Page 2 of 25 

### Abbreviations and Acronyms

BHP break horsepower

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

CFR Code of Federal Regulations

CO Carbon monoxide

EPA United States Environmental Protection Agency

°F degree Fahrenheit gal gallon

HAP Hazardous Air Pollutant

HHV higher heating value

hr hour

IC Internal Combustion kg kilogram

kW kiloWatt

lb pound

MVAC Motor Vehicle Air Conditioner

MMBtu million British Thermal Units

MMscf million Standard Cubic Feet

NO
x Nitrogen Oxides

O 2 Oxygen

PM Particulate Matter

PM

- 10 Particulate matter less than 10 microns in diameter

p pm parts per million QA Quality Assurance QC Quality Control

RICE Reciprocating Internal Combustion Engine

SCR Selective catalytic reduction

SO 2 Sulfur Dioxide

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

TSP Total Suspended Particulate

VOC Volatile Organic Compounds

yr yearPage 3 of 25 Table of Contents

TITLE V PERMIT TO OPERATE

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

Abbreviations and Acronyms

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

I. Source Identification

................................ ................................ ................................ ............. 5

I.A. General Information

................................ ................................ ................................ ......... 5

I.B. Emission

- Generating Units and Activities

................................ ................................ ....... 5

II. Standard Terms and Conditions

................................ ................................ .......................... 6

II.A. Duty to Comply

................................ ................................ ................................ ................ 6

II.B. Cr edible Evidence

................................ ................................ ................................ ............ 6

II.C. Permit Actions and Expiration

................................ ................................ ......................... 6

II.D. Changes Not Requiring Permit Modification

................................ ................................ ... 7

II.E. Inspection and Entry

................................ ................................ ................................ ......... 7

II.F. Fragmentation

................................ ................................ ................................ ................... 8

II.G. Property Rights

................................ ................................ ................................ ................. 8

II.H. Severability

................................ ................................ ................................ ....................... 8

II.I. Fees

................................ ................................ ................................ ................................ ... 8

II.J. Document Submittal

................................ ................................ ................................ ......... 8

II.K. Circumvention

................................ ................................ ................................ .................. 9

III. General Requirements

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

III.A. Work Practice Requirements

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

III.B. Monitoring and Testing

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

III.C. Recordkeeping Requirements

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

III.D. Notification and Reporting

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

III.E. Payment of Fees and Reporting of Actual Emissions

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

IV. Facility Wide Requirements

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

IV.A. Emission Limits

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

IV.B. Monitoring and Testing Requirements

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

V. Emis sion Unit Specific Requirements

—— Non

- Emergency Internal Combustion Engines

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

V.A. Emission Limits

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

V.B. Work Practice and Operational Requirements

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

V.C. Monitoring and Testing Requirements

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

V.D. Recordkeeping and Reporting Requirements

................................ ................................ . 21Page 4 of 25 VI. Emission Unit Specific Requirements

—— Commercial Emergency Compression Ignition IC Engines

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

VI.A. Emission Limits

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

VI.B. Work Practice and Operational Requirements

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

VI.C. Recordkeeping and Reporting Requirements

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

Attachment A

................................ ................................ ................................ .............................. 25Page 5 of 25 

### I. Source Identification

I.A. General Information

Applicant Name Morongo Band of Mission Indians

Mailing Address 12700 Pumarra Road Banning, CA 92220 Facility Name Morongo Casino Cogeneration Facility

Facility Location 49500 Seminole Drive, Cabazon, CA 92230

Reservation Morongo Band of Mission Indians

Responsible Official Robert Martin, Tribal Chairman (951) 755

- 5100

Facility Contact Michael Milhiser, Chief Administrative Officer (951) 755

- 5115

AFS Identification Number 06

- 065

- MOR01

SIC Code 7011 Hotels and Motels (Casino Hotels)

2012 NAICS Code 721120 Casino Hotels Process Description Cogeneration plant Source Category Synthetic Minor Source

I.B. Emission

- Generating Units and Activities

Emission

Unit I.D.

No. Unit Description Associated Control Equipment

EG

- 1 Caterpillar G3520 natural gas

- fired spark ignition 4 stroke lean burn IC engine (2,055 kW) SCR unit and oxidation catalyst with automatic shutdown system before the catalyst inlet temperature exceeds 1350°F

EG

- 2 Caterpillar G3520 natural gas

- fired spark ignition 4 stroke lean burn IC engine (2,055 kW) SCR unit and oxidation catalyst with automatic shutdown system before the catalyst inlet temperature exceeds 1350°F

EG

- 3 Caterpillar G3520 natural gas

- fired spark ignition 4 stroke lean burn IC engine (2,055 kW) SCR unit and oxidation catalyst with automatic shutdown system before the catalyst inlet temperature exceeds 1350°F

EG

- 4 Caterpillar G3520 natural gas

- fired spark ignition 4 stroke lean burn IC engine (2,055 kW) SCR unit and oxidation catalyst with automatic shutdown system before the catalyst inlet temperature exceeds 1350°F

EG

- 5 Caterpilla r 3516B diesel

- fired commercial compression ignition emergency IC engine (2,000 kW) N/A

EG

- 6 Caterpillar 3516B diesel

- fired commercial compression ignition emergency IC engine (2,000 kW) N/A

EG

- 7 Caterpillar 3516B diesel

- fired commercial compression ignition emergency IC engine (2,000 kW) N/APage 6 of 25 

### II. Standard Terms and Conditions

II.A. Duty to Comply

1. The permittee shall comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; f or permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. [4 0 CFR 71.6(a)(6)(i)]

2. It shall not be a defense for 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

condi tions of this permit. [40 CFR 71.6(a)(6)(ii)]

II.B. Credible Evidence

1. For the purpose of submitting compliance certifications in accordance with Condition III.D.3 of this permit, or establishing whether or not a person has violated or is in violation of any requirement of this permit, nothing shall preclude the use, includin g the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [Sections 113(a) and 11 3(e)(1) of the Act, 40 CFR 60.11(g), and 61.12]

II.C. Permit Actions and Expiration

1. This permit may be modified, revoked, reopened and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissua nce, or termination, or of a notification of planned changes or anticipated noncompliance does not

stay any permit condition. [40 CFR 71.6(a)(6)(iii)]

2. This permit may be reopened and revised by EPA following the procedures s pecified in 40

CFR 71.7(f)(2) a nd (3) under any of the fo llowing circumstances: [40 CFR 71.7(f)(1)]

a. Additional applicable requirements under the Act become applicable and the
remaining permit term is three or more years.

b. Additional requirements (including excess emissions requirements) become
applicable to an affected source under the acid rain program.

c. EPA determines that the permit contains a material mistake or that inaccurate
statements were made in establishing the emissions standards or other terms or
conditions of the permit.

d. EPA determines that the permit shall be revised or revoked to assure compliance with
the applicable requirements.

3. This permit is issued for a fixed term and will expire five years from the date of issuancePage 7 of 25 unless it is revoked or superseded by another per mit issued by EPA or an approved or
delegated authority. [40 CFR 71.6(a)(11)(ii)

- (iii)]

4. Permit expiration terminates the permittee’s right to operate the source unless a complete
permit renewal application has been submitted at least six months but not m ore than 18
months prior to the expiration date. If a complete permit renewal application has been
submitted in a timely manner, then the permit and any permit shield that may have been
granted shall not expire but shall remain in effect until the renewal permit is issued or the
renewal ap plication is denied.

[40 CFR 71.5(a)(1)(iii), 71.7(b), 71.7(c)(1)(ii), and 71.7(c)(3)]

II.D. Changes N ot Requiring Permit Modification

1. The permittee may make certain changes not addressed or prohibited by the permit
provided t he following requirements are met: [40 CFR 71.6(a)(12)]

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

b. The permittee provides written notice as required by Condition III.D.6 ;

c. The permittee keeps a record required by Condition III.C.2.

2. The permittee is allowed to make section 502(b)(10) of the Act changes without requiring a
permit revision, if the changes are not modifications under any provision of T itle I of the
Act and the changes do not exceed the emissions allowable under the permit. For each such
change, written notification as required by Condition III.D.7 shall be submitted to EPA. [40

CFR 71.6(a)(13)(i)]

3. No permit revision shall be required u nder any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provide d for in this permit. [40 CFR 71.6(a)(8)]

II.E. Inspection and Entry

1. Upon presentation of credentials and other doc uments as may be required by law,
the permittee shall allow EPA or authorized representatives to p erform the
following: [40 CFR 71.6(c)(2)]

a. Enter upon the permittee's premises where a part 71 source is located or emissions

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

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

c. Inspect at reasonable times any facilities, equipment (including monitoring and airPage 8 of 25 pollution control equipment), practices, or operations regulated or required under the
permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances or
parameters for the purpose of assuring compliance with the permit or ap plicable
requirements

.

II.F. Fragmentation

1. Fragmentation, which divides ownership of an operation within the same facility among
various owners where there is no real change in control, will not affect the applicability
of the provisions of 40 CFR P art 63. [40 C FR 63.4(c)]

II.G. Property Rights

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

[40 CFR 71.6(a)(6)(iv)]

II.H. Severability

1. The provisions of this permit are severable, and in the event of any challenge to any
portion of this permit, or if any portion is held invalid, the remaining permit conditions

shall remai n valid and in force. [40 CFR 71.6(a)(5)]

II.I. Fees

1. The permittee shall pay annual fees in accordance with Condition III.E.1.

[40 CFR 71.6(a)(7) and 71.9(a)]

II.J. Document Submittal

1. Any document required to be submitted under this permit shall contain a certification by a responsible official of truth, accuracy, and completeness. This certification and any other
certification required under this part shall state that, base d on information and belief
formed after reasonable inquiry, the statements and information in the document are true,
accurate, and complete. Unless otherwise specified in this permit, any document required
to be submitted under this permit shall be submit ted to: [40 CFR 71.5(d), 71.6(c)(1)]

Director, Enforcement Division (Attn: ENF

- 2

- 1)
U. S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105Page 9 of 25 II.K. Circumvention

1. The permittee shall not build, erect, install, or use any article, machine, equipment, or
process to conceal an emission that would otherwise constitute noncompliance with a

relevant standard. Such concealment includes, b ut is not limited to: [40 CFR 60.12 and
63.4(b)]

a. The use of diluents to achieve compliance w ith a relevant standard based on the
concentration of a pollutant in the effluent discharged to the atmosphere; and

b. The use of gaseous diluents to achieve compliance with a relevant standard for

visible emissions.Page 10 of 25 

### III. General Requirements

III.A. Work Practice Requirements

1. The permittee shall: [40 CFR 71.6(c)(3)]

a. Continue to comply with all applicable requirements with which the permittee is in
compliance at the time of permit issuance;

b. Comply on a timely basis with all applicable requirements that become effec tive
during the permit term; and

c. Comply with applicable requirements with which the permittee is not in
compliance at the time of permit issuance according to the compliance schedule in
the permit application.

2. The permittee shall comply with 40 CFR P art 6 1, S ubpart M for asbestos removal and
disposal when conducting any renovation or demolition at the facility.

[40 CFR P art 61, S ubpart M]

3. The permittee shall comply with the chemical accident release prevention provisions of

40 CFR P art 6 8 no later than the following dates: [40 CFR 68.10]

a. Three years after the date on which a regulated substance is first listed under 40

CFR 68.130; or

b. The date on which a regulated substance is first present above a threshold quantity
in a process.

4. Except as provided for motor vehicle air conditioners (MVACs) in 40 CFR P art 82,

S ubpart B, the permittee shall comply with the stratospheric ozone and climate protection
standards for recycling and emissions reduction pursuant to 40 CFR P art 82, S ubpart F

. [40 CFR P art 82, S ubpart F]

5. When service on motor vehicles involves ozone

- depleting substances in MVACs, the
permittee shall comply with all the applicable requirements for stratospheric ozone and
climate protection as specified in 40 CFR P art 82, S ubpa rt B. [40 CFR P art 82, S ubpart

B]

III.B. Monitoring and Testing

1. In addition to the specific testing requirements contained in the emission unit sections of
this permit, the permittee shall comply with the following generally applicable testing
requirements unle ss otherwise specified in the applicable regulation or emission unit
specific condition requiring the test, or EPA determines o therwise in writing:

[40 CFR 60.8(b)

- (g), 63.7(b)

- (g), 71.6(a)(3) and 71.6(c)(1)]Page 11 of 25 a. Testing shall be performed according to an EPA approved test plan that includes
and addresses the following element:

(1) Purpose and scope of testing;
(2) Source description and mode of operation during the test;

(3) Schedules and dates of testing;

(4) Process data to be collected during the test;
(5) Sampling and analysis procedures;
(6) Sampling locations;

(7) Test methods;

(8) Analysis procedures and laboratory identification;

(9) Quality assurance;
(10) Calibration procedures and frequency;

(11) Sample recovery and field documentation;

(12) Chain of custody procedures;

(13) QA/QC project flow cha rt;
(14) Data processing and reporting
(15) Description of data handling and QC procedures; and

(16) Report content and timing.

b. The source shall be operated at a capacity at leas t 90 percent but no more than 11 0
percent of design capacity during each test run.

c. All perfor mance tests and data reduction shall be conducted in accordance with the
procedur es in the appendices of 40 CFR P art 51, 60, 61, or 63.

d. Only regular operating staff may adjust the processes or emission control device
parameters during a compliance source test. No adjustments are to be made within
two hours of the start of the tests. Any operating adjustments made during a source
test, that are a result of consultation during the tests with source testing personnel,
equipment vendors, or consultants, may re nder the source test invalid.

e. Each source test shall consist of at least three test runs and the emission results shall
be reported as the arithmetic average of all valid test runs and in the terms o f the

emission limit. There shall be at least two valid t est runs for the test to be

considered valid.

2. The permittee shall provide performance testing fa cilities as follows:

[40 CFR 60.8(b)

- (g), 63.7(b)

- (g), 71.6(a)(3) and 71.6(c)(1)]

a. Sampling ports adequate for test methods applicable to such source. This includes:

(1) Constructing the air pollution control system such that volumetric flow
rates and pollutant emission rates can be accurately determined by
applicable test methods and proce dures; and

(2) Providing a stack or duct free of cyclonic flow during performance tests,
as demonstrated by applicable test methods and procedures;

b. Safe sampling platform(s);Page 12 of 25 c. Safe access to sampling platform(s);

d. Utilities for sampling and testing equipment ; and

e. Any other facilities that the Administrator deems necessary for safe and adequate
testing of a source.

III.C. Recordkeeping Requirements

1. The permittee shall keep records of required monitoring information that i nclude the
following: [40 CFR 71.6(a)(3)(ii )(A)]

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

measurements;

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 as existing at the time of sampling or measurement.

2. The permittee shall keep a record describing off

- permit changes allowed by

Condition II.D .1 made at the source that result in emissions of a regulated air
pollutant subject to an app licable requirement, but not otherwise regulated under the
permit, and the emissions resultin g from those changes. [40 CFR 71.6(a)(12)(iv)]

3. The permittee shall 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 and all original strip

- chart recordings for continuous monitoring
instrumentation, and copies of all reports req uired by the permit.

[40 CFR 60.7(f), 60.116b(a), 60.505(d) and (f), 63.4(a)(2), 63.10(b)(1), 63.567(j)(2),
63.6660, and 71.6(a)(3)(ii)(B)]

III.D. Notification and Reporting

1. The permittee, upon becoming aware that any relevant facts were omitted or i ncorrect information was submitted in the permit application, shall promptly submit such
supplementary facts or co rrected information. [40 CFR 63.9(j) and 71.5(b)]

2. The permittee shall submit to EPA Region 9 reports of any monitoring required under
71.6(a) (3)(i)(A), (B), or (C) for each six month reporting period from January 1 to June

30 a nd from July 1 to December 31. All reports shall be submitted to EPA and shall be
postmarked by the 30th day following th e end of the reporting period. All instances of

d eviations from permit requirements shall be clear ly identified in such reports. AllPage 13 of 25 required reports shall be certified by a responsible official consistent with condition II.J.1.

a. A monitoring report under this section shall include the following:
(1) The company name and address;

(2) The beginning and endin g dates of the reporting period;

(3) The emissions unit or activity being monitored ; (4) The emissions limitation or standard, including operational requirements
and limitations (such as parameter ranges), specified in the permit for

whic h compliance is being monitored;
(5) All instances of deviations from permit requirements, including those
attributable to upset conditions as defined in the permit and including

excursions or ex ceedances as defined under 40 CFR Part 64, and the date

o n which each deviation occurred;

(6) If the permit requires continuous monitoring of an emissions limit or
parameter range, the report shall include the total operating time of the
emissions unit during the reporting period, the total duration o f excess
emissions or parameter exceedances during the reporting period, and the
total downtime of the continuous monitoring system during the reporting

per iod;
(7) If the permit requires periodic monitoring, visual observations, work
practice checks, or simil ar monitoring, the report shall include the total
time when such monitoring was not performed during the reporting
period and at the source’s discretion either the total duration of deviations
indicated by such monitoring or t he actual records of deviation s; (8) All other monitoring results, data, or analyses required to be reported by
the applicable requirement ; (9) The name, title, and signature of the responsible official who is certifying
to the truth, accuracy, and completeness of the report.

b. Any report requir ed by an applicable requirement that provides the same

information described in Conditions III.D.2 .a .(1) through (9) above shall satisfy the
requirement und er Condition III.D.2

. a.

3. The permittee shall submit to EPA Region 9 a certification of compliance wi th permit
terms and conditions, including emission limitations, standards, or work practices,
postmarked by January 30 of each year and coveri ng the previous calendar year. The
compliance certification shall be certified as to truth, accuracy, and complete ness by the
permit

- designated responsible official consistent with Section II.J.1 of this permit and 40

CFR 71.5(d). [40 CFR 63.9(h)(3), 63.428(c)(2) and 71.6(c)(5)]

a. The annul compliance certification shall include the following:

(1) The identification of each term or condition of the permit that is the basis

of the certification;Page 14 of 25 (2) The identification of the method(s) or other means used by the permittee
for determining the compliance status with each term and condition
during the certification period. Such metho ds and other means shall
include, at a minimum, the monitoring required by this permit; and

(3) The status of compliance with the terms and conditions of the permit for
the period covered by the certification, including whether compliance
during the period was continuous or intermittent. The certification shall
be based on the method or means designated in Condition III.D.3.a.(2)

. The compliance certification shall identify each deviation.

4. The permittee shall promptly report to EPA deviations from any permit requi rements, as

defined in 40 CFR 71.6(a)(3)(iii)(C), 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. Where the underlying applicabl e requirement contains a
definition of prompt or otherwise specifies a time frame for reporting deviations, that
definition or time frame shall govern. Where the underlying applicable requirement fails
to address the time frame for reporting deviations, re ports of deviations shall be submitted
to the permitting authority based on the following schedule:

[40 CFR 71.6(a)(3)(iii)(B)]

a. For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in an
applicable regulation) that continue fo r more than an hour in excess of permit
requirements, the report shall be made with 24 hours of the occurrence.

b. For emissions of any regulated air pollutant, excluding hazardous or toxic air
pollutants (as identified in an applicable regulation), that cont inue for more than
two hours in excess of permit requirements, the report shall be made within 48

hours.

c. If any of the conditions are met as described in Condition III.D.4.a or III.D.4.b, the
permittee shall notify EPA by telephone or facsimile based on th e timetable listed in

these conditions. A written notice, certified consistent with 40 CFR 71.5(d), shall be
submitted within ten (10) working days of the occurrence.

d. For all other deviations from permit requirements, the report shall be contained in

the semiannual monitoring report submitted in accordance with the timeframe given

in Condition III.D.2.

5. The permittee shall provide contemporaneous written notice to EPA of each off

- permit
change allowed by Condition II.D .1, except for changes that qualify as insignificant under

40 CFR 71.5(c)(11). Such written notice shall describe each such change, including the
date, any change in emissions, pollutants emitted, and any applicable requirement that
would apply as a result of the change. [40 CFR 71.6(a)(12)(ii )]

6. For each section 502(b)(10) of the Act change allowed by Condition II.D .2, the permitteePage 15 of 25 shall provide written notification to EPA at least seven days before the proposed change
which includes a brief description of the change within the permitted faci lity, 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. [40 CFR 71.6(a)(13)(i)]

7. The permittee shall furnish to EPA, within a reasonable time, any info rmation that EPA
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 EPA copies of records that are required to be
kept pursuant to the terms of the permit, including information claimed to be confidential.

Information claimed to be confidential shall be accompanied by a claim of confidentiality

accordi ng to the provisions of 40 CFR Part 2, S ubp art B

. [40 CFR 71.6(a)(6)(v) and 71.5(a)(3)]

8. The permittee shall submit the following notifications and reports, in a timely manner, or
a compliance test, including monitoring system performance test, may b e considered

invalid: [40 CFR 60.8(b)

- (g), 63.9(e ) and (g), 63.10(d)(2), 71.6(a)(3) and 71.6(c)(1)]

a. Written notification of the intention to perform a compliance test at least 60 days
before the test is schedule to begin;

b. A written test plan that addresses the elements in Condition III.B.1 at least 60 da ys before the test is scheduled to begin; and

c. A test report that addresses adherence to the written test plan submitted in
accordance with Condition III.B.1 and includes records of data required to be
monitored during the test by the test plan, applicable regulation, or emission uni t specific conditions submitted to the Administrator at the address specified in

Condition II.J.1

.

III.E. Payment of Fees and Reporting of Actual Emissions

1. The permittee shall pay annual fees and submit actual emission reports in accordance with the procedures described below. Failure to pay fees in a timely manner shall subject the permittee to assessment of penalties and inter est in accordance with 40 CFR 71.9(l): [40 CFR 71.9(a), 71.9(h)(1)

- (3), 71.9(j), 71.9(k), and 71.9(l)]

a. T he permittee shall pay the annual permit fee and submit the fee filing form by April

1 of each year.

b. The fee payment shall be in United States currency and shall be paid by money order, bank draft, certified check, corporate check, or electronic funds tran sfer payable to the order of the U.S. Environmental Protection Agency and sent to one of the two

addresses below:

A ddress for regular mail through US Postal Service :

U.S. Environmental Protection AgencyPage 16 of 25 FOIA and Miscellaneous Payments

C incinnati Finance Center

PO Box 979078 St. Louis, MO 63197

- 9000

Address for Express Delivery (or when a physical address is required) :

U.S. Bank Government Lockbox 979078 US EPA FOIA & Misc. Payments

1005 Convention Plaza

Mail Station SL

- MO

- C2GL St. Louis, MO 63101

c. The permittee shall send an updated fee calculation worksheet and confirmation of fee payment to EPA Region 9 simultaneous with fee payment at the following

address:

Director, Air Division (Attn: AIR

- 3) U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street San Francisco, CA 94105

d. If EPA determines that a source has completed the fee calculation work sheet incorrectly, the permitting authority shall bill the applicant for the corrected fee or credit overpayments to the source’s account.

e. The permittee shall calculate and update the calculation worksheet using the following method s :

(1) The annual emissions fee shall be calculated by multiplying the total tons

of actual emissio ns of all “regulated pollutants (for fee calculation)” emitted from the source by the presumptive emissions fee (in dollars/ton)

in effect at the time of calculation. (i) “Actual emissions” means the actual rate of emissions in tpy of any regulated pollutant ( for fee calculation), as defined in 40 CFR 71.2, emitted from a Part 71 source over the preceding calendar year. Actual emissions shall be calculated using each emissions unit’s actual operating hours, production rates, in

- place control equipment, and type s of materials processed, stored, or combusted during the preceding calendar year. (ii) Actual emissions shall be computed using methods required by the permit for determining compliance, such as monitoring or source testing data. (iii) If actual emissions cannot be determined using the compliance methods in the permit, the permittee shall use other federally recognized procedures. (2) The permittee shall exclude the following emissions from the calculation ofPage 17 of 25 fees: (i) The amount of actual emissions of each regulated polluta nt (for fee calculation) that the source emits in excess of 4,000 tons per year; (ii) Actual emissions of any regulated pollutant (for fee calculation) already included in the fee calculation; and (iii) The quantity of actual emissions (for fee calculation) of insign ificant activities defined in 40 CFR 71.5(c)(11)(i) or of insignificant emissions levels from emissions units identified in the permittee’s ap plication pursuant to 40 CFR 7 1.5(c)(11)(ii). (iv) Fee calculation worksheets shall be certified as to truth, accuracy, and completeness by a responsible official. (v) If the permittee is notified by EPA of additional amounts due, the permittee shall remit full payment within 30 days of receipt of the

invoice. (vi) If the permittee thinks that the assessed fee is in error, the perm ittee shall provide a written explanation of the alleged error to EPA along with the assessed fee. (vii) The permitting authority shall, within 90 days of receipt of the correspondence, review the data to determine whether the assessed fee was in error. If an error was made, the overpayment shall be

credited to the account of the P art 71 source.

2. The permitte e shall retain, in accordance with Condition III.C.3, all work sheets and other materials used to determine fee payments. Records shall be retained for 5 years following the year in which the emissions d ata is submitted. [40 CFR 71.9(i)]Page 18 of 25 

### IV. Facility Wide Re quirements

IV.A. Emission Limits

1. The actual emissions from the entire facility, including startups, shutdowns, and malfunctions shall not exceed 18.7 tons per year of NO
x and 18.7 tons per year of VOC,

based on a 12

- month rolling average. [CAA 304(f), 40 CFR 71.6(b)]

IV.B. Monitoring and Testing Requirements

1. To demonstrate compliance with Condition IV.A.1, the permittee shall calculate the annual

emissi ons of NO
x and VOC on a r olling 12

- month basis. A sample equation can be found in

Attachment A.

2. The permitte e sh all perform the rolling 12

- month annual emission calculation in the first week of each month using the heat input for the prior month and the emission factors of the most recent performance tests for each CA T 3520 natural gas

- fired engine

.

3. The permittee s hall maintain all records of all calculations at the Facility.Page 19 of 25 

### V. Emission Unit Specific Requirements: Non

- Emergency Internal Combustion Engines

V.A. Emission Limits

1. T he CAT G3520 natural gas

- fired engines at the Facility shall not emit air pollutants in amounts higher than 0.15 grams per brake horsepower hour (g/BHP hr) of NO
x and 0.15 g/BHP hr of VOC at any time during operation e xcept during periods of startups and

shutdowns

. [CAA 304(f), 40 C FR 71.6(b)]

V.B. Work Practice and Operational Requirements [CAA 304(f), 40 CFR 71.6(b) , 40 CFR 63 ]

1. T he permittee shall maintain and operate each CAT G3520 engine , including any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions, and according to the manufacture’s emission

- related written instructions at all times, including periods of startup, shutdown, maintenance, and malfunction

. [4 0 CFR 63.6605(b)]

2. The CAT G3520 engines’ annual average CO concentration shall not exceed 47 ppmvd at 15 percent O 2 as measured during the annual compliance demonstration specified in

Condition V.C.6 . [40 CFR 63 Subpart ZZZZ Table 6, Item 14.a.i ]

3. At all times, t he permittee shall ensure the CAT G3520 engines’ NO
x concentration shall

not exceed 12 ppmv d at 15 percent O 2 as measured by the portable analyzer specified in

Condition V.C.3

. [40 CFR 71.6(b)]

4. Periodic maintenance for each device shall be conduct ed at least onc e each calendar year. [40 CFR 71.6(b)]

5. At all times the permittee shall be in compliance with all applicable requirements under 40 CFR Subpart ZZZZ. [ 40 CFR 63.6605(a)]

6. The permittee shall minimize each engine’s time spent at idle during s tartup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine,

not to exceed 30 minutes. [40 CFR 63.6625(h)]

7. The permittee shall utilize pipeline quality natural gas as the exclusive internal reciprocating engine fuel for the CAT G3520 engines. [40 CFR 71.6(b)]

8. Natural gas usage for the f acility shall not exceed 451.1 million standard cubic feet per year (mmscf/yr). [40 C FR 71.6(b)]

9. The permittee shall immediately shuts down the engine if the catalyst inlet temperature

exceeds 1350°F . [ 40 CFR Part 63 Subpart ZZZZ Table 5, Item 13 ]Page 20 of 25 V.C. Monitoring and Testing Requirements [40 CFR 71.6(a)(3)(i)(B) and (C);71.6(a)(3)(ii); and 71.6(c)(1)]

1. Except for monitor m alfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities, the permittee shall monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden,

in frequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.[40 CFR 63.6635(b)]

2. The permittee shall use all the valid data collected during all period except data r ecorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. [40 CFR 63.6635(c)]

3. T he permittee shall monitor and record the st ack concentration of NO
x (as NO 2 ) and O 2 from EG

- 1, EG

- 2, EG

- 3, and EG

- 4, using a portable NO
x analyzer in accordance with EPA

Test Method 034 or ASTM D6522

- 00 as incorporated by reference in 40 CFR 63.14(b)(86)

. The facility shall conduct this monitoring on a quarterly basis.

a. If the NO
x concentration, as measured by the portable analyzer , exceeds 12 ppmv d at 15 percent O 2 , the permittee shall take corrective action to return the emissions to below this concentration as soon as possible, but no longer than one hour of operation

after detection. If NO
x e missions continue to exceed 12 ppmv d at 15 percent O 2 after

one hour o f operation after detection, the permittee shall shut down the generator and not operate it again until the problem has been corrected. The permittee shall notify EPA of any such event that lasts for one hour or longer via electroni c mail sent to r9.aeo@epa.gov. Each event that equals or exceeds one hour in duration shall also be

identified in the semi

- annual monitoring report required by Condition III.B .1 of this permit as a deviation

.

b. If any generator is shut down for one hour or longer as a result of a NO
x reading that

exceeds 12 ppmv d at 15 percent O 2 , the permittee shall begin monthly monitoring of

NO
x emissions from EG

- 1, EG

- 2, EG

- 3, and E G

- 4 for the next three months. After three months of monthly monitoring which demonstrates compliance , the permittee

may resum e quarterly monitoring.

c. During each monthly or quarterly use of the portable NO
x analyzer on EG

- 1, EG

- 2,

EG

- 3, and EG

- 4, the permittee shall monitor and record the engine load in kWs output and the urea injection rate.

4. The permittee shall conduct or caus e to be conducted performance tests (as described in 40 CFR 60.8) for NO
x and VOCs on the exhausts of the four natural gas

- fired engines at the facility (EG

- 1, EG

- 2, EG

- 3, and EG

- 4). The performance tests shall be conducted to demonstrate compliance with the emission limits specified in C ondition V.A.1 of thisPage 21 of 25 permit. The tests for NO
x and VOC shall be conducted at the maximum operating capacit y of the engines being tested. The permittee shall conduct performance tests on one gas

- fired engine per year, acc ording to the following schedule:

year 1: EG

- 2 year 2: EG

- 3 year 3: EG

- 4 year 4: EG

- 1 year 5: EG

- 2

In addition, any engine that was s hut down for one hour or longer as a result of a NO
x reading that exceeded 12 ppmv d at 15 percent O 2 as required by C ondition V.C.3.a shall also be tested during the next scheduled round of performance testing.

5. If the catalyst is changed, the facility sha ll conduct a performance test in accordance with

Condition V.C.6 to demonstrate that the emission limitation s pecified in Condition V.B .2 is being met. [ 40 CFR 63.6640 (b)]

6. The permittee shall demonstrate continuous compliance with the applicable requirem ents of

40 CFR Subpart ZZZZ by conducting an annual compliance demonstration . The compliance demonstration shall measure CO and O 2 emissions at the same time using one of the measurement methods specified in Ta ble 4 or Appendix A of 40 CFR Subpart ZZZZ.

a. The compliance demonstration shall consist of at least one test run; and

b. Each test run shall be at least 15 minute duration, except that each test conducted using the method in Appendix A of 40 CFR Subpart ZZZZ shall consist of at least

one measurement cy cle and include at least 2 minutes of test data phase measurement.
[ 40 CFR 63.6640, 40 CFR Part 63 Subpart ZZZZ Table 5, Item 13; Table 6, Item

14.a. ii i ]

7. If the results of the annual compliance demonstration show that the CO emissions exceed 47 ppmvd at 1 5 percent O 2 and temperature limit, the stationary RICE shall be shut down as soon as safely possible, and appropriate corrective action shall be taken (e.g., repairs, catalyst cleaning, catalyst replacement). The stationary RICE shall be retested within 7 days of being restarted and the emissions shall meet the levels specified in Condition V.B .2 . If the retest shows that the emissions continue to exceed the specified levels, the stationary

RICE shall again be shut down as soon as safely possible, and the stationary RICE may not operate, except for purposes of startup and testing, until the owner/operator demonstrates through testing that the emissions do not exceed the emission limitation specified in

Condition V.B .2 . [40 CFR 63.6640(c)(7)]

V.D. Recordkeeping and Reporting Requirements [40 CFR 71.6(a)(3)(i)(B) and (C); 71.6(a)(3)(ii); and 71.6(c)(1)]

1. A file shall be maintained of all notification and report s submitted, measurements including continuous monitoring system evaluations, all continuous monitoring system or monitoring device calibration checks, adjustments and maintenance performed on these systems orPage 22 of 25 devices, performance and all other information required by 40 CFR P arts 60 , 63 or 75 recorded in a permanent form suitable for inspection.

2. The permittee shall maintain a log of the NO
x monitoring sessions perform ed with the portable analyzer. At a minimum the log shall contain the following records:

a. T he date an d time of NO
x and O 2 measurements ; b. T he measured O 2 concentration as a percentage ;

c. T he measured NO
x concentrations corrected to 15 percent O 2 ; d. E ngine load in kWs output and urea injection rate in gallons per hour ;

e. M ake and model of exhaust gas analyzer ; f. E xhaust gas analyzer calibration records ; and

g. A description of any corrective action taken to maintain the emissions within the acceptable range.

3. The permittee shall maintain a log of the operation of all natural gas engine s (EG

- 1, EG

- 2,

EG

- 3, and EG

- 4 ). T he log shall contain the dates and times of each startup and shutdown of each engine.

4. The permittee shall maintain all natural gas purchase records, including HHV of natural gas purchased.

5. The permittee shall submit a 40 CFR Subpart ZZZZ compliance repor t with the monitoring report specified in Condition III.B.1 semiannually . The Compliance report shall contain the following a dditional information:[40 CFR 63.6650(c)(1)

- (5); (d)(1)

- (2); 40 CFR Subpart

ZZZZ Table 7 , Item 3.a.1 ]

a. If there are no deviations fr om any applicable emission or operating limitations, a statement that there were no deviations from the emission or operating limitations during the reporting period;

b. The total operating time of the CAT G3520 engines at which the deviation occurred during the reporting period;

c. Information on the number, duration, and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken.

d. The results of the annual compliance demonstration as indicated in Condition V.C.9, if conducted during the reporting period.

6. Records shall be retained for at least five (5) years following the date of such measurement,

mai ntenance, reports, and records. T he most recent two years of data shall be r etained on

site. [40 CFR 63.6660, 63.10(b)(1) and 71.6(a)(3)(ii)(B ) ]Page 23 of 25 

### VI. Emission Unit Specific Requirements: Commercial Emergency Compression Ignition IC Engines

VI.A. Emission Limits

1. T he CAT 3516B low sulfur diesel oil

- fired engines at the Facility shall not emit air pollutants in amounts higher than 9.17 g/BHP hr of NO
x and 0.32 g/BHP hr of VOC at any time during operation e xcept during periods of startup and shutdown. [CAA 304(f), 40 CFR 71.6(b)]

VI.B. Work Practice and Ope rational Requirements [CAA 304(f), 40 CFR 71.6(b)]

1. The permittee shall utilize No. 2 fuel oil for the CAT 3516B engines. The fuel oil shall be

limited to a maximum sulfur content of 0.05 percent sulfur by weight.

2. No.2 fuel oil usage for the Facility shall not exceed 49,052 gallons/year.

3. The permittee shall minimize each emergency diesel engine’s time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. [40 CFR 63.6625(h)]

4. Operation of each emergency diesel engine shall be in accordance with the fo llowing requirements: [40 CFR 63.6640(f)]

a. Emergency situations and there is no time limit on the use during emergency situations;

b. Limited to 100 hou rs per year for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine;

c. The CAT 3516B engines shall not be used for emergency demand response purposes.

d. Up to 50 hours per year for other non

- emergency situations, but those 50 hours are

counted towards the 100 hou rs pe r year as listed in Condition VI.B.4 .b. The 50 hours per year for non

- emergency situations cannot be used:

(1) For peak shaving; (2) To generate income for a facility to supply power to an electric grid; (3) For non

- emergency demand response; or (4) Otherwise supply power as part of a financial arrangement with another entity

.

e. Any engine which fails to comply with these operational limits may be reclassified asPage 24 of 25 a non

- emergency engine and may be subject to additional requirements.

VI.C. Recordkeeping and Reporting Require ments [40 CFR 71.6(a)(3)(i)(B) and (C); 71.6(a)(3)(ii); and 71.6(c)(1)]

1. The permittee shall maintain a log of th e CAT 3516B diesel engines . The log shall contain the notification of the emergency situation, and the date, start time, and end time of engines operation for these purposes.

2. The sulfur content of the fuel oil shall be documented in a valid purchase contract, supplier certification, or tari ff or transportation contract. The permittee shall maintain this

documentation for at least five years and make it available for inspection at all times.Page 25 of 25 A ttachment A

The rolling 12

- month emission total is the sum of each natural gas engine’s monthly emissions

, plus the monthly diesel engines emission , and plus the previous 11 months of emissions as

shown below:

Rolling 12 Month Emissions ( tons ) = GG EEEE

− 1 + GG EEEE

− 2 + GG EEEE

− 3 + GG EEEE

− 4 + D + P

For each natural gas engine (EG

- 1, EG

- 2, EG

- 3, EG

- 4):

G = Monthly Natural Gas Engine Emissions � tons

month �

= F ∗ E

H + SU + SD

2000

F = Fuel Throughput � MMBtu

month �

= HHV ∗ lbs fuel

month ∗ MM

10 6

E = Emission from the Most Recent Performance Test � lb

hr �

H = Heat Input Rate � MMBtu

hr �

= ( R ∗ HHV )

10 6

R = Fuel Rate � lbs fuel

hr �

HHV = Higher Heating Value of the Fuel � Btu

lb fuel �

SU � lbs

month �

= Number of Startups Each Month ∗ 0

. 7 lbs for NO xx or 0

. 118 lbs for VOC

SD � lbs

month �

= Number of Shutdowns Each Month ∗ 0

. 3 lbs for NO xx or 0

. 05 lbs for VOC

For all diesel engines (EG

- 5, EG

- 6, EG

- 7):

D = Total Monthly Diesel Engine Emissions � tons

month �

= Total Monthly Heat Input for all Three Engines ∗ 3

. 105 llllll NO xx
MMBtu or 0

. 35 lbs VOC

MMBtu

2000

P = Previous 11 Months of Emissions (tons)