MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

September 4, 2014

PERMIT TO INSTALL

27-13A

ISSUED TO

DTE Energy

LOCATED AT

3500 Front Street

Monroe, Michigan

IN THE COUNTY OF

Monroe

STATE REGISTRATION NUMBER

B2816

The Air Quality Division has approved this Permit to Install, pursuant to the delegation of authority 

from the Michigan Department of Environmental Quality. This permit is hereby issued in 

accordance with and subject to Section 5505(1) of Article II, Chapter I, Part 55, Air Pollution 

Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. 

Pursuant to Air Pollution Control Rule 336.1201(1), this permit constitutes the permittee’s authority 

to install the identified emission unit(s) in accordance with all administrative rules of the Department 

and the attached conditions. Operation of the emission unit(s) identified in this Permit to Install is 

allowed pursuant to Rule 336.1201(6).

DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203:

August 19, 2014

DATE PERMIT TO INSTALL APPROVED:

September 4, 2014

SIGNATURE:

DATE PERMIT VOIDED: SIGNATURE:

DATE PERMIT REVOKED: SIGNATURE:
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 1 of 103

PERMIT TO INSTALL

Table of Contents

Section Page

Alphabetical Listing of Common Abbreviations / Acronyms ......................................................................... 2

General Conditions ....................................................................................................................................... 3

Special Conditions ........................................................................................................................................ 5

Emission Unit Summary Table...................................................................................................................... 5

Special Conditions for EU-UNIT1-S1............................................................................................................ 8

Special Conditions for EU-UNIT2-S1.......................................................................................................... 18

Special Conditions for EU-UNIT3-S1.......................................................................................................... 28

Special Conditions for EU-UNIT4-S1.......................................................................................................... 37

Emission Unit EU-WFGD-QP1.................................................................................................................... 46

Emission Unit EU-WFGD-QP2.................................................................................................................... 49

Emission Unit EU-WFGD-QP3.................................................................................................................... 52

Emission Unit EU-WFGD-QP4.................................................................................................................... 55

Special Conditions for EU-CASCADES-S1 ................................................................................................ 58

Special Conditions for EU-TRANSFERHS-S1............................................................................................ 62

Special Conditions for EU-DUMPERHS-S1................................................................................................ 67

Special Conditions for EU-COALUNLOAD-S1 ........................................................................................... 70

Special Conditions for EU-CRUSHERHS-S1 ............................................................................................. 72

Special Conditions for EU-REFHS&BL-S1 ................................................................................................. 75

Special Conditions for EU-PETCOKE-S1 ................................................................................................... 78

Special Conditions for EU-LIMESTONE-S1 ............................................................................................... 81

Special Conditions for EU-GYPSUMHAND-S1 .......................................................................................... 84

Special Conditions for EU-HYDRATEDLIME-S1........................................................................................ 87

Flexible Group Summary Table .................................................................................................................. 90

Special Conditions for FG-ProjectPC1-4 .................................................................................................... 91

Special Conditions for FGAUXBOILERS-S1 .............................................................................................. 94

Special Conditions for FGPEAKERS-S2 .................................................................................................... 96

Special Conditions for FGUNITS1&2TEMP................................................................................................ 98

Appendices ............................................................................................................................................... 101
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 2 of 103

Common Abbreviations / Acronyms

Common Acronyms Pollutant / Measurement Abbreviations

AQD Air Quality Division BTU British Thermal Unit

BACT Best Available Control Technology °C Degrees Celsius

CAA Clean Air Act CO Carbon Monoxide

CEM Continuous Emission Monitoring dscf Dry standard cubic foot

CFR Code of Federal Regulations dscm Dry standard cubic meter

CO2e Carbon Dioxide Equivalent °F Degrees Fahrenheit

COM Continuous Opacity Monitoring gr Grains

EPA Environmental Protection Agency Hg Mercury 

EU Emission Unit hr Hour 

FG Flexible Group H2S Hydrogen Sulfide

GACS Gallon of Applied Coating Solids hp Horsepower 

GC General Condition lb Pound

GHGs Greenhouse Gases kW Kilowatt

HAP Hazardous Air Pollutant m Meter

HVLP High Volume Low Pressure * mg Milligram 

ID Identification mm Millimeter

LAER Lowest Achievable Emission Rate MM Million

MACT Maximum Achievable Control 

Technology MW Megawatts

MAERS Michigan Air Emissions Reporting 

System ng Nanogram

MAP Malfunction Abatement Plan NOx Oxides of Nitrogen 

MDEQ Michigan Department of Environmental 

Quality (Department) PM Particulate Matter 

MSDS Material Safety Data Sheet PM10 PM with aerodynamic diameter ≤10 microns 

NESHAP National Emission Standard for 

Hazardous Air Pollutants PM2.5 PM with aerodynamic diameter ≤ 2.5 microns

NSPS New Source Performance Standards pph Pounds per hour

NSR New Source Review ppm Parts per million

PS Performance Specification ppmv Parts per million by volume 

PSD Prevention of Significant Deterioration ppmw Parts per million by weight 

PTE Permanent Total Enclosure psia Pounds per square inch absolute

PTI Permit to Install psig Pounds per square inch gauge 

RACT Reasonably Available Control 

Technology scf Standard cubic feet

ROP Renewable Operating Permit sec Seconds 

SC Special Condition SO2 Sulfur Dioxide 

SCR Selective Catalytic Reduction THC Total Hydrocarbons

SRN State Registration Number tpy Tons per year

TAC Toxic Air Contaminant μg Microgram 

TEQ Toxicity Equivalence Quotient VOC Volatile Organic Compound

VE Visible Emissions yr Year 

* For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not 

exceed ten (10) pounds per square inch gauge (psig). 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 3 of 103

GENERAL CONDITIONS

1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or modified, 

unless a Permit to Install authorizing such action is issued by the Department, except to the extent such 

action is exempt from the Permit to Install requirements by any applicable rule. (R 336.1201(1))

2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which this 

permit has been approved has not commenced within 18 months, or has been interrupted for 18 months, 

this permit shall become void unless otherwise authorized by the Department. Furthermore, the permittee 

or the designated authorized agent shall notify the Department via the Supervisor, Permit Section, Air 

Quality Division, Michigan Department of Environmental Quality, P.O. Box 30260, Lansing, Michigan 48909-

7760, if it is decided not to pursue the installation, construction, reconstruction, relocation, or modification 

of the equipment allowed by this Permit to Install. (R 336.1201(4))

3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is 

not subject to the Renewable Operating Permit program requirements pursuant to R 336.1210, operation 

of the process or process equipment is allowed by this permit if the equipment performs in accordance with 

the terms and conditions of this Permit to Install. (R 336.1201(6)(b))

4. The Department may, after notice and opportunity for a hearing, revoke this Permit to Install if evidence 

indicates the process or process equipment is not performing in accordance with the terms and conditions 

of this permit or is violating the Department’s rules or the Clean Air Act. (R 336.1201(8), Section 5510 of 

Act 451, PA 1994)

5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or 

hereafter owns or operates the process or process equipment at the location authorized by this Permit to 

Install. If the new owner or operator submits a written request to the Department pursuant to R 336.1219 

and the Department approves the request, this permit will be amended to reflect the change of ownership 

or operational control. The request must include all of the information required by subrules (1)(a), (b), and 

(c) of R 336.1219 and shall be sent to the District Supervisor, Air Quality Division, Michigan Department of 

Environmental Quality. (R 336.1219)

6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious 

effects to human health or safety, animal life, plant life of significant economic value, or property, or which 

causes unreasonable interference with the comfortable enjoyment of life and property. (R 336.1901)

7. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results 

in emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any 

applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in 

excess of an applicable standard or limitation, as required in Rule 912, to the Department. The notice shall 

be provided not later than two business days after start-up, shutdown, or discovery of the abnormal condition 

or malfunction. Written reports, if required, must be filed with the Department within 10 days after the startup or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been corrected, 

or within 30 days of discovery of the abnormal condition or malfunction, whichever is first. The written 

reports shall include all of the information required in Rule 912(5). (R 336.1912)

8. Approval of this permit does not exempt the permittee from complying with any future applicable 

requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal Clean 

Air Act.

9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law.

10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as amended 

and the rules promulgated thereunder. 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 4 of 103

11. Except as provided in subrules (2) and (3) or unless the special conditions of the Permit to Install include 

an alternate opacity limit established pursuant to subrule (4) of R 336.1301, the permittee shall not cause 

or permit to be discharged into the outer air from a process or process equipment a visible emission of 

density greater than the most stringent of the following. The grading of visible emissions shall be determined 

in accordance with R 336.1303. (R 336.1301) 

a) A six-minute average of 20 percent opacity, except for one six-minute average per hour of not more 

than 27 percent opacity.

b) A visible emission limit specified by an applicable federal new source performance standard.

c) A visible emission limit specified as a condition of this Permit to Install.

12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as 

to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in 

Priority I and II areas requires the use of material handling methods specified in R 336.1370(2). 

(R 336.1370)

13. The Department may require the permittee to conduct acceptable performance tests, at the permittee’s 

expense, in accordance with R 336.2001 and R 336.2003, under any of the conditions listed in R 336.2001. 

(R 336.2001)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 5 of 103

SPECIAL CONDITIONS

EMISSION UNIT SUMMARY TABLE

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID Emission Unit Description

(Process Equipment & Control Devices)

Installation Date / 

Modification Date Flexible Group ID

EU-UNIT1-S1 Boiler Unit No. 1 - Coal-fired boiler nominally 

rated 817 MW (gross) with low-NOx burners, 

Reduced Emissions Fuel (REF) sorbent 

system, sulfur trioxide (SO3) and ammonia flue 

gas conditioning systems, selective catalytic 

reduction (SCR), dry wire electrostatic 

precipitators (ESP), and (to be installed) wet 

flue gas desulfurization (FGD). Fires No. 2 fuel 

oil for boiler start-up.

01-01-1968 /

03-03-2006 / 

12-21-2010

FG-ProjectPC1-4

EU-UNIT2-S1 Boiler Unit No. 2 - Coal-fired boiler nominally 

rated 823 MW (gross) with low-NOx burners, 

REF sorbent system, sulfur trioxide (SO3) and 

ammonia flue gas conditioning systems, (to be 

installed) selective catalytic reduction (SCR), 

dry wire electrostatic precipitators (ESP), and 

(to be installed) wet flue gas desulfurization 

(FGD). Fires No. 2 fuel oil for boiler start-up.

01-01-1969 /

03-23-2005 / 

12-21-2010

FG-ProjectPC1-4

EU-UNIT3-S1 Boiler Unit No. 3 - Coal-fired boiler nominally 

rated 823 MW (gross) with low-NOx burners, 

REF sorbent system, sulfur trioxide (SO3) and 

ammonia flue gas conditioning systems, 

selective catalytic reduction (SCR), dry wire 

electrostatic precipitators (ESP), and wet flue 

gas desulfurization (FGD). Fires No. 2 fuel oil 

for boiler start-up.

06-01-1969 /

8-28-2006 /

08-02-2010

FG-ProjectPC1-4

EU-UNIT4-S1 Boiler Unit No. 4 - Coal-fired boiler nominally 

rated 817 MW (gross) with low-NOx burners, 

REF sorbent system, sulfur trioxide (SO3) and 

ammonia flue gas conditioning systems, 

selective catalytic reduction (SCR), dry wire 

electrostatic precipitators (ESP), and wet flue 

gas desulfurization (FGD). Fires No. 2 fuel oil 

for boiler start-up.

06-01-1969 /

11-15-2005 /

08-02-2010

FG-ProjectPC1-4

EU-WFGD-QP1 252 hp diesel fuel-fired FGD quench pump and 

a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 3 stack.

11-21-2006 / 

08-02-2010

FG-ProjectPC1-4

EU-WFGD-QP2 252 hp diesel fuel-fired FGD quench pump and 

a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 4 stack.

11-21-2006 / 

08-02-2010

FG-ProjectPC1-4

EU-WFGD-QP3 252 hp diesel fuel-fired FGD quench pump and 

a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 1 stack.

TBD FG-ProjectPC1-4

EU-WFGD-QP4 252 hp diesel fuel-fired FGD quench pump and 

a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 2 stack.

TBD FG-ProjectPC1-4
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 6 of 103

Emission Unit ID Emission Unit Description

(Process Equipment & Control Devices)

Installation Date / 

Modification Date Flexible Group ID

EU-CASCADES-S1 This emission unit represents coal handling 

activity in the Cascades room. Coal handling 

activity emissions are limited by an enclosure, 

wet dust suppression, and baghouse dust 

collectors.

01-01-1968 /

11-01-1980 / 

08-02-2010

FG-ProjectPC1-4

EU-TRANSFERHS-S1 This emission unit represents coal handling 

activity in the Transfer House. Coal handling 

activity emissions are limited by an enclosure, 

wet dust suppression, and baghouse dust 

collectors. 

01-01-1968 /

11-01-1980 / 

08-02-2010

FG-ProjectPC1-4

EU-DUMPERHS-S1 This emission unit represents coal handling 

activity in the Dumper House. Coal handling 

activity emissions are limited by an enclosure, 

wet dust suppression, and baghouse dust 

collectors.

01-01-1968 /

11-01-1980 / 

08-02-2010

FG-ProjectPC1-4

EU-COALUNLOAD-S1 This emission unit represents the coal 

unloading activities from Great Lakes ships and 

includes storage and pile maintenance. Coal 

handling activity emissions are limited by 

enclosures and wet dust suppression methods.

01-01-1968 /

11-01-1980 /

08-02-2010

FG-ProjectPC1-4

EU-CRUSHERHS-S1 This emission unit represents coal handling 

activity in the Crusher House. Coal handling 

activity emissions are limited by an enclosure 

and baghouse dust collectors.

01-01-1968 /

1-07-2005 / 

08-02-2010

FG-ProjectPC1-4

EU-REFHS&BL-S1 This emission unit represents coal and sorbent 

handling activity in the REF Transfer House 

and Refined Coal Plant Building including an 

8,500 gallon Mersorb storage tank, a 750 ton SSorb solid storage silo, associated conveyors, 

and any trucking and unloading activities. 

Sorbent handling activity inside the Refined 

Coal Plant Building includes two pug mills, two 

day bins, and mixing operations. Coal and 

sorbent handling activity emissions are limited 

by enclosures, baghouse dust collectors, wet 

dust suppression methods, or bin vent filters.

06-13-2011 NA

EU-PETCOKE-S1 This emission unit represents petroleum coke 

handling activity, including roadway traffic and 

pile maintenance. Emissions are limited by 

partial enclosures, including a portable wind 

screen, and wet dust suppression.

TBD FG-ProjectPC1-4

EU-LIMESTONE-S1 This emission unit represents limestone 

handling activities and includes the ship 

unloading process, storage and pile 

maintenance, and reclaim activities – including 

any trucking activities, and the Prep building. 

Limestone handling activity emissions are 

limited by enclosures, wet dust suppression 

methods, or bin vent filters.

02-01-2008 / 

08-02-2010 / 

12-21-2010

FG-ProjectPC1-4
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 7 of 103

Emission Unit ID Emission Unit Description

(Process Equipment & Control Devices)

Installation Date / 

Modification Date Flexible Group ID

EU-GYPSUMHAND-S1 This emission unit represents gypsum handling 

activity in the gypsum dewatering building and 

the gypsum storage and loading building. 

Gypsum handling activity emissions are limited 

by a building enclosure. 

02-01-2008 / 

08-02-2010 / 

12-21-2010

FG-ProjectPC1-4

EU-HYDRATEDLIME-S1 Storage and handling of hydrated lime. 

Hydrated lime is delivered via truck and is 

stored in a silo. 

02-01-2008 / 

08-02-2010 / 

12-21-2010

FG-ProjectPC1-4

EU-SOUTHAUX-S1 South Auxiliary Boiler 01-01-1968 / 

08-02-2010 / 

12-21-2010

FGAUXBOILERS-S1

EU-NORTHAUX-S1 North Auxiliary Boiler 01-01-1968 / 

08-02-2010 / 

12-21-2010

FGAUXBOILERS-S1

EU-DIESEL11-1-S2 Diesel Generator Peaking Unit DG 11-1 – 3,960 

hp (2.75 MW), 2-cycle compression ignition 

internal combustion engine

10-24-1969 / 

08-02-2010 / 

12-21-2010 /

3-9-2012

FGPEAKERS-S2

EU-DIESEL11-2-S2 Diesel Generator Peaking Unit DG 11-2 – 3,960 

hp (2.75 MW), 2-cycle compression ignition 

internal combustion engine

10-24-1969 / 

08-02-2010 / 

12-21-2010 /

3-9-2012

FGPEAKERS-S2

EU-DIESEL11-3-S2 Diesel Generator Peaking Unit DG 11-3 – 3,960 

hp (2.75 MW), 2-cycle compression ignition 

internal combustion engine

10-24-1969 / 

08-02-2010 /

12-21-2010 /

3-9-2012

FGPEAKERS-S2

EU-DIESEL11-4-S2 Diesel Generator Peaking Unit DG 11-4 – 3,960 

hp (2.75 MW), 2-cycle compression ignition 

internal combustion engine

10-24-1969 / 

08-02-2010 / 

12-21-2010 /

3-9-2012

FGPEAKERS-S2

EU-DIESEL11-5-S2 Diesel Generator Peaking Unit DG 11-5 –

3,960 hp (2.75 MW), 2-cycle compression 

ignition internal combustion engine

10-24-1969 / 

08-02-2010 / 

12-21-2010 /

3-9-2012

FGPEAKERS-S2

Changes to the equipment described in this table are subject to the requirements of R 336.1201, except as allowed 

by R 336.1278 to R 336.1290.
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 8 of 103

The following conditions apply to: EU-UNIT1-S1

DESCRIPTION: Coal-fired cell burner boiler nominally rated at a maximum heat input of 7,624 MMBtu per hour 

on a fuel input basis. The boiler serves a steam turbine electric generator nominally rated at 817 MW (gross). 

Fires No. 2 fuel oil for boiler start-up and flame stabilization.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, overfire air, REF sorbent system, SO3 and ammonia 

flue gas conditioning systems, selective catalytic reduction (SCR), dry wire electrostatic precipitators (ESP), and 

(to be installed) wet flue gas desulfurization (FGD). 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent* 6-minute average 

except one 

6-minute average 

per hour of not 

more than 

20 percent

EU-UNIT1-S1 SC V.1, 

SC VI.2

R 336.1301(1)(c), R 336.2810,

40 CFR 52.21(j) 

2. PM 0.011 lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time or 24-hr 

rolling average as 

determined each 

hour the boiler 

operates

EU-UNIT1-S1 SC V.1,

SC VI.3

R 336.1224,

R 336.1225,

R 336.1331(1)(c),

R 336.2810,

40 CFR 52.21(j) 

3. PM 0.12 pounds per 

1,000 pounds of 

exhaust gases, 

on a wet basis, 

corrected to 50% 

excess air**

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.10 R 336.1331(1)

4. PM10 0.024 lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.2 R 336.2810,

40 CFR 52.21(j)

5. PM10 183.0 pph* Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.2 R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

6. SO2 0.107 lb/MMBtu

heat input*

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT1-S1 SC VI.4,

SC VI.8

R 336.1401,

R 336.2810,

40 CFR 52.21(j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

7. SO2 1.6 lb/MMBtu

heat input**

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT1-S1 SC VI.4,

SC VI.8

R 336.1401
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 9 of 103

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

8. SO2 815.8 pph* 24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT1-S1 SC VI.4,

SC VI.6,

SC VI.8

R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

9. NOx 0.08 lb/MMBtu

heat input*

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT1-S1 SC VI.4,

SC VI.9

R 336.2810,

40 CFR 52.21(j)

10. NOx 222.6 

ton/month*

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT1-S1 SC VI.4,

SC VI.6,

SC VI.9

R 336.2803, R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

11. CO 0.15 lb/MMBtu 

heat input 

excluding 

periods of startup and 

shutdown*

30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT1-S1 SC VI.4,

SC VI.10

R 336.2810,

40 CFR 52.21(j)

12. CO 27,446.4 lb/day* 30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT1-S1 SC VI.4,

SC VI.6,

SC VI.10

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

13. VOC 0.0034 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.4 R 336.1122(f),

R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

14. VOC 25.9 pph* Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.4 R 336.1122(f), R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

15. Lead (Pb) 1.69 x 10-5

lb/MMBtu heat 

input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.5 R 336.1901,

R 336.2810,

40 CFR 52.21(j)

16. Lead (Pb) 0.13 pph* Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.5 R 336.1901,

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

17. Sulfuric 

acid mist 

(H2SO4)

0.005 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.6 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

18. Hydrogen 

Chloride 

(HCl)

0.0024 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.7 R 336.1224,

R 336.1225

19. Hydrogen 

Fluoride 

(HF)

0.00023 

lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.8 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 10 of 103

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

20. Mercury 

(Hg)

0.02 lb/GW-hr 

gross energy 

output*

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT1-S1 SC V.9,

SC VI.5,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

21. Mercury 

(Hg)

143.1 lb/year* 12-month rolling 

time period as 

determined at the 

end of each 

calendar month

EU-UNIT1-S1 SC V.9,

SC VI.5,

SC VI.6,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

22. Arsenic

(As)

6.3 x 10-6

lb/MMBtu heat 

input*

Test protocol will 

specify averaging 

time.

EU-UNIT1-S1 SC V.5 R 336.1224,

R 336.1225(2)

* These emission limits apply after start-up and shakedown of the wet FGD system is completed.

** These emission limits apply until start-up and shakedown of the wet FGD system is completed.

II. MATERIAL LIMITS

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. Startup is defined in SC III.2. (R 336.1205(1)(a) and (1)(b), R 336.2810, 40 CFR 52.21(j))

2. The permittee shall only combust bituminous coal, subbituminous coal, and up to 23,652 tons per calendar 

month of petroleum coke in EU-UNIT1-S1. Petroleum coke shall not be combusted in EU-UNIT1-S1 until 

after start-up and shakedown of the wet FGD system is completed. (R 336.1205(1)(a) and (1)(b), 

R 336.1224, R 336.1225, R 336.1702(a), R 336.1901, R 336.2810, 40 CFR 52.21(j))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-UNIT1-S1 unless a malfunction abatement plan (MAP) as described in 

Rule 911(2), for operation of the process and emission control equipment, is implemented and maintained. If 

at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of a 

malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1224, R 336.1225, R 336.1331, R 336.1702(a), R 336.1910, R 336.1911, R 336.1912, 

R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

2. Start-up is defined as the period of time from initiation of combustion firing until the unit reaches steady state 

operation and the SCR is brought into service upon the flue gas reaching a minimum operating temperature 

for the SCR of 650°F. Shutdown is defined as that period of time beginning when the flue gas temperature 

entering the SCR drops below the operating temperature of the SCR system. (R 336.1912, R 336.2810, 

40 CFR 52.21(j))

3. The permittee shall not operate EU-UNIT1-S1 unless an acceptable plan that describes how emissions will be 

minimized during all start-ups and shutdowns has been submitted to the AQD District Supervisor. The plan 

shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard 

industry practices. (R 336.1911, R 336.1912, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21(c), (d), and (j))
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IV. DESIGN/EQUIPMENT PARAMETERS

1. The maximum design heat input rate of EU-UNIT1-S1 shall not exceed 7,624 million British thermal units per 

hour (MMBtu/hr) on a fuel heat input basis. (R 336.1205(1)(a) and (1)(b))

2. The permittee shall not operate EU-UNIT1-S1 unless the low-NOx burners, overfire air, SO3 and ammonia 

flue gas conditioning systems, SCR system, ESP, and wet FGD system (after start-up and shakedown) are 

installed, maintained, and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-UNIT1-S1 as required in

SC III.1. (R 336.1224, R 336.1225, R 336.1901, R 336.1910, R 336.2810, 40 CFR 52.21(j))

3. The permittee shall not operate EU-UNIT1-S1 unless the REF sorbent system is installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT1-S1 as required in SC III.1. (R 336.1225, 

R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. Within 180 days after start-up and shakedown of the wet FGD system, verification of visible emissions and 

PM emission rates from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every five years, thereafter. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.2001, R 336.2003, 

R 336.2004, R 336.2810, 40 CFR 52.21(j))

2. Within 180 days after start-up and shakedown of the wet FGD system, verification of PM10 emission rates 

from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.2803, R 

336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

3. Within 180 days after start-up and shakedown of the wet FGD system, verification of PM2.5 emission rates 

from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every calendar year for the next ten years of operation 

after the modification. No less than 60 days prior to testing, the permittee shall submit a complete test plan 

to the AQD Technical Programs Unit and District Office. The final plan must be approved by the AQD prior 

to testing. Verification of emission rates includes the submittal of a complete report of the test results to the 

AQD Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.2001, 

R 336.2003, R 336.2004, R 336.2902(2)(c), 40 CFR 51 (Appendix S))

4. Within 180 days after start-up and shakedown of the wet FGD system, verification of VOC emission rates 

from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1224, R 336.1702(a), R 336.2001, R 336.2003, 

R 336.2004, R 336.2810, 40 CFR 52.21(j))
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5. Within 180 days after start-up and shakedown of the wet FGD system, verification of Pb and As emission 

rates from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1225, R 336.1901, R 336.2001, R 336.2003, 

R 336.2004, R 336.2804, R 336.2810, 40 CFR 52.21(d) and (j))

6. Within 180 days after start-up and shakedown of the wet FGD system, verification of H2SO4 emission rates 

from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1224, R 336.2001, R 336.2003, R 336.2004, 

R 336.2810, 40 CFR 52.21(j))

7. Within 180 days after start-up and shakedown of the wet FGD system, verification of HCl emission rates from 

EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be required. 

The permittee must complete the test once every five years, thereafter. No less than 60 days prior to testing, 

the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The 

final plan must be approved by the AQD prior to testing. Verification of emission rates includes the submittal 

of a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days 

following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, R 336.2003, R 336.2004)

8. Within 180 days after start-up and shakedown of the wet FGD system, verification of HF emission rates from 

EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be required. 

The permittee must complete the test once every five years, thereafter. No less than 60 days prior to testing, 

the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The 

final plan must be approved by the AQD prior to testing. Verification of emission rates includes the submittal 

of a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days 

following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, R 336.2003, R 336.2004, 

R 336.2810, 40 CFR 52.21(j))

9. Within 180 days after start-up and shakedown of the wet FGD system, verification of total Hg emission rates 

from EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD within 60 days following the last date of the 

test.1 (R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2001, R 336.2003, R 336.2004)

10. Prior to the start-up and shakedown of the wet FGD system, verification of PM emission rates from 

EU-UNIT1-S1 by testing at owner’s expense, in accordance with Department requirements, will be required. 

The permittee must complete the test once every five years, or more frequently upon request of AQD. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days 

following the last date of the test. (R 336.1205(1)(a) and (1)(b), R 336.1213(3), R 336.2001, R 336.2003, 

R 336.2004)
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VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1224, R 336.1225, 

R 336.1702, R 336.1901) 

2. Within 180 days after start-up and shakedown of the wet FGD system, the permittee shall conduct visible 

emission observations using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)), or an alternate 

method approved by the AQD, on a calendar day basis each day the boiler operates or the permittee shall 

install, calibrate, maintain and operate in a satisfactory manner a COM system to monitor and record the 

visible emissions before the wet FGD from EU-UNIT1-S1 on a continuous basis. The permittee shall install 

and operate the COM system to meet the timelines, requirements and reporting detailed in Appendix A and 

correlate pre-wet FGD visible emissions to post-wet FGD visible emissions on an annual basis. If the 

permittee installs a PM CEM per SC VI.3.c., this special condition is void. (R 336.1301, R 336.2810, 

40 CFR 52.21(j))

3. Within 180 days after start-up and shakedown of the wet FGD system and prior to the implementation of a 

continuous monitoring system as specified in (a), (b) or (c) below, the permittee shall perform PM emission 

testing as specified in SC V.1 on a quarterly basis for the next 12-months. If the PM emission rates are less 

than 50% of the emission limit specified in SC I.2 for four consecutive quarters, the permittee may reduce the 

PM emission testing to a semi-annual basis for the next 12-months and then an annual basis until an 

acceptable continuous monitoring system as specified in (a), (b), or (c) is implemented. If PM emissions are 

greater than 50% of the emission limit specified in SC I.2 for any single semi-annual or annual test, then 

quarterly testing shall be required.

The permittee shall implement an acceptable continuous monitoring system as specified in (a), (b), or (c) no 

later than January 1, 2015.

 

a. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a Continuous 

Parameter Monitoring System (CPMS) per the requirements of an approved Performance Specification 

or an alternative method approved by the AQD for PM. The permittee shall also meet the following 

requirements:

i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

CPMS is out of control based upon the results of quality assurance tests conducted in accordance 

with a Performance Specification. This alternative monitoring shall, unless alternate methods and 

frequencies are approved in writing by the AQD District Supervisor, require verification of the 

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT1-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 30 minutes 

until emissions are no longer visible or until emissions have been observed for more than two 

hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

b. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a PM Predictive 

Emission Monitoring System (PEMS) per the requirements of Performance Specification 16 (Appendix B 

to Part 60) or an alternative method approved by the AQD. The permittee shall also meet the following 

requirements:
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i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PEMS is out of control based upon the results of quality assurance tests conducted in accordance 

with Performance Specification 16 of 40 CFR Part 60 (Appendix B). This alternative monitoring shall, 

unless alternate methods and frequencies are approved in writing by the AQD District Supervisor, 

require verification of the presence of visible emissions by taking 6-minute visible emission readings 

for EU-UNIT1-S1 a minimum of once per calendar day when the boiler is operating. Either a certified 

or non-certified reader shall take each visible emission reading during routine operating conditions. 

If the permittee observes any visible emissions, the permittee shall immediately implement the 

following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

c. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor 

and record the PM emissions from EU-UNIT1-S1 on a continuous basis. The permittee shall install and 

operate the CEM to meet the timelines, requirements and reporting detailed in Appendix B. The permittee 

shall also meet the following requirements:

i. During the initial performance test required by SC V.1, the permittee shall conduct visible emission 

observations using Method 9 or an alternative method approved by the AQD.

ii. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PM CEM is out of control based upon the results of quality assurance tests conducted in accordance 

with Procedure 2 of 40 CFR Part 60 (Appendix F). This alternative monitoring shall, unless alternate 

methods and frequencies are approved in writing by the AQD District Supervisor, require verification 

of the presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT1-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

(R 336.1205, R 336.1301, R 336.1303, R 336.1331, R 336.1901, R 336.1911, R 336.2810, 

40 CFR 52.21(j))

4. The permittee shall install, calibrate, maintain and operate in a satisfactory manner device(s) to monitor and 

record the SO2, NOx, and CO emissions, and oxygen or carbon dioxide (O2 or CO2) content of the exhaust 

gas from EU-UNIT1-S1 on a continuous basis. The permittee shall install and operate each CEM to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52.21(j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

5. Within 180 days after start-up and shakedown of the wet FGD system, the permittee shall install, calibrate, 

maintain and operate in a satisfactory manner a device to monitor and record the mercury emissions from 

EU-UNIT1-S1 on a continuous basis. The permittee shall install and operate an Hg monitor to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1224, R 336.1228, 

R 336.1229(2)(b), R 336.2503(2))
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6. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the exhaust gas flow rate from EU-UNIT1-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in Appendix B attached. (R 336.2810, 40 CFR 52.21(j),

R 336.2902(2)(c), 40 CFR 51 (Appendix S))

7. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the gross energy output from EU-UNIT1-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in 40 CFR 60.49Da(k).1 (R 336.1224)

8. The permittee shall keep, in a satisfactory manner, hourly and 24-hour rolling average SO2 emission 

rate and mass records for EU-UNIT1-S1, as described in emission limits SC I.6, I.7, and I.8, respectively. 

(R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j), R 336.2902(2)(c), 

40 CFR 51 (Appendix S))

9. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average NOx emission rate 

and mass records for EU-UNIT1-S1, as described in emission limits SC I.9, and I.10. (R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

10. The permittee shall keep, in a satisfactory manner, daily and 30-day rolling average CO emission rate and 

mass records for EU-UNIT1-S1, as described in emission limits SC I.11 and I.12. (R 336.2804, R 336.2810, 

40 CFR 52.21(d), and (j))

11. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average mercury emission 

rate records, expressed on a basis of gross energy output, and monthly and 12-month rolling time period

mercury mass emission rate records for EU-UNIT1-S1, as described in emission limits SC I.20 and SC I.21. 

If the monitoring required by Monitoring/Recordkeeping SC VI.4 is only capable of detecting gaseous mercury, 

the permittee shall use the testing required by Testing/Sampling SC V.9 to develop a correction factor to 

adjust the mercury monitoring data to total mercury. Based on the available testing and monitoring data, the 

correction factor may be adjusted upon review and approval of the AQD District Supervisor.1

(R 336.1224, R 336.1228, R 336.1229(2)(b)) 

12. The permittee shall maintain records of all information necessary for all notifications and reports as specified 

in these special conditions as well as that information necessary to demonstrate compliance with the emission 

limits of this permit. This information shall include, but shall not be limited to the following:

a. Compliance tests and any testing required under the special conditions of this permit;

b. Monitoring data;

c. Heat input calculations required to show compliance with SC IV.1;

d. Identification, type and the amounts of all fuels combusted in EU-UNIT1-S1 on a calendar month basis;

e. Total gigawatt-hours of energy produced on a monthly basis;

f. Records of the duration of all times EU-UNIT1-S1 is operated under start-up or shutdown conditions as 

defined in SC III.2;

g. All calculations necessary to show compliance with the limits contained in this permit.

All of the above information shall be stored in a format acceptable to the Air Quality Division and made 

available to the Department upon request. (R 336.1205(1)(a), R 336.1224, R 336.1225, R 336.1228, 

R 336.1229(2)(b), R 336.1301, R 336.1331, R 336.1401, R 336.1702(a), R 336.1901, R 336.1912, 

R 336.2802(4), R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))
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VII. REPORTING

1. The permittee shall submit an excess emission report (EER) and summary report in an acceptable format to 

the AQD District Supervisor and the TPU Supervisor within 30 days following the end of each calendar quarter 

as specified in 40 CFR 60.7(c) and (d). The Summary Report shall follow the format of Figure 1 in 40 CFR 

60.7(d). The EER shall include the following information:

a. A report of each exceedance above the limits specified in the emission limits of this permit. This includes 

the date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b. A report of all periods of the Continuous Emission Monitoring and Continuous Emission Rate Monitoring 

System (CEMS/CERMS), and if applicable Predictive Emission Monitoring System (PEMS), downtime 

and corrective action.

c. A report of the total operating time of the boiler during the reporting period.

d. A report of any periods that the CEMS/CERMS, and if applicable PEMS, exceed the instrument range.

e. If no exceedances or CEMS/CERMS, and if applicable PEMS, downtime occurred during the reporting 

period, the permittee shall report that fact.

(R 336.1205, R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2803, R 336.2804, R 336.2810, 

R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.7(c) and (d))

2. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification of 

EU-UNIT1-S1 authorized by this Permit to Install, the permittee or the authorized agent pursuant to 

Rule 204, shall notify the AQD District Supervisor, in writing, of the completion of the activity. Completion of 

the installation, construction, reconstruction, relocation, or modification is considered to occur not later than 

commencement of trial operation of EU-UNIT1-S1. (R 336.1201(7)(a))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV015-001 336 579

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)

2. SV015-001* 336 805 R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)

* The stack height in SC VIII.2 applies until start-up of the wet FGD.
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IX. OTHER REQUIREMENTS

1. The permittee shall comply with all of the applicable requirements contained in the Clean Air Interstate Rule, 

as it applies to EU-UNIT1-S1. (40 CFR Part 97)

2. The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain Program, 

as it applies to EU-UNIT1-S1. (40 CFR Parts 72 - 76)

3. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT1-S1,

by the initial compliance date. (40 CFR Part 63 Subparts A and UUUUU)

4. The start-up and shakedown period for the wet FGD shall not exceed 180 days. (R 336.2803, R 336.2804, 

R 336.2810, 40 CFR 52.21(c), (d), and (j))

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
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The following conditions apply to: EU-UNIT2-S1

DESCRIPTION: Coal-fired cell burner boiler nominally rated at a maximum heat input of 7,624 MMBtu per hour 

on a fuel input basis. The boiler serves a steam turbine electric generator nominally rated at 823 MW (gross). 

Fires No. 2 fuel oil for boiler start-up and flame stabilization.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, overfire air, REF sorbent system, SO3 and ammonia 

flue gas conditioning systems, (to be installed) selective catalytic reduction (SCR), dry wire electrostatic 

precipitators (ESP), and (to be installed) wet flue gas desulfurization (FGD). 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent* 6-minute average 

except one 

6-minute average 

per hour of not 

more than 20 

percent

EU-UNIT2-S1 SC V.1, 

SC VI.2

R 336.1301(1)(c), 

R 336.2810, 40 CFR 52.21(j) 

2. PM 0.011 lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time or 24-hr 

rolling average as 

determined each 

hour the boiler 

operates

EU-UNIT2-S1 SC V.1,

SC VI.3

R 336.1224,

R 336.1225,

R 336.1331(1)(c),

R 336.2810,

40 CFR 52.21(j) 

3. PM 0.12 pounds per 

1,000 pounds of 

exhaust gases, 

on a wet basis, 

corrected to 50% 

excess air**

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.10 R 336.1331(1)

4. PM10 0.024 lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.2 R 336.2810,

40 CFR 52.21(j)

5. PM10 183.0 pph* Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.2 R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

6. SO2 0.107 lb/MMBtu

heat input*

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT2-S1 SC VI.4,

SC VI.8

R 336.1401,

R 336.2810,

40 CFR 52.21(j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

7. SO2 1.6 lb/MMBtu

heat input**

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT2-S1 SC VI.4,

SC VI.8

R 336.1401
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Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

8. SO2 815.8 pph* 24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT2-S1 SC VI.4,

SC VI.6,

SC VI.8

R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

9. NOx 0.08 lb/MMBtu

heat input*

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT2-S1 SC VI.4,

SC VI.9

R 336.2810,

40 CFR 52.21(j)

10. NOx 1,419.0 

ton/month***

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT2-S1 FGUNITS1

&2TEMP -

SC VI.3,

SC VI.4

R 336.2804,

40 CFR 52.21(d)

11. NOx 222.6 ton/month* 12-month rolling 

average as 

determined each 

calendar month

EU-UNIT2-S1 SC VI.4,

SC VI.6,

SC VI.9

R 336.2803, R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

12. CO 0.15 lb/MMBtu 

heat input 

excluding periods 

of start-up and 

shutdown*

30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT2-S1 SC VI.4,

SC VI.10

R 336.2810,

40 CFR 52.21(j)

13. CO 27,446.4 lb/day* 30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT2-S1 SC VI.4,

SC VI.6,

SC VI.10

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

14. VOC 0.0034 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.4 R 336.1122(f),

R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

15. VOC 25.9 pph* Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.4 R 336.1122(f), R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

16. Lead (Pb) 1.69 x 10-5

lb/MMBtu heat 

input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.5 R 336.1901,

R 336.2810,

40 CFR 52.21(j)

17. Lead (Pb) 0.13 pph* Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.5 R 336.1901,

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

18. Sulfuric acid 

mist (H2SO4)

0.005 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.6 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

19. Hydrogen 

Chloride 

(HCl)

0.0024 lb/MMBtu 

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.7 R 336.1224,

R 336.1225
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Permit No. 27-13A Page 20 of 103

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

20. Hydrogen 

Fluoride (HF)

0.00023 

lb/MMBtu

heat input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.8 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

21. Mercury (Hg) 0.02 lb/GW-hr 

gross energy 

output*

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT2-S1 SC V.9,

SC VI.5,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

22. Mercury (Hg) 144.2 lb/year* 12-month rolling 

time period as 

determined at the 

end of each 

calendar month

EU-UNIT2-S1 SC V.9,

SC VI.5,

SC VI.6,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

23. Arsenic (As) 6.3 x 10-6

lb/MMBtu heat 

input*

Test protocol will 

specify averaging 

time.

EU-UNIT2-S1 SC V.5 R 336.1224,

R 336.1225(2)

* These emission limits apply after start-up and shakedown of the SCR and wet FGD systems are completed.

** These emission limits apply until start-up and shakedown of the SCR and wet FGD systems are completed.

*** This emission limit applies when EU-UNIT1-S1 and EU-UNIT2-S1 no longer share a common stack, and until 

start-up and shakedown of the SCR and wet FGD systems are completed.

II. MATERIAL LIMITS

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. Startup is defined in SC III.2. (R 336.1205(1)(a) and (1)(b), R 336.2810, 40 CFR 52.21(j))

2. The permittee shall only combust bituminous coal, subbituminous coal, and up to 23,652 tons per calendar 

month of petroleum coke in EU-UNIT2-S1. Petroleum coke shall not be combusted in EU-UNIT2-S1 until 

after start-up and shakedown of the SCR and wet FGD system is completed. (R 336.1205(1)(a) and (1)(b), 

R 336.1224, R 336.1225, R 336.1702(a), R 336.1901, R 336.2810, 40 CFR 52.21(j))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-UNIT2-S1 unless a MAP as described in Rule 911(2), for operation of the 

process and emission control equipment, is implemented and maintained. If at any time the MAP fails to 

address or inadequately addresses an event that meets the characteristics of a malfunction, the permittee 

shall amend the MAP within 45 days after such an event occurs. The permittee shall also amend the MAP 

within 45 days, if new equipment is installed or upon request from the AQD District Supervisor. The permittee 

shall submit the MAP and any amendments to the MAP to the AQD District Supervisor for review and approval. 

If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended MAP shall be 

considered approved. Until an amended plan is approved, the permittee shall implement corrective 

procedures or operational changes to achieve compliance with all applicable emission limits.

(R 336.1224, R 336.1225, R 336.1331, R 336.1702(a), R 336.1910, R 336.1911, R 336.1912, R 336.2803, R 

336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

2. Start-up is defined as the period of time from initiation of combustion firing until the unit reaches steady state 

operation and the SCR (after start-up and shakedown) is brought into service upon the flue gas reaching a 

minimum operating temperature for the SCR of 650°F. Shutdown is defined as that period of time beginning 

when the flue gas temperature entering the SCR (after start-up and shakedown) drops below the operating 

temperature of the SCR system. (R 336.1912, R 336.2810, 40 CFR 52.21(j))
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Permit No. 27-13A Page 21 of 103

3. The permittee shall not operate EU-UNIT2-S1 unless an acceptable plan that describes how emissions will be 

minimized during all start-ups and shutdowns has been submitted to the AQD District Supervisor. The plan 

shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard 

industry practices. (R 336.1911, R 336.1912, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21(c), (d), and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The maximum design heat input rate of EU-UNIT2-S1 shall not exceed 7,624 million British thermal units per 

hour (MMBtu/hr) on a fuel heat input basis. (R 336.1205(1)(a) and (1)(b))

2. The permittee shall not operate EU-UNIT2-S1 unless the low-NOx burners, overfire air, SO3 and ammonia 

flue gas conditioning systems, SCR system (after start-up and shakedown), ESP, and wet FGD system (after 

start-up and shakedown) are installed, maintained, and operated in a satisfactory manner. Satisfactory 

manner includes operating and maintaining each control device in accordance with an approved MAP for EUUNIT2-S1 as required in SC III.1. (R 336.1224, R 336.1225, R 336.1901, R 336.1910, R 336.2810, 40 CFR 

52.21(j)) 

3. The permittee shall not operate EU-UNIT2-S1 unless the REF sorbent system is installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT2-S1 as required in SC III.1. (R 336.1225, 

R 336.1910)

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of visible 

emissions and PM emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with 

Department requirements, will be required. The permittee must complete the test once every five years, 

thereafter. No less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD 

Technical Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD 

Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, 

R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

2. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of PM10 

emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every five years, thereafter. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, 

R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

3. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of PM2.5 

emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every calendar year for the next 

ten years of operation after the modification. No less than 60 days prior to testing, the permittee shall submit 

a complete test plan to the AQD Technical Programs Unit and District Office. The final plan must be approved 

by the AQD prior to testing. Verification of emission rates includes the submittal of a complete report of the 

test results to the AQD Technical Programs Unit and District Office within 60 days following the last date of 

the test. (R 336.2001, R 336.2003, R 336.2004, R 336.2902(2)(c), 40 CFR 51 (Appendix S))
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4. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of VOC emission 

rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1224, 

R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

5. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of Pb and As 

emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every five years, thereafter. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1225, 

R 336.1901, R 336.2001, R 336.2003, R 336.2004, R 336.2804, R 336.2810, 40 CFR 52.21(d) and (j))

6. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of H2SO4

emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every five years, thereafter. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.2001, R 336.2003, 

R 336.2004, R 336.2810, 40 CFR 52.21(j))

7. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of HCl emission 

rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1224, 

R 336.1225, R 336.2001, R 336.2003, R 336.2004)

8. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of HF emission 

rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department requirements, will be 

required. The permittee must complete the test once every five years, thereafter. No less than 60 days prior 

to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District 

Office. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes 

the submittal of a complete report of the test results to the AQD Technical Programs Unit and District Office 

within 60 days following the last date of the test. (R 336.1224, 

R 336.1225, R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

9. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, verification of total Hg 

emission rates from EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department 

requirements, will be required. The permittee must complete the test once every five years, thereafter. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days 

following the last date of the test.1 (R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2001, R 336.2003, 

R 336.2004)
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Permit No. 27-13A Page 23 of 103

10. Prior to the start-up and shakedown of the SCR and wet FGD systems, verification of PM emission rates from 

EU-UNIT2-S1 by testing at owner’s expense, in accordance with Department requirements, will be required. 

The permittee must complete the test once every five years, or more frequently upon request of AQD. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days 

following the last date of the test. (R 336.1205(1)(a) and (1)(b), R 336.1213(3), R 336.2001, R 336.2003, 

R 336.2004)

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1224, R 336.1225, 

R 336.1702, R 336.1901) 

2. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, the permittee shall conduct 

visible emission observations using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)), or an 

alternate method approved by the AQD, on a calendar day basis each day the boiler operates or the permittee 

shall install, calibrate, maintain and operate in a satisfactory manner a COM system to monitor and record the 

visible emissions before the wet FGD from EU-UNIT2-S1 on a continuous basis. The permittee shall install 

and operate the COM system to meet the timelines, requirements and reporting detailed in Appendix A and 

correlate pre-wet FGD visible emissions to post-wet FGD visible emissions on an annual basis. If the 

permittee installs a PM CEM per SC VI.3.c., this special condition is void. (R 336.1301, R 336.2810, 

40 CFR 52.21(j))

3. Within 180 days after start-up and shakedown of the SCR and wet FGD systems and prior to the 

implementation of a continuous monitoring system as specified in (a), (b) or (c) below, the permittee shall 

perform PM emission testing as specified in SC V.1 on a quarterly basis for the next 12-months. If the PM 

emission rates are less than 50% of the emission limit specified in SC I.2 for four consecutive quarters, the 

permittee may reduce the PM emission testing to a semi-annual basis for the next 12-months and then an 

annual basis until an acceptable continuous monitoring system as specified in (a), (b), or (c) is implemented. 

If PM emissions are greater than 50% of the emission limit specified in SC I.2 for any single semi-annual or 

annual test, then quarterly testing shall be required.

The permittee shall implement an acceptable continuous monitoring system as specified in (a), (b), or (c) no 

later than January 1, 2015.

 

a. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a Continuous 

Parameter Monitoring System (CPMS) per the requirements of an approved Performance Specification 

or an alternative method approved by the AQD for PM. The permittee shall also meet the following 

requirements:

i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

CPMS is out of control based upon the results of quality assurance tests conducted in accordance 

with a Performance Specification. This alternative monitoring shall, unless alternate methods and 

frequencies are approved in writing by the AQD District Supervisor, require verification of the 

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT2-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.
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B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

b. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a PM Predictive 

Emission Monitoring System (PEMS) per the requirements of Performance Specification 16 (Appendix B 

to Part 60) or an alternative method approved by the AQD. The permittee shall also meet the following 

requirements:

i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PEMS is out of control based upon the results of quality assurance tests conducted in accordance 

with Performance Specification 16 of 40 CFR Part 60 (Appendix B). This alternative monitoring shall, 

unless alternate methods and frequencies are approved in writing by the AQD District Supervisor, 

require verification of the presence of visible emissions by taking 6-minute visible emission readings 

for EU-UNIT2-S1 a minimum of once per calendar day when the boiler is operating. Either a certified 

or non-certified reader shall take each visible emission reading during routine operating conditions. 

If the permittee observes any visible emissions, the permittee shall immediately implement the 

following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

c. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor 

and record the PM emissions from EU-UNIT2-S1 on a continuous basis. The permittee shall install and 

operate the CEM to meet the timelines, requirements and reporting detailed in Appendix B. The permittee 

shall also meet the following requirements:

i. During the initial performance test required by SC V.1, the permittee shall conduct visible emission 

observations using Method 9 or an alternative method approved by the AQD.

ii. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PM CEM is out of control based upon the results of quality assurance tests conducted in accordance 

with Procedure 2 of 40 CFR Part 60 (Appendix F). This alternative monitoring shall, unless alternate 

methods and frequencies are approved in writing by the AQD District Supervisor, require verification 

of the presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT2-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

(R 336.1205, R 336.1301, R 336.1303, R 336.1331, R 336.1901, R 336.1911, R 336.2810, 

40 CFR 52.21(j))

4. The permittee shall install, calibrate, maintain and operate in a satisfactory manner device(s) to monitor and 

record the SO2, NOx, and CO emissions, and oxygen or carbon dioxide (O2 or CO2) content of the exhaust 

gas from EU-UNIT2-S1 on a continuous basis. The permittee shall install and operate each CEM to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52.21(j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

5. Within 180 days after start-up and shakedown of the SCR and wet FGD systems, the permittee shall install, 

calibrate, maintain and operate in a satisfactory manner a device to monitor and record the mercury emissions 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 25 of 103

from EU-UNIT2-S1 on a continuous basis. The permittee shall install and operate an Hg monitor to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1224, R 336.1228, 

R 336.1229(2)(b), R 336.2503(2))

6. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the exhaust gas flow rate from EU-UNIT2-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in Appendix B attached. (R 336.2810, 40 CFR 52.21(j),

R 336.2902(2)(c), 40 CFR 51 (Appendix S))

7. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the gross energy output from EU-UNIT2-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in 40 CFR 60.49Da(k).1 (R 336.1224)

8. The permittee shall keep, in a satisfactory manner, hourly and 24-hour rolling average SO2 emission rate and 

mass records for EU-UNIT2-S1, as described in emission limits SC I.6, I.7, and I.8, respectively. (R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

9. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average NOx emission rate 

and mass records for EU-UNIT2-S1, as described in emission limits SC I.9, I.10, and I.11. (R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

10. The permittee shall keep, in a satisfactory manner, daily and 30-day rolling average CO emission rate and 

mass records for EU-UNIT2-S1, as described in emission limits SC I.12 and I.13. (R 336.2804, R 336.2810, 

40 CFR 52.21(d), and (j))

11. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average mercury emission 

rate records, expressed on a basis of gross energy output, and monthly and 12-month rolling time period

mercury mass emission rate records for EU-UNIT2-S1, as described in emission limits SC I.21 and SC I.22. 

If the monitoring required by Monitoring/Recordkeeping SC VI.4 is only capable of detecting gaseous mercury, 

the permittee shall use the testing required by Testing/Sampling SC V.9 to develop a correction factor to 

adjust the mercury monitoring data to total mercury. Based on the available testing and monitoring data, the 

correction factor may be adjusted upon review and approval of the AQD District Supervisor.1

(R 336.1224, R 336.1228, R 336.1229(2)(b)) 

12. The permittee shall maintain records of all information necessary for all notifications and reports as specified 

in these special conditions as well as that information necessary to demonstrate compliance with the emission 

limits of this permit. This information shall include, but shall not be limited to the following:

a. Compliance tests and any testing required under the special conditions of this permit;

b. Monitoring data;

c. Heat input calculations required to show compliance with SC IV.1;

d. Identification, type and the amounts of all fuels combusted in EU-UNIT2-S1 on a calendar month basis;

e. Total gigawatt-hours of energy produced on a monthly basis;

f. Records of the duration of all times EU-UNIT2-S1 is operated under start-up or shutdown conditions as 

defined in SC III.2;

g. All calculations necessary to show compliance with the limits contained in this permit.

All of the above information shall be stored in a format acceptable to the Air Quality Division and made 

available to the Department upon request. (R 336.1205(1)(a), R 336.1224, R 336.1225, R 336.1228, 

R 336.1229(2)(b), R 336.1301, R 336.1331, R 336.1401, R 336.1702(a), R 336.1901, R 336.1912, 

R 336.2802(4), R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

VII. REPORTING
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Permit No. 27-13A Page 26 of 103

1. The permittee shall submit an excess emission report (EER) and summary report in an acceptable format to 

the AQD District Supervisor and the TPU Supervisor within 30 days following the end of each calendar quarter 

as specified in 40 CFR 60.7(c) and (d). The Summary Report shall follow the format of Figure 1 in 40 CFR 

60.7(d). The EER shall include the following information:

a. A report of each exceedance above the limits specified in the emission limits of this permit. This includes 

the date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b. A report of all periods of the Continuous Emission Monitoring and Continuous Emission Rate Monitoring 

System (CEMS/CERMS), and if applicable Predictive Emission Monitoring System (PEMS), downtime 

and corrective action.

c. A report of the total operating time of the boiler during the reporting period.

d. A report of any periods that the CEMS/CERMS, and if applicable PEMS, exceed the instrument range.

e. If no exceedances or CEMS/CERMS, and if applicable PEMS, downtime occurred during the reporting 

period, the permittee shall report that fact.

(R 336.1205, R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2803, R 336.2804, R 336.2810, 

R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.7(c) and (d))

2. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification of 

EU-UNIT2-S1 authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, 

shall notify the AQD District Supervisor, in writing, of the completion of the activity. Completion of the 

installation, construction, reconstruction, relocation, or modification is considered to occur not later than 

commencement of trial operation of EU-UNIT2-S1. (R 336.1201(7)(a))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV015-002 336 579

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)

2. SV015-002* 336 805 R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)

* The stack height in SC VIII.2 applies until start-up of the wet FGD.

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all of the applicable requirements contained in the Clean Air Interstate Rule, 

as it applies to EU-UNIT2-S1. (40 CFR Part 97)

2. The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain Program, 

as it applies to EU-UNIT2-S1. (40 CFR Parts 72 - 76)

3. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT2-S1,

by the initial compliance date. (40 CFR Part 63 Subparts A and UUUUU)

4. The start-up and shakedown period for the wet FGD shall not exceed 180 days. (R 336.2803, R 336.2804, 

R 336.2810, 40 CFR 52.21(c), (d), and (j))
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5. The start-up and shakedown period for the SCR shall not exceed 180 days. (R 336.2803, R 336.2804, 

R 336.2810, 40 CFR 52.21(c), (d), and (j))

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
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The following conditions apply to: EU-UNIT3-S1

DESCRIPTION: Coal-fired cell burner boiler nominally rated at a maximum heat input of 7,624 MMBtu per hour 

on a fuel input basis. The boiler serves a steam turbine electric generator nominally rated at 823 MW (gross). 

Fires No. 2 fuel oil for boiler start-up and flame stabilization.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, overfire air, REF sorbent system, SO3 and ammonia 

flue gas conditioning systems, selective catalytic reduction (SCR), dry wire electrostatic precipitators (ESP), and 

wet flue gas desulfurization (FGD). 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent 6-minute average 

except one 6-minute 

average per hour of 

not more than 

20 percent

EU-UNIT3-S1 SC V.1, 

SC VI.2

R 336.1301(1)(c), R 336.2810,

40 CFR 52.21(j) 

2. PM 0.011 lb/MMBtu

heat input

Test protocol will 

specify averaging 

time or 24-hr rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT3-S1 SC V.1,

SC VI.3

R 336.1224,

R 336.1225,

R 336.1331(1)(c),

R 336.2810,

40 CFR 52.21(j) 

3. PM10 0.024 lb/MMBtu

heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.2 R 336.2810,

40 CFR 52.21(j)

4. PM10 183.0 pph Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.2 R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

5. SO2 0.107 lb/MMBtu

heat input

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT3-S1 SC VI.4,

SC VI.8

R 336.1401,

R 336.2810,

40 CFR 52.21(j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

6. SO2 815.8 pph 24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT3-S1 SC VI.4,

SC VI.6,

SC VI.8

R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

7. NOx 0.08 lb/MMBtu

heat input

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT3-S1 SC VI.4,

SC VI.9

R 336.2810,

40 CFR 52.21(j)

8. NOx 222.6 ton/month 12-month rolling 

average as 

determined each 

calendar month

EU-UNIT3-S1 SC VI.4,

SC VI.6,

SC VI.9

R 336.2803, 

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)
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Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

9. CO 0.15 lb/MMBtu heat 

input excluding 

periods of start-up 

and shutdown

30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT3-S1 SC VI.4,

SC VI.10

R 336.2810,

40 CFR 52.21(j)

10. CO 27,446.4 lb/day 30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT3-S1 SC VI.4,

SC VI.6,

SC VI.10

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

11. VOC 0.0034 lb/MMBtu 

heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.4 R 336.1122(f),

R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

12. VOC 25.9 pph Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.4 R 336.1122(f), 

R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

13. Lead (Pb) 1.69 x 10-5lb/MMBtu 

heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.5 R 336.1901,

R 336.2810,

40 CFR 52.21(j)

14. Lead (Pb) 0.13 pph Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.5 R 336.1901,

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

15. Sulfuric acid 

mist (H2SO4)

0.005 lb/MMBtu heat 

input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.6 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

16. Hydrogen 

Chloride (HCl)

0.0024 lb/MMBtu 

heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.7 R 336.1224,

R 336.1225

17. Hydrogen 

Fluoride (HF)

0.00023 lb/MMBtu

heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.8 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

18. Mercury (Hg) 0.02 lb/GW-hr gross 

energy output

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT3-S1 SC V.9,

SC VI.5,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

19. Mercury (Hg) 144.2 lb/year 12-month rolling time 

period as 

determined at the 

end of each calendar 

month

EU-UNIT3-S1 SC V.9,

SC VI.5,

SC VI.6,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

20. Arsenic (As) 6.3 x 10-6

lb/MMBtu heat input

Test protocol will 

specify averaging 

time.

EU-UNIT3-S1 SC V.5 R 336.1224,

R 336.1225(2)
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II. MATERIAL LIMITS

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. Startup is defined in SC III.2. (R 336.1205(1)(a) and (1)(b), R 336.2810, 40 CFR 52.21(j))

2. The permittee shall only combust bituminous coal, subbituminous coal, and up to 23,652 tons per calendar 

month of petroleum coke in EU-UNIT3-S1. (R 336.1205(1)(a) and (1)(b), R 336.1224, R 336.1225, 

R 336.1702(a), R 336.1901, R 336.2810, 40 CFR 52.21(j))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-UNIT3-S1 unless a MAP as described in Rule 911(2), for operation of the 

process and emission control equipment, is implemented and maintained. If at any time the MAP fails to 

address or inadequately addresses an event that meets the characteristics of a malfunction, the permittee 

shall amend the MAP within 45 days after such an event occurs. The permittee shall also amend the MAP 

within 45 days, if new equipment is installed or upon request from the AQD District Supervisor. The permittee 

shall submit the MAP and any amendments to the MAP to the AQD District Supervisor for review and approval. 

If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended MAP shall be 

considered approved. Until an amended plan is approved, the permittee shall implement corrective 

procedures or operational changes to achieve compliance with all applicable emission limits.

(R 336.1224, R 336.1225, R 336.1331, R 336.1702(a), R 336.1910, R 336.1911, R 336.1912, R 336.2803, R 

336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

2. Start-up is defined as the period of time from initiation of combustion firing until the unit reaches steady state 

operation and the SCR is brought into service upon the flue gas reaching a minimum operating temperature 

for the SCR of 650°F. Shutdown is defined as that period of time beginning when the flue gas temperature 

entering the SCR drops below the operating temperature of the SCR system. (R 336.1912, R 336.2810, 

40 CFR 52.21(j))

3. The permittee shall not operate EU-UNIT3-S1 unless an acceptable plan that describes how emissions will be 

minimized during all start-ups and shutdowns has been submitted to the AQD District Supervisor. The plan 

shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard 

industry practices. (R 336.1911, R 336.1912, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21(c), (d), and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The maximum design heat input rate of EU-UNIT3-S1 shall not exceed 7,624 million British thermal units per 

hour (MMBtu/hr) on a fuel heat input basis. (R 336.1205(1)(a) and (1)(b))

2. The permittee shall not operate EU-UNIT3-S1 unless the low-NOx burners, overfire air, SO3 and ammonia 

flue gas conditioning systems, SCR system, ESP, and wet FGD system are installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT3-S1 as required in SC III.1. (R 336.1224, 

R 336.1225, R 336.1901, R 336.1910, R 336.2810, 40 CFR 52.21(j)) 

3. The permittee shall not operate EU-UNIT3-S1 unless the REF sorbent system is installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT3-S1 as required in SC III.1. (R 336.1225, 

R 336.1910)
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V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the visible emissions and PM emission rates from EU-UNIT3-S1 by testing at 

owner’s expense, in accordance with Department requirements. The permittee must complete the test once 

every five years. No less than 60 days prior to testing, the permittee shall submit a complete test plan to the 

AQD Technical Programs Unit and District Office. The AQD must approve the final plan prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD 

Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, 

R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

2. The permittee shall verify the PM10 emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The AQD must approve the final plan prior to testing. Verification of 

emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, 

R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

3. The permittee shall verify the PM2.5 emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every calendar year 

for the next ten years of operation after the modification. No less than 60 days prior to testing, the permittee 

shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The final plan must 

be approved by the AQD prior to testing. Verification of emission rates includes the submittal of a complete 

report of the test results to the AQD Technical Programs Unit and District Office within 

60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.2902(2)(c), 

40 CFR 51 (Appendix S))

4. The permittee shall verify the VOC emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, 

R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

5. The permittee shall verify the Pb and As emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1225, R 336.1901, R 336.2001, 

R 336.2003, R 336.2004, R 336.2804, R 336.2810, 40 CFR 52.21(d) and (j))

6. The permittee shall verify the H2SO4 emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.2001, R 336.2003, 

R 336.2004, R 336.2810, 40 CFR 52.21(j))
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Permit No. 27-13A Page 32 of 103

7. The permittee shall verify the HCl emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years, 

thereafter. No less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD 

Technical Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD 

Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, 

R 336.1225, R 336.2001, R 336.2003, R 336.2004)

8. The permittee shall verify the HF emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, 

R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

9. The permittee shall verify the total Hg emission rates from EU-UNIT3-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days 

following the last date of the test.1 (R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2001, R 336.2003, 

R 336.2004)

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1224, R 336.1225, 

R 336.1702, R 336.1901) 

2. The permittee shall conduct visible emission observations using federal Reference Test Method 9 

(40 CFR Part 60 (Appendix A)), or an alternate method approved by the AQD, on a calendar day basis each 

day the boiler operates or the permittee shall install, calibrate, maintain and operate in a satisfactory manner 

a COM system to monitor and record the visible emissions before the wet FGD from EU-UNIT3-S1 on a 

continuous basis. The permittee shall install and operate the COM system to meet the timelines, 

requirements and reporting detailed in Appendix A and correlate pre-wet FGD visible emissions to post-wet 

FGD visible emissions on an annual basis. If the permittee installs a PM CEM per SC VI.3.c., this special 

condition is void. (R 336.1301, R 336.2810, 40 CFR 52.21(j))

3. Prior to the implementation of a continuous monitoring system as specified in (a), (b) or (c) below, the 

permittee shall perform PM emission testing as specified in SC V.1 on a quarterly basis. If the PM emission 

rates are less than 50% of the emission limit specified in SC I.2 for four consecutive quarters, the permittee 

may reduce the PM emission testing to a semi-annual basis for the next 12-months and then an annual basis 

until an acceptable continuous monitoring system as specified in (a), (b), or (c) is implemented. If PM 

emissions are greater than 50% of the emission limit specified in SC I.2 for any single semi-annual or annual 

test, then quarterly testing shall be required.

The permittee shall implement an acceptable continuous monitoring system as specified in (a), (b), or (c) no 

later than January 1, 2015.

 

a. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a Continuous 

Parameter Monitoring System (CPMS) per the requirements of an approved Performance Specification 

or an alternative method approved by the AQD for PM. The permittee shall also meet the following 

requirements:
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i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

CPMS is out of control based upon the results of quality assurance tests conducted in accordance 

with a Performance Specification. This alternative monitoring shall, unless alternate methods and 

frequencies are approved in writing by the AQD District Supervisor, require verification of the 

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT3-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for 

more than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 

(Appendix A)).

b. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a PM Predictive 

Emission Monitoring System (PEMS) per the requirements of Performance Specification 16 (Appendix B 

to Part 60) or an alternative method approved by the AQD. The permittee shall also meet the following 

requirements:

i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PEMS is out of control based upon the results of quality assurance tests conducted in accordance 

with Performance Specification 16 of 40 CFR Part 60 (Appendix B). This alternative monitoring shall, 

unless alternate methods and frequencies are approved in writing by the AQD District Supervisor, 

require verification of the presence of visible emissions by taking 6-minute visible emission readings 

for EU-UNIT3-S1 a minimum of once per calendar day when the boiler is operating. Either a certified 

or non-certified reader shall take each visible emission reading during routine operating conditions. 

If the permittee observes any visible emissions, the permittee shall immediately implement the 

following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

c. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor 

and record the PM emissions from EU-UNIT3-S1 on a continuous basis. The permittee shall install and 

operate the CEM to meet the timelines, requirements and reporting detailed in Appendix B. The permittee 

shall also meet the following requirements:

i. During the initial performance test required by SC V.1, the permittee shall conduct visible emission 

observations using Method 9 or an alternative method approved by the AQD.

ii. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PM CEM is out of control based upon the results of quality assurance tests conducted in accordance 

with Procedure 2 of 40 CFR Part 60 (Appendix F). This alternative monitoring shall, unless alternate 

methods and frequencies are approved in writing by the AQD District Supervisor, require verification 

of the presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT3-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.
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Permit No. 27-13A Page 34 of 103

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

(R 336.1205, R 336.1301, R 336.1303, R 336.1331, R 336.1901, R 336.1911, R 336.2810, 

40 CFR 52.21(j))

4. The permittee shall install, calibrate, maintain and operate in a satisfactory manner device(s) to monitor and 

record the SO2, NOx, and CO emissions, and oxygen or carbon dioxide (O2 or CO2) content of the exhaust 

gas from EU-UNIT3-S1 on a continuous basis. The permittee shall install and operate each CEM to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52.21(j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

5. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the mercury emissions from EU-UNIT3-S1 on a continuous basis. The permittee shall install and 

operate an Hg monitor to meet the timelines, requirements and reporting detailed in Appendix B attached. 

(R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2503(2))

6. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the exhaust gas flow rate from EU-UNIT3-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in Appendix B attached. (R 336.2810, 40 CFR 52.21(j),

R 336.2902(2)(c), 40 CFR 51 (Appendix S))

7. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the gross energy output from EU-UNIT3-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in 40 CFR 60.49Da(k).1 (R 336.1224)

8. The permittee shall keep, in a satisfactory manner, hourly and 24-hour rolling average SO2 emission rate 

records for EU-UNIT3-S1, as described in emission limits SC I.5 and I.6, respectively. (R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

9. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average NOx emission rate 

and mass records for EU-UNIT3-S1, as described in emission limits SC I.7, and I.8. (R 336.2803, R 336.2804,

R 336.2810, 40 CFR 52.21(c), (d), and (j))

10. The permittee shall keep, in a satisfactory manner, daily and 30-day rolling average CO emission rate and 

mass records for EU-UNIT3-S1, as described in emission limits SC I.9 and I.10. (R 336.2804, R 336.2810, 

40 CFR 52.21(d), and (j))

11. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average mercury emission 

rate records, expressed on a basis of gross energy output, and monthly and 12-month rolling time period

mercury mass emission rate records for EU-UNIT3-S1, as described in emission limits SC I.18 and SC I.19. 

If the monitoring required by Monitoring/Recordkeeping SC VI.4 is only capable of detecting gaseous mercury, 

the permittee shall use the testing required by Testing/Sampling SC V.9 to develop a correction factor to 

adjust the mercury monitoring data to total mercury. Based on the available testing and monitoring data, the 

correction factor may be adjusted upon review and approval of the AQD District Supervisor.1

(R 336.1224, R 336.1228, R 336.1229(2)(b)) 

12. The permittee shall maintain records of all information necessary for all notifications and reports as specified 

in these special conditions as well as that information necessary to demonstrate compliance with the emission 

limits of this permit. This information shall include, but shall not be limited to the following:

a. Compliance tests and any testing required under the special conditions of this permit;

b. Monitoring data;

c. Heat input calculations required to show compliance with SC IV.1;

d. Identification, type and the amounts of all fuels combusted in EU-UNIT3-S1 on a calendar month basis;

e. Total gigawatt-hours of energy produced on a monthly basis;
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f. Records of the duration of all times EU-UNIT3-S1 is operated under start-up or shutdown conditions as 

defined in SC III.2;

g. All calculations necessary to show compliance with the limits contained in this permit.

All of the above information shall be stored in a format acceptable to the Air Quality Division and made 

available to the Department upon request. (R 336.1205(1)(a), R 336.1224, R 336.1225, R 336.1228, 

R 336.1229(2)(b), R 336.1301, R 336.1331, R 336.1401, R 336.1702(a), R 336.1901, R 336.1912, 

R 336.2802(4), R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

1. The permittee shall submit an excess emission report (EER) and summary report in an acceptable format to 

the AQD District Supervisor and the TPU Supervisor within 30 days following the end of each calendar quarter 

as specified in 40 CFR 60.7(c) and (d). The Summary Report shall follow the format of Figure 1 in 40 CFR 

60.7(d). The EER shall include the following information:

a. A report of each exceedance above the limits specified in the emission limits of this permit. This includes 

the date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b. A report of all periods of the Continuous Emission Monitoring and Continuous Emission Rate Monitoring 

System (CEMS/CERMS), and if applicable Predictive Emission Monitoring System (PEMS), downtime 

and corrective action.

c. A report of the total operating time of the boiler during the reporting period.

d. A report of any periods that the CEMS/CERMS, and if applicable PEMS, exceed the instrument range.

e. If no exceedances or CEMS/CERMS, and if applicable PEMS, downtime occurred during the reporting 

period, the permittee shall report that fact.

(R 336.1205, R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2803, R 336.2804, R 336.2810, 

R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.7(c) and (d))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV016-003 336 579

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all of the applicable requirements contained in the Clean Air Interstate Rule, 

as it applies to EU-UNIT3-S1. (40 CFR Part 97)

2. The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain Program, 

as it applies to EU-UNIT3-S1. (40 CFR Parts 72 - 76)

3. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT3-S1,

by the initial compliance date. (40 CFR Part 63 Subparts A and UUUUU)
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Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
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The following conditions apply to: EU-UNIT4-S1

DESCRIPTION: Coal-fired cell burner boiler nominally rated at a maximum heat input of 7,624 MMBtu per hour 

on a fuel input basis. The boiler serves a steam turbine electric generator nominally rated at 817 MW (gross). 

Fires No. 2 fuel oil for boiler start-up and flame stabilization.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, overfire air, REF sorbent system, SO3 and ammonia 

flue gas conditioning systems, selective catalytic reduction (SCR), dry wire electrostatic precipitators (ESP), and 

wet flue gas desulfurization (FGD). 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent 6-minute 

average except 

one 6-minute 

average per 

hour of not more 

than 20 percent

EU-UNIT4-S1 SC V.1, 

SC VI.2

R 336.1301(1)(c), 

R 336.2810,

40 CFR 52.21(j) 

2. PM 0.011 lb/MMBtu

heat input

Test protocol will 

specify 

averaging time 

or 24-hr rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT4-S1 SC V.1,

SC VI.3

R 336.1224,

R 336.1225,

R 336.1331(1)(c),

R 336.2810,

40 CFR 52.21(j) 

3. PM10 0.024 lb/MMBtu

heat input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.2 R 336.2810,

40 CFR 52.21(j)

4. PM10 183.0 pph Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.2 R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

5. SO2 0.107 lb/MMBtu

heat input

24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT4-S1 SC VI.4,

SC VI.8

R 336.1401,

R 336.2810,

40 CFR 52.21(j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

6. SO2 815.8 pph 24-hour rolling 

average as 

determined each 

hour the boiler 

operates

EU-UNIT4-S1 SC VI.4,

SC VI.6,

SC VI.8

R 336.2803,

R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j),

R 336.2902(2)(c),

40 CFR 51 (Appendix S)

7. NOx 0.08 lb/MMBtu

heat input

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT4-S1 SC VI.4,

SC VI.9

R 336.2810,

40 CFR 52.21(j)
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Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

8. NOx 222.6 ton/month 12-month rolling 

average as 

determined each 

calendar month

EU-UNIT4-S1 SC VI.4,

SC VI.6,

SC VI.9

R 336.2803, R 336.2804,

R 336.2810,

40 CFR 52.21(c), (d), and (j)

9. CO 0.15 lb/MMBtu 

heat input 

excluding periods 

of start-up and 

shutdown

30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT4-S1 SC VI.4,

SC VI.10

R 336.2810,

40 CFR 52.21(j)

10. CO 27,446.4 lb/day 30-day rolling 

average as 

determined each 

calendar day the 

boiler operates

EU-UNIT4-S1 SC VI.4,

SC VI.6,

SC VI.10

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

11. VOC 0.0034 lb/MMBtu 

heat input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.4 R 336.1122(f), R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

12. VOC 25.9 pph Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.4 R 336.1122(f), R 336.1224,

R 336.1225,

R 336.1702(a),

R 336.2810,

40 CFR 52.21(j)

13. Lead (Pb) 1.69 x 10-5

lb/MMBtu heat 

input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.5 R 336.1901,

R 336.2810,

40 CFR 52.21(j)

14. Lead (Pb) 0.13 pph Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.5 R 336.1901,

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j)

15. Sulfuric acid 

mist (H2SO4)

0.005 lb/MMBtu 

heat input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.6 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

16. Hydrogen 

Chloride 

(HCl)

0.0024 lb/MMBtu 

heat input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.7 R 336.1224,

R 336.1225

17. Hydrogen 

Fluoride (HF)

0.00023 

lb/MMBtu

heat input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.8 R 336.1224,

R 336.1225,

R 336.2810,

40 CFR 52.21(j)

18. Mercury (Hg) 0.02 lb/GW-hr 

gross energy 

output

12-month rolling 

average as 

determined each 

calendar month

EU-UNIT4-S1 SC V.9,

SC VI.5,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b),

R 336.2503(2)

19. Mercury (Hg) 143.1 lb/year 12-month rolling 

time period as 

determined at 

the end of each 

calendar month

EU-UNIT4-S1 SC V.9,

SC VI.6,

SC VI.5,

SC VI.7,

SC VI.11

R 336.1224,

R 336.1228,

R 336.1229(2)(b), 

R 336.2503(2)

20. Arsenic (As) 6.3 x 10-6

lb/MMBtu heat 

input

Test protocol will 

specify 

averaging time.

EU-UNIT4-S1 SC V.5 R 336.1224,

R 336.1225(2)
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II. MATERIAL LIMITS

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. Startup is defined in SC III.2. (R 336.1205(1)(a) and (1)(b), R 336.2810, 40 CFR 52.21(j))

2. The permittee shall only combust bituminous coal, subbituminous coal, and up to 23,652 tons per calendar 

month of petroleum coke in EU-UNIT4-S1. (R 336.1205(1)(a) and (1)(b), R 336.1224, R 336.1225, 

R 336.1702(a), R 336.1901, R 336.2810, 40 CFR 52.21(j))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-UNIT4-S1 unless a MAP as described in Rule 911(2), for operation of the 

process and emission control equipment, is implemented and maintained. If at any time the MAP fails to 

address or inadequately addresses an event that meets the characteristics of a malfunction, the permittee 

shall amend the MAP within 45 days after such an event occurs. The permittee shall also amend the MAP 

within 45 days, if new equipment is installed or upon request from the AQD District Supervisor. The permittee 

shall submit the MAP and any amendments to the MAP to the AQD District Supervisor for review and approval. 

If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended MAP shall be 

considered approved. Until an amended plan is approved, the permittee shall implement corrective 

procedures or operational changes to achieve compliance with all applicable emission limits.

(R 336.1224, R 336.1225, R 336.1331, R 336.1702(a), R 336.1910, R 336.1911, R 336.1912, R 336.2803, R 

336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

2. Start-up is defined as the period of time from initiation of combustion firing until the unit reaches steady state 

operation and the SCR is brought into service upon the flue gas reaching a minimum operating temperature 

for the SCR of 650°F. Shutdown is defined as that period of time beginning when the flue gas temperature 

entering the SCR drops below the operating temperature of the SCR system. (R 336.1912, R 336.2810, 

40 CFR 52.21(j))

3. The permittee shall not operate EU-UNIT4-S1 unless an acceptable plan that describes how emissions will be 

minimized during all start-ups and shutdowns has been submitted to the AQD District Supervisor. The plan 

shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard 

industry practices. (R 336.1911, R 336.1912, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21(c), (d), and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The maximum design heat input rate of EU-UNIT4-S1 shall not exceed 7,624 million British thermal units per 

hour (MMBtu/hr) on a fuel heat input basis. (R 336.1205(1)(a) and (1)(b))

2. The permittee shall not operate EU-UNIT4-S1 unless the low-NOx burners, overfire air, SO3 and ammonia 

flue gas conditioning systems, SCR system, ESP, and wet FGD system are installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT4-S1 as required in SC III.1. (R 336.1224, 

R 336.1225, R 336.1901, R 336.1910, R 336.2810, 40 CFR 52.21(j)) 

3. The permittee shall not operate EU-UNIT4-S1 unless the REF sorbent system is installed, maintained, and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-UNIT4-S1 as required in SC III.1. (R 336.1225, 

R 336.1910)
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V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the visible emissions and PM emission rates from EU-UNIT4-S1 by testing at 

owner’s expense, in accordance with Department requirements. The permittee must complete the test once 

every five years. No less than 60 days prior to testing, the permittee shall submit a complete test plan to the 

AQD Technical Programs Unit and District Office. The final plan must be approved by the AQD prior to 

testing. Verification of emission rates includes the submittal of a complete report of the test results to the 

AQD Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224,

R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

2. The permittee shall verify the PM10 emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, 

R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

3. The permittee shall verify the PM2.5 emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every calendar year 

for the next ten years of operation after the modification. No less than 60 days prior to testing, the permittee 

shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The final plan must 

be approved by the AQD prior to testing. Verification of emission rates includes the submittal of a complete 

report of the test results to the AQD Technical Programs Unit and District Office within 

60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.2902(2)(c), 

40 CFR 51 (Appendix S))

4. The permittee shall verify the VOC emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224,

R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

5. The permittee shall verify the Pb and As emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1225, R 336.1901, R 336.2001, 

R 336.2003, R 336.2004, R 336.2804, R 336.2810, 40 CFR 52.21(d) and (j))

6. The permittee shall verify the H2SO4 emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.2001, R 336.2003, 

R 336.2004, R 336.2810, 40 CFR 52.21(j))
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7. The permittee shall verify the HCl emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, 

R 336.2003, R 336.2004)

8. The permittee shall verify the HF emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD Technical Programs 

Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, 

R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j))

9. The permittee shall verify the total Hg emission rates from EU-UNIT4-S1 by testing at owner’s expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. No 

less than 60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical 

Programs Unit and District Office. The final plan must be approved by the AQD prior to testing. Verification 

of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days 

following the last date of the test.1 (R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2001, R 336.2003, 

R 336.2004)

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1224, R 336.1225, 

R 336.1702, R 336.1901) 

2. The permittee shall conduct visible emission observations using federal Reference Test Method 9 

(40 CFR Part 60 (Appendix A)), or an alternate method approved by the AQD, on a calendar day basis each 

day the boiler operates or the permittee shall install, calibrate, maintain and operate in a satisfactory manner 

a COM system to monitor and record the visible emissions before the wet FGD from EU-UNIT4-S1 on a 

continuous basis. The permittee shall install and operate the COM system to meet the timelines, requirements 

and reporting detailed in Appendix A and correlate pre-wet FGD visible emissions to post-wet FGD visible 

emissions on an annual basis. If the permittee installs a PM CEM per SC VI.3.c., this special condition is 

void. (R 336.1301, R 336.2810, 40 CFR 52.21(j))

3. Prior to the implementation of a continuous monitoring system as specified in (a), (b) or (c) below, the 

permittee shall perform PM emission testing as specified in SC V.1 on a quarterly basis. If the PM emission 

rates are less than 50% of the emission limit specified in SC I.2 for four consecutive quarters, the permittee 

may reduce the PM emission testing to a semi-annual basis for the next 12-months and then an annual basis 

until an acceptable continuous monitoring system as specified in (a), (b), or (c) is implemented. If PM 

emissions are greater than 50% of the emission limit specified in SC I.2 for any single semi-annual or annual 

test, then quarterly testing shall be required.

The permittee shall implement an acceptable continuous monitoring system as specified in (a), (b), or (c) no 

later than January 1, 2015.

 

a. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a Continuous 

Parameter Monitoring System (CPMS) per the requirements of an approved Performance Specification 

or an alternative method approved by the AQD for PM. The permittee shall also meet the following 

requirements:
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i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

CPMS is out of control based upon the results of quality assurance tests conducted in accordance 

with a Performance Specification. This alternative monitoring shall, unless alternate methods and 

frequencies are approved in writing by the AQD District Supervisor, require verification of the 

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT4-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

b. The permittee shall install, calibrate, maintain and operate in a satisfactory manner, a PM Predictive 

Emission Monitoring System (PEMS) per the requirements of Performance Specification 16 (Appendix B 

to Part 60) or an alternative method approved by the AQD. The permittee shall also meet the following 

requirements:

i. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PEMS is out of control based upon the results of quality assurance tests conducted in accordance 

with Performance Specification 16 of 40 CFR Part 60 (Appendix B). This alternative monitoring shall, 

unless alternate methods and frequencies are approved in writing by the AQD District Supervisor, 

require verification of the presence of visible emissions by taking 6-minute visible emission readings 

for EU-UNIT4-S1 a minimum of once per calendar day when the boiler is operating. Either a certified 

or non-certified reader shall take each visible emission reading during routine operating conditions. 

If the permittee observes any visible emissions, the permittee shall immediately implement the 

following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).

c. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor 

and record the PM emissions from EU-UNIT4-S1 on a continuous basis. The permittee shall install and 

operate the CEM to meet the timelines, requirements and reporting detailed in Appendix B. The permittee 

shall also meet the following requirements:

i. During the initial performance test required by SC V.1, the permittee shall conduct visible emission 

observations using Method 9 or an alternative method approved by the AQD.

ii. The MAP required in SC III.1 shall include provisions for alternative monitoring in the event that the 

PM CEM is out of control based upon the results of quality assurance tests conducted in accordance 

with Procedure 2 of 40 CFR Part 60 (Appendix F). This alternative monitoring shall, unless alternate 

methods and frequencies are approved in writing by the AQD District Supervisor, require verification 

of the presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT3-S1 a 

minimum of once per calendar day when the boiler is operating. Either a certified or non-certified 

reader shall take each visible emission reading during routine operating conditions. If the permittee 

observes any visible emissions, the permittee shall immediately implement the following procedures:

A. The permittee shall perform the 6-minute visible emission readings at least once every 

30 minutes until emissions are no longer visible or until emissions have been observed for more 

than two hours.

B. If visible emissions have been observed for more than two hours, a certified reader shall 

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 (Appendix A)).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 43 of 103

(R 336.1205, R 336.1301, R 336.1303, R 336.1331, R 336.1901, R 336.1911, R 336.2810, 

40 CFR 52.21(j))

4. The permittee shall install, calibrate, maintain and operate in a satisfactory manner device(s) to monitor and 

record the SO2, NOx, and CO emissions, and oxygen or carbon dioxide (O2 or CO2) content of the exhaust 

gas from EU-UNIT4-S1 on a continuous basis. The permittee shall install and operate each CEM to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52.21(j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

5. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the mercury emissions from EU-UNIT4-S1 on a continuous basis. The permittee shall install and 

operate an Hg monitor to meet the timelines, requirements and reporting detailed in Appendix B attached. 

(R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2503(2))

6. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the exhaust gas flow rate from EU-UNIT4-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in Appendix B attached. (R 336.2810, 40 CFR 52.21(j),

R 336.2902(2)(c), 40 CFR 51 (Appendix S))

7. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a device to monitor and 

record the gross energy output from EU-UNIT4-S1 on a continuous basis. The monitor shall be operated in 

accordance with procedures outlined in 40 CFR 60.49Da(k).1 (R 336.1224)

8. The permittee shall keep, in a satisfactory manner, hourly and 24-hour rolling average SO2 emission rate 

records for EU-UNIT4-S1, as described in emission limits SC I.5 and I.6, respectively. (R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j), R 336.2902(2)(c), 40 CFR 51 (Appendix S))

9. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average NOx emission rate 

and mass records for EU-UNIT4-S1, as described in emission limits SC I.7, and I.8. (R 336.2803, R 336.2804, 

R 336.2810, 40 CFR 52.21(c), (d), and (j))

10. The permittee shall keep, in a satisfactory manner, daily and 30-day rolling average CO emission rate and 

mass records for EU-UNIT4-S1, as described in emission limits SC I.9 and I.10. (R 336.2804, R 336.2810, 

40 CFR 52.21(d) and (j))

11. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average mercury emission 

rate records, expressed on a basis of gross energy output, and monthly and 12-month rolling time period

mercury mass emission rate records for EU-UNIT4-S1, as described in emission limits SC I.18 and SC I.19. 

If the monitoring required by Monitoring/Recordkeeping SC VI.4 is only capable of detecting gaseous mercury, 

the permittee shall use the testing required by Testing/Sampling SC V.9 to develop a correction factor to 

adjust the mercury monitoring data to total mercury. Based on the available testing and monitoring data, the 

correction factor may be adjusted upon review and approval of the AQD District Supervisor.1

(R 336.1224, R 336.1228, R 336.1229(2)(b)) 

12. The permittee shall maintain records of all information necessary for all notifications and reports as specified 

in these special conditions as well as that information necessary to demonstrate compliance with the emission 

limits of this permit. This information shall include, but shall not be limited to the following:

a. Compliance tests and any testing required under the special conditions of this permit;

b. Monitoring data;

c. Heat input calculations required to show compliance with SC IV.1;

d. Identification, type and the amounts of all fuels combusted in EU-UNIT4-S1 on a calendar month basis;

e. Total gigawatt-hours of energy produced on a monthly basis;

f. Records of the duration of all times EU-UNIT4-S1 is operated under start-up or shutdown conditions as 

defined in SC III.2;
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 44 of 103

g. All calculations necessary to show compliance with the limits contained in this permit.

All of the above information shall be stored in a format acceptable to the Air Quality Division and made 

available to the Department upon request. (R 336.1205(1)(a), R 336.1224, R 336.1225, R 336.1228, 

R 336.1229(2)(b), R 336.1301, R 336.1331, R 336.1401, R 336.1702(a), R 336.1901, R 336.1912, 

R 336.2802(4), R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

1. The permittee shall submit an excess emission report (EER) and summary report in an acceptable format to 

the AQD District Supervisor and the TPU Supervisor within 30 days following the end of each calendar quarter 

as specified in 40 CFR 60.7(c) and (d). The Summary Report shall follow the format of Figure 1 in 40 CFR 

60.7(d). The EER shall include the following information:

a. A report of each exceedance above the limits specified in the emission limits of this permit. This includes 

the date, time, magnitude, cause and corrective actions of all occurrences during the reporting period. 

b. A report of all periods of the Continuous Emission Monitoring and Continuous Emission Rate Monitoring 

System (CEMS/CERMS), and if applicable Predictive Emission Monitoring System (PEMS), downtime 

and corrective action.

c. A report of the total operating time of the boiler during the reporting period.

d. A report of any periods that the CEMS/CERMS, and if applicable PEMS, exceed the instrument range.

e. If no exceedances or CEMS/CERMS, and if applicable PEMS, downtime occurred during the reporting 

period, the permittee shall report that fact.

(R 336.1205, R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2803, R 336.2804, R 336.2810, 

R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.7(c) and (d))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV016-004 336 579

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804,

40 CFR 52.21 (c) and (d)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 45 of 103

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all of the applicable requirements contained in the Clean Air Interstate Rule, 

as it applies to EU-UNIT4-S1. (40 CFR Part 97)

2. The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain Program, 

as it applies to EU-UNIT4-S1. (40 CFR Parts 72 - 76)

3. The permittee shall comply with the provisions of the National Emission Standards for Hazardous Air 

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT4-S1,

by the initial compliance date. (40 CFR Part 63 Subparts A and UUUUU)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 46 of 103

The following conditions apply to: EU-WFGD-QP1

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel fuel

servicing the Unit 3 stack.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit

Time Period/ 

Operating 

Scenario

Equipment

Monitoring/

Testing 

Method

Underlying Applicable 

Requirements

1. Opacity 20 percent 6-minute 

average except 

one 6-minute 

average per 

hour of not more 

than 27 percent

EU-WFGD-QP1 GC 13 R 336.1301(1)(c), 

R 336.2810,

40 CFR 52.21(j) 

2. PM 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP1 40 CFR 

60.4211,

GC 13

R 336.2810,

40 CFR 52.21(j),

40 CFR 60.4205(b)

3. PM10 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP1 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j)

4. PM2.5 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP1 GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

5. NMHC + NOx 7.80 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP1 40 CFR 

60.4211,

GC 13

R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j),

40 CFR 60.4205(b)

6. CO 2.60 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP1 40 CFR 

60.4211,

GC 13

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j),

40 CFR 60.4205(b)

II. MATERIAL LIMITS

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP1. 

(R 336.1205(1)(a) and (1)(b), R 336.1401, R 336.2803, R 336.2804, R 336.2810, R 336.2902(2)(c), 

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.4207)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 47 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall operate and maintain EU-WFGD-QP1 according to the manufacturer’s written instructions 

or procedures that are approved by the manufacturer to ensure compliance with the applicable emission 

standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211)

2. The permittee shall not operate EU-WFGD-QP1 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar month. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e))

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP1 unless permitted by the manufacturer in writing. (40 CFR 60.4211)

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain EU-WFGD-QP1 with a non-resettable hour meter to track the number 

of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.21(j), 40 CFR 60.4209(a))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901,

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j)) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP1. 

The record shall include the time and duration of operation, and the reason the engine was in operation. The 

permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b))

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

R 336.2804, R 336.2810, R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 48 of 103

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust 

Diameter (inches)

Minimum Height Above 

Ground (feet)

Underlying Applicable 

Requirements

1. SV-WFGD-QP1 6 34

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and IIII, as they apply to EU-WFGD-QP1.

(40 CFR Part 60 Subparts A and IIII)

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 CFR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7)

3. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 49 of 103

The following conditions apply to: EU-WFGD-QP2

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel fuel

servicing the Unit 4 stack.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit

Time Period/ 

Operating 

Scenario

Equipment Monitoring/

Testing Method

Underlying Applicable 

Requirements

1. Opacity 20 percent 6-minute 

average except 

one 6-minute 

average per 

hour of not more 

than 27 percent

EU-WFGD-QP2 GC 13 R 336.1301(1)(c), R 336.2810,

40 CFR 52.21(j) 

2. PM 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP2 40 CFR 60.4211,

GC 13

R 336.2810,

40 CFR 52.21(j),

40 CFR 60.4205(b)

3. PM10 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP2 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j)

4. PM2.5 0.40 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP2 GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

5. NMHC + 

NOx

7.80 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP2 40 CFR 60.4211,

GC 13

R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j),

40 CFR 60.4205(b)

6. CO 2.60 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP2 40 CFR 60.4211,

GC 13

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j),

40 CFR 60.4205(b)

II. MATERIAL LIMITS

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP2. 

(R 336.1205(1)(a) and (1)(b), R 336.1401, R 336.2803, R 336.2804, R 336.2810, R 336.2902(2)(c),

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.4207)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 50 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall operate and maintain EU-WFGD-QP2 according to the manufacturer’s written instructions 

or procedures that are approved by the manufacturer to ensure compliance with the applicable emission 

standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211)

2. The permittee shall not operate EU-WFGD-QP2 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar month. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e))

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP2 unless permitted by the manufacturer in writing. (40 CFR 60.4211)

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain EU-WFGD-QP2 with a non-resettable hour meter to track the number 

of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.21(j), 40 CFR 60.4209(a))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901,

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j)) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP2. 

The record shall include the time and duration of operation, and the reason the engine was in operation. The 

permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b))

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

R 336.2804, R 336.2810, R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 51 of 103

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust 

Diameter (inches)

Minimum Height Above 

Ground (feet)

Underlying Applicable 

Requirements

1. SV-WFGD-QP2 6 34

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and IIII, as they apply to EU-WFGD-QP2.

(40 CFR Part 60 Subparts A and IIII)

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 CFR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7)

3. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 52 of 103

The following conditions apply to: EU-WFGD-QP3

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel fuel

servicing the Unit 1 stack.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit

Time Period/ 

Operating 

Scenario

Equipment Monitoring/

Testing Method

Underlying Applicable 

Requirements

1. Opacity 20 percent 6-minute average 

except one 6-

minute average 

per hour of not 

more than 27 

percent

EU-WFGD-QP3 GC 13 R 336.1301(1)(c), 

R 336.2810, 40 CFR 52.21(j) 

2. PM 0.15 g/hp-hr Test protocol will 

specify averaging 

time.

EU-WFGD-QP3 40 CFR 60.4211,

GC 13

R 336.2810,

40 CFR 52.21(j),

40 CFR 60.4205(b)

3. PM10 0.15 g/hp-hr Test protocol will 

specify averaging 

time.

EU-WFGD-QP3 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j)

4. PM2.5 0.15 g/hp-hr Test protocol will 

specify averaging 

time.

EU-WFGD-QP3 GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

5. NMHC + 

NOx

3.00 g/hp-hr Test protocol will 

specify averaging 

time.

EU-WFGD-QP3 40 CFR 60.4211,

GC 13

R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j),

40 CFR 60.4205(b)

6. CO 2.60 g/hp-hr Test protocol will 

specify averaging 

time.

EU-WFGD-QP3 40 CFR 60.4211,

GC 13

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j),

40 CFR 60.4205(b)

II. MATERIAL LIMITS

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP3. 

(R 336.1205(1)(a) and (1)(b), R 336.1401, R 336.2803, R 336.2804, R 336.2810, R 336.2902(2)(c), 

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.4207)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 53 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall operate and maintain EU-WFGD-QP3 according to the manufacturer’s written instructions 

or procedures that are approved by the manufacturer to ensure compliance with the applicable emission 

standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211)

2. The permittee shall not operate EU-WFGD-QP3 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar month. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e))

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP3 unless permitted by the manufacturer in writing. (40 CFR 60.4211)

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain EU-WFGD-QP3 with a non-resettable hour meter to track the number 

of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.21(j), 40 CFR 60.4209(a))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901,

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j)) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP3. 

The record shall include the time and duration of operation, and the reason the engine was in operation. The 

permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b))

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

R 336.2804, R 336.2810, R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 54 of 103

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust 

Diameter (inches)

Minimum Height Above 

Ground (feet)

Underlying Applicable 

Requirements

1. SV-WFGD-QP3 6 34

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and IIII, as they apply to EU-WFGD-QP3.

(40 CFR Part 60 Subparts A and IIII)

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 CFR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7)

3. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 55 of 103

The following conditions apply to: EU-WFGD-QP4

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel fuel

servicing the Unit 2 stack.

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit

Time Period/ 

Operating 

Scenario

Equipment Monitoring/

Testing Method

Underlying Applicable 

Requirements

1. Opacity 20 percent 6-minute 

average except 

one 6-minute 

average per 

hour of not more 

than 27 percent

EU-WFGD-QP4 GC 13 R 336.1301(1)(c), 

R 336.2810, 40 CFR 52.21(j) 

2. PM 0.15 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP4 40 CFR 60.4211,

GC 13

R 336.2810,

40 CFR 52.21(j),

40 CFR 60.4205(b)

3. PM10 0.15 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP4 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j)

4. PM2.5 0.15 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP4 GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

5. NMHC + 

NOx

3.00 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP4 40 CFR 60.4211,

GC 13

R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21(c), (d), and (j),

40 CFR 60.4205(b)

6. CO 2.60 g/hp-hr Test protocol will 

specify 

averaging time.

EU-WFGD-QP4 40 CFR 60.4211,

GC 13

R 336.2804,

R 336.2810,

40 CFR 52.21(d) and (j),

40 CFR 60.4205(b)

II. MATERIAL LIMITS

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP4. 

(R 336.1205(1)(a) and (1)(b), R 336.1401, R 336.2803, R 336.2804, R 336.2810, R 336.2902(2)(c), 

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.4207)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 56 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall operate and maintain EU-WFGD-QP4 according to the manufacturer’s written instructions 

or procedures that are approved by the manufacturer to ensure compliance with the applicable emission 

standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211)

2. The permittee shall not operate EU-WFGD-QP4 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar month. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e))

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP4 unless permitted by the manufacturer in writing. (40 CFR 60.4211)

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain EU-WFGD-QP4 with a non-resettable hour meter to track the number 

of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.21(j), 40 CFR 60.4209(a))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901,

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j)) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP4. 

The record shall include the time and duration of operation, and the reason the engine was in operation. The 

permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b))

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

R 336.2804, R 336.2810, R 336.2902(2)(c), 40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j))

VII. REPORTING

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 57 of 103

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust 

Diameter (inches)

Minimum Height Above 

Ground (feet)

Underlying Applicable 

Requirements

1. SV-WFGD-QP4 6 34

R 336.1225, R 336.1901, 

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and IIII, as they apply to EU-WFGD-QP4.

(40 CFR Part 60 Subparts A and IIII)

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 CFR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7)

3. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 58 of 103

The following conditions apply to: EU-CASCADES-S1

DESCRIPTION: This emission unit represents coal handling activity in the Cascades room. Coal handling activity 

emissions are limited by an enclosure, wet dust suppression, and baghouse dust collectors. 

Flexible Group ID: FG-ProjectPC1-4

POLLUTION CONTROL EQUIPMENT: Cascade room dust collector (SV-D1), Cascade room dust collector (SVD2), Cascade room dust collector (SV-D3), Cascade room dust collector (SV-D4), Cascade room dust collector 

(SV-D5), Cascade room dust collector (SV-D6), enclosures, water sprays, and/or dust suppressants. 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent Test protocol 

will specify 

averaging time.

Exhaust vents 

SV-D1, SV-D2, 

SV-D3 

SC VI.3 R 336.1301(1)(c) 

2. Opacity 5 percent Test protocol 

will specify 

averaging time.

Exhaust vents 

SV-D4, SV-D5, 

SV-D6

SC VI.3 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j)

3. PM 0.020 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

SV-D1,

SV-D2,

SV-D3

GC 13 R 336.1331(1)(c)

4. PM 0.004 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

SV-D4,

SV-D5,

SV-D6

GC 13 R 336.1331(1)(c),

R 336.2810,

40 CFR 52.21(j)

5. PM10 5.95 pph Test protocol 

will specify 

averaging time.

SV-D1 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d) 

6. PM2.5 5.95 pph Test protocol 

will specify 

averaging time.

SV-D1 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

7. PM10 5.95 pph Test protocol 

will specify 

averaging time.

SV-D2 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

8. PM2.5 5.95 pph Test protocol 

will specify 

averaging time.

SV-D2 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

9. PM10 5.95 pph Test protocol 

will specify 

averaging time.

SV-D3 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

10. PM2.5 5.95 pph Test protocol 

will specify 

averaging time.

SV-D3 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

11. PM10 1.19 pph Test protocol 

will specify 

averaging time.

SV-D4 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21 (c), (d) and (j)

12. PM2.5 1.19 pph Test protocol 

will specify 

averaging time.

SV-D4 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

13. PM10 1.19 pph Test protocol 

will specify 

averaging time.

SV-D5 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21 (c), (d) & (j)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 59 of 103

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

14. PM2.5 1.19 pph Test protocol 

will specify 

averaging time.

SV-D5 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

15. PM10 1.21 pph Test protocol 

will specify 

averaging time.

SV-D6 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21 (c), (d) and (j)

16. PM2.5 1.21 pph Test protocol 

will specify 

averaging time.

SV-D6 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-CASCADES-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any time 

the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)

2. The permittee shall not operate EU-CASCADES-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), 

and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-CASCADES-S1 unless the associated enclosures, 

water sprays, and fabric filters are installed, maintained and operated in a satisfactory manner. The permittee 

shall equip each fabric filter with broken bag leak detectors, or an alternative monitoring 

method approved in writing by the AQD District Supervisor. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-CASCADES-S1 as required 

in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 60 of 103

2. The permittee shall not operate EU-CASCADES-S1 unless the external conveyor hoods or enclosures 

are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-CASCADES-S1 

as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d) and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the PM2.5 emission rates from EU-CASCADES-S1 or a representative emission 

unit by testing at owner’s expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less than 

60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The final plan must be approved by the AQD prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and 

District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R

336.2902(2)(c), 40 CFR 51 (Appendix S))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative 

monitoring measures, as approved by the AQD District Supervisor on each fabric filter of 

EU-CASCADES-S1. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations as 

required in Emission Limit SC I.1 and I.2 on a daily basis when EU-CASCADES-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity 

from that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 

40 CFR 52.21 (j))

VII. REPORTING

1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-CASCADES-S1. (R 336.1201(7)(b))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 61 of 103

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground (feet)

Underlying Applicable 

Requirements

1. SV-D1 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

2. SV-D2 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

3. SV-D3 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

4. SV-D4 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

5. SV-D5 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

6. SV-D6 38 200

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 62 of 103

The following conditions apply to: EU-TRANSFERHS-S1

DESCRIPTION: This emission unit represents coal handling activity in the Transfer House. Coal handling activity 

emissions are limited by an enclosure, wet dust suppression, and baghouse dust collectors.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Transfer house 1 dust collector (SV-DC01/DC22), Transfer house 1 dust 

collector (SV-DC02/DC23), Transfer house 2 dust collector (SV-DC21), Transfer house 2 dust collector (SVDC15), Transfer house 9 dust collector (SV-DC17), Transfer house 11 dust collector (SV-DC19), Transfer house 

3 dust collector (SV-DC04), enclosures, water sprays, and/or dust suppressants. 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 5 percent Test protocol 

will specify 

averaging time.

Each individual fabric 

filter in 

EU-TRANSFERHS-S1 

(vents SV-DC01/DC22, 

SV-DC02/DC23, 

SV-DC21, SV-DC15, 

SV-DC17, SV-DC19, 

SV-DC04)

SC VI.3 R 336.1301(1)(c),

R 336.2810, 

40 CFR 52.21 (j) 

2. PM 0.010 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

SV-DC01/DC22, 

SV-DC02/DC23,

SV-DC21, SV-DC15

GC 13 R 336.1331(1)(c)

3. PM 0.020 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

SV-DC17,

SV-DC19

GC 13 R 336.1331(1)(c)

4. PM 0.004 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

SV-DC04 GC 13 R 336.1331(1)(c), 

R 336.2810, 

40 CFR 52.21 (j) 

5. PM10 1.93 pph Test protocol 

will specify 

averaging time.

SV-DC01/DC22 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

6. PM2.5 1.93 pph Test protocol 

will specify 

averaging time.

SV-DC01/DC22 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

7. PM10 1.93 pph Test protocol 

will specify 

averaging time.

SV-DC02/DC23 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

8. PM2.5 1.93 pph Test protocol 

will specify 

averaging time.

SV-DC02/DC23 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

9. PM10 1.29 pph Test protocol 

will specify 

averaging time.

SV-DC21 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

10. PM2.5 1.29 pph Test protocol 

will specify 

averaging time.

SV-DC21 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 63 of 103

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

11. PM10 1.54 pph Test protocol 

will specify 

averaging time.

SV-DC15 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

12. PM2.5 1.54 pph Test protocol 

will specify 

averaging time.

SV-DC15 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

13. PM10 2.40 pph Test protocol 

will specify 

averaging time.

SV-DC17 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

14. PM2.5 2.40 pph Test protocol 

will specify 

averaging time.

SV-DC17 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

15. PM10 2.74 pph Test protocol 

will specify 

averaging time.

SV-DC19 GC 13 R 336.2803, R 336.2804, 

R 336.2810,

40 CFR 52.21 (c) and (d)

16. PM2.5 2.74 pph Test protocol 

will specify 

averaging time.

SV-DC19 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

17. PM10 0.89 pph Test protocol 

will specify 

averaging time.

SV-DC04 GC 13 R 336.2803, R 336.2804, R 

336.2810, 

40 CFR 52.21 (c), (d) and (j)

18. PM2.5 0.89 pph Test protocol 

will specify 

averaging time.

SV-DC04 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-TRANSFERHS-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 64 of 103

2. The permittee shall not operate EU-TRANSFERHS-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept at 

the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. 

The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the 

AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of 

submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is approved, the 

permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j))

3. The permittee shall not operate the Transfer House 1 and Transfer House 2 portions of 

EU-TRANSFERHS-S1 for more than 12 hours per calendar day. (R 336.1205(1)(a), R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-TRANSFERHS-S1 unless the associated enclosures, water 

sprays, and fabric filters are installed, maintained and operated in a satisfactory manner. The permittee shall 

equip each fabric filter with broken bag leak detectors, or an alternative monitoring method approved in writing 

by the AQD District Supervisor. Satisfactory manner includes operating and maintaining each control device 

in accordance with an approved MAP for EU-TRANSFERHS-S1 as required in SC III.2. (R 336.1901, 

R 336.1910, R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c), and (d))

2. The permittee shall not operate EU-TRANSFERHS-S1 unless the external conveyor hoods or 

enclosures are installed, maintained and operated in a satisfactory manner. Satisfactory manner 

includes operating and maintaining each control device in accordance with an approved MAP for 

EU-TRANSFERHS-S1 as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, 40 CFR 52.21 (c) and (d))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the PM2.5 emission rates from EU-TRANSFERHS-S1 or a representative emission 

unit by testing at owner’s expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less than 

60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The final plan must be approved by the AQD prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and 

District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 

336.2902(2)(c), 40 CFR 51 (Appendix S))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative monitoring 

measures, as approved by the AQD District Supervisor on each fabric filter of EU-TRANSFERHS-S1. 

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 65 of 103

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations as 

required in Emission Limit SC I.1 on a daily basis when EU-TRANSFERHS-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity 

from that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 

40 CFR 52.21 (j))

4. The permittee shall keep, in a satisfactory manner, daily records of the Transfer House 1 

and Transfer House 2 portions of EU-TRANSFERHS-S1. (R 336.1205(1)(a), R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d))

VII. REPORTING

1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-TRANSFERHS-S1. (R 336.1201(7)(b))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted with an asterisk(*) indicating a non-vertical discharge:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground (feet)

Underlying Applicable 

Requirements

1. SV-DC01/DC22* 55 40

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

2. SV-DC02/DC23* 55 40

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

3. SV-DC21* 51 16

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

4. SV-DC15* 30 50

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

5. SV-DC17* 30 46

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

6. SV-DC19* 30 121

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

7. SV-DC04 41 20

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 66 of 103

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 67 of 103

The following conditions apply to: EU-DUMPERHS-S1

DESCRIPTION: This emission unit represents coal handling activity in the Dumper House. Coal handling activity 

emissions are limited by an enclosure, wet dust suppression, and/or baghouse dust collectors.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Dumper house dust collector (SV-DC24), enclosures and dust 

suppressants. 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 5 percent Test protocol will 

specify averaging 

time.

SV-DC24 SC VI.3 R 336.1301(1)(c) 

2. PM 0.005 gr / dscf 

of exhaust 

gases

Test protocol will 

specify averaging 

time.

SV-DC24 GC 13 R 336.1331(1)(c)

3. PM10 6.44 pph Test protocol will 

specify averaging 

time.

SV-DC24 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

4. PM2.5 6.44 pph Test protocol will 

specify averaging 

time.

SV-DC24 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-DUMPERHS-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any time 

the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 68 of 103

2. The permittee shall not operate EU-DUMPERHS-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), 

and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-DUMPERHS-S1 unless the associated enclosures, 

water sprays, and fabric filters are installed, maintained and operated in a satisfactory manner. The permittee 

shall equip each fabric filter with broken bag leak detectors, or an alternative monitoring 

method approved in writing by the AQD District Supervisor. Satisfactory manner includes operating 

and maintaining each control device in accordance with an approved MAP for EU-DUMPERHS-S1 

as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))

2. The permittee shall not operate EU-DUMPERHS-S1 unless the external conveyor hoods are 

installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-DUMPERHS-S1 as 

required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the PM2.5 emission rates from EU-DUMPERHS-S1 or a representative emission 

unit by testing at owner’s expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less than 

60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The final plan must be approved by the AQD prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and 

District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 

336.2902(2)(c), 40 CFR 51 (Appendix S))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative 

monitoring measures, as approved by the AQD District Supervisor on each fabric filter of 

EU-DUMPERHS-S1. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 69 of 103

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations as 

required in Emission Limit SC I.1 on a daily basis when EU-DUMPERHS-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity 

from that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground (feet)

Underlying Applicable 

Requirements

1. SV-DC24North 48 25

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

2. SV-DC24South 48 25

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 70 of 103

The following conditions apply to: EU-COALUNLOAD-S1

DESCRIPTION: This emission unit represents the coal unloading activities from Great Lakes ships and includes 

storage and pile maintenance. Coal handling activity emissions are limited by an enclosures and wet dust 

suppression methods.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Coal handling activity emissions are limited by an enclosures and wet 

suppression methods.

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying 

Applicable 

Requirements

1. Opacity 10 percent Test protocol 

will specify 

averaging time.

The drop points and 

transfer points of 

EU-COALUNLOAD-S1

SC VI.2 R 336.1301(1)(c) 

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-COALUNLOAD-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)

2. The permittee shall not operate EU-COALUNLOAD-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept at 

the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. 

The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the 

AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of 

submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is approved, the 

permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 71 of 103

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-COALUNLOAD-S1 unless the associated enclosures and 

water sprays are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-COALUNLOAD-S1 as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, 40 CFR 52.21 (c) and (d))

2. The permittee shall not operate EU-COALUNLOAD-S1 unless the external conveyor hoods or 

enclosures are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-COALUNLOAD-S1 as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, 40 CFR 52.21 (c) and (d))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-COALUNLOAD-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

NA

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 72 of 103

The following conditions apply to: EU-CRUSHERHS-S1

DESCRIPTION: This emission unit represents coal handling activity in the Crusher House. Coal handling activity 

emissions are limited by an enclosure and baghouse dust collectors.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Transfer house 4 dust collector (SV-DC05)

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 5 percent Test protocol will 

specify averaging 

time.

Each individual fabric 

filter in 

EU-CRUSHERHS-S1

SC VI.3 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j) 

2. PM 0.004 gr / dscf 

of exhaust 

gases

Test protocol will 

specify averaging 

time.

Each individual fabric 

filter in 

EU-CRUSHERHS-S1

GC 13 R 336.1331, R 336.2810, 

40 CFR 52.21 (j)

3. PM10 0.99 pph Test protocol will 

specify averaging 

time.

SV-DC05 GC 13 R 336.2803, R 336.2804, 

40 CFR 52.21 (c), (d) and (j)

4. PM2.5 0.99 pph Test protocol will 

specify averaging 

time.

SV-DC05 SC V.1 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-CRUSHERHS-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 73 of 103

2. The permittee shall not operate EU-CRUSHERHS-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), 

and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-CRUSHERHS-S1 unless the associated enclosures and 

fabric filters are installed, maintained and operated in a satisfactory manner. The permittee shall equip each 

fabric filter with broken bag leak detectors, or an alternative monitoring method approved in writing by the 

AQD District Supervisor. Satisfactory manner includes operating and maintaining each control device in 

accordance with an approved MAP for EU-CRUSHERHS-S1 as required in SC III.2. (R 336.1901, 

R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j))

2. The permittee shall not operate EU-CRUSHERHS-S1 unless the external conveyor hoods or enclosures are 

installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-CRUSHERHS-S1 as required 

in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d) and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall verify the PM2.5 emission rates from EU-CRUSHERHS-S1 or a representative emission 

unit by testing at owner’s expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less than 

60 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit 

and District Office. The final plan must be approved by the AQD prior to testing. Verification of emission 

rates includes the submittal of a complete report of the test results to the AQD Technical Programs Unit and 

District Office within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 

336.2902(2)(c), 40 CFR 51 (Appendix S))

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative 

monitoring measures, as approved by the AQD District Supervisor on each fabric filter of 

EU-CRUSHERHS-S1. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 74 of 103

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations as 

required in Emission Limit SC I.1 on a daily basis when EU-CRUSHERHS-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity 

from that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 

40 CFR 52.21 (j))

VII. REPORTING

1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-CRUSHERHS-S1. (R 336.1201(7)(b))

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted with an asterisk (*) indicating a non-vertical discharge:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground (feet)

Underlying Applicable 

Requirements

1. SV-DC05* 30 40

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 75 of 103

The following conditions apply to: EU-REFHS&BL-S1

DESCRIPTION: This emission unit represents coal and sorbent handling activity in the REF Transfer House and 

Refined Coal Plant Building including an 8,500 gallon Mersorb storage tank, a 750 ton S-Sorb solid storage silo, 

associated conveyors, and any trucking and unloading activities. Sorbent handling activity inside the Refined 

Coal Plant Building includes two pug mills, two day bins, conveying and mixing operations. Coal and sorbent 

handling activity emissions are limited by enclosures, baghouse dust collectors, wet dust suppression methods, 

or bin vent filters.

Flexible Group ID: NA 

POLLUTION CONTROL EQUIPMENT: REF Transfer house dust collector #1 (SV-REFDC01), Refined Coal 

Plant Building Transfer dust collector #2 (SV-REFDC02), storage silo with a bin vent filter (SV-REFBV), enclosures 

and dust suppressants

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 5 percent Test protocol 

will specify 

averaging time.

Each individual 

fabric filter and bin 

vent filter in 

EU-REFHS&BL-S1

SC VI.2 R 336.1301(1)(c),

40 CFR 60.254(b)(1)

2. PM 0.004 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging time.

Each individual 

fabric filter and bin 

vent filter in 

EU-REFHS&BL-S1

GC 13 R 336.1205,

R 336.1331(1)(c),

40 CFR 60.254(b)(2)

3. PM10 0.21 pph Test protocol 

will specify 

averaging time.

Each individual 

fabric filter 

SV-REFDC01 and 

SV-REFDC02

GC 13 R 336.1205,

R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

4. PM2.5 0.21 pph Test protocol 

will specify 

averaging time.

Each individual 

fabric filter 

SV-REFDC01 and 

SV-REFDC02

GC 13 R 336.1205

5. PM10 0.041 pph Test protocol 

will specify 

averaging time.

SV-REFBV GC 13 R 336.1205,

R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

6. PM2.5 0.041 pph Test protocol 

will specify 

averaging time.

SV-REFBV GC 13 R 336.1205

II. MATERIAL LIMITS

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 76 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-REFHS&BL-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any time 

the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d), Act 451 Section 324.5524)

2. The permittee shall not operate EU-REFHS&BL-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-REFHS&BL-S1 unless the associated enclosures, fabric 

filters, and bin vent filter are installed, maintained and operated in a satisfactory manner. Satisfactory manner 

includes operating and maintaining each control device in accordance with an approved MAP 

for EU-REFHS&BL-S1 as required in SC III.2. (R 336.1910, R 336.1911, R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d))

2. The permittee shall not operate EU-REFHS&BL-S1 unless the external conveyor hoods or enclosures are 

installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-REFHS&BL-S1 as required in 

SC III.2. (R 336.1910, R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1301) 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 77 of 103

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-REFHS&BL-S1 is operating. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), 40 CFR 60.254)

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted with an asterisk (*) indicating a non-vertical discharge:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground (feet)

Underlying Applicable 

Requirements

1. SV-REFDC01* 14 x 20 53

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

2. SV-REFDC02* 14 x 20 40

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

3. SV-REFBV* 14 x 14 64

R 336.1901, R 336.2803,

R 336.2804, 

40 CFR 52.21 (c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and Y, as they apply to EU-REFHS&BL-S1. (40 CFR Part 

60 Subparts A and Y)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 78 of 103

The following conditions apply to: EU-PETCOKE-S1

DESCRIPTION: This emission unit represents petroleum coke handling activity, including roadway traffic and pile 

maintenance. Emissions are limited by partial enclosures, including a portable wind screen, and wet dust 

suppression.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Partial enclosures, including a portable wind screen, and dust 

suppressants. 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent Test protocol 

will specify 

averaging time.

The drop points and 

transfer points of 

EU-PETCOKE-S1

SC VI.2 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-PETCOKE-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any time 

the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)

2. The permittee shall not operate EU-PETCOKE-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), 

and (j))

3. The permittee shall not operate the wheeled traffic portion of EU-PETCOKE-S1 for more than 16 hours per 

calendar day. (R 336.1205(1)(a), R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 79 of 103

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-PETCOKE-S1 unless the associated enclosures and water 

sprays are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for EU-PETCOKE-S1 

as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j))

2. The permittee shall not operate EU-PETCOKE-S1 unless the enclosures are installed, maintained and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP for EU-PETCOKE-S1 as required in SC III.2. (R 336.1901, 

R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j))

3. The permittee shall not operate the haul truck activities associated with EU-PETCOKE-S1 unless the wheel 

wash system is installed, maintained, and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for EU-PETCOKE-S1 

as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d) and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-PETCOKE-S1 is operating. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 40 CFR 52.21 (j))

3. The permittee shall keep, in a satisfactory manner, daily records of the hours of operation of the wheeled 

traffic portion of EU-PETCOKE-S1. (R 336.1205(1)(a), R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))

VII. REPORTING

1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-PETCOKE-S1. (R 336.1201(7)(b))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 80 of 103

VIII. STACK/VENT RESTRICTIONS

NA

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 81 of 103

The following conditions apply to: EU-LIMESTONE-S1

DESCRIPTION: This emission unit represents limestone handling activities and includes the ship unloading 

process, storage and pile maintenance, and reclaim activities – including any trucking activities, and the Prep 

building. Limestone handling activity emissions are limited by enclosures, wet dust suppression methods, or bin 

vent filters.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Three silos each with a bin vent filter (SV-26A). Limestone handling 

activity emissions are limited by enclosures, wet suppression methods, or bin vent filters.

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent Test protocol 

will specify 

averaging 

time.

Any exterior drop 

points and transfer 

points of 

EU-LIMESTONE-S1

SC VI.2 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j), 

40 CFR 60.672(b)

2. Opacity 5 percent Test protocol 

will specify 

averaging 

time.

Each bin vent filter in 

EU-LIMESTONE-S1 

(SV-26A)

SC VI.3 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j), 

40 CFR 60.672(a)(2)

3. PM 0.004 gr / dscf 

of exhaust 

gases

Test protocol 

will specify 

averaging 

time.

SV-26A GC 13 R 336.1331, R 336.2810, 

40 CFR 52.21 (j)

4. PM10 0.0046pph Test protocol 

will specify 

averaging 

time.

SV-26A GC 13 R 336.2803, R 336.2804,

R 336.2810,

40 CFR 52.21 (c), (d) and (j)

5. PM2.5 0.0046 pph Test protocol 

will specify 

averaging 

time.

SV-26A GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 82 of 103

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-LIMESTONE-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any time 

the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)

2. The permittee shall not operate EU-LIMESTONE-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemented, updated as necessary, and kept at the facility. 

If at any time the MAP fails to address or inadequately addresses an event that meets the characteristics of 

a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. The permittee 

shall also amend the MAP within 45 days, if new equipment is installed or upon request from the AQD District 

Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the AQD District 

Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of submittal, the 

MAP or amended MAP shall be considered approved. Until an amended plan is approved, the permittee shall 

implement corrective procedures or operational changes to achieve compliance with all applicable emission 

limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), 

and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-LIMESTONE-S1 unless the associated pollution control 

equipment is installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-LIMESTONE-S1 as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, 

R 336.2810, 40 CFR 52.21 (c), (d), and (j))

2. The permittee shall not operate EU-LIMESTONE-S1 unless the external conveyor hoods are installed, 

maintained and operated in a satisfactory manner. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-LIMESTONE-S1 as required in SC III.2. 

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 83 of 103

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-LIMESTONE-S1 is operating. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 40 CFR 52.21 (j), 40 CFR 60.676))

3. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.2 on a daily basis when EU-LIMESTONE-S1 is operating. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 40 CFR 52.21 (j), 40 CFR 60.676)

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack and Vent ID

Maximum Exhaust

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV-26A1* 12 115

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

2. SV-26A2* 12 115

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

3. SV-26A3* 12 115

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

*Stack/Vents discharged non-vertically.

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and OOO, as they apply to EU-LIMESTONE-S1. 

(40 CFR Part 60 Subparts A and OOO)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 84 of 103

The following conditions apply to: EU-GYPSUMHAND-S1

DESCRIPTION: This emission unit represents gypsum handling activity in the gypsum dewatering building and 

the gypsum storage and loading building. Gypsum handling activity emissions are limited by a building enclosure.

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Loading operations take place in a building.

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 7 percent Test protocol will 

specify 

averaging time.

The gypsum storage 

and handling building 

portion of 

EU-GYPSUMHAND-S1

SC VI.2 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j), 

40 CFR 60.672(e)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-GYPSUMHAND-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)

2. The permittee shall not operate EU-GYPSUMHAND-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept at 

the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. 

The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the 

AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of 

submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is approved, the 

permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 85 of 103

3. The permittee shall not operate the haul truck activities associated with EU-GYPSUMHAND-S1 for more than 

16 hours per calendar day. (R 336.1205(1)(a), R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate EU-GYPSUMHAND-S1 unless the associated enclosures are installed, 

maintained and operated in a satisfactory manner. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-GYPSUMHAND-S1 as required in SC III.2.

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j))

2. The permittee shall not operate the haul truck activities associated with EU-GYPSUMHAND-S1 unless the 

wheel wash system is installed, maintained, and operated in a satisfactory manner. Satisfactory manner 

includes operating and maintaining each control device in accordance with an approved MAP for 

EU-GYPSUMHAND-S1 as required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-GYPSUMHAND-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 40 CFR 52.21 (j), 40 CFR 60.676)

3. The permittee shall keep, in a satisfactory manner, daily records of the hours of operation for the haul truck 

activities associated with EU-GYPSUMHAND-S1. (R 336.1205(1)(a), R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 86 of 103

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and OOO, as they apply to EU-GYPSUMHAND-S1. 

(40 CFR Part 60 Subparts A and OOO)

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 87 of 103

The following conditions apply to: EU-HYDRATEDLIME-S1

DESCRIPTION: Storage and handling of hydrated lime. Hydrated lime is delivered via truck to facility for silo

storage. 

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Bin vent filters (SV-26B), enclosures and dust suppressants. 

I. EMISSION LIMITS

Pollutant Limit

Time Period /

Operating

Scenario

Equipment

Testing / 

Monitoring 

Method

Underlying Applicable 

Requirements

1. Opacity 10 percent Test protocol will 

specify averaging 

time.

Any exterior drop points 

and transfer points of 

EU-HYDRATEDLIME-S1 

SC VI.2 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j)

2. Opacity 5 percent Test protocol will 

specify averaging 

time.

Each bin vent filter in 

EU-HYDRATEDLIME-S1 

(SV-26B)

SC VI.3 R 336.1301(1)(c),

R 336.2810,

40 CFR 52.21 (j)

3. PM 0.004 gr / 

dscf of 

exhaust 

gases

Test protocol will 

specify averaging 

time.

SV-26B GC 13 R 336.1331, R 336.2810, 

40 CFR 52.21 (j)

4. PM10 0.045 pph Test protocol will 

specify averaging 

time.

SV-26B GC 13 R 336.2803, R 336.2804,

R 336.2810,

40 CFR 52.21 (c), (d) and (j)

5. PM2.5 0.045 pph Test protocol will 

specify averaging 

time.

SV-26B GC 13 R 336.2902(2)(c), 

40 CFR 51 (Appendix S)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-HYDRATEDLIME-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee shall 

amend the fugitive dust control program within 45 days after such an event occurs. The permittee shall also 

amend the fugitive dust control program within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the fugitive dust control program and any 

amendments to the fugitive dust control program to the AQD District Supervisor for review and approval. If 

the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control program or 

amended fugitive dust control program shall be considered approved. Until an amended plan is approved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 88 of 103

2. The permittee shall not operate EU-HYDRATEDLIME-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept at 

the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event occurs. 

The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon request from 

the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the MAP to the 

AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 90 days of 

submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is approved, the 

permittee shall implement corrective procedures or operational changes to achieve compliance with all 

applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 

CFR 52.21 (c), (d), and (j))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall not operate any portion of EU-HYDRATEDLIME-S1 unless the pollution control equipment 

is installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-HYDRATEDLIME-S1 as 

required in SC III.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 

52.21 (c), (d), and (j))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.1 on a daily basis when EU-HYDRATEDLIME-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 40 CFR 52.21 (j))

3. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC I.2 on a daily basis when EU-HYDRATEDLIME-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that emission 

point. Records of the non-certified visible emissions observations, USEPA Method 9 observations that are 

performed, the reason for any visible emissions observed and any corrective actions taken shall be kept on 

file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d) and (j))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS
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Permit No. 27-13A Page 89 of 103

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack and Vent ID

Maximum Exhaust 

Diameter/Dimensions 

(inches)

Minimum Height 

Above Ground 

(feet)

Underlying Applicable 

Requirements

1. SV-26B1* 18 89

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

1. SV-26B2* 18 89

R 336.1901, R 336.2803,

R 336.2804,

40 CFR 52.21 (c) and (d)

*Stack/Vents discharged non-vertically.

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 90 of 103

FLEXIBLE GROUP SUMMARY TABLE

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Flexible Group ID Flexible Group Description Associated

Emission Unit IDs

FG-ProjectPC1-4 The project is to increase the capacity to use 

subbituminous coal and add petroleum coke to provide 

additional fuels for Units 1, 2, 3, and 4; installation of four

(4) wet FGD quench pumps; modifications to the fuel 

handling systems; the installation of new material 

handling systems for limestone and gypsum; and the 

installation of a new fuel handling system for petroleum 

coke. This results in a minor nonattainment source 

modification by use of the actual-to-projected-actual 

applicability test.

EU-UNIT1-S1, 

EU-UNIT2-S1, 

EU-UNIT3-S1, 

EU-UNIT4-S1, 

EU-WFGD-QP1, 

EU-WFGD-QP2, 

EU-WFGD-QP3, 

EU-WFGD-QP4, 

EU-CASCADES-S1, 

EU-TRANSFERHS-S1, 

EU-DUMPERHS-S1, 

EU-COALUNLOAD, 

EU-CRUSHERHS-S1, 

EU-PETCOKE-S1, 

EU-LIMESTONE-S1, 

EU-GYPSUMHAND-S1, 

EU-HYDRATELIME-S1

FGAUXBOILERS-S1 North and South Auxiliary Boilers EU-NORTHAUX-S1,

EU-SOUTHAUX-S1

FGPEAKERS-S2 Five diesel fuel-fired generator peaking units that are 

limited use stationary reciprocating internal combustion 

engines.

EU-DIESEL11-1-S2, 

EU-DIESEL11-2-S2, 

EU-DIESEL11-3-S2, 

EU-DIESEL11-4-S2, 

EU-DIESEL11-5-S2

FGUNITS1&2TEMP Boilers 1 and 2 EU-UNIT1-S1, 

EU-UNIT2-S1
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 91 of 103

The following conditions apply to: FG-ProjectPC1-4

DESCRIPTION: The project is to increase the capacity to use subbituminous coal and add petroleum coke to 

provide additional fuels for Units 1, 2, 3, and 4; installation of four (4) wet FGD quench pumps; modifications to 

the fuel handling systems; the installation of new material handling systems for limestone and gypsum; and the 

installation of a new fuel handling system for petroleum coke. This results in a minor nonattainment source 

modification by use of the actual-to-projected-actual applicability test.

Emission Units: EU-UNIT1-S1, EU-UNIT2-S1, EU-UNIT3-S1, EU-UNIT4-S1, EU-WFGD-QP1, 

EU-WFGD-QP2, EU-WFGD-QP3, EU-WFGD-QP4, EU-CASCADES-S1, EU-TRANSFERHS-S1, 

EU-DUMPERHS-S1, EU-COALUNLOAD-S1, EU-CRUSHERHS-S1, EU-PETCOKE-S1, EU-LIMESTONE-S1, 

EU-GYPSUMHAND-S1, and EU-HYDRATELIME-S1

POLLUTION CONTROL EQUIPMENT: NA 

I. EMISSION LIMITS

NA

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

NA

IV. DESIGN/EQUIPMENT PARAMETERS

NA

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901, 

R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 92 of 103

2. The permittee shall calculate and keep records of PM2.5 and SO2 emissions from EU-UNIT1-S1, 

EU-UNIT2-S1, EU-UNIT3-S1, EU-UNIT4-S1, EU-WFGD-QP1, EU-WFGD-QP2, EU-WFGD-QP3, and 

EU-WFGD-QP4 in tons per calendar year. The recordkeeping period shall begin on the first day of the month 

during which EU-UNIT3-S1 and EU-UNIT4-S1 commences operation (after the modification) and continues 

for consecutive calendar months. The calculations and records shall be kept in the format described in 

Appendix C, or an alternative format acceptable to the AQD Permit Section Supervisor. The requirement to 

calculate and keep records shall end ten years after EU-UNIT1-S1, EU-UNIT2-S1, 

EU-UNIT3-S1, EU-UNIT4-S1, EU-WFGD-QP1, EU-WFGD-QP2, EU-WFGD-QP3, and EU-WFGD-QP4 

completes the modification as approved by the AQD Permit Section Supervisor. The permittee shall keep all 

records on file and make them available to the Department upon request. (R 336.2902(2)(c), 

40 CFR 51 (Appendix S))

3. The permittee shall calculate and keep records of PM2.5 emissions from EU-CASCADES-S1, 

EU-TRANSFERHS-S1, EU-DUMPERHS-S1, EU-COALUNLOAD-S1, EU-CRUSHERHS-S1, 

EU-PETCOKE-S1, EU-LIMESTONE-S1, EU-GYPSUMHAND-S1, and EU-HYDRATELIME-S1 in tons per 

calendar year. The recordkeeping period shall begin on the first day of the month during which 

EU-CASCADES-S1, EU-TRANSFERHS-S1, EU-DUMPERHS-S1, EU-COALUNLOAD-S1, 

EU-CRUSHERHS-S1, EU-PETCOKE-S1, EU-LIMESTONE-S1, EU-GYPSUMHAND-S1, and 

EU-HYDRATELIME-S1 commences operation (after the modification) and continues for consecutive calendar 

months. The calculations and records shall be kept in the format described in Appendix C, or an alternative 

format acceptable to the AQD Permit Section Supervisor. The requirement to calculate and keep records 

shall end ten years after EU-CASCADES-S1, EU-TRANSFERHS-S1, EU-DUMPERHS-S1,

EU-COALUNLOAD-S1, EU-CRUSHERHS-S1, EU-PETCOKE-S1, EU-LIMESTONE-S1, 

EU-GYPSUMHAND-S1, and EU-HYDRATELIME-S1 completes the modification/installation as approved by 

the AQD Permit Section Supervisor. The permittee shall keep all records on file and make them available to 

the Department upon request. (R 336.2902(2)(c), 40 CFR 51 (Appendix S))

VII. REPORTING

1. The permittee shall submit records of PM2.5 and SO2 emissions from FG-ProjectPC1-4 in tons per calendar 

year to both the AQD Permit Section Supervisor and the AQD District Supervisor within 60 days following the 

end of each calendar year identified in FG-ProjectPC1-4 SC VI.2 and SC VI.3. In addition, the records shall 

identify the following: 

a. Exceedences of the yearly actual emission of PM2.5 and SO2 above the baseline actual emissions (BAE) 

by a significant amount, and 

b. Identify if the year’s actual emissions differ from the pre-construction projection. The pre-construction

projection is the sum of the projected actual emissions from each existing emission unit and the potential 

emissions from each new emission unit included in the Hybrid Applicability Test used for 

FG-ProjectPC1-4.

The report shall contain the name, address, and telephone number of the facility (major stationary source); 

the annual emissions as calculated pursuant to FG-ProjectPC1-4, SC VI.2 and SC VI.3, and any other 

information the owner or operator wishes to include (i.e., an explanation why emissions differ from the 

pre-construction projection). (R 336.2902(2)(c), 40 CFR 51 (Appendix S))

VIII. STACK/VENT RESTRICTIONS

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 93 of 103

IX. OTHER REQUIREMENTS

NA

Footnotes:

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 94 of 103

The following conditions apply to: FGAUXBOILERS-S1

DESCRIPTION: North and south auxiliary boilers.

Emission Unit: EU-NORTHAUX-S1, EU-SOUTHAUX-S1

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit

Time Period/ 

Operating 

Scenario

Equipment

Monitoring/

Testing 

Method

Underlying Applicable 

Requirements

1. NOx 33.3 pph per boiler Test protocol will 

specify averaging 

time.

EU-NORTHAUX-S1, 

EU-SOUTHAUX-S1

GC 13 R 336.2804, 

40 CFR 52.21(d)

2. SO2 0.33 pph per boiler Test protocol will 

specify averaging 

time.

EU-NORTHAUX-S1, 

EU-SOUTHAUX-S1

GC 13 R 336.1401,

R 336.2803, 

R 336.2804, 

40 CFR 52.21(c) and (d)

II. MATERIAL LIMITS

1. The permittee shall only burn No. 2 fuel oil with a maximum sulfur content of 15 ppm in 

FGAUXBOILERS-S1. (R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not burn any fuel in the two auxiliary boilers other than No. 2 fuel oil without prior 

notification to and approval by the AQD.2 (R 336.1201(3))

IV. DESIGN/EQUIPMENT PARAMETERS

1. NA

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1401, R 336.2803, 

R 336.2804, 40 CFR 52.21(c) and (d))

2. The permittee shall record the monthly fuel oil usage rates in gallons. (R 336.1401, R 336.2803, 

R 336.2804, 40 CFR 52.21(c) and (d))
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 95 of 103

3. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of 

delivery, analytical results from laboratory testing, or any other records adequate to demonstrate compliance 

with the percent sulfur limit in fuel oil. (R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d))

4. The permittee shall monitor and record in a satisfactory manner, the monthly hours of operation for each 

auxiliary boiler in FGAUXBOILERS-S1. The permittee shall keep all records on file for a period of at least five 

years and make them available to the Department upon request. (R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum 

Exhaust 

Dimensions

(inches)

Minimum Height 

Above Ground

(feet)

Underlying Applicable 

Requirements

1. SV015-003 108 231 R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

NA

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 96 of 103

The following conditions apply to: FGPEAKERS-S2

DESCRIPTION: Five diesel fuel-fired generator peaking units that are limited use stationary reciprocating internal 

combustion engines.

Emission Units: EU-DIESEL11-1-S2, EU-DIESEL11-2-S2, EU-DIESEL11-3-S2, EU-DIESEL11-4-S2, 

EU-DIESEL11-5-S2

POLLUTION CONTROL EQUIPMENT: NA

I. EMISSION LIMITS

Pollutant Limit Time Period/ 

Operating Scenario Equipment

Monitoring/

Testing 

Method

Underlying Applicable 

Requirements

1. NOx 90.2 pph per 

unit

Test protocol 

will specify averaging 

time.

EU-DIESEL11-1-S2, 

EU-DIESEL11-2-S2, 

EU-DIESEL11-3-S2, 

EU-DIESEL11-4-S2, 

EU-DIESEL11-5-S2

GC 13 R 336.2804, 

40 CFR 52.21(d)

2. SO2 0.043 pph per 

unit

Test protocol 

will specify averaging 

time.

EU-DIESEL11-1-S2, 

EU-DIESEL11-2-S2, 

EU-DIESEL11-3-S2, 

EU-DIESEL11-4-S2, 

EU-DIESEL11-5-S2

GC 13 R 336.1401,

R 336.2803,

R 336.2804, 

40 CFR 52.21(c) and (d)

II. MATERIAL LIMITS

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in FGPEAKERS-S2.

(R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d))

 

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall not operate each diesel generator in FGPEAKERS-S2 for more than 99.9 hours per 

12-month rolling time period as determined at the end of each calendar month. (R 336.2804, 

40 CFR 52.21(d), 40 CFR 63.6600(c))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain each diesel generator in FGPEAKERS-S2 with a non-resettable hour 

meter to track the number of minutes and hours the engine operates. (R 336.2804, 40 CFR 52.21(d), 

40 CFR 63.6600(c))

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1201(3))

NA
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

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VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1401, R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)) 

2. The permittee shall record the monthly fuel usage rates in gallons. (R 336.1401, R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d))

3. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of 

delivery, analytical results from laboratory testing, or any other records adequate to demonstrate compliance 

with the percent sulfur limit in fuel oil. (R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d))

4. The permittee shall monitor and record in a satisfactory manner, the hours of operation for each unit in

FGPEAKERS-S2. The record shall include the time and duration of operation. The permittee shall keep all 

records on file for a period of at least five years and make them available to the Department upon request. (R 

336.2804, 40 CFR 52.21(d), 40 CFR 63.6600(c))

VII. REPORTING

NA

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID

Maximum Exhaust 

Dimensions

(inches)

Minimum Height 

Above Ground

(feet)

Underlying Applicable 

Requirements

1. SV-DIESEL11-1 32 20

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

2. SV-DIESEL11-2 32 20

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

3. SV-DIESEL11-3 32 20

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

4. SV-DIESEL11-4 32 20

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

5. SV-DIESEL11-5 32 20

R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENTS

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR 63.6595, 40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b).
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

Permit No. 27-13A Page 98 of 103

The following conditions apply to: FGUNITS1&2TEMP

DESCRIPTION: Two coal-fired cell burner boilers nominally rated at 1,570 megawatts total (net).

Emission Units: EU-UNIT1-S1, EU-UNIT2-S1

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, dry wire electrostatic precipitator (ESP), selective 

catalytic reduction (SCR) – except Unit 2, SO3 flue gas conditioning system, and ammonia flue gas conditioning 

system

I. EMISSION LIMITS

Pollutant Limit Time Period/ Operating 

Scenario Equipment

Monitoring/

Testing 

Method

Underlying Applicable

Requirements

1. NOx 1,641.6

ton/month

12-month rolling average 

as determined each 

calendar month

FGUNITS1&2

TEMP

SC VI.3,

SC VI.4

R 336.2803, 

R 336.2804, 

40 CFR 52.21(c) and (d)

II. MATERIAL LIMITS

NA

III. PROCESS/OPERATIONAL RESTRICTIONS

NA

IV. DESIGN/EQUIPMENT PARAMETERS

NA

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

NA

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.2804, 40 CFR 52.21(d)) 

2. The permittee shall install, calibrate, maintain and operate in a satisfactory manner a continuous opacity 

monitoring system (COMS) to monitor and record the visible emissions from FGUNITS1&2TEMP on a 

continuous basis. The permittee shall install and operate the COM system to meet the timelines, requirements 

and reporting detailed in Appendix A. (R 336.1301, R 336.2101, R 336.2159, 

40 CFR Part 60, 40 CFR Part 75)
DTE Energy, Monroe Power Plant (B2816) September 4, 2013

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3. The permittee shall install, calibrate, maintain and operate in a satisfactory manner device(s) to monitor and 

record the NOx emissions, and oxygen or carbon dioxide (O2 or CO2) content of the exhaust gas from 

FGUNITS1&2TEMP on a continuous basis. The permittee shall install and operate each CEM to meet the 

timelines, requirements and reporting detailed in Appendix B attached. (R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d), 40 CFR Part 60, 40 CFR Part 75) 

4. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling average NOx emission rate 

records for FGUNITS1&2TEMP, as described in emission limits SC I.1. (R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d))

VII. REPORTING

1. For the COMS and NOx CEMS, the permittee shall submit to the District Supervisor and the Technical 

Programs Unit Supervisor, AQD, and to the Chief of the Air Compliance Branch, USEPA, within 30 days of 

the end of the calendar quarter, a written report for each calendar quarter which shall include all of the following 

information:

a. Excess emissions and the nature and cause of excess emissions, if known, as follows: 

i. For opacity measurements, the report shall consist of the magnitude, in actual percent opacity, of all 

6-minute averages of opacity more than the applicable opacity standard for each hour of operation 

(all allowable exceptions are to be deducted prior to determining the excess averages of opacity). 

Average values shall be obtained by integration over the averaging period or by arithmetically 

averaging a minimum of 24 equally spaced, instantaneous opacity measurements per 6 minutes.

ii. For gaseous measurements, the report shall consist of emission averages, in the units of the 

applicable standard, for each averaging period during which the applicable standard was exceeded.

b. The date and time identifying each period during which the continuous monitoring system was 

inoperative, except for zero and span checks, and the nature of repairs or adjustments made.

c. If the monitoring system has not been inoperative, repaired, or adjusted, and if no excess emissions 

occurred, a statement attesting to this fact. 

(R 336.2170(1)(a), (b) and (c))

2. The permittee shall report NOx emissions, volumetric flow, and opacity data in accordance with 

40 CFR Part 75 (Continuous Emission Monitoring). (40 CFR Part 75) 

VIII. STACK/VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust 

Dimensions (inches)

Minimum Height Above 

Ground (feet)

Underlying Applicable 

Requirements

1. SV015-001 336 805 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)

2. SV015-002 336 805 R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)
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IX. OTHER REQUIREMENTS

NA
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APPENDIX A 

Continuous Opacity Monitoring System (COMS) Requirements

1. The permittee shall submit two copies of a Monitoring Plan to the AQD, for review and approval. The 

Monitoring Plan shall include drawings or specifications showing proposed locations and descriptions of the 

required COMS.

2. The permittee shall submit two copies of a complete test plan for the COMS to the AQD for approval.

3. Within 30 calendar days after test plan approval, the permittee shall complete the installation and testing of 

the COMS.

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final report 

demonstrating the COMS complies with the requirements of Performance Specification (PS) 1.

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations.

6. The COMS shall be installed, calibrated, maintained, and operated in accordance with the procedures set 

forth in 40 CFR 60.13 and PS 1 of Appendix B, 40 CFR Part 60.

7. Until such time as the US EPA promulgates quality assurance requirements for COMS under Appendix F to 

40 CFR Part 60, the permittee shall perform an annual audit of the COMS using the procedures set forth in 

EPA Publication 450/4-92-010, “Performance Audits Procedures for Opacity Monitors,” or a procedure 

acceptable to the AQD. The results of the annual audit shall be submitted to the AQD within the quarterly 

EER for the quarter in which the annual audit is conducted. Upon promulgation of COMS quality assurance 

requirements under Appendix F of Part 60, the permittee shall follow such procedures. 

8. In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission report 

(EER) and summary report in an acceptable format to Air Quality Division, within 30 days following the end of 

each calendar quarter. The Summary Report shall follow the format of Figure 1 in 

40 CFR 60.7(d). The EER shall include the following information:

a. A report of each exceedance above 10 percent. This includes the date, time, magnitude, cause and 

corrective actions of all occurrences during the reporting period. 

b. A report of all periods of COMS downtime and corrective action.

c. A report of the total operating time of boilers during the reporting period.

d. If no exceedances or COMS downtime occurred during the reporting period, the permittee shall report 

that fact.

All monitoring data is shall be kept on file for a period of at least five years and made available to the AQD 

upon request.
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APPENDIX B

NOx, SO2, CO, PM, CO2/O2, Mercury Monitoring

Continuous Emission Monitoring and Continuous Emission Rate Monitoring System (CEMS/CERMS) 

Requirements

1. Within 30 calendar days after permit issuance, the permittee shall submit two copies of a Monitoring Plan to 

the AQD for review and approval. The Monitoring Plan shall include drawings or specifications showing 

proposed locations and descriptions of the required CEMS/CERMS.

2. Within 150 calendar days after permit issuance, the permittee shall submit two copies of a complete test plan 

for the CEMS/CERMS to the AQD for approval.

3. Within 180 calendar days after permit issuance, the permittee shall complete the installation and testing of 

the CEMS/CERMS with the exception of the mercury CEMS which must be installed within 365 days after 

permit issuance.

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final report 

demonstrating the CEMS/CERMS complies with the requirements of the corresponding Performance 

Specifications (PS) in the following table:

 

Pollutant Applicable PS

NOx/SO2 2

CO 4

CO2/O2 3

CERMS 6

PM 11

Mercury 12A* 

*Or other PS as approved by the AQD

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations.

6. The CEMS/CERMS shall be installed, calibrated, maintained, and operated in accordance with the procedures 

set forth in 40 CFR 60.13 and PS 2, 3, 6, 11, and 12A (see No. 4 above) of Appendix B to 

40 CFR Part 60 or 40 CFR Part 75, Appendices A and B, as applicable.

7. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the CEMS/CERMS 

set forth in Appendix F of 40 CFR Part 60 or 40 CFR Part 75, Appendix B. Within 30 days following the end 

of each calendar quarter, the permittee shall submit the results to the AQD in the format of the data 

assessment report (Figure 1, Appendix F of 40 CFR Part 60). 

8. When a mercury CEM is used, and daily calibration and cylinder gas audits are performed using elemental 

mercury, a single point converter check must be performed weekly using a NIST traceable source of oxidized 

mercury. 

9. The permittee shall keep all monitoring data on file for a period of at least five years and make them available 

to the AQD upon request.
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APPENDIX C

Recordkeeping Provisions for a Nonattainment Source Using

Actual-to-Projected-Actual Applicability Test

All information in this appendix shall be maintained pursuant to R 336.2902 and 40 CFR 51 (Appendix S) for ten

years after the modification, and shall be made available to the Department upon request. 

1. Project Description:

The project is to increase the capacity to use subbituminous coal and add petroleum coke to provide additional 

fuels for EU-UNIT1-S1, EU-UNIT2-S1, EU-UNIT3-S1 and EU-UNIT4-S1; installation of four (4) wet FGD 

quench pumps (EU-WFGD-QP1, EU-WFGD-QP2, EU-WFGD-QP3, and EU-WFGD-QP4); modifications to 

the fuel handling systems (EU-CASCADES-S1, EU-TRANSFERHS-S1,

EU-DUMPERHS-S1, EUCOALUNLOAD-S1, and EU-CRUSHERHS-S1); the installation of new material 

handling systems for limestone and gypsum (EU-LIMESTONE-S1, EU-GYPSUMHAND-S1, and 

EU-HYDRATELIME-S1); and the installation of a new fuel handling system for petroleum coke

(EU-PETCOKE-S1).

2. Applicability Test Description:

Minor modifications are not subject to nonattainment. The actual-to-projected-actual hybrid applicability test 

as described in the table below was used to demonstrate that nonattainment does not apply to these 

modifications.

3. Emission Projections:

Emissions (tpy)

Emission 

Unit/Flexible 

Group ID 

Pollutant

Baseline 

Actual 

Emissions 

(tpy)

Projected 

Actual 

Emissions 

(tpy)

Excluded 

Emissions 

(tpy) 

Reason for Exclusion

FG-ProjectPC1-4 PM2.5 5,315 2,730 381 FG-ProjectPC1-4 was capable 

of accommodating emissions 

up to 381 tpy. There is no

projected emissions increase, 

therefore the project is less 

than the significant level of 10

tpy.

FG-ProjectPC1-4 SO2 117,940 11,753 1,757 FG-ProjectPC1-4 was capable 

of accommodating emissions 

up to 1,757 tpy. There is no

projected emissions increase, 

therefore the project is less 

than the significant level of 40

tpy.