Indiana Department of Environmental Management 

Michael R. Pence 

Governor 

Mr. Robert Kaplan 

Acting Regional Administrator 

We Protect Hoosiers and Our Environment. 

100 N. Senate Avenue • Indianapolis, IN 46204 

(800) 451 -6027 • (317) 232-8603 • www.idem.IN.gov 

March 21,2016 

Carol S. Comer 

Commissim1e1· 

U.S. Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard 

Chicago, IL 60604-3950 

Dear Mr. Kaplan: 

Re: State Implementation Plan Submittal for 

Indiana Regarding 1-Hour S02 Attainment 

Clifty Creek Generating Station in 

Jefferson County, Indiana 

(Commissioner's Order #2016-02) 

Addendum Documentation of the Public 

Participation Process 

Pursuant to Section 110 of the Clean Air Act (CAA) and Title 13 of the Indiana Code 

(IC), the Indiana Department of Environmental Management (IDEM) submits an 

amendment to the Indiana state implementation plan (SIP) for the Clifty Creek 

Generating Station (Clifty Creek) accomplished by Commissioner's Order #2016-02. 

IDEM submitted a request for parallel processing of the amendment to Indiana's SIP on 

February 5, 2016. IDEM scheduled a public hearing concerning the proposed SIP 

revision on March 10, 2016, and the public comment period concluded on March 17, 

2016. No comments were received during the public comment period. Additionally, 

there was no request for a public hearing during the comment period, thus a hearing 

was not held. 

The attached enclosure consists of the following: 

• Commissioner's Order #2016-02 issued on February 1, 2016, that establishes 

permanent and enforceable sulfur dioxide (S02) emission limits for Clifty Creek, 

located in Jefferson County, Indiana, in order to ensure continued attainment of 

the 2010 primary 1-hour S02 standard in the area surrounding the facility. The 

Commissioner's Order contains a facility-wide maximum 720 operating hour S02 

rolling average mass emission rate applicable to Units 1 through 6 combined, as 

well as reporting and recordkeeping requirements and method for compliance. 

The effective date for the emission limitations in the Commissioner's Order is 

April19, 2016. It contains and meets the requirements set forth in 42 U.S.C. § 

An Equal Opportunity Employer 0 Please Reduce, Reuse, Recycle A State that ~ 
Mr. Robett Kaplan 

Page 2 of2 

7407(d)(3)(E)(iii) and the conditions will become applicable requirements as 

defined in 326 Indiana Administrative Code (lAC) 2-7-1 . 

• Administrative checklist, modeling summary and documentation of the public 

participation process. 

This submittal consists of one (1) hard copy of the required documentation. An 

electronic version of the submittal in PDF format that is identical to the hard copy has 

been sent to Doug Aburano, Chief of U.S. EPA Region 5's Attainment Planning and 

Maintenance Section and Chris Panos of U.S. EPA Region 5. 

IDEM requests that U.S. EPA proceed with review and approval of this amendment 

to Indiana's SIP. If you have any questions or need additional information, please 

contact Brian Callahan, Chief, Air Quality Standards and Implementation Section, Office 

of Air Quality at (317) 232-8244 or bcallaha@idem.IN.gov. 

KB/sd/mad/bec/gf 

Attachments: Supporting Documents 

Sincerely, 

~6~ Keith Baugues 

Assistant Commissioner 

Office of Air Quality 

cc: Doug Aburano, U.S. EPA Region 5 (no enclosures) 

John Mooney, U.S. EPA Region 5 (no enclosures) 

Steve Rosenthal, U.S. EPA Region 5 (no enclosures) 

Pamela Blakley, U.S. EPA Region 5 (no enclosures) 

John Summerhays, U.S. EPA Region 5 (no enclosures) 

Chris Panos, U.S. EPA Region 5 (no enclosures) 

Jennifer Liljegren, U.S. EPA Region 5 (no enclosures) 

Keith Baugues, IDEM-OAQ (no enclosures) 

Scott Deloney, IDEM-OAQ (no enclosures) 

Mark Derf, IDEM-OAQ (no enclosures) 

Brian Callahan, IDEM-OAQ (no enclosures) 

Mike Mosier, IDEM-OAQ (no enclosure) 

Christine Pedersen, IDEM-OAQ (no enclosures) 

Jessica Reiss, IDEM-OAQ (no enclosures) 

File Copy 
Supporting Documents 

Attachment A: Administrative Checklist (40 CFR 51, Appendix V) 

Attachment B: Commissioner's Order #2016-02 

Attachment C: Legal Notice of Public Hearing and Certificates of Web Publication 

Attachment D: Modeling Summary 

Data, calculations and methodology for determining a facility-wide maximum 720 

operating hour rolling average S02 mass emission rate based on Clifty Creek's 

continuous emission monitoring data (available upon request). 
Attachment A 

Administrative Checklist 
ADMINISTRATIVE CHECKLIST (40 CFR 51, Appendix V) 

1. The submittal is accompanied by a formal letter of submittal 

from the governor or his designee. 

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, consent 

agreement ("document"); in final form. 

a. Date of adoption or final issuance: 

b. The effective date of the plan, if different 

from the adoption/issuance date. 

3. Evidence that the State has the necessmy legal authority 

under state law to adopt and implement the plan. 

4. A copy of the actual regulation or document submitted for 

approval and incorporation by reference into the plan, 

including the following: 

a. Indication of the changes made to the existing 

approved plan, where applicable. 

b. The submittal shall be a copy of the official State 

regulation or document signed, stamped, dated by 

the appropriate state official indicating that it is fully 

enforceable by the State. Effective date shall be stated 

in the document itself. 

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in 

conducting and completing the adoption/issuance of the plan. 

6. Evidence that public notice was given, including date of 

proof of publication. 

7. Certification that public hearings were held in accordance 

with information provided in public hearing notice. 

8. Compilation of public comments and State's response. 

9. Technical Suppoti Document (if source specific change). 

Enclosed 

Attachment B 

February 1, 2016 

Aprill9, 2016 

IC 13-14-1-9 

IC 13-14-2-1 

Attachment B 

Attachment B 

Attachment C 

Attachment C 

Attachment C 

Attachment D 
Attachment B 

Commissioner's Order for Clifty Creek 

Generating Station addressing the 1-hour S02 

NAAQS 

Jefferson County 
DDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Michael R. Pence 

GU\'t!l'llnt' 

100 N. Senate Avenue • Indianapolis, IN 46204 

(800) 451-6027 • (317) 232-8603 • www.ldem.IN.gov 

Carol S. Comer 

Cmmul.ulmwr 

STATE OF INDIANA 

COUNTY OF MARION 

) 

) SS: 

) 

BEFORE THE INDIANA DEPARTMENT 

OF ENVIRONMENTAL MANAGEMENT 

IN THE MA ITER OF: ) 

ORDER OF THE COMMISSIONER ) 

PURSUANT TO IC 13-14-2-1 ) 

FOR CLIFTY CREEK GENERATING STATION ) 

OF INDIANA ) 

) 

NOTICE AND ORDER OF THE 

COMMISSIONER OF THE 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

This Notice and Order of the Commissioner of the Department of Environmental 

Management ("Order") is issued pursuant to Indiana Code ("IC") 13-14-1-9, IC 13-14-2-1, and 

IC 13-14-2-7. During the Commissioner's review, it was determined that the Petition should be 

granted according to the terms specified below: 

PETITION 

Petitioner is the Indiana Kentucky Electric Corporation's, Clifty Creek Generating Station 

("Petitioner"), a stationary electric power plant with Source I.D. Number 077-00001, located at 

1335 Clifty Hollow Road in Madison, Jefferson County, Indiana, and permitted under the Part 70 

air operating permit program. 

On March 2, 2015, the U.S. District Court for the Northern District of California accepted 

a Consent Decree between the U.S. Environmental Protection Agency ("U.S. EPA"), the Siena 

Club, and the Natural Resources Defense Council to resolve litigation concerning deadlines for 

completing one (1) hour sulfur dioxide ("S02") National Ambient Air Quality Standard 

("NAAQS") designations. Under the Consent Decree, U.S. EPA must designate certain areas as 

nonattainment, attaimnent, or unclassifiable in tluee phases. 

The first Consent Decree phase requires U.S. EPA to designate areas that contain 

stationary sources that had not been announced for retirement as of March 2, 2015 and either 

emitted more than 16,000 tons ofS02 in 2012 or emitted more than 2,600 tons ofS02 and had an 

ammal average emission rate of more than 0.45 pounds of S02 per one million British thermal 

units ("lb/MMBtu") in 2012, according to U.S. EPA's Air Quality Markets Database. 

An Equal Opportunity Ellltlloycr 0 · (i} 1/ecyded Paper A State that Wol'ks 

-
Commissioner's Order No 2016-02 

Page 2 of4 

On March 20, 2015, U.S. EPA identified five (5) sources in Indiana that met the criteria 

for the first phase of the Consent Decree designations. U.S. EPA's list included the Petitioner, 

Clifty Creek Generating Station. 

On September 16, 2015, the Indiana Department of Enviromnental Management 

("IDEM") recommended designation of the area surrounding Clifty Creek Generating Station as 

attainment. The recommendation was based on modeling that included operation of a flue gas 

desulfurization system that became operational in July 2013. 

On January 22,2016, the Petitioner submitted a request to the Commissioner to impose a 

permanent and enforceable S02 mass emission rate on the Petitioner in order to ensure continued 

attaimnent of the S02 NAAQS in the area surrounding Clifty Creek Generating Station. The 

Petitioner proposed a facility-wide SOz mass emission rate of 2,624.5 SOz pounds per hour 

("lb/hr"), 720 operating hour rolling average, applicable to Unit No. I through Unit No. 6, 

combined. 

FINDINGS 

Pursuant to IC 13-14-2-1 (b) and lC 13-14-2-7(1 ), the Commissioner may issue Orders to 

secure compliance with Indiana's environmental statutes and rules, including the ambient air 

quality standard for S02 at 326 Indiana Administrative Code ("lAC") l-3-4(b)(l)(A). 

Based on the foregoing information, IDEM finds the following: 

I. A permanent and enforceable S02 mass emission rate for Clifty Creek Generating Station 

is required in order to model continued attahm1ent of the one (I) hour SOz NAAQS in the area 

surrounding the Petitioner. 

2. Issuance of a Commissioner's Order will ensure the S02 mass emission rate remains 

permanent and enforceable, as required by 42 U.S.C. § 7407(d)(3)(E)(iii). Whereas revising a 

Part 70 Operating Penn it would not create an adequately "permanent" requirement. 

3. Approval by U.S. EPA of the Commissioner's Order as part of the Indiana State 

Implementation Plan ("SIP") will make the Order requirements federally enforceable. Upon 

approval as part of the Indiana SIP, the Order requirements become applicable requirements as 

defined in 326 lAC 2-7-1(6). · 

4. Based on modeling conducted by IDEM, the S02 mass emission rate proposed by the 

Petitioner is adequate to assure continued attai11111ent of the S02 NAAQS. 

ORDER 

I. This Order approves the Petition submitted by the Petitioner according to the terms 

specified below. This Order imposes on the Petitioner the S02 mass emission rate described 

below. 

2. When any of Unit No. l through Unit No. 6, or any combination thereof, is operating, the 

combined S02 mass emission rate shall not exceed 2,624.5 lb/lu, as a 720 operating hour rolling 

average. 
Commissionel''s Ol'det· No 2016-02 

Page 3 of4 

3. The Petitioner shall comply with the 720 operating hour rolling average S02 mass 

emission rate beginning Aprill9, 2016. 

4. As required by 326 lAC 2-7-2(d)(l) and 326 lAC 2-7-5, the Petitioner shall apply to 

incorporate these Order requirements, including reporting and recordlceeping requirements and 

methods to determine compliance, into its Part 70 Operating Permit within ninety (90) days of 

U.S. EPA's approval of the Commissioner's Order as part of the Indiana SIP. 

5. From April 19, 2016 until IDEM issues a Permit incorporating these Order requirements, 

the Petitioner shall comply with the reporting and recordkeeping requirements and methods to 

determine compliance specified in this paragraph. 

a. Repmiing: The Petitioner shall submit to IDEM, on a quarterly basis, a report of 

the facility-wide maximum 720 operating hour S02 rolling average mass emission rate 

for each day that any of Unit No. I through Unit No. 6, or any combination thereof, 

operates, begilllling the second quarter reporting period, which is July 2016. 

b. Recordkeeping: The Petitioner shall maintain records adequate to document 

compliance with the 720 operating hour rolling average S02 mass emission rate. 

c. Method to determine compliance: Compliance shall be determined by a 

continuous emission monitoring system (CEMS) in accordance with 326 lAC 3-5; except 

that data substituted in accordance with 40 Code of Federal Regulations ("CFR") Part 75 

will not be considered in this evaluation. The Petitioner may use the existing cetiified 

CEMS to meet this requirement. 

6. This Order shall apply to and be binding upon the Petitioner, its successors and assigns. 

No change in ownership, cm'jloTate, or partnership status of the Petitioner shall in any way alter 

its status or responsibilities under this Order. 

7. The requirements of this Order supersede any Jess stringent requirements applicable to 

the Petitioner. 

EFFECTIVE DATE OF ORDER 

Pursuant to IC 13-14-2-l(d), IC 4-21.5-3-1, IC 4-21.5-3-5(a)(6), and 40 CFR 51.102, 

IDEM will give notice of this Order to each entity to whom the Order is directed and affected 

neighbors by mailing and to the general public by web publication. 

Pursuant to IC 4-21.5-3-7(a)(3), IC 4-21.5-3-2(e), and IC 4-21.5-3-5, this Order may be 

appealed by filing a Petition for review within eighteen (18) days after the date affected persons 

were given notice of the Order by U.S. mail. Information on petitions for review of this Order 

can be found at IC 4-21.5-3-7. 

Pursuant to IC 4-21.5-3-5(1) and IC 4-21.5-3-2(e), the Order is effective eighteen (18) 

days from mailing of notice unless a Petition for review has been filed before or on the 

eighteenth (18111) day. However, the compliance date for the S02 mass emission rate in this Order 

is Aprill9, 2016. 

Pursuant to 40 CFR 51.103, IDEM will submit this Order to U.S. El' A as a revision to the 

Indiana SIP. Upon approval by the U.S. EPA, this Order will be part of the Indiana SIP. 
Commissioncl''s Ot·dcl' No 2016-02 

Page4 of4 

Persons seekingjudicial review of this Order may do so in accordance with IC 4-21.5-5. 

If you have procedural or scheduling questions regarding yom request for review, you 

may contact the Office of Envirom11ental Adjudication at (317) 232-8591. If you have questions 

regarding this Order, please contact Mark Derf, Office of Air Quality, by telephone at (317) 233-

5682 or email at MDERF@idem.IN.gov. 

Dated at Indianapolis, Indiana this I\,.- day of~ 2016. 

zcarotS:COl11ef 

Commissioner 

Indiana Department of Environmental Management 
Attachment C 

Public Notice and Certificate of Publication for 

the Commissioner's Order for Clifty Creek 

Generating Station addressing the 1-hour S02 

NAAQS 

· Jefferson County 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Michael R. Pence 

Govenwr 

100 N. Senate Avenue • Indianapolis, IN 46204 

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov 

Carol S. Comer 

Commissi011er 

Legal Notice- Public Comment Period and Opportunity for Public Hearing 

State Implementation Plan (SIP) Submittal 

Clifty Creek Generating Station in Jefferson County 

Commissioner's Order No 2016-02 

Notice is hereby given under 40 CFR 51.102 that the Indiana Department of Environmental 

Management ("IDEM") is accepting written comments and providing an opp01tunity for a public 

hearing regarding a revision to the Indiana state implementation plan (SIP) for Indiana Kentucky 

Electric Corporation, Clifty Creek Generating Station, Source I.D. Number 077-00001, located at 

1335 Clifty Hollow Road in Madison, Jefferson County, Indiana. All interested persons are 

invited and will be given reasonable opportunity to express their views concerning the proposed 

revision to the SIP. · 

The pmpose of this notice is to solicit public comment on a proposed revision to the SIP that is 

accomplished by Commissioner's Order No. 2016-02 for Clifty Creek Generating Station. The 

Commissioner's Order imposes a sulfur dioxide emission limit upon Clifty Creek Generating 

Station. This Commissioner's Order will be submitted to the United States Environmental 

Protection Agency ("U.S. EPA") for approval as a revision to the Indiana SIP. 

Any person may submit written comments on the proposed SIP revision. Written comments must 

be postmarked or delivered in person on or before March 17, 2016. 

Any person may request a public hearing on the proposed SIP revision. Requests for a public 

hearing must be submitted on or before March 4, 2016. A hearing has been scheduled for March 

10,2016 at 6:00p.m. eastern time. The hearing will occur at Hanover College Science Center, 

607 Ball Drive, Hanover, Indiana, Building SCC, Room 136. If no timely request for a public 

hearing is received by March 4, 2016, the hearing will be cancelled. Interested parties can check 

the online IDEM calendar at http://www.in.gov/activeca lendar/EventList.aspx or contact Mark 

Derf at the contact information listed below to see if the hearing has been cancelled. Interested 

parties may present oral or written comments at the public hearing, if held. 

Comments and supporting documentation, or a request for a public hearing must be sent in 

writing to Mark Derfvia the information provided below. Please refer to Commissioner's Order 

2016-02 in all correspondence. 

MarkDerf 

Indiana Department of Environmental Management 

Office of Air Quality 

100 North Senate A venue 

Mail Code 61-50 IGCN 1003 

Indianapolis, Indiana 46204 

An Equal Opportunity Employer A State that~ G} Recycled Paper 
Phone: (317) 233-5682 

Fax: (317) 233-2342 

E-rnail: MDERF@idem.IN.gov. 

A copy of the Commissioner's Order is avajlable to any person upon request and is 

· available for public inspection at the following locations: 

Indiana Department of Environmental Management 

Office of Air Quality 

Indiana Government Center-North 

100 North Senate Avenue 

lOth Floor 

Indianapolis, Indiana 46204. 

and 

Indiana Department of Environmental Management 

Southeast Regional Office 

820 Sweet Street 

Brownstown, Indiana 47220 

and 

Madison Jefferson County Public Library 

420 West Main Street 

Madison, Indiana 47250-3796 

The Conunissioner's Order is also available on the IDEM website at: 

http://\vww.in.gov/idem/4686.htm. 

For addltion<~l information, please contact Mark Derf at the contact information provided 

above. 
IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

February 3> 2016 

CERTIFICATE OF PUBLICATION 

This is to certify that the Indiana Department ofEnviromnental Management (IDEM) Notice of 

the oppmiunity for a Public Hearing regarding the following: 

o Commissioner's Order #2016-02 for Clifty Creek Generating Station of Indiana 

was published on IDEM's web site on February 3> 2016. It is expected that it will remain posted 

on the site until at least March 4, 2016. 

The notice in full was available online at the following web address, under "Southeastern". 

http:/ /www.in.gov /idem/54 7 4 .htm 

The notice was also available the same date at the following web address. 

http://www.in.gov/idem/4686.htm 

Web publication of the notice was at the request of Scott Deloney, Branch Chief, Programs 

Branch, Office of Air Quality, IDEM. 

Attachments: 

Copy of web page as published. 

Recycled Paper ® 

By: 

Mike Finklestein 

IDEM Webmaster 

An Equal Opportunity Employer Please Recycle O 
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The Indiana Administrative Code litle 326 Air Pollution Cootrol Division website provides 

the most up-to-date listing of these files. 

Commi:.sioner':: Orders 

A Commissioner's Order is a permanent enforceable order specificaDy authorized by an air 

rule as an alternative to a rule requirement Once issued, a Commissioner's Order becomes 

a condition in an air permit In most cases, a Commissioner's Order will be submitted to 

U.S. EPA for approval as an amendment to Indiana's state implementation plan for the 

Clean Air Act 

• Commissionet"'s Order 12016-02 for Cfdty Creek Generating Station of Indiana: 

• Notice and Order pf the Comrni<sioner of the Denamneot pf Envjroomen!l!l 

Management IPDR !rl 

• legal Notice of Public Hearjnn IPDFl !rl 

Commissioner's Order 12016-01 for A.B. Brown 6enercrting Station of Indiana: 

• Notice and Order of the Commissioner of the Denartment of Environmental 

Management IPDR !rl 

• Legal Notjce of Public Hearing IPDFJ !rl 

Commissionet"'s Order 12015-01 for Abengoa Bioenergy of Indiana: 

• Notice and Order oft he Commissjonerofthe Department of Eoyirpnmenta( 

Management IPDR lrl 

• leo a I Notjce of Public Hearing IPDR !rl 

• Commissioner's Order 12014-01 for Jeftboat UC: 

• Notice and Order of the Commjssioner otthe Qeoaament of Environmental 

Management IPDFI 1<9 

• Legal Notice of Public Hearing IPPA lrl 

Commissionet"'s Order 12009-0AQ-01: 

• Notice of Commissioner's Order IPDFI t9 

Commissionet"'s Order 12008-02 and Variance, Indianapolis Power & ligbtHarding Street Generating Station: 

• Notice, Order, and Variance of the Commissioner of the pepartment of 

Environmental Management IPPR !rl 

• IPL legal Notice of Comment Period and Oooortvnity to Request a Public 

Hearinn !DOC! 8 

• Notice of Variance Decision IPDEJ !rl 

Commissioner's Order 12008-01 and Variance, ALCOA Generating. Inc. -

ALCOA \Vanidt PowerPian1: 
Attachment D 

Clifty Creek Generating Station: 

Modeling Summary 

Jefferson County 
Indiana-Kentucky Electric Corporation- Clifty Creek Generating Station 

Commissioner's Order Modeling Summary 

Background 

Initial modeling, using Clifty Creek's hourly Continuous Emissions Monitoring (CEM) data from 2012-

2014, showed higher modeled S02 concentrations that exceeded the 1-hour S02 National Ambient Air 

Quality Standards (NAAQS). This modeling included emissions before and after Clifty Creek had installed 

their Fluidized Gas Desulfurization {FGD) system. After consultation with U.S. EPA, Indiana remodeled 

the S02 emissions from Clifty Creek after the FGD system became operational to determine the 

attainment designation for the area since emission controls have to be in place by the final S02 area 

designation date of July 2, 2016. The FGD system became fully operational in July 2013. The modeling 

period was set for one and half years from July 2013 through December 2014. This modeling showed 

attainment of the 1-hour S02 standard. Following the submittal of Indiana's recommendations 

addressing the Round 2 consent decree in September of 2015, U.S. EPA pointed out a full three years of 

modeling would be required to make a characterization of air quality in the area and emission limits 

would have to be established that would be federally enforceable and permanent. Since this was the 

case, discussions with Clifty Creek resulted in their request for new S02 emission limits to be established, 

based on three years of meteorological data, per a Commissioner's Order. These limits would be 

federally enforceable and permanent and incorporated into their permit at a later date. 

Modeled Emission Limits and Results 

The FGD system controls S02 emissions from flue gases for all six generating units at Clifty Creek. Units 

1, 2, and 3 are vented into Stack CS013. Units 3, 4, and 5 are vented into Stack CS046. The two stacks 

are contained within one stack shell. Base elevations at Clifty were reevaluated based on construction 

drawings for the facility. These new base elevations were used in this modeling analysis. All other 

modeling parameters were maintained and can be found in Enclosure 3, page 15 of Indiana's Round 2 

Consent Decree modeling submittal, dated September 16, 2015. 

Three S02 emission scenarios were modeled: Scenario 1 was all emissions emitted from Stack CS013, 

Scenario 2 was all emissions emitted from Stack CS046, and Scenario 3 divided the emissions equally 

between Stack CS013 and Stack CS046. The worst case modeling scenario was Scenario 1, represented 

by all S02 emissions being emitted from Stack CS013. Based on this worst case modeling scenario, the 

emission limit was determined to be any of the Units 1 through 6 or any combination can never exceed 

4,670 lbs/hr for the 1-hour S02 averaging period. A summary of the three modeling scenarios S02 

emission and modeling results can be seen below in Table 1. 

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Table 1: Clifty Creel< 1-hour S02 Modeling Scenario Summary and Results 

Modeled 

Emission Rate Concentration Concentration Concentration 

Scenario Group ID lb/hr llg/m' llg/m' 11g/m' 

Scenario 1 CS013 4,670 195.98 

Scenario 2 CS046 4,670 187.93 

Scenario 3 SPLT 2,335.2 192.11 

Determination of Longer Time-Averaged Limits 

Clifty Creek requested a 720 operating hour rolling average emission limit that would demonstrate 

compliance among multiple units and model attainment of the 1-hour S02 standard. The reduction ratio 

used in order to demonstrate an equivalent 720 operating hour rolling average S02 mass emission limit 

based on the modeled 1-hour emission limit is discussed in Clifty Creek's Commissioner Order request 

and the assessment process for developing a longer term averaging period limit, dated January 22, 2016. 

The equivalent 720 operating hour site rolling average S02 emission limit calculated from the 4,670 lb/hr 

1-hour modeled emission limit was determined to be 2,624.Sibs of S02 /hr. 

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