September 6

, 2011

Mr. Jim Williams Basin Creek Equity Partners, LLC

P.O Box 11 65 East Broadway Street
Butte, MT 59701

RE: Basin Creek Equity Partners, LLC Title V Operating Permit #OP3 2 11

- 02

Dear Mr. Williams :

The Department of Environmental Q uality has prepared the enclosed Final Operating Permit #OP 3211

- 02 , for Basin Creek Equity Partners, LLC , located in Butte , Montana. Please review the cover page of the attached permit for information pertaining to the action taking place on Permit #OP 321 1

- 02

.

If you have any questions, please contact Deanne Fischer , the permit writer, at (406) 444

- 3403 or by

email at dfischer@mt.gov

.

Sincerely,

Vickie Walsh Air Permitting Program Supervisor Air Resources Manag ement Bureau (406) 444

- 9741 Deanne Fischer, P.E. Environmental Engineer Air Resources Management Bureau (406) 444

- 3403

VW: DF

Enclosure

Cc: Christopher Ajayi, US EPA Region VIII 8P

- AR Carson Coate, US EPA Region VIII, Montana OfficeOP3211

- 02 i Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 STATE OF MONTANA Department of Environmental Quality Helena, Montana 59620

AIR QUALITY OPERATING PERMIT OP3 2 11

- 02

Issued to: Basin Creek Equity Partners, LLC

65 East Broadway Street Butte, MT 59701

Final Date: September 4, 2011

Ex piration Date: September 4, 2016

Effective Date: September 4, 2011

Date of Decision: July 28, 2011

End of EPA 45

- day Review: July 15, 2011 Proposed Issue Date: April 31, 2011

Draft Issue Date: April 26, 2011

Application Deemed Technically Compl ete: March 4, 2010 Application Deemed Administratively Complete: March 4, 2010 Renewal Application Received: March 4, 2010

AFS Number: 030

- 093

- 0018A

Permit Issuance and Appeal Processes: In accordance with Montana Code Annotated (MCA) Sections

75

- 2

- 217 and 218 and the Administrative Rules of Montana (ARM), ARM Title 17, Chapter 8, Subchapter 12, Operating Permit Program, this operating permit is hereby issued by the Department of Environmental Quality (Department) as effective and final on September 4, 2011. This permit must be kept on

- site at the above named facility.OP3211

- 02 ii Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 Montana Air Quality Operating Permit Department of Environmental Quality

SECTION I. GENERAL INFORMATION

................................ ................................ .......................... 1

SECTION II. SUMMARY OF EMISSI ON UNITS

................................ ................................ .......... 2

SECTION III. PERMIT CONDITIONS

................................ ................................ ............................. 3

A. F ACILITY

- W IDE

................................ ................................ ................................ .................... 3

B. EU001

–
................................ ................................ ................................ ................................ 6

SECTION IV. NON

- APPLICABLE REQUIREME NTS

................................ ................................ 10

A. F ACILITY

- W IDE

................................ ................................ ................................ .................. 10

B. E MISSION U NITS

................................ ................................ ................................ ................. 12

SECTION V. GENERAL PERMIT CONDI TIONS

................................ ................................ ....... 13

A. C OMPLIANCE R EQUIREMENTS

................................ ................................ ............................ 13

B. C ERTIFICATION R EQU IREMENTS

................................ ................................ ........................ 13

C. P ERMIT S HIELD

................................ ................................ ................................ ................... 14

D. M ONITORING

, R ECORDKEEPING

, AND R EPORTING R EQUIREMENTS

................................ .. 15

E. P ROMPT D EVIATION R EPORTING

................................ ................................ ........................ 16

F. E MERGENCY P R OVISIONS

................................ ................................ ................................ ... 16

G. I NSPECTION AND E NTRY

................................ ................................ ................................ ..... 17

H. F EE P AYMENT

................................ ................................ ................................ ..................... 18

I. M INOR P ERMIT M ODIFICATIONS

................................ ................................ ........................ 18

J. C HANGES N OT R EQUIRING P ERMIT R EVISION

................................ ................................ ... 18

K. S IGNIFICANT P ERMIT M ODIFICATIONS

................................ ................................ ............... 19

L. R EOPENING FOR C AUSE

................................ ................................ ................................ ...... 20

M. P ERMIT E XPIRATION AND R ENEWAL

................................ ................................ .................. 20

N. S EVERABILITY C LAUSE

................................ ................................ ................................ ...... 20

O. T RANSFER OR A SSIGNMENT OF O WNERSHIP

................................ ................................ ...... 21

P. E MISSIONS T RADING

, M ARKETABLE P ERMITS

, E CONOMIC I NCENTIVES

........................... 21 Q. N O P ROPERTY R IGHTS C ONVEYED

................................ ................................ ..................... 21

R. T ESTING R EQUIRE MENTS

................................ ................................ ................................ ... 21

S. S OURCE T ESTING P ROTOCOL

................................ ................................ ............................. 21

T. M ALFUNCTIONS

................................ ................................ ................................ .................. 21

U. C IRCUMVENTION

................................ ................................ ................................ ................ 21

V. M OTOR V EHICLES

................................ ................................ ................................ .............. 22

W. A NNUAL E M ISSIONS I NVENTORY

................................ ................................ ....................... 22

X. O PEN B URNING

................................ ................................ ................................ ................... 22

Y. M ONTANA A IR Q UALITY P ERMITS

................................ ................................ ..................... 22

Z. N ATIONAL E MISSION S TANDARD FOR A SBESTOS

................................ .............................. 23

AA. A SBESTOS

................................ ................................ ................................ ........................... 23

BB. S TRATOSPHERIC O ZONE P ROTECTION

– S ERVICING OF M OTOR V EHICLE A IR
C ONDITIONERS

................................ ................................ ................................ ................... 23

CC. S TRATOSPHERIC O ZONE P ROTECTION

– R ECYCLING AND E MISSION R EDUCTIONS

.......... 23

DD. E MERGENCY E PISODE P LAN

................................ ................................ ............................... 24

EE. D EFINITIONS

................................ ................................ ................................ ....................... 24

APPENDIX A INSIGNIFICANT EMISSI ON UNITS

................................ ................................ ... A

- 1

APPENDIX B DEFINITIONS AND ABBR EVIATIONS

................................ .............................. B

- 1OP3211

- 02 iii Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 APPENDIX C NOTI FICATION ADDRESSES

................................ ................................ ............. C

- 1

APPENDIX D AIR QUALITY INSPECTO R INFORMATION

................................ .................. D

- 1OP3211

- 02 1 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit have the meaning assigned to them in the referenced regulations.

SECTION I. GENERAL INFORMATION

The following general information is provided pursuant to ARM 17.8.1210(1).

Company Name: Basin Creek Equity Partners, LLC

Mailing Address: P.O Box 11

City: Butte Sta te: Montana Zip: 59701

Plant Location: NW1⁄4 of Section 18, Township 2 North, Range 7 West, Silver Bow County

Responsible Official: Jim Williams Phone: 406

- 533

- 6740

Facility Contact Person: Jim Williams Phone: 406

- 533

- 6740

Primary SIC Code: 4911

Nature of Business: Power Generation

Description of Process:

Basin Creek Equity Partners, LLC (BCEP), operates a nominal 54.9

- megawatt (MW) electrical power generation facility incorporating nine (6.1 MW/unit) four

- stroke, lean

- burn, natural ga s fired reciprocating internal combustion engines (RICE). The RICE produce electrical power by engine shaft rotation of an electric generator. The RICE will combust pipeline quality natural gas and will incorporate an oxidation catalyst (OxiCat) for the control of carbon monoxide (CO), Volatile Organic Compound (VOC), and Hazardous Air Pollutant (HAP) emissions. No add

- on control will be incorporated for oxides of nitrogen (NO

x ) emissions, as the combustion of pipeline quality natural gas in lean

- burn RI CE inherently results in

low NO

x emissions and the limit of 34,200 combined operating hours per year will also reduce NO

x emissions. Further, the RICE will not incorporate add

- on controls for sulfur dioxide (SO 2 ) and particulate

matter less than 10 micron s (μm) aerodynamic diameter (PM 10 ) emissions. BCEP is required by permit to combust only pipeline quality natural gas, which, similar to the previously discussed inherent NO

x control, will result in reduced SO 2 and PM 10 emissions.OP3211

- 02 2 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the following (ARM 17.8.1211):

Emissions Unit

ID Description Pollution Control Device/Practice

EU001 Caterpillar Lean

- Burn Natural Gas

- fired RICE (9 RICE @ 6.1

MW/RICE) CO, VOC, HAPs: Oxidat ion Catalyst

PM/PM 10 , NO

x : Lean

- Burn Technology Firing Pipeline Quality Natural Gas Only, Operational LimitsOP3211

- 02 3 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 SECTION III. PERMIT CONDITIONS

The following requirements and conditions are applicable to the facility or to specific emission units

located at the facility (ARM 17.8.1211, 1212, and 1213).

A. Facility

- Wide

Conditions Rule Citation Rule Description Pollutant/Parameter Limit

A.1 ARM 17.8.105 Testing Requirements Testing Requirements

------- A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 4 0%

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20%

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20%

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions

------- A.6 ARM 17.8.308 Particulate Matter, Airbo rne Reasonable Precaution,

Construction 20%

A.7 ARM 17.8.309 Particulate Matter, Fuel Burning Equipment Particulate Matter E= 0.882 * H

- 0.1664 Or

E= 1.026 * H

- 0.233

A.8 ARM 17.8.310 Particulate Matter, Industrial

Processes Particulate Matter E= 4.10 * P 0.67 or E= 55 * P 0.11

- 40

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions,

Sulfur in Fuel Sulfur in Fuel (liquid or solid fuels) 1 lb/MMBtu fired

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions,

Sulfur in Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF

A.11 ARM 17.8. 324(3) Hydrocarbon Emissions,

Petroleum Products Gasoline Storage Tanks

-------

A.12 ARM 17.8.324 Hydrocarbon Emissions,

Petroleum Products 65,000 Gallon Capacity

-------

A.13 ARM 17.8.324 Hydrocarbon Emissions,

Petroleum Products Oil

- effluent Water Sepa rator

-------

A.14 ARM 17.8.342 NESHAPs General Provisions SSM Plans Submittal

A.15 ARM 17.8.1211(1)(c)

and 40 CFR Part 98 Greenhouse Gas Reporting Reporting

-------

A.16 ARM 17.8.1212 Reporting Requirements Prompt Deviation Reporting

------- A.17 ARM 17.8.1212 Reporting Requirements Compliance Monitoring

------- A.18 ARM 17.8.1207 Reporting Requirements Annual Certification

-------

Conditions

A.1. Pursuant to ARM 17.8.105, any person or persons responsible for the emission of any air

contaminant into th e outdoor atmosphere shall, upon written request of the Department, provide the facilities and necessary equipment (including instruments and sensing devices) and shall conduct test, emission or ambient, for such periods of time as may be necessary using m ethods approved by the Department.

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 17.8.105. In addition, for such sources, compliance with limits and conditions listing “as required by the Department” as the f requency, is verified annually using emission factors and engineering calculations by the Department’s compliance inspectors during the annual emission inventory review; in the case of Method 9 tests, compliance is monitored during the regular inspection b y the compliance inspector.

A.2. Pursuant to ARM 17.8.304(1), BCEP shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.OP3211

- 02 4 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 A.3. Pursuant to ARM 17.8.304(2), BCEP shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.4. Pursuant to ARM 17.8.308(1), BCEP shall not cause or authorize the production, handling, transportation, or storage of any mat erial unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless

o therwise specified by rule or in this permit.

A.5. Pursuant to ARM 17.8.308(2), BCEP shall not cause or authorize the use of any street, road or parking lot without taking reasonable precautions to control emissions of airborne particulate matter, unless other wise specified by rule or in this permit.

A.6. Pursuant to ARM 17.8.308, BCEP shall not operate a construction site or demolition project unless reasonable precautions are taken to control emissions of airborne particulate matter. Such emissions of airborne p articulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, BCEP shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in excess of the maximum allowable emissions of particulate matter for existing fuel burnin g equipment and new fuel burning equipment calculated using the following equations:

For existing fuel burning equipment (installed before November 23, 1968):

E =0.882 * H
- 0.1664

For new fuel burning equipment (installed on or after November 23, 1968):

E =1.026 * H
- 0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable particulate emissions rate in pounds per MMBtu.

A.8. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, BCEP shal l not cause or authorize particulate matter to be discharged from any operation, process, or activity into the outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate matter calculated using the following equations:

For proce ss weight rates up to 30 tons per hour: E = 4.10 * P 0.67
For process weight rates in excess of 30 tons per hour: E = 55.0 * P 0.11

– 40

Where E = rate of em issions in pounds per hour and P = process weight rate in tons per hour.

A.9. Pursuant to ARM 17.8.322( 4), BCEP shall not burn liquid or solid fuels containing sulfur in excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit.

A.10. Pursuant to ARM 17.8.322(5), BCEP shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions, unless otherwise specified by rule or in this permit.OP3211

- 02 5 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 A.11. Pursuant to ARM 17.8.324(3), BCEP shall not load or permit the loading of gasoline int o any stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a permanent submerged fill pipe, unless such tank is equipped with a vapor loss control device or is a pressure tank as described in ARM 17.8.324(1) , unless otherwise specified by rule or in this permit.

A.12. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, BCEP shall not place, store or hold in any stationary tank, reservoir or other container of more than 65,000 gallon

cap acity any crude oil, gasoline or petroleum distillate having a vapor pressure of 2.5 pounds per square inch absolute or greater under actual storage conditions, unless such tank, reservoir or other container is a pressure tank maintaining working pressure sufficient at all times to prevent hydrocarbon vapor or gas loss to the atmosphere, or is designed and equipped with a vapor loss control device, properly installed, in good working order and in operation.

A.13. Pursuant to ARM 17.8.324, unless otherwise spec ified by rule or in this permit, BCEP shall not use any compartment of any single or multiple

- compartment oil

- effluent water separator, which compartment receives effluent water containing 200 gallons a day or more of any petroleum product from any equipme nt processing, refining, treating, storing or handling kerosene or other petroleum product of equal or greater volatility than kerosene, unless such compartment is equipped with a vapor loss control device, constructed so as to prevent emission of hydrocar bon vapors to the atmosphere, properly installed, in good working order and in operation.

A.14. Pursuant to ARM 17.8.342 and 40 CFR 63.6, BCEP shall submit to the Department a copy of any startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6 (e)(3) within 30 days of the effective date of this operating permit (if not previously submitted), within 30 days of the compliance date of any new National Emission Standard for Hazardous Air Pollutants (NESHAPs) or Maximum Achievable Control Technology (MACT) standard, and within 30 days of the revision of any such SSM plan, when applicable. The Department requests submittal of such plans in electronic form, when possible.

A.15. Pursuant to ARM 17.8.1211(1)(c) and 40 CFR Part 98, BCEP shall comply with requi rements of

40 CFR Part 98

– Mandatory Greenhouse Gas Reporting, as applicable (ARM 17.8.1211(1)(c), NOT an applicable requirement under Title V).

A.16. BCEP shall promptly report deviations from permit requirements including those attributable to upset conditio ns, as upset is defined in the permit. To be considered prompt, deviations shall be reported to the Department using the schedule and content as described in Section V.E (unless otherwise specified in an applicable requirement) (ARM 17.8.1212)

.

A.17. On or bef

ore February 15 and August 15 of each year, BCEP shall submit to the Department the compliance monitoring reports required by Section V.D. These reports must contain all information required by Section V.D, as well as the information required by each indi vidual emissions unit. For the reports due by February 15 of each year, BCEP may submit a single report, provided that it contains all the information required by Section V.B & V.D. Per ARM
17.8.1207,

any application form, report, or compliance certifi cation submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including semiannual monitoring reports), shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certification requir ed under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.”OP3211

- 02 6 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 A.18. By February 15 of each year, BCEP shall su bmit to the Department the compliance certification required by Section V.B. The annual certification required by Section V.B must include a statement of compliance based on the information available which identifies any observed,

documented or otherwise known instance of noncompliance for each applicable requirement. Per
ARM 17.8.1207,

any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall contain ce rtification by a responsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12,
shall state that, “based on information and belief formed after reasonable inq uiry, the statements and information in the document are true, accurate and complete.”

B. EU001: Caterpillar Lean

- Burn Natural Gas

- Fired RICE (9 RICE @ 6.1 MW/RICE)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Reporting Requiremen ts Method Frequency

B.1, B. 10

, B.1 8 , B.2 4

, B.2 5 Opacity 20% Burning Pipeline Quality

Natural Gas Only Ongoing Semiannual

B.2, B.1 1

, B.1 9 , B.2 3

, B.2 4 , B.2 5 NOx 1 14.4 lb/hr/RICE Method 7 Initial and Every

2 Years Semiannual

B.3, B.1 1

, B.1 9 , B.2 3

, B.2 4 , B.2 5 CO 5.10 lb/hr/RICE Method 10 Initial and Every

2 Years Semiannual

B.4, B.1 2

, B.1 9 , B.2 3

, B.2 4 , B.2 5 VOC 2.60 lb/hr/RICE Method 18 Initial and As Required By The Department

and Section

III.A.1 Semiannual

B.5, B.1 3

, B.1 9 , B.2 4

, B.2 5 Combined RICE

O perational Limit 34,200 hr/rolling

12

- month period Recordkeeping Ongoing Semiannual

B.6, B.1 4

, B.1 8 , B.2 4

, B.2 5 Fuel Specification Pipeline Quality Natural Gas Only Recordkeeping Ongoing Semiannual

B.7, B.1 5

, B. 20 , B.2 4

, B.2 5 Oxidation Catalyst Each RICE : Install, Operate, and

Maintain Maintenance

and Inspection Semiannual Semiannual

B.8, B.1 6

, B. 2 1 , B.2 4

, B.2 5 Acid Rain Program 40 CFR Part 72

- 78, As Applicable Recordkeeping As Applicable Semiannual

B.9, B.17, B.22, B.25. 40 CFR 63 Subpart ZZZZ 40 CFR 63 Subpart

ZZZZ 40 CFR 63

Subpart ZZZZ 40 CFR 63

Subpart ZZZZ 40 CFR 63 Subpart

ZZZZ

1 NO

x reported as NO 2

.

Conditions

B.1. BCEP shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any sources installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304).

B.2. NO

x (as NO 2 ) emissions from each RICE shall not exceed 14.4 pounds per hour (lb/hr) based on a

1

- hour averaging period (ARM 17.8.752).OP3211

- 02 7 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 B.3. CO emissions from each RICE shall not exceed 5.10 lb/hr based on a 1

- hour averaging period (ARM 17.8.752).

B.4. VOC emissions from each RICE shall not exceed 2.60 lb/hr based on a 1

- hour averaging period (ARM 17.8.752).

B.5. Combined RICE operation (9 engines total) shall be limit ed to a maximum of 34,200 hours during any rolling 12

- month time period (ARM 17.8.749).

B.6. BCEP shall combust only pipeline quality natural gas for RICE operations (ARM 17.8.752).

B.7. BCEP shall install, operate, and maintain an oxidation catalyst on each RICE (ARM 17.8.752).

B.8. BCEP shall comply with all applicable standards and limitations, and the reporting, recordkeeping, and notification requirements of the Acid Rain Program contained in 40 CFR Part(s) 72

- 78 (40 CFR 72 through 40 CFR 78 ).

B.9. BCEP shall comply with all applicable standards, limitations and the reporting, recordkeeping, and notification requirements of 40 CFR 63, Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) (ARM

1 7.8.340).

Compliance Demonstration

B.10. Monitoring compliance with the opacity limit shall be satisfied by burning only pipeline quality natural gas for RICE operations. However, this does not preclude the Department from initiating

an enforcement action if a Reference Method test indicates that these limits are being violated, even if only pipeline quality natural gas is combusted (ARM 17.8.1213).

B.11. BCEP shall monitor compliance with the NO

x 1 and CO emission limits for each RICE by conducting an initial sourc e test for NO

x 1 and CO, concurrently, within 180 days of initial start

- up of each RICE or according to another testing/monitoring schedule as may be approved by the Department. After the initial source test, testing shall continue on an every 2

- year basis or according to another testing/monitoring schedule as may be approved by the Department (ARM 17.8.105 and 17.8.749).

B.12. BCEP shall monitor compliance with the VOC emission limits for each RICE by conducting an initial source test within 180 days of ini tial start

- up of each RICE or according to another testing/monitoring schedule as may be approved by the Department. After the initial source test, testing shall continue as required by the Department (ARM 17.8.105).

B.13. Monitoring compliance with the RI CE operational limitation in Section III.B.5 shall be accomplished through recordkeeping. BCEP shall document, by month, the combined hours of operation of the nine RICE. By the 25th day of each month, BCEP shall total the combined hours of operation of the nine RICE to verify compliance with the limit in Section III.B.5 (ARM 17.8.749).

B.14. Monitoring compliance with the fuel use limitation in Section III.B.6 shall be accomplished through recordkeeping. BCEP shall maintain a daily fuel log documenting the t ype of fuel fired for all RICE operations, the date, and the initials of the documenting personnel (ARM 17.8.1213).OP3211

- 02 8 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 B.15. BCEP shall perform at least semiannual inspections of the oxidation catalyst(s) controlling emissions from each RICE. The inspections sho uld be conducted in accordance with the manufacturer's recommendations (ARM 17.8.1213).

B.16. Monitoring compliance with the Acid Rain Program in 40 CFR Part(s) 72

- 78 shall be accomplished through recordkeeping (40 CFR 72 through 40 CFR 78).

B.17. BCEP shall mo nitor compliance as required by 40 CFR 63, Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) (ARM 17.8.340).

Recordkeeping

B.18. BCEP shall maintain a daily operations log indicatin g the operating status of each RICE, the combined RICE operating hours, the type of fuel fired, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

B.19. All compliance source test recordkeeping shall be performed in accordance wi th the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

B.20. BCEP shall record in a log the results of the semiannual oxidation catalyst inspections; each log

entry m ust include the date, the time, the results of the inspection, any maintenance activity or preventive action conducted for the oxidation catalyst or the RICE, and the initials of the documenting personnel. The log must be maintained on

- site and must be su bmitted to the Department upon request (ARM 17.8.1212).

B.21. BCEP shall comply with all applicable recordkeeping requirements contained in 40 CFR Part(s)

72

- 78 (40 CFR 72

- 78).

B.22. BCEP shall comply with all applicable standards, limitations and the reporting, rec ordkeeping, and notification requirements of 40 CFR 63, Subpart ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) (ARM 17.8.340).

Reporting

B.23. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

B.24. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

B.25. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. a summary of results of any source testing that was performed during that semiannual period ;

b. a summary of the reporting period specific information contained in the daily operations log required by Section III.B.18 ;

c. c ertification of oxidation catalyst operation and maintenance, including a summary of the semiannual inspection required by Section III.B.20;OP3211

- 02 9 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 d. c ertification of compliance with the applicable requirements contain ed in the Acid Rain Program contained in 40 CFR 72

- 78.

e. a summary of any testing and reporting as may be applicable pursuant to 40 CFR 63, Subpart

ZZZZ

.OP3211

- 02 10 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 SECTION IV. NON

- APPLICABLE REQUIREMENTS

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable to the facility or to a specific emissions unit at the time of the permit issuance are listed below (ARM 17.8.1214). The following list does not preclude the need to comply with any new requirements that may

becom e applicable during the permit term.

A. Facility

- Wide

The following table contains non

- applicable requirements which are administrated by the Air Resources Management Bureau of the Department of Environmental Quality.

Rule Citation Reason State Federal

ARM 17.8.321

ARM 17.8.323

ARM 17.8 331

ARM 17.8.332

ARM 17.8.333

ARM 17.8.334

ARM 17.8.335

ARM 17.8.506

ARM 17.8.610
ARM 17.8, Subchapters 16

and 17 These rules are not applicable because the facility is not listed in the source category cited in the rules.

ARM 17.8.316

ARM 17.8.320

ARM 17.8.324 These rules are not applicable because the facility does not have the specific emissions unit that is

cited in the rules.

ARM 17.8.809

ARM 17.8.818

ARM 17.8.819

ARM 17.8.820

ARM 17.8.821

ARM 17.8.822

A RM 17.8.823

ARM 17.8.824

ARM 17.8.827 These rules are not applicable because the facility is not classified as a major stationary source under

ARM 17.8.801.

ARM 17.8.1106

ARM 17.8.1107

ARM 17.8.1110

ARM 17.8.1111 These rules are not applicable because the facility has not made any changes that would trigger these procedural rule requirements.

ARM 17.8, Subchapters 13

and 14 These rules apply only to the Department, EPA, and/or regional authorities.

40 CFR 55 These rules are not applicable to the fa cility

because it is not located on an outer continental

shelf

40 CFR 57

40 CFR 59 40 CFR 60, Subparts C, Cb, Cc, Cd, Ce 40 CFR 60, Subparts D, Da, Db, Dc 40 CFR 60, Subparts E

- J 40 CFR 60, Subparts K, Ka, Kb 40 CFR 60, Subparts L

- Z 40 CFR 60, Subparts AA

- EE 40 CFR 60, Subpart GG

- HH 40 CFR 60, Subparts KK

- NN 40 CFR 60, Subparts PP

- XX 40 CFR 60, Subparts AAA

- BBB These requirements are not applicable b ecause the facility is not an affected source as defined in these regulations.OP3211

- 02 11 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 Rule Citation Reason State Federal

40 CFR 60, Subparts DDD 40 CFR 60, Subparts FFF

- JJJ 40 CFR 60, Subpart KKK

- LLL 40 CFR 60, Subparts NNN

- WWW

40 CFR 60, Subparts AAAA

- FFFF (IIII

- KK KK) 40 CFR 61, Subparts B

- F 40 CFR 61, Subparts H

- L 40 CFR 61, Subparts N

- R 40 CFR 61, Subpart T 40 CFR 61, Subparts V

- W 40 CFR 61, Subpart Y 40 CFR 61, Subpart BB 40 CFR 61, Subpart FF 40 CFR 63, Subparts F

- J 40 CFR 63, Subparts L

- O 40 CFR 63, Subpart Q

- U 40 CFR 63, Subpart W

- Y 40 CFR 63, Subpart AA

- EE 40 CFR 63, Subpart GG

- MM 40 CFR 63, Subpart II

- MM 40 CFR 63, Subparts OO

- YY 40 CFR 63, Subparts CCC

- EEE 40 CFR 63, Subparts GGG

- JJJ 40 CFR 63, Subparts LLL

- RRR 40 CFR 63, Subparts TTT

- VVV 40 CFR 63, Subpart XXX 40 CFR 63, Subpart AAAA. 40 CFR 63, Subparts CCCC

- KKKK 40 CFR 63, Subparts MMMM

- YYYY 40 CFR 63, Subparts AAAAA

- NNNNN 40 CFR 63, Subparts PPPPP

- TTTTT 40 CFR 63, Subpart WWWWW 40 CFR 63, Subpart YYYYY

- ZZZZZ 40 CFR 63, Subparts BBBBBB

HHHHHH 40 CFR 63, S ubparts LLLLLL

TTTTTT 40 CFR 63, Subparts WWWWWW

ZZZZZZ 40 CFR 63, Subparts AAAAAAA

DDDDDDD 40 CFR 63, Appendices B

- E

40 CFR 65

40 CFR 79

- 80 40 CFR 82, Subpart A

- E, G

- I

40 CFR 85

- 86

40 CFR 88

40 CFR 93

40 CFR 95

- 97 40 CFR 60, Subpart GG 40 CFR 60, Subparts IIII

- KKKK 40 CFR 63, Subparts YYYY

40 CFR 68

40 CFR 69

40 CFR 87

40 CFR 89

- 92

40 CFR 94 These requirements refer to a process, equip ment, or activity that is not used at this facility

40 CFR 72

- 40 CFR 78 These requirements are not applicable because the facility is not an affected source as defined by the acid rain regulations.OP3211

- 02 12 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 B. Emission Units

The permit application identified ap plicable requirements: non

- applicable requirements for individual or specific emission units were not listed. The Department has listed all non

- applicable requirements in Section IV.A, these requirements relate to each specific unit, as well as facility w ideOP3211

- 02 13 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 SECTION V. GENERAL PERMIT CONDITIONS

A. Compliance Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)

- (c)&(e), §1206(6)(c)&(b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the

terms or co nditions of the permit constitutes a violation of the Montana Clean Air Act, and may result in enforcement action, permit modification, revocation and reissuance, or termination, or denial of a permit renewal application under ARM Title 17, Chapter 8, Subc hapter 12.

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

3. It shall not be a defense f or a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. If appropriate, this factor may be considered as a mitigating factor in

a ssessing a penalty for noncompliance with an applicable requirement if the source demonstrates that both the health, safety or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing operations, and that such health, safety or environmental impacts were unforeseeable and could not have otherwise been

avoided.

4. The permittee shall furnish to the Department, within a reasonable time set by the Department (not to be less than 15 days), any information that t he Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Department copies of those records that are required to be kept pursuant to the terms of the permit. This subsection does not impair or otherwise limit the right of the permittee to assert the confidentiality of the information requested by the Department, as provided in 75

- 2

- 105, MCA.

5. Any schedule of compliance for applicable requirements with which the source is not in compliance with at the time of permit issuance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it was based.

6. For applicable requirements that will become effective during the permit term, the source shall meet such requirements on a timely basis unless a more detailed plan or schedule is required by the applicable requirement or the Department.

B. Certi fication Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)

- (d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, based on information and belief formed after reasonable inquiry, the statemen ts and information in the document are true, accurate and complete.OP3211

- 02 14 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 2. Compliance certifications shall be submitted by February 15 of each year, or more frequently if otherwise specified in an applicable requirement or elsewhere in the permit. Each certif ication must include the required information for the previous calendar year (i.e., January 1

– December 31).

3. Compliance certifications shall include the following:

a. The identification of each term or condition of the permit that is the basis of the

certi fication;

b. The identification of the method(s) or other means used by the owner or operator for determining the status of compliance with each term and condition during the certification period, consistent with ARM 17.8.1212;

c. The status of compliance with each term and condition for the period covered by the certification, including whether compliance during the period was continuous or

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as described above); and

d. Such other fa cts as the Department may require to determine the compliance status of the

source.

4. All compliance certifications must be submitted to the Environmental Protection Agency, as well as to the Department, at the addresses listed in the Notification Addresses Appendix of this permit.

C. Permit Shield ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)

- (4)

1. The applicable requirements and non

- federally enforceable requirements are included and specifically identified in this permit and the permit includes a precise summary of the requirements not applicable to the source. Compliance with the conditions of the permit shall be deemed compliance with any applicable requirements and any non

- federally enforceable requirements as of the date of permit issuance.

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit action (renewal, revision, reopening, or revocation and reissuance) to the Board of Environmental Review (Board), until such time as the Board renders its final decision.

3. Nothing in this permit alters or affects the following:

a. The provisions of Sec. 7603 of the FCAA, including the authority of the administrator under that section;

b. The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance;

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) of the FCAA;

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414

of the F CAA;OP3211

- 02 15 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 e. The ability of the Department to obtain information from a source pursuant to the Montana Clean Air Act, Title 75, Chapter 2, MCA;

f. The emergency powers of the Department under the Montana Clean Air Act, Title 75, Chapter 2, MCA; and

g. The ability of the Department to establish or revise requirements for the use of R easonably

A vailable C ontrol T echnology (RACT) as defined in ARM Title 17, Chapter 8. However, if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s existing permit, shall remain in effect until such time as the Board has rendered its final

decision.

4. Nothing in this permit alters or affects the ability of the Department to tak e enforcement action for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 17.8.106, Source Testing Protocol.

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in

these rules sha ll preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance. However, when compliance or noncompliance is demonstrated by a test or procedure provided by permit or

ot her applicable requirements, the source shall then be presumed to be in compliance or noncompliance unless that presumption is overcome by other relevant credible evidence.

6. The permit shield will not extend to minor permit modifications or changes not req uiring a permit revision (see Sections I & J).

7. The permit shield will extend to significant permit modifications and transfer or assignment of ownership (see Sections K & O ).

D. Monitoring, Recordkeeping, and Reporting Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring records that include the following information:

a. The date, place as defined in the permit, and time of sampling or measureme nt;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The results of such analyses; and

f. The operating conditions at the time of sampling or measurement.

2. The permittee sh all retain records of all required monitoring data and support information for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records a nd all original strip

- chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All monitoring data, support information, and required reportsOP3211

- 02 16 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 and summaries may be maintained in computerized form at the plant site if the information is made available to Department personnel upon request, which may be for either hard copies or computerized format. Strip

- charts must be maintained in their original form at the plant site and shall be made available to Depar tment personnel upon request.

3. The permittee shall submit to the Department, at the addresses located in the Notification Addresses Appendix of this permit, reports of any required monitoring by February 15 and August 15 of each year, or more frequently if otherwise specified in an applicable requirement or elsewhere in the permit. The monitoring report submitted on February 15 of each year must include the required monitoring information for the period of July 1 through December 31 of the previous year. The monitoring report submitted on August 15 of each year must include the required monitoring information for the period of January 1 through June 30 of the current year. All instances of deviations from the permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official, consistent with ARM

17.8.1207.

E. Prompt Deviation Reporting ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations fr om permit requirements, including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. To be considered prompt, deviations shall be reported to the Department within the following timeframes (unless otherwise specified in an applicable requirement):

1. For deviations which may result in emissions potentially in violation of permit limitations:

a. An initial phone notification (or faxed or electronic noti fication) describing the incident within 24 hours (or the next business day) of discovery; and,

b. A follow

- up written, faxed, or electronic report within 30 days of discovery of the deviation that describes the probable cause of the reported deviation and a ny corrective actions or preventative measures taken

.

2. For deviations attributable to malfunctions, deviations shall be reported to the Department in accordance with the malfunction reporting requirements under ARM 17.8.110 ; and

3. For all other deviations, deviations shall be reported to the Department via a written, faxed, or electronic report within 90 days of discovery (as determined through routine internal review by the permittee).

Prompt deviation reports do not need to be resubmitted with regular sem iannual (or other routine) reports, but may be referenced by the date of submittal.

F. Emergency Provisions ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arising from sudden and reasonab ly unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation and causes the source to exceed a technology

based emission limitation under this permit due t o the unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of reasonable preventive maintenance, careless or improper operation, or opera tor error.OP3211

- 02 17 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a technology

- based emission limitation if the permittee demonstrates through properly signed, contemporaneous logs, or other relevant evidence, that:

a. A n emergency occurred and the permittee can identify the cause(s) of the emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in the permit; and

d. The permittee submitted notice of the emergency to the Department within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice

f ulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

3. These emergency provisions are in addition to any emergency, malfunction or ups et provision contained in any applicable requirement.

G. Inspection and Entry ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the permittee shall allow the Dep artment, the administrator, or an authorized representative (including an authorized contractor acting as a representative of the Department or the administrator) to perform the following:

a. Enter the premises where a source required to obtain a permit is l ocated or emissions

related activity is conducted, or where records must be kept under the conditions of the permit;

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit;

c. Inspect at reasonable tim es any facilities, emission units, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, samp le or monitor, at reasonable times, any substances or parameters at any location for the purpose of assuring compliance with the permit or applicable requirements.

2. The permittee shall inform the inspector of all workplace safety rules or requirements at t he time of inspection. This section shall not limit in any manner the Department’s statutory right of entry and inspection as provided for in 75

- 2

- 403, MCA.OP3211

- 02 18 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 H. Fee Payment ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subcha pter 5, Air Quality Permit Application, Operation, and Open Burning Fees §505(3)

- (5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, Subchapter 5.

2. Annually, the Department shall provide the permitt ee with written notice of the amount of the fee and the basis for the fee assessment. The air quality operation fee is due 30 days after receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any portion of the fee is n ot appealed, that portion of the fee that is not appealed is due 30 days after receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, is due immediately upon issuance of the Board’s decision or upon completion of any judicial

review of the Board’s decision.

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 90 days of the due date of the fee, the Department may impose an additional assessment of 15% of the fee (or any r equired portion of an appealed fee) or $100, whichever is greater, plus interest on the fee (or any required portion of an appealed fee), computed at the interest rate

established under 15

- 31

- 510(3), MCA.

I. Minor Permit Modifications ARM 17.8, Subchapter 12 , Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the permit application that require revision, updating, supplementation, or deletion, and may reference any required info rmation that has been previously submitted.

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed pursuant to ARM 17.8.1226.

J. Changes Not Requiring Permit Revision ARM 17.8, Subchapter 12, Operating Permit Program §122 4(1)

- (3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided the following conditions are met:

a. The proposed changes do not require the permittee to obtain a Montana Air Quality Permit under ARM Title 17, Chapter 8, Subchapter 7;

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in ARM Title 17, Chapter 8, Subchapters 8, 9, or 10;

c. The emissions resulting from the proposed changes do not exceed the emissions allowable

unde r this permit, whether expressed as a rate of emissions or in total emissions;

d. The proposed changes do not alter permit terms that are necessary to enforce applicable emission limitations on emission units covered by the permit; and

e. The facility provides the administrator and the Department with written notification at least 7 days prior to making the proposed changes.OP3211

- 02 19 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to their respective copies of this permit.

3. Pur suant to the conditions above, the permittee is authorized to make Section 502(b)(10) changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, the written notification required under 1.e above shall include a description of the change within the source, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change.

4. The permittee may make a change not specifically addressed or prohi bited by the permit terms and conditions without requiring a permit revision, provided the following conditions are met:

a. Each proposed change does not weaken the enforceability of any existing permit conditions;

b. The Department has not objected to such ch ange;

c. Each proposed change meets all applicable requirements and does not violate any existing permit term or condition; and

d. The permittee provides contemporaneous written notice to the Department and the administrator of each change that is above the le vel for insignificant emission units as defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each such change, including the date of the change, any change in emissions, pollutants emitted, and any applicable requirement that wou ld apply as a result of the change.

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases and decreases in emissions pursuant to ARM 17.8.1224(4).

K. Significant Permit Modifications ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a significant modification of this perm it. Significant modifications include the following:

a. Any permit modification that does not qualify as either a minor modification or as an administrative permit amendment;

b. Every significant change in existing permit monitoring terms or conditions;

c. Ever y relaxation of permit reporting or recordkeeping terms or conditions that limit the Department’s ability to determine compliance with any applicable rule, consistent with the requirements of the rule; or

d. Any other change determined by the Department to b e significant.

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including those for applications, public participation, and review by affected states and the administrator, as they apply to permit issuance and renewal, exc ept that an application for a significant permit modification need only address in detail those portions of the permit application that require revision, updating, supplementation or deletion.OP3211

- 02 20 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 3. The permit shield provided for in ARM 17.8.1214 shall extend t o significant modifications.

L. Reopening for Cause ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the following circumstances:

1. Additional applicable requirements under the FCAA become applicabl e to the facility when the permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be completed not later than 18 months after promulgation of the applicable requirement. No reopening is required under ARM 17.8.1228(1)( a) if the effective date of the applicable requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms or conditions have been extended pursuant to ARM 17.8.1220(12) or 17.8.1221(2);

2. Additional r equirements (including excess emission requirements) become applicable to an affected source under the Acid Rain Program. Upon approval by the administrator, excess emission offset plans shall be deemed incorporated into the permit;

3. The Department or the administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the emission standards or other terms or conditions of the permit; or

4. The administrator or the Department determines that the per mit must be revised or revoked and reissued to ensure compliance with the applicable requirements.

M. Permit Expiration and Renewal ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fi xed term of 5 years.

2. Renewal of this permit is subject to the same procedural requirements that apply to permit issuance, including those for application, content, public participation, and affected state and

administrator review.

3. Expiration of this perm it terminates the permittee’s right to operate unless a timely and administratively complete renewal application has been submitted consistent with ARM 17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been

submitted , all terms and conditions of the permit, including the application shield, remain in effect after the permit expires until the permit renewal has been issued or denied.

4. For renewal, the permittee shall submit a complete air quality operating permit appli cation to the Department not later than 6 months prior to the expiration of this permit, unless otherwise specified. If necessary to ensure that the terms of the existing permit will not lapse before renewal, the Department may specify, in writing to the permittee, a longer time period for submission of the renewal application. Such written notification must be provided at least 1 year before the renewal application due date established in the existing permit.

N. Severability Clause ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of an initial permit under this subchapter shall not impair in any manner the underlying applicability of all applicable re quirements, and such requirements continue to apply as if a final permit decision had not been reached by the Department.OP3211

- 02 21 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 2. If any provision of a permit is found to be invalid, all valid parts that are severable from the invalid part remain in effect. If a provision of a permit is invalid in one or more of its applications, the provision remains in effect in all valid applications that are severable from the invalid applications.

O. Transfer or Assignment of Ownership ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, the applicant must include in its request to the Department a written agreement containing a specific date for the transfer of permit respon sibility, coverage and liability between the current and new permittee.

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative permit

amendments.

P. Emissions Trading, Marketable Permits, Economic Incentives ARM 17.8, Subchapter 1 2, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification procedures may be used for permit modifications involving the use of economic incentives, marketable permits, emissions trading, and other similar approaches, to the extent that such minor permit modification procedures are explicitly provided for in the Montana State Implementation Plan or in applicable requirements promulgated by the administrator.

Q. No Property Rights Conveyed

AR M 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

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

R. Testing Requirements ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105.

S. Source Testing Protocol ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106.

T. Malfunctions ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110.

U. Circumvention

A RM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111.OP3211

- 02 22 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 V. Motor Vehicles ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325.

W. Annual Emissions Inventory ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 (STATE ONLY)

The permittee shall supply the Department with annual production and other information for all emission units necessary to calculate actual or estimated actual amount of air pollutants emitted during each calendar year. Information shall be gathered on a calendar

- year basis and submitted to the Department by the date required in the emission inventory request, unless otherwise specified in this permit. Information shall be in the units required by the Department.

X. Open Burning ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606.

Y. Montana Air Quality Permits ARM 17.8, Subchapter 7, Permit, Construction and Opera tion of Air Contaminant Sources §745 and

764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP)

1. Except as specified, no person shall construct, install, modify or use any air contaminant source

or stack associated with any source without first obtaining a permit from the Department or Board. A permit is not required for those sources or stacks as specified by ARM 17.8.744(1)(a)

- (k).

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764.

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of operation at a facility holding a Montana Air Quality Permit (MAQP) issued under Chapter 8 that does not increase the facility’s potential to emit by more than 5 tons pe r year of any pollutant, except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP):

a. Any construction or changed condition that would violate any condition in the facility’s existing MAQP or any applicable rule contained in Chapter 8 is prohibited, except as provided in ARM 17.8.745(2);

b. Any construction or changed conditions of operation that would qualify as a major modification under Subchapters 8, 9 or 10 of Chapter 8;

c. Any construction or changed condition of operation that would aff ect the plume rise or dispersion characteristic of emissions that would cause or contribute to a violation of an ambient air quality standard or ambient air increment as defined in ARM 17.8.804;

d. Any construction or improvement project with a potentia l to emit more than 5 tons per year may not be artificially split into smaller projects to avoid Montana Air Quality Permitting ;

orOP3211

- 02 23 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 e. Emission reductions obtained through offsetting within a facility are not included when determining the potential emission incre ase from construction or changed conditions of operation, unless such reductions are made federally enforceable.

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the Department if the change would include a change in contro l equipment, stack height, stack diameter, stack gas temperature, source location or fuel specifications, or would result in an increase in source capacity above its permitted operation or the addition of a new emission unit. The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de minimis change, or as soon as reasonably practicable in the event of an unanticipated circumstance causing the de minimis change, and must include the information requested in ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP).

Z. National Emission Standard for Asbestos 40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 CFR 61, Subpart M (N ational Emission Standard for Hazardous Air Pollutants for Asbestos).

AA. Asbestos ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq. , and ARM 17.74.401, et seq . (State only)

BB. Stratospher ic Ozone Protection

– Servicing of Motor Vehicle Air Conditioners 40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone

- depleting substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR 82, Subpart B.

CC. Stratospheric Ozone Protection

– Recycling and Emission Reductions 40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling a nd emission reductions in 40 CFR 82, Subpart F, except as provided for MVACs in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156;

2. Equipment used during the mai ntenance, service, repair or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to §82.158;

3. Persons performing maintenance, service, repair or disposal of appliances must be certified by an approved technic al certification program pursuant to §82.161;

4. Persons disposing of small appliances, MVACs and MVAC

- like (as defined at §82.152) appliances must comply with recordkeeping requirements pursuant to §82.166;

5. Persons owning commercial or industrial process r efrigeration equipment must comply with the leak repair requirements pursuant to §82.156; andOP3211

- 02 24 Date of Decision: 0 7/28 /2011

Effective Date: 09/04/2011 6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursu ant to §82.166.

DD. Emergency Episode Plan

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of Montana Air Quality Control Implementation Plan.

Each major source emitting 100 tons per year located in a Priority I Air Qu ality Control Region, shall submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that details how the source will curtail emissions during an air pollutant emergency episode. The industrial

EEAP shall be in accordance with t he Department’s EEAP and shall be submitted according to a timetable developed by the Department, following Priority I reclassification.

EE. Definitions

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permi t, shall have the meaning assigned to them in the referenced regulations.OP3211

- 02 25 Date of Decision: 0 7/28 /2011 Effective Date; 09/04/2011 APPENDICESOP3211

- 02 A

- 1 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Appendix A INSIGNIFICANT EMISSION UNITS

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to

assist BCEP , the permitting auth ority, inspectors, and the public.

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emissions unit located within a source that: (i) has a potential to emit less than 5 tons per year of any regulated pollutant; (ii) h as a potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 pounds per year of hazardous air pollutants listed pursuant to S ection 7412 (b) of the FCAA; and (iv) is not regulated by an applicable requirement, o ther than a generally applicable requirement that applies to all emission units subject to Subchapter 12.

List of Insignificant Activities:

The following table of insignificant sources and/or activities were provided by BCEP

.

Emissions Unit ID Descrip tion

IEU01 9

– Natural Gas

- Fired Furnace Heaters @ 2.0 MMBtu/hr/heater

IEU02 9

– Natural Gas

- Fired Combustion Air Pre

- Heaters @ 2.5 MMBtu/hr/Unit

IEU03 Fugitive Emissions: Haul Roads/Vehicle TrafficOP3211

- 02 B

- 1 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Appendix B DEFINITIONS and ABBREVIATIONS

"Act" means the Cl ean Air Act, as amended, 42 U.S. 7401, et seq

.

"Administrative permit amendment" means an air quality operating permit revision that:

(a) corrects typographical errors;

(b) identifies a change in the name, address or phone number of any person identified in the air quality operating permit, or identifies a similar minor administrative change at the source;

(c) requires more frequent monitoring or reporting by BCEP ;

(d) requires changes in monitoring or reporting requirements that the Department deems to be no

less str ingent than current monitoring or reporting requirements;

(e) allows for a change in ownership or operational control of a source if the Department has determined that no other change in the air quality operating permit is necessary, consistent

with ARM 17.8. 1225; or

(f) incorporates any other type of change which the Department has determined to be similar to those revisions set forth in (a)

- (e), above.

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an air quality operating permit (including requirements that have been promulgated or approved by the Department or the administrator through rule making at the time of issuance of the air quality operating permit, but have future

- effective compliance dates, provided that such requirements apply to sources covered under the operating permit):

(a) any standard, rule, or other requirement, including any requirement contained in a consent decree or judicial or administrative order entered into or issued by the Depar tment, that is contained in the Montana state implementation plan approved or promulgated by the administrator through rule making under Title I of the FCAA;

(b) any federally enforceable term, condition or other requirement of any Montana Air Quality

Permit issued by the Department under S ubchapters 7, 8, 9 and 10 of this chapter, or pursuant to regulations approved or promulgated through rule making under Title I of the FCAA, including parts C and D;

(c) any standard or other requirement under Section 7411 of t he FCAA, including Section 7411(d);

(d) any stand ard or other requirement under Section 7412 of the FCAA, including any requirement concer ning accident prevention under Section 7412(r)(7), but excluding the contents of any risk man agement plan required under Section 7412(r);

(e) any standard or other requirement of the acid rain program under Title IV of the FCAA or regulations promulgated thereunder;

(f) any requireme nts established pursuant to Section 7661c(b) or Section 7414(a)(3) of the
FCAA;OP3211

- 02 B

- 2 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 (g) any standard or oth er requirement governing soli d waste incineration, under Section 7429 of the FCAA;

(h) any standard or other requirement for consumer an d commercial products, under Section 7511b(e) of the FCAA;

(i) any standard or other requirement for tank vessels, under Secti on 7511b(f) of the FCAA;

(j) any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the FCAA, unless the administrator determines that such requirements need not be contained in an air quality operati ng permit;

(k) any national ambient air quality standard or increment or visibility requirement under part C of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to

Section 7661c(e) of the FCAA; or

(l) any federally enforcea ble term or condition of any air quality open burning permit issued by the Department under S ubchapter 6.

"Department" means the Montana Department of Environmental Quality.

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit any regulated air pollutant or any pollutant listed under Section 7412(b) of the FCAA. This term is not meant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA.

"FCAA" means the Federal C lean Air Act, as amended.

"Federally enforceable" means all limitations and conditions which are enforceable by the administrator, including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana state implementat ion plan, and any permit requirement established pursuant to 40 CFR 52.21 or under regulations a pproved pursuant to 40 CFR 51, Subpart I, including operating permits issued under an EPA approved program that is incorporated into the Montana state implement ation plan and expressly requires adherence to any permit issued under such program.

"Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening.

"General air quality operating permit" or "general permit" means an air quality operating permit that meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in lieu of individual permits being issued to each source.

"Hazardous ai r pollutant" means any air pollutant listed as a hazar dous air pollutant pursuant to

S ection 112(b) of the FCAA.

"Non

- federally enforceable requirement" means the following as they apply to emission units in a source requiring an air quality operating pe rmit:

(a) any standard, rule, or other requirement, including any requirement contained in a consent decree, or judicial or administrative order entered into or issued by the Department, that is not contained in the Montana state implementation plan approved or promulgated by the administrator through rule making under Title I of the FCAA;OP3211

- 02 B

- 3 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 (b) any term, condition or other requirement contained in any Montana Air Quality P ermit issued by the Department under S ubchapters 7, 8, 9 and 10 of this chapter that is not fe derally enforceable;

(c) does not include any Montana ambient air quality standard contained in Subchapter 2 of this chapter.

"Permittee" means the owner or operator of any source subject to the permitting requirements of this subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has submitted a timely and complete permit application for issuance, renewal, amendment, or modification pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) nitrogen ox ides or any volatile organic compounds;

(b) any pollutant for which a national ambient air quality standard has been promulgated;

(c) any pollutant that is subject to any standard promulgated under Section 7411 of the FCAA;

(d) any Class I or II substance subject t o a standard promulgated under or established by Title VI of the FCAA; or

(e) any pollutant subject to a standard or other requirement estab lished or promulgated under

Section 7412 of the FCAA, including but not limited to the following:

(i) any pollutant su bjec t to requirements under Section 7412(j) of the FCAA. If the administrator fails to promulgate a stand ard by the date established in S ection 7412(e) of the FCAA, any pollutant for which a subject source would be major shall be considered to be regulated on the date 18 months after the applicable date established in S ection 7412(e) of the FCAA;

(ii) any pollutant for which the requirements of S ection 7412(g)(2) of the FCAA have been met but only with respect to th e individual source subject to Section 7412(g)(2 ) requirement.

"Responsible official" means one of the following:

(a) For a corporation: a president, secretary, treasurer, or vice

- president of the corporation in charge of a principal business function, or any other person who performs similar policy or

de cision

- making functions for the corporation, or a duly authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a pe rmit and

either:

(i) the facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or

(ii) the delegation of authority to such representative is approved in advance by the Departmen t.

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively.OP3211

- 02 B

- 4 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 (c) For a municipality, state, federal, or other public agency: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a federal agency includes the chief executive officer having responsibility for the overall operations of a principal geographic unit of the agency (e.g., a regional administrator of the environmental protection agency).

(d) Fo r affected sources: the designated representative in so far as actions, standards, requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated thereunder are concerned, and the designated representative for any other purposes un der this subchapter.OP3211

- 02 B

- 5 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Abbreviations:

ARM Administrative Rules of Montana

ASTM American Society of Testing Materials

BACT Best Available Control Technology

BDT bone dry tons

BTU British Thermal Unit

CFR Code of Federal Regulations

CO carbon monoxide DEQ Department of Environmental Quality

dscf dry standard cubic foot

dscfm dry standard cubic foot per minute

EEAP Emergency Episode Action Plan

EPA U.S. Environmental Protection Agency

EPA Method Test methods contained in 40 CFR 60, Appendix A

EU emissions un it

FCAA Federal Clean Air Act

gr grains

HAP hazardous air pollutant

IEU insignificant emissions unit

Mbdft thousand board feet

Method 5 40 CFR 60, Appendix A, Method 5

Method 9 40 CFR 60, Appendix A, Method 9

MMbdft million board feet

MMBTU million British Thermal Units

NOx oxides of nitrogen

NO 2 nitrogen dioxide

O 2 oxygen Pb lead

PM particulate matter

PM10 particulate matter less than 10 microns in size psi pounds per square inch

scf standard cubic feet

SIC Source Industrial Classification

SO 2 sulfur dioxi de

SOx oxides of sulfur

tpy tons per year
U.S.C. United States Code

VE visible emissions

VOC volatile organic compoundOP3211

- 02 C

- 1 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Appendix C NOTIFICATION ADDRESSES

Compliance Notifications:

Montana Department of Environmental Quality Permitting and Compliance Division

Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

United States EPA Air Program Coordinator Region VIII, Montana Office

10 W. 15 th Street, Suite 3200 Helena, MT 59626

Permit Modifications:

Montana Department of Environmental Quality

Perm itting and Compliance Division Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

Office of Partnerships and Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P

- AR 1595 Wynkoop Street
Denver, CO 80202

- 1129OP3211

- 02 D

- 1 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Appendix D AIR QUALI TY INSPECTOR INFORMATION

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to

assist BCEP, the permitting authority, inspectors, and the public.

1. Direction to Plant: Exit Interstate 90 at the Harrison Av e. Proceed south on Harrison Avenue approximately 2 miles pa s t the Bert Mooney Airport turn West and travel approximately 3⁄4 of a mile to the Butte, MT Industrial Park.

2. Safety Equipment Required: BCEP’s policy requires the following safety equipment; safe ty glasses, hearing protection, and hard hat.

3. Facility Plot Plan: A facility plot plan was included with BCEP’s Title V Operating Permit application and is available for review, upon request.OP3211

- 02 D

- 2 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 COMPLIANCE ASSURANCE MONITORING

Oxidation Catalyst for CO Control (EU001) Compliance Assurance Monitoring Plan

Background: The following Compliance Assurance Monitoring (CAM) plan was proposed by BCEP for Operating Permit #OP3211

- 02.

Emissions Unit

Description: Caterpillar Lean

- Burn Natural Gas

- Fired Reciproc ating Internal Combustion Engines (9 RICE at 6.1 MW/RICE)

Identification: EU001 (From Operating Permit OP3211

- 01)

Applicable Regulations, Emission Limit, and Monitoring Requirements Carbon Monoxide (CO)

Requirement: Montana Air Quality Operating Permit Number

OP3211

- 02

Emission Limit: 5.1 lbs CO/hr Monitoring Requirements: Administrative Rules of Montana Chapter 17.8 Air Quality, Subchapter 15 Compliance Assurance Monitoring

Control Technology: Oxidation Catalyst

Monitoring Approach:

The key elements of the monitoring approach are presented in the following table. Engine exhaust temperature prior to the catalyst shall be measured and recorded for each of the 9 RICEs once per day during unit operation. Additionally, semi

- annual cat alyst inspections will be performed in accordance with the manufacturer’s specifications. Please note that this CAM plan is not in effect when an engine is not in operation.OP3211

- 02 D

- 3 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 Indicator No. 1: Temperature Monitoring Indicator No. 2: Catalyst Inspection

I. Indicator Temperature of exhaust gas into the catalyst. Inspection/Preventative Maintenance (IPM) of catalyst in accordance with plan.

Measurement Approach Temperature of exhaust gas into the catalyst is monitored at the turbocharger turbine inlet points A and B using thermocouples. Semi

- annual IPM in accordance with the manufacturers’ specifications. Maintenance performed as needed.

II. Indicator Range Temperature of the exhaust gas prior to the catalyst shall be maintained between 450°F (232°C) and 1350°F (732°C) during unit operation. N/A

III. Performance Criteria

A. Data Representativeness Temperature of exhaust gas into the catalyst is monitored at the turbocharger turbine inlet points A and B using thermocouples. IPM is performed on the catalyst according to the manufacturer’s recommendations and specifications.

B. QA/QC Practices and

Criteria Thermocouples calibrated semi

annually per manufacturer’s specifications. Qualified personnel perform IPM.

C. Monitoring Frequency Temperatu re is monitored and recorded once per day during unit operation. Semi

- annually.

Data Collection Procedures Temperature data will be recorded once per day during unit operation using either log sheets or a data acquisition system. No observation require d for days when engine does

not operate. Records are maintained to document

semi

- annual IPM, and any maintenance performed.

Averaging period None. N/A

Response to Excursion :

Excursions of the catalyst inlet temperature range will trigger an inspect ion, possible corrective action, and reporting. Maintenance personnel will inspect the catalysts within 24 hours of receiving notification and make needed repairs as soon as practicable. Operation will return to normal upon completed corrective action.

Monitoring Approach Justification :

Background

The Basin Creek facility is an electrical generation plant consisting of nine natural gas

- fired RICE, each rated at 8180 horsepower ( hp ) . Each of the RICE has an electrical generation capacity of 6.1 MW, wi th a total facility electrical generation capacity of 54.9 MW.OP3211

- 02 D

- 4 Date of Decision: 0 7/28 /2011
Effective Date; 09/04/2011 This CAM Plan is a pollutant

- specific plan for control of CO from EU001 (nine Caterpillar lean

burn natural gas

- fired RICE). This plan describes the compliance assurance monitoring strategy for CO emissions using an oxidation catalyst. Because EU001 consists of nine separate units, each with its own control device, the CAM plan applies to each engine as it is operating, not to

EU001 as a whole.

The monitoring approach outlined here applies t o the oxidation catalyst system used on the nine natural gas

- fired engines (EU001). The reduction reaction does not take place properly if the temperature of the engine exhaust gas into the catalyst system is too low or too high.

Rationale for Selection t he of Performance Indicators

The turbocharger turbine inlet temperature is currently monitored and serves as an accurate indicator of the engine exhaust temperature. Monitoring this temperature will assure that the oxidation catalyst inlet temperature is in a range that will allow the catalyst to operate effectively. It has been proven that the oxidation catalysts operate properly in multiple stack tests where both turbocharger turbine inlet temperature and CO emissions were monitored for each engine. T he results of the CO emissions tests indicate the oxidation catalyst was performing sufficiently to enable Basin Creek to meet its CO emission limits. The proposed temperature monitoring plan will ensure that the oxidation catalyst will be operating in an ideal temperature range for optimal

CO destruction.

Semi

- annual catalyst inspections will ensure that the catalyst is in good, working order. By verifying that the catalysts of each of the nine engines are in good condition, it ensures that exhaust gas w ill flow through the catalyst as it is designed and that the catalyst performance will not be affected by any foreign matter or substance.

Rationale for Selection of Temperature Indicator Range and Semi

- Annual Inspections

Temperatures that are too low will result in a reduction of the chemical reactions that destruct CO. Temperatures that are too high will result in sintering of the catalyst. The temperature range proposed is also in line with the temperature range specified in the proposed 40 CFR 63 Subpart ZZZZ regulations. The semi

- annual inspection criteria were developed by the catalyst manufacturer in order to maintain the catalyst in good working order. The manufacturer developed plan was determined to be the best possible plan for ensuring c atalyst performance.