### IN THE MATTER OF APERMIT APPLICATION (AP-6045) FROMFMC WYOMING CORPORATION FORA BEST AVAILABLE RETROFIT TECHNOLOGY (BART) PERMIT FORTHE 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 ifitbelongs within a group ofstationary source categories, was notin operationpriorto August 7, 1962, was in existence onAugust7, 1977, and has the potential to emit 250 tons peryear (tpy) or more ofany visibility impairing air pollutant. Fossil fuel boilers ofmore 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 airpollutants, nitrogen oxides (NOx) and sulfurdioxide (S02), exceed 250 tpy andthereforethe facility is eligible for BART. The Division conducted an analysis ofthe BART permit application and on August 12, 2008, published in the Rock Springs Daily Rocket-Miner a public notice and notice ofpublic hearing ofthe proposed intent to issue BART determinations. Copies ofthe 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 6p.m., in Room 1302 atWestern Wyoming Community College, located at 2500 College Drive inRock Springs, Wyoming. To allow adequate opportunity for comment as specified under the Regional Haze Rule 40 CFR 51.308(i)(2), the public commentperiod was extendedto October20, 2008. The Divisionreceived five (5) comment letters onthe proposed permit during the public commentperiod: 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 ofthe 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 ofComments 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 recentpermitting action and shouldbe consideredthe 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 SNCRvs. LNB. This determination was made independent ofthe gas-fired boiler, as EPA BART guidelines require.FMC Wyoming Corporation Decision Document, BART Permit Application, AP-6045 Page 2 of 12 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 use of chemical reagents and because ofthe low level ofmodeled visibility improvement for Option 2. Option 2 provided a predicted improvement in visibility at BridgerWA 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 pointfor development ofthe milestone required by paragraph (d) (4) (i) ofthis section." Because the Western Regional Air Partnership (WRAP) used 2003 as the starting point for development ofmilestones 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 optionratherthan a baseline configuration. II.2 

### Impacts Analysis in the Proposed Permit is too Limited

- The Wyoming Outdoor Council commented that the Division's analysis ofthe 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 ofcompliance, (2) the energy and non-air quality environmental impacts ofcompliance, (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 controltechnology, 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 ofchemical reagents and because ofthe low level ofmodeled 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 improvementwas 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 oflow 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 (equivalentto 0.35 IblMMBtu) to 290 lb/hr (equivalent to 0.33 IblMMBtu), based on a review ofactual 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/hrwill be set as the BART limitfor each ofthe two coal-frred boilers, as reflected in the final section of this document. The performance/efficiency-based limit willFMC Wyoming Corporation DecisionDocument, BARTPermitApplication, AP-6045 

### Page 3 of 12 remain at 0.35 IblMMBtu (30-day rolling), as described in the response to comment V.1 below. Copies ofthe letters from FMC are attachedto this document. 11.3 Receptors Are Not Adequately Identified

- The Wyoming Outdoor Council commented that the Division's analysis did not adequately identifythe receptors that were usedto 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 ofClass 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 thatwere used for BridgerWilderness Area (W A) andFitzpatrickWA are shown inthe figures below. Figure 

### 1 tors for Brid erWA

BridgerWilderness 684 Receplors USFS Boundary Source:

- FSNalional Coverage file: NRIS· AlP-group Cor;allis.OR AuguSl 27.2003

Source: http://www.nature.nps.gov/airlMapslReceptorsFMC Wyoming Corporation DecisionDocument, BARTPermitApplication, AP-6045 Page 4 of 12 Figure 2 Receptors for FitzpatrickWA

• • • + • .. • • + •

• • • • • • + • • 

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+ • + + + + + FlzpatrickWiderness 316 Receptors USFS BoundarySource:

FS National Coverage file: NRIS· ALP group Corvallis, OR .August 27,2003

Source: http://www.nature.nps.gov/air/MapslReceptors/index.cfmFMC Wyoming Corporation DecisionDocument, BART PermitApplication, AP-6045 Page 5 of 12 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 of0.5 dv should not be used as a threshold belowwhich visibility impacts are deemedto be insignificant. Response

- The Division is comfortable using 0.5 dv as the threshold level to exempt a source from BART orto deem modeled impacts as insignificant. EPA's 

### RegionalHaze Regulations and Guidelinesfor BestAvailable 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 greaterthan 1.0 dv (frompage 39120 ofAppendix Y to 40 CFRpart 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 ofthe EPA document 

### Guidancefor Estimating Natural Visibility Conditions Under the Regional Haze Rule. The EPA guidance document provides annual average values ofnatural 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 thatparticular 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 lightextinction is expressed as follows: dv

## = lOin (bex

### JI0) orbext

## = 10 exp (dv/10) where: bext

### =lightextinction 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 betweentotal light extinction andthe individual components ofthe light extinction is as follows:FMC Wyoming Corporation DecisionDocument, BART PermitApplication, AP-6045 Page 6 of12 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 (appliedto 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 

### W A, 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 convertthe annual average natural background concentrations to values representative ofthe 20% best days natural background. Solving for X provides a value of0.376. Table 1 presents the annual average natural background concentrations, the calculated scaling factor, and the calculatedbackground concentrations for the 20% best days natural background for Bridger WA. Table 1: Calculated Back2round Components for Brid2erWA Annual Average 20% BestDays Natural Natural Background for Calculated Background for the WestRegion Scaling BridgerWA Component (J.l2/m3) Factor (J.lWm3) Ammonium Sulfate 0.12 0.376 0.045 AmmoniumNitrate 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 ofthe geographical proximity and similar annual background visibility for the Bridger WA and FitzpatrickWA, the scaled aerosol concentrations for the two areas were averaged. The 20% best days natural background aerosol concentrations thatwere used for the two Class I areas in question for this analysis are listed in Table 2 below.I C centrations (J.1g/m3) dA avs aura ac**~j!roun** eroso on Fitzpatrick Aerosol WA& Component Bridj!erWA Ammonium Sulfate 0.045 AmmoniumNitrate 0.038 Organic Carbon 0.178 Elemental Carbon 0.008 Soil 0.189 Coarse Mass 1.136 FMC Wyoming Corporation DecisionDocument, BARTPermitApplication, AP-6045 Page 7 of 12 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 atable intheir October 17, 2008 letter. Response

- Summing the 98th percentile modeled visibility impacts for separate facilities is not an accurate portrayal ofcombined 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 inthe EPA's Appendix Y to part 40 CFR 51

- Guidelinesfor BARTDeterminations Under the RegionalHaze Rule, relative to the use ofthe CALPUFF model for BART determinations, "We believe that CALPUFF is an appropriate applicationfor States to usefor theparticularpurposes of this rule, to determine if an individual source is reasonably anticipated to cause or contribute to impairment of visibility in Class I areas, and topredict the degree of visibility improvement which could reasonably be anticipated to resultfrom the use ofretrofit technology at an individual source. We encourage States to use it for thesepurposes." 

## m. Analysis ofComments from the FWS (and NPS): ilL1 SOLControls

- The FWS commented that the Bridger WA is not one ofthe 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 onthe 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 creditfor strategies implemented under 309 when addressing Class 1Areas away from the Colorado Plateau (51.309(g)(4)(i»).FMC Wyoming Corporation DecisionDocument, BARTPermit Application, AP-6045 Page 8 of12 T bl 3 WRAP M d 

## r fi S 

### If: t E f f a e : o e ID2 or u a e x IDC Ion Visibility - Sulfate Extinction Onh (Mm-1) 20% WorstVisibilityDays 20% BestVisibilityDays (Monthly Avera2e) (MonthlyAveraf!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 (BridgerW. andFitzpatrickW.) North Absaroka, WY (NorthAbsarokaW. and 4.8 4.5 1.1 1.1 Washakie W.) Yellowstone, WY (Yellowstone NP, GrandTeton 4.3 3.9 1.6 1.4 NP, andTetonW.) Badlands, SD 17.8 16.0 3.5 3.1 Wind Cave, SD 13.0 12.1 2.7 2.5 MountZirkel, CO 4.6 4.1 1.4 1.3 (Mt. ZirkelW. andRawahW.) 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 andArches 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 PreliminaryReasonable 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 ofPerceptibility

- The FWS commented· that athreshold ofperceptibility should notbe usedto interpretvisibility modeling orto exclude a given control strategy from consideration as BART. The FWS stated that the Division's misinterpretation ofthe 0.5 dv threshold led to the Division proposing only combustion controls ratherthan SNCR. Response

- The Division did state thatthe 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 isFMC Wyoming Corporation Decision Document, BARTPermitApplication, AP-6045 Page 9 of 12 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 ofonly 0.06 dv, based on the modeled 98th percentile results. For Fitzpatrick, the predicted improvementwas at most 0.04 dv. The Division concluded, after consideration ofcost and other factors, that the small differences in modeled visibility did not warrant the requirement ofa greater level ofcontrol. IlIA Gas-Fired Boiler

- The FWS commented thatthere is no exemption in the BART Guidelines for the gas-firedboiler andthat aBARTNOxdetermination should be made forthat source. Response

- The gas-fired boiler at the Westvaco Facility emits negligible quantities of the visibility-reducing pollutants S02 and PMlO• Emissions ofNOx from the gas-fired boiler are an order ofmagnitude lower than the emissions from the two larger boilers at the facility. The low level ofemissions ofvisibility-reducing pollutants, coupled with the baseline visibility modeling thatyielded a maximum 98th percentile impact ofonly 0.05 dv at BridgerWA, ledthe Divisionto 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 ofComments from EPA Region 8: IV.l NO!..-BART Control Option Selection

- EPA Region 8 commented that greater control ofNOx 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 Divisionto consider SNCR as BART. Response

- See response to Wyoming Outdoor Council comments II.l and II.2 and FWS CommentIlI.3. IV.2 SOLControl

- EPA Region 8 commented that the Division's Regional Haze SIP under the Western Backstop SulfurDioxide Trading Program must demonstrate greaterreasonable 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 forthe gas-firedboiler and that a BART analysis should be conducted forthat source.. Response

- See response to FWS CommentIlIA.FMC Wyoming Corporation Decision Document, BART PermitApplication, AP-6045 

### Page 10 of12 IVA Class I 

### receptor locations

- EPA Region 8 commented that the receptors used to model Class I areas were not adequately documented andjustified. Response

- Seeresponse to Wyoming Outdoor Council CommentII.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 ofcontrol associated withthatpermitting action shouldbe consideredthe baseline condition for BART. Response

- Seeresponse to Wyoming Outdoor Council CommentILl. IV.6 RBLC Review

- 'EPA Region 8 commented thatthe 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 ofSignificant 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 controltechnologies identifiedbyFMC. IV.7 BART Permit Conditions

- EPA Region 8 commented that if S02 controls are installed at the facility, the BARTpermit shouldinclude limits for S02. Response

- Wyoming is a §309 state andwill participate inthe Western Backstop SulfurDioxide Trading Program should itbe 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 subjectto BART to install, operate, and maintain additional control technology to meet an established emission limit on a continuous basis. Because ofPermit 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 orrequirements to install S02controls. 

# v. Analysis ofComments 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 maybe inflatedwhen steam loads decrease. Response

- The Division agrees that emission limits set on the basis of IblMMBtu may be difficultto meet when steam loads fluctuate, and therefore emission limits based on lb/hr will be setfor the facility. The Divisionwill also setperformance/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 ofemission limits. Regional Haze SIPs produced by Western states also rely on emission limits based on IblMMBtu. Lastly, the Division believes that limits basedFMC Wyoming Corporation DecisionDocument, BART PermitApplication, AP-6045 Page 11 of 12
on IblMMBtu promote diligence on the part ofoperators to run their sources in the most efficient manner. VI. Decision: Onthe basis ofcomments received during the public commentperiod, 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 ofthe conditions proposed in the Division's analysis will be included in the permitwiththe following changes and additions (inbold): 5. Effective upon issuance ofpermit, emissions from boilerNS-IA shall not exceedthe 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 ofpermit, emissions from boilerNS-IB shall not exceedthe 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 laterthan 90 days afterpermit issuance and shall consist ofthe following: i. Coal-fired Boilers (NS-IA, NS-lB): NQy Emissions

- Compliance withthe NOx 30-dayrolling 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 permitMD-5723 may be submitted to satisfy the testing required by this condition. 8. Priorto any perfarmaneetesting required bythis permit, atestprotocol shall be submittedto the Division for approval, at least30 days priorto testing. Notification should be provided to the Division at least 15 days priorto anytesting. Results ofthe tests shall be submittedto this office within 45 days ofcompletingthe tests.FMC Wyoming Corporation Decision Document, BART Permit Application, AP-6045 Page 12 of 12


### 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, ofthe WAQSR. 10. 

### Testing forPM shall be conducted annually, or more frequently as specified by the Administrator, following 40 CFR 60.46 and EPA Reference TestMethods 1-4 and 5. Testing required by the Chapter 6, Section 3, OperatingPermitorpermitMD-5723 may be submitted to satisfythe testing required bythis condition.

Datedthis _17th

_ day ofJuly, 2009.



### J n V. Corra irector Wyoming Department ofEnvironmental Quality DavidA. Fmley Administrator Wyoming Air Quality Division