oil to the relevant

storage tank.

C.

From a sample taken no later than 30 days after

a request for such a sample is made

by

the

Illinois EPA, provided, however, that such

sample shall be taken prior to adding more oil

to the relevant storage tank.

ii.

Sampling and analysis, including that which forms the

basis for the suppliers' data, shall be conducted

using methods that would be acceptable under the

federal New Source Performance Standards for

Stationary Gas Turbines, 40 CFR 60.335(b) (2) and (e)

or the federal Acid Rain Program, 40 CFR 75, Appendix

0, Optional S02 Emissions Data Protocol for Gas-Fired

and Oil-Fired Units e.g., ASTM D4057-88 and ASTM

D129-91.

Note: Condition 7.2.7(b) (ii) is for fuel testing

methodology only, and is in no way intended to

subject the source to those provisions.

Monitoring Requirements

a.

i.

If an affected diesel engine is routinely operated or

exercised to confirm that the affected diesel engine

will operate when needed, the operation and opacity

of the affected diesel engine shall be formally

observed by operating personnel for the affected

diesel engine or a member of Permittee's

environmental staff on a regular basis to assure that

the affected diesel engine is operating properly,

which observations shall be made at least every six

months.

ii.

If an affected diesel engine is not routinely

operated or exercised, i.e., the time interval

between operation of an affected diesel engine is

typically greater than six months, the operation and

opacity of the affected diesel engine shall be

formally observed as provided above each time the

Permittee carries out a scheduled exercise of the

affected diesel engine.

iii. The Permittee shall also conduct formal observations

of operation and opacity of an affected diesel engine

upon written request by the Illinois EPA. With the

agreement of the Illinois EPA, the Permittee may

schedule these observations to take place during

52

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7.2.9

periods when it would otherwise be operating the

affected diesel engine.

Note: The "formally 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 diesel engines

who would be able to make a determination based from the

affected diesel engines who would be able to make a

determination based from the observed opacity as to whether

of not the affected diesel engine was running properly, and

subsequently initiate a corrective action if necessary.

Recordkeepinq Requirements

In addition to the records required

by

Condition 5.9, the

Permittee shall maintain records of the following items for each

affected diesel 'engine to demonstrate compliance with Conditions

5.6.1 and 7.2.3. pursuant to Section 39.5(7) (b) of the Act:

a.

1.

An operating log for each affected diesel engine,

which shall include the following information:

A.

Information for each time the affected diesel

engine is operated, with date, time, duration,

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

Monthly and annual records of hours of

operation of each engine and total hours of

operation.

B.

Information for the observations conducted

pursuant to Condition 7.2.8(a) or 7.2.7(a).

with date, time, personnel, and findings.

I.

The Permittee shall keep records for all

opacity measurements made in accordance

with USEPA Method 9 for an affected

diesel engine that it conducts or that

are conducted on its behalf by

individuals who are qualified to make

such observations for Condition 7.2.7(a).

For each occasion on which such

observations are made, these records

shall include the identity of the

observer, a description of the various

observations that were made, the observed

opacity, and copies of the raw data

sheets for the observations.

II.

The Permittee shall keep records for all

formal observations of opacity conducted

pursuant to Condition 7.2.8(a). For each

occasion on which observations are made,

53

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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 diesel engine was running

properly, and whether or not corrective

action is necessary and was subsequently

initiated.

C.

Information identifying any deviation from

Condition 7.2.5(b).

ii.

A maintenance and repair log for each affected diesel

engine and associated equipment, listing activities

performed with date.

iii. The Permittee shall keep records of good operating

practices for each affected diesel engine, as defined

in Condition 7.2.5(a).

b.

Fuel usage for the affected diesel engines:

i.

Total usage of fuel oil for the affected diesel

engines, gallons/month and gallons/year.

c.

The following records related to the sulfur content of the

oil fuel supply and 80

2

emissions of the affected diesel

engines:

i.

Records for each shipment of fuel for the affected

diesel engines, including date, supplier, quantity

(in gallons), sulfur content, and whether the 80

2

emissions from the burning of such fuel would meet

the standard in Condition 7.2.3(c).

ii.

The Permittee shall maintain records of the sulfur

content of the fuel oil supply to the affected diesel

engines, based on the weighted average of material in

the storage tank, or the sulfur content of the supply

shall be assumed to be the highest sulfur content in

any shipment in the tank.

d.

Emissions from each affected diesel engine (i.e., NO

x

,

CO,

802, VOM, and PM) in tons/month and tons/year with

supporting calculations and data as required by Condition

7.2.9.

7.2.10 Reporting Requirements

a.

Reporting of Deviations

The Permittee shall promptly notify the Illinois EPA, Air

Compliance Unit, of deviations of an affected diesel

engines with the permit requirements as follows, pursuant

54

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

describe the probable cause of such deviations, and any

i.

Emissions of opacity, 80

21

from the affected diesel

engines in excess of the limits specified in

ii.

Operation of the affected diesel engines in

noncompliance with the requirements specified in

Condition 7.2.5 within 30 days of such occurrence.

Operational flexibility is not set for the affected diesel

engines.

7.2.12 Compliance Procedures

SO, ppm

a.

Compliance with the PM emission limitations of Conditions

7.2.3(b) is addressed

by

the requirements of Condition

7.2.5(a), the testing requirements in Condition 7.2.7(a),

the monitoring requirements of Condition 7.2.8(a), the

records required in Condition 7.2.9(a), and the reports

required in Condition 7.2.l0(a).

b.

i.

Compliance with the S02 emission limitation of

Condition 7.2.3(c) (i) is addressed by the

requirements of Condition 7.2.5, the testing

requirements in Condition 7.2.7(b), and the records

and reports required in Conditions 7.2.9(b) and (c)

and 7.2.10(a).

ii.

For this purpose, complete conversion of sulfur into

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

are twice the sulfur content of the fuel supply, in

Ib/rnmBtu, using the following equation:

Fuel sulfur content (lb/mmBtu) x 2 x 1/64 x 385.2 x 1,000,000

Engine exhaust rate factor (scf/rnmBtu)

Note: Stoichiometric combustion of distillate oil with the

maximum available sulfur content, i.e., 1.0 percent, would

result in an 802 concentration in the exhaust that is well

below the 2000 ppm limit in Condition 7.2.3(c) (i), i.e.,

only about 500 ppm, based on 10,320 scf/mmBtu, the F-factor

for oil in USEPA's Reference Method 19.

c.

Compliance with the emission limits in Conditions 5.6 are

addressed by the records and reports required in Conditions

7.2.9 and 7.2.10 and the emission factors and formulas

listed below if suitable manufacture's emission rate data

is not available:

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i.

Emission factors for the affected diesel engines up

to 600 horsepower:

Emission Factors

Pollutant

(lb/mmBtu)

(lb/hE-hr)

Fuel

Input

Power Output

VOM

0.35

2.46 x

10 -03

PM

0.31

2.20 x 10

-03

SO,

0.29

2.05 x 10

-03

NO

x

4.41

0.031

CO

0.95

6.68 x 10

-03

The heat content of distillate fuel oil shall be

assumed to be 137,030 Btu/gal as per AP-42.

Emissions

=

Distillate Fuel Oil Usage x Heat Content

of Fuel Oil x Emission Factor

The emission factors are for Gasoline And Diesel

Industrial Engines from AP-42 Section 3.3 (dated

10/96) .

ii.

Emission factors for the affected engines greater

Pollutant

VOM

PM

SO,

NO

x

CO

Emission Factors

(lb/mmBtu)

Fuel Input

0.09

0.1

1.01 x

SFO

3.2

0.85

(lb/hp-hr)

Power Output

7.05 x 10 -04

0.0007

8.09 x 10 -03 xS1

0.024

5.5 x 10 -03

Where SFO represents the percent sulfur in the fuel

oil. Sl

=

% sulfur in fuel oil. The heat content of

distillate fuel oil shall be assumed to be 137,030

Btu/gal as per AP-42.

Emissions

=

Distillate Fuel Oil Usage x Heat Content

of Fuel Oil x Emission Factor

The emission factors are for Large Stationary Diesel

And All Stationary Dual-fuel Engines from AP-42

Section 3.4 (dated 10/96).

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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 Reguirements (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;

57

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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 eAA;

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.

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8.6

Reporting Requirements

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.

59

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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 (Me 40)

P.O. Box 19276

Springfield, Illinois 62794-9276

60

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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

2009 Mall Street

Collinsville, Illinois 62234

iv.

USEPA Region 5 - Air Branch

USEPA (AR -

17J)

Air & Radiation Division

77 west Jackson Boulevard

Chicago, Illinois 60604

c.

Permit applications should be addressed to the Air Permit

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

address of the Air Permit Section is as follows:

8.7

Title I Conditions

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section (MC 11)

P.O. Box 19506

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 (Tl 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.)

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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 all 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.

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9.2.2

9.2.3

9.2.4

9.2.5

Duty to Maintain Equipment

The Perrnittee.shall maintain all equipment covered under this

permit in such a manner that the performance or operation of

such equipment shall not cause a violation 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),

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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.

64

---

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 of 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

65

---

certification; the compliance status; whether compliance was

continuous or intermittent; the methodes) 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 [Section

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

66

---

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.

67

---

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 39.5(15) 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

68

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

* * * * * PCB 2009-099 * * * * *

---

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 the 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.

69

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

* * * * * PCB 2009-099 * * * * *

---

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

---

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 lAC

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 lAC 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

2-1

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

* * * * * PCB 2009-099 * * * * *

---

iii.

Limits for Process Emission Units For Which Construction or

Modification Commenced On or After April 19, 1972

[35 IAC

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

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 IAC

266.110].

2-2

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

* * * * * PCB 2009-099 * * * * *

---

b.

Existing Process Emission Units for Which Construction or

Modification Prior to April 14, 1972 [35 rAC 212.322J.

i.

No person shall cause or allow the emission of particulate

matter into the atmosphere in anyone hour period 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 rAC 212.322(a)J.

ii. Interpolated and extrapolated values of the data in

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

using the equation [35 rAC 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

lb/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

Eng:lish

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 (el J:

Metric

English

p

E

P

E

Mg/hr

kg/hr

T/hr

Ib/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

l3.8

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

266.110J.

2-4

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

* * * * * PCB 2009-099 * * * * *

---

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

---

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

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/air/permits/197-fee.pdf

4-1

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

* * * * * PCB 2009-099 * * * * *

---

Attachment 5 Clean Air Interstate Rule (CAIR) Permit

217-782-2113

CAIR PERMIT

Union Electric Company d/b/a Ameren UE

Attn: Michael L. Menne, Designated Representative

1901 Chouteau Avenue

Post Office Box 66149; MC 602

St. Louis, Missouri 63166-6149

Oris No.:

IEPA

1.D.

No.:

55496

147803AAC

Source/Unit:

Goose Creek Power Plant

Date Received:

December 24, 2007

Date Issued:

March 20, 2009

Expiration Date: March 20, 20014

STATEMENT OF BASIS:

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

2

Trading

Program, the CAIR NO

x

Annual Trading Program and the CAIR NO

x

Ozone Season

Trading Program, and 35 rAC Part 225, Subparts C, Of and E, respectively, the

Illinois Environmental Protection Agency is issuing this CAIR permit to Union

Electric Company d/b/a Ameren UE for the affected units at its Goose Creek

Power Plant located at 760 E 2150 N Road, Monticello, Illinois, 61856, i.e.,

CT01 - CT 06.

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

ALLOWANCES, 1\NIl NO. OZONE SEASON ALLOWANCES FOR THE AFFECTED UNITS:

Program

Allocation of Allowances

CAIR 50

2

These units are not entitled to an allocation

of CAIR S02

Allowances

allowances pursuant to

40 CFR Part 96.

CAIR NO

x

Annual These units are eligible to an allocation of CAIR 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 CAIR 50

2

Trading

Program requirements, CAIR NO

x

Annual Trading Program requirements, CAIR 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 S02 emissions and NO

x

emissions and requires the owners and operators to

hold CAIR S02 allowances to account for S02 emissions, CArR NO

x

annual

allowances to account for annual NO

x

emissions, and CAIR NO

x

ozone season

allowances to account for ozone season NO

x

emissions from the CAIR units. An

5-1

---

allowance is a limited authorization to emit S02 or NO

x

emissions during or

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

,

CAIR 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 3, Illinois EPA

5-2

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

* * * * * PCB 2009-099 * * * * *

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

DIvISION Of AIR POLLUTION CONTROL., PERMIT S.CTION

1>.0. BOX 19500

SPRlNt)FIEW.

iLLINOIS

62794.9500

Application For CAIR

II)-NU!ItBEft

Permit For

PeRMIT

N:G',_

Electrical Generating Units (EGU)

IlATF'

FOR AF>PLfCANrs USE

I

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APPLICATION PAGE ;::.4 __

Il'ri01M

on

RiOl>uyded Paper

S7O-CMPP

5-6

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

* * * * * PCB 2009-099 * * * * *

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