. Patch HI - Next Pagestarb New Batch 
December 3,20 1 0 

#A HAND Om 

John S. Lyons, Director 

Division for Air Quality 

200 Fair Oaks Lane, First Floor 

Frankfort, KY 4060 1 

DEC 32010 

RE: Application for Minor Permit Revision to Permit No. V-05-070 R3 

J. K Smith Generating Station 

Source ID: 2 1 -049-00027 

Source AI: 808 

Activity No.: APE2008002 

Dear Mr. Lyons: 

In accordance with 401 KAR 52:020 $14 and pursuant to discussions with 

counsel for the Division, please find enclosed an application for a minor revision to the 

above-referenced Title V Permit for the East Kentucky Power Cooperative, Inc. 

("EKPC") J. K. Smith Generating Station located near Trapp, Kentucky in Clark County. 

As is detailed in the attached Application and other documentation required by 401 KAR 

52:020 $14, EKPC is requesting that the Permit be revised by removing Emissions Units 

11, 12, 13, 14, 15, 16% 16b, 17, 18 and 19. 

EKPC's decision to request revision of the Permit to remove the two coal-fired 

circulating,fluidized bed (CFB) boilers and ancillary equipment is the result of several 

contributing factors, including a significant downward trend in EKPC's electrical load 

growth, which has eliminated the current need for significant new baseload generation. 

EKPC also has determined that Smith CFB 1 is not the cukent least cost option for 

meeting its present baseload needs. In addition, EKPC has recently entered into a 

Settlement Agreement with Gallatin Steel Company, the Kentucky Attorney General, the 

Sierra Club, and various other environmental interest groups and individuals that, among 

other things, calls for EKPC to .submit an application for a pexmit amendment or 

modification to the Cabinet to request that the above-referenced emission units be 

removed from the permit. 

EKPC's submittaI should not be construed in any way as a waiver of any rights 

EKPC may have, now or in the future, to apply for authorization from the Division for 

any other proposed action at the Smith Generating Station or any other site. Nothing. in 

the above-referenced Settlement Agreement prohibits EKPC from pursuing any such 

approvals from the Division, other than a prohibition on seeking approval for a coal-fired 

electric generating unit within two years of the date of execution of the Settlement 

Agreement. 

4775 Lexington Road 40391 Tel. (859) 744-4812 

to. Bax 707, Wnchestor, Fax: (859) 744-6008 

Ken+ 40392-0707 htfp:/lwww.ekpc.coop 
EKPC appreciates the Division's helpfui assistance and diligent efforts 

throughout the past few years as EKPC has pursued the Smith CFB project. We at EKPC 

look forward to working with you in the coming months and years as EKPC continues to 

pursue those actions necessary to meet the needs of its member cooperrrtives and their 

retail customers. 

Thank you again for your time and assistance. Please give me a call at 

859.745.9244 should you have any questions about the enclosed application. 

Sincerely, 

Fh' Jerry Purvis, Manager V Environmental Affairs 

Enclosures 

c: Rick Shewekah, DAQ 

Jackie Quarles, DAQ 

Sean Alteri, DAQ 

D. Mosier, EKPC 

T. Campbell, EKPC 

I.. . . .. . . .. . . . . . .. . . . . . .. . . . . . . .. . . . . . . . .- . . .--.-.. . . . . . ... - ..--.-...--.--.p --.-".--.-*-.--.."--.-- 
East Kentucky Power Cooperative, Inc. 

J.K. Smith Generating Station 

Minor Permit Revision 

To Permit No. V-05-070 R3 

East Kentucky Power Cooperative, Inc. ("EKPC') is requesting that its existing Title IV 

Permit No. V-05-070 R3 be revised by removing certain units, Specifically, EKPC 

requests that the Division remove two coal-fired, circulating fluidized bed (CFB) boilers 

and associated material handling and storage facilities for coal, limestone, lime and ash 

along with cooling towers and paved haul roads that will not be constructed at the facility 

at this time. The units to be removed are identified in the existing permit as Emissions 

Units 1 1 - 19. 

As explained in the cover letter accompanying this application, EKPC's decision to 

request revision of the Permit to remove the two CFB boilers and ancillary equipment is 

the result of several contributing factors, including a significant downward trend in 

EKPC's electrical load growth, which has eliminated the current need for significant new 

baseload generation. EKPC also has determined that Smith CFB 1 is not the current least 

cost option for meeting its present baseload needs. In addition, EKPC has recently 

entered into a Settlement Agreement with Gallatin Steel Company, the Kentucky 

Attorney General, the Sierra Club, and various other environmental interest groups and 

individuals that, among other things, calls for EKPC to submit an application for a permit 

amendment or modification to the Cabinet to request that the above-referenced emission 

units be removed from the permit. 

The proposed project meets all requirements of Kentucky Regulation 401 KAR 52:020 $ 

14 (Title V Permits - Minor Pennit Revision). 

A Descriptiort of the Change and the Resulting Change in Emhstans 

The EKPC decision not to proceed with construction of the permitted units and to remove 

them fiom the Permit will result in no increase of emissions fiom the facility. In fact, the 

decision to remove the units results in a decrease in allowable emissions at the facility, as 

quantified in Table 4- 1, page 4, of the Statement of Basis for Permit V-05-070 R3. 

New Applicable ~e~u&e&nl~ that Will app& Ajler the Change 

No new applicable requirements wiH result from the deletion of Emission Units 11 - 19. 

Requirements applicable to those units will simply be removed. 
Addaonal Required Information and Forms 

Pursuant to 401 KAR 52:020§14(3), the following information and forms are also 

submitted with this package: 

1. Suggested draft permit language associated with this change, showing only the 

information that is new or different than the existing Permit for the Smith Station. 

See Attachment 1. Please note that in essence this minor permit revision will 

return the permit language to that found in Permit No. V-05-070 R2. 

2. Form DEP7007AI is submitted herewith; however, no other forms are 

appropriate for this revision. See Attachment 2. 

3. Completed forms for the Cabinet to notify the U.S. EPA and affected states. See 

Attachment 3. 

I, as the Responsible Official, hereby certify on information and belief after 

reasonable inquiry, that the proposed permit revisions meet the criteria for use of 

minor permit revision procedures. 

ffairs Manager 

East Kentucky Power Cooperative, Inc. 
ATTACHMENT 1 
TABLE OF CONTENTS 

SECTION PAGE ISSUANCE 

A. PERMIT AUTHORIZATION 1 Revision 

B. EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 2 Revision 

REGULATIONS, AND OPERATING CONDITIONS 

Emissions Units 0 1-04 (SCT01-SCT04) - Combustion Turbines ............. 2 Existing 

Emissions Units 05 - 07 (SCTS - SCT7) - Combustion Turbines ........... 1 0 Existing 

Emissions Units 09 and 10 - GE LMS 100 Combustion Turbines .......... 16 Existing 

,....*.............,..,....... 

C. INSIGNIFICANT ACTIVITIES 

D. SOURCE EMISSION LIMITATIONS AND TESTING 

REQUIREMENTS 

E. SOURCE CONTROL EQUIPMENT OPERATING 

REQUIREMENTS 

F. MONITORING, RECORDKEEPING, AND REPORTING 

REQUIREMENTS 

G. GENERAL PROVISIONS 

H. ALTERNATE OPERATING SCENARIOS 

I. COMPLIANCE SCHEDULE 

J. ACID RAIN 

K. CLEAN AIR INTERSTATE RULE 

Revision 

Revision 

Revision 

Revision 

Revision 

Revision 

Revision 

Revision 

Revision 
Permit Number: V-05-070 R3 C 

Page 21 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emissio Unit 11 - Circulating Fluidized Bed Boiler Unit 1 (CFB1) at 

Coal-fired Bed boiler, rating 3000 MMBtuhr (300 MW) 

gas used for startup and stabilization 

Injection, Flash Dryer Absorber with fresh lime 

401 KAR 51:017 

401 KAR 51:160 

401 KAR 51:210 

401 KAR 51:220 

401 KAR 51:230 

401 KAR 52:MO 

40 CFR 68 

40 CFR 75 

fair quality, applicable to major 

ification commenced after September 22, 1982. 

for large utility and industrial boilers. 

rating the Federal Acid Rain provisions as 

incorporating 40 C 60, Standards of performance for new 

40 CFR 60, Subpart Da, Standards of 

perlomaace for electric 

Contiaaws emission monitoring. 

Statc-Onlv A~~Hcabk Reatllatioas: 

401 KAR 63:020 Potentially hazardous matter or toxic 

1. Owratina Limitations: \ 

a. Pursuant to 401 KAR 51:017, the permittee shall install all 

meet Best Available Control Technology (BACT): 

i. BACT for PIVWM~~PM~.~ is a fabric filter; 

ii. BACT for SOz and H2SO4 is limestone injection and 

fresh lime injection; 

iii. BACT for NOx is an SNCR; and 

iv. BACT for CO and VOCs is the use of good combustion controls. 

b. Pursuant to 401 KAR 63:020, persons responsible for a source from which 

matter or toxic substances may be emitted shall provide the utmost care and 

in the handling of these materials, to the potentially harmfbl effects of 

resulting fiom such activities. No owner or operator shall allow any affected facility t 
Permit Number: V-05-070 R3 Page 22 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

hazardous matter or toxic substances in such quantities or duration as to 

health and welfare of humans, animals and plants. The use of good 

fabric filter, limestone injection, flash dryer absorber, and SNCR 

of toxic substances. 

be considered to be the setting in operation of a boiler for any 

of initial compliance, beginning with the introduction of 

when the generator has sustained 45 percent (135 MW) of 

for at least one hour. A Startup Event shall not exceed 24 

damage, unsafe operation, or deviation fiom 

(OEM) procedure [4O 1 KAR 5 1 :0 171. 

d. Pipeline quality gas shall be burned exclusively during a Startup Event for 

startup and KAR 51:017]. 

e. A "Shutdown Event" as cessation of operation of a boiler beginning 

with the generator curtailment of the he1 supply to the boiler, and 

ending after fuel Event shall not exceed 10 hours [401 

KAR 51:017]. 

Compliance Demonstration Meth 

Refer to Section F.9 for d above. For compliance with 

b, refer to 2. Emission 

a. Particulate matter emissions shall not exceed (o a 24-hour block average): 

i. 0.14 IWMWh (filterable PM) gross energy utput or 0.015 IWtu (filterable 

PM) heat input except during startup, shutdo , or rnalfunction[40 CFR 60,42Da]; 

ii. 0.009 IbMMBtu (filterable PMdPM2.5) and 12 Ib/MMBtu (total PMl@M2.5) 

except during startup, shutdown, or malfimction 01 KAR 5 1 :017]; and 

iii. 36 Ibhr (total PMldPM2.5) on a 24-hour block t aver e [(NAAQS)]. 

Compliance Demonstration Method: 

Compliance filterable PM emission limits shall be 

Emission Monitoring System (GEMS) and shall 

CFR 60.48Da(p) with the exception that there are 

in 2.a.iii. Compliance with total PMldPM2.5 

stack testing as described in 3. Testia~. 

b. Sulhr dioxide (Sa) emissions shall not exceed: 

i. 1.4 Ib/MWh gross energy output on a 30day rolling average basis 

emergency [40 CFR 60.43Da and 40 CFR 60.48Da(d)(l)-(3)]; 

ii. 0.075 IbMMBtu heat input on a 24-hour average, except during 

or emergency [40 1 KAR 5 1 :0 1 TJ; and 

iii. 225 lbhr on a 24-hour block average WAAQS]. 
Permit Number: V-05-070 R3 Page 23 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Compliance Demonstration Method: 

with S@ emission limits shall be demonstrated by S& CEMS and shall 

specified in 40 CFR 60.48Da, with the exception that there are no 

limit in 2.b.iii. 

erage basis except during 

ng start up, shut down, or 

Compliance Demonst 

Compliance shall be NOx CEMS and shall follow the procedures 

specified in 40 CFR exception that there are no exemptions from the 

emission limit in 2.c.iii. 

Mercury emissions shall not x lo4 IbMWh x MWh of bituminous coal) + 

(16 x lo6 lWMWh x MWh of bituminous coal + MWh coal refuse] 

on an output basis averaged average basis (401 KAR 63:020]. 

Compliance Demonstration 

Compliance shall be mercury (Hg) CEMS or sorbent trap 

monitoring Refer to 4. S~ccific Moai tori= 

Reauiremegtd 

Carbon monoxide shall not exceed: 

i. 0.10 Ibs/M?vlBtu based on a 30-day ro ing average except during startup, 

shutdown, or malfunction [401 KAR 5 1 :017J; d 

ii. 300 Ibh on an 8-hour block average WAAQS \ . 

Compllaace Demonstration Method: 

Compliance shall be demonstrated by CO CEMS. no exemptions from the 

emission limit in 2.e.ii. 

VOC emissions shall not exceed 0.002 Ib/MMBtu based on 

except during startup, shutdown, or malfunction 1401 KAR 5 1 

Compliance Demonstration Method: 

Compliance shall be demonstrated by CO CEMS. If a 3-hour 

CEMS data is in compliance with the CO limit, then VOC 

in comptiance. 

Sulfuric acid mist emissions shall not exceed: 

i. 0.005 Ib/MMBtu based on a 3-hour average except during startup, 

malfunction [401 KAR 51:017]; and 
Permit Number: V-05-070 R3 Page 24 of 84 

B -EMISSION POINTS, ElMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

"K 15 lbfhr on 3-hour block average 1401 KAR 5 1 :017]. 

Method: 

the sulfur dioxide limit shall constitute compliance with the sulfuric 

of Section 112(g) of the Clean Air Act, emissions shall not 

Hazardous Air Pollutant (HAP) and 22.5 tons for all HAPS 

Compliance 

annual performance testing using Method 26 for 

emission factors in the Appendix to this pennit 

Any emission factors derived fiom testing shall 

the Appendix. Testing is not required for all 

specified in 3. zestin& 

Monthly HCI emissions shall be ca ulated using the following formula: 2 

HCI Emissions = monthly HCI emission in tons 

P = monthly total fuel usage rate in tons 

Fuela = monthly average &el CI conce tion, Ib CVlb !%el, determined as 

follows: a 

P, = monthly usage rate for fuel n in tons 

CI, = C1 content of fuel n 

EFa=pounds CI emitted/pound CI in fuel fiom stack 

3. Testing \ 

a. Except as specified in 40 CFR 60.8, (a)(l),(a)(2), (a)(3), and (a)(4), w 

achieving the maximum production rate at which the affected facili 

but not later than 180 days after initial startup of such facility, 

demonstrate compliance with applicable emission standards. I 

performance tests, the permittee shall use as reference methods 

methods in 40 CFR 60 Appendix A and procedures as specified in 

[40 CFR 60.8, 40 CFR 60.50Da, and 401 KAR 50:055, Sect 

performance tests shall be conducted within 12-months of the previ 
Permit Number: V-05-070 R3 Page 25 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

compliance test, the permittee shall take a sample of the fbel as fired 

ASTM methods to determine the chlorine content in the fbel. This 

used to establish a correlation between the sample's chlorine 

chloride emissions. The permittee shall validate each year these 

c. During the test, the permittee shall take a sample of the fuel as fued 

to determine the sulfur content in the fuel. This 

a correlation between the sample's sulk content 

A correlation shall be developed between the 

SQz emissions as measured by CEMS, and 

shall validate each year these correlations 

[40 CFR 64.31. 

d. During the initial stack shall determine emission factors for 

acetaldehyde, acrolein, I chloride, chromium, chromium VI, 

cyanide, hychvgen chl horone, lead, manganese, mercury, 

methyl chloride, nicke factors from stack testing (except 

for mercury, which m in conjunction with the emission 

factors in the Appen that total potential emissions of 

HAPS do not excee nths [401 KAR 52:020, Section 

261. 

e. During the initial compliance testing, the shall verifj. that when CO is in 

compliance when measured by CO CEMS, are in compliance with the 

VOC limit [401 KAR 50:055]. 

f. Refer to Section D for additional requirements. \ 

a. Pursuant to 40 1 KAR 52:020,40 1 KAR 5 1 :0 17,401 KAR 6 

the owner or operator shall install, calibrate, maintain, operate continuous 

monitoring systems for measuring the sulfbr dioxide e 

emissions, nitrogen oxides emissions, particulate matter emission 

carbon dioxide diluents. Oxygen or carbon dioxide shall 

where sulfur dioxide or nitrogen oxides emissions are monitored. 

shall ensure the continuous monitoring systems are in compliance 

of 40 CFR 60.5ODa and 40 CFR Part 75. 

b. The permittee shall monitor mercury emissions using either mercury (Hg) 

sorbent trap monitoring system (as defined in 40 CFR 72.2). If Hg CEMS is 

CEMS must be installed, operated, and maintain according to Performance 

12A in Appendix B to 40 CFR Part 60. If a sorbent trap monitoring system 

monitor Hg concentration, the procedures described in 40 CFR 75.15 and 
Permit Number: V-05-070 R3 Page 26 of 84 

CTION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

40 CFR Part 75 shall be followed. The 12-month rolling average shall be calculated in 

accordance with 40 CFR 60.50Da(h). \ 

emission results less than the minimum detection level of the 

demonstrate compliance with the limits for HCI. 

The permittee shall install, calibrate, a wattmeter; measure gross 

electrical output in MWh on a output of the monitor [40 

CFR 60.49Da(k)]. 

Data from a continuous flow monitoring system 

requirements of 40 CFR 75.20(c) and 40 CFR Part 

quality control and quality assurance requirements 

Appendix B shall be used. Flow rate data 

60.51Da shall not include substitute 

procedures in 40 CFR 75, Subpart D, 

according to the procedures of 40 CFR Part 75 [40 CFR 60.49Da(m)]. 

The permittee shall prepare and submit to the Division for approval a 

monitoring plan for each monitoring system, at least 45 days before 

certification testing of the monitoring systems. The permittee shall 

requirements in its plan. The plan must address the requirements 

Da(s)( 1 ) through (6) [40 CFR 60.49Da(s) J. 
Permit Number: V-05-070 R3 Page 27 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

has not obtained the minimum quantity of emission data as required 

60.49Da, the permittee shall comply with the procedures in 40 CFR 

shall monitor the time, date, and duration of startups and shutdowns 1401 

i. Consistent 64.4, limestone and hsh lime injection rates shall be measured 

minutes and recorded as an hourly average. Continuous 

ion rates shall be monitored and recorded and maintained 

[40 CFR 64.6). 

5. Spcciflc Record Kceda~mbremtnts 

a. The permittee shall provide in accordance with 40 CFR 60.7(a) and shall 

maintain records of all to demonstrate compliance including 

performance tests, and calculations, consistent with the 

requirements of 40 

b. The permittee shall record and the time, date and duration of any 

startup, shutdown, or of the affected facility, any 

malfunction of the air which a CEM 

system or emission 

a. The permittee shall submit the written 

Subpart A to the Division semiannual h period. All semiannual 

repurts shall be postmarked by the 3 d of each six-month period 

and shall include the following info 

i. For Sa, N&, PM, and Hg emissions, 

and subsequent performance test and evaluation of the 

continuous monitors. 

ii. For S@ and N& the following informat 

(1) Calendar date. 

(2) The average SQ and NOx emissi 

each 30 successive boiler operati 

in the quarter; reasons for non-c 

description of corrective actions taken. 

(3) For owners or operato 

reduction requirement, pe 

concentration of SQ for each 

with the last 30day period in 

the standard, and description o 

(4) Identification of the boiler operating days for which pollutant or diluent 

have not been obtained by an approved method for at least 75 percent o 
Permit Number: V-05-070 R3 Page 28 of 84 

N B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

of times when hourly averages have been obtained based on 

e times when the pollutant concentration exceeded fiill 

iii. If the minimum quantity of data as required by 40 CFR 60.49Da is not 

obtained under the require 

(1) The number of hourly avera 

(2) The standard deviation of houri 

inlet emission rates (si) as applic 

(3) The lower confidence limit for the emission rate (E,*) and the 

upper confidence limit for the mean n rate (Ei*) as applicable. 

(5) The ratio of the upper confidence mean outlet emission rate 

iv. If any standards under 40 CFR 60.43Da 

statement: 

60.48Da(d) were met during each period, and 

(2) Listing the following information: I 
Permit Number: V-05-070 R3 Page 29 of 84 

* 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

ission rate, due to unit startup, shutdown and 

(2) The data used to show not obtained in accordance 

b. The permittee shall report each period of any excess emissions that occurs 

startups, shutdowns, and malfunctions of the affected facility [401 KAR 50:055]. 

report shall include: 
Permit Number: V-05-070 R3 Page 30 of 84 

B -EMISSION POINTS? EMISSIONS UNITS, APPLICABLE 

TIONS, AND OPERATING CONDITIONS (CONTTNUED) 

(if known), the corrective action taken or 

also be reported, the type of start-up (cold, 

as determined to be cold, warm, or hot (or the 

arm, or hot start-up), as well as the shut down; 

d time of (or duration of) the start-up, and shut 

duration for emergency conditions, that type of 

istorical durations for that type of start-up, and 

v. Whether or up, emergency conditions and shut down 

mendation or typical, historical durations, and 

start-up exceeded recommended or typical 

durations. 

c. , CAM Requirements - The permittee 

, with the general reporting requ 

I 64.9(a)]: 

i. Number of exceedances or excursions; 

ii. Duration of each exceed 

iii. Cause of each 

iv. Corrective actions taken 

v. Numk of 

vi. Duration of each mon 

vii. Cause of each monito 

viii. Description of acti 

documentation that 

excursions or exceedances and downtimes. 

d. The permittee shall report semiannually the HCI and total HAP 

calculations and correlations used to determine the HCI and total 

e. Refer to Section F for additional requirements \ 
Pemit Number: V-05-070 R3 Page 31 of 84 

MISSION POINTS, EMISSIONS UNITS, APPLICABLE 

S, AND OPERATING CONDITIONS (CONTINUED) 

Eaoi~ment Oberatine Conditions: 
Permit Number: V-05-070 R3 Page 32 of 84 * 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emissio Unit12 - Circulating Fluidized Bed Boiler Unit 2 (CFB2) \ 

Coal-fired boiler, rating 3061 MMBtu/hr (300 MW) 

and stabilization only - 

Dryer Absorber with fiesh lime 

401 KAR 51:017 

401 KAR 51:160 

401 KAR 51:210 

401 KAR 51:220 

401 KAR 51:230 

401 KAR 52:060 

401 KAR 60:005 

State-Onh Avdicablc Renrrlatious; 

401 KAR 63:020 Potentially hazardous matter or toxic substances. 

1. -rating Limitations., 

\ 

\ 

a. Pursuant to 401 KAR 5 1 :017 the permittee shall install all control 

meet Best Available Control Technotogy (BACT): 

i. BACT for PM/PM,I~PM~.~ is a fabric filter; 

ii. BACT for SOz and H2S04 is limestone injection and a flash 

fiesh lime injection; 

iii. BACT for NOx is an SNCR; and 

iv. BACT for CO and VOCs is the use of good combustion controls. 

b. Pursuant to 401 KAR 63:020, persons responsible for a source from which 

matter or toxic substances may be emitted shall provide the utmost care and consideration, 

in the handling of these materials, to the potentially harmful effects of the emissions 

resulting from such activities. No owner or operator shall allow any affected facility to 
Permit Number: V-05-070 R3 Page 33 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

TIONS, AND OPERATING CONDITIONS (CONTINUED) 

emit potentially hazardous matter or toxic substances in such quantities or duration as to 

to the health and welfare of humans, animals and plants. The use of good 

bustion controls, fabric filter, limestone injection, flash dryer absorber, and SNCR 

used for the control of toxic substances. 

be considered to be the setting in operation of a boiler for any 

of initial compliance, beginning with the introduction of 

when the generator has sustained 45 percent (1 35 MW) of 

for at least one hour. A Startup Event shall not exceed 24 

damage, unsafe operation, or deviation from 

(OEM) procedure [401 KAR 5 1 :0 17). 

d. Pipeline quality be burned during a Startup Event for startup and 

stabilization [401 

e. A "Shutdown Event" shall be onsidered as cessation of operation of a boiler beginning 

I with the generator going below 35 MW, curtailment ofthe he1 supply to the boiler, and 

ending after fbel flow has cease A Shutdown Event shall not exceed 10 hours 1401 

KAR 51:017J. \ 

Compliance Demonstration Method: 

Refer to Section F.9 for compliance rep 'ng for a, c, and d above. For compliance with 

b, refer to 2. Emisslon Limitation& Sub a 'ons d and h. 

2. Emission ~itatlonri \ 

a. Particulate matter emissions shall not exceed (on 

ii. 0.009 

Compliance Demonstration Method: 

Compliance filterable PM emission limits shall be I Emission Monitoring System (CEMS) and shall I CFR 60.48Da(p), with the exception that there 

2.a.iii. Compliance with total PM 

testing as described in 3. Testing. 

b. Sulfi~r dioxide (SQ2) emissions shall not exceed: 

i. 1.4 Ib/MWh gross energy output on a 30-day rolling average basis 

an emergency [40 CFR 60.43Da and 40 CFR 60.48Da(d)(l)-(3)]; 

ii. 0.075 1bIMMBtu heat input on a 24-hour average, except during 

or emergency [40 1 KAR 5 1 :0 1 73; and 

iii. 229.58 Ibhr on a 24-hour block average [NAAQS]. 
Permit Number: V-05-070 R3 Page 34 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Demonstration Method: 

limits shall be demonstrated by S@ CEMS and shall 

specified in 40 CFR 60.48Da, with the exception that there are no 

limit in 2.b.iii. 

c. Nitrogen dl ide emissions shall not exceed: 

i. I .O Ib Wh gross energy output on a 30day rolling average bash except during 

startup, sh tdown, or malfunction [40 CFR 60.44Da(e)]; 

ii. 0.07 IbsM tu on a 30-day rolling average except during start up, shut down, or 

malfunction [ 1 KAR 5 1 :0 17J; and 

iii. 214.27 t lbh on 4-how block average WAAQS]. 

Compliance shall be N& CEMS and shall follow the procedures 

specified in 40 CFR exception that there are no exemptions fiom the 

emission limit 

d. Mercury emissions shall not loa lb/MWh x MWh of bituminous coal) + 

(16 x loa IbMWh x MWh of bituminous coal + MWh coal refuse] 

on an output basis averaged average basis 1401 KAR 63:020]. 

Compliance Demonstration Method: 

Compliance shall be demonstrated by (Hg) CEMS or sorbent trap 

monitoring system (as defined in 40 to 4. S~ecific IM odtoriqg 

Subsection b. for 

e. Carbon monoxide shall not exceed: 

i. 0.10 Ibs/MMBtu based on a 30-day except during starnap, 

shutdown, or malfinction (401 KAR 5 1 :017]; and 

ii. 306.10 lblhr on an &hour block average [NAAQS]. 

Compliance Demonstration Method: 

Compliance shall be demonstrated by CO CEMS. There are no for the limit 

specified in 2.e.ii. 

f. VOC emissions shall not exceed 0.002 IbRMMBtu based on a 

except during startup, shutdown, or malfhction [401 KAR 51 :017]. 

Compliance Demonstration Method: 

Compliance shall be demonstrated by CO CEMS. If a 3-hour rolling 

CEMS data is in compliance with the CO limit, then VOC emissions 

in compliance. 

g. Sulfbric acid mist emissions shall not exceed: \ 
Permit Number: V-05-070 R3 Page 35 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

0.005 lb/MMBtu based on a 3-hour average except during startup, shutdown, or 

malfunction [4O 1 KAR 5 1 :0 17J 

1 Iblhr on 3-hour block average [401 KAR 5 1 :017]. 

Method: 

limit shall constitute compliance with the sulhric 

of Section 1 12(g) of the Clean Air Act, emissions shall not 

Hazardous Air Pollutant (HAP) and 22.5 tons for all HAPS 

Compliance 

to this permit 

Monthly HCI emissions shall be calcula using the following formula: Y 

HCI Emissions = monthly HCI emissions in 

P = monthly total fuel usage rate in tons 

Fuelcl = monthly average fuel Cl ClAb f'bel, determined as 

follows: 

P,, = monthly usage rate for fitel n in tons 

CI, = Cl content of fuel n 

EFa--pounds CI emittedlpound Cl in fuel from stack testing res k ts. 

a. Except as specified in 40 CFR 60.8, (a)(l),(a)(2), (a)(3), and (a)(4), within 

achieving the maximum production rate at which the affected facility will 

but not later than 180 days after initial startup of such facility, the pe 

demonstrate compliance with applicable emission standards. In con 

performance tests, the permittee shall use as reference methods and proce 

methods in 40 CFR 60 Appendix A and procedures as specified in 40 C 

[40 CFR 60.8, 40 CFR 60.5ODa, and 401 KAR 50:055, Section 21. Subse 

performance tests shall be conducted within 12-months ofthe previous 
Permit Number: V-05-070 R3 Page 36 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

initial compliance test, the permittee shall take a sample of the he1 as fired 

it using ASTM methods to determine the chlorine content in the fuel. This 

shall be used to establish a correlation between the sample's chlorine 

emissions. The permittee shall validate each year these 

c. During shall take a sample of the he1 as fired 

to determine the sulfur content in the fuel. This 

a correlation between the sample's sulfur content 

A correlation shall be developed betwten the 

S(h emissions as measured by CEMS, and 

shall validate each year these correlations 

[40 CFR 64.33. 

d. During the initial shall determine emission factors for 

acetaldehyde, chloride, chromium, chromium VI, 

lead, manganese, mercury, 

from stack testing (except 

with the emission 

emissions of 

261. 

e. During the initial compliance testing, the shall verify that when CO is in 

compliance when measured by CO CEMS, emissions are in compliance with the 

VOC limit 1401 KAR 50:055]. 

f. Refer to Section D for additional requirements. \ 

4, Specific MonitorCnr ReauiremenQl \ 

a. Pursuant to 401 KAR 52:020,40 1 KAR 5 1 :017,401 KAR 

the owner or operator shall install, 

monitoring systems for measuring the sulfur 

emissions, nitrogen oxides emissions, particulate 

carbon dioxide diluents. Oxygen or carbon 

where sulfbr dioxide or nitrogen oxides 

shall ensure the continuous monitoring 

of 40 CFR 60.50Da and 40 CFR Part 75. 

b. The permittee shall monitor mercury emissions using either mercury (Hg) 

sorbent trap monitoring system (as defined in 40 CFR 72.2). If Hg CEMS is 

CEMS must be installed, operated, and maintain according to Performance 

12A in Appendix B to 40 CFR Part 60. If a sorbent trap monitoring system 

monitor Hg concentration, the procedures described in 40 CFR 75.15 and 
Permit Number: V-05-070 R3 Page 37 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

Part 75 shall be followed. The 12-month rolling average shall be calculated in 

with 40 CFR 60.50Da(h). 

c. ~ursmt(t9 40 CFR 64.3, HCl CEMS shall serve as a continuous indicator of annual HCI 

average HCI emissions based on CEMS data equal or exceed 0.75 

ittee shall notify the Division, investigate the cause and implement 

onth equal or exceed 0.75 tons, the permittee shall take 

test within 30 days to demonstrate compliance with the 

ii. For HCI monitored em results less than the minimum detection level of the 

CEMS, the permittee 

d. The permittee shall install, calibrate, maintain, and measure gross 

electrical output in MWh on a continuous basis; and 

CFR 60.49Da(k)]. 

e. Data from a continuous flow monitoring system shall be 

requirements of 40 CFR 75.20(c) and 40 CFR Part 75, 

quality control and quality asswmce requirements of 40 

Appendix B shall be used. Flow rate data reported to 

60.51Da shall not include substitute data values 

procedures in 40 CFR 75, Subpart D, nor shall 

according to the procedures of 40 CFR Part 75 [40 CFR 60.49Da(m)]. 

f. The permittee shall prepare and submit to the Division for approval a unit-s 

monitoring plan for each monitoring system, at least 45 days before 

certification testing of the monitoring systems. The permittee shall 

requirements in its plan. The plan must address the requirements 

Da(s)(l) through (6) [40 CFR 60.49Da(s)]. 
0 

Permit Number: V-05-070 R3 Page 38 of 84 

qECTION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

If the permittee has not obtained the minimum quantity of emission data as required 

40 CFR 60.49Da, the permittee shall comply with the procedures in 40 CFR 

the time, date, and duration of startups and shutdowns 1401 

limestone and fresh lime injection rates shall ba measured 

minutes and recorded as an hourly average. Conthuous 

rates shall be monitored and recorded and maintained 

5. Sdc Record Kee~in~ ~hments 

\ 

a. The permittee shall in accordance with 40 CFR 60.7(a) and shall 

maintain records to demonstrate compliance including 

performance tests, and calculations, consistent with the 

requirements of 40 

b. The permittee shall record and of the time, date and duration of any 

startup, shutdown, or of the affected facility, any 

malfunction of the air period during which a CEM 

system or emission 

a. The permittee shall submit the written reports 

Subpart A to the Division semiannually for 

reports shall be postmarked by the 30th day 

and shall include the following information [40 CFR 60. 

i. For S@, NOx, PM, and Hg emission 

and subseque~t performance test and fiom the pe ce evaluation of the 

continuous monitors. 

ii. For S@ and NOx the following info 

(1) Calendar date. 

(2) The average Sa and 

each 30 successive boil 

in the quarter; reasons for 

description of corrective actions taken. 

(3) For owners or operato 

reduction requirement, 

concentration of SOz for 

with the last 30day peri 

the standard, and descrip 

(4) Identification of the boiler operating days for which pollutant or diluent 

have not been obtained by an approved method for at least 75 percent o 
Pennit Number: V-05-070 R3 Page 39 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

hours of operation of the facility, justification for not obtaining sufficient 

data, and description of corrective actions taken. 

(5) Identification of the times when emissions data have been excluded from the 

s available for outlet emission rates (rb) snd 

erages for outlet emission rates (h) and 

inlet emission rates (si) as a 

(3) The lower confidence limit 

r the mean outlet emission rate 

statement: 

uirements under 40 CFR 
Permit Number: V-05-070 R3 Page 40 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

ission rate, due to unit startup, shutdown and 

(5) The data assessment 

equivalent summary 

(1) The required CEMS calib 

(2) The data used to show compl or was not obtained in accordance 

with approved methods and p of this part and is representative of 

plant performance; 

(4) Compliance with the standards has or 

b. The permittee shall report each period of any excess emissions that 

startups, shutdowns, and malfunctions of the affected facility I401 KAR 

report shall include: 
Permit Number. V-05-070 R3 Page 41 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

lfbnction (if known), the corrective action taken or 

all also be reported, the type of start-up (cold, 

was determined to be cold, warm, or hot (or the 

, warm, or hot start-up), as well as the shut down; 

apsed time of (or duration of) the start-up, and shut 

ded duration for emergency conditions, that type of 

historical durations for that type of start-up, and 

ineering practices; and 

v. Whether or uration of the start-up, emergency conditions and shut down 

turds recommendation or typical, historical durations, and 

the start-up exceeded recommended or typical 

c. CAM Requirements - The pe shall report the following information in accordance 

with the general reporting F of this permit [40 CFR 

64.9(a)]: 

i. Number of exceedan 

ii. Duration of each ex 

iii. Cause of each e 

iv, Corrective actions taken on each ex 

v. Number of monitoring equipment d 

vi. Duration of each monitoring equipment 

vii. Cause of each monitoring equipment do 

viii. Description of actions taken to imp provement plan for 

operating and monitoring, and upon co quality improvement plan, 

documentation that e likelihood of similar 

excursions or exceedances and downtimes. 

d. The permittee shall report semiannually the HCI and emissions, and the 

calculations and wmlations used to determine the HCI 

e. Refer to Section F for additional requirements \ 

7. SDecific Control Eaai~ment O~eratin~ Conditions; \ 

a. Control equipment shall be operated in accordance with manufacturer's 

and standard operating practices to maintain compliance with 

limitations [401 KAR 50:055, Section 21. 

b. Records regarding the maintenance of the control equipment shall be maintained 

KAR 52:020, Section 261. 

c. Refer to Section E for additional requirements. \ 
Permit Number: V-05-070 R3 Page 42 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

&Pable Regulations: 

401KAR59:OlO operations, applicable to each affected facility or source 

after July 2, 1975, which is not 

standard with respect to particulates. 

401 KAR51:017 deterioration of air quality applicable to major 

commenced after September 22, 1982. 

40 CFR Part 64 (applies to PM). 

1. Omratinn Limitations: \ 

The permittee shall install control as BACT. BACT for PM/PMl@M2.5 is 

a fabric filter [401 KAR 51:017]. 

Compliance Demonstration Method: 

Refer to Section F.9 for compliance reporting. 

2. Emission Limitations 

\ 

\ 

a. The permittee shall not cause, suffer, allow, or permit emission into the 

open air from a control devb or stack associated with which is equal 

to or greater than 20 percent opacity [401 KAR 59:010, 

Compliance Demonstmition Method: 

Refer to 3. Testing Reaairemcnts. 

b. Particulate matter (PMIPMldPM2.5) emissions shall not exceed: 

i. 0.005 gddscf fiom each stack [4O 1 KAR 5 1 :017]. 

ii. 0.34 Ibslhour on a 24-hour block average basis from each bed ash 

iii. 0.39 Ibdhour on a 24-hour block average basis from each fly ash 

Compliance Demonstration Method: 

Refer to 3. Testing Rwuirements. Compliance with 2b.i. shall constitute 

with 2b,ii, 2b.iii, and 401 KAR 59:010, Section 3(2). 
Permit Number: V-05-070 R3 Page 43 of 84 

B -EMISSION POINTS, EMlSSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

permittee shall demonstrate compliance with opacity and particulate matter 

within 60 days after achieving the maximum production rate at 

facility will be operated, but not later than 180 days after initial 

Section 2(l)(a)]. 

b. Testing shall in accordance with 401 KAR 50:045, Performance Tests, and 

the testing shall be conducted under conditions 

potential under anticipated operating conditions at 

c. Except as provided in 50:045, in conducting performance tests the permittee 

shall use as rekrence the test methods in 401 KAR 59:010, 

Section 4 or other as specified in 40 CFR Part 60, Appendix A. 

d. The permittee shall determine from each stack by Method 9 (40 

CFR 60, Appendix A) requested by the Division, unless 

visible emissions from daily monitoring requirement 

listed in Subsection 60, Appendix A) reading shall 

be conducted of the control equipment 

a. Within 60 days after achieving the maximum at which the affected 

facility will be operated, but not later than 180 startup of such facility, 

the permittee shall demonstrate comptlance standards. [401 

KAR 50:055, Section 21 

b. Pursuant to 40 CFR 64.4 (a)(l) and the CAM plan filed 

shall be used as an indicator of particulate matter ittee shall perform 

a qualitative visual observation of the opacity 

weekday (Monday thm Friday) basis and 

emissions from any stack are seen, then a 

shall be conducted and an inspection shall 

repairs. [40 CFR 64.4(c)(1)]. 

c. The pressure drop across the fabric filters shall be monitored through the 

recorder or other continuous recording device. The permittee shall 

recorder (or other continuous recording device) charts. In case 

indications, the permittee must log the date and time of the 

the exceedance (if known) and the measures taken to 
Permit Number: V-05-070 R3 Page 44 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

5. ~l;haf Record Kee~inp Reauirements 

a. ~he)epittee shall maintain results of all compliance tests and calculations. 

record each weekday the date, time and opacity of the visible 

In case of an exceedance, the permittee shall record the reason (if 

taken to minimize or eliminate the exceedance [40 CFR Part 

a. The permittee shall report the above the opacity standard, date and 

time of the excursions, and excursion semiannually [401 KAR 

52:020, Section 261. 

b. Refer to Section F for additional requireme Y 

7. S- C011trol ~9~1~mtnt ~wtim COU~MOII~\ 

a. Controt equipment shall be operated in accordance specifications 

and standard operating practices to maintain 

limitations [401 KAR 50:055, Section 21. 

b. Records regatding maintenance of the control equipment shall be 

52:020, Section 261. 

c. Refer to Section E for additional requirements. \ 
Permit Number: V-05-070 It3 Page 45 of 84 . B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emissio Unit 14 - Coal Crushing and Silo Storage 'Y 

Ae~liutble 

401 KAR60:085 Part 60, Standards of performance for new 

40 CFR 60 Subpart Y, Standards of 

401 KAR 51:017 air quality applicable to major 

September 22, 1982. 

Operating Rate Control Devicea 

14-01 CF&,Coal Silos 340 tonshour Fabric Filter 

14-02 CFB2 &a1 Silos 340 tonshour Fabric Filter 

, 14-03 1 Coal Cnd$ng 1200 tonshour Fabric Filter 

The permittee shall install control methods as BACT. BACT for PM/PMlo/PM2,5 is a 

fabric filter [401 KAR 51:017]. 

Construction 

Commend 

Estimated 20 10 

Estimated 201 0 

Estimated 201 0 

Compliance Demonstration Method: 

Refer to Section F.9 for compliance reporting. \ 

Unit 14-01) and CFBI Limestone Silo (Emission Unit 16-01) are ducted to same 

ilo (Emission Unit 14-02) and CFB2 Limestone Silo (Emission Unit 16-02) are 

2. Emission LimItatbns 

a. The permittee shall not cause to be discharged into fiom any coal 

processing and conveying equipment, wal storage and loading 

system pmssing coal, gases which exhibit 10 

5 1 :01740 CFR 60.254(b)]. 

Compliance Demonstration Method: 

Refer to 3. Testion Reauirements 

b. Particulate matter emissions shall not exceed: 

i. 0.005 grldscf (filterable PM) from each stack or mechanical 

51:017]. 

ii. 0.5 1 Ibshour (filterable PMdPM2.5) on a 24-hour block average 

coal silo on a 24-hour basis WAAQS]. 

iii. 0.43 Ibshour (filterable PMI~PM~.~) on a 24-hour block 

coal crusher house WAAQS]. 
Permit Number: V-05-070 R3 Page 46 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Compliance Demonstration Method: 

to 3. Testine Reaniremenb, Compliance with 2b.i. shall constitute compliance 

demonstrate compliance with opacity and particulate matter 

60 days after achieving the maximum production rate at 

will be operated, but not later than 180 days after initial 

KAR 50:055, Section 2(l)(a)]. 

I. matter emissions: 

emonstrate that 

applicable emission 

within 24 calendar 

ilities that are subject to PM 

PM standard; 

(b) The manufacturer's recommended maintena 

followed for each control device; and 

(c) A performance test is conducted on each affected 

once every 5 calendar years [40 CFR 60.255(e)]. 

ii. With respect to opacity: 

(1) If any 6-minute average opacity reading in the most re 

test exceeds half the applicable opacity limit, a new 

must be conducted within 90 operating days of the date 

performance test was required to be completed; and 

(2) If all 6-minute average opacity readings in the most 

test are equal to or less than half the applicable o 

performance test must be conducted within 12 calendar months of the 
Permit Number: V-05-070 R3 Page 47 of 84 

-EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

date that the previous performance test was required to be completed [40 

CFR 60.255@)2]. 

As an alternative to (I) and (2) above, the permittee may elect to: 

(a) Conduct one daily 15-second observation each operating day for 

each affected facility (during normal operation) when the coal 

preparation and processing plant is in operation. Each observation 

must be recorded as either visible emissions observed or no visible 

\ emissions observed. Each observer determining the presence of 

visible emissions must meet the training requirements specified in 

CFR 60, Appendix A-7, Method 22(2.3). If visible emissions are 

d observation, the permittee must 

operation of the affected facility and demonstrate within 

ns are observed from the affected 

ible emissions are observed, a Method 9, of 40 CFR 

A-4, performance test must be conducted within 45 

visual observations of all process and control 

deficiencies are observed, the necessary 

ed as expeditiously as possible; and 

using Method 9 of 40 CFR 60, 

every 5 calendar years for each affected 

As an alternative to (1)-(3) a ay prepare a written 

site-specific monitoring plan mpliance system for 

approval by the Division. Th in accordance with 

40 CFR 60.255(f)(2). 

As an alternative to (1)-(4) install, operate, and 

maintain a continuous opac MS). Each COMS 

must be installed, calib nuously operated 

according to the require and (2) 140 CFR 

60.255(g)]. 

If any affected coal processing and conveying equipment 

screens, conveying systems), coal storage systems, or coal 

are enclosed in a building, and emissions from the 

standards in 40 CFR 60.254 that apply to the 

deemed to be in compliance with such standards [40 CFR 60.255(c)]. 

Testing shall be conducted in accordance with 401 KAR 50:045, Performance Test Z 

In conducting performance tests the permittee shall use as reference methods 

procedures the test methods in 40 CFR 60.257. 
Permit Number: V-05-070 R3 Page 48 of 84 

CTION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

Refer a 3. test in^ Reauirementn. 

on-site and make it 

and the date and time 

Its of those activities. 

all be noted [40 CFR 

I preparation and processing plant visual 

ith visible emissions along with corrective 

actions taken to visible emissions along with corrective actions taken to 

actions should be noted [40 CFR 60.2581. 

- each calendar month [40 CFR 60.2581. 

plan for a digital opacity compliance 

that the plan was implemented as described. 

be noted 140 CFR 60.2581. 

eed the applicable standard [40 CFR 

b. The permittee shall maintain results of all tests and calculations [401 KAR 

52:020, Section 261. 

a. The permittee shall report semi-annually: 

i. all 6-minute average opacities that exceed standard [40 CFR 

60.7(c)]. 

ii. the results of initial performance tests, of 40 CFR 

60.8. 

b. After July 1, 201 1, within 60 days after the date of 

evaluation conducted to demonstrate compliance, the 

the US. EPA following the procedures in the 40 CFR 60.258(d). 

c. Refer to Section F for additional requirements. \ 

7. S~eciflc Control Eaui~ment O~eratiav Conditions \ 

a. Control equipment shall be operated and maintained in accordance with 

specifications and standard operating practices to ensure the 

compliance with applicable requirements 1401 KAR 50:055, Section 21. 
Pennit Number: V-05-070 R3 Page 49 of 84 

ON B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

of the control equipment shall be maintained [401 

c. Refer to Section E for additional re 
Permit Number: V-05-070 R3 Page 50 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emission 9 Unit 15 - Coal Stockpile Storage and Handling 

A~~Umble R~aiations: 

401 KAR60:OQS incarpmating 40 Standards of performance for new 

stationary CFR 60 Subpart Y, Standards of 

401 KAR51:017 air qnality, applicable to major 

September 22, 1092. 

1. O~eratiag Limitations \ 

a. The permittee shall install and use control as BACT. BACT for 

PM.PMdPM2.s is application of wet and the use of a 

lowering well and compaction for 

b. The permittee shall preparc and operate in accordance 

dust emissions control plan as specified in 40 CFR 60.254tc). 

i. The plan shall be submitted to the Division prior to 

ii. The plan shall be revised to reflect any changing 

be dated and submitted to the Division before the 

these revisions. The Division may also object to 

CFR 60.254tc). 

Compliance Demonstration Method: 

Refer to Section F.9 for compliance reporting. 

2. Emwin Limitations \ 

Except for equipment used in the loading, unloading, and conveying operations of 

storage piles, the permittee shall not cause to be discharged into the atmosphere any 

which exhibit 10 percent opacity or greater [40 CFR 60.254(b)(l)]. 

Compliance Demonstration Method: \ 
Permit Number: V-05-070 R3 Page 51 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

R r to 3. test in^ Reaairements. t . . 

observation each operating day for each 

I operation) when the coal preparation and 

Each observation must be recorded as either 

a Method 9 of 40 CFR 60, 

according to the requirements in 40 CFR 60.255(g). 

b. If any affected coal processing and conveying equipment (e.g., breakers, 

screens, conveying systems), coal storage systems, or coal transfer and 

are enclosed in a building, and emissions Eom the building do not 
Permit Number: V-05-070 R3 Page 52 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

in 40 CFR 60.254 that apply to the affected facility, then the facility shall be 

eemed to be in compliance with such standards. 

erations, the permittee shall: 

test using Method 9 in 40 CFR 60, Appendix A-4 

taken during the duration of three separate truck 

ump event commences when the truck bed begins 

n the truck bed returns to a horizontal position. 

e opacity limit is determined by averaging all 

e during the duration of three separate truck 

of all process and control equipment. If any 

ssary maintenance must be performed as 

hod 9 of 40 CFR 60 Appendix A at least 

d facility 140 CFR 60.255(h)]. 

d. Testing shall be conducted in accor ce with 401 KAR 50:045, Performance Tests. Y 

e. In conducting performance tests the shall use as reference methods and 

procedures the test methods in 40 CFR 

Refer to 3. Testiae Reauirements. \ 

1. 

ii. 

iii. 

iv. 

v, 

vi. 

a. The permittee shall maintain a logbook (written or el tronic) on-site and make it 

available upon request. The logbook shall record the followi 

The manufacturer's recommended maintenance proce \ res and the date and time 

of any maintenance and inspection activities id the 

Any variance from manufacturer recommendation, if 

The date and time of periodic coal preparation a 

observations, noting those sources with visible emi 

actions taken to reduce visible emissions. Results 

The amount and type of coal processed each calendar month. 

The amount of chemical stabilizer or water pu 

preparation and processing plant. 

Monthly certification that the dust suppressant sy 

any coal was processed and that manufacturer's re 

for all control systems. Any variance fiom the m 

if any, shall be noted. 

Monthly certification that the fugitive coal dust emissions control plan was 

implemented as described. Any variance fiom the plan, if any, shall be noted. A 
Permit Number: V-05-070 R3 Page 53 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

copy of the applicable figitive coal dust emissions control plan and any letters 

from the Division providing approval of any alternative control measures shall be 

maintained with the logbook. Any actions, e.g, objections, to the plan and any 

to the alternative control measures, e.g. approvals, shall be noted 

cable monitoring plan for a digital opacity compliance 

ification that the plan was implemented as described. 

any, shall be noted [40 CFR 60.258(a)]. 

a. The permittee shall report all 6-minute average opacities that exceed the 

applicable standard [40 

b. The permittee shall submit the tests to the Division, 

consistent with the provisions of If the permittee elects to comply 

with the reduced performance 3b. Testing the permittee shall 

include in the performance test each affected facility that will be 

subject to the reduced testing 

c. After July 1, 201 1, within 60 days after the each performance 

evaluation conducted to demonstrate submit test data to 

the U.S. EPA following the 

d. Refer to Section F for additional requirements. \ 

7. Swific Cootrol Eaabme~t Qnemtina Co . . ndl;tloug \ 

a. Control methods and equipment shall he operated and maintained to 

unit is in compliance with the applicable requirements of 401 

50:055 and 401 KAR 51:017]. 

b. Records regarding the maintenance of the control equipment shall be 

KAR 52:020, Section 261. 

c. Refer to Section E for additional requirements. \ 
Permit Number: V-05-070 R3 Page 54 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

GULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

~m*os Unit 16. - Limestone Silo Storage and Handling 

. . - - - . - - - - - filter. 

CFB2 ~o'lo i~mission Unit l~j and CPBZ Limestone Sib @mission Unit 1602jm. dumd to same fabric filter. 

Unit X 

rating 40 CF'R Part 60, Standards of performance for new 

sources, specifically 40 CFR 60 Subpart 000, Standards of 

ance for Nonmetatlk Mineral Processing Plants 

401KAR51:017 Preve of sigoiflcant deterioration of air quality, applicable to major 

Note: CFBl CAI Silo Emission Unit 14131\ and CEBl Limestone Silo (Emission Unit 16-011 em ducted to same fabric 

40 tonslhour 

40 tonshour 

16-0 1 

16-02 

constructidq or modification commenced after September 22,1982. 

XFBl Limestone Silo 

~m2 Limestone Silo 

The permittee shall install selected as BACT. BACT for PMIPMldPM2.5 is 

a fabric filter [401 KAR 5 1 :01n. 

Fabric Filter 

Fabric Filter 

Compliance Demonstration 

Refer to Section F.9 for 

Commenc~ 

Estimated 201 0 

Estimated 20 10 

a. Particulate matter (PM/PMldPM2,s) each stack shall not exceed: 

i. 0.005gr/dscf[401KAR51:017]. 

ii. 0.51 Ibskour on a 24-hour from each limestone silo [NAAQS]. 

Compliance Demonstration Method: 

Refer to 3. Testing Reamiremen$ shall constitute compliance 

with 2a.ii. 

b. If any transfer point on a conveyor belt or any other is enclosed in a 

building, then each enclosed affected facility must limits in 40 

CFR 60.672(e). 

Compliance Demonstration Method: 

Refer to 3. test in^ Reauirements. 

test in^ Reauirements \ 

a. The permittee shall demonstrate compliance with emission standards 

after achieving the maximum production rate at which the affected 

operated, but not later than 180 days after initial startup [401 KAR 

2(l)(a), 40 CFR 60.6724 40 CFR 60.8,40 CFR 60.1 11. 
Permit Number: V-05-070 R3 Page 55 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

In conducting performance tests the permittee shall use as reference methods and 

rocedures the test methods in 40 CFR Part 60 Appendix A or other methods and 

ures as specified in 40 CFR 60.675. 

4.d., the permittee shall conduct quarterly 30-minute 

EPA Method 22 (40 CFR part 60, Appendix A-7) 

22 test shall be conducted while the fabric filter is 

no visible emissions are observed. If any visible 

shall initiate corrective action within 24 hours to 

The owner or operator must record each 

corrective actions taken, in the logbook 

b. The permittee fabric filter-specific success level for the visible 

emissions test by following the procedures in 40 CFR 

60.674(c). 

c. As an alternative to emissions inspections specified in 

Subsection 4.a. The system. The permittee shall 

install, operate, and according to 40 CFR 60,674 

(d)(l) through (3) [40 CFR 

a. The permittee shall record each periodic by 4.a. Saeciflq 

Monitoring Reuolremeetp, including dates actions taken, in a 

logbook (in written or electronic the logbook onsite 

and make hard or electronic copies avaiIable to 

the Division upon request [40 CFR 

b. For each bag leak detection system installed and operated, 

records specified below 140 CFR 60.676(b)(2): 

i. Records of the bag leak detection system output; 

ii. Records of bag leak detection system adjustments, in 

the adjustment, the initial bag leak detection syste 

leak detection system settings; and 

iii. The date and time of all bag leak detection 

procedures to determine the cause of the alarm 

alarm, an explanation of the actions taken, the 

alarm was alleviated, and whether the cause oft 

hours of the alarm. 
Permit Number: V-05-070 R3 Page 56 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

records related to pressus drop strip recorder (or other 

device) charts and shall keep the logbook onsite and make hard or 

is requested) of the logbook available to the Division upon 

a. The permittee reports of the results of all performance tests 

conducted to demon the standards in 40 CFR Subpart 000, 

including [40 CFR 60.676(f)]. 

b. The 40 CFR Subpart A requi a)(l) for notification of the date 

construction or reconstructi for these emission units. A 

notification of the actual d cted facility shall be submitted 

to the Division. For a co n a production line that begin 

actual initial startup on of startup may be submitted. 

The notification shall such date and shall include a 

description of each , and serial number of the 

equipment, if available [40 CFR 60.67601) and (i)]. 

c. Refer to Section F for additional requirements. \ 

7. S~ecific Control Eaui~ment O~eratina Conditions \ 

a. Control equipment shall be operated in accordance with 

and standard operating practices to maintain compliance 

and [401 KAR 50:055, Section 21. 

b. Records regarding maintenance of the control equipment shall be maintained 

52:020, Section 261. 

G. Refer to Section E for additional requirements. 
Permit Number: V-05-070 R3 Page 57 of 84 . CTION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE t RE ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emission Unit 16b - Lime Silo Storage and Handling \ 

Fabric Fitter 1 Estimated 2010 

I 

Fabric Filter Estimated 201 0 

I 

Fabric Filter I Estimated 20 10 

Annlica ble 

401 KAR 59010 to each affected facility or source 

401 KAR 5 1:017 

40 CFR Part 64 from the fiesh 

The permittee shall install control equipment BACT for PM/PMlflM2.s is 

a fabric filter [401 KAR 51:017]. 

2. Emission Limitations \ 

a. Opacity firom each stack shall not exceed 7 percent [401 9 51:017]. 

Compliance Demonstration Metbod: 

Refer to 3. Testing Reauiremeats. Compliance with the shall constitute 

compliance with 401 KAR 59:010, Section 3(1). 

b. Particulate matter (PM/PMl~M2.s) emissions fiom each stack shall 

i. 0.005 gr/dscf [4Ol KAR 5 1 :01TJ. 

ii. 0.30 Ibdhour on a 24-hour block average fiom each fiesh lime 

iii. 0.17 Ibdhour on a 24-hour block average ftom each recycled 

iv. 0.02 Ibshour on a 24-hour block average fiom each scrubber 

Compliance Demonstration Method: 

Refer to 3. Testing Reaufrements. Compliance with 2b.i. shall constitute 

with 2b.ii. through 2b.iv. and 401 KAR 59:010, Section 3(2). 
Permit Number: V-05-070 R3 Page 58 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

GULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

tin R uirem ts 

3* w 

e permittee shall demonstrate compliance with emission standards within 60 days 

the maximum production rate at which the aff'ected facility will be 

later than 180 days after initial startup [401 KAR 50:055, Section 

b. In conduc 'ng performance tests the permittee shall use as reference methods and 

procedures a t test methods in 40 CFR Par& 60 Appendix A, 

a. The permittee 30-minute visible emissions inspections using 

A-7) for each fabric filter. The Method 22 

is operating. The test is successfbl if no 

are observed, the permittee shall 

fabric filter to normal operation. 

test, including the date and any 

KAR 52:020, Section 261. 

b. Pressure drop across the fabric through the use of a strip 

recorder or other continuous shall maintain strip 

recorder (or other of out-of-range 

indications, the the reason for 

the exceedance 

Part 64,401 KAR 52:020, Section 261. 

a. The permittee shall record each periodic inspection Subsection 4.sr, 

S~eciflc Monitorinn Reauiremenb, including dates actions taken, 

in a logbook (in written or electronic format). The 

onsite and make hard or electronic copies 

available to the Division upon request [40 

b. The permittee shall maintain records related to pressure drop strip 

continuous recording device) charts and shall keep the logbook 

electronic copies (whichever is requested) of the logbook 

request [40 CFR Part 64,401 KAR 52:020, Section 261. 

c. As an alternative to the periodic Method 22 visible emissions inspections 

Subsection 5.a., and the pressure drop strip recorder in Subsection 5.b., 

may use a bag leak detection system. The permittee shall install, operate, 

the bag leak detection system according to 40 CFR 60.674 (d)(l) through 

Part 64,401 KAR 52:020, Section 261. 
Permit Number: V-05-070 R3 Page 59 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

6. SD&& Re~ortinv Reauirementq 

written reports of the results of all performance tests 

with the standards in 2. Emission Limitations, 

[401 KAR 52:020, Section 261. 

b. Refer to Section F for ad ' 'onal requirements. '"\ 

7. S~ecifCc Control Eaui~rnent ~~eratk~ondition~ 

a. Control equipment shall be operated manufacturer's specifications 

and standard operating practices to permitted emission limits 

and [401 KAR 50:055, Section 21. 

b. Records regarding maintenance of the control equipment [401 KAR 

52:020, Section 261. 

c. Refer Section E for additional requirements. \ 
Permit Number: V-05-070 R3 Page 60 of 84 

ION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDJTXONS (CONTINUED) 

Emissi s Unit 17 - Limestone Unloading and Storage 'Y 

rage Pik Fugitive 

A~ali-le R-lrtioPr: 

401 KAR 63:010 Fugitive to each affected facility which emits or may 

not elsewhere subject to an opacity standard 

of the Division for Air Quality; 

401 KAR 51:017 of air quality, applicable to major 

September 22, 1982. 

17-02 

a. The permittee shall use control as BACT. BACT for PM/PMrdPM2.5 

is the application of wet [401 KAR 5 1:017J. 

Operating 

Rate 

44 tonshour 

b. The permittee shall not cause, suffer, or to be handled, processed, 

transported, or stored; a building or its &xed, repaired, 

or demolished, or a road to be used to prevent 

particulate matter fiom becoming 

when applicable, but not be limited to the following: 

\ 

~nloadinghgmdling 

Limestone St le Fugitive 

1. 

ii. 

iii. 

iv. 

v. 

vi. 

Control Devices 

Wet Suppression 

or Dust 

use, where possible, of water or chemicals for 

existing buildings or structures, construction o 

clearing of land; 

Application and maintenance of asphalt, oil, 

materials stockpiles, and other svfaces whic 

Installation and use of hoods, fans, and 

handling of dusty materials, or the use 

suppress the dust emissions during handli 

be employed during sandblasting or other 

Covering, at all times when in motion, o 

likely to become airborne; 

The maintenance of paved roadways in a clean condition; 

The prompt removal of earth or other m 

other material has been transported th 

or erosion by water [401 KAR 63:Ol 

Construction 

Commend 

Estimated 2010 

44 tonshour 

Suppressant 

Wet Suppression 

or Dust 

Suppressant 

Estimated 2010 
Permit Number: V-05-070 R3 Page 61 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

shall cause or permit the discharge of visible fbgitive dust emissions beyond the 

property on which the emissions originate [401 KAR 63:010, Section 31. 

stration Method: 

iflc Control Eaniument Oueratin~ Conditions and Section ~:9 for 

None. \ 

40 CFR 60, Appendix A, be used to determine opacity upon request by the 

Division. 

The permittee shall perform qualitative on a weekly basis and maintain a 

log of the observations and corrective Section 261. 

5. Rc~ottian and RccordkaDfon ReaoircmeaQ \ 

The permittee shall maintain a log of the date, time, the monitoring required in 

4. Monitorlnn. Reaairernents and the use and dust duppressant 

[401 KAR 52:020, Section 263. 

Refer to Section F. \ 

7. Swciflc ContreC Eauiument Omratha Conditions \ 

a. Wet or dust suppressant shall be used to ensure the emission unit is in co 

the applicable requirements of 401 KAR 63:010 [401 KAR 50:055 

51:017]. 

b. Refer to Section E for additional requirements. \ 
Permit Number: V-05-070 R3 . Page 62 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

Emissions nit 18 - Cooling Towers \ 

A~eNcable Reealrrtions: 

401 KAR 63:010 to each affected facility which emits or 

is not elsewhere subject to an opacity 

regulations of the Division for Air 

Quality; 

401 KAR 51:017 of air quality, applicable to 

after September 22, 1982. 

Non-Aoalicable Rermlatiog! 

40 CFR 63, Subpart Q National Emission Hazardous Air Pollutants for 

Industrial Process 

1. om rat in^ Limitations \ 

a. The permittee shall install control methods BACT. BACT for 

PMPMldPM2.5 is 0.0005% Drift Eliminators 1401 

b. The permittee shall not cause, suffer, or allow any material 

transported, or stored; a buiMing or its appurtenances to be 

or demolished, or a road to be used without taking 

particulate matter hm becoming airborne [401 KAR 63:O 10, Section 31. 

c. No person shall cause or permit the discharge of visible 

lot line of the property on which the emissions originate 

d. To preclude applicability of 40 CFR 63, Subpart Q, the permittee shall not 

chromium-based water treatment chemicals in the cooling towers. [40 CFR 63.4021 

Compliance Demonstration Metbod: 

Refer to 4. S~ecific monitor in^ Reauirements, 7. Swific Control Eaainment Owrating 

Conditions and Section F.9 for compliance reporting. 
Permit Number: V-05-070 R3 Page 63 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

ULATIONS, AND OPERATING CONDJTIONS (CONTINUED) 

a ~hhqoolin~ tower shall utilize 0.0005% Drift Eliminators 1401 KAR 5 1 :017J 

shall be taken to prevent particulate matter fnrm becoming 

airborne. 

Compliance Method: For compliance with Subsection 2.a., refer to 3. 

with Subsection 2.a., constitutes compliance with 2.b. 

3. test in^ Reauirements \ 

The permittee shall conduct an i 'tial performance test based on Cooling Technology Institute 

(CTI) Acceptance Test Code (A ) #I40 to verify drift percent achieved by the drift 

eliminator. k 

The permittee shall monitor total dissolv content of the circulating water on a 

monthly basis [401 KAR 52:020, Section 

5. S~ccifk Record Kee~ing Reauirements \ 

the permittee 

pliance status 

least 5 years 

b. The permittee shall maintain records of the manufac design of the Drift 

Eliminators [401 KAR 52:020, Section 261. 

c. The permittee shall maintain records of maximum pumping and monthly 

records of the total dissolved solids content [401 KAR 52:020, 

6. Specific Rewrtin~ Reauirements \ 

Refer to Section F for additional requirements. \ 

7. Smcific Control Eauiumtnt Omratinn Conditions \ 

a. Pursuant to 401 KAR 50:055, Section 5, the drift eliminators shall be operat 

maintained in accordance with manufacturer's specifications and standard 

practices to ensure the emission units are in compliance with applicable requirement 

[401 KAR 50:055, Section 21. 

b. Refer to Section E for additional requirements. \ 
Permit Number: V-05-070 R3 Page 64 of 84 

B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

GULATIONS, AND OPERATING CONDITIONS (CONTINUED) 

Emiss ns Unit 19 - Haul Roads \ 

used as Haul Roads 

suppression as applicable. 

Estimated 201 0 

missions, applicable to each affected facility which emits or may 

ve emissions and is not elsewhere subject to an opacity standard 

histrative regulations of the Division for Air Quality; 

401KAR51:017 Preventi significant deterioration of air quality, applicable to major 

edification commenced after September 22, 1982. 

a. The permittee shall methods selected as BACT. BACT for 

PM.PMI~PM~.s is or prompt removal of material, and the 

application of wet KAR 5 1 :Of 71. 

b. The permittee shall not cause, s material to be handled, processed, 

transported, or stored; a buil to be constructed, altered, repaired, 

or demolished, or a road to 

particulate matter fkom beco 

when applicable, but not be limit 

i. Use, where possible, of water or chemi trol of dust in the demolition of 

existing buildings or structures, construction ions, the grading of roads or the 

clearing of land; 

ii. Application and maintenance of asphalt, oil, w 

materials stockpiles, and other surfaces which c 

iii. Installation and use of 

handling of dusty other measures to 

suppress the dust emi 

be employed during sand 

iv. Covering, at all times w 

likely to become airborne; 

v. The maintenance of paved roadways in a clean condition; 

vi. The prompt removal of earth or other material from a paved street w 

other material has been hutsported thereto by trucking or earth moving 

or erosion by water (401 KAR 63:010, Section 31. 

c. No person shall cause or permit the discharge of visible hgitive dust emissions beyond 

lot line of the property on which the emissions originate [401 KAR 63:010, Section 31. 
Permit Number: V-05-070 R3 Page 65 of 84 

CTION B -EMISSION POINTS, EMISSIONS UNITS, APPLICABLE 

AND OPERATING CONDITIONS (CONTINUED) 

pliance Demonstration Method: 

S~ecific monitor in^ Reanirements, 7. Swific Control Eaaiument O~eratinp 

and Section F.9 for compliance reporting. 

None. \ 

Method 22 of 40 CFR 60hppendix A, shall be used to determine opacity upon request by the 

Division. \ 

The permittee shall perform qualita 've visual observations on a weekly basis and maintain a 

log of the observations and corrective a ions [401 KAR 52:020, Section 261. 

The permittee shall maintain a log of the da time, and results of the monitoring required in 

4. Suecific Monitorinn Rcaairemenb [401 & 52:02O, Section 261. 

See Section F. \ 

7. S~cciflc Control Eauiment O~eratinn Conditions \ 

a. The wet suppression shall be used to ensure haul in compliance with the 

applicable requirements of 401 KAR 63 :0 10 140 1 401 KAR 5 1 :017]. 

b. Records regarding the maintenance of the control equipment maintained [401 

KAR 52:020, Section 261. 

c. See Section E for additional requirements. \ 
Permit Number: V-05-070 R3 Page 68 of 84 

SECTION D - SOURCE EMISSION LIMITATIONS AND TESTING 

REQUIREMENTS 

1. As required by Section 1 b of the Cabinet Provisions and Procedures for Issuing Title V 

Permits incorporated by reference in 401 KAR 52:020, Section 26; compliance with annual 

. emissions and processing limitations contained in this permit, shall be based on emissions and 

processing rates for any twelve (1 2) consecutive months. 

2. Nitrogen oxides, sulfbr dioxide, particulate matter (PMlPM,dPM2.5), opacity, volatile organic 

matter, carbon monoxide emissions, sulfiuic acid mist, mercury, hydrogen chloride, and other 

hazardous air pollutants measured by applicable reference methods, or an equivalent or 

alternative method specified in 40 CFR Chapter I, or by a test method specified in the state 

implementation plan shall not exceed the respective limitations specified herein. 
-. Permit Number: V-05-070 R3 Page 76 of 84 a 

SECTION G - GENERAL PROVISIONS (CONTINUED) 

4. Construction, Start-Uv. and Initial Com~liance Demonstration Reauirements 

Pursuant to a duly submitted application the Kentucky Division for Air Quality hereby 

authorizes the construction of the equipment described herein, :: in 

accordance with the terms and conditions of this permit. 

a. Construction of any process and/or air pollution control equipment authorized by this permit 

shall be conducted and completed only in compliance with the conditions of this permit. 

b. Within thirty (30) days following commencement of construction and within fifteen (15) 

days following start-up and attainment of the maximum production rate specified in the 

permit application, or within fifteen (1 5) days following the issuance date of this permit, 

whichever is later, the permittee shall fiunish to the Regional Office listed on the fiont of 

this permit in writing, with a copy to the Division's Frankfort Central Ofice, notification of 

the following: 

(1) The date when construction commenced. 

(2) The date of start-up of the affected facilities listed in this permit. 

(3) The date when the maximum production rate specified in the permit application was 

achieved. 

c. Pursuant to 401 KAR 52:020, Section 3(2), unless construction is commenced within 

eighteen (1 8) months after the permit is issued, or begins but is discontinued for a period of 

eighteen (18) months or is not completed within a reasonable timefiame then the 

construction and operating authority granted by this permit for those affected facilities for 

which construction was not completed shall immediately become invalid. Upon written 

request, the Cabinet may extend these time periods if the source shows good cause. 

d. For those affected facilities for which construction is authorized by this permit, a source 

shall be allowed to construct with the proposed permit. Operational or final permit approval 

is not granted by this permit until compliance with the applicable standards specified herein 

has been demonstrated pursuant to 401 KAR 50:055. If compliance is not demonstrated 

within the prescribed timefiame provided in 401 KAR 50:055, the source shall operatc 

thereafter only for the purpose of demonstrating compliance, unless otherwise authorized by 

Section I of this permit or order of the Cabinet. 

e. This permit shall allow time for the initial start-up, operation, and compliance demonstration 

of the affected facilities listed herein. However, within sixty (60) days after achieving the 

maximum production rate at which the affected facilities will be operated but not later than 

180 days after initial start-up of such facilities, the permittee shall conduct a performance 

demonstration on the affected facilities in accordance with 401 KAR 50:055, General 

compliance requirements. Testing must also be conducted in accordance with General 

Provisions G.5 of this permit. 

f. Terms and conditions in this permit established pursuant to the construction authority of 401 

KAR 5 1:017/51:017E or 401 KAR 5 1 :052 shall not expire. 
Permit Number: V-05-070 R3 

SECTION J - ACID RAIN 

ACID RAIN PERMlT CONTENTS 

Page 82 of 84 

Statement of Basis 

SOz allowances allocated under this permit and NOx requirements for each affected unit. 

Comments, notes and justifications regarding permit decisions and changes made to the permit 

application forms duringthe review process, and any additional requirements or conditions. 

The permit application submitted for this source. The owners and operators of the source 

must comply with the standard requirements and special provisions set forth in the Acid Rain 

Permit Application and the CAIR Permit Application. 

Summary of Actions 

Statement of Basis: 

Statutory and Regutatory Authorities: The Energy and Environmental Cabinet, Division 

for Air Quality issues this permit pursuant to 401 KAR 52:020, Title V permits, 401 KAR 

52:060, Acid rain permits, and 40 CFR 76 and in accordance to KRS 224.10-1 00 and Titles IV 

and V of the Clean Air Act. 

SOt allowances allocated under this permit and N& requirements for each amted 

unit. 

Plant Name: J. K. Smith Generating Station, East Kentucky Power Cooperative, Inc. 

I Affected Unit.: EU 0 1 (SCT 0 1) - EU 07 (SCT 07), EU 09-10, I 

[ NOx Requirements I 

SOz Allowances 

Tables 2,3 or 4 of 

40 CFR Part 73 

1 There is no Emission Unit 8. 

I I 

Year 

NO, Limits 

2006 

0 

N/A 

2007 

0 

2008 

0 

2009 

0 

2010 

0 
9 Permit Number: V-05-070 R3 

b 

SECTION J - ACID RAIN 

Page 83 of 84 

3. Comments, Notes, and Justifications: 

a. The nine combustion turbines, Emission Units 01 - 07, 09-17 I I 

l I mtlcWI, currently have no SOz allowances 

allocated by US. EPA. 

b. The nine combustion turbines, Emission Units 01 - 07 , 09-10, ae, . * . . do not have applicable NOx limits set by 

40 CFR Part 76. 

4. Permit Applicatior: 0 

'The Acid Rain Permit Application and CAIR Permit Application are a part of this permit and 

the source must comply with the standard requirements and special provisions set forth in the 

applications. 

5. Summary of Actions: 

a: Past Action: 

i. DraA Phase I1 Permit (#V-05-070) was advertised for public comment March 20, 

2006. The Phase I1 Final Permit (#V-05-070) was issued on August 1,2006. 

ii. An Acid Rain Permit Application for Emission Units 09 and 10 was received on 

February 19, 2008 and the CAIR Permit Application for these units was received 

on Febnrary 26, 2008. Draft Permit V-05-070R1 was advertised for public 

comment on July 12,2008 and a final permit was issued on October 22,2008. 
$ Pemit Number: V-05-070 R3 

& 

Page 84 of 84 

SECTION K - Clean Air Interstate Rule (CA.) 

1) Statement of Basis 

Statutory and Regulatory Authorities: In accordance with ,KRS 224.10-100, the 

Kentucky Energy and Environment Cabinet issues4& permit pursuant to 401 KAR 52:020, 

Title V permits, 401 KAR 51:210, CAIR NOx Annual Trading Program, 401 KAR 51:220, 

CAIR NOx Ozone season trading program, and 401 KAR 51:230, CAIR SO2 Trading 

Program. 

2) CAIR Application 

The CAIR application for nine electrical generating units was submitted to the Division and 

received on February 26, 200&& 

Requirements contained in that application are hereby incorporated into and made part of 

this CAIR Permit. Pursuant to 401 KAR 52:020, Section 3, the source shall operate in 

compliance with those requirements. 

3) Comments, notes, justifications regarding permit decisions and changes made to the 

permit application forms during the review process, and any additional requirements 

or condition& 

The affected units are nine simple cycle combustion turbines (EU 01-EU07, EU 9 and 10) 

11 used for electrical power 

production. Each unit has a nameplate capacity to generate greater than 25 megawatts of 

electricity, which is offered for sale. The combustion turbines use natural gas (at least 90 

percent of the time) as a primary fuel source and he1 oil (not more than 10 percent of the . . . . time) as a secondary source. 

4) Summary of Actions 

The CAIR Permit is being issued as part of the Title V permit for this source. Public, 

affected state, and U.S. EPA review shall follow procedures specified in 401 KAR 52: 100. 
ATTACHMENT 2 
Commonwealth of Kentuclry 

Energy and Environment Cabinet 

Department for Environmental Protection 

Division for Air Quality 

200 Fair Oaks Lane, 1st Floor 

Frankfort, Kentucky 40601 

1 Administrative 

Information 

AFS Phnt ID# 

(502) 564-3999 

http://www.air.ky.gov/ 

PERMIT APPLICATION r 

Tbe completion of this form is required under Regalations 401 KAR 52:020,52:030, and 52:040 pumnt 

to KRS 224. Applications are incomplete ualcu accompanied by copies of all plans, spcciflcations, and 

drawings requested herein. Failure to supply information required or deemed necessary by tbe division 

to enable it to act upon the application shdl result in denial of the pennit and ensuing administrative and. 

legal action. Applications shall be submitted in triplicate. 

v 

11 APPLICATION INFORMATION 

Note: The applicant must be the owner or operator. (?be ownerlopcrator may be individual(s) or a corporation.) 

Name: East Kentucky Power Cooperative, Inc. 

Title: Phone: 859-744-4812 

(~f apptiunt Is m indlvidnal) 

Mailing Address: East Kentucky Power Cooperative, Inc. 

Company 

Street or P.O. Box: 4775 Lexington Road, P.O. Box 707 

City: Winchester State: KY Zip Code: 40392-0707 

Is the applicant (check one): Owner Operator Owner & Operator 0 Corporation/LLC* LP*i 

* If the applicant is a Corporation or a Limited Liability Corporation, submit a copy of the current Certificate of Authority from thc 

Kentucky Secretary of State. ON FILE 

** If the applicant is a Limited Partnership, submit a copy of the current Certificate of Limited Partnership from the Kentucky Secretaq 

of State. 

Person to contact for technical information relating to application: 

Name: Jerry Purvis 

Title: Manager of Environmental Affairs Phone: 859-745-9244 

2) OPERATOR INFORMATION 

Note: The applicant must be the owner or operator. (The ownmlopcrator may be individual(s) or a corporation.) 

Name: East Kentucky Power Cooperative, Inc. 

Title: Phone: 859-744-4812 

Mailing Address: East Kentucky Power Cooperative, Inc. 

Company 

Street or P.O. Box: 4775 Lexington Road, P.O. Box 707 

City: Winchester State: KY Zip Code: 40392-0707 

Page 1 A1 of A A1 

(Revised 1 1/08} 
,3) TYPE OF PERMIT APPLICATION 

For new sources that currently do not hold any air quality permits in Kentucky and are required to obtain a permit prior to construction I pursuant to 401 KAR R:OZO, 52:030, or 52:040. 

0 Initial Operating Permit (the permit will authorize both construction and operation of the new source) 

Type of Source (Check all that apply): a Major Conditional Major Synthetic Minor Minor 

For existing sources that do not have a sourcawide Operating Permit required by 401 KAR 52:020,52:030, or 52:040. 

I Type of Source (Check all that apply): C] Major Conditional Major Synthetic Minor [7 Minor 

I (Check one onlyl 

[7 Initial Source-wide Operating Permit Modification of Existing Facilities at Existing Plant 

I Consbuction of New Facilities at Existing Plant 

Other (explain) 

For existing sources that currently have a source-wide Operating Permit. 

Type of Source (Check all that apply): a Major Conditional Major Synthetic Minor Minor 

Current Operating Permit # V-05-070 R3 

17 Administrative Revision (describe type of revision requested, e.g. name change): 

Permit Renewal C] Significant Revision Minor Revision 

Addition of New Facilities Modification of Existing Facilities 

For all construction and modification requiring a permit pursuant to 401 KAR 52:020,52:030, or 52:040. 

I Proposed Date for Start Proposed date for 

of Construction or Modification: not applicable Operation Start-up: not applicable 

4) SOURCE INFORMATION 

I Source Name: J.K. Smith Generating Station I source street AM-: 12145 Irvine Road 

I City: Winchester Zip Code: 40391 County: Clark 

Primary Standard Industrial 

Classification (SIC) Category: Electric Power Generation Primary SIC #: 4911 

Property Area Number of 

(Acres or Square Feet): approx. 3,200 acres Employees: 8 

Description of Area Surrounding Source (check one): 

Commercial Area Residential Area C] Industrial Area CI] Industrial Park IXj Rural Area C] Urban Area 

Approximate Distance to Nearest 

Residence or Commercial Property: approx. 1 mile 

UTM Standard Location Coordinates: (Include topographical map showing property boundaries) 

I UTM Coordinates: Zone 16 Horizontal (krn) 754.7 Vertical (lun) 4 1 96.8 I Standard Coordinates: Latitude Degrees Minutes Seconds 

Longitude Degrees Minutes Seconds 

Page 2 A1 of A1 

(Revised 1 1/08) 
1) SOURCE INFROMATION (CONTINUED) 

[s any part of the source located on federal land? Yes No 

What other environmental permits or registrations doea this source currently hold in Kentucky? 

KPDES Permit 

Underground Storage Tank Permit 

What other environmental permits or registrations does this source need to obtain in Kentucky? 

None 

5) OTHER REQUIRED INFORMATION 

Indicate the type(s) and number of forms attached as part of this application. NIA 

- DEW007A Indirect Heat Exchanger, Turbine, Internal ,, DEP7007R Emission Reduction Credit 

Combustion Engine ,, DEP7007S Service Stations 

,, DEP7007B Manufacturing or Processing Operations - DEP7007T Metal Plating & Surface Treatment Operations 

DEP7007C Incinerators & Waste Burners - DEP7007V Applicable Requirements & Compliance , DEP7007F Episode Standby Plan Activities 

,, DEP7007J Volatile Liquid Storage - DEP7007Y Good Engineering Practice (GEP) Stack Height 

- DEP7007K Surface Coating or Printing Operations Determination 

- DEP7007L Concrete, Asphalt, Coal, Aggregate, Feed, - DEP7007AA Compliance Schedule for Noncomplying 

Corn, Flour, Grain, & Fertilizer Emission Units 

- DEW007M Metal Cleaning Degreasers ,, DEW007BB Certified Progress Report 

- DEP7007N Emissions, Stacks, and Controls Information - DEW007CC Compliance Certification 

- DEP7007P Perchloroethylene Dry Cleaning Systems - DEP7007DD Insignificant Activities 

Check other attachments that are part of this application. NIA 

Rewired Data 

Map or Drawing Showing Location 

Process Flow Diagram and Description 

Site Plan Showing Stack Data and Locations 

Emission Calculation Sheets 

Su~~lemental Data 

Stack Test Report 

Certificate of Authority from the Secretary of State 

(for Corporations and Limited Liability Companies) 

Certificate of Limited Partnership from the Secretary 

of State (for Limited Partnerships) 

Claim of Confidentiality (See 400 KAR 1 :060) 

C] Material Safety Data Sheets (MSDS) a Other (Specify) 

Indicate if you expect to emit, in any amount, hazardous or toxic materials or compounds or such materials into the atmosphere from any 

operation or process at this location. 

Pollutants regulated under 401 KAR 57:002 (NESHAP) ti4 Pollutants listed in 401 KAR 63:060 (HAPS) 

rXj Pollutants listed in 40 CFR 68 Subpart F [112(r) pollutants] 0 Other 

Has your company filed an emergency response plan with local andlor state and federal officials outlining the measures that would be 

implemented to mitigate an emergency release? 

a yes IXI NO 

Check whether your company is setking coverage under a permit shield. If "Yes* is checked, applicable requiremenb must be identified on 

Form DEWOO'N. Identify any non-applicable requirements for which you are seeking permit shield coverage on a separate attachment to 

the application. 

Yes El No A list of non-applicable requirements is attached 

Page 3 A1 of 4 A1 

(Revised 1 1/08) 
6) OWNER INFORMATION 

I Note: If the applicant is the owner, write "same as applicant" on the name line. 

( Name: Same as applicant 1 Title: Phone: 

I Mailing Address: 

Company 

I Street or P.O. Box: 

City: State: Zip Code: 

List names of owners and officers of your company who have an interest in the company of 5% or more. 

- Name Position (owner. ~artner, resident. CEO, treasurer, etc.) 

(attach another sheet if necessary) 

7) SIGNATURE BLOCK 

I, the undersigned, hereby certify under penalty of law, that I am a responsible official, and that I have personally 

I examined, and am familiar with, the information submitted in this document and all its attachments. Based on my inquiry 1 of those individuals with primary responsibility for obtaining the information, I certify that the information is on 

I knowledge and belief, true, accurate, and complete. I am aware that then are significant penalties for submitting false or 

I incomplete information, including the possibility of fine or imprisonment. 

BY: 

/ (~'uthorized Signature) 

Jerry Purvis 

(Typed or Printed Name of Signatory) 

Manager of Environmental Affairs 

(Title of Signatory) 

Page 4 A1 of A1 

(Revised 1 1/08) 
ATTACHMENT 3 
FORM FOR NOTICE TO AFFECTED STATES 

Pursuant to 401 KAR 52:020 Section 14(3)(e) and 401 KAR 52:100 Section 9(3)(a), 

please be advised that on December 3,201 0, East Kentucky Power Cooperative, Inc. 

(EKPC) applied to the Kentucky Division for Air Quality for a minor permit revision for 

Permit V-05-070 R3 to remove Emissions Units 1 1, 12, 13,14, 15, 16% 16b, 17, 18 and 

19 that will not be constructed at this time at the J. K. Smith Generating Station near the 

community of Trapp, Kentucky in Clark County. 
FORM FOR NOTICE TO U.S. EPA 

Pursuant to 401 KAR 52:020 Section 14(3)(e) and 401 KAR 52: 100 Section 9(3)(b), 

please be advised that on December 3,2010, East Kentucky Power Cooperative, Inc. 

(EKPC) applied to the Kentucky Division for Air Quality for a minor permit revision for 

Permit V-05-070 R3 to remove Emissions Units 1 1, 12,13,14,15, 16% 16b, 17,18 and 

19 that will not be constructed at this time at the J. K. Smith Generating Station near the 

community of Trapp, Kentucky in Clark County.