IN THE MATTER OF A PERMIT APPLICATION (AP-6045) FROM FMC WYOMING

CORPORATION FOR A BEST AVAILABLE RETROFIT TECHNOLOGY (BART) PERMIT

FOR THE WESTVACO FACILITY

DECISION

I. Introduction:

The Air Quality Division received a BART permit application from FMC Wyoming Corporation for two

existing 887 million BTU (MMBtu) coal-fired boilers and one existing natural gas-fired boiler (336

MMBtu) at the Westvaco Facility in Sweetwater County, Wyoming. Regulations governing the BART

program have been established by the U.S. EPA in 40 CFR Part 51 - Appendix Y. As stated in the

regulations, a source is eligible for BART ifit belongs within a group ofstationary source categories, was

not in operation prior to August 7, 1962, was in existence on August 7, 1977, and has the potential to emit

250 tons per year (tpy) or more of any visibility impairing air pollutant. Fossil fuel boilers of more than

250 MMBtu per hour heat input are listed as an eligible source type. Potential emissions from the

Westvaco Facility coal-fired boilers (installed in 1975) for two visibility impairing air pollutants, nitrogen

oxides (NOx) and sulfur dioxide (S02), exceed 250 tpy and therefore the facility is eligible for BART.

The Division conducted an analysis of the BART permit application and on August 12, 2008, published

in the Rock Springs Daily Rocket-Miner a public notice and notice of public hearing of the proposed

intent to issue BART determinations. Copies of the BART application and the Division's analysis were

placed in the Sweetwater County Clerk's office in Green River, Wyoming, in accordance with

regulations. A 30-day public notice period ran from August 12, 2008, to September 11, 2008, and a

public hearing was held on Thursday, September 11,2008, at 6 p.m., in Room 1302 at Western Wyoming

Community College, located at 2500 College Drive in Rock Springs, Wyoming.

To allow adequate opportunity for comment as specified under the Regional Haze Rule 40 CFR

51.308(i)(2), the public comment period was extended to October 20, 2008.

The Division received five (5) comment letters on the proposed permit during the public comment period:

1) a September 10, 2008 letter from the Wyoming Outdoor Council; 2) a September 11, 2008 letter from

the FMC Corporation; 3) a September 15, 2008 letter co-signed by the U.S. Fish and Wildlife Service

(FWS) and the National Park Service (NPS); 4) an October 17, 2008 letter with supplemental comments

from the Wyoming Outdoor Council; and 5) an October 17, 2008 letter from EPA Region 8. The

Division received one (1) comment letter on the proposed permit after the public comment period on

November 7,2008 from the USDA Forest Service. The USDA Forest Service comments were received

after the close of the 69-day public notice period that ran from August 12, 2008 through October 20,

2008. As such, the Division cannot consider or respond to the comments in the [mal BART

determination on this application. The comments and the Division's responses are presented on the

following pages.

II. Analysis of Comments from the Wyoming Outdoor Council:

ILl SNCR Should Be Required as BART in Addition to LNB - The Wyoming Outdoor Council

commented that selective non-catalytic reduction (SNCR) should be required as BART for the

coal-fired boilers to increase visibility improvement because no additional controls will be

required for the gas-fired boiler, and because the 10w-NOxburners (LNB) are already required by

a recent permitting action and should be considered the baseline condition.

Response - The Division's BART determination for the coal-fired boilers was based on several

factors, including the negligible impact on visibility that was modeled for SNCR vs. LNB. This

determination was made independent of the gas-fired boiler, as EPA BART guidelines require.
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Control Option 1 (LNB and overfire air [OFA]) was chosen as BART rather than Control Option

2 (LNB/OFA + SNCR) not only because of the added costs associated with Option 2, but also

because LNB/OFA does not require non-air quality environmental mitigation for the use of

chemical reagents and because ofthe low level of modeled visibility improvement for Option 2.

Option 2 provided a predicted improvement in visibility at Bridger WA of(at most) only 0.06 dv,

based on the modeled 98th percentile results. For Fitzpatrick, the predicted improvement was at

most 0.04 dv.

Regarding the recent permitting action at the Westvaco Facility, 40 CFR 51.309(b)(7) states that

"Base year means the year for which data for a source included within the program were used by

the WRAP to calculate emissions as a starting point for development ofthe milestone required by

paragraph (d) (4) (i) of this section." Because the Western Regional Air Partnership (WRAP)

used 2003 as the starting point for development of milestones for S02 emissions, the emission

control configuration in place at a given facility in 2003 was considered by the Division to be the

baseline configuration for BART. Additionally, the period for establishing the baseline visibility

conditions under the Regional Haze Rule is 2000 to 2004 [40 CFR 51.308(d)(2)]. The LNB

configuration for the two boilers at the FMC Westvaco Facility that was permitted in 2007 was

therefore considered a control strategy option rather than a baseline configuration.

II.2 Impacts Analysis in the Proposed Permit is too Limited - The Wyoming Outdoor Council

commented that the Division's analysis of the BART options for the Westvaco Facility did not

fully consider all factors for a BART analysis, and that cost was the only driver in the BART

determination for NOx.

Response - The Division's BART determination for the Westvaco Facility was not driven by a

single factor. After considering: (1) the costs of compliance, (2) the energy and non-air quality

environmental impacts of compliance, (3) any pollution equipment in use or in existence at the

source, (4) the remaining useful life ofthe source, and (5) the degree ofimprovement in visibility

(all five statutory factors) from each proposed control technology, the Division determined BART

for the Westvaco Facility. Control Option 1 (LNB and overfire air [OFA]) was chosen as BART

rather than Control Option 2 (LNB/OFA + SNCR) not only because ofthe added costs associated

with Option 2, but also because LNB/OFA does not require non-air quality environmental

mitigation for the lIse of chemical reagents and because of the low level of modeled visibility

improvement for Option 2. Option 2 provided a predicted improvement in visibility at Bridger

WA of (at most) only 0.06 dv, based on the modeled 98th percentile results. For Fitzpatrick, the

predicted improvement was at most 0.04 dv.

After reviewing the comments received on the proposed BART limits for the Westvaco Facility,

the Division requested that FMC evaluate additional state-of-the-art control levels achievable

through the application of low NOx burners with enhanced overfrre air on the two boilers at the

facility. In a letter dated November 24, 2008, FMC proposed that the lb/hr NOx limit (30-day

rolling) could be reduced from 310.5 lb/hr (equivalent to 0.35 IblMMBtu) to 290 lb/hr (equivalent

to 0.33 IblMMBtu), based on a review of actual emission levels from the LNB/OFA retrofits on

the two coal-fired boilers. After further review of the actual performance of the LNB/OFA

retrofits, FMC sent a letter to the Division dated May 27, 2009 that proposed an additional

reduction in the 30-day rolling average to 284 lb/hr (equivalent to 0.32 IblMMBtu). The lower

emission limit of284lb/hr will be set as the BART limit for each ofthe two coal-frred boilers, as

reflected in the final section of this document. The performance/efficiency-based limit will
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remain at 0.35 IblMMBtu (30-day rolling), as described in the response to comment V.1 below.

Copies ofthe letters from FMC are attached to this document.

11.3 Receptors Are Not Adequately Identified - The Wyoming Outdoor Council commented that

the Division's analysis did not adequately identify the receptors that were used to model visibility

impacts at Class I areas.

Response - Latitude and longitude coordinates for Class I area receptors were taken from the

NPS Class I Receptors database and converted to the appropriate Lambert Conformal Conic

coordinates for input to the CALPUFF model. The Class I receptors contained in the NPS

database are recommended by the Federal Land Managers for use in long-range transport (e.g.,

CALPUFF) modeling of Class I areas. Receptor spacing for the modeled areas is approximately

1.3 km in the east-west direction and approximately 1.8 km in the north-south direction. The

receptor configurations that were used for Bridger Wilderness Area (WA) and Fitzpatrick WA are

shown in the figures below.

Figure 1

tors for Brid er WA

Bridger Wilderness

684 Receplors

USFS Boundary Source: - FSNalional Coverage file: NRIS· AlP-group

Cor;allis.OR

AuguSl 27.2003

Source: http://www.nature.nps.gov/airlMapslReceptors
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Figure 2

Receptors for Fitzpatrick WA

• • • + • .. • • + •

• • • • • • + • •

... .. ......... + • • .. • • • • • .. • •

·.... ... .... .. • • • • + .. • .. • +

·.. ........ .... .. .. .. ... ..... ..... .. ..... .. . .. ... ... .. .. ... ...... . ................

.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..

+ + •

+ •

+ +

+ + +

FlzpatrickWiderness

316 Receptors

USFS Boundary Source:

FS National Coverage file: NRIS· ALP group

Corvallis, OR

.August 27,2003

Source: http://www.nature.nps.gov/air/MapslReceptors/index.cfm
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11.4 Impacts Less Than 0.5 dv Should Not Be Deemed A Per Se Does Not Contribute Situation -

The Wyoming Outdoor Council commented that a modeled level of 0.5 dv should not be used as

a threshold below which visibility impacts are deemed to be insignificant.

Response - The Division is comfortable using 0.5 dv as the threshold level to exempt a source

from BART or to deem modeled impacts as insignificant. EPA's Regional Haze Regulations and

Guidelines for Best Available Retrofit Technology (BART) Determinations (Appendix Y to 40

CFR part 51), suggest that 0.5 dv can represent the level at which a source "contributes" to

visibility impairment. This is also consistent with the rules which are being applied by most

states in the WRAP region. Further, the Division believes that the 0.5 deciview threshold is a

conservative value given that language in the Regional Haze Rule suggests that 1.0 dv is an

appropriate perceptibility threshold and recent literature suggests that the perceptibility threshold

is greater than 1.0 dv (from page 39120 ofAppendix Y to 40 CFR part 51).

II.5 Scaling Factors Used for Background Aerosol Concentrations Should be Explained And

Justified - The Wyoming Outdoor Council commented that the process of determining

background aerosol concentrations for the 20% best visibility days was not explained in adequate

detail.

Response - Individual species concentrations corresponding to the 20% best days natural

background were calculated for each Class I area by scaling back the annual average natural

background concentrations given in Table 2-1 of the EPA document Guidance for Estimating

Natural Visibility Conditions Under the Regional Haze Rule. The EPA guidance document

provides annual average values of natural background for individual species, and total deciview

values for the 20% best days for particular areas, but does not provide values for individual

species for the 20% best days. Therefore, the Division developed separate scaling factors for

each Class I area such that, when multiplied by the guidance table annual concentrations for each

species, the 20% best days concentrations for each species for that particular Class I area could be

calculated.

The scaling procedure is illustrated here for Bridger WA. From Appendix B in the EPA natural

visibility guidance document, the total deciview value for the 20% best days at Bridger WA is

1.96 dv. To obtain the speciated background concentrations representative ofthe 20% best days,

the deciview value (1.96 dv) was first converted to light extinction. The relationship between

deciviews and light extinction is expressed as follows:

dv = lOin (bexJI0) or bext = 10 exp (dv/10)

where: bext= light extinction expressed in inverse megameters (Mm-I

).

Using this relationship with the known deciview value of 1.96, one obtains an equivalent light

extinction value of 12.17 Mm-I

. Next, the annual average natural visibility concentrations were

set equal-to a total extinction value-of 12.17 Mm-I

. The relationship between total light extinction

and the individual components ofthe light extinction is as follows:
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bext = (3)f(RR)[ammonium sulfate] + (3)f(RR)[ammonium nitrate] + (0.6)[coarse mass] +

(4)[organic carbon] +(1)[soil] +(10)[elemental carbon] + bray

where:

• bracketed quantities represent background concentrations in Ilglm3

• values in parenthesis represent scattering efficiencies

• f(RR) is the relative humidity adjustment factor (applied to hygroscopic species only)

• bray is light extinction due to Rayleigh scattering (10 MIn-I used for all Class I areas)

Substituting the total light extinction for the 20% best days, the annual average natural

background concentrations, the average f(RR) for Bridger WA, and including a coefficient for

scaling, one obtains:

12.17 = (3)(2.1)[0.12]X + (3)(2.1)[0.1]X + (0.6)[3.0]X + (4)[0.47]X + (1)[0.5]X + (10)[0.02]X +

10

In the equation above, X represents a scaling factor needed to convert the annual average natural

background concentrations to values representative of the 20% best days natural background.

Solving for X provides a value of 0.376. Table 1 presents the annual average natural background

concentrations, the calculated scaling factor, and the calculated background concentrations for the

20% best days natural background for Bridger WA.

Table 1: Calculated Back2round Components for Brid2er WA

Annual Average 20% Best Days

Natural Natural

Background for Calculated Background for

the West Region Scaling BridgerWA

Component (J.l2/m3

) Factor (J.lWm3)

Ammonium Sulfate 0.12 0.376 0.045

Ammonium Nitrate 0.10 0.376 0.038

Organic Carbon 0.47 0.376 0.176

Elemental Carbon 0.02 0.376 0.008

Soil 0.50 0.376 0.188

Coarse Mass 3.00 0.376 1.127

Because of the geographical proximity and similar annual background visibility for the Bridger

WA and Fitzpatrick WA, the scaled aerosol concentrations for the two areas were averaged. The

20% best days natural background aerosol concentrations that were used for the two Class I areas

in question for this analysis are listed in Table 2 below.
I C centrations (J.1g/m3

avs aura ac ~j!roundAeroso on )

Fitzpatrick

Aerosol WA&

Component Bridj!erWA

Ammonium Sulfate 0.045

Ammonium Nitrate 0.038

Organic Carbon 0.178

Elemental Carbon 0.008

Soil 0.189

Coarse Mass 1.136

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Table 2: 20% BestD N t IB k

11.6 Combined Impacts from Three Trona Plants in Southwestern Wyoming - The Wyoming

Outdoor Council commented that the modeled impacts from three trona plants in southwestern

Wyoming should be considered in combination rather than individually. Modeled results for

individual facilities were summed in a table in their October 17, 2008 letter.

Response - Summing the 98th percentile modeled visibility impacts for separate facilities is not

an accurate portrayal of combined impacts because the individual impacts may occur at different

locations (receptors) and during different 24-hour time periods. Moreover, the visibility impacts

from BART-eligible sources are to be determined separately. As stated in the EPA's Appendix Y

to part 40 CFR 51 - Guidelinesfor BART Determinations Under the Regional Haze Rule, relative

to the use of the CALPUFF model for BART determinations, "We believe that CALPUFF is an

appropriate application for States to use for the particular purposes ofthis rule, to determine if

an individual source is reasonably anticipated to cause or contribute to impairment of visibility

in Class I areas, and to predict the degree ofvisibility improvement which could reasonably be

anticipated to result from the use ofretrofit technology at an individual source. We encourage

States to use itfor these purposes."

m. Analysis of Comments from the FWS (and NPS):

ilL1 SOLControls - The FWS commented that the Bridger WA is not one of the Class 1 areas under

the Western Backstop Trading Program, and therefore "S02 controls of Section 309 sources

should be evaluated and documented as to the effects on the Section 308 areas."

Response - Wyoming, along with other 309 States in the WRAP region, evaluated the impact of

the 309 program on all Class 1 areas in the west, even though the requirement by rule was to

demonstrate improvement in Class 1 areas on the Colorado Plateau. The following table .

summarizes WRAP modeling for sulfates, and shows that all Class 1 areas in and around

Wyoming sources are benefiting from the sulfur dioxide emission reductions instituted in the 309

program. Sulfate extinction levels show improvement on the 20% worst days and improvement

or at least no degradation on the 20% best days. Furthermore, the Regional Haze rule allows the

state to take full credit for strategies implemented under 309 when addressing Class 1Areas away

from the Colorado Plateau (51.309(g)(4)(i»).
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Ta e bl 3: WRAP M do erID2 fior Su a e x If: t E fIDCfIon

Visibility - Sulfate Extinction Onh (Mm-1

)

20% Worst Visibility Days 20% Best Visibility Days

(Monthly Avera2e) (Monthly Averaf!e)

20181 20182 20182

Base Preliminary Preliminary

Case Reasonable 20181 Reasonable

(Base Progress Case Base Case Progress Case

Class JArea 18b) (pRP18) (Base 18b) (pRP18)

Bridger, WY 5.2 4.3 1.6 1.3 (Bridger W. and Fitzpatrick W.)

North Absaroka, WY

(North Absaroka W. and 4.8 4.5 1.1 1.1

Washakie W.)

Yellowstone, WY

(Yellowstone NP, Grand Teton 4.3 3.9 1.6 1.4

NP, and Teton W.)

Badlands, SD 17.8 16.0 3.5 3.1

Wind Cave, SD 13.0 12.1 2.7 2.5

Mount Zirkel, CO 4.6 4.1 1.4 1.3 (Mt. Zirkel W. and Rawah W.)

Rockv Mountain, CO 6.8 6.2 1.3 1.1

Gates ofthe Mountains, MT 5.3 5.1 1.0 1.0

ULBend,MT 9.7 9.6 1.8 1.7

Craters ofthe Moon, ill 5.8 5.5 1.5 1.5

Sawtooth, ill 3.0 2.8 1.2 1.1

Canyonlands, UT

(Canyonlands NP and Arches 5.4 4.8 2.1 1.9

NP)

Capitol Reef, UT 5.7 5.4 1.9 1.8 j

Represents 2018 Base Case wIthout S02 control strategIes

2Represents 2018 Preliminary Reasonable Progress with Regional S02 Strategies

III.2 SNCR Should Be Required as BART in Addition to LNB - The FWS commented that SNCR

should be required as BART in addition to low NOx burners (LNB) to increase visibility

improvement and because costs are reasonable.

Response - See response to Wyoming Outdoor Council comments II. 1 and II.2.

III.3 Control Strategies Should Not be Dismissed Because of Perceptibility - The FWS commented·

that a threshold of perceptibility should not be used to interpret visibility modeling or to exclude a

given control strategy from consideration as BART. The FWS stated that the Division's

misinterpretation of the 0.5 dv threshold led to the Division proposing only combustion controls

rather than SNCR.

Response - The Division did state that the chosen control option for BART (LNB/OFA) brought

the modeled impacts for each boiler to less than the 0.5 dv threshold at which a source is
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considered to "contribute" to visibility impairment, but incremental differences between control

options were also considered. Option 2 (SNCR) provided a predicted improvement in visibility at

Bridger WA of only 0.06 dv, based on the modeled 98th percentile results. For Fitzpatrick, the

predicted improvement was at most 0.04 dv. The Division concluded, after consideration of cost

and other factors, that the small differences in modeled visibility did not warrant the requirement

of a greater level of control.

IlIA Gas-Fired Boiler - The FWS commented that there is no exemption in the BART Guidelines for

the gas-fired boiler and that a BART NOx determination should be made for that source.

Response - The gas-fired boiler at the Westvaco Facility emits negligible quantities of the

visibility-reducing pollutants S02 and PMlO• Emissions of NOx from the gas-fired boiler are an

order of magnitude lower than the emissions from the two larger boilers at the facility. The low

level of emissions of visibility-reducing pollutants, coupled with the baseline visibility modeling

that yielded a maximum 98th percentile impact of only 0.05 dv at Bridger WA, led the Division to

conclude that the gas-fired boiler is not a significant contributor to regional haze. The Division

focused the refined BART analyses on the larger sources at the facility rather than the gas-fired

boiler.

IV. Analysis of Comments from EPA Region 8:

IV.l NO!..-BART Control Option Selection - EPA Region 8 commented that greater control of NOx

emissions and lower emissions limits should be required for the facility. The Division's use of

the 0.5 dv threshold to deem a given control strategy as acceptable is questioned, and Region 8

encourages the Division to consider SNCR as BART.

Response - See response to Wyoming Outdoor Council comments II.l and II.2 and FWS

Comment IlI.3.

IV.2 SOLControl - EPA Region 8 commented that the Division's Regional Haze SIP under the

Western Backstop Sulfur Dioxide Trading Program must demonstrate greater reasonable progress

than source-specific BART at all Class I areas, including Bridger WA and Fitzpatrick WA.

Suggestions for S02 control at the Westvaco Facility in the event reasonable progress cannot be

demonstrated were provided.

Response - See response to FWS Comment IlL1.

IV.3 Gas-Fired Boiler - EPA Region 8 commented that there is no exemption in the BART

Guidelines for the gas-fired boiler and that a BART analysis should be conducted for that source..

Response - See response to FWS Comment IlIA.
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IVA Class I receptor locations - EPA Region 8 commented that the receptors used to model Class I

areas were not adequately documented and justified.

Response - See response to Wyoming Outdoor Council Comment II.3.

IV.S PSD Requirements - EPA Region 8 commented that LNB and OFA are being installed under a

recent Chapter 6, Section 4 permitting action for the facility, and the level of control associated

with that permitting action should be considered the baseline condition for BART.

Response - See response to Wyoming Outdoor Council Comment ILl.

IV.6 RBLC Review - 'EPA Region 8 commented that the BART analysis does not adequately explain

why information for particular facilities was taken from the RACT/BACT/LAER (RBLC)

Clearinghouse. Also, several LNB upgrades in Wyoming that were not listed in the RBLC

should also be considered.

Response - FMC used the RBLC to compile listings of recent NOx and PMlO control

determinations for modified coal-fired boilers subject to Prevention of Significant Deterioration

(PSD). This information was used by FMC to help identify the available retrofit control

technologies for NOx and PMlO and was not intended to be the type of exhaustive search that

would have been required under a PSD BACT analysis. The Division is satisfied with the list of

potential control technologies identified by FMC.

IV.7 BART Permit Conditions - EPA Region 8 commented that if S02 controls are installed at the

facility, the BART permit should include limits for S02.

Response - Wyoming is a §309 state and will participate in the Western Backstop Sulfur Dioxide

Trading Program should it be triggered. §308(e)(2) provides States with the option to implement

or require participation in an emissions trading program or other alternative measure rather than

to require sources subject to BART to install, operate, and maintain additional control technology

to meet an established emission limit on a continuous basis. Because of Permit Condition 9,

requiring FMC's participation in the Western Backstop Sulfur Dioxide Trading Program, should

it be triggered, the BART permit for the Westvaco Facility will not include limits on S02

emissions or requirements to install S02 controls.

v. Analysis of Comments from FMC Corporation:

V.l NO!.,.Limits (lb/hr vs. IblMMBtu) - FMC Corporation commented that the Division should

establish NOx emission limits solely on a mass per unit time basis (lb/hr), rather than Ib/MMBtu,

to allow for periods when IblMMBtu levels may be inflated when steam loads decrease.

Response - The Division agrees that emission limits set on the basis of IblMMBtu may be

difficult to meet when steam loads fluctuate, and therefore emission limits based on lb/hr will be

set for the facility. The Division will also set performance/efficiency-based emission limits based

on IblMMBtu. This decision is based on several factors. First, the analyses that the EPA relied

on to develop their BART guidance, including the presumptive BART analyses, used IblMMBtu

as the only representation of emission limits. Regional Haze SIPs produced by Western states

also rely on emission limits based on IblMMBtu. Lastly, the Division believes that limits based
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on IblMMBtu promote diligence on the part of operators to run their sources in the most efficient

manner.

VI. Decision:

On the basis of comments received during the public comment period, an analysis ofthose comments, and

representations made by FMC Wyoming Corporation, the Department of Environmental Quality has

determined that the permit application filed by FMC Wyoming Corporation complies with all applicable

Wyoming Air Quality Standards and Regulations and that a BART permit will be issued for the FMC

Westvaco Facility. All of the conditions proposed in the Division's analysis will be included in the

permit with the following changes and additions (in bold):

5. Effective upon issuance of permit, emissions from boiler NS-IA shall not exceed the levels

below. The limits shall apply during all operating periods.

Fllterable portlOn only

Pollutant Ib/MMBtu lb/hr tpy

NOx 0.35 (30-day rolling) 284.0 (30-day rolling) 1244.0

PMlPMlO (l) 0.05 45.0 197.0

(II· •

6. Effective upon issuance of permit, emissions from boiler NS-IB shall not exceed the levels

below. The limits shall apply during all operating periods.

Fllterable portlOll only

Pollutant Ib/MMBtu lb/hr tpy

NOx 0.35 (30-day rolling) 284.0 (30-day rolling) 1244.0

PMlPMlO (l) 0.05 45.0 197.0

(I)· .

7. Performance tests shall be conducted no later than 90 days after permit issuance and shall

consist ofthe following:

i. Coal-fired Boilers (NS-IA, NS-lB):

NQy Emissions - Compliance with the NOx 30-day rolling average shall be determined

using a continuous emissions monitoring system (CEMS) certified in accordance with 40

CFRpart 60.

PMlPMlO Emissions - Testing shall follow 40 CFR 60.46 and EPA Reference Test .

Methods 1-4 and 5.

Testing required

.

by the Chapter 6, Section 3, Operating..Permit or permit MD-5723 may be

submitted to satisfy the testing required by this condition.

8. Prior to any perfarmanee testing required by this permit, a test protocol shall be submitted to the

Division for approval, at least 30 days prior to testing. Notification should be provided to the

Division at least 15 days prior to any testing. Results ofthe tests shall be submitted to this

office within 45 days of completing the tests.
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9. FMC Wyoming Corporation shall comply with all requirements of the Regional S02

Milestone and Backstop Trading Program in accordance with Chapter 14, Sections 2 and 3,

of the WAQSR.

10. Testing for PM shall be conducted annually, or more frequently as specified by the

Administrator, following 40 CFR 60.46 and EPA Reference Test Methods 1-4 and 5.

Testing required by the Chapter 6, Section 3, Operating Permit or permit MD-5723 may be

submitted to satisfy the testing required by this condition.

Dated this _17th _ day ofJuly, 2009.

J n V. Corra

irector

Wyoming Department ofEnvironmental Quality

David A. Fmley

Administrator

Wyoming Air Quality Division