,.-- I**~** 1 

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# -- 16 17 18 !""" 19 20 

# - 21


# ,... 22 

## ,-....., 

# ,.. 24 INTHE MA TIER OF COMPLIANCE WITH RCW 70.94AND THE GENERAL REGULATIONS FOR AIR POLLUTION SOURCES OF THE SOUTHWEST AIR POLLUTION CONTROL AUTHORITY Centralia Plant PacifiCorp, _et. al. Centralia, Washington RESPONDENT



### INTRODUCTION ) ) ) ) ) ) ) SW APCA 97-2057R1 REGULATORY ORDER TO ESTABLISH RACT EMISSION LIMITS AND ·oRDER OF APPROVAL

1. Under RCW 70.94.154 ofthe Washington Clean Air Act, "reasonably available control technology" or "RACT" is required for all existing sources in Washington. All sources
are required to achieve the lowest emission limit that the source or source category is capable ofmeeting by the application ofcontrol teclulology that is reasonably available considering technological and economic feasibility. See RCW 70.94.154(1). In setting RACT, SW APCA is required to consider the following factors: (1) the impact of the
source upon air quality, (2) the availability of additio:n\1.1 controls, (3) the emission reduction to be achieved by additional controls, (4) the impact ofadditional controls on air quality, and (5) the capital and operating costs ofthe additional controls. See RCW 70.94.030(19). 2. An important consideration in SW APCA's determination ofsource-specific RACT for the Centralia Plant's sulfur dioxide (802) emissions is Centralia Plant's agreement to achieve certain significant reductions in emissions of sulfur dioxide, which are discussed below in Item 7. Because the Centralia Plant has already agreed as part ofthe COM process to accept these emission reductions once required .in a Regulatory Order, it is not Page SWAPCA 97-2057RI1 2 3 4 5 6 7 

### 8 

### 9 

### 4. 10 11

2 

### 5. 13 14 15 16 17 18 19 6. 20 necessary for SWAPCA to assess whether a less**string~nt** S02 emission-limit will meet the requirements for RACT. Instead, in the RACT determination for S02 as provided in the Technical Support Document, SW APCA has considered whether RACT requires a
more stringent**emissio~** limit than.the CDM target solution. The Washington State legislature's decision to grant certain tax relief to the Centralia Plantbaschangedtheeconomicfeasibility determinationanalysis underRACTthatwoi.dd otherwise apply to this or similar sources. Thus, RACT .for the Centralia Plant's S02 emission limit may not be easily transferred to other sources·or source**c~tegories.** In addition to determining RACT for sulfur dioxide emissions, SW APCA bas also determined RACT emission limits for nitrogen oxides, particulate matter, and carbon monoxide. SW APCA has considered visibility impairmentin MountRainierNationalParkand other Class I areas. While no formal BART determination has been made, SWAPCA has considered the federal "best available retrofit technology" (BART) guidelines for large coal-firedpowerplants, and specificallyhowthe RACT emission limits comparewiththe
new source**~rformance** standards (NSPS) (40 'CFR 60.40a, Subpart Da). 

### REGULATORYBACKGRQUND RACT Order 

### SWAPCA 95-1787. SWAPCA issuedRACT OrderSWAPCA 95-1787inAugust 1995 establishing plant-wide S02 emission limits of 1.1 pounds per million Btu (lb/MBtu), annual average and 55,000 21 tons/yr. Comments from the National Park Service and USDA Forest Service concerning 22 BART prompted on-going discussions about additional S02 reductions. The 1995 RACT

3 Order was withdrawn in September 1996 to facilitate another review of RACT and to
Page 2 SWAPCA 97-2057RI 

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.... l determine whether the collaborative decision making (COM) target solution exceeds


# - 2 ·emission limits consistent with RACT. 3 

### CDM Target 

### Solution 4 

### 7. A collaborative decision making (CDM)process during 1996 ledto agreement amongthe r 

### 5 Centralia Plant owners, federal land managers, and regulatory agencies to seek further 

### 6
. emission reductions. The outcome ofthis process was a proposal to limit

## so2 emissions 7 to no more

# than 10,000 tons/yr after December 31, 2002 and install NOx controls. In·



# . 8 addition, proposed criteria were developed for: (a) Current Standards

- Hourly



# - 9 Concentrations; (b) Operating Conditions with Controls

- Good Operating Practices, 10 ScrubberOutages, Unit Startup/Shutdown, Emissions Accounting, andModifications; (c) 11 Emission Limits

- Control System Deadline, Hourly Concentrations in 2002, Hourly 

# r 2 Concentration 2003 Onward, Annual Limit, and Bypass Stacks; (d) Monitoring
.and



# - 13 Reporting

- CEMs, Compliance Data, InterimCompliance, Compliance Evaluation, Data 14 Availability, and Reporting Frequency; and (e) Exceedances and Penalties

- Hourly 

# ,... 15 Exceedance, Annual Exceedance, Excess Emission, Defmition ofViolation, and General



## ,... 16 Enforcement and Allowance Forfeiture. Documentation from the CDM group 17 collaborative process is provided in Appendix B ofthe Technical Support Document. r 18 LEGAL 

### AUTHORITY



# ,.. 19 8. ' RCW 70.94.154 specifies that all sources in Washington State are required to meet 20 emission limitations consistent with RACT. SWAPCA may issue a Regulatory Order to 

## ,.... 21 define emission limitations that constitute RACT and require compliance with such r ' 

# ,-...., 22 emission limitations. RACT means the lowest emission limit that a particular source or 

# r 3 source category is capable of meeting by the application of control technology that is
Page 3 SWAPCA 97-2057Rl1 2 

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### 9. 4 5 6 

### 7 

### 8 

### 9 10 11

2 13 14 

### 15 16 17 18 19 20 21 22

3
Page 4 

# J l feasibility

# J J reasonably available considering technological feasibility and economic (SW APCA 400-030(68)). Regulations have been 

### established for the control ofair

### pollutants**emitt~d** 

### to the ambient air. · 

### Regulations applicable to the Centralia Plant which have been considered in establishing RACT emission limits and control requirements include, but are not limited 

### to, the following regulations, codes or requirements. These items establish minimally acceptable emission limits that could be 

### allowed for**exi~g** 

### facilities. More stringent limits maybe established in this Order consistent with implementation ofRACT:


### a. Title 40 Code of Federal Regulations (CFR) Part 60.40 et**~** 

### (Subpart D) 

### ustandardsofPerformap.ceforFossil-Fuel-FiredSteamGenerators" appliestoeach steam generatingunit ofmore than 250 

### million Btuper·hourheat input for which construction commenced after August 17, 1971. This regulation does not apply to the Centralia Plant because construction ofthe Centralia Plant commenced 

### in 1968. SWAPCA approved construction of the Centralia Plant in a letter dated November 7, 

### 1969. 

### b. Title '40 Code of Federal Regulations (CFR) Part 60.40a et seq. (Subpart Da) "Standards ofPerformance for Electric Utility Steam Generating Units for Which Construction Is Commenced After September 18, 1978" applies to each steam· generating unit of more than 250 million Btu per hour heat input for which construction commenced after September 18, 1978. This regulation does not apply to the Centralia Plant because construction of the Centralia · Plant commenced in 1968 and has not since been modified. SWAPCA approved construction ofthe Centralia Plant in a letter dated November 7, 1969.

SWAPCA 97-2057R 1 ! l

...... 

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## "-' '-. 

### 1 c. WAC 173-400-151 "Retrofit Requirements for Visibility·Protection" requires the 

## ,_ 2 owner or operator ofany source to which significant visibility impairment ofa



## ,.... 3 mandatory Class I 

### area is reasonably attributable, to apply BART for each 4 contaminant contributing to visibility impairmentthat is emitted at more than 250 

### r 5 tons per year. 6 d. WAC 173-470 "AmbientAirQualityStandards forParticulateMatter" establishes 7 ambient air 

### quality standards for total**suspend~** 

### particulate matter and for 

# ,... 8 particulate matter smaller than 

### 10 microns (PMuJ, which may not be exceeded 9 more than 

### one day per year.



### ,.... 10 e. WAC 173-474 "Ambient Air Quality Standards for Sulfur Oxides" established 11 

### ambient airquality standards for sulfur oxides, measured as sulfur dioxide. (S02), 

# r 2 of 0.4 parts per million {1-hour average) .and 0.1 parts per million (24-hour 

# r 13 average) which may not be exceeded more than once in a one-year period, and 14 

# "'- 0.25 parts per million (1-hour average) which may not be exceeded more than 15 twice in 

### a consecutive seven-day period. 16 f. WAC 173-475 "AmbientAirQuality Standards for CarbonMonoxide, Ozone, and ,) 17 

### Nitrogen Dioxide" establishes an ambient air quality standard of 0.05 

### part per 18 million (ppm), annual arithmetic mean for nitrogen dioxide; an ambient airquality 

## r 19 

### standard of 0.12 ppm, one hour average, for ozone; and ambient air quality 20 standards of 9.0 ppm, eight hour average, and 35.0.ppm, one hour average, for 21 carbon monoxide.


# ,... 22 g. SW APCA 400-040 "General Standards for Maximum Emissions" Section 6 

## i,....... 

# ,. 3 

### requires that no person shall cause or permit the emission of a gas containing
Page 5 SWAPCA 97-2057RI1 2 

### 3 

### 4 

### 5 6 7 

### 8 9 10 11 

### 2 13 14 15 

### 16 17 18 19 10. 20 21 sulfur dioxide from any emission unit in excessof 1000 ppm dry vtv corrected to 7% 

### 0 2 or 12% C02 average for 

# any consecutive 60 minutes. h. · SW APCA 400-091 "Voluntary Limits on Emissions" requires that SWAPCA

i. establish enforceable limits on emissions orlimitations on potential to emit upon request by a sourCe to an amount agreed to by the owner or operator and SW APCA. SW APCA shall issue a Regulatory Order to reduce. that source's

·potential. to emit whereby the terms and conditions of such Order sha11 be federally enforceable. SuchOrder shall

### be subjectto publicnotice andcomment.. SW APCA 400-114 "Requirements for Replacement or Substantial Alteration of Emission Control Technology at

# an Existing Stationary Source" requires that the owner/operator of a source submit a Notice. of Construction application to SWAPCA and that an Order of Approval/Regulatory Order be issued prior to makingthereplacement oralteration. Forprojectsnototherwisereviewable under SWAPCA 400-110; SWAPCA may require the owner or operator to employ RACT. SWAPCA 400-114 applies to fuel modifications strictly for control of emissions, as. well as to the installation ofpollution control equipment. 

### REGULATORY FINDINGS Emission Units SWAPCA evaluated all emission units at the Centralia Plant to determine those units that should be considered for inclusion in a RACT evaluation. There were eight emission units identified as major plant components. In addition, the Title V application further 22 identified four additional emission units. These four additional emission units were

3 identified to be insignificant emission units in accordance with Title Y requirements. 24 Based on the RACT criteria of RCW 70.94.154 and RCW 70.94.030, only the main Page,6 .SWAPCA 97-2057Rl 

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### boilers (Boilers #I and #2) were determined tobe ofsignificant nature such that a RACT evaluation and establishinent ofRACT emission limits would bepracticable at this time. The full evaluation of the emission units are documented in the Technical Support Document in Section 2.2. Pollutants Deemed to be ofConcern ·swAPCA evaluated certain pollutants to determine whether they are "ofconcern.. and whether it would be practicable to set RACT emission**~imits** 

### for ·them at this .time. SWAPCA evaluated each of the criteria pollutants (sulfur dioxide, particulate matter, oxides ofnitrogen, an.d 

### ca:rbon monoxide) to determine ifthey qualified as contaminants ofconcern for the Centralia Plant. Ozone was not directly evaluated because it is not a pollutant directly emitted by the Centralia Plant, however, ozone was evaluated 

### as a byproduct ofoxides ofnitrogen and volatile organic compounds. In addition volatile organic compounds, hazardous air pollutants (HAPs) andtoxic air·pollutants (TAPs), and carbon dioxide were evaluated. Lead was not evaluated separately as a criteriapollutant but was considered under the category of hazardous air pollutant. SW 

### APCA applied criteria contained in RCW 70.94.154 and RCW 70.94.030 to each pollutant to arrive at
a conclusion ofwhich pollutants should be evaluated for RACT. Only those pollutants emitted from the emission units ofconcern that were identified above were evaluated. The pollutants ofconcern for which a RACT determination was deemed to be practicable 20r

### are: sulfur dioxide, oxides ofnitrogen, particulate matter and carbon monoxide. The full 21 

### evaluation of the pollutants of concern are documented in the Technical Support 

### r 22 Document in Section 2.3. 

## ' 

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# ,. r Page 7 

### SWAPC.A 97-2057RIl 

### 2 3 

### 4 

### 5 6 7 

### 8 9 10 

## u

2 13 14 

### 15 16 17 18 19 

### 20 21 

### 22

3 24 

### SW APCA's Discretion to Not Determine RACT Where Not Practicable 12. Volatile organic compounds,.hazardous airpollutants and toxic airpollutants, and carbon dioxide were determined to not be subject to·RACT for the Centralia Plant based on individual factors explained in the Technical Support Document. The hazardous air pollutants were found to be ilisignificant (not of concern) or determined to not be practicable to have a RACT emission limit established at this time. One hazardous air pollutant, mercury (Hg), 

### was determined to be potentially ofconcern and was evaluated in more ·detail than the other hazardous**-~** pollutants. The U.S. EPA is currently evaltiating merctiry 

### emissions from all powerplants to establish the need: for max.in;lUm achievable control technology (MACT) controls. Because the concentration ofmercury emissions from the Centralia Plant are significantly below the Washington State· established acceptable source _impact level (ASIL) of WAC 173-460 and the fact that mercury is being considered for a federal MACT standard, mercury is not yet a pollutant of concern. Therefore, establishment of a RACT emission limit for mercury was not considered to be practicable at this time. Basis 

### for Order 13. This Order, in part, is issued in accordance with SWAPCA 400-091, upon request by the Respondent, to limit the potential to emit from the auxiliary boiler. The emission limitation is based on establishing an annual total fuel consumption limit for the auxiliary boiler of600,000 gallons per year and AP-42 emission factors. 14. This Order, in part, is issued .in accordance with SWAPCA 400..:ll4(2)(a) requiring installation of RACT and is deemed to meet the requirements of SWAPCA 400-114(3) for Notice ofConstruction subminal and approval ofreplacement or substantial alteration ofemission control technology at an existing stationary source. Respondent shall notify Page 8 SWAPCA 97-2057R1 

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# - , SW APCA ofthe selected control technology upon its final selection. Any additional monitoring and operating requirements necessary to ensure continuous compliance with applicable requirements shall be incorporated into the Title V permit at the time ofits issuance or renewal, as appropriate. RACT and BART Findings 15. SWAPCA finds that the 10,000 tons per year emission limit for S02 required in this Ordermeetsorexceedstherequirement for an S02 RACT**~ission** limit fortheCentralia Plant. 16. SWAPCA fmds that a 0.30 lb!MBtu, annual average, bothunits combined, emission limit for oxides ofnitrogen, a 0.010 gr/dscf and 200/o opacity emission limits for particulate matter, and 200 ppm, annual average, both units combined, emission limit for carbon monoxide, are levels of emissions that can be achieved by the Centralia Plant by application ofRACT control technology, thereby establishing RACT emission limits as provided under RCW 70.94.154. 17. SWAPCA finds that, while no formal BART determination has been made, based on the requirements in this Order and documentation in the Technical Support Document, the emission limits in this RACT Order represent BART under 40 CFR 51 Subpart P, WAC 173-400-151 and SW APCA 400-151 for emissions of sulfur dioxide, particulate matter and nitrogen oxides by meeting the BART requirements for those pollutants.

Page 9 SWAPCA 97-2057RI

### 1



### 3 4 5 

### 6 7 

### 8 9 

### 10 

### 11

2 13 14 15 16 17 18 19 20 21 22

3 .24 

### NOW HAVING. CONSIDERED'THIS MAlTER AND·BEING DULY ADVISED, IT IS HEREBY ORDERED:

18.

19.

20. 

### SQLFUR DIOXIDE THAT; unless otherwise provided below, no later than January 

### I, 2003 total 

### S02 emissions from units #1 and #2, the auxiliary boiler (as described in Item 45), and other emission points throughoutthe facility' combined, shallnot exceed.10,000 tons/yrin any rolling 12-month period. The determination of 

### annual**~issions** shall be based on a rolling monthly calculation from the· recorded hourly 

### 802 emissions 

### used for Acid Rain Program complianceevaluation. An 

### annual average 

### shall be computed for the preceding 

### l2
...month periodwhich ends with each month·ofthe quarter, tobereported quarterly by the endofthe month following the end ofthe calendar quarter. THAT, the

### s~lected 

### 802 emission control technology shall be operational no later than December 31, 2001 for one ofthe Plant units, and shall be operational no later than December 31, 2002 for the other Plant unit. However, if the selected 

### 802 emission control method is fuel supply modification or a post-combustion control system applied to only one ofthe two units, neither ofthe ·units, or no controls, the emission limit for the entire Plant shall be effective after December 31,·2001. THAT, the annual 

### 802 exhaust gas emissions, during and after installation of control technology according to the schedule in Item 19 above, shall not exceed the following:

a. 7,500 tons per year, annual average, for the controlled unit including any bypass, and no annual limit for the uncontrolled unit, ifdischarged through separate stacks (flues), effective only in calendar year 2002; b. l0,000 tons per year, annual average, for all exhaust gases discharged through a
new flue (and bypass for the controlled unit) ifthis flue is to be common for both Page 10 SWAPCA 97-2057Rl 

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# JI '--.._ 1 units once control technology is applied to**b~th** units. The exhaust stream tor2 which this limit applies consists ofemissions from the first controlled unit forthe


# ,... 3 entire year of2002 and emissions from the second controlled unit for only that 4 portion ofthe year 2002 that the second unit is in startup testing and discharges 

# .,.. 5 its exhaust through the new common flue. Compliance evaluation periods that 

# ,.. 6 span startup ofthe second unit shall use the monthly emissions calculated by the 7 

# ,.. appropriate accounting method for each month; 8 c. 10,000 tons per year, annual average, both units combmed, if both units have 

# r- 9 control technology installed (operational) by December 31, 2001, effective in



# - 10 calendar year 2002 and beyond; 11 

### -d. 10,000 tons per year, annual average, both units combined, both units controlled, 

# r .2 one or two stacks, effective_in calendar year 2003 and beyond;



# ,... 13 e. The CentraliaPlant shall, within its operation andmaintenance constraints, use all 14 best efforts to preferentiallyload the unit first equipped with

### so2 emission control


# - 15 technology when the Plant is operating at less than maximum capacity from


# ,.. 16 December 31, 2001 through December 30, 2002. Daily generation records for ' 17

/ both units will be made available during calendar ye_ar 2002 to assess the relative 

# ,... 18 loading ofthe scrubbed and unscrubbed units.


# ,... 19 21. THAT, from January I, 2002 onward, the S02 exhaust gas concentration from units to 20 which emission reduction technology has been applied, according to the schedule in Item 

## """ 21 19 above, shall not exceed the following short-term levels: 

# r 22**~** a. 250 ppm, 1-hour average measured on a dry basis corrected to 7% 0 2 for the 

## r .3 controlled unit(s); 1000 ppm, 1-hour average measured on a dry basis corrected 24 to 7% 0 2 for the uncontrolled unit for only 2002; Page II SWAPCA 97-2057RI

### 1 2 3 

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### 6 7 8 

### 9 10 11

13 14 15 16 17 18 19 20 21 22

24 

### b. During planned or forced outages ofthe 

### 802 emission control technology and during startups and/orshutdowns ofa unit as defined in Section 25 below, ifthe selected

## solemission control**~hnology** cannotoperate,the following alternative emission levels measured on a dry basis corrected to 7% 

### 0 2 shall apply: (i) 1000ppm, 1-houraverage, ifthe exhaustgas from each unit is discharged through separate flues which are independentlymonitored; (ii) ·Iftheexhaustgasesfrom bothunits are**diseh~ed** through a newcommon flue 

### inwhich only

### acombinedexhaustmixturemaybe monitored,thenthe following outage and startup/shutdown levels shall apply: (a) In 2002, 1000 ppm, 1-hour average; and (b) In 2003 and onward, 750 ppm, 1-hour average ifthe outage or startup/shutdown condition exists for only oneunit, and 1000ppm, 1-hour average ifthe condition exists for both units concurrently;
c. Ifthe exhaust gases from both units are discharged through a new common flue, during startup testing ofthe second unit's 

### S02 emission control technology, 

### 802 concentrations·shall not exceed 750 ppm, 1-hour average, only in 2002. 22. THAT, priorto compliance with the 

### 802 emission limit in Item 18 above, neither.Unit #1
nor Unit #2 shall exceed for any fixed hour at any time while fuel is being supplied to the unit, an S02 stack concentration of 1000 ppm, l-hour average, dry basis corrected to 7% 0 2 as provided in SWAPCA 400-040(6). 23. THAT, the duration ofa forced outage ofthe S02 emission control technology shall be minimized by returning the emission control system to operation as soon as practicable. A planned outage is defined as one that is scheduled in advance regardless ofthe length ofthe planning horizon. All other unanticipated system outages are defined to be forced. Page 12 SWAPCA 97-2057RI 

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I '-.._ 1 The Centralia Plant is
. responsible for demonstrating that a forced outage which occurs 

# - 2 while the plant continues to operate is unavoidable and is being managed to minimize


# ,... 3 emissions as provided in SWAPCA 400-107. Emission control system outages shall be 4 reported to SWAPCA by telephone during the current business day or no later than the 5 nextbusinessmorning; a messagemaybelefton an automatic answeringmachineoutsi<,le**~** 6 normal business hours. A written report may 

### be requested by SW APCA, and shall be 7 required for any forced outage longerthan72 hours. Foroutages exceeding 72 hours, the 8 plant shall consideravailablemeansto reduceemissions ofS02, including,-butnotlimited 

# ,... 9 to, a reduction in electrical output, use ofreduced sulfur content coal, or taking one or 10 both units offline. Planned emission control system outages shall be conducted to the 11 maximum extent possible during daily or weekly plant load reduction periods. No 

# i_,-.., "'2 planned emission control system outages shall occur during the period ofJune 15 through 13 September 15 except when the plant is completely offline and no fuel is burned. 14 24. THAT, all S02 emissions during startup, shutdown, equipment out ofservice, and upset 

# ,.. 15 conditions shall beincluded in the summation ofemissions to determine compliance with 16 the annual (12 month) emissions limit of 10,000 tpy. 17 25. THAT, during startup and shutdown,ofthe Centralia Plant units (for normal operations 18 or planned outages), emissions control equipment shall be operated to minimize overall 19 emissions, except to the extent equipment operation will cause degradation of its long20 term performance. Exceedances of the normal operation hourly S02 (250 ppm) and 21 opacity limitations (20%) are excused under SWAPCA 400-107 during startup and**~** 22 

### ' 

### ,.......__ shutdown when the electrostatic precipitators (ESPs) and S02 emission control system(s) !""' 1 are out of service. The shutdown period begins when the ESP temperature drops to 24 220°F, the critical ESP de-energize temperature. When the critical temperature is 

# ,.. ' Page 13 SWAPCA 97-2057Rl1 2 3 4 5 

### 6 7 8 9 10 

### 11 "2 13 

### i4 15 16 17 18 19 20 21 22

24 26.

27. 

# \ :\ f attained, first the 

## so2 control system, and then the ESPs are taken .out ofservice. For ' 

# I

............. l peri,odswhenall fuel is out oftheboiler, 

## so2 emissions shall beassumedtobe

### zero. The 

# J startup period begins when fuel is introduced**in~o** a boiler with the intent ofraising its temperatureto operatingconditions. TheESPs are energized whentheyreach operationai temperature, or220°F. The S02 control system(s) is(are) placedin service following ESP stabilization. The startupperiod ends when the earlier ofthe two operating events below
occurs: 

### a. Opacity inthe gas path dpwnstream ofthe ESPs has stabilized below 10% for 30 minutes (five consecutive 6-minute periods); or b. 8 hours have elapsed after the startup unit is synchronized to be electrica1Iy online. THAT, during equipment out ofservice and upsets (including forced outages), emissions in excess of the 250 ppm hourly 

## so2 limitation are excused from the hourly limit provided they meet the burden ofproofregarding unavoidable conditions that lead to
excess emissions in accordance with SWAPCA 400-107. Centralia Plant shall record equipment out ofservice and upset conditions in the operation log for periodic inspection by SWAPCA. For periods when all fuel is out of the boiler, S02 emissions shall be assumed to be zero. THAT, the compliance determination methodology for S02 emissions shall be as follows:
a. S02 emissions from each unit, ifemitted through separate flues, shall be measured by an S02 monitor and the diluent (02 or C02) monitor, which are continuous emission monitors (CEM) installed and operated to meet the requirements of40 

### ...J 

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CFR Part 75
.. Hourly (over a fixed clock hour, e.g., 1:00 p.m. to 1:59 p.m.) S02 '-· ( ' averages shall be calculated by the CEM. Compliance with the hourly S02 

## J Page 14 SWAPCA 97-2057R I 

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1 24 

### b.

c.

Page 15 limitations shall be determined from the CEM data, collected in·compliance with 40 CFRPart75 separately for CentraliaPlant Units#1 and #2 from separate flues,
or a combined flue, ifapplicable. Compliance with the annual emission limit in tons per year shaH be determined at the end ofeach calendar quarter from tons of802 emitted during the three 12- month periods ending in that .quarter. Emissions shall be calculated using the methodology in40 CFR75 for theAcidRain**Pro~.** Ifpriorto June 2000, the U.S. EnvironmentalProtection Agencyhasnotresolvedthediscrepancythatexists in calculating tons of802 between the current 40 CFR Part 75 and coal burned methodologies, the Centralia Plant may propose to SW APCA, for review and modification ofthis.provision, alternative monjtoring and compliance evaluation methods that more accurately represent true emissions. The minimum data availability requirements of40 CFR 75.20 to 75.34 shall be met. Periods ofCEM malfunctions shall be subject toSW APCA 400-105(5)(h) which exempts the Centralia Plant from monitoring andreporting requirements if SWAPCA determines that the CEM malfunction was unavoidable. When determiningcompliance withthe S02 1imitations formonitorout-of-serviceperiods of four hours or less in duration, the average of the hour before and the hour following a monitor out-C?f-service period, in accordance with 40 CFR 75.33(b)(l)(i) shall be used. Because the missing data substitution procedures for 40 CFR 75.30 to 75.34 may require the use of emission values that do not represent actual emissions, alternative data may be used for missing data periods. When determining compliance with S02 limitations for monitor out-of-service periods greater than four hours, data from the on-line coal analyzer operated by SWAPCA 97-2057R1I 2 

### 3 4 5 

### 6 7 

### 8 9 

### 10 

### 11**~** 

### 13 14 15 

### 16 17 18 19 20 21 22

24 28. 

### d. the Centralia Mining Company, the as-burned coal analyses conducted by ·Centralia Plant, and emission control system operating data shall be evaluated. The dataor combination of data, that best 'representS actual emissions shall be used to determine compliance with the S02 

### limitations. Stack test data may be used, ifavailable and approved by SW APCA. Quarterly reports for Centralia Plant Units #I and #2 shall be submitted to SW APCA by the end ofthe month following the c:nd ofeach calendar quarter. Each report shall include, but not be 

### limited to, the following: {1) 

### Hourly concentrations of

### S02 

### in ppni, dry 

### basis corrected to 7% 0 2; {2) 

### Tons ofS02 

### emittedfrom all relevant stacks {plus any extreme emergency bypassesthroughtheoldstacks) foreach 12-monthperiod, endingwiththe last day ofeach month in the quarter; (3) 

### Complete 40 CFRPart75 quarterly reportondisk may be submitted under separate cover; (4) 

### During 2002, daily megawatt generation from each boiler to allow confirmation ofloading priority ofthe boilers. THAT; exceedances and violations ofshort-term and annual emissions limitations shall be deftned as described below:
a. An exceedance ofthe hourly limitation (250

### ppm and 1000

### ppm) is defined as any fixed hour (e.g., 1:00 

### p.m. to 1:59 

### p.m.) with 

## so2 concentration over the limitations as deftned and determined under Items 21 

### and 22 

### above; b. Exceedance of the hourly S02 

### limitations in Items 21 

### and 22 

### above shall.be 

### ·- 

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subject to SW

### APCA 400-107. 

### The Centralia Plant shall have the burden ofproof · . ......._..,**~** 

### demonstrating unavoidable conditions that lead to excess emission in accordance 

# J Page 16 SWAPCA 97-2057Rl

### 1


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### 3 

### 4 5


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# ,.. 9 10 11 

# r**-~** 13 14 15 16 17 

# ,... ' 18


# ,... 19 I 20 

# - 21 

# r 22**~** ,... 1 with SWAPCA 400-107. Excess emissions shall be reported to SWAPCA by telephone during the current business day or next business morning; a message may be left .on an automatic answering machine outside normal business hours. A written report may be required by SWAPCA if determined necessary. Violations and penalties for exceedances ofthe hourly limits shall be determined in accordance with SW APCA 400-230 and RCW 70.94; 

### c. An exceedance ofthe annual limitation is one 12-month period exceeding the tons/year S02 limitations as defmed- and determined**und~r** Items 18, 19, and 20 above. All hourly 

## so2 emission data. for startup, shutdown, upset and forced or planned emission control system outage. periods shall be included in the calculations ofthe annual tons of

## so2 emitted; 

### d. Except as provided herein, ea?h exceedance of the annual (rolling 12-month) emission limitation shall constitute a continuing violation for the days in the last month ofthe 12-month (annual) period. Each day ofviolation shall be treated equally and be subject to penalty as allowed by law at the time of the noncompliance. The Centralia Plant may calculate 365-day emission summations ending on each day in the last month ofthe 12-monthperiodto reduce the number ofviolation days subject to penalty. Ifadequately demonstrated, the number of violation days shall not include the number of365-day periods ending within the last month ofthe exceedance period for which the emissions summation did not exceed the annual limit;
e. SWAPCA retains the authority to take enforcement action m response to deficiencies in plant operation and maintenance, equipment performance, or any Page 17 SWAPCA 97-2057Rl

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I othermatternotexplicitly

### i~entified inItems 25 and26, consistentwith SWAPCA

### ~~ 

### ' 2 400 General Regulations for Air Pollution Sources; 

# ..J 3 f. In addition to penalties that ·may be assessed under statutory and regulatory I ....I 4 authorities, beginning in calendar year 2002, the Centralia Plant shall forfeit
. 5 ownership of 802 allowances to SW APCA equal to 1.5 times the quantity of 

# - 6 emissions in excess ofthe 10,000 ton annual limit calculated on a calendar year ! 

## j 7 basis. 8 

### 29. THAT, ifthe selectedemission oontroltechnologyincludes constructionofanewstack(s) 

### 9 with one ortwo flues, the existing stack for each unit may remain for bypass situations 10 11 provided that certified CEMs 

### are maintained in the existing stacks. If there 

### are no certified functioning CEMs in the existing stacks, these stacks shall only beused during 

# J
2 extreme emergency conditions, provided that a separate bypass duct.around the S02 13 emission control technology is not constructed into the new stack. Examples of ' 14 emergency conditions are interruption ofthe exhaust gas flow path through that unit's 

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15 scrubbervessel, orother situations with the potential to result inpersonal injury or severe 16 damage to the boiler, emission control systems, or new stack. Any bypass that is not 17 monitored by a certified functional CEM 'is considered an upset condition and shall be 18 reported to SWAPCA during the current business day or by the next business morning 19 and shall be documented to SWAPCA within 5 days of the occurrence. All S02 

# J 20 emissions discharged from a**bypa~s** stack shall be included in the calculation ofemissions 21 for determining compliance with the annual limit.


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# ,..
.. OXIDES OF NITROGEN 30. THAT, the annual average (calendar year) emission rate for NOx shall not exceed 0.30 lb/MBtu, both units averaged together, for those hours when a unit's generating load is 360 MW 

### gross or greater. (This annual average emission rate is calculated·as the combined arithmetic sum of hourly emission**ra~es** 

### for each unit when ·each unit's generating load is 360MW gross, orgreater, dividedbythe combined sum ofthenumber ofhours that each unit operated at 360 MW, 

### or greater,**d~** 

### the calendar year.) For all operatinghours, emissions ofNOx shall not exceed 0.35 lb NOxfMBtu annual average (calendar year), both units averaged together. These emission limits shall be. subject to the schedule in Items 31 and 32. All other provisions including compliance demonstration shall be consistent with the Acid Rain Program provisions. 31. THAT, the selected NOx. emission control technology shall be operational no later than December 31, 2001 for the frrst unit and December 31, 2002 for the second unit. 32. THAT, the NOx exhaust gas emission rate during installation of control technology according to the schedule in Item 31 above, shall not exceed the following:
a. 0.31 lb!MBtu annual average for the controlled unit for all hours when the unit generating load is 360 MW 

### gross or above, 0.36 lb!MBtu annual average for all operating hours for the controlled unit, 0.45 lb/MBtu annual average for the uncontrolled unit, ifdischarged through separate stacks, effective only in calendar year 2002; b. 0.40 lb/MBtu, annual average, both units combined, ifthe exhaust gases from both units (one unit controlled, one unit not controlled) are discharged through a new common flue, effective only in calendar year 2002;
Page 19 SWAPCA 97-2057Rl1 2 3 4 5 6 7 8 9 10 11

'2 13 14 15 16 17 18 19 20 21 

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c. Ifboth units have 802 control technology installed by December 31, 2001, the /**~;**

33. d. emission limits.in Item 30 shall be effective 

## mcalendar year 2002 .and beyond; The emission limits in Item 30 shall be effective in calendar ye&- 2003 and beyond. THAT, for good cause, SWAPCA may, at its discretion and after meeting any public involvement requirements under SWAPCA 400-171 and any other applicable law or regulation, modifY theNOx emissions limitations ofthis 0r4er. Good causemay include, for example, higher NOx emissions than predicted by the manufacturer in the RACT submittal when operated in accordance with good industry practices or excessive boiler waterwall tube corrosion resulting from the installation and operation ofthe low NOx modifications. All causes resulting from installation ofLevel III low NOx technology shall be documented to SWAPCA no later than December 31, 2006, except excessive boiler waterwall tube corrosion which shall be documented to SWAPCA no later than December 31, 2008. A request to modifY the NOx conditions ofthis Order shall include
an explanation ofthe reasons why the RACT NOx emissions limits established in this Order**~ot** be met, why the reasons for such modification were beyond the control of the Centralia Plant, identification ofariy special operating conditions that may be the sole
or principle reason for a modification, and what efforts were taken within the timelines specified above to avoid and/or mitigate the need for a modification. Nothing in this section shall be construed to limit SWAPCA's authority to revise this Order pursuant to Item 59 ofthis Order.

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### PARTICULATE MATTER 34. THAT, emissions offront halfparticulate matter shall not exceed 0.010 .gr/dscf(Method 5, orequivalent, front halfonly), as corrected to 7% 0 2, evaluated onceperyearfor each stack (flue) by source testing effective after December 31, 2001. 35. THAT, compliance with the grain loading limit shall be· based on an annual stack test using EPA Method j, or equivalent. The test method selected shall be consistent with the 802 control technology selected and shall be**approp~ate.** for the stack conditions existing for the selected 802 control technology (i.e., wet or dry stack and maximum temperature). Only the front halfcatch shall be used for compliance demonstration with this limit, however, the backhalfcatch should continue to be performed to provide an indication oftotal (condensible and non-condensible) particulate matter emitted from the plant. 36. THAT, the opacity ofemissions shall be based on the continuous opacity monitoring system (COM8) if stack conditions allow accurate particulate matter readings without being adversely affected bymoisture. Opacity shall not exceed 20% based on a 6-minute average, except for one 6-minute period per hour ofnot more than 27% opacity. See 40 

### CFR60.42a(b). Inaddition, visible emissions as determinedbya Certified Observershall not exceed 20% opacity for more than 3 minutes in anyone hour period as provided in SWAPCA 400-040(1 ). Both standards for opacity determination apply. If moisture is present in the gas stream to the extent that it interferes with the COMS providing accurate opacity data, then visual observations using EPA Method 9 shall be performed a minimum ofonce per quarter to demonstrate compliance. 37. THAT, the particulate matter and opacity emission limits shall apply at all times but are excused for startup and shutdown, and may be excused for periods of malfuncti.on or Page 21 SWAPCA 97-2057R I

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1 upset consistent with S\:VAPCA 400-107. In addition, opacity exceedances shall be 2 allowed during periods ofmanual precipitator rapping and are excused under SW APCA 3 400-107(5). Such opacity exceedances shall be reported to SW APCA no later than the. 4 next business day and shall be noted 

### in the quarterly report. 

### 5 38. THAT, during startup and shutdown ofthe Centralia Plant boilers for phmned or forced 

### 6 unit outages, emissions control equipment shall be operated to minimize overall 7 emissions,.except to.the extent equipment operation will cause degradation ofits long-



## . '
. 8 term performance. Exceedances ofthe normal operation particulate matter and opacity 9 limitations are excused under WAC 173-400-107(4) and SWAPCA 400-107(4) during 

### j 

# - 10 startup andshutdownwhentheelectrostaticprecipitators(ESPs)andS02emission·control ! 

### 11 system(s) are out ofservice. The shutdown period begins when the ESP temperature 

### ...J

2 drops to the critical ESP de-energize temperature, 220°F. When the critical temperature 13 is attained; first the S02 control system, and then the ESPs are taken out ofservice. The 14 startup period begins when fuel is introduced into a boiler with the intent ofraising its 15 temperatureto operating conditions. TheESPs are energizedwhenthey reach operational ' 

### .....! 16 temperature. The S02 control**syst~(s)** is(are) placed in service following ESP 17 stabilization. The startup period ends when the earlier ofthe two operating events below 18 occurs: 19 a. Opacity in the gas path downstream ofboth ESPs has stabilized below 10% for 20 30 minutes (five consecutive 6-minute periods); or 21 b. 8 hours have elapsed after the startup unit is synchronized to be electrically on22 line.**~~** 

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### 24 CARBON MONOXIDE 

### 39. THAT, emissions ofcarbon monoxide·shall not exceed 200 ppm on an 

### annual average (calendar year), combined. This emission limit is effective after December 31, 2001. 

### 40. THAT, compliance with the carbon monoxide emission concentration limit shall be 

### determined annually using**existin~** 

### plant operating· data to identify average CO 

### concentrations: For information**purpose~,** 

### year-to-date average carbon monoxide concentrations shall be calculated.and reported quarterly.**~lant** 

### operating data collected by the CO 

### monitors shall be validated once per year, for each stack (flue), by .source testing, using EPA

### Method 10, to confirm the representativeness ofthe CO

### monitor data. PROJECT MILESTONES 41. THAT, to the extent applicable to the control technology selected, the following project milestones shall be met through reporting ofprogress to 

### SWAPCA:
a. Demonstration ofinitial progress to install 

### S02 

### airpollution control facilities shall be submitted by November 1, 1998. 

### Initial progress may include, but is 

### not limited to: engineering work, agreements to proceed with construction, contracts to purchase or contracts for construction ofair pollution control facilities. b. A 

### procurement contract for the first unit S02 

### emission control system(s) shall be awarded no later than March 31,·1999.


### c. Commencement of physical onsite construction activity for the first unit S02 

### emission control system(s) shall commence no later than August 31, 1999. 

### d. A procurement contract for the second unit S02 

### emission control system(s) shall be awarded no later than March 31, 

### 2000.
e. Commencement ofphysical onsite construction activity for the second unit S02 

### emission control system(s) shall commence no later than August 31, 

### 2000. Page 23 

### SWAPCA 97-2057R I2 3 4 5 6 7 8 9 10 11 2 13 14 15 16 17 18 19 20 21 22

3 24 42. 

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ComJl!encement ofstartup testing of802 control equipment for the first unit shall , 

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## ..........,., f.
occurno later than October 31, 2001 andthe second unitby no later

### than October 31, 2002. Startuptesting is consideredto be the initiation offlue gas through the 802 control system. 

### g. The 802 control system shall be installed and fully operational for the first unit
no later than·December 31, 2001 and for the second unit no laterthan December 31, 2002. 

### h. A procurement contract for the first unit NOx emission control system(s) shall be awarded no later than October 31, 2000. The second unit NOx emission control system(s) shall be awarded no later than October 31, 2001. i. Commencement of physical onsite construction activity for the first unit NOx emission control system(s) shall commence no later than August 31, 2001. Commencement ofphysical onsite construction activity for the second unit NO._ emission control system(s) shall commence no later than August 31, 2002. J. NOx control equipment startup testing shall be commenced no later than October 31, 2001 and October 31, 2002, for the first and second units, respectively. k. The NOx controls shall be installed and fully operational for the first unit no later than December 31, 2001 and for the secondunit no laterthan December31, 2002. RECORDKEEPING AND REPORTING THAT, a comprehensive test plan shall be submitted to SWAPCA for revxew and approval at least five business days prior to performance ofany periodic testing beyond CEMS monitoring required in this Order. SWAPCA shall be notified at least three days in advance of any testing so that personnel may be present during testing. A minimum of three test runs shall be performed at a**minim~m** ·of 500 MW gross to establish that 

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### .,.... collected datais representative ofnormal operation. Compliance shall be determined by ·averaging the results ofindividual test runs. The results ofrequired emissions testing shall beprovidedto 8W APCA by no later than 45 days followirig completion oftesting.· All gaseous emissions shall, as a minimum, be reported in parts per million by volume, pounds per hour, and pounds per million Btu of heatinput. Emissions data shall be reported as correctedto 7% 0 2• The test report shall include a summary of operating conditions for each test run to include, as a minimum:**~**l) estimated heat input into furnace (MBtulhr), (2) estimated fuel'consumption rate Oblhr), (3) airdischarge flowrate in dry standard cubic feet, (4) exhatist temperature of emissions out the stack, (5) estimated sulfur content ofcoal, 

### (6) estimated 

### 802 reduction in percent, as a result of controls, and (7) unit load in megawatts on an hourly basis. Initial source testing ofthe 

## so2 control system shall be completed no later than 90 days after demonstration of successful operation ofthat 

### 802 technology. 43.
. THAT, Respondent shall submitquarterly emissionreports byno later than the end ofthe month following the end of each calendar quarter of the calendar year. These reports shall contain, as a minimum, the following information:
a. Total·gallons offuel oil burned in each boiler (Boiler # 1, Boiler #2 and auxiliary boiler) and certification of sulfur content in fuel oil; b. Information required under 

### 40 CFR 75;
c. CEMS/DAHS data for NO, and S02 corrected to the units of measure and averaging times, including rolling averages, consistent with the emission limits established by this Order and applicable federal requirements. The date, time and measured oxygen content in percent shall be provided for each reported hourly value; Page 25 SWAPCA 97-2057RII 2 3 

### 4 5 6



### 8 9 10 11 '2 13 14 15 16 17 18 19 20 21 22

3 

### 44.

45.

46. 

### d.
e.

f.



### g. Quarterly average CO concentrations for each boiler; Quarterly opacity excess emissions over 20%, ifopacity monitoring is possible under stack conditions,. otherwise report results ofquarterly Method 9 test;. Yearto date tot:S.Is for

### S02 emissions and averageNOx emission rate for Units #1 and #2 under all operating conditions; and Estimated monthly average fuel heating values (Btullb) for coal burned in Boiler #1 and Boiler#2 to assistwith periodic**complianc~** checks. HSB 1257 TAXABATEMENT REQUIREMENTS.**THAT~** Respondent shallreport progress to SW APCA on meeting the requirements of House SubstituteBill (HSB) 1257 annuallybyJune 1 ofeachyear duringtheconstruction period ofthe 

## so2 control equipment (both units) and then monthly after the 

## so2 control equipment is operational. Suchreport shall contain sufficient data and/or documentation to demonstrate compliance with HSB 1257 for tax abatement purposes. VOLUNTARY 

### EMISSION LIMIT THAT, the total annual fuel oil combustedin the auxiliaryboiler shallnot exceed 600,000 gallons per year. Consumption shall be reported quarterly to SW APCA. The auxiliary boiler shall have a separate fuel meter to monitor the total amount offuel it consumes in that boiler. Emissions ofS02 from the auxiliary boiler shall be included in the 10,000 tons per year emission limit of Item 18. Emissions shall be calculated based on fuel consumption and fuel sulfur content. GENERAL PROVISIONS THAT, the owners ofthe Centralia Plant shall have sole discretion to select the control technology which complies with the emission limitations herein specified.
Page 26. SWAPCA 97-2057RI 

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24 47.

-48.

49.

50.

51. THAT, any physical changes of the boilers and draft systems, including fans for the purpose ofinstalling NOx and S02 emissions control equipment, will'not trigger New Source Performance Standards (NSPS) or BACT/PSD under New Source Review as a modification per 40 CFR 60.14(e), WAC 173-400-110, or SWAPCA 400-110. Any physicalchanges associatedwiththeinstallationofpolbitioncontrolstomeetthe emission limitations of this Order shall not be major modifications because such changes are exempted for electric utility boilers in 40 CFR52.21(b)(2)(iii)(h) from thePrevention of Significant Deterioration (l>SD) program under 

### WA,C 173-400-141, SWAPCA 400-141, and 40 CFR 51 Subpart I and 40 CFR 52.21. THAT, at all times, including periods ofstartup, shutdown, and malfunction, the plant shall, to the extent practicable, maintain and operate air pollution control equipment in
a manner consistent w.ith good air pollution control practice for minimizing emissions. Determinationofwhetheracceptableoperatingandmaintenanceprocedures arebeingused will bebased on information available to SWAPCA which may include, but is not limited to, monitoring.results, review ofoperating and maintenance procedures and records, and inspection ofthe source. THAT, the emission limits and conditions 

### ofthis Order supersede all previously issued Regulatory Orders including SWAPCA 90-934E. THAT, the Centralia Plant shall submit an annual emission inventory to SWAPCA in accordance with SWAPCA 400-105. THAT, this RACT Regulatory Order is subject to SWAPCA's authority to review and revise this Order pursuant to RCW 70.94. I53 and 70.94.154 and shall not limit SWAPCA's authority under RCW 70.94 or other applicable federal and state laws and regulations. Page 27 SWAPCA 97-2057RII 2 3 

### 4 5 6 7 

### 8 

### 9 10 11 

### '2 13 14 15 

### 16 17 18 19 20 21 22 

### 52.



### 53.

54.



### 55.

56.

57. 

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THAT, ifany provision ofthis Regulatory Order shall be declared invalid by any court .........._,( of competent jurisdiction,
.all unaffected
.provisions shall remain 

# meffect and be j 

### enforceable. THAT, for the purpose of ensuring compliance with this Regulatory Order, duly au$orized representatives of the Southwest Air Pollution Control Authority shall be 

### permitted access to Respondent's premises and the facilities being constructed, owned, 

### operated and/ormaintainedbyRespondent duritig**regul~ ~usiness**  

### hotirs for the purpose ofinspecting said facilities. These inspections are required to determine the· status of compliance with the terms ofthis Regulatory Order. THAT, the provisions, terms and conditions ofthis Regulatory Order shall be·deemed to bind Respondent, its. officers, directors, agents, servants, employees, successors and assigns, and all persons, firms and corporations under or for it. THAT, the requirements ofthis Order shall survive any transfer of ownership of the Centralia Plant or any portion thereof. THAT, this Orderdoes notsupersederequirements ofotheragencieswithjurisdiction and further, this Order does not relieve Respondent of any requirements of any other governmental agency. In addition to this Order, Respondent may be requiredto obtain other permits.or approvals from other Agencies withjurisdiction. THAT, compliance with this Order and its requirements does not relieve the Respondent from responsibility ofcompliancewith Southwest Air Pollution Control Authority General Regulations for Air Pollution Sources, RCW 70.94, WAC Title 173 or any other applicable air contaminant emission control requirements, nor from the resulting liabilities and/or legal remedies for failure to comply. 

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### 58. THAT, the CentraliaPlant shall provide annualwritten certification thattherequirements



# - 2 of this**R~atory** Order have been met. Certification of truth, accuracy and



# ,... 3 completeness shall be provided by a responsible official, as defmed in WAC 173-401 4**~Operating**PermitRegulation", andshallbesu.bmitted witheachreport. Thiscertification 

# ,.. 5 shall state that, "based on the information and beliefformed afterreasonable inquiry, the



# - 6 statements and informa?on in the report·are true, accurate and complete." 7 

### 59. THAT, for good cause shown, SWAPCA may, in its disc;etion and after meeting any 

# ,.. 8 public.involvementrequirements under SWAPCA400-171 and any other applicable law 

# ,.. 9
.orregulation, modify or stay theproject milestones, effective dates, orOrder
..A request 10 to modify or stay the project milestones, effective dates, or Order should include an 

# ,.. 11 explanation ofthe reasons why the current project milestones, effective dates, or Order 

# r 12 cannot be met, whether the reasons for the modification or stay were beyond the control 13 ofthe Centralia Plant, what efforts were taken to avoid and/or mitigate the need for a 

# - j 14 modificatio11 or stay, and a proposed schedule that can be met.


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### 5 6 

### 7 

### 8 9 10 11



### 13 14 15 60. THAT, this Order, once signed and issued, may be 

### appealed pursuant tQ 

### RCW 43.21B.230
.. An 

### appeal must be filed with the Pollution ControlHearings Board (PCHB) atPO Box40903,·olympia, WA 98504-0903, and shall be served on SW APCA within thirty (30) days from the date of the notice of this Order. This Order may also be appealed as provided in SW APCA 400-250. DATED this 26th day ofFebruary, 1998.

Reviewed

# by:~~~ Paul T. Mairose, P.E. ChiefEngineer
Approved by:

# ---=~=-:::::...;;--=-·**_..:...•;___~_....;._·** .....;__ ___ _ 

### Robert D. Elliott Executive Director SouthwestAir Pollution Control Authority

Page 30 SWAPCA 97-2057RI 

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