SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Emission Standards, Fuel Specifications, and Other Limitations

 1. This permit covers only those sources of emissions listed in the attached table entitled 

AEmission Sources - Maximum Allowable Emission Rates,@ (MAERT) and those sources 

are limited to the emission limits and other conditions specified in that attached table. 

Compliance with the annual emission limits shall be based on throughput for a rolling 

12-month year rather than the calendar year. This permit authorizes routine maintenance, 

startup, and shutdown (MSS) activities which comply with the emission limits in the 

MAERT. (4/12)

 2. Emission limits are based upon the permit application representations dated November 

2003, and subsequent submittals dated: July 2004 (Supplemental to Application), 

September 2004, (Air Quality Analysis), October 2004 (Air Quality Analysis Supplement)

and May 2007 (Amendment), January 2011 (Amendment). (4/12)

Federal Applicability

 3. These facilities shall comply with applicable requirements of the Environmental Protection 

Agency (EPA) regulations in 40 CFR Part 60 on Standards of Performance for New 

Stationary Sources promulgated for:

A. Applicable General Conditions, Subpart A.

B. The Spruce 2 Utility Boiler is subject to the applicable requirements of Subpart Da, 

Standards of Performance for Electric Utility Steam Generating Units.

C. The coal handling facilities shall comply with all applicable requirements of Subpart 

Y, Standards of Performance for New Stationary Sources promulgated for coal 

preparation plants.

D. The limestone handling facilities shall comply with all applicable requirements of 

Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. 

(8/09)

Utility Boiler Fuel Specifications, Operating Limitations, Performance Standards, and 

Construction Specifications

 4. Fuel fired in the Spruce 2 Utility Boiler shall be limited to: 

A. Low sulfur coal with a sulfur (S) content not to exceed an annual average of 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 2

0.625 pounds per million British Thermal Units (lbs/MMBtu) heat input and with the 

trace metal concentrations not to exceed the concentration limitation identified in 

Attachment C. (3/12)

B. Sweet natural gas as defined in Title 30 Texas Administrative Code Chapter 101

(30 TAC Chapter 101).

Use of any other fuel will require prior approval from the permitting authority. Upon 

request by the Executive Director of the Texas Commission on Environmental Quality

(TCEQ) or any air pollution control program having jurisdiction, the holder of this permit 

shall provide a sample and/or an analysis of the fuel fired in the utility boiler or shall allow 

air pollution control agency representatives to obtain a sample for analysis.

 5. The Spruce 2 Utility Boiler shall be limited to a maximum heat input of 8,000 MMBtu/hr, 

averaged over a calendar month, based on the higher heating value (HHV) of the fuel fired.

(11/07)

 6. Opacity of emission from the utility boiler must not exceed 10 percent as determined by

EPA Reference Method 9 or by a continuous opacity monitoring system (COMS) as 

required by Special Condition No. 22 averaged over a six-minute period, except during 

periods of routine maintenance, start-up, or shutdown (MSS) or as otherwise allowed by

law. During periods of MSS, the opacity shall not exceed 20 percent over a six-minute 

period. 

 7. Emissions from the Spruce 2 Utility Boiler exhausting through emission point number 

(EPN) U-6 shall not exceed the heat input-based performance standards identified in the 

table below. The heat input shall be based upon the higher heating value of the fuel. The 

performance standards of this permit condition shall apply at all times except during 

periods of routine MSS. During periods of MSS, the holder of this permit shall operate the 

Spruce 2 Utility Boiler and associated air pollution control equipment in accordance with 

good air pollution control practices to minimize emissions. The permit holder shall retain 

records of MSS periods in which the emission specifications identified below are exceeded 

and shall identify all measures taken to mitigate emissions. Initial compliance with the 

performance standards of this special condition shall be demonstrated in the initial 

determination of compliance stack sampling utilizing EPA Reference Method testing and 

shall be determined based upon the average of three stack sampling test runs. Continuous 

compliance thereafter shall be either via continuous emissions monitoring systems (CEMS)

or COMS for the pollutants monitored by CEMS or COMS or via stack sampling described 

by Special Condition No. 24. The averaging periods identified in the table shall be the 

basis for continuous compliance. (4/12)
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 3

Pollutant

Performance

Standard

Averaging

Period

Compliance

Method

Nitrogen Oxides (NOx) 0.069 lb/MMBtu 30-day roll CEMS1

NOx 0.05 lb/MMBtu 12-month roll CEMS1

Sulfur Dioxide (SO2) 0.10 lb/MMBtu 30-day roll CEMS1

SO2 0.06 lb/MMBtu 12-month roll CEMS1

Carbon Monoxide (CO) 0.15 lb/MMBtu 12-month roll CEMS1

Mercury (Hg) 2E-05 lb/MWh 12-month roll CEMS1

Opacity 10% six minutes COMS2

Ammonia (NH3) 0.0063 lb/MMBtu hourly Stack sample3

Particulate Matter, PM10 0.015 lb/MMBtu4

0.022 lb/MMBtu5

annual Stack sample3

Lead (Pb) 8.4E-06 lb/MMBtu annual Stack sample3

Hydrogen Fluoride (HF) 0.0008 lb/MMBtu annual Stack sample3

Sulfuric Acid Mist 

(H2SO4)

0.0037 lb/MMBtu annual Stack sample3

Hydrogen Chloride 

(HCl)

0.0019 lb/MMBtu annual Stack sample3

Volatile Organic 

Compounds (VOC)

0.0025 lb/MMBtu annual Stack sample3

Notes: 

1 CEMS are subject to the requirements of Special Condition No. 21. 

2 COMS are subject to the requirements of Special Condition No. 22.

3

Stack sampling is the average of three stack sampling runs to be conducted as 

prescribed by Special Condition Nos. 20 and 24.

4

Particulate Matter emission rate is for front half only excluding back half condensable.

5

Particulate Matter emission rate is for front and back-half condensable, for the 

concentration of particulate matter less than 10 microns in diameter (PM10).

 8. In the event that the Continuous Emissions Monitoring Systems (CEMS) for NOx or SO2

are not operating (except when the CEMS are down for planned QA/QC procedures), the 

permit holder shall operate at the minimum ammonia feed rate to the selective catalytic 

reduction system and the minimum sorbent feed rate to the flue gas desulfurization system, 

or at the pH levels, that were established during a successful initial performance test 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 4

(adjusted for load) or at the feed rates that were measured prior to the loss of the CEMS, 

which ever feed rates are higher. 

 9. Stack sampling ports and platform(s) shall be constructed on the stack as specified in the 

attachment entitled “Chapter 2, Stack Sampling Facilities,” or an alternate design may be 

required at a later date if determined necessary by the TCEQ Regional Director. (8/09)

10. Emergency Generators, EPNs EMGEN-1 and EMGEN-2, shall be limited to a maximum of 

60 non-emergency hours per year and these generators shall be limited to firing distillate

fuel oil containing no more than 0.1 percent sulfur by weight.

Ammonia (NH3) Storage

11. The service of NH3 storage tanks represented in this permit is limited to the storage of 

aqueous NH3 only.

12. Audio, olfactory, and visual checks for NH3 shall be made once per day within the 

operating area. 

A. No later than one hour following detection of a leak, plant personnel shall take the 

following actions: 

(1) Locate and isolate the leak.

(2) Use a leak collection/containment system to control the leak until repair or 

replacement can be made.

B. Within 24 hours of detection of a leak, plant personnel shall commence repair or 

replacement of the leaking component as appropriate. 

Material Handling Operating Limitations and Standards

13. Annual throughput of coal received at the Calaveras Lake site shall not exceed 15 million 

tons per year. Coal may be delivered at either of the two rotary car dumper buildings which 

shall be partially enclosed, or via trucks to the coal pile, as described in the application. 

(11/07)

14. Fugitive emissions from the transfer points on belt conveyors, any material handling, or the 

stockpile activities shall not create an off-property nuisance condition. A trained observer 

with delegation from the TCEQ may determine compliance with this special condition by
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 5

EPA Reference Method 22 or equivalent. Continuous demonstration of compliance with 

this special condition is not required. If this condition is violated, additional controls or 

process changes may be required to limit visible PM emissions. 

15. As determined by a certified opacity observer with delegation from the Executive Director 

of the TCEQ and according to EPA Reference Method 9 or equivalent, opacity of 

emissions from any single fabric filter baghouse stack listed in Special Condition No. 19 

shall not exceed 5 percent averaged over a six-minute period. Continuous demonstration of 

compliance with this special condition is not required.

16. All conveyors shall be covered or enclosed to minimize fugitive particulate matter (PM) 

emissions except the stacker/reclaim conveyor. If visibility problems occur, additional 

controls may be required. Covering and enclosures are considered abatement equipment, 

and should be kept in good repair.

17. A watering truck and/or the coal yard watering system shall be used to minimize dust 

emissions from the coal storage pile area.

18 The combined active and inactive stockpiles of coal, sludge/ash landfill, and limestone 

stockpiles shall be limited to 55 acres, 26 acres, and 1 acre, respectively. If spontaneous 

combustion occurs in the coal stockpile, plant personnel will begin efforts as a soon as 

possible to extinguish the fires, except when extinguishing stockpile fires may unduly

jeopardize the safety of plant personnel and equipment or may cause the fire to spread, in 

which case these stockpile fires may be permitted to burn themselves out.

19. Baghouses, properly installed and in good working order, shall control PM emissions from 

the following emission point numbers (EPNs): (8/09)

Emission Point No. Source

FAS3 Fly Ash Silos for Spruce Unit 1

FAS4 Fly Ash Silos for Spruce Unit 2

EAS4 Economizer Ash Silo for Spruce Unit 2

LDC-12 Limestone Receiving Baghouse

LDC-13 Limestone Silo (8/09)

LDC-10 Limestone Silos

PX-CO1A/B Railcar No. 1 Unloading and Transfer Baghouse

DC-1 Transfer Building 1

DC-2 South Reclaim Hopper to Conveyor 4

DC-3 Transfer Building 1a

DC-CCG016 Crusher Building 1
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 6

DC-4A Silo Group A Headhouse

DC-4B Silo Group A Unloading

DC-5 Crusher Building 2

DC-6 North Reclaim Hopper to Conveyor 23B

Emission Point No. Source

DC-7 Transfer Building 4

DC-8 Transfer Building 3 (11/07)

DC-14 Transfer Building 1B

DC-101 Unit 1 Transfer Building 5 and Tripper Deck

DC-201 Unit 2 Transfer Building 6 and Tripper Deck (11/07)

Initial Demonstration of Compliance

20. The holder of this permit shall perform stack sampling and other testing as required to 

establish the actual quantities of air contaminants being emitted into the atmosphere from 

the Spruce 2 Utility Boiler stack, EPN U-6. Newly constructed coal handling facilities 

shall be tested to demonstrate compliance with 40 CFR Part 60, Subpart Y.

A. Sampling shall be conducted in accordance with the appropriate procedures of the 

TCEQ Sampling Procedures Manual, EPA Methods in 40 CFR Part 60, Appendix A 

and 40 CFR Part 51, Appendix M, and American Society for Testing and Materials 

(ASTM) as follows:

(1) Methods 201A and 202, or Reference Methods 5, 5B, or 17, modified to include 

back-half condensibles, for the concentration of PM and PM10; (11/07)

(2) Reference Method 8 or Reference Methods 6 or 6c for SO2;

(3) Reference Method 9 for opacity (consisting of 30 six-minute readings as 

provided in 40 CFR § 60.11[b]);

(4) Reference Method 10 for the concentration of CO;

(5) Reference Method 25A, modified to exclude methane and ethane, for the 

concentration of VOC (to measure total carbon as propane);

(6) Reference Method 7E for the concentrations of NOx and O2 or equivalent 

methods;
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 7

(7) Reference Method 8 or a modified Method 8 for H2SO4; 

(8) Reference Methods 26 or 26A for HCl and HF;

(9) Reference Method 29 for Total Selected Metals identified in C. of this 

condition; and

(10) Reference Method 30A (Instrumental Analyzer Procedure) or 30B (Using 

Carbon Sorbent Traps) for Mercury from Coal-Fired Combustion Sources; or if 

approved by the San Antonio Regional Office: ASTM D6784-02, Standard Test 

Method for Elemental, Oxidized, Particle-Bound, and Total Mercury in Flue 

Gas Generated from Coal-Fired Stationary Sources (also known as the Ontario 

Hydro Method), or other approved EPA methods. (8/09)

Any deviations from those procedures must be approved by the TCEQ prior to 

sampling. The TCEQ Executive Director or his designated representative shall be 

afforded the opportunity to observe all such sampling. The holder of this permit is 

responsible for providing sampling and testing facilities and conducting the sampling 

and testing operations at his expense.

B. The TCEQ San Antonio Regional Office shall be contacted as soon as testing is 

scheduled but not less than 30 days prior to sampling to schedule a pretest meeting. 

The notice shall include:

(1) Date for pretest meeting.

(2) Date sampling will occur.

(3) Name of firm conducting sampling.

(4) Type of sampling equipment to be used.

(5) Method or procedure to be used in sampling; a copy of any ASTM test method 

used shall be provided. (11/07)

(6) Procedure used to determine turbine load during and after the sampling period.

The purpose of the pretest meeting is to review the necessary sampling and testing 

procedures, to provide the proper data forms for recording pertinent data, and to 

review the format procedures for submitting the test reports. The permit holder 

shall present at the pretest meeting the manner in which stack sampling will be 

executed in order to demonstrate compliance with emission standards found in 

40 CFR Part 60, Subparts Da, and Y. A written proposed description of any deviation 

from sampling procedures specified in permit conditions or TCEQ, EPA or ASTM 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 8

sampling procedures shall be made available to the TCEQ prior to the pretest 

meeting. The TCEQ Regional Director shall approve or disapprove of any deviation 

from specified sampling procedures. Requests to waive testing for any pollutant 

specified in this condition shall be submitted to the TCEQ Office of Air, Air Permits 

Division. Test waivers and alternate or equivalent procedure proposals for New 

Source Performance Standards testing which must have the EPA approval shall be 

submitted to the TCEQ Austin Regional Office. (8/09)

C. Air contaminants from the utility boiler stack, EPN U-6, to be sampled and analyzed 

include: NOx, SO2, CO, VOC, H2SO4, HCl, HF, PM10, NH3, Pb, Hg, opacity, and 

total selected metals. Diluents to be measured include oxygen (O2) or carbon dioxide 

(CO2). Total selected metals means the combination of the following metallic 

hazardous air pollutants: arsenic, beryllium, cadmium, chromium, lead, manganese, 

nickel, and selenium. Newly constructed coal handling facilities subject to 40 CFR 

Part 60, Subpart Y shall be tested for opacity. 

D. Sampling as required by this condition shall occur within 60 days after achieving the 

maximum fuel firing rate at which the new Spruce 2 Utility Boiler will be operated 

but no later than 180 days after initial start-up.

E. Two copies of the final sampling report shall be forwarded to the TCEQ within 60 

days after sampling is completed. Sampling reports shall comply with the attached 

conditions of Chapter 14 of the TCEQ Sampling Procedures Manual. The reports 

shall be distributed as follows:

One copy to the TCEQ San Antonio Regional Office

One copy to the TCEQ Austin Office of Air, Air Permits Division

Continuous Demonstration of Compliance

21. The holder of this permit shall install, calibrate, maintain, and operate a CEMS to measure 

and record the concentrations of Hg, NOx, CO, and SO2 from EPN U-6. Diluents to be 

measured include O2 or CO2. The continuous monitoring data shall also be used to 

determine compliance with the emission limitations in the attached maximum allowable 

emission rates table. (8/09)

A. The CEMS shall meet the design and performance specifications, pass the field tests, 

and meet the installation requirements and the data analysis and reporting 

requirements specified in the applicable Performance Specification Nos. 1 through 9, 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 9

40 CFR Part 60, Appendix B, or an acceptable alternative. If there are no applicable 

performance specifications in 40 CFR Part 60, Appendix B, contact the TCEQ Office 

of Air, Air Permits Division in Austin for requirements to be met. 

B. The holder of this permit shall assure that the CEMS meets the applicable 

quality-assurance requirements specified in 40 CFR Part 60, Appendix F, Procedure 

1, or an acceptable alternative. Relative accuracy exceedances, as specified in 40 

CFR Part 60, Appendix F, § 5.2.3 and any CEMS downtime and all cylinder gas audit 

exceedances of 15 percent accuracy shall be reported semi-annually to the 

appropriate TCEQ Regional Director, and necessary corrective action shall be taken. 

Supplemental stack concentration measurements may be required at the discretion of 

the appropriate TCEQ Regional Director.

C. The monitoring data shall be reduced to hourly average concentrations at least once 

each day, using a minimum of four equally-spaced data points from each one hour 

period. The individual average concentrations shall be reduced to units of the permit 

allowable emission rate in pounds per hour at least once each day. Pounds per hour 

data shall be summed on a monthly basis to tons per year (TPY) and used to 

determine compliance with the annual emissions limits of this permit. If the CEMS 

malfunctions, then the recorded concentrations may be reduced to units of the permit 

allowable as soon as practicable after the CEMS resumes normal operation.

D. All required monitoring data and quality-assurance data shall be maintained by the 

source for a period of five years and shall be made available to the TCEQ Executive 

Director or his designated representative upon request.

E. The appropriate TCEQ Regional Office shall be notified at least 30 days prior to any

required relative accuracy test audits (RATA) in order to provide them the 

opportunity to observe the testing.

F. If applicable, each CEMS will be required to meet the design and performance 

specifications, pass the field tests, and meet the installation requirements and data 

analysis and reporting requirements specified in the applicable performance 

specifications in 40 CFR Part 75, Appendix A and B, as an acceptable alternative to 

Special Condition 21 A, B, and E, in which case only 21 days notice to the TCEQ 

Regional Office is required prior to the RATA. (11/07)

22. The owner or operator of the facility shall install, calibrate, operate, and maintain a COMS

to measure and record the opacity of emissions from the Spruce 2 Utility Boiler. 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 10

A. The COMS may be located where no interference with opacity readings will be 

experienced due to water droplets from the FGD system. The COMS shall satisfy all 

of the Federal NSPS requirements for COMS as specified in 40 CFR Part 60, 

Appendix B, Performance Specification 1 (PS-1). In order to demonstrate compliance

with PS-1, the COMS shall meet the manufacturer=s design and performance 

specifications, and undergo performance evaluation testing as outlined in 40 CFR 60, 

Subpart A, § 60.13. The TCEQ Regional Director shall be notified 30 days prior to 

the certification.

B. The COMS shall be zeroed and spanned daily as specified in 40 CFR Part § 60.13. 

Corrective action shall be taken when the 24-hour span drift exceeds two times the 

amounts specified in PS-1, or as specified by the TCEQ if not specified in PS-1.

C. If the EPA promulgates a quality assurance, quality control standard for the COMS, a

Quality Assurance Plan shall be prepared and maintained in accordance with the EPA

standard for the COMS within six months. At the request of the TCEQ Regional 

Director, the holder of this permit shall submit documentation demonstrating 

compliance with these standards. 

D. The data shall be reduced to six-minute opacity averages, using a minimum of 

36 equally-spaced data points from each six-minute period.

E. Data including all periods of operation, all monitoring data, and quality-assurance 

data shall be maintained and made available on request to representatives of the 

TCEQ and any local air pollution program having jurisdiction, and shall be retained 

for at least two years following the date that the data is obtained.

F. If the COMS exceeds greater than 5 percent downtime for the reporting quarter, the 

owner/operator shall develop and implement a monitor quality improvement plan. 

The plan should address the downtime issues to improve availability and reliability. 

The plan should provide additional assurance of compliance including EPA Reference 

Method 9 support during daytime monitor downtime periods and parametric support 

for nighttime monitor downtime periods.

G. For Special Condition No. 22A and B, the COMS shall meet the applicable 

requirements of 40 CFR Part 60, Appendix B, PS-1 upon certification and/or 

recertification where compliance is based on the regulation in effect at the time of 

initial certification of the system. 

23. If any emission monitor fails to meet specified performance, it shall be repaired or replaced 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 11

as soon as reasonably possible.

24. Compliance stack sampling for pollutants that are not monitored with a CEMS or COMS 

that are identified in Special Condition No. 7 shall occur once annually. If after two years 

of stack sampling, the average of the two stack sampling results per pollutant is below 70 

percent of the performance standard identified in Special Condition No. 7, then compliance 

stack sampling for the specific pollutant may be conducted once every three years. If the 

compliance method for a pollutant changes from stack sampling to a monitoring system, the 

holder of this permit shall alter the permit accordingly. (11/07)

Emission Reduction and Netting

25. The permit holder will net out of PSD review for NOx and SO2. The reduction of emissions 

relied upon for netting shall occur not later than the commencement of operation of the 

Spruce Unit 2 Utility Boiler. The permit holder will upgrade the wet limestone scrubbing 

system serving J.K. Spruce Unit 1 to generate SO2 reductions. Upon completion of the 

upgrades to Spruce Unit 1, the combined SO2 emissions from Spruce Unit 1 and Spruce 

Unit 2 shall not exceed a total of 4,319 tons per year. The permit holder will over control 

NOx emissions from J.T. Deely Units 1 and 2, Spruce Unit 1, and O.W. Sommers Units 1 

and 2 to generate NOx reductions. The permit holder will over control NOx emissions such 

that the combined total emissions from J.T. Deely Units 1 and 2, Spruce Units 1 and 2, and 

O.W. Sommers Units 1 and 2, shall not exceed 10,454 tons per year of NOx. 

Recordkeeping Requirements

26. The following records shall be kept at the plant for the life of the permit. All records 

required in this permit shall be made available at the request of personnel from the TCEQ, 

the EPA, or any air pollution control agency with jurisdiction.

A. A copy of this permit.

B. Permit application dated November 2003 and subsequent representations submitted to 

the TCEQ.

C. A complete copy of the testing reports and records of the initial performance testing 

completed pursuant to Special Condition No. 20 to demonstrate initial compliance. 

(11/07)
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 12

D. Required stack sampling results or other air emissions testing (other than CEMS or 

COMS data) that may be conducted on units authorized under this permit after the 

date of issuance of this permit.

27. Records shall be kept for a minimum of five (5) years after collection and shall be made 

immediately available upon request to representatives of the TCEQ, the EPA, or any local 

air pollution control program having jurisdiction. The most recent two (2) years shall be 

maintained on-site and shall be available for inspection. The remaining three (3) years of 

records may be maintained off site. Records shall be legible and maintained in an orderly

manner. The following records shall be maintained:

A. Continuous emission monitoring data for opacity, SO2, Hg, NOx, CO, and diluent 

gases, O2 or CO2, from CEMS or COMS to demonstrate compliance with the 

emission rates listed in the MAERT and performance standards listed in Special 

Condition Nos. 6 and 7 for pollutants that are monitored by CEMS or COMS. 

Records should identify the times when emissions data have been excluded from the 

calculation of average emission rates because of startup, shutdown, maintenance, and 

malfunction along with the justification for excluding data. The permit holder shall 

retain additional records of SSM periods in which the emission specifications 

identified in Special Condition No. 7 are exceeded and shall identify all measures 

taken to mitigate emissions. All records should also identify factors used in 

calculations that are used to demonstrate compliance with emissions limits and 

performance standards.

B. Raw data files of all continuous emission monitoring including calibration checks 

and adjustments and maintenance performed on these systems.

C. Records of coal analysis and analysis provided by natural gas suppliers to show 

compliance with Special Condition No. 4A and 4B.

D. Records of the average coal feed rate to the Spruce 2 Utility Boiler in pounds per hour 

and the corresponding average heat input (HHV) in MMBtu/hr, based upon an 

average over a calendar month, to show compliance with Special Condition No. 5. 

(11/07)

E. Records of ammonia feed rate, sorbent feed rate, and pH established during the initial 

determination of compliance stack sampling to fulfill the requirements of Special 

Condition No. 8.

F. Records of the hours of operation of the emergency generators to show compliance 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 13

with Special Condition No. 10.

G. Records of the coal received at Calaveras Lake site to show compliance with Special 

Condition No. 13.

H. Records of cleaning and maintenance performed on abatement equipment, including 

records of replacement maintenance performed on baghouses and conveyors.

I. Records of NOx and SO2 emissions from other combustion units identified in Special 

Condition No. 25, to show compliance with the emissions cap in the MAERT and 

with the emissions reductions required by Special Condition No. 25.

J. Records required to show compliance with 40 CFR part 60, Subparts Da and Y, 

including records of required reporting.

Reporting

28. The holder of this permit shall submit to the TCEQ San Antonio Regional Office and the 

Air Enforcement Branch of EPA in Dallas, semi-annual reports as described in 40 CFR §

60.7. Such reports are required for each emission unit which is required to be continuously

monitored pursuant to this permit.

Optimization Studies

29. If the permit holder is unable to demonstrate initial compliance with the Spruce 2 Utility

Boiler performance standards for the control of NOx, Hg, H2SO4, and PM10 identified in 

Special Condition No. 7 within the time allotted for in this permit, then the permit holder 

may request additional time for an emissions optimization study to mitigate emissions from 

the unit. Optimization studies may be requested by the permit holder to evaluate and 

implement additional efforts to mitigate the emissions of NOx, Hg, H2SO4, and PM10. 

Exceedances of any emission limit that occur during an approved optimization study are 

not a violation of the emission limits set forth for NOx, Hg, H2SO4, and PM10 in this permit, 

as long as the owner or operator maintains and operates the equipment and control 

equipment at all times in a manner consistent with good practice for minimizing emissions. 

The following conditions shall be met for the studies:

Prior to the initiation of optimization studies, a protocol shall be developed and approved 

by the Executive Director of the TCEQ. The protocol shall include at a minimum a 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 14

proposed duration of the study period and an explanation of control efforts that will be 

evaluated. Additionally, the protocol will include a description of the specific testing that 

will be used to evaluate emissions during the optimization study. All stack testing done for 

this optimization study shall be coordinated with the TCEQ Regional Office.

A report summarizing the results of the optimization study shall be submitted to the TCEQ 

Regional Office within forty-five (45) days after the completion of the individual 

optimization study. This report shall include a summary of the effort utilized to mitigate 

emissions and the resulting emission rates measured during the study, as well as a listing of 

actions that will be undertaken by the permit holder to achieve the emission standard listed 

in Special Condition No. 7. (11/07)

All optimization studies shall be completed within 12 months of the initial demonstration 

of compliance stack testing.

Routine Maintenance, Startup, and Shutdown

30. This permit authorizes the emissions from the planned MSS activities listed in Attachment 

A, Attachment B, or the MAERT attached to this permit. Attachment A identifies the 

inherently low emitting (ILE) planned maintenance activities that this permit authorizes to 

be performed. Attachment B identifies the planned MSS activities that are non-ILE

planned maintenance activities that this permit authorizes to be performed. (4/12)

31. The holder of this permit shall minimize emissions during planned MSS activities by

operating the facility and associated air pollution control equipment in accordance with 

good air pollution control practices, safe operating practices, and protection of the facility.

(4/12)

32. Emissions during planned startup and shutdown activities will be minimized by limiting the 

duration of operation in planned startup and shutdown mode as follows: (4/12)

A. A planned cold startup of the electric generating facility (EGF), Spruce Unit 2, is 

defined as the period that begins with the impulse metal temperature being less than 

300 degrees Fahrenheit, and a hot startup event is defined as a startup that is not a 

cold startup. Startup commences when the Induced Draft Fan is placed in service and 

is complete when the boiler is released to dispatch. A planned cold start event 

shall not exceed 840 minutes in duration and a hot startup event shall not exceed 480 

minutes in duration. Extended startups lasting longer than either a cold or hot start 

duration are allowed provided the total hours of extended startups does not exceed 
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 15

600 hours per unit per year.

B. A planned shutdown of the EGF, Spruce Unit 2, is defined as the period that

commences when dispatched requests a shutdown due to market conditions or when 

plant personnel request a shutdown for maintenance, and ends when fuel is no longer 

fired. A planned shutdown event shall not exceed 360 minutes in duration. 

33. When a planned maintenance activity identified in Attachment B is associated with a VOC 

liquid storage facility and may result in VOC emissions from that facility, the permit holder 

shall not open that facility to the atmosphere in connection with the planned maintenance 

activity until the VOC liquids are removed from that facility to the maximum extent 

practicable. (4/12)

34. No vacuum pump on a vacuum truck that is used to move solids (such as ash) during 

planned maintenance activities shall be operated unless the vacuum system exhaust is 

routed to a filtering system. (4/12)

35. Vacuum trucks that are used to move liquids during planned maintenance activities shall 

utilize submerged loading. (4/12)

36. Compliance with the emissions limits for planned MSS activities identified in the MAERT 

attached to this permit may be demonstrated as follows. (4/12)

A. For each pollutant emitted during ILE planned maintenance activities, the permit 

holder shall annually confirm the continued validity of the estimated potential to emit 

represented in the permit application for all ILE planned maintenance activities. The 

total emissions from all ILE planned maintenance activities (See Attachment A) shall 

be considered to be no more than the estimated potential to emit for those activities 

that are represented in the permit application.

B. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions are measured using a CEMS, as per Special Condition No. 37A, 

the permit holder shall compare the pollutant’s short-term (hourly) emissions during 

planned MSS activities as measured by the CEMS to the applicable short-term 

planned MSS emissions limit in the MAERT.

C. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions occur through a stack, but are not measured using CEMS as per 

Special Condition No. 37A, the permit holder shall determine the total emissions of 

the pollutant through the stack that result from such non-ILE planned MSS activities 

in accordance with Special Condition No. 37B.
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 16

D. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions do not occur through a stack, the permit holder shall do the 

following for each calendar month.

(1) Determine the total emissions of the pollutant from such non-ILE planned MSS 

activities in accordance with Special Condition No. 37B.

(2) Once monthly emissions have been determined in accordance with Special 

Condition No. 36D(1) for 12 months after the MSS permit amendment has been 

issued, the permit holder shall compare the sum of the rolling 12-month 

emissions for the pollutant for all non-ILE planned MSS activities to the annual 

emissions limit for the pollutant in the MAERT.

37. The permit holder shall determine the emissions during planned MSS activities for use in 

Special Condition No. 36 as follows. (4/12)

A. For each pollutant whose emissions during normal facility operations are measured 

with a CEMS that has been certified to measure the pollutant’s emissions over the 

entire range of a planned MSS activity, the permit holder shall measure the emissions 

of the pollutant during the planned MSS activity using the CEMS.

B. For each pollutant not described in Special Condition No. 37A, the permit holder 

shall calculate the pollutant’s emissions during all occurrences of each type of 

planned MSS activity for each calendar month using the frequency of the planned 

MSS activity identified in work orders or equivalent records and the emissions of the 

pollutant during the planned MSS activity as represented in the planned MSS permit 

application. In lieu of using the emissions of the pollutant during the planned MSS 

activity as represented in the planned MSS permit application to calculate such 

emissions, the permit holder may determine the emissions of the pollutant during the 

planned MSS activity using an appropriate method, including but not limited to, any

of the methods described in paragraphs 1 through 4 below, provided that the permit 

holder maintains appropriate records supporting such determination:

(1) Use of emission factor(s), facility-specific parameter(s), and/or engineering 

knowledge of the facility’s operations.

(2) Use of emissions data measured (by a CEMS or during emissions testing) 

during the same type of planned MSS activity occurring at or on a similar 

facility, and correlation of that data with the facility’s relevant operating 

parameters, including, but not limited to, electric load, temperature, fuel input, 

and fuel sulfur content.
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 17

(3) Use of emissions testing data collected during a planned MSS activity occurring 

at or on the facility, and correlation of that data with the facility’s relevant 

operating parameters, including, but not limited to, electric load, temperature, 

fuel input, and fuel sulfur content.

(4) Use of parametric monitoring system (PEMS) data applicable to the facility. 

38. With the exception of the emission limits in the MAERT attached to this permit, the permit 

conditions relating to planned MSS activities do not become effective until 60 days after 

issuance of the permit amendment that added such conditions. (4/12) 

Permits by Rule and Standard Permits

39. The following maintenance activities at the site are currently authorized by permits by rule 

(PBR) under 30 TAC Chapter 106. 

Description PBR/Standard 

Permit No.

Brazing, Soldering, and Welding 106.227

Enclosed Dry Abrasive Blasting 106.263

Solvent Cleaning-Parts Degreaser 106.454

Hand-Held Equipment for Buffing, 

Polishing, Cutting, Drilling, Sawing, 

Grinding, Turning, or Machining 

Wood, Metal or Plastic

106.265

Date: April 10, 2012
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 18

Attachment A

Permit Nos. 70492 and PSDTX1037

Inherently Low Emitting (ILE) Planned Maintenance Activities

Planned Maintenance Activity Emissions

NH3/Urea VOC NOx CO PM SO2

Miscellaneous particulate filter 

maintenance1 X

Maintenance of storage vessels 

storing material with vapor 

pressure <0.5 psia

X X

Catalyst handling and 

maintenance X

Water based washing X

Organic chemical usage, not 

authorized by “manual surface 

coating or solvent cleaning 

operations” or by “use and 

disposal of aerosol products”

X

Boiler general maintenance

2

X

Management of sludge from 

pits, ponds, sumps, and water 

conveyances3 

X

Inspection, repair, replacement, 

adjusting, testing, and 

calibration of analytical 

equipment, process instruments 

including sight glasses, meters, 

gauges, CEMS, PEMS. 

X X X X

Deslagging of boiler4

X X X X

Material handling system 

maintenance5 X

Small equipment and fugitive 

component repair/replacement 

in VOC and inorganic service6

X X
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 19

Notes:

1. Includes, but is not limited to, baghouse filters, ash silo/transfer filters, coal handling 

filters, process-related building air filters, and combustion turbine air intake filters.

2. Includes pre-heater basket handling and maintenance, refractory change-out, fan 

maintenance and balancing, damper, air heater, and soot blower maintenance, and any

other general boiler maintenance that does not exceed the worst-case emissions 

representation in the application.

3. Includes, but is not limited to, management by vacuum truck/dewatering of materials in 

open pits and ponds, and sumps, tanks and other closed or open vessels. Materials 

managed include water and sludge mixtures containing miscellaneous VOCs such as 

diesel, lube oil, and other waste oils.

4. Includes, but is not limited to, explosive blasting, clinker shooting, and other boiler 

deslagging activities; does not include dry abrasive blasting that may occur in boilers. 

5. Material handling system equipment includes, but is not limited to, silos, transport 

systems, coal bunkers, coal crushing equipment, coal handling, nuvafeeders, hoppers, 

FGD sludge handling system. Materials handled include coal, ash, limestone, gypsum, 

mercury, and sorbents. 

6. Includes, but is not limited to, (i) repair/replacement of pumps, compressors, valves, 

pipes, flanges, transport lines, filters and screens in natural gas, fuel oil, diesel oil, 

ammonia, lube oil, and gasoline service, (ii) vehicle and mobile equipment maintenance 

that may involve small VOC emissions, such as oil changes, transmission service, and 

hydraulic system service, and (iii) off-line NOx control device maintenance (including 

maintenance of the anhydrous ammonia systems and aqueous ammonia systems 

associated with SCR systems and SNCR systems)
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 20

Attachment B

Permit Nos. 70492 and PSDTX1037

Non-Inherently Low Emitting Planned MSS Activities

Planned Maintenance Activity

Emissions

EPN NH3/Urea VOC NOX CO PM SO2

Combustion optimization1

U-6 X X X X X

Vacuum truck solids loading2

MSSFUG4 X

Vacuum truck solids 

unloading MSSFUG4 X

Maintenance of storage 

vessels storing gasoline or 

other material with vapor 

pressure >0.5 psia that 

requires clearing of the vessels 

to allow for entry of personnel 

MSSFUG4 X X

Flue gas conditioning system 

maintenance - unit online U-6 X X

Flue gas conditioning system 

maintenance fugitives - unit 

offline3

MSSFUG4 X X

NOx control device 

maintenance - unit online U-6 X X

PM control device 

maintenance - unit online U-6 X

SO2 control device 

maintenance - unit online U-6 X

Smoke test of boiler U-6 X X X X

Smoke test of boiler fugitives MSSFUG4 X X X X

Use of fans during 

maintenance - unit offline U-6 X

Main unit Planned Startup and 

Planned Shutdown U-6 X X X X X X
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 21

Notes:

1. Includes, but is not limited to, (i) leak and operability checks (e.g., turbine overspeed tests, troubleshooting), (ii) balancing, and (iii) tuning activities that occur 

during seasonal tuning or after the completion of initial construction, a combustor 

change-out, a major repair, maintenance to a combustor, or other similar 

circumstances.

2. Includes site-wide solids vacuuming operations (e.g., SCR, baghouse, ESP, ducts, 

furnace, loop seals, stripper coolers, and airlocks).

3. Includes, but is not limited to, maintenance of anhydrous ammonia systems and 

aqueous ammonia systems used to condition flue gas before it is controlled by a 

PM control device.

4. Emission point MSSFUG represents permitted site-wide MSS fugitive emissions 

for J.T. Deely Units 1 and 2, and Spruce Units 1 and 2. MSSFUG emissions are 

quantified in the maximum allowable emissions rate table in Permit No. 70492

and PSDTX1037.
SPECIAL CONDITIONS

Permit Numbers 70492 and PSDTX1037

Page 22

Attachment C

Permit Numbers 70492 and PSDTX1037

Trace Metal Concentrations

Constituent Maximum Concentration (ppmw)

Mercury 0.49

Beryllium 6.3

Lead 11.55

Arsenic 9.45

Cadmium 4.52

Vanadium 326.

Nickel 47.3

Silver 2.64

Barium 1019

Chromium 77.7

Cobalt 42.0

Manganese 158.0

Antimony 5.25

Selenium 5.3

Zinc 231.00

Date: April 10, 2012