**APPLICATION REVIEW**

AND DETERMINATION OF PRELIMINARY COMPLIANCE

FOR:

**Barrick Goldstrike Mines, Inc.**

## Western 102 Power Generation Facility

# Reno-Tahoe Industrial Park

Storey County, Nevada

### Operating Permit to Construct convert to Class I Operating Permit Application AP4911-2189

![](media/image1.png){width="1.8020833333333333in" height="1.3125in"}

BY

########  STATE OF NEVADA

########  DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES

DIVISION OF ENVIRONMENTAL PROTECTION

BUREAU OF AIR POLLUTION CONTROL

Rod Moore

Staff Engineer

September 26, 2006

**1.0 INTRODUCTION**

On June 19, 2006, Barrick Goldstrike Mines, Inc. (Barrick) submitted an
application to the Nevada Division of Environmental Protection - Bureau
of Air Pollution Control (NDEP-BAPC), to convert their current Operating
Permit to Construct (AP4911-1364) to a new Class 1 Air Quality Operating
Permit. The facility is located at the Tahoe-Reno Industrial Park
located in Storey County, Nevada approximately 25 km east of Reno on the
south side of the Truckee River. The Standard Industrial Classification
(SIC) number for the process is 4911, Electrical Services, described as
"*Establishments engaged in the generation, transmission, and/or
distribution of electric energy for sale.*" The North American Industry
Classification System (NAICS) number is 221112, described as *"Electric
power generators, fossil fuel."* The project consists of 14 Wartsila
lean-burn natural gas reciprocating engines that turn generators to
develop power. Each engine is attached to an 8.2 MW electric generator.
Combined gross facility output is estimated at 115 MW.

Current emission estimates indicate that the Barrick plant will be a
Class 1 stationary source (emissions of criteria pollutants are greater
than 100 tons/year). The controlled pollutant emissions of PM~10~, PM,
Carbon Monoxide and Volatile Organic Compounds are greater than 100 tons
per year each.

+----------------------------------------+-----------------------------+
| The facility is an area source for the | +------------------------+  |
| single HAP formaldehyde, with          | | ***Applicant Proposed  |  |
| estimated emissions at 9.94 tons/yr,   | | Facility-wide PTE.***  |  |
| just below the 10 TPY major source     | |                        |  |
| threshold (for any single HAP).        | | +---------+--------+   |  |
| Similarly, the total combined HAP      | | | **Poll  | *      |   |  |
| emissions of 22.45 TPY are less than   | | | utant** | *TPY** |   |  |
| the 25 TPY major source threshold (for | | +---------+--------+   |  |
| all HAPs combined).                    | | | PM      | 158.76 |   |  |
|                                        | | +---------+--------+   |  |
| The project's source category has a    | | | PM~10~  | 158.76 |   |  |
| 250 TPY threshold to be designated a   | | +---------+--------+   |  |
| major stationary source for PSD        | | | NO~x~   | 93.80  |   |  |
| applicability. The potential to emit   | | +---------+--------+   |  |
| of the following NSR regulated         | | | CO      | 152.32 |   |  |
| pollutants (PM~10~, NO~X~, CO, SO~2~   | | +---------+--------+   |  |
| and VOCs) are below the 250 TPY        | | | VOC     | 149.52 |   |  |
| threshold.                             | | +---------+--------+   |  |
|                                        | | | ####### | 35.56  |   |  |
|                                        | | | # SO~2~ |        |   |  |
|                                        | | +---------+--------+   |  |
|                                        | | | HAPs    | \<     |   |  |
|                                        | | | (all)   | 25.0   |   |  |
|                                        | | +---------+--------+   |  |
|                                        | | | Forma   | \<     |   |  |
|                                        | | | ldehyde | 10.0   |   |  |
|                                        | | +---------+--------+   |  |
|                                        | +------------------------+  |
+----------------------------------------+-----------------------------+

Potential emission rates are accomplished with control technologies
achieving very high emissions reduction rates for Reciprocating Internal
Combustion Engines (RICEs). Of special interest and discussion in this
review is the potential for formaldehyde to exceed the applicant
proposed PTE of 9.94 TPY and to trigger the source as a major HAP
source. Major source status for formaldehyde would require the facility
to be subject to the recently promulgated 40 CFR Part 63, Subpart ZZZZ
NESHAP MACT for RICEs. Applicability to the Subpart ZZZZ would mandate
additional monitoring and a continuous parametric monitor system for
each RICE.

**1.0 INTRODUCTION** (Continued)

The Western 102 project is located in Hydrographic Basin HA-83, an air
management area triggered for PSD and increment consumption. HA-83 is a
designated PSD-triggered air management area consuming increment for
NO~x~, PM~10~ and SO~2~. Basin 83 was first triggered by the Sierra
Pacific Power Company, Tracy Generating Station Pinion Pine Power
Generating Project March 11, 1994. Several large facilities currently
reside in this area and both a Nevada Ambient Air Quality Standards
(NAAQS) analysis and PSD increment analysis will be performed for the
Barrick Western 102 facility and discussed in this review.

  -----------------------------------------------------------------------
  ***Location of Barrick Western 102 facility. Interstate 80 located
  directly North above the Truckee River. Other nearby sources are
  indicated.***

  ![](media/image2.jpeg){width="7.018055555555556in"
  height="3.8722222222222222in"}

  -----------------------------------------------------------------------

**2.0 DESCRIPTION OF FACILITY**

Pipeline quality natural gas is used by 14 reciprocating internal
combustion engine (RICE) gensets to produce electricity for various
Barrick facilities in Nevada. Each engine is a 4-stroke lean-burn (4SLB)
design with a comprehensive computer management system that controls
air/fuel ratio, ignition timing and various vital engine functions. The
lean-burn design utilizes a pre-combustion chamber for each cylinder
that pre-mixes the air-fuel mixture, which is then spark plug ignited.
The engines have 20 cylinders each and turbochargers that provide forced
induction. The engines operate at 720 RPM and displace approximately 726
liters each.

Each engine has its own selective catalyst reduction (SCR) system for
the reduction of NO~x~ and an oxidation catalyst system for the
reduction of CO, VOC and HAPs. The engine computer management system
also monitors and manages the SCR to make sure the proper amount of
ammonia/urea is fed to the catalyst at proper catalyst bed temperature
to achieve the manufacture guaranteed emissions reductions. The
manufacturer's guarantee for emissions reductions are: 94% for NO~x~,
94% for CO, 79% for VOCs and 97% for formaldehyde.

The engines are cooled by closed-loop cooling systems that do not emit
to the atmosphere. The systems consist of large outdoor radiators with
cooling fans. The turbo-charged compressed air/fuel mixture is
after-cooled with outdoor radiators and cooling fans to keep intake
charge temperatures low.

Each engine has a computer display console that warns the attendants of
cautionary or critical operating conditions. Critical conditions such as
over-heating or uncontrollable ignition detonation result in automatic
shutdown of the affected engine. The units do not have CEMs or COMs.

The lack of Continuous Emissions Monitoring (CEMs) and Continuous
Opacity Monitoring (COMs) was of great concern to NDEP-BAPC because
there is no continuous measurement of exhaust stack emissions. There was
also no automatic shutdown for emission control failures or poor
emission control efficiency. However, the various engine and emission
control systems are computer-controlled and designed to be configurable.
To make sure that the engines' controls are always functioning
correctly, the NDEP-BAPC has created a permit requirement for the
facility to custom-configure the computer systems. The configured system
will include an alarm that will sound when either an incorrect catalyst
bed temperature or incorrect ammonia/urea injection is detected. The
system alarm will sound for up to one hour until an attendant addresses
the alarm. If during the one hour period the attendant does not respond
or cannot rectify the problem, the affected engine will shut itself off.

[]{.mark}

**2.0 DESCRIPTION OF FACILITY** (Continued)

The engines are all housed within a single metal building. Each engine
has an individual exhaust stack that exits horizontally through the
building, through the SCR and oxidation catalyst and then turns-up
vertically. Stacks are 3.75 feet in diameter and 54 feet tall. The
stacks are grouped in units of 3 or 4 stacks on an open scaffold support
structure. Each engine displaces 726 liters with a flow rate of
110,000-120,000 pounds per hour at a temperature of \~750°F.

Engines may be individually started or stopped with power demands to
create a specific MW output in 8.2 MW increments. The engines are
started from a "warm state." A warm state is created by an engine block
heater that keeps the engine warmer than ambient temperatures. The warm
state prevents thermal stresses associated with cold-starting an engine.
The applicant states that the engines will never be cold-started. The
engines may be started-up remotely without an attendant onsite. From a
warm start, an engine takes approximately 15 minutes to reach
steady-state operation with the emission controls working at their
advertised (peak) efficiency.

The control catalyst technologies play a critical role in the facility's
potential to emit (PTE). The applicant distinguishes between cold and
warm catalyst starts. The catalysts heat quickly (\~15 minutes) but cool
very slowly (\~ 3 days). A warm catalyst start occurs when the catalyst
is 200°C or hotter. A cold catalyst start occurs when the catalyst is
below 200°C. Once an engine is shutdown the catalyst system essentially
remains \"closed\" with no ambient air introduced and the catalyst is
heavily insulated. The conductive loss through the catalyst housing is
very slow. Test results at a facility demonstrated that 16 hours after
an engine shutdown that the catalyst was at 600°F. Thirty-six hours
later the catalyst was still above 200°F.

Wartsilia provided warm and cold catalyst start emission factors derived
from: 1) factory tests; 2) fuel tests and 3) partial load steady-state
tests. It also appears that this data was interpolated on a graph.
Barrick proposes 420 cold catalyst startups and 1,120 warm catalyst
startups per year for all 14 units. This translates to 30 cold catalyst
starts and 80 warm catalyst starts per year for each engine.

The effectiveness and lifespan of the catalyst materials may vary.
According to Wartsila the catalyst manufacturer provides a 16,000-24,000
hour warranty (1.8-2.7 years). However, field results demonstrate that
with proper maintenance that catalyst life may be 36,000-48,000 hours
(4.1-5.5 years). A Wartsila engine facility in Arvada, Colorado noted
that catalyst efficiency began to decrease after approximately three
years of service. The technology at the Arvada facility is approximately
4 years older than the proposed project and is employed on the smaller,
18 cylinder natural gas model engines.

Barrick proposes to operate the facility 8,760 hours per year as a base
(power generation) plant. This is not so typical of RICE plants that are
typically used as peaking plants. Used as a base facility, maintenance
will be more frequent and without CEMs it may be difficult to ascertain
if controls are slipping or failing. It is apparent the catalyst
performance and maintenance should be carefully monitored, especially
after approximately three years of service.

**2.0 DESCRIPTION OF FACILITY** (Continued)

On an annual basis, each engine will be tested for PM, PM~10~, NO~X~,
CO, VOC and formaldehyde. SO~2~ shall be calculated from the sulfur
content in the natural gas. These tests will be used to verify the
manufacturer's emission factors and then to create emission factors
specific for each engine.

**3.0 DISCUSSION OF PROCESS**

1.  **Pipeline Quality Natural Gas**

Barrick will combust pipeline quality natural gas only for each of the
14 engines. Natural gas consists of a high percentage of methane
(generally above 85 percent) and varying amounts of ethane, propane,
butane, and inert gases. The average gross heating value of natural gas
is approximately 1,020 British thermal units per standard cubic foot
(Btu/scf), usually varying from 950 to 1,050 Btu/scf. Combustion
processes of natural gas typically yield particulate emissions below 10
microns in size, low SO~2~ emissions, notable CO, NO~x~ and VOC
emissions and some HAPs. The permit will require the use of natural gas
with a maximum sulfur content of 100 grains per dry standard cubic foot
(or less).

**3.2 RICE Engine Types**

Natural gas-fired reciprocating engines are separated into three design
classes: 2-cycle (stroke) lean-burn, 4-stroke lean-burn, and 4-stroke
rich-burn. Two-stroke engines complete the power cycle in a single
crankshaft revolution as compared to the two crankshaft revolutions
required for 4-stroke engines. All engines in these categories are
spark-ignited.

The Wartsila engines are lean-burn 4-stroke engines. Lean-burn engines
may operate up to the lean flame extinction limit, with exhaust oxygen
levels of 12 percent or greater. The air to fuel ratios of lean-burn
engines range from 20:1 to 50:1 and are typically higher than 24:1. The
exhaust excess oxygen levels of lean-burn engines are typically around 8
percent, ranging from 4 to 17 percent.

3.  **Pollutants Emitted from RICEs**

The primary criteria pollutants from natural gas-fired reciprocating
engines are oxides of nitrogen (NO~x~), carbon monoxide (CO), and
volatile organic compounds (VOC). The formation of nitrogen oxides is
exponentially related to combustion temperature in the engine cylinder.
The other pollutants, CO and VOC species, are primarily the result of
incomplete combustion. Particulate matter (PM) emissions include trace
amounts of metals, non-combustible inorganic material, and condensable,
semi-volatile organics which result from volatized lubricating oil,
engine wear, or from products of incomplete combustion. Sulfur oxides
are very low since sulfur compounds are removed from natural gas at
processing plants. However, trace amounts of sulfur containing odorant
are added to natural gas at city gates prior to distribution for the
purpose of leak detection.

[3.3.1 NOX]{.underline}

90-95% of the nitrogen oxides that form from a combustion process are in
the form of nitrogen dioxide (NO~2~) and sometimes nitrous oxide
(N~2~O). There are two main mechanisms in which NO~x~ is formed in a
reciprocating engine. The first mechanism is due to nitrogen in the air
(thermal NO~x~), the second is due to nitrogen in the fuel (organic or
fuel NO~x~). Most types of natural gas have little or no fuel bound
nitrogen.

Essentially all NO~x~ formed in natural gas-fired reciprocating engines
occurs through the thermal NO~x~ mechanism. The rate of NO~x~ formation
through the thermal NO~x~ mechanism is highly dependent upon the
stoichiometric ratio, combustion temperature, and residence time at the
combustion temperature. Maximum NO~x~ formation occurs through the
thermal NO~x~ mechanism near the stoichiometric air-to-fuel mixture
ratio since combustion temperatures are greatest at this air-to-fuel
ratio.

[3.3.2 CO]{.underline}

Carbon monoxide is emitted from RICEs due to incomplete combustion.
Incomplete combustion occurs with an incorrect fuel/air mixture or low
combustion temperatures. CO emissions are a function of temperature and
decrease with higher combustion temperatures. CO results when there is
insufficient residence time at high temperature to complete the final
step in hydrocarbon oxidation.

There is a conflict in terms of temperature for CO and NO~x~ emissions.
High temperatures will produce more NO~x~ and less CO, while lower
temperatures will produce less NO~x~ and more CO.

[3.3.3 SO]{.underline}~x~

SO~x~ are primarily SO~2~ but may also include SO~3~. SO~2~ comes from
the combustion of fuels with sulfur in them. Sulfur compounds occur
naturally in fuels derived from petroleum. Sulfur burning in a fuel
contributes to its energy input, but is undesirable because it corrodes
combustion equipment and emits SO~x~. Sulfur compounds can also be found
in natural gas in the form of hydrogen sulfide.

[3.3.4 Hydrocarbons (VOCs and aldehydes)]{.underline}

Hydrocarbons (HCs) are compounds made of carbon and hydrogen atoms, and
fuels are mostly made up of different hydrocarbons. Hydrocarbon
emissions are a concern because volatile hydrocarbons can contribute to
the formation of ozone. Potential sources of HCs from RICEs are unburned
hydrocarbons in the exhaust. Engine misfire and deposits from fuel are
sources of HC emissions. Partially oxidized HC compounds can form
aldehyde HAPs such as formaldehyde. Aldehydes may be generated from the
quenching of the flame on the walls of the cylinder and in other low
temperature areas of the engine. Aldehydes can also form from
photochemical reactions involving HCs and oxygen.

######### 3.3.5 PM/PM~10~ Emissions

Most of the PM emissions from a RICE result from incomplete combustion
and burning of the lubricating oil. Lubricating oil contributes 50 to
280 times as much material to particulate matter than fuel. A small
amount of oil consumption can have a large effect on emissions. Fuel
with high aromatic and sulfur content will have more PM emissions.
Emissions of PM from natural gas-fired reciprocating engines are
generally minimal and comprise fine filterable and condensable PM.

4.  **Factors That Affect RICE Emissions**

######## The emission factors provided by Wartsila are quite low for a RICE. Extensive literature research did not yield any emission factors as low as those of Wartsila. The main factors that affect emissions from RICEs include atmospheric conditions, air/fuel ratio, charging method, ignition timing, combustion cycle, load, speed, fuel and valve and combustion chamber design. 

The Wartsila engines benefit from extensive design, field-testing and
computer management systems. Key components such as air/fuel ratio,
ignition timing, combustion cycle, load and speed are managed by a
computer system that maintains ideal performance and emissions. Each
engine cylinder has individually adjustable parameters. The computer
system has the ability to adjust itself or "to learn" new engine
management parameters to retain the ideal operating conditions through
varying fuel quality, environmental conditions and engine wear. The
computer management systems are setup onsite by the manufacturer and are
then "locked" and cannot be modified by the facility.

Characteristics such as valve and combustion chamber design include a
proprietary pre-mix combustion chamber and ignition system. Years of
field-testing in maritime freight applications and a long production
history have given Wartsila substantial expertise with large RICEs.

Atmospheric conditions that may affect emissions such as temperature and
humidity are also controlled by pre-warming the engines and by having
the engines housed in a climate-controlled building atmosphere. The
implementation of turbochargers with after-cooling provides for a
constant atmospheric charge (temperature and pressure) into the engines
regardless of climate and elevation.

**3.5 RICE Emission Factors**

######## When estimating a proposed facility's PTE, it is standard practice to use approved emission factors until initial stack performance tests may be performed. The development and selection of emission factors to estimate PTE can be difficult because there are so many RICE engines available of varying age, design and emission controls. When the USEPA developed the AP-42 emission factor for RICE's combusting natural gas, they generated a total of 71 emissions test reports containing 469 emissions tests. When developing the emission factors, the USEPA attempted to define dependant variables and predictive algorithms.

[3.5.1 Emission levels of NOx, CO, total hydrocarbons, and
formaldehyde]{.underline} were compared against engine size and
operating load. Within the scatter of the data, size showed no
consistent effect on the emission levels of NO~x~, CO, total
hydrocarbons, or formaldehyde for any of the engine types. Load showed
the highest effect on NO~x~ and CO emissions. However, the EPA was not
able to develop an algorithm that relates NO~x~ or CO to load. For all
other pollutants, load showed some effect on emission levels; however,
the trends were not consistent nor were they significant compared to the
data scatter.

[3.5.2 PM Emission Factors]{.underline}

For a limited number of tests, PM measurements were conducted. For 4SLB
engines, these PM measurements include filterable PM~10~, inorganic
condensable PM, and organic condensable PM. To provide a total PM~10~
emission factor, these three PM fractions were added together.

[3.5.3 CO]{.underline}~2~ [and SO]{.underline}~2~ [Emission
Factors]{.underline}

Emission factors for CO~2~ were calculated by mass balance. This
approach was also taken for calculating SO~2~. Since the carbon and
sulfur content in pipeline-quality natural gas is fairly consistent, EPA
believes this is the best method for calculating CO~2~ and SO~2~
emission factors. For CO~2~, it was assumed that 99.5% of the fuel
carbon was converted to CO~2~. For SO~2~, a 100% conversion of fuel
sulfur was assumed. The CO~2~ emission factor was based on a carbon
weight percent in natural gas of 75% and the SO~2~ emission factor was
based on a sulfur concentration in natural gas of 2,000 grains per
million standard cubic feet.

[3.5.4 Wartsila Emission Factors]{.underline}

Wartsila provided emission factors for criteria pollutants and
formaldehyde derived from approved EPA test methods, except for the
speciation of HAPs. Emission factors for speciated HAPs were provided
from AP-42. Given the comprehensive engine control systems, Wartsila
maintains that their provided emission factors are representative for
any operating environment regardless of climate and altitude.

6.  **RICE Control Technologies**

Three generic control techniques have been developed for reciprocating
engines: parametric controls (timing and operating at a leaner
air-to-fuel ratio); combustion modifications such as advanced engine
design for new sources or major modification to existing sources
(clean-burn cylinder head designs and pre-stratified charge combustion);
and post combustion catalytic controls installed on the engine exhaust
system. Post-combustion catalytic technologies include selective
catalytic reduction (SCR) for lean-burn engines, nonselective catalytic
reduction (NSCR) for rich-burn engines, and CO oxidation catalysts for
lean-burn engines.

[3.6.1 Lean Burn Technology]{.underline}

The Wartsila engines are of a lean burn design. The focus of lean burn
technology is to operate with the leanest fuel/air mixture that will not
pre-detonate or create excessive CO emissions. Wartsila accomplishes
this with precise computer engine controls and a pre-combustion chamber.
In the Wartsila engine with larger bore sizes, it is difficult or
impossible to ignite a very lean mixture. Therefore an attached
pre-combustion chamber that has 5-10% of the volume of the engine
cylinder is filled with a rich fuel/air mixture that is easy to ignite
and then propagate through the rest of the cylinder, burning the very
lean air/fuel mixture. This lean burn provides a cleaner exhaust for the
add-on emission controls and utilizes less fuel.

[3.6.2 SCR Control]{.underline}

Each Wartsila engine employs an SCR control device. Selective catalytic
reduction is a post-combustion technology that is effective in reducing
NO~x~ in exhaust from lean-burn engines. An SCR system consists of
ammonia storage, feed, and injection system, and a catalyst and catalyst
housing. Selective catalytic reduction systems selectively reduce NO~x~
emissions by injecting ammonia (either in the form of liquid anhydrous
ammonia or aqueous ammonium hydroxide) into the exhaust gas stream
upstream of the catalyst.

Nitrogen oxides, NH~3~, and O~2~ react on the surface of the catalyst to
form N~2~ and H~2~O. For the SCR system to operate properly, the exhaust
gas must be within a particular temperature range (typically between 450
and 850°F). The temperature range is dictated by the catalyst. Exhaust
gas temperatures greater than the upper limit (850°F) will pass the
NO~x~ and ammonia un-reacted through the catalyst. Ammonia emissions,
called NH~3~ slip, are a key consideration when specifying a SCR system.
SCR is most suitable for lean-burn engines operated at constant loads,
and can achieve efficiencies as high as 90%. For engines that typically
operate at variable loads, such as engines on gas transmission
pipelines, an SCR system may not function effectively, causing either
periods of ammonia slip or insufficient ammonia to gain the reductions
needed.

The US EPA conducted two sets of upstream and downstream tests on SCR
performance. These tests were conducted on one 4-stroke lean-burn
engine. The average NO~x~ reduction efficiency across the SCR unit was
77%. This reduction efficiency compared well with the results of the SCR
analysis conducted by GRI, which reported average NO~x~ reductions
across SCR units for natural gas-fired reciprocating engines of 80%. It
should be noted that Wartsila claims a 97% reduction for their engine
and SCR.

[3.6.3 NSCR Control]{.underline}

This control technology is not applicable to the lean-burn Wartsila
Engines. NSCR is non-selective catalytic reduction. A NSCR technology
controls two or more different pollutants at once. The NSCR technique is
effectively limited to engines with normal exhaust oxygen levels of 4
percent or less. This includes 4-stroke rich-burn naturally aspirated
engines and some 4-stroke rich-burn turbocharged engines. Lean-burn
engines can not be retrofitted with NSCR control because of their lower
exhaust temperatures.

######### 3.6.4 Catalytic Oxidation Control

The Wartsila engines each employ an oxidation catalyst. Limited
emissions data were available for simultaneous measurements of
uncontrolled and controlled emissions from engines equipped with
oxidation catalysts (CO, VOC and HAP oxidation catalyst). Oxidation
catalyst performance increases with increased engine exhaust
temperatures. For natural gas fired engines, 2-stroke engines typically
have lower exhaust temperatures than 4-stroke engines. Therefore, it is
expected that higher emission reductions would be achieved from 4-stroke
engines as compared to 2-stroke engines.

From the gathered emissions data and catalyst manufacturer's
information, CO catalyst performance for 4SLB natural gas-fired engines
is expected to be higher than 90% reduction. Wartsila claims a 97%
reduction for their engine and oxidation catalyst.

+--------------------------------+-------------------------------------+
| **3.7 Emission Catalysts**     | +--------------------------------+  |
|                                | | ![](media/image3.pn            |  |
| [3.7.1 Combination of          | | g){width="3.265972222222222in" |  |
| Controls]{.underline}          | | height="1.0131944444444445in"} |  |
|                                | |                                |  |
| The Western 102 project        | | ***Wartsila Ultra-low          |  |
| utilizes the Wartsila          | | Emissions Control System       |  |
| lean-burn engine with the      | | combines an SCR and oxidation  |  |
| Ultra Low Emissions (ULE)      | | catalyst.***                   |  |
| system. The ULE system is      | +--------------------------------+  |
| comprised of a SCR and         |                                     |
| oxidation catalyst             |                                     |
| specifically calibrated to the |                                     |
| Wartsila engine application.   |                                     |
| The ULE system provides        |                                     |
| substantial emissions          |                                     |
| reductions, but the system     |                                     |
| adds additional up-front cost  |                                     |
| and maintenance. Both the SCR  |                                     |
| and oxidation catalysts have a |                                     |
| limited lifespan.              |                                     |
|                                |                                     |
| [3.7.2 Catalyst                |                                     |
| Testing]{.underline}           |                                     |
|                                |                                     |
| The EPA believes initially     |                                     |
| high levels of emissions       |                                     |
| reduction may be attributed to |                                     |
| fresh or "green" catalyst      |                                     |
| conditions. It may be          |                                     |
| suggested that catalyst        |                                     |
| performance testing be         |                                     |
| performed after a suitable     |                                     |
| catalyst break-in period to    |                                     |
| represent typical catalyst     |                                     |
| operating behavior. Likewise,  |                                     |
| it has been suggested that     |                                     |
| brand-new or rebuilt engines   |                                     |
| should be run bypassing the    |                                     |
| controls until the engines are |                                     |
| broken-in. New engines have    |                                     |
| more oil blow-by and misfires  |                                     |
| that may damage the catalyst   |                                     |
| systems.                       |                                     |
|                                |                                     |
| Catalyst performance has been  |                                     |
| observed to decrease over time |                                     |
| due to catalyst decay.         |                                     |
| Catalyst decay may result from |                                     |
| excessive temperature          |                                     |
| differentials, catalyst        |                                     |
| masking and catalyst           |                                     |
| poisoning.                     |                                     |
+--------------------------------+-------------------------------------+
|                                | +--------------------------------+  |
|                                | | ![](media/image4.jpe           |  |
|                                | | g){width="3.252083333333333in" |  |
|                                | | height="2.446527777777778in"}  |  |
|                                | |                                |  |
|                                | | ***Wartsila SCR systems.***    |  |
|                                | +--------------------------------+  |
+--------------------------------+-------------------------------------+
|                                | +--------------------------------+  |
|                                | | ![](media/image5.png           |  |
|                                | | ){width="3.2527777777777778in" |  |
|                                | | height="1.34375in"}            |  |
|                                | |                                |  |
|                                | | ***Wartsila SCR and oxidation  |  |
|                                | | catalyst system.***            |  |
|                                | +--------------------------------+  |
+--------------------------------+-------------------------------------+

3.7.3 Catalyst Masking and Poisoning

Masking agents are particulates, ammonium salts, sulfur, chlorine,
chloride and other substances that deposit on the surface of the
catalyst and inhibit catalyst activity by forming a barrier between the
exhaust gas and the catalyst. Masking agents can usually be removed by
cleaning. Over 90% of the catalyst activity can be regained by removing
masking agents. Catalyst poisoning is permanent. Poisoning is usually
caused by the fuel or lubrication oil. Natural gas is usually free of
poisoning agents. Any lubricating oil that burns can create emissions
that foul the catalyst. Oils with high ash or phosphorous content are
more likely to create catalyst poisoning. The leading edge of the
catalyst is more subject to erosion and masking if particulate is
present.

The chemical reactions that occur in the SCR occur over a small
temperature range, generally between 600-800°F. If the temperature drops
below this range, excessive amounts of ammonia will release out the
exhaust stack; if too high the catalyst and ammonia will decompose.

High sulfur fuels may form SO~2~ in the SCR and react with the catalyst
and ammonia to create ammonium salts that quickly erode SCR surfaces.
Natural gas has little or no sulfur, but may contain hydrogen sulfide
that will contribute to ammonium salt formation. Ammonium salt formation
may also be deterred by raising the inlet gas temperature above the
ammonium bisulfate formation temperature and controlling ammonia slip.

Ammonia is necessary for the chemical reactions in the SCR to work.
Ammonia is on the USEPA's list of extremely hazardous substances.
Ammonia is typically released (slipped) from the SCR exhaust because
excess ammonia is required due to inefficient distribution across the
catalyst. As a catalyst ages the ammonia slip increases.

Urea is a chemical that comes in the form of a powder that can be used
in place of ammonia for SCR. The temperature range for efficient NO~x~
reduction with Urea is higher than the exhaust temperature of most
engines, so urea injection is limited to systems where there is
supplemental firing applied to the exhaust stream.

**3.8 Formaldehyde**

# 

Special attention is given in this Technical Support Document with
regards to the chemical compound formaldehyde. Formaldehyde is listed as
a Hazardous Air Pollutant (HAP) by the EPA and in the Western 102
facility it is of concern because the facility proposes to emit
formaldehyde at a rate of 9.94 TPY, which is just below the major source
threshold for any single HAP. HAPs are chemicals that can cause adverse
effects to human health or the environment. Congress has identified over
188 of these pollutants, including substances that cause cancer,
neurological, respiratory, and reproductive effects.

The 1990 amendments to the Clean Air Act (CAA) mandated significant new
air quality programs and substantially enhanced some existing ones.
Title I of the CAA includes the provisions for attaining the NAAQS for
criteria pollutants, and provisions for controlling emissions of
hazardous air pollutants (HAPs). The provisions in Title I that address
the control of HAP emissions, or air toxics, are found in Section 112.
Section 112 of the CAA includes provisions for the promulgation of
NESHAP, or maximum achievable control technology (MACT) standards, as
well as several related programs to enhance and support the NESHAP
program.

Formaldehyde is normally present at low levels, usually less than 0.06
ppm (parts per million), in both outdoor and indoor air. When present in
the air at levels at or above 0.1 ppm, acute health effects can occur
including watery eyes; burning sensations in the eyes, nose and throat;
nausea; coughing; chest tightness; wheezing; skin rashes; and other
irritating effects. In chronic doses formaldehyde is considered
carcinogenic and mutagenic. Individuals with pre--existing diseases of
retina, kidneys, liver or cardiovascular system may have increased
susceptibility to the toxic effects of formaldehyde. The target organs
are the eyes, kidneys, liver, cardiovascular system, and skin.

[]{.mark}

Formaldehyde is a probable human carcinogen. The U.S. EPA classifies it
as a Group B1 carcinogen and the International Agency for Research on
Cancer (IARC) classifies it as a Group 2A carcinogen. Studies identified
increased incidences of lung and nasopharyngeal cancer.

[3.8.1 The Characteristics of Formaldehyde in RICEs]{.underline}

The available data for HAPs, including formaldehyde, in regards to RICEs
is low. More data is available correlating the behavior of HAPs and
turbines. Of note IC engines typically create more NO~2~ than turbines
and studies suggest that higher NO~2~ levels yield less accurate HAP
measurements with certain procedures. The following items seem
predominant across available documents on the topic:

1)  HAPs do not show a clear dependence on engine load.

2)  Regarding major source criteria, formaldehyde is the only likely
    compound to reach 10 TPY and will likely be triggered before the 25
    TPY threshold for all HAPs combined.

3)  Formaldehyde is formed as a normal intermediate that is typically
    created in the later stages of combustion.

4)  Formaldehyde measurements during combustion are 5-10X higher than
    those measured from exhaust gas.

5)  Engine maintenance is shown to reduce formaldehyde emissions.

6)  Acetylhede factors are 1/7^th^ of formaldehyde factors.

7)  Attempts to predict formaldehyde based on measurement of CO, NO~x~
    or NMHC have generally failed.

[3.8.2 Formaldehyde Test Methods]{.underline}

Several methods exist for determining formaldehyde in gas streams,
including colorimetric analysis, chromatography (gas, liquid and ion),
and spectrometric. However, only a few are considered accurate and
specific enough to demonstrate compliance with federal or state air
requirements. The USEPA generally accepts three methods for determining
formaldehyde emissions: 1) EPA Method 0011 of SW-846; 2) California Air
Resource Board (CARB) Method 430; and 3) EPA Method 320 of 40 CFR Part
63.

[EPA Method 0011 and CARB Method 430]{.underline}

EPA Method 0011 and CARB Method 430 are very similar methods. Both use a
liquid solution of dinitrophenylhydrazine (DNPH) to absorb formaldehyde
from the gas stream and convert it to a stable chemical derivative that
can be quantified using high performance liquid chromatography (HPLC).
These methods utilize traditional \"wet\" stack sampling procedures to
collect an integrated sample that is then analyzed at an off-site
laboratory. This approach yields a \"snapshot\" measurement of average
formaldehyde concentration over a specific interval of time. Some
disadvantages of this method are:\
reagent shipping and shelf life are problems, questions exist as to the
accuracy for lean burn sources and results are determined off-site.

[Method 320: Fourier Transform Infrared spectrometer]{.underline}

EPA Method 320 is a generic method using Fourier transform infrared
spectroscopy (FTIR). This technology uses sophisticated computer
analysis of infrared spectra of the gas stream to determine its
composition. The analysis is direct and on-site, and provides near
real-time and semi-continuous measurements of the gas composition.

Some advantages of the Method 320 are: extensive supporting data - used
extensively in AP-42 data collection, it has been validated for
formaldehyde testing on reciprocating engines (July 1995) and it
speciates most aldehydes (can provide acetaldehyde number). Some
disadvantages are: cost, expensive equipment and additional test time,
and it requires more setup time per source than other technologies

AP-42 Emission factors for 4SLB Rice combusting natural gas were derived
with the measurement technique FTIR (Fourier Transformation Infra-red),
a direct spectrographic measurement. EPA claims another popular method,
DNPH may represent a negative bias due to oxygen and nitrogen, but it is
still an accepted Method. Therefore, EPA chose FTIR measurement to
develop the AP-42 emission factor.

[3.8.3 Choosing a Formaldehyde Test Method]{.underline}

The most relevant problem with the DNPH methods is their lack of
reliability in gas streams containing significant amounts of NO~2~.
Research suggests that NO~2~ scavenges the DNPH from the sample
solution, thus making it unavailable to collect the formaldehyde and
producing a negative bias in the results. Data suggests that the
interference may be insignificant if the NO~2~ concentration is below
approximately 50 ppm.

Due to the nature in which FTIR works, interference from other gas
species is not a problem with this method. The most significant
disadvantage with this method is cost, due to the requirement for more
specialized instrumentation and highly trained personnel to conduct the
analysis. However, this cost is somewhat offset by the larger and more
useful set of data that the method gives.\
\
USEPA personnel have stated that the soon-to-be proposed gas turbine
MACT rule will likely endorse both CARB Method 430 and EPA Method 320
for formaldehyde measurements. The EPA has, however, voiced their
concern over the potential NO~2~ interference with the CARB method. For
this reason, there may be some language in the rule that more favorably
recommends the use of the FTIR method.\
\
For the Barrick Western 102 facility, either EPA Method 0011 of SW-846
or EPA Method 320 of 40 CFR 63 would be suitable. Since the NO~2~ after
the SCR is less than 50 ppm and since speciation of aldehydes is not
desired, either test method would be acceptable. NDEP-BAPC will let the
applicant decide and then review the proposed testing protocol prior to
testing.

**4.0 APPLICABLE REGULATIONS**

#### Applicable regulations are those regulatory requirements that apply to a stationary source or to emission units contained within the stationary source. In Nevada's program, the regulations governing the emissions of air pollutants from which the applicable requirements originate are derived from four categories of regulations. These four categories consist of the requirements contained in the Nevada Revised Statutes (NRS), the Nevada Administrative Code (NAC), the Approved State Implementation Plan (ASIP) and the Code of Federal Regulations (CFR, contained within various Parts within Title 40).

**4.1 STATE STATUTES AND ADMINISTRATIVE CODE**

The Nevada Revised Statutes (NRS) and the Nevada Administrative Code
(NAC) require that where state regulations are more stringent in
comparison to Federal regulations, the State regulations are also
applicable. The Barrick facility will be subject to NAC and NRS.

1.  **NEVADA REVISED STATUTES**

The Nevada Revised Statutes (NRS) are the statutory authority for the
adoption and implementation of administrative regulations. Barrick is
subject to NRS requirements stipulated in NRS 445B.100 through 445B.640,
which refer to the control of air pollution. The NRS specifies the State
Environmental Commission as the governing body given the power to adopt
administrative regulations. Because the NRS is the enabling statutory
authority, very few specific requirements are contained in the statutes.
Rather, the NRS provides broad authority for the adoption and
implementation of air pollution regulations.

**4.1.2 NEVADA ADMINISTRATIVE CODE**

The Nevada Administrative Code (NAC) are administrative regulations that
contain specific requirements relating to the control of air pollution.
Barrick is also subject to NAC 445B.001 through 445B.3689, inclusive,
that govern the control of air pollution from regulated facilities in
Nevada. The State Environmental Commission adopts these regulations.

**4.2 NEVADA APPLICABLE SIP (ASIP)**

The Applicable State Implementation Plan (ASIP) is a document that is
prepared by a State or local air regulatory agency and is required to be
submitted to the USEPA for approval. Title I of the Clean Air Act is the
statutory authority for the USEPA regulations that require a State to
submit a SIP. The contents of the SIP are intended to show how a State,
through the implementation and enforcement of the regulations contained
in the SIP, will either show how attainment of the National Ambient Air
Quality Standards (NAAQS) will be achieved or how a State will continue
to maintain compliance with the NAAQS. Nevada's most recent ASIP,
approved by USEPA, is based on State regulations codified in 1982.
Nevada submitted an updated ASIP to the USEPA in early 2006. The USEPA
has provided limited approval of the revised ASIP regulations and there
have not been any major changes that may affect the permitting process,
since the codified regulations of 1982.

In general, the regulations contained in the ASIP closely parallel the
current NAC regulations. However, because the ASIP is based on older air
quality regulations (at this time), compliance with all of the current
NAC regulatory requirements does not necessarily ensure compliance with
all of the current ASIP regulatory requirements. All of the equipment
considered in this application must meet, at minimum, the standards set
forth in the ASIP. Specifically, the emission standards contained in
ASIP 445.731 for particulate matter, ASIP article 8.2 for sulfur
emissions, SIP 445.721 for opacity and 12.1 for the ambient air quality
standards must not be exceeded. The proposed Barrick facility does not
exceed applicable ASIP standards.

[ASIP PM Calculations (445.731)]{.underline}

Y=1.02X\^-0.231

Y=(1.02)(77\^-.231)

Y=(1.02)(0.367)

Y=0.374 pounds per MMBtu/hr

The maximum allowable PM emission is 0.374 lbs/MMBtu/hr.

######### ASIP Sulfur (Article 8.2.1)

This value is derived from a reference table. For units with a heat
input greater then 10 MMBtu but less than 100 MMBtu the maximum
allowable sulfur emission is 70 pounds per hour.

######### ASIP Opacity Standard (445.721) 

No owner or operator shall discharge any air contaminant for a period or
periods aggregating more than 3 minutes in any one hour opacity equal or
greater to 20%.

######### ASIP Ambient Air Quality Standards (12.1)

Applicant and NDEP-BAPC testing demonstrates no exceedance of State
standards.

**4.3 CODE OF FEDERAL REGULATIONS**

The Code of Federal Regulations (CFR) are regulations adopted by the
USEPA and published in the Federal Register pursuant to the authority
granted by Congress in the Clean Air Act. The CFR addresses multiple
topics, including but not limited to: permitting requirements,
performance standards, testing methods and monitoring requirements.

**4.3.1 NEW SOURCE PERFORMANCE STANDARDS**

The U.S. EPA has promulgated maximum emission standards and/or
monitoring/recordkeeping methods for selected source categories. These
standards are contained in Title 40 of the CFR, Part 60, and are known
as the New Source Performance Standards (NSPS). The NSPS are considered
the maximum emissions that may be emitted from a source, unless the NAC,
ASIP or PSD provisions are more stringent.

The Barrick Western 102 Power project is not subject to NSPS
requirements.

**4.3.2 PREVENTION OF SIGNIFICANT DETERIORATION REGULATIONS (PSD)**

40 CFR Part 52.21 specifies that PSD review is required for any new
major stationary source or any major modification to an existing major
stationary source. A major stationary source is defined as any pollutant
emitting activities, which belong to the same two-digit Source Industry
Classification and:

> 1\. Emits 100 tons/yr or more of any regulated NSR pollutant as one of
> the listed categories of sources listed in 40 CFR 52.21; or

2.  Emits 250 tons/yr or more of any regulated NSR pollutant and belongs
    to any other category source.

The Barrick Western 102 facility is **[not]{.underline}** subject to the
provisions of PSD, because the Western 102 facility is not of the listed
categories of sources subject to a PTE of any regulated NSR pollutant of
100 tpy major stationary source threshold, and the PTE of any regulated
NSR pollutant is less than the 250 tpy major stationary source threshold
required for "other" sources.

The Barrick Western 102 facility may revise their operations in future
modifications and increase the emissions of any regulated NSR pollutant
until that time that the 250 tpy major stationary source threshold of
NSR regulated pollutants is surpassed.

From that point on, any future modifications to the facility that
increase the emissions of any regulated NSR pollutant above the
applicable significant emissions threshold will require a Full PSD/NSR
review of the source.

Because HA-83 has been triggered earlier for PM~10~, NO~x~ and SO~2~,
emissions from the Western 102 facility will consume increment and an
analysis for PSD increment consumption is mandatory.

**\
**

3.  **NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS**

The federal National Emission Standards for Hazardous Air Pollutants
(NESHAP) provisions are contained in 40 CFR Parts 61 and 63. Proposed
standards are to be implemented August 14, 2004 for RICE HAPs under 40
CFR Part 63, Subpart ZZZZ. A proposed facility must be a major source
for HAPs for applicability to this requirement. Currently the applicant
estimates a PTE of 9.94 tpy for formaldehyde; which is slightly below
the 10 tpy threshold that would define it as a major source for any
single HAP. Periodic performance tests shall be performed on an annual
basis for each engine to demonstrate compliance with the permitted
emission limits.

The applicant proposes control technologies for CO and HAPs using an
oxidation catalyst with reduction rates similar to those required in
Subpart ZZZZ. The main difference between the applicants proposed
control operations and Subpart ZZZZ is that the Subpart requires the use
of a Continuous Parametric Monitoring System to measure catalyst bed
temperatures.

**COMPLIANCE ASSURANCE MONITORING**

The USEPA has promulgated requirements for sources to provide detailed
monitoring plans that will ensure compliance with all applicable
requirements. These monitoring requirements are contained in 40 CFR Part
64. Section 64.2 specifies that these monitoring requirements apply to a
"pollutant- specific emission unit at a major source" if all of the
following are satisfied:

1.  The unit is subject to an emission limit or standard;

2.  The unit uses a control device to achieve compliance with any such
    emission limitation or standard; and

3.  The unit has the potential pre-control device (uncontrolled)
    emission equal to or greater than 100% of the amount, in tons per
    year, required for a source to be classified as a major source.

40 CFR Part 64.5(a) requirements specify that for all pollutant-specific
emission units (PSEU) with the potential to emit ([taking into account
control devices to the extent appropriate under the definition of this
term in Part 64.1]{.underline}) the applicable regulated air pollutant
in an amount equal to or greater than 100% of the amount, in tons per
year, required for a source to be classified as a major source (i.e., a
"LARGE" PSEU), the owner or operator shall submit a CAM Plan at the
following times:

-   On or after April 20, 1998, the owner or operator shall submit
    information as part of an application for an [initial Part 70
    permit]{.underline} if, by that date, the application either: Has
    not been filed; or Has not been determined to be complete by the
    permitting authority.

-   On or after April 20, 1998, the owner or operator shall submit a CAM
    Plan as part of an application for a [Significant permit
    revision]{.underline}, but only with respect to those
    pollutant-specific emissions units for which the proposed permit
    revision is applicable.

-   The owner or operator shall submit a CAM Plan as part of the
    application for [Renewal]{.underline} of a Part 70 permit.

40 CFR Part 64.5(b) requirements specify that for all other PSEU's NOT
subject to Part 64.5(a) (i.e., "OTHER" PSEU), the owner or operator
shall submit a CAM Plan as part of an application for
[Renewal]{.underline} of a Part 70 permit.

The proposed facility meets the requirements of criteria 1-3 above. Each
of the 14 Generators have the potential to emit of regulated NSR
pollutants at the following annual major source threshold emissions
rates, based on an "Uncontrolled" scenario, and each generator is
therefore identified as a PSEU:

NOx = 112 ton/yr, (\> 100 tpy, criteria pollutant)

CO = 181 ton/yr, (\> 100 tpy, criteria pollutant)

Formaldehyde = 24 ton/yr, (\> 10 tpy, individual HAP)

The facility is subject to 40 CFR Part 64.5(b) and will be required to
submit a CAM Plan for each PSEU upon renewal of this initial Class I Air
Quality Operating Permit.

**4.3.5 ACID RAIN PROGRAM**

The Clean Air Act Amendments of 1990 (Title V) established a requirement
to reduce the emissions of pollutants contributing to acid rain (SO~2~
and NO~x~). The USEPA is responsible for developing regulations and
implementing the requirements of the acid rain provisions of the Clean
Air Act. Currently the acid rain program applies to units that generate
25.0 MW or greater *[each]{.underline}*. The proposed units at Barrick
are below this threshold, producing approximately 8.2 MW. Therefore the
Barrick facility will not be subject to the Acid Rain Program. This
determination was confirmed by US EPA Region 9 (Roger Kohn) via e-mail
on 7/1/04.

**4.3.6 ACCIDENTAL RELEASE PROGRAM**

The Chemical Accident Prevention Provisions are contained in 40 CFR,
Part 68. The Western 102 facility is required to comply with the
Chemical Accident Prevention Provisions, if the facility stores any
chemicals regulated by 40 CFR, Part 68, in quantities greater than their
respective threshold quantity. The applicant has stated that they will
not store urea/ammonia in quantity or concentration that makes them
applicable to Chemical Accident Prevention Provisions (draft comments
letter 7/27/04).

**4.3.7 PROTECTION OF STRATOSPHERIC OZONE**

The Protection of Stratospheric Ozone Provisions is contained in 40 CFR,
Part 82. The Western 102 Station is required to comply with 40 CFR, Part
82, if the facility operates any equipment or store any products
regulated by 40 CFR, Part 82. The permit application states that 40 CFR
Part 82 requirements are not applicable because the facility does not
service its own air conditioning equipment or store any regulated
products.

**4.3.8 EMERGENCY EPISODES PLAN**

NAC 445B.230.1 requires a plan for the reduction of emissions from any
facility that is able to cause or permit the emission of 100 tons or
more per year of a regulated pollutant from a stationary source. The
facility is required to prepare and submit to NDEP-BAPC a plan for
reducing or eliminating emissions in accordance with the episode stages
of alert, warning and emergency as defined in the air quality plan for
the State of Nevada.

On April 15, 2004 Barrick submitted an emergency episodes plan (EEP) for
the Western 102 facility as part of the original OPTC application.

**4.4 DUST CONTROL PLAN**

The NDEP-BAPC requires that permit holders who disturb 20 acres or more
of topsoil must submit a dust control plan as one of the necessary
measures to prevent particulate matter from becoming airborne (ASIP
445.734). The dust control plan is a written plan signed by a facility's
responsible official that outlines the methods a facility will use to
minimize fugitive dust. The Western 102 facility will not disturb more
than 20 acres.

**5.0 EMISSIONS INVENTORY**

**5.1 Emissions Inventory Summary**

The proceeding tables, Tables 5.1.1-5.1.5, are NDEP-BAPC calculations of
estimated emissions from the Barrick Class I permit application. A
comparison of Barrick calculations against NDEP-BAPC calculations
determined that there is little significant variance between the two
sets of calculations.

+----------+----+-----+-------+-----+---------+-------+-------+-----+
| Table    |    |     |       |     |         |       |       |     |
| 5.1.1    |    |     |       |     |         |       |       |     |
| below    |    |     |       |     |         |       |       |     |
| re       |    |     |       |     |         |       |       |     |
| presents |    |     |       |     |         |       |       |     |
| 30 cold  |    |     |       |     |         |       |       |     |
| catalyst |    |     |       |     |         |       |       |     |
| starts   |    |     |       |     |         |       |       |     |
| at 15    |    |     |       |     |         |       |       |     |
| minutes  |    |     |       |     |         |       |       |     |
| per      |    |     |       |     |         |       |       |     |
| start.   |    |     |       |     |         |       |       |     |
| This is  |    |     |       |     |         |       |       |     |
| 7.5      |    |     |       |     |         |       |       |     |
| hours of |    |     |       |     |         |       |       |     |
| the      |    |     |       |     |         |       |       |     |
| total    |    |     |       |     |         |       |       |     |
| 8,760    |    |     |       |     |         |       |       |     |
| annual   |    |     |       |     |         |       |       |     |
| o        |    |     |       |     |         |       |       |     |
| perating |    |     |       |     |         |       |       |     |
| hours    |    |     |       |     |         |       |       |     |
| per each |    |     |       |     |         |       |       |     |
| engine.  |    |     |       |     |         |       |       |     |
|          |    |     |       |     |         |       |       |     |
| ***Table |    |     |       |     |         |       |       |     |
| 5.1.1 -  |    |     |       |     |         |       |       |     |
| Cold     |    |     |       |     |         |       |       |     |
| Catalyst |    |     |       |     |         |       |       |     |
| Starts   |    |     |       |     |         |       |       |     |
| (partial |    |     |       |     |         |       |       |     |
| control  |    |     |       |     |         |       |       |     |
| reduc    |    |     |       |     |         |       |       |     |
| tion)*** |    |     |       |     |         |       |       |     |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| Po       | ** |     |       |     |         |       |       |     |
| llutants | Co |     |       |     |         |       |       |     |
|          | ld |     |       |     |         |       |       |     |
|          | Ca |     |       |     |         |       |       |     |
|          | ta |     |       |     |         |       |       |     |
|          | ly |     |       |     |         |       |       |     |
|          | st |     |       |     |         |       |       |     |
|          | St |     |       |     |         |       |       |     |
|          | ar |     |       |     |         |       |       |     |
|          | ts |     |       |     |         |       |       |     |
|          | ** |     |       |     |         |       |       |     |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
|          | \# | Op. | cold  | ste | lbs/hr  | tpy   | l     | tpy |
|          | of | Ho  | cat   | ady | cold    | (1    | bs/hr | (14 |
|          | st | urs | alyst | fac | +steady | en    | (14   | en  |
|          | ar |     | f     | tor | (1      | gine) | eng   | gin |
|          | ts |     | actor | (lb | engine) |       | ines) | es) |
|          | (y |     | (     | /45 |         |       |       |     |
|          | r) |     | lb/   | m   |         |       |       |     |
|          |    |     | 15min | in) |         |       |       |     |
|          |    |     | )     |     |         |       |       |     |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
|          |    |     |       |     |         |       |       |     |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| PM       | 30 | 7   | 0     | 1   | 2.59    | 0.04  | 36.22 | 0   |
|          |    | .50 | .6468 | .94 |         |       |       | .54 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| PM10     | 30 | 7   | 0     | 1   | 2.59    | 0.04  | 36.22 | 0   |
|          |    | .50 | .6468 | .94 |         |       |       | .54 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| CO       | 30 | 7   | 7     | 1   | 9.75    | 0.15  | 1     | 2   |
|          |    | .50 | .9400 | .81 |         |       | 36.55 | .05 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| NOX      | 30 | 7   | 4     | 1   | 5.96    | 0.09  | 83.50 | 1   |
|          |    | .50 | .8500 | .11 |         |       |       | .25 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| SO2      | 30 | 7   | 0     | 0   | 0.58    | 0.01  | 8.09  | 0   |
|          |    | .50 | .1444 | .43 |         |       |       | .12 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| VOC      | 30 | 7   | 2     | 1   | 4.46    | 0.07  | 62.49 | 0   |
|          |    | .50 | .6500 | .81 |         |       |       | .94 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| Total    | 30 | 7   | 1     | 0   | 1.95    | 0.03  | 27.30 | 0   |
| HAPs     |    | .50 | .6900 | .26 |         |       |       | .41 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+
| Form     | 30 | 7   | 1     | 0   | 1.43    | 0.02  | 20.02 | 0   |
| aldehyde |    | .50 | .3200 | .11 |         |       |       | .30 |
+----------+----+-----+-------+-----+---------+-------+-------+-----+

+---------+----+-----+-------+-----+----------+-------+-------+-----+
| Table   |    |     |       |     |          |       |       |     |
| 5.1.2   |    |     |       |     |          |       |       |     |
| below   |    |     |       |     |          |       |       |     |
| rep     |    |     |       |     |          |       |       |     |
| resents |    |     |       |     |          |       |       |     |
| 80 warm |    |     |       |     |          |       |       |     |
| c       |    |     |       |     |          |       |       |     |
| atalyst |    |     |       |     |          |       |       |     |
| starts  |    |     |       |     |          |       |       |     |
| at 15   |    |     |       |     |          |       |       |     |
| minutes |    |     |       |     |          |       |       |     |
| per     |    |     |       |     |          |       |       |     |
| start.  |    |     |       |     |          |       |       |     |
| This is |    |     |       |     |          |       |       |     |
| 20      |    |     |       |     |          |       |       |     |
| hours   |    |     |       |     |          |       |       |     |
| of the  |    |     |       |     |          |       |       |     |
| total   |    |     |       |     |          |       |       |     |
| 8,760   |    |     |       |     |          |       |       |     |
| annual  |    |     |       |     |          |       |       |     |
| op      |    |     |       |     |          |       |       |     |
| erating |    |     |       |     |          |       |       |     |
| hours   |    |     |       |     |          |       |       |     |
| per     |    |     |       |     |          |       |       |     |
| engine. |    |     |       |     |          |       |       |     |
|         |    |     |       |     |          |       |       |     |
| *       |    |     |       |     |          |       |       |     |
| **Table |    |     |       |     |          |       |       |     |
| 5.1.2 - |    |     |       |     |          |       |       |     |
| Warm    |    |     |       |     |          |       |       |     |
| C       |    |     |       |     |          |       |       |     |
| atalyst |    |     |       |     |          |       |       |     |
| Starts  |    |     |       |     |          |       |       |     |
| (       |    |     |       |     |          |       |       |     |
| partial |    |     |       |     |          |       |       |     |
| control |    |     |       |     |          |       |       |     |
| reduct  |    |     |       |     |          |       |       |     |
| ion)*** |    |     |       |     |          |       |       |     |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| Pol     | ** |     |       |     |          |       |       |     |
| lutants | Wa |     |       |     |          |       |       |     |
|         | rm |     |       |     |          |       |       |     |
|         | Ca |     |       |     |          |       |       |     |
|         | ta |     |       |     |          |       |       |     |
|         | ly |     |       |     |          |       |       |     |
|         | st |     |       |     |          |       |       |     |
|         | St |     |       |     |          |       |       |     |
|         | ar |     |       |     |          |       |       |     |
|         | ts |     |       |     |          |       |       |     |
|         | ** |     |       |     |          |       |       |     |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
|         | \# | Op. | warm  | ste | lbs/hr   | tpy   | l     | tpy |
|         | of | Ho  | cat   | ady | war      | (1    | bs/hr | (14 |
|         | st | urs | alyst | fac | m+steady | en    | (14   | en  |
|         | ar |     | f     | tor | (1       | gine) | eng   | gin |
|         | ts |     | actor | (lb | engine)  |       | ines) | es) |
|         | (y |     | (     | /45 |          |       |       |     |
|         | r) |     | lb/   | m   |          |       |       |     |
|         |    |     | 15min | in) |          |       |       |     |
|         |    |     | )     |     |          |       |       |     |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
|         |    |     |       |     |          |       |       |     |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| PM      | 80 | 20  | 0     | 1   | 2.59     | 0.10  | 36.22 | 1   |
|         |    | .00 | .6468 | .94 |          |       |       | .45 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| PM10    | 80 | 20  | 0     | 1   | 2.59     | 0.10  | 36.22 | 1   |
|         |    | .00 | .6468 | .94 |          |       |       | .45 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| CO      | 80 | 20  | 4     | 0   | 5.03     | 0.20  | 70.44 | 2   |
|         |    | .00 | .8500 | .18 |          |       |       | .82 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| NOX     | 80 | 20  | 3     | 0   | 3.20     | 0.13  | 44.82 | 1   |
|         |    | .00 | .0900 | .11 |          |       |       | .79 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| SO2     | 80 | 20  | 0     | 0   | 0.58     | 0.02  | 8.09  | 0   |
|         |    | .00 | .1444 | .43 |          |       |       | .32 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| VOC     | 80 | 20  | 1     | 0   | 1.94     | 0.08  | 27.18 | 1   |
|         |    | .00 | .7600 | .18 |          |       |       | .09 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| Total   | 80 | 20  | 1     | 0   | 1.28     | 0.05  | 17.86 | 0   |
| HAPs    |    | .00 | .2500 | .03 |          |       |       | .71 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+
| Forma   | 80 | 20  | 0     | 0   | 0.89     | 0.04  | 12.47 | 0   |
| ldehyde |    | .00 | .8800 | .01 |          |       |       | .50 |
+---------+----+-----+-------+-----+----------+-------+-------+-----+

+---------+----+--------+--------+----+------+------+-------+-----+
| > Table |    |        |        |    |      |      |       |     |
| > 5.1.3 |    |        |        |    |      |      |       |     |
| > below |    |        |        |    |      |      |       |     |
| > rep   |    |        |        |    |      |      |       |     |
| resents |    |        |        |    |      |      |       |     |
| > all   |    |        |        |    |      |      |       |     |
| > of    |    |        |        |    |      |      |       |     |
| > the   |    |        |        |    |      |      |       |     |
| > stead |    |        |        |    |      |      |       |     |
| y-state |    |        |        |    |      |      |       |     |
| > op    |    |        |        |    |      |      |       |     |
| eration |    |        |        |    |      |      |       |     |
| >       |    |        |        |    |      |      |       |     |
|  hours. |    |        |        |    |      |      |       |     |
| > Subt  |    |        |        |    |      |      |       |     |
| racting |    |        |        |    |      |      |       |     |
| > the   |    |        |        |    |      |      |       |     |
| > cold  |    |        |        |    |      |      |       |     |
| > and   |    |        |        |    |      |      |       |     |
| > warm  |    |        |        |    |      |      |       |     |
| > c     |    |        |        |    |      |      |       |     |
| atalyst |    |        |        |    |      |      |       |     |
| >       |    |        |        |    |      |      |       |     |
|  starts |    |        |        |    |      |      |       |     |
| > this  |    |        |        |    |      |      |       |     |
| > is    |    |        |        |    |      |      |       |     |
| >       |    |        |        |    |      |      |       |     |
| 8,732.5 |    |        |        |    |      |      |       |     |
| > stead |    |        |        |    |      |      |       |     |
| y-state |    |        |        |    |      |      |       |     |
| > op    |    |        |        |    |      |      |       |     |
| erating |    |        |        |    |      |      |       |     |
| > hours |    |        |        |    |      |      |       |     |
| > per   |    |        |        |    |      |      |       |     |
| > year. |    |        |        |    |      |      |       |     |
|         |    |        |        |    |      |      |       |     |
| *       |    |        |        |    |      |      |       |     |
| **Table |    |        |        |    |      |      |       |     |
| 5.1.3 - |    |        |        |    |      |      |       |     |
| Steady  |    |        |        |    |      |      |       |     |
| State   |    |        |        |    |      |      |       |     |
| Ope     |    |        |        |    |      |      |       |     |
| rations |    |        |        |    |      |      |       |     |
| (full   |    |        |        |    |      |      |       |     |
| control |    |        |        |    |      |      |       |     |
| reduct  |    |        |        |    |      |      |       |     |
| ion)*** |    |        |        |    |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| Pol     | ** |        |        |    |      |      |       |     |
| lutants | St |        |        |    |      |      |       |     |
|         | ea |        |        |    |      |      |       |     |
|         | dy |        |        |    |      |      |       |     |
|         | S  |        |        |    |      |      |       |     |
|         | ta |        |        |    |      |      |       |     |
|         | te |        |        |    |      |      |       |     |
|         | O  |        |        |    |      |      |       |     |
|         | pe |        |        |    |      |      |       |     |
|         | ra |        |        |    |      |      |       |     |
|         | ti |        |        |    |      |      |       |     |
|         | on |        |        |    |      |      |       |     |
|         | ** |        |        |    |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
|         | \# | Op.    | factor | M  | lb   | tpy  | l     | tpy |
|         | of | Hours  | (lb/   | MB | s/hr | (1   | bs/hr | (14 |
|         | st |        | MMBtu) | tu | (1   | eng  | (14   | en  |
|         | ar |        |        |    | eng  | ine) | eng   | gin |
|         | ts |        |        |    | ine) |      | ines) | es) |
|         | (y |        |        |    |      |      |       |     |
|         | r) |        |        |    |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
|         |    |        |        |    |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| PM      | 0  | 8,     | 0.0336 | 7  | 2.59 | 1    | 36.22 | 158 |
|         |    | 732.50 |        | 7. |      | 1.30 |       | .15 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| PM10    | 0  | 8,     | 0.0336 | 7  | 2.59 | 1    | 36.22 | 158 |
|         |    | 732.50 |        | 7. |      | 1.30 |       | .15 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| CO      | 0  | 8,     | 0.0314 | 7  | 2.42 | 1    | 33.85 | 147 |
|         |    | 732.50 |        | 7. |      | 0.56 |       | .79 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| NOX     | 0  | 8,     | 0.0193 | 7  | 1.49 | 6.49 | 20.81 | 90  |
|         |    | 732.50 |        | 7. |      |      |       | .84 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| SO2     | 0  | 8,     | 0.0075 | 7  | 0.58 | 2.52 | 8.09  | 35  |
|         |    | 732.50 |        | 7. |      |      |       | .30 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| VOC     | 0  | 8,     | 0.0314 | 7  | 2.42 | 1    | 33.85 | 147 |
|         |    | 732.50 |        | 7. |      | 0.56 |       | .79 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| Total   | 0  | 8,     | 0.0045 | 7  | 0.35 | 1.51 | 4.85  | 21  |
| HAPs    |    | 732.50 |        | 7. |      |      |       | .18 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+
| Forma   | 0  | 8,     | 0.0019 | 7  | 0.15 | 0.64 | 2.05  | 8   |
| ldehyde |    | 732.50 |        | 7. |      |      |       | .94 |
|         |    |        |        | 00 |      |      |       |     |
+---------+----+--------+--------+----+------+------+-------+-----+

Table 5.1.4 below shows the total of cold catalyst starts, warm catalyst
starts and steady state operations combined to represent the total
potential operations for 1 year.

***Table 5.1.4 - Total Emissions for all 14 Engines Including Cold &
Warm Catalyst Starts***

  ----------------------- ----------------------- -----------------------
  **Pollutants**          **Totals for All 14     
                          Engines**               

                                                  

                          **lbs/hr**              **tpy**

  PM                      108.66                  160.14

  PM10                    108.66                  160.14

  CO                      240.83                  152.66

  NOX                     149.13                  93.89

  SO2                     24.26                   35.75

  VOC                     123.51                  149.82

  Total HAPs              50.01                   22.30

  Formaldehyde            34.54                   9.94
  ----------------------- ----------------------- -----------------------

Table 5.1.5 below exhibits the facility-wide total for all operations
including non-permit items. There are 3 non-permit items: 1) emergency
generator, 1) emergency fire pump and 1) facility HVAC heater.

***Table 5.1.5 - Facility-Wide Total - Requested Emission Cap***

+-----------------------------+----------------------------------------+
| **Pollutants**              |                                        |
+-----------------------------+----------------------------------------+
|                             |                                        |
+-----------------------------+----------------------------------------+
|                             | **Annual Emissions**                   |
|                             |                                        |
|                             | **tpy**                                |
+-----------------------------+----------------------------------------+
| PM                          | 158.76                                 |
+-----------------------------+----------------------------------------+
| PM10                        | 158.76                                 |
+-----------------------------+----------------------------------------+
| CO                          | 152.32                                 |
+-----------------------------+----------------------------------------+
| NOX                         | 93.80                                  |
+-----------------------------+----------------------------------------+
| SO2                         | 35.56                                  |
+-----------------------------+----------------------------------------+
| VOC                         | 149.52                                 |
+-----------------------------+----------------------------------------+
| Total HAPs                  | \< 25.0                                |
+-----------------------------+----------------------------------------+
| Formaldehyde                | \< 10.0                                |
+-----------------------------+----------------------------------------+

**5.2 Emissions Inventory: Formaldehyde Discussion**

[]{.mark}

The applicant provided a facility-wide PTE for formaldehyde of 9.94 tons
per year. This value is so close to the major source threshold of 10.0
tons per year for any individual HAP that it bears investigation. The
9.94 ton/year value was created with a Wartsila factor that was
generated from stack testing of similar units currently in operation.

Table 5.2.1 below demonstrates the AP-42 formaldehyde calculation based
on MMBtu/hr. The final value, **[with the Wartsila guaranteed 97%
control]{.underline}**, yields 7.48 tpy; a value much lower than the
applicants requested 9.94 tpy. Wartsila has stated that stack tests
typically yield formaldehyde values much lower than the manufacturer's
guarantee. This sentiment was echoed by the Arvada, Colorado Wartsila
facility that achieved performance test values notably lower than the
manufacturer's guarantee.

Table 5.2.1

+-----------------------------------------------------------------------+
| # AP-42 Factor Calculations                                           |
|                                                                       |
| Formaldehyde emission calculations for a Warstila engine using AP-42  |
| factors:                                                              |
|                                                                       |
| 0.0528 lb/MMBtu is the emission factor value used in AP-42.           |
|                                                                       |
| 77 MMBtu/hr \* 0.0528 lb/MMBtu = 4.07 lbs/hr.                         |
|                                                                       |
| 4.07 lbs/hr \* 8,760 hours = 35,614.66 lbs/yr = **[17.8 TPY]{.mark}** |
|                                                                       |
| 14 engines \* 17.8 TPY = **[249.3 TPY]{.mark}**                       |
|                                                                       |
| 249.3 tpy \* 97% control reduction = **[7.48 TPY]{.mark}**            |
+-----------------------------------------------------------------------+

Table 5.2.2 and Table 5.2.3 below demonstrate calculations using the
Wartsila-provided emission factors. These factors were provided in two
forms: as a kWh-based uncontrolled factor and a kWh-based controlled
factor. Assumably the control factor is based on the controlled factor
with the addition of the 97% reduction rate. The two factors appear to
be different, yielding values of 10.8 vs. 9.5 tpy, respectively. This is
a fairly substantial difference, but it appears that the application
requested value of 9.94 tpy is in the center of the value range.

Table 5.2.2

+-----------------------------------------------------------------------+
| # Wartsila Factor Calculations                                        |
|                                                                       |
| 0.307 g/kWh is the Warstila [uncontrolled]{.underline} factor, then   |
| the guaranteed 97% reduction is applied:                              |
|                                                                       |
| KWh = 8,700                                                           |
|                                                                       |
| 0.307 \* 8,700 = 2670.9 g/hr = 5.88832 lbs/hr                         |
|                                                                       |
| 5.88832 lbs \* 8,760 hr = 5181.6832 lbs/yr = 25.791 TPY               |
|                                                                       |
| 25.791 TPY \* 14 engines = 361.074 TPY                                |
|                                                                       |
| 361.074 TPY \* 97% reduction = **[10.832 TPY]{.mark}**                |
+-----------------------------------------------------------------------+

Table 5.2.3

+-----------------------------------------------------------------------+
| Wartsila Factor Calculations                                          |
|                                                                       |
| 0.008 g/kWH is the Wartsila [controlled]{.underline} factor (should   |
| incorporate 97% catalyst reduction):                                  |
|                                                                       |
| KWh = 8,700                                                           |
|                                                                       |
| 0.008 \* 8,700 = 70.08 g/hr = 0.1544998 lb/hr                         |
|                                                                       |
| 0.1544998 lb \* 8,760 hr = 1,353.418 = 0.677 TPY                      |
|                                                                       |
| 0.677 TPY \* 14 engines = **[9.478 TPY]{.mark}**                      |
+-----------------------------------------------------------------------+

**5.2 Emissions Inventory: Formaldehyde Discussion** (Continued)

Table 5.2.4 below provides a third party estimation of potential
formaldehyde emissions. Similar to the AP-42 emissions factor, the APT
factor estimates 7.7 TPY for formaldehyde with the 97% manufacturer's
reduction control. Of note, the APT group found that the typical
oxidation catalyst control yielded an 86.3% reduction; notable lower
than Wartsila's guaranteed 97%. Applying the observed APT control
efficiency of 86.3% yields a much higher facility PTE value of 35.14
TPY; much higher than the 10 TPY major source threshold.

Table 5.2.4

+-----------------------------------------------------------------------+
| # [APT Formaldehyde Factor Calculations]{.underline}                  |
|                                                                       |
| A third party, APT, derived a formaldehyde factor similar to AP-42    |
| for LB RICE with value of: 0.0543 lb/MMBtu. APT test data             |
| demonstrated an 86.3% reduction for LB RICEs (across 31 tests) with   |
| an oxidation catalyst.                                                |
|                                                                       |
| 0.0543 lb/MMBtu/hr \* 77.0 MMBtu = 4.1811 lbs/hr                      |
|                                                                       |
| 4.811 lbs/hr \* 8,760 hr = 36,626.44 lbs/yr = **[18.31 TPY]{.mark}**  |
| \* 14 engines = 256.3 TPY                                             |
|                                                                       |
| 18.31 TPY \* 97% reduction = 0.55                                     |
|                                                                       |
| 0.55 TPY \* 14 engines = **[7.7 TPY]{.mark}**                         |
|                                                                       |
| 18.31 TPY \* 86.3% reduction = 2.51 TPY                               |
|                                                                       |
| 2.51 TPY \* 14 engines = **[35.14 TPY]{.mark}**                       |
+-----------------------------------------------------------------------+

These calculations exemplify the importance and sensitivity of the
emission factor for facility formaldehyde PTE estimates.

To further investigate the relationship between PTE and control
reduction rates, calculations were performed to determine what amount of
emission reductions would be needed for formaldehyde to be less than 10
TPY using various available published emission factors. As displayed in
Table 5.2.5 below, the required emissions reduction ranges from 95.9% to
97.3% based on the available AP-42, Wartsila and APT uncontrolled
factors.

Table 5.2.5

+------------------------+-----------------------+---------------------+
| REQUIRED CONTROL       | REQUIRED CONTROL      | REQUIRED CONTROL    |
| EFFICIENCY TO MEET 10  | EFFICIENCY TO MEET 10 | EFFICIENCY TO MEET  |
| TPY USING              | TPY USING             | 10 TPY USING        |
| [AP-42]{.underline}    | [                     | [APT]{.underline}   |
| FACTORS:               | WARTSILA]{.underline} | FACTORS:            |
|                        | FACTORS:              |                     |
| 249.3 - (249.3r) = 10  |                       | 256.3 -- (256.3r) = |
|                        | 361.1 -- (361.1r) =   | 10                  |
| r = **[95.9%]{.mark}** | 10                    |                     |
|                        |                       | r =                 |
|                        | r =                   | **[96.1%]{.mark}**  |
|                        | **[97.3%]{.mark}**    |                     |
+------------------------+-----------------------+---------------------+

These brief calculations demonstrate that the Wartsila manufacturer's
guarantee of 97% formaldehyde reduction is quite high; definitely above
average. It may be argued that the rather sophisticated computer engine
management system, pre-mix combustion chamber and other design variables
assist the catalyst for above-average formaldehyde reduction. This has
been confirmed by an existing Wartsila facility in Arvada, Colorado.

**5.2 Emissions Inventory: Formaldehyde Discussion** (Continued)

The NDEP-BAPC had some general discussion with Barrick and Wartsila
regarding concerns of formaldehyde emissions. Wartsila stated that
typically stack tests for formaldehyde on their engines yield emissions
50-66% lower than the manufacturer\'s provided guarantee, thus providing
a safety buffer. Barrick states that their submitted formaldehyde PTE
rate of 9.94 tons/year is very conservative and therefore is not likely
to exceed the 10-ton/year threshold that would trigger the facility as a
major source for HAPs. These estimates shall be easily verified by the
required periodic performance testing in the Operating Permit that
requires each engine to be tested for formaldehyde emissions on an
annual basis. These empirical tests will provide a more definitive
emission factor specific to the engines and their operating conditions.

**6.0 AMBIENT AIR IMPACT**

The purpose of the ambient air quality analyses is to demonstrate that
the emissions from the project will not cause or contribute to a
violation of any applicable federal or state ambient air quality
standards.

+----------------------------------------+-----------------------------+
| **6.1 CLASSIFICATION OF AIR BASIN**    | ![](media/image6.jpeg){w    |
|                                        | idth="2.5701388888888888in" |
| Barrick Western 102 facility is        | hei                         |
| located in the (*Tracy Segment of the  | ght="3.7243055555555555in"} |
| Truckee River Basin)*, Air Quality     |                             |
| Hydrographic Basin HA83. Basin HA83    |                             |
| has been triggered for PSD increment   |                             |
| consumption. Basin 83 was first        |                             |
| triggered (i.e., Minor Source Baseline |                             |
| Date) by the Sierra Pacific Power      |                             |
| Company, Tracy Generating Station      |                             |
| Pinion Pine Power Generating Project   |                             |
| March 11, 1994. The basin is triggered |                             |
| for PM~10~, NO~x~ and SO~2~.           |                             |
|                                        |                             |
| The purpose of the air quality         |                             |
| analyses is to demonstrate that the    |                             |
| emissions from the process will not    |                             |
| cause or contribute to a violation of  |                             |
| any applicable federal or state        |                             |
| ambient air quality standards.         |                             |
|                                        |                             |
| For this facility's OPTC rollover to   |                             |
| Class I, two ambient air impact        |                             |
| studies were required: one to          |                             |
| demonstrate compliance with the Nevada |                             |
| Ambient Air Quality Standards (NAAQS), |                             |
| and one to demonstrate compliance with |                             |
| the allowable PSD increment            |                             |
| consumption.                           |                             |
+----------------------------------------+-----------------------------+
|                                        | > *Location of Basin 83,    |
|                                        | > located primarily in      |
|                                        | > Storey County with a      |
|                                        | > small portion of the      |
|                                        | > basin located in Washoe   |
|                                        | > County.*                  |
+----------------------------------------+-----------------------------+

### 

### **6.2 METHOD OF NAAQS AIR QUALITY MODELING ANALYSIS**

The EPA approved model AERMOD was used to determine the air quality
impacts in order to demonstrate no exceedance of the NAAQS. The NAAQS
modeling was performed using a 30m USGS DEM terrain sample and four
years of on-site hourly meteorological data collected near the Tracy
Power Plant and provided by the BAPC. Receptors were placed from the
center of the facility at 25m intervals within the property boundary,
and then at 50m intervals for 125 meters and then at 100m intervals for
250 meters. Models were run for PM~10~, NO~x~, SO~2~ and CO for all
averaging periods. The Scheffe model was used to model ozone generation.

+--------------------------------+-------------------------------------+
| **6.3 METHOD OF PSD INCREMENT  |                                     |
| MODELING ANALYSIS**            |                                     |
+--------------------------------+-------------------------------------+
| The increment modeling was     | > *Model view of engine building,   |
| generated using the model      | > property fence, engine exhaust    |
| AERMOD and the Increment       | > stacks and receptor grid. Engine  |
| Tracking System (ITS). The ITS | > building located in center of     |
| is a modeling tool developed   | > property fence. Engine exhaust    |
| by the NDEP-BAQP/BAPC to model | > stacks on the right side of the   |
| increment availability across  | > engine building*                  |
| an entire air management       |                                     |
| basin. ITS utilizes the same   |                                     |
| source input file as the NAAQS |                                     |
| AERMOD modeling, but employs a |                                     |
| wider scale terrain and        |                                     |
| meteorological data with more  |                                     |
| receptors. The ITS is able to  |                                     |
| overlay the modeling results   |                                     |
| from each facility in an Air   |                                     |
| Management Basin to determine  |                                     |
| the amount of increment        |                                     |
| available.                     |                                     |
|                                |                                     |
| It has been indicated by the   |                                     |
| NDEP-BAQP that both the NAAQS  |                                     |
| and PSD increment models must  |                                     |
| be run because the interaction |                                     |
| of all the model variables are |                                     |
| too complex to guess.          |                                     |
| Acceptable results in one      |                                     |
| model are not necessarily      |                                     |
| indicative of acceptable       |                                     |
| results in the other. The BAPC |                                     |
| engineer Greg Remer performed  |                                     |
| the increment analysis and     |                                     |
| summary report.                |                                     |
+--------------------------------+-------------------------------------+
|                                | ![](media/image                     |
|                                | 7.png){width="3.6770833333333335in" |
|                                | height="3.404861111111111in"}       |
+--------------------------------+-------------------------------------+
|                                | > *Model illustration (at scale) of |
|                                | > engine building and engine        |
|                                | > exhaust stack clusters.*          |
+--------------------------------+-------------------------------------+
|                                | ![](media/image                     |
|                                | 8.png){width="3.6798611111111112in" |
|                                | height="3.1569444444444446in"}      |
+--------------------------------+-------------------------------------+

4.  **NAAQS MODEL RESULTS**

***Table 6.4.1 -- Barrick NAAQS Model Results***

  --------------- ------------- ------------- ------------------------ --------------
  **Pollutant**   **Averaging   **NAAQS       **Background^\*^ +       **% of NAAQS
                  Period**      Standard      modeled = Total          Standard**
                                (μg/m^3^)**   (μg/m^3^)**              

  **PM~10~**      24-hr         150.0         32.0 + 13.4 = **45.4**   30.3

                  Annual        50.0          32.0 + 2.0 = **34.0**    68.0

  **CO**          1-hr          40,500.0      6,634.2 + 1,184.8        22.3
                                              =**7,819.0**             

                  8-hr (\<5,000 10,500.0      4,597.4 + 214.0 =        45.8
                  ft ASL                      **4,811.4**              
                  elevation)                                           

  **NO~x~**       Annual        100.0         57.4 + 1.1 = **58.5**    58.5

  **SO~2~**       3-hr          1,300.0       0 + 18.9 = **18.9**      1.5

                  24-hr         365.0         0 + 4.1 = **4.1**        1.1

                  Annual        80.0          0 + 0.5 = **0.5**        0.6

  **Ozone**       1-hr          235.0         179.6 + 29.5 = **209.1** 88.9
  --------------- ------------- ------------- ------------------------ --------------

**^\*^** Background concentrations measured at the Reno, Nevada
monitoring station, located approximately 16 miles west of the Western
102 Project for the years 2000 & 2001. Station ID = 32-031-0016
NAMS/SLAMS/SPMS

5.  **WIND ROSE/SURROUNDING TERRAIN**

+------------------------------------+---------------------------------+
| ![](media/image                    | ![](media/image10.pn            |
| 9.png){width="3.407638888888889in" | g){width="3.0055555555555555in" |
| height="2.807638888888889in"}      | height="2.8402777777777777in"}  |
+------------------------------------+---------------------------------+
| *Wind rose diagram displaying the  | > *Terrain surrounding the      |
| magnitude and direction of wind.   | > proposed Barrick facility     |
| Orientation is "direction blowing  | > that affects modeling.        |
| from."*                            | > Facility is the square in the |
|                                    | > center of the image.*         |
+------------------------------------+---------------------------------+

**6.6 INCREMENT TRACKING MODEL RESULTS**

Increment was analyzed on a paired-in-time basis at each receptor in the
HA83 study receptor grid. Increment impacts were evaluated for PM~10~
and NO~2~ only. SO~2~ was not analyzed, since a paired-in-time
re-analysis of the increment impacts for HA 83 has not yet been
completed. Based on the modeling information provided, Barrick's 102
Power project OPTC rollover to Class I will not contribute to or cause
an exceedance of the NO~x~ increment standard. Likewise, the project did
not cause an exceedance of the PM~10~ 24-hour increment standard.
However, the original increment study identified 9 existing receptors
that previously indicated an exceedance of the PM~10~ 24-hour increment
standard. The following tables present a summary of the results of the
analysis for Barrick and indicate the top 3 Barrick contributions to
these receptors that indicate existing PM~10~ exeedances.

+------+-------+-----+----------+--------+---------+--------+--------+
| PM   |       |     |          |        |         |        |        |
| ~10~ |       |     |          |        |         |        |        |
| Res  |       |     |          |        |         |        |        |
| ults |       |     |          |        |         |        |        |
|      |       |     |          |        |         |        |        |
| C    |       |     |          |        |         |        |        |
| lass |       |     |          |        |         |        |        |
| 2    |       |     |          |        |         |        |        |
| I    |       |     |          |        |         |        |        |
| ncre |       |     |          |        |         |        |        |
| ment |       |     |          |        |         |        |        |
| Stan |       |     |          |        |         |        |        |
| dard |       |     |          |        |         |        |        |
| = 30 |       |     |          |        |         |        |        |
| µg/  |       |     |          |        |         |        |        |
| m^3^ |       |     |          |        |         |        |        |
| (24- |       |     |          |        |         |        |        |
| hour |       |     |          |        |         |        |        |
| a    |       |     |          |        |         |        |        |
| vera |       |     |          |        |         |        |        |
| ging |       |     |          |        |         |        |        |
| per  |       |     |          |        |         |        |        |
| iod) |       |     |          |        |         |        |        |
|      |       |     |          |        |         |        |        |
| C    |       |     |          |        |         |        |        |
| lass |       |     |          |        |         |        |        |
| 2    |       |     |          |        |         |        |        |
| I    |       |     |          |        |         |        |        |
| ncre |       |     |          |        |         |        |        |
| ment |       |     |          |        |         |        |        |
| Stan |       |     |          |        |         |        |        |
| dard |       |     |          |        |         |        |        |
| = 17 |       |     |          |        |         |        |        |
| µg/  |       |     |          |        |         |        |        |
| m^3^ |       |     |          |        |         |        |        |
| (an  |       |     |          |        |         |        |        |
| nual |       |     |          |        |         |        |        |
| a    |       |     |          |        |         |        |        |
| vera |       |     |          |        |         |        |        |
| ging |       |     |          |        |         |        |        |
| per  |       |     |          |        |         |        |        |
| iod) |       |     |          |        |         |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
| Met  | Avg.  | Inc |          |        |         | B      | Max.   |
| Year | P     | rem |          |        |         | arrick | B      |
|      | eriod | ent |          |        |         | C      | arrick |
|      |       | Rec |          |        |         | ontrib |        |
|      |       | ept |          |        |         |        | Conc.  |
|      |       | ors |          |        |         |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | Rec | X Coord  | Y      | Total   |        |        |
|      |       | No  |          | Coord  | Conc.   |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
| 2000 | 24    | 1   | 275000   | 4      | 9       | 0      | \--    |
|      |       | 035 |          | 373000 | 9.71429 | .00012 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 302500   | 4      | 6       | 0      | \--    |
|      |       | 922 |          | 388500 | 3.25147 | .83405 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 303500   | 4      | 5       | 0.0788 | \--    |
|      |       | 984 |          | 389000 | 2.89966 |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 303000   | 4      | 4       | 0      | \--    |
|      |       | 983 |          | 389000 | 3.87201 | .57946 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 1   | 275500   | 4      | 4       | 0      | \--    |
|      |       | 036 |          | 373000 | 1.90667 | .00017 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 287000   | 4      | 3       | 0      | \--    |
|      |       | 119 |          | 382000 | 9.97998 | .21441 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 1   | 274500   | 4      | 3       | 0      | \--    |
|      |       | 034 |          | 373000 | 7.46125 | .07686 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 302500   | 4      | 35.9462 | 0      | \--    |
|      |       | 982 |          | 389000 |         | .82111 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 3   | 303000   | 4      | 3       | 0      | \--    |
|      |       | 044 |          | 389500 | 2.97115 |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 3   | 28       | 4      | -       | 1      | 1      |
|      |       | 836 | 4749.906 | 382000 | 0.89012 | 0.0879 | 0.0879 |
+------+-------+-----+----------+--------+---------+--------+--------+
|      | A     | 1   | 275000   | 4      | 3.44537 | 0      | \--    |
|      | nnual | 035 |          | 373000 |         | .03488 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 3   | 28       | 4      | -34     | 1      | 1      |
|      |       | 848 | 4999.906 | 382250 | 6.30447 | .89301 | .89301 |
+------+-------+-----+----------+--------+---------+--------+--------+
| 2001 | 24    | 1   | 275000   | 4      | 18      | 0      | \--    |
|      |       | 035 |          | 373000 | 9.09564 | .00924 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 1   | 274500   | 4      | 59.8154 | 0      | \--    |
|      |       | 034 |          | 373000 |         | .01439 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 1   | 275500   | 4      | 4       | 0      | \--    |
|      |       | 036 |          | 373000 | 9.66788 |        |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 302500   | 4      | 3       | 0      | \--    |
|      |       | 922 |          | 388500 | 0.35289 | .16571 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 3   | 28       | 4      | -       | 8      | 8      |
|      |       | 453 | 3899.906 | 382000 | 15.9363 | .18919 | .18919 |
+------+-------+-----+----------+--------+---------+--------+--------+
|      | A     | 1   | 275000   | 4      | 8.31272 | 0      | \--    |
|      | nnual | 035 |          | 373000 |         | .03277 |        |
+------+-------+-----+----------+--------+---------+--------+--------+
|      |       | 2   | 287000   | 4      | -3      | 1      | 1      |
|      |       | 119 |          | 382000 | 26.5257 | .83068 | .83068 |
+------+-------+-----+----------+--------+---------+--------+--------+

>  
>
>  

+------+-------+-----+----------+--------+--------+--------+--------+
| N    |       |     |          |        |        |        |        |
| O~2~ |       |     |          |        |        |        |        |
| Res  |       |     |          |        |        |        |        |
| ults |       |     |          |        |        |        |        |
|      |       |     |          |        |        |        |        |
| C    |       |     |          |        |        |        |        |
| lass |       |     |          |        |        |        |        |
| 2    |       |     |          |        |        |        |        |
| I    |       |     |          |        |        |        |        |
| ncre |       |     |          |        |        |        |        |
| ment |       |     |          |        |        |        |        |
| Stan |       |     |          |        |        |        |        |
| dard |       |     |          |        |        |        |        |
| = 25 |       |     |          |        |        |        |        |
| µg/  |       |     |          |        |        |        |        |
| m^3^ |       |     |          |        |        |        |        |
| (an  |       |     |          |        |        |        |        |
| nual |       |     |          |        |        |        |        |
| a    |       |     |          |        |        |        |        |
| vera |       |     |          |        |        |        |        |
| ging |       |     |          |        |        |        |        |
| per  |       |     |          |        |        |        |        |
| iod) |       |     |          |        |        |        |        |
+------+-------+-----+----------+--------+--------+--------+--------+
| Met  | Avg.  | Inc |          |        |        | B      | Max.   |
| Year | P     | rem |          |        |        | arrick | B      |
|      | eriod | ent |          |        |        | C      | arrick |
|      |       | Rec |          |        |        | ontrib |        |
|      |       | ept |          |        |        |        | Conc.  |
|      |       | ors |          |        |        |        |        |
+------+-------+-----+----------+--------+--------+--------+--------+
|      |       | Rec | X Coord  | Y      | Total  |        |        |
|      |       | No  |          | Coord  | Conc.  |        |        |
+------+-------+-----+----------+--------+--------+--------+--------+
| 2000 | A     | 1   | 272500   | 4      | 29     | 0      | \--    |
|      | nnual | 640 |          | 378000 | .42385 | .01744 |        |
+------+-------+-----+----------+--------+--------+--------+--------+
|      |       | 3   | 28       | 4      | 19     | 1      | 1      |
|      |       | 848 | 4999.906 | 382250 | .12705 | .15209 | .15209 |
+------+-------+-----+----------+--------+--------+--------+--------+
| 2001 | A     | 1   | 272500   | 4      | 2      | 0      | \--    |
|      | nnual | 640 |          | 378000 | 6.0893 | .01721 |        |
+------+-------+-----+----------+--------+--------+--------+--------+
|      |       | 3   | 28       | 4      | 18     | 1.1121 | 1.1121 |
|      |       | 848 | 4999.906 | 382250 | .03848 |        |        |
+------+-------+-----+----------+--------+--------+--------+--------+

>  
>
>  

As can be seen in the preceding table, the top three contributions to
existing PM~10~ exceeding receptors (#2922, 2984 and 2982) all occur
using the 2000 meteorology. However, upon further analysis of the impact
contributions, the exceedances at these three receptors are due to the
influences of area sources. In fact the area contributions result in
more than 100% of the total increment impact at the three receptors. The
lower total increment concentration is the result of point sources
actually expanding increment at these receptors. NDEP-BAPC is concerned
that the area source inventory methods used in the increment study do
not correctly allocate emissions spatially. As a result, it is possible
that the increment results due to the area inventory influences are not
spatially correct. In addition, there is also concern that the model
software does not treat fugitive area sources accurately. These issues
were discussed in the Bureau's Air Quality Monitoring Report for the
Assessment of PSD Increment in the Fernley Area and Truckee River
Corridor. The study report discussed various methods for adjusting the
concentrations. The NDEP-BAPC has not yet chosen a methodology. The
fugitive inventory methods and model treatment are also being discussed
national forums and their resolution will impact Nevada. Although the
increment contribution from the area source inventory is the cause of
the exceedances at the receptors of concern, NDEP-BAPC does not believe
that adequate information exists to reliably determine that the
operation of the Western 102 power project will significantly impact
receptors that exceed the increment standard, at this time.

 

**8.0 CONCLUSIONS**

The Wartsila engine systems are a new process type of combustion engines
for the State of Nevada. The NDEP-BAPC has not previously permitted a
Wartsila engine with the Ultra-low Emissions system. While internal
combustion engines are not in themselves a new technology, the
sophisticated computer management systems and high efficiency exhaust
controls exceed any other engine system performance documented in
available literature. Calculations performed in Section 5 above,
demonstrate the sensitive relationship of control efficiency to facility
potential to emit and highlight the very high control efficiencies
required for the proposed Barrick facility to avoid major stationary
source classification.

Realizing that the facility did not have CEMs or COMs, the NDEP-BAPC was
concerned with how the facility would know if a control efficiency was
deteriorating. Even a slight drop in efficiency could have a significant
impact on facility emissions.

To remedy these concerns, the Operating Permit includes 4 components to
help provide assurance:

1\. Annual performance source testing of each engine. This testing will
verify the manufacturer's emission estimations.

2\. The Operating Permit requires Barrick to check each engines system
console daily for maintenance messages and to schedule any required
repairs. If the engines remain in proper repair they should not have any
unexpected emission increases.

3\. The Operating Permit requires an alarm to be configured into the
control system computers to alert an attendant if emission control
parameters are out of specification, and to initiate an automatic
shutdown within 1 hour if not remedied. This prevents a malfunctioning
control from going unnoticed.

4\. Long-term engine re-testing. The subsequent operating permit will
include re-testing of the engines to verify that they remain operating
within permitted limits.

**9.0 RECOMMENDATIONS**

Based on the above review and supporting data and analyses, the Barrick
OPTC rollover to Class I Air Quality Operating Permit will not result in
an exceedence of any applicable ambient air quality standards. As a
result, I recommend that the conditions specified in the Class I
facility-wide Air Quality Operating Permit be issued with all
appropriate restrictions.

######## 

> Rod Moore Date

Permitting Branch

> Matthew DeBurle Date

Supervisor, Class I Permitting

Attachment (1) Facility and Vicinity Map

Attachment (2) Emission Inventory Calculations

Attachment (3) Dispersion Modeling Results

Attachment (4) Proposed Operating Permit

####### Attachment 1

Facility and Vicinity Map

**Attachment 2**

Emissions Inventory Calculations

**Attachment 3**

Dispersion Modeling Results

**Attachment 4**

Proposed Operating Permit

**Summary of Subpart ZZZZ RICE MACT**

Table 2A - Required Emission Limitations:

+-----------------------------------------------------------------------+
| 2\. 4SLB stationary RICE                                              |
|                                                                       |
| a\. Reduce CO emissions by 93 percent or more; or                     |
|                                                                       |
| b\. Limit concentration of formaldehyde in the stationary RICE        |
| exhaust to 14 ppmvd or less at 15 percent O2.                         |
+-----------------------------------------------------------------------+

Table 2B -- Operational Limits

+-----------------------------------------------------------------------+
| 1\. 2SLB and 4SLB stationary RICE and CI stationary RICE requirement  |
| to reduce CO emissions and using an oxidation catalyst; or 2SLB and   |
| 4SLB stationary RICE and CI stationary RICE complying with the        |
| requirement to limit the concentration of formaldehyde in the         |
| stationary RICE exhaust and using an oxidation catalyst.              |
|                                                                       |
| a\. Maintain your catalyst so that the pressure drop across the       |
| catalyst does not change by more than two inches of water at 100      |
| percent load plus or minus 10 percent from the pressure drop across   |
| the catalyst that was measured during the initial performance test;   |
| and                                                                   |
|                                                                       |
| b\. Maintain the temperature of your stationary RICE exhaust so that  |
| the catalyst inlet temperature is greater than or equal to            |
| 450\[deg\]F and less than or equal to 1350\[deg\]F.                   |
+-----------------------------------------------------------------------+

Table 3 -- Performance Tests

+-----------------------------------------------------------------------+
| 2SLB and 4SLB stationary RICE and CI stationary RICEs reducing CO     |
| emissions and not using a CEMS are required to conduct subsequent     |
| performance tests semiannually.\\1\\                                  |
|                                                                       |
| \\1\\ After you have demonstrated compliance for two consecutive      |
| tests, you may reduce the frequency of subsequent performance tests   |
| to annually. If the results of any subsequent annual performance test |
| indicate the stationary RICE is not in compliance with the CO or      |
| formaldehyde emission limitation, or you deviate from any of your     |
| operating limitations, you must resume semiannual performance tests.  |
+-----------------------------------------------------------------------+

Table 6 - Recordkeeping

+-----------------------------------------------------------------------+
| 1.  2SLB and 4SLB stationary RICE and CI stationary RICE              |
|                                                                       |
| a\. Reduce CO using an oxidation catalyst, and using CPMS.            |
|                                                                       |
| i\. Conducting emissions and semiannual performance tests for CO to   |
| demonstrate that the required CO percent reduction is achieved        |
| \\1\\;and                                                             |
|                                                                       |
| ii\. Collecting the catalyst inlet temperature data according to Sec. |
| 63.6625(b); and                                                       |
|                                                                       |
| iii\. Reducing these data to 4-hour rolling averages; and             |
|                                                                       |
| iv\. Maintaining the 4-hour rolling averages within the operating     |
| limitations for the catalyst inlet temperature; and                   |
|                                                                       |
| v\. Measuring the pressure drop across the catalyst once per month    |
| and                                                                   |
|                                                                       |
| demonstrating that the pressure drop across the catalyst is within    |
| the operating limitation established during the performance test.     |
+-----------------------------------------------------------------------+

Table 7 -- Compliance Reporting

+-----------------------------------------------------------------------+
| 1\. Compliance report according to the requirements in Sec.           |
| 63.6650(b). Semiannually according to the requirements in Sec.        |
| 63.6650(b).                                                           |
|                                                                       |
| > a\. If there are no deviations from any limitations or operating    |
| > limitations that apply to you, a statement that there were no       |
| > deviations from the emission limitations or operating limitations   |
| > during the reporting period. If there were no periods during which  |
| > the CMS, including CEMS and CPMS, was out-of-control, as specified  |
| > in Sec. 63.8(c)(7), a statement that there were not periods during  |
| > which the CMS was out-of-control during the reporting period; or;   |
| >                                                                     |
| > b\. If you had a deviation from any emission limitation or          |
| > operating limitation during the reporting period, the information   |
| > in Sec. 63.6650(d). If there were periods during which the CMS,     |
| > including CEMS and CPMS, was out-of-control, as specified in Sec.   |
| > 63.8(c)(7), the information in Sec. 63.6650(e); or                  |
| >                                                                     |
| > c\. If you had a startup, shutdown or malfunction during the        |
| > reporting period, the information in Sec. 63.10(d)(5)(i).           |
|                                                                       |
| 2\. An immediate startup, shutdown, and malfunction report if actions |
| addressing the startup, shutdown, or malfunction were inconsistent    |
| with your startup, shutdown, or malfunction plan during the reporting |
| period. By letter within7 working days after the end of the event     |
| unless you have made alternative arrangements with the permitting     |
| authorities. (Sec. 63.10(d)(5)(ii))                                   |
|                                                                       |
| > a\. Actions taken for the event; and By fax or telephone within 2   |
| > working days after starting actions inconsistent with the plan.     |
| >                                                                     |
| > b\. The information in Sec. 63.10(d)(5)(ii).                        |
|                                                                       |
| 3\. Report annually according to the requirements in Sec. 63.6650.    |
|                                                                       |
| > a\. The fuel flow rate of each fuel and the heating values that     |
| > were used in your calculations, and you must demonstrate that the   |
| > percentage of heat input provided by landfill gas or digester gas,  |
| > is equivalent to 10 percent or more of the gross heat input on an   |
| > annual basis; and                                                   |
| >                                                                     |
| > b\. The operating limits provided in your federally enforceable     |
| > permit, and any deviations from these limits; and                   |
|                                                                       |
| c\. Any problems or errors suspected with the meters.                 |
+-----------------------------------------------------------------------+