# A PREVENTION OF SIGNIFICANT DETERIORATION (PSD) PERMIT TO CONSTRUCT / RECONSTRUCT / MODIFY AN AIR CONTAMINANT SOURCE

Lincoln

- Lancaster County Health Department

Environmental Public Health Division Air Quality Program

3140 N Street Lincoln, Nebraska 68510

Phone: (402) 441

- 8040 Fax: (402) 441

- 3890 Judith A. Halstead, MS
Health Director

Scott E. Holmes, REHS, MS
Environmental Public Health

Division Manager

Chris Schroeder, MCRP Air Quality Program Supervisor



### LLCHD Air Quality Program Source Number: 00 005
LLCHD Air Quality Program Construction Permit Number: 1 58 A

Effective Date of Permit: 04

– 15

– 2016

MM

– DD

– YYYY 

### A Permit to Construct / Reconstruct / Modify an Air Contaminant Source is Hereby Issued to:

Permit Holder Name: Nebraska Public Power District (NPPD)

Address: 1414 15 th 

### Street

City, County, State, ZIP: Columbus, Platte County, Nebraska 68602



### This Construction / Reconstruction / Modification Permit is Issued to the Following Source:
Facility Site Name: NPPD Sheldon Station

Facility Address: 4500 West Pella Road

City, County, State, ZIP: Lincoln, L ancaster County, Nebraska 68368

Facility NAICS: 221112 : Fossil Fuel Electric Power Generation



### Environmental Public Health Division / Air Quality Program Recommendation:

Permit Writer: Approve Issuance Deny Issuance PERMIT WRITER APPROVAL



### Air Quality Program Supervisor: Approve Issuance Deny Issuance SUPERVISOR APPROVAL



### Environmental Public Health Division Manager: Approve Issuance Deny Issuance MANAGER APPROVAL



### Health Director / Air Pollution Control Officer Authorization: Pursuant to the delegation contract signed by the Director of the Nebraska Department of Environmental Quality (NDEQ) on Apri l 1, 1986, the undersigned hereby executes this document on behalf of the Director of the NDEQ.

ACTION TAKEN:

Approve Issuance

Deny Issuance Date Judith A. Halstead, MS Health DirectorConstruction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 2 of 14 Permitted Emission Unit(s):
This permit allows the owner/operator to construct/reconstruct/modify the following emission unit(s):

Emission Unit (EU) # SCC Code # Emission Point Description Emission Segment Description

1

- 1 1

- 01

- 002

- 23 Unit #1

– External Combustion Boiler and Associated Equipment Coal

1

- 2 1

- 01

- 006

- 01 Unit #1

– External Combustion Boiler and Associated Equipment Natural Gas

Introduction

– Source Description

The Nebraska Public Power District (NPPD) Sheldon Station , located at 4500 West Pella Road, Hallam , Nebraska is an electricity generating station. The existing facility consists of the following emissions units:
Emission Unit (EU) # SCC Code # Emission Point Description Emission Segment Description

1

- 1 1

- 01

- 002

- 23 Unit #1

– External Combustion Boiler and Associated Equipment Coal

1

- 2 1

- 01

- 006

- 01 Unit #1

– External Combustion Boiler and Associated Equipment Natural Gas

1

- 3 N/A Unit #1

– External Combustion Boiler and Associated Equipment Coal/TDF/Scrap Rubber

2

- 1 1

- 01

- 002

- 23 Unit #2

– External Combustion Boiler and Associated Equipment Coal

2

- 2 1

- 01

- 006

- 01 Unit #2

– External Combustion Boiler and Associated Equipment Natural Gas

2

- 3 N/A Unit #2

– External Combustion Boiler and Associated Equipment Coal/TDF/Scrap Rubber

3

- 1 2

- 01

- 002

- 01 Unit #3

– Combustion Turbine A and Associated Equipment Natural Gas

3

- 2 2

- 01

- 001

- 01 Unit #3

– Combustion Turbine A and Associated Equipment Fuel Oil

4

- 1 2

- 01

- 002

- 01 Unit #4

– Combustion Turbine B and Associated Equipment Natural Gas

4

- 2 2

- 01

- 001

- 01 Unit #4

– Combustion Turbine B and Associated Equipment Fuel Oil

5

- 1 1

- 01

- 006

- 02 Auxiliary Boiler #1 Natural Gas

6

- 1 1

- 01

- 006

- 02 Auxiliary Boiler #2 Natural Gas

11

- 1 3

- 05

- 010

- 08 Track Hopper Building Coal Unloading

12

- 1 3

- 05

- 010

- 11 Track Hopper to Belt Conveyor #1 Coal Transfer

13

- 1 3

- 05

- 010

- 11 Belt Conveyor #1 to Belt Conveyor #2 Coal Transfer

14

- 1 3

- 05

- 010

- 11 Belt Conveyor #2 to Active Coal Pile Coal Transfer

14a

- 1 3

- 05

- 010

- 11 Low

- BTU Coal Pile to Reclaim Hoppers #1

- 4 Coal Transfer

15

- 1 3

- 05

- 010

- 11 Reclaim Hoppers #1

- 4 to Belt Conveyor #3 Coal Transfer

16

- 1 3

- 05

- 010

- 11 High BTU Coal Pile to Reclaim Hopper #5 Coal Transfer

17

- 1 3

- 05

- 010

- 11 Reclaim Hopper #5 to Belt Conveyor #6 Coal Transfer

18

- 1 3

- 05

- 010

- 11 Belt Conveyor #6 to Crusher House Coal Transfer

19

- 1 3

- 05

- 010

- 11 Belt Conveyor #3 to Crusher House Coal Transfer

20

- 1 3

- 05

- 010

- 10 Crusher House Coal CrushingConstruction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 3 of 14 Emission Unit (EU) # SCC Code # Emission Point Description Emission Segment Description

21

- 1 3

- 05

- 010

- 11 Crusher House to Belt Conveyor #4 Coal Transfer

22

- 1 3

- 05

- 010

- 11 Belt Conveyor #4 to Belt Conveyor #5 Coal Transfer

23 a

- 1 3

- 05

- 010

- 11 Belt Con veyor #5 to Boiler #1 Coal Bunker 1a Coal Transfer

23 b

- 1 3

- 05

- 010

- 11 Belt Conveyor #5 to Boiler #1 Coal Bunker 1b Coal Transfer

23 c

- 1 3

- 05

- 010

- 11 Belt Conveyor #5 to Boiler #1 Coal Bunker 1c Coal Transfer

24 a

- 1 3

- 05

- 010

- 11 Belt Conveyor #5 to Boiler #2 Coal Bunker 2a Coal Transfer

24 b

- 1 3

- 05

- 010

- 11 Belt Conveyor #5 to Boiler #2 Coal Bunker 2b Coal Transfer

24 c

- 1 3

- 05

- 010

- 11 Belt Conveyor #5 to Boiler #2 Coal Bunker 2c Coal Transfer

26

- 1 3

- 05

- 101

- 99 Lime Silo

– Loading Lime Transfer

27

- 1 3

- 05

- 101

- 99 Fly Ash from Boilers to Silo (Bin Vent Filter Exhaust) Fly Ash Transfer

27a

- 1 3

- 05

- 101

- 99 Fly Ash Filter Separator UCC C (baghouse) via Vacuum Pump B Fly Ash Transfer

27b

- 1 3

- 05

- 101

- 99 Fly Ash Filter Separator UCC B (ESP) via Vacuum Pump C Fly Ash Transfer

27c

- 1 3

- 05

- 101

- 99 Fly Ash Filter Separators UCC B or UCC C via Vacuum Pump A Fly Ash Transfer

28

- 1 3

- 05

- 101

- 99 Fly Ash from Silo & Precipitator to Truck Fly Ash Transfer

29

- 1 3

- 05

- 101

- 99 Fly/Bottom Ash from Truck to Ash Landfill Fly/Bottom Ash Transfer

30

- 1 3

- 05

- 010

- 43 Coal Storage Pile

– Live Coal Storage

31

- 1 3

- 05

- 010

- 43 Coal Storage Pile

– Standby Coal Storage

32

- 1 3

- 05

- 010

- 43 Ash Landfill Bottom Ash

33

- 1 3

- 05

- 020

- 11 Haul Roads

– Unpaved Roadway Traffic

34

- 1 3

- 05

- 020

- 11 Haul Roads

– Paved Roadway Traffic

43

- 1 3

- 85

- 001

- 01 Cooling Tower #1 Mechanical Draft

44

- 1 3

- 85

- 001

- 01 Cooling Tower #2 Mechanical Draft

46

- 1 2

- 02

- 003

- 01 Honda GX 240 Air Compressor (8 hp

- 0.020 MMbtu/hr) Gasoline

47

- 1 2

- 02

- 001

- 02 Emergency Generator (650 hp

- 4.55 MMbtu/hr) Diesel

48

- 1 2

- 02

- 001

- 02 Fire Pump 1 (274 hp

- 0.96 MMBtu/hr) Diesel

49

- 1 2

- 02

- 001

- 02 Fire Pump 2 (274 hp

- 0.96 MMBtu/hr) Diesel

Introduction

– Description of Modification
The original Construction Permit #158 allowed the owner/operator to modify Sheldon Station Unit #1 by installing an over

- fire

- air (OFA) system in the unit. The modification included the following elements:

 I nstallation of an over

- fire

- air (OFA) s ystem; and

 M odifications of boiler control system to incorporate control of the new OFA system. The intent of this modification was to reduce emissions of nitrogen oxides ( NO X ) from Unit #1. Howe ver, this reduction in NO X emissions was expected to result in an increase in emissions of carbon monoxide (CO). Because this source is a major source for the purposes of PSD, this modification was subject to the PSD provisions. This modified permit, bein g issued as Construction Permit #1 58 A, is being issued to establish a minimum stack height for the stack associated wit h Sheldon Station Unit # 1 , as well as additional applicable requirements that have been requested by the owner/operator. This constructi on permit supersedes the previously

- issued Construction Permit #1 58

.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 4 of 14 Facility Regulatory Classification

 The facility is a major source of hazardous air pollutants (HAP).

 The facility operates units subject to the acid rain provisions of the Clean Air Act (CAA).

 The facility is a Title V major source of air pollution in accordance with LLCAPCPRS Article 2, Section 2, paragraph (B), as well as 40 CFR Part 70 §70.2.

 The facility is a major stationary source for the purposes of the Prevention of Significant De terioration (PSD) of Air Quality in accordance with Lincoln

- Lancaster County Health Department Air Pollution Control Program Regulations and Standards ( LLCAPCPRS ) Article 2, Section 2, paragraph (H)(1).

 The modification allowed by this permit will result i n increased emissions of carbon monoxide (CO). The increase in CO emissions is a significant increase in accordance with the prevention of significant deterioration of air quality (PSD) requirements set forth under LLCAPCPRS Article 2, Section 19, as well as 40 CFR Part 52, §52.21. The modification allowed by this permit will not result in the increased emissions of any other regulated pollutants or hazardous air pollutants

.

 This permit allows for construction/reconstruction/modification of units that ar e subject to the following applicable New Source Performance Standards (NSPS) in Title 40, Part 60 of the Code of Federal Regulations (40 CFR 60):

o Subpart A: General Provisions

 This permit allows for construction/reconstruction/modification of units tha t are subject to the following applicable National Emissions Standards for Hazardous Air Pollutants (NESHAP) in Title 40, Part 63 of the Code of Federal Regulations (40 CFR 63):

o Subpart A: General Provisions

o Subpart UUUUU: National Emission Standards f or Hazardous Air Pollutants from Coal and Oil

Fired Electric Utility Steam Generating Units
Public Participation

 Pursuant to the provisions set forth in Article 2, Section 15, paragraph (C)(2) and (C)(6) of the LLCAPCPRS, construction permit modifications that qualify as a “minor permit modification” do not require a public comment period. As such, this permit is being issued without public participation.
Permitting Authority

 The permitting authority for this project is the Air Quality Program in the Envi ronmental Public Health Division of the Lincoln

- Lancaster County Health Department (LLCHD). All documents related to applications for permits to construct/reconstruct/modify or operate an y emissions unit or source shall be submitted to the LLCHD at the following address. Lincoln

- Lancaster County Health Department c/o Air Quality Program 3140 ‘N’ Street Lincoln, NE 68510 Compliance Authorities

 All documents related to compliance activities such as reports, tests, and notifications shall be submitted to the following:  If required or requested by the EPA, the owner/operator shall submit reports, tests, and/or notifications to the following:
Lincoln

- Lancaster County Health Department c/o Air Quality Program 3140 ‘N’ Street Lincoln, NE 68510 US EPA Region 7 APCO

– Nebraska Air Compliance Coordinator 11201 Renner Blvd. Lenexa, KS 66219

Definitions

 Unless otherwise defined, or a different meaning is clearly required by context, the words and phrases, as used in this operating permit, the LLCAPCPRS, and the related appendices shall have the meanings set forth in LLCAPCPRS Article 2, Section 1 (Definitions)

.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 5 of 14 General Conditions

I. The owner/operator shall maintain compliance with all applicable regulations and requirements set forth in the Lincoln

- Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS), the Lancaster County Air Pollution Control Resoluti on (Lancaster County Resolution R

- 13

- 0073) , as well as any applicable federal regulations and standards.

II. In accordance with LLCAPCPRS Article 1, Section 1 (Intent) , holding of this permit does not relieve the owner/operator from the responsibility to comply with all applicable portions of the LLCAPCPRS and any other requirements under Local, State, or Federal law. Compliance with this permit shall not be a defense to any enforcement action for violation of a n ambient air quality standard.

III. In accordanc e with paragraph (C) of LLCAPCPRS Article 1, Section 2 (Unlawful Acts

– Permits Required) , it is unlawful to: (A) Construct or operate an air pollution source without first obtaining a permit required under the LLCAPCPRS; (B) Violate any term or condition of this permit or any emission limit set in this permit; or (C) Violate any emission limit or standard established in the LLCAPCPRS.

IV. Violations , hearings, and orders shall be conducted in accordance with LLCAPCPRS Article 1, Section 3 (Violations

– Hearings

– Orders).

V. Appeals shall be conducted in accordance with LLCAPCPRS Article 1, Section 4 (Appeal Procedure)

.
VI. In accordance with LLCAPCPRS Article 1, Section 5 (Variance) , any person who owns or is in control of any plant, building, structure, process, or equipment ma y apply to the Director for a variance from rules or regulations. Any person who is applying for, or has obtained a variance must comply with all applicable requirements of Article 1, Section 5 of the LLCAPCPRS.

VII. The following provisions of LLCAPCPRS Artic le 1 , Section 6 (Fees) are applicable requirements of this permit: (A) Paragraph (A)

– In accordance with paragraph (A)(1) of Section 6

, any person who owns or operates a source as defined in Article 2, Section 1 of the LLCAPCPRS and is required to obtain a Class I or Class II operating permit in accordance with Article 2, Section 5 of the LLCAPCPRS, or is required to obtain a construction permit in accordance with Article 2, Section 17 of the LLCAPCPRS, must pay annual emission fees as specified in paragraph (A) of Section 6

. (B) Paragraph (D)

– In accordance with paragraph (D)(1) of Section 6

, any person or source required to obtain a construction permit under Article 2, Section 17 (with the exception of a construction permit obtained in accordance with Article 2, Section 17, paragraph (O)) shall pay a permit fee for activities included under paragraphs (D)(1)(a) through (D)(1)(f) of Section 6. The permit fee shall be charged at the rate specified in paragraph (D)(1) of Section 6. A ny person required to submit fees pursuant to Section 6 shall submit the fees to the Director of the Department by check or other authorized transfer payable to the Lincoln

- Lancaster County Health Department. The fees shall be due and payable within thirty (30) days after issuance of the permit. (C) Paragraph (H)

– All money collected from the fees, provided for herein, shall be payable to the Lincoln

- Lancaster County Health Department and shall be credited to the Air Pollution Control Fund.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 6 of 14 VIII. The following provisions of LLCAPCPRS Article 1 , Section 7 ( Compliance

– Actions to Enforce

– Penalties for Non

- Compliance ) are applicable requirements of this permit: (A) P aragraph (A)

– T he County Attorney or Attorney General may institute enforcement proceedings pursuant to Neb. Rev. Stat., §81

- 1504(23) Neb. Rev. Stat. §81

- 1508(4), or Nebr. Rev. Stat. §81

- 1528(2) against any person who fails to comply with the requirements of the LLCAPCPR S. Nothing in the LLCAPCPRS shall preclude the control of air pollution by resolution, ordinance, or rule, regulation, or standard not in actual conflict with the state air pollution control regulations. (Ref: Neb. Rev. Stat. §71

- 1631(15)) (B) P aragraph ( B )

– Any person who fails to comply with the requirements of the LLCAPCPRS or who fails to perform any duty imposed by the LLCAPCPRS shall be subject to a civil penalty of not more than ten thousand dollars ($10,000) per day per violation. (C) P aragraph ( C )

– Any person who knowingly and willfully fails to comply with the requirements of the LLCAPCPRS or who knowingly and willfully fails to perform any duty imposed by the LLCAPCPRS shall be subject to felony prosecution under Neb. Rev. Stat. §81

- 1508(f) includi ng a fine of not more than ten thousand dollars ($10,000) per day per violation , and up to a maximum six (6) month term of imprisonment. (D) P aragraph ( D )

– Enforcement proceedings may include injunctive relief in court to restrain any violation that creates a n imminent and substantial endangerment to the public health or to the environment.

IX. In accordance with LLCAPCPRS Article 1, Section 8 (Procedure for Abatement) , if the Director has determined a violation of the Air Pollution Control Program after any heari ng required hereunder or if the Director has probable cause to believe a violation has occurred, the Director shall refer the matter to the County Attorney.

X. In accordance with LLCAPCPRS Article 1, Section 9 (Severability) , if any clause, paragraph, or sect ion of the LLCAPCPRS shall be held invalid, it shall be conclusively presumed that the City and County would have enacted the remainder of the LLCAPCPRS not directly related to such clause, paragraph, or section.

XI. The owner/operator shall maintain complianc e with the requirements set forth in LLCAPCPRS Article 2, Section 4 (Ambient Air Quality Standards)

.
XII. In accordance with LLCAPCPRS Article 2, Section 6 (Emissions Reporting

– When Required) , the owner/operator shall submit completed emission inventory forms for the preceding calendar ye ar to the Department by March 31 of each year. The inventory shall include all emissions associated with the emission units for which this permit is issued . The inventory form shall be certified in accordance with LLCAPCPRS Article 2, Section 7, paragraph (H)

.
XIII. The following provisions of LLCAPCPRS Article 2, Section 15 ( Permit Modifications

– Reopening For Cause) are applicable requirements of this permit: (A) Paragraph (C)(2)

– Subject to the approval of the Director, the terms of a construction permit may be modified without public review through the substitution of alternative provisions, provided the following conditions are met: (1) No emission limit in the original construction permit is exceeded; (2) No applicable requirement included in an operating permit to which the source is subject is violated; (3) No emissions limit, equipment or operational standard applicable to the source will be exceeded; (4) No emissions limit, equipment or operational standard assumed to avoid a classification that would render the source subject to an otherwise applicable requirement will be exceeded; and (5) The nature of the constructed facility will be consistent with that described in the original public notice materi als.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 7 of 14 (B) Paragraph (G)

– The owner/operator may make changes to a permitted facility without a permit revision if the change is not a modification under LLCAPCPRS Article 2, Sections 18, 23, 27, or 28 , the change does not require a construction permit under LL CAPCPRS Article 2, Sections 17 or 19, and the change is allowed under the applicable provisions of paragraphs (G)(1) or (G)(2) of Section 15. (C) P aragraph (H)

– N o permit revisions shall be required under any State

- approved programs providing for economic incentives, marketable permits, emissions trading or other similar programs or processed for changes that are provided for in the permit.

XIV. In accordance with paragraph (A) of LLCAPCPRS Article 2, Section 16 (Stack Heights

– Good Engineering Practice), the d egree of emissions limitation required of any source for control of any air pollutant shall not be affected by so much of any source’s stack height that exceeds good engineering practice or by any other dispersion technique, except as provided in paragraph (B) of Section 16

.
XV. The following provisions of LLCAPCPRS Article 2, Section 17 ( Construction Permits

– When Required ) are applicable requirements of this permit: (A) P aragraph (A)

– N o person shall cause the construction, reconstruction, or modification of

an y source specified in paragraphs (A)(1)

- (4) of Section 17 without first having obtained a construction permit from the Department in the manner prescribed by the LLCAPCPRS. (B) Paragraph (C)

– The owner or operator of any source required to obtain a constructi on permit under the LLCAPCPRS shall submit an application on forms provided by the Department. (C) Paragraph (N)

– Modification of the Construction Permit. The purpose of this section is to provide a means to address unforeseen situations which may develop in the process of constructing or modifying an emission source subject to this section. Modification of the construction permit shall be performed as follows: (1) Subject to the approval of the Director, the terms of a construction permit may be modified withou t public review through the substitution of alternative provisions, provided the conditions set forth in Condition XIII(A) of this permit are met. (2) M odifications meeting the conditions of Condition XIII(A) of this permit shall be processed as follows: (a) The owner or operator shall submit a request for modification of a construction permit as provided in LLCAPCPRS Article 2, Section 15

, paragraph (C) (3) and provide such additional information as may be required to determine if the conditions of Condition XIII(A) of this permit have been met; (b) The Department shall review the request and determine whether or not a modification of the construction permit is required. The applicant shall not proceed with the project until a determination is made by the Director. (3) Proposed modifications to a construction permit which do not meet the cond itions of Condition XIII(A) of this permit must be processed through the full construction permit process as provided in paragraphs (C) through (M) of Section 17.

XVI. The following provisions of LLCAPCPRS Article 2, Section 20 ( Particulate Limitations and Standards ) are applicable requirements of this permit: (A) Paragraph (A)

– The owner/operator shall limit the emissions of particulates from any process ing machine, equipment, device or other articles, or any combination thereof to no greater than the amounts set forth in Table 20

- 2 of Section 20 during any one (1) hour. (B) Paragraph (B)

– The owner/operator shall limit the emissions of particulate matter ca used by the combustion of fuel in accordance with the limits set forth in Table 20

- 1 of Section 20

, as they apply based on heat input rating.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 8 of 14 (C) Paragraph (E)

– The owner/operator shall not cause or allow emissions from any emission point that are of opacity equal to or greater than twenty percent (20%), as evaluated by Method 9 in Appendix A of 40 CFR 60, or recorded by a continuous opacity monitoring system operated and maintained pursuant to 40 CFR Part 60 Appendix B, except as provided for in paragraph (D) of this condition. (D) Paragraph (F)

– Emission sources subject to monitoring requirements of Article 2, Section 34, paragraph (E) of LLCAPCPRS are allowed to have one six

- minute period per hour of not more than twenty

- seven percent ( 27% ) opacity. For the purpose of this permit, this exception applies to any unit equipped with a continuous opacity monitoring system (COMS) installed, calibrated, and operated in accordance with the procedures specified in 40 CFR Part 60 Appendix B.

XVII. In accordance with paragraph (A) of LLCAPCPRS Article 2, Section 24 ( Sulfur Compound Emissions

– Existing Sources

– Emission Standards ) , the owner/operator shall not cause or allow emissions of sulfur oxides from any fossil fuel burning equipment in excess of two and one

- half pounds per million British thermal units ( 2. 5 lbs/MMBtu) input, maximum two (2) hour average.

XVIII. The following provisions of LLCAPCPRS Article 2, Section 32 (Dust

– Duty to Prevent Escape Of)

are applicable requirements of this permit: (A) P aragraph (A)

– T he source shall not cause or permit fugitive parti culate matter to become airborne in such quantities and concentrations that it remains visible in the ambient air beyond the premise where it originates. (B) Paragraph (B )

– T he source shall not cause or permit a road, driveway, or open area to be used without applying all such reasonable measures to prevent particulate matter from becoming airborne so that it remains visible beyond the premises where it originates. Such reasonable measures include but are not limited to: paving or frequent cleaning of roads, d riveways, and parking lots; application of water or chemical dust suppressants; and the planting and maintenance of vegetative ground cover.

XIX. The following provisions of LLCAPCPRS Article 2, Section 33 (Compliance

– Time Schedule For) are applicable require ments of this permit: (A) Paragraph (A)

– Except as otherwise noted in specific emission control regulations, compliance with the LLCAPCPRS shall be according to the schedule provided under paragraphs (A)(1)

- (3) of Section 33. (B) Paragraph (B)

– Compliance schedu les requiring more than twelve (12) months to conform with applicable rules and regulations to meet National Primary and Secondary Ambient Air Quality Standards will be accomplished in progressive steps. A report will be made in writing to the Director wit hin five (5) days after each step is completed. (C) Paragraph (C)

– Failure to meet time schedules approved in ac cordance with paragraphs (A)(1)

- (2) of Section 33 shall constitute a violation of the LLCAPCPRS unless a request to amend the time schedule is rece ived at least thirty (30) days before the end of any specified period approved for a particular activity. Such a request to amend the schedule shall contain the same type of information as required for the initial request for variance as described in para graph (A)(3) of Section 33

.
XX. The following provisions of LLCAPCPRS Article 2, Section 34 (Emission Sources

– Testing and Monitoring) are applicable requirements of this permit: (A) Paragraph (A)

– The Department may require any person responsible for the operation of an emission source to make or have tests made to determine the rate of contaminant emissions from the source whenever it has reason to believe, on the basis of estimates of potential contaminant emissions rates from the source and due consider ation of probable efficiency of any existing control device, or visible emission determinations made by an official observer, that existing emissions exceed the limitations required in the LLCAPCPRS. Such tests may also be required pursuant to verifying t hat any newly installed control deviceConstruction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 9 of 14

meets performance specifications. Should the Department determine that the test did not represent normal operating conditions or emissions, additional tests may be required. Such a requirement shall be considered as an order and subject to all administrative and legal requirements specified. (B) Paragraph (B)

– Required tests shall be conducted in accordance the test method s and procedures established in paragraphs (B)(1)

- (7) of Section 34. (C) Paragraph (C)

– The owner or o perator of a source shall provide notice to the Department at least thirty (30) days prior to testing to afford the Department an opportunity to have an observer present. The Department may, in writing, approve a notice of less than thirty (30) days. If t he testing is pursuant to an underlying requirement contained in a federal rule, the notice provisions of the underlying requirement shall apply. (D) Paragraph (F)

– The Director may require the owner or operator of any other emission source which is subject t o the provisions of these regulations to install, use and maintain such stationary monitoring equipment as is required to demonstrate continuing compliance with any applicable emissions limitations, and to maintain records and make reports regarding such m easured emissions to the Department in a manner and on a schedule to be determined by the Director. (E) Paragraph (H)

– Notwithstanding any other provisions of LLCAPCPRS, the following methods may be used to determine compliance with applicable requirements: (1) A monitoring method approved for the source and incorporated in an operating permit pursuant to LLCAPCPRS Article 2, Section 8 ; (2) Any compliance test method specified in the State Implementation Plan (SIP); (3) Any test or monitoring method approved for the source in a permit issued pursuant to LLCAPCPRS Article 2, Section s 17, 19 , or 27 ; (4) Any test or monitoring method provided for in the LLCAPCPRS ; or (5) Any other test, monitoring, or information gathering method that produces information comparable to that prod uced by any method described in paragraphs (1) through (4) of this condition.

XXI. The following provisions of LLCAPCPRS Article 2, Section 35 ( Compliance

– Exceptions Due to Startup, Shutdown, or Malfunction ) are applicable requirements of this permit: (A) P aragraph (A)

– U pon receipt of a notice of excess emissions issued by the Department, the owner/operator may provide information showing that the excess emissions were the result of a malfunction, start

- up, or shutdown. (B) P aragraph ( B )

– T he information provided by the source operator under paragra ph (A) of this condition shall include, at a minimum, the information specified in paragraphs (B)(1)

- (9) of Section 35

. (C) Paragraph (C )

– T he owner/op erator shall submit the information specified in paragraph (B) of this condition no later than fifteen ( 15 ) days after receipt of the notice of ex cess emissions. (D) P aragraph ( D )

– T he owner/operator shall notify the Director, in writing, whenever a planned start

- up or shut down may result in excess emissions. This notice shall be mailed, no later than ten ( 10 ) days prior to such action and shall incl ude, but not be limited to, the information specified in paragraphs (D)(1)

- (10) of Section 35

. (E) P aragraph ( E )

– T he owner/operator shall notify the Director, in writing, whenever emissions due to malfunctions, unplanned shutdowns or ensuing start

- ups are, or may be, in excess of applicable emission control regulations for one hour or more. Such notification shall be mailed within forty

- eight ( 48 ) hours of the beginning of each period of excess emissions and shall include, but not be limited to, the informa tion required in paragraph (D) of Section 35

.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 10 of 14 XXII. In accordance with LLCAPCPRS Article 2, Section 37 (Compliance

– Responsibility of Owner/ Operator Pending Review by Director) , application for review of plans or advice furnished by the Director will not relie ve the owner or operator of a new or modified stationary source of legal compliance with any provision of the LLCAPCPRS, or prevent the Director from enforcing or implementing any provision of the LLCAPCPRS.

XXIII. In accordance with LLCAPCPRS Article 2, Section 3 8 (Emergency Episodes

– Occurrence and

Control: Contingency Plans)

, i f and when the Director declares an air pollution emergency episode as defined in Section 38, the source shall immediately take all applicable required actions listed in LLCAPCPRS Append ix I until the Director declares the air pollution episode terminated.

XXIV. Any modification of the operational and/or construction permit application documents must have

prior approval from the Department. The source shall provide all necessary information to validate the modification, including, but no limited to, additional engineering, modeling, and ambient air quality studies.

XXV. Approval to construct, reconstruct and/or modify the source will become invalid if a continuous program of construction is not comm enced within eighteen (18) months after the date of issuance of the construction permit; if construction is discontinued for a period of eighteen (18) months or more; or if construction is not completed within a reasonable period of time. The conditions set forth in this permit shall remain applicable requirements until such time that all permitted emission units are removed from the source, or until the owner/operator requests that the permit be nullified and all permitted emission units are rendered inoperable.

XXVI. The owner/operator of the source shall notify the Department of the actual date of anticipated initial

startup of each independently operable emission unit, process, or group of equipment or emission units, and said notification shall be postmarked not more than sixty (60) days nor less than thirty (30) days prior to such date.

XXVII. The owner/operator must maintain a copy of the permit and of the letter of transmittal on

- site. A

copy of the permit must also be kept on file at the comp any's main or corporate office. A copy of the permit must be placed on file at each of the aforementioned locations no later than fourteen (14) calendar days after the date of receipt of the letter of transmittal.

XXVIII. In accordance with the Section 4 of the L ancaster County Air Pollution Control Resolution

(Lancaster County Resolution R

- 13

- 0073) , upon presentation of credentials and other documents as may be required by law, the owner/operator shall allow the LLCHD or an authorized representative to perform th e following: (A) Enter and inspect or cause to be inspected, during reasonable hours, any building, facility, or place, except a building designed for and used exclusively for a private residence, as the Director deems necessary to determine compliance with the provisions of the LLCAPCPRS and to require the submission of air contaminant emission information in connection with such inspections, tests, and studies. (B) Have access to existing and available records relating to emissions or discharges, which

cause or contribute to air pollution or the monitoring of such emissions or discharges; (C) Issue, modify, or revoke orders prohibiting or abating discharges of air pollutants, or requiring the construction of control systems or any parts thereof or the modification, extension, or adoption of other remedial measures to prevent, control, or abate air pollution. (D) Conduct tests and take samples of air contaminants, fuel, process materials, or any other substance which affects or may affect discharges or emissions of air co ntaminants from any source, giving the owner or operator a receipt for the sample obtained. (E) Issue, continue in effect, revoke, modify, or deny permits, under such conditions as the Director may prescribe and consistent with the Clean Air Act and the LLCAPC PRS

.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 11 of 14 Specific Conditions
XXIX. This permit authorizes the owner/operator to install and operate an over

- fire

- air (OFA) system for

Emission Unit 1 (Sheldon Station Unit #1). The owner/operator shall install the OFA system and operate Emission Unit 1 (EU

- 1) in a ccordance with the approved application and the following conditions, which have been determined to meet the requirements for Best Available Control Technology (BACT) pursuant to Article 2, Section 19 of the LLCAPCPRS and 40 CFR Part 52 §52.21: (A) Operational Requirements. (1) All combustion controls shall be fully functional during operation of EU

- 1 except as allowed during emission unit startup and shutdown periods. (B) Emission Limits. (1) The owner/operator shall limit the emissions of carbon monoxide (CO) from EU

- 1 to no more than 1.26 pounds per million British thermal unit (lbs/MMBtu) based on a 30

- day rolling average, except during periods of startup and shutdown. For the purpose of this condition, the 30

- day rolling average CO emission rate shall be calculated in accordance with the procedures established in paragraph (D)(1)(c) of this condition. (2) The owner/operator shall maintain compliance with all particulate emission limits set forth in Condition XVI of this permit. (3) The owner/operator shall maintain compliance with the sulfur oxide emission limit set forth in Condition XVII of this permit. (C) Emission Testing Requirements. (1) Relative Accuracy Test Audits (RATA) shall be performed in accordance with the following: (a) 40 CFR 60

– Appendix B

– Performance Specification 4 (b) Test Protocol: At least 45 days prior to t he date of testing, the owner/operator shall develop a formal “Test Protocol” which shall be submitted to and approved by the Department prior to commencement of testing. This “Test Protocol” shall include, as a minimum, the following items: (i) A test plan d etailing the methods and procedures that will be used for testing; (ii) A test schedule describing the tentative agenda as to when testing will occur; (iii) A description as to how testing will determine compliance with the permit conditions along with a copy of the permit. (c) Pre

- Test Notification: The owner/operator shall notify the Department of the intent to perform a RATA as required in paragraph (F)(5) of this condition. (d) Final Test Report: The owner/operator shall submit the results of each RATA as required in paragraph (F)(6) of this condition. The Final Test Report shall be certified by the tester and shall include, at a minimum, the following: (i) An executive summary. (ii) A description of the source testing conditions, including, but not limited to, the following: 1. Actual achieved firing rate (i.e. MM Btu/hr); 2. Quantity of fuel consumed (ton/hr); 3. Heating value of the fuel; 4. Ambient atmospheric conditions; and 5. Any other information that may be relevant to the test. (iii) Copies of all data sheets from the test run(s). (iv) A description and explanation of any erroneo us data or unusual circumstance(s) and the cause for such situation.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 12 of 14 (v) A final conclusion section describing the outcome of the testing. (2) The owner/operator shall conduct all testing required by this permit in accordance with the requirements set forth in Condition XX of this permit. (3) T he owner/operator shall notify the Department of the intent to conduct any performance tests as required in paragraph (F)(5) of this condition. (4) The owner/operator shall report the results of all performance tests required by this permit as required in paragraph (F)(6) of this condition. (D) Monitori ng Requirements. (1) The owner/operator shall calculate the CO emission rates in accordance with the following requirements: (a) Hourly average CO emission rates shall be calculated as follows: (i) The continuous emissions monitoring system (CEMS) associated with EU

- 1 shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15

- minute period. (ii) Except during periods of CEMS malfunction or calibration, the CEMS shall be utilized to collect CO emission data at all time s EU

- 1 is combusting fuel. (iii) The owner/operator shall utilize data collected by the CEMS to calculate 1

- hour average CO emission rates, in units of pounds of CO per million British thermal units (lbs/MMBtu), in accordance with the applicable procedures set f orth under 40 CFR Part 60 §60.13 paragraph (h). (iv) Data for startup and shutdown shall not be used to calculate the hourly average CO emissions. (b) Daily average CO emission rates shall be calculated as follows: (i) Daily average CO emission rates shall be calcula ted using only data from days for which at least one (1) hour of valid CO emission data was collected and calculated in accordance with paragraph (D) (1) (a) above. One (1) valid hour of CO emission dat a can constitute a daily average. (ii) The owner/operator shall divide the sum of the hourly averages by the number of hours in which an hourly average was obtained in accordance with paragraph (D) (1) (a) above. (c) Thirty (30) day rolling average CO emission rates shall be calculated as follows: (i) The 30

- day rolling average shall be calculated using only data from days for which a daily average CO emission rate was calculated in accordance with paragraph (D) (1) (b) above. (ii) The owner/operator shall sum the daily average CO emission rate for each operating day with the daily average CO emission rates for the previous 29 operating days (total of 30 consecutive operating days) and divide the resulting total by 30. (d) Annual average CO emission rates shall be calculated as follows: (i) The annual average CO emission rate shall be calculated no later than January 30 th of each year, and shall be calculated for the previous calendar year (January 1 through December 31). (ii) The owner/operator shall sum the hourly average CO emission rates, calculated according to paragraph (D) (1) (a) above, for the previous calendar year. The owner/operator shall then divide th e sum of the hourly averages by the number of hours for which an hourly average was obtained in accordance with paragraph (D) (1) (a) above.Construction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 13 of 14

(2) No later than 180 days following the completion of all element s of the OFA installation project and resuming normal operation of EU

- 1 , the owner/operator shall demonstrate initial compliance with the CO emission limit set forth in paragraph (B)(1) of this condition by utilizing the continuous emission monitoring system (CEMS) associated with EU

- 1 . The CEMS shall be maintained as follows: (a) The CEMS shall be certified in accordance with 40 CFR 60

– Appendix B

– Performance Specification 4. (b) Daily calibrations on the CEMS shall be conducted in accordance with 40 CFR Part 60 §60.13 paragraph (d)(1). (3) If the annual average CO emission rate for EU

- 1 , calculated in accordance with paragraph (D) (1)(d) of this condition, is less than 90% of the emission l imit set forth in paragraph (B)(1) of this condition, the owner/operator shall monitor CO emissions from EU

- 1 with a CEMS meeting the specifications established in paragraphs (D) (4)(a) and (D) (4)(b) of this condition, or with a CEMS that shall be certified and operated in accordance with the follo wing requirements: (a) The CEMS shall be operated in accordance with 40 CFR 60

– Appendix B

– Performance Specification 4. (b) Daily calibrations on the existing CEMS shall be conducted in accordance with 40 CFR Part 60 §60.13 paragraph (d)(1). (c) A relative accuracy test audit (RATA) shall be performed on the existing CEMS each year in accordance with the requirements set forth in paragraph (C)(1) of this condi tion. (4) If the annual average CO emission rate for EU

- 1 , calculated in accordance with paragraph (D) (1)(d) of this condition, exceeds 90% of the emission limit set forth in paragraph (B)(1) of this condition, the owner/operator shall monitor CO emissions from EU

- 1 with a CEMS that shall be certified and operated in accordance with paragraphs (D) (4) (a) and (D) (4) (b) below. The CEMS shall be installed, certified, and operational no later than June 15 th following the year in which the CO emission rate exceeds 90% of the emission limit set forth in paragraph (B)(1) of this condition. Prior to installation and certification of the new CEMS, the owner/operator shall continue to monitor the CO emissions using a CEMS meeting the specifications set forth in paragraph (D) (2) of this condition. (a) 40 CFR 60

– Appendix B

– Performance Specification 4 (b) 40 CFR 60

– A ppendix F (E) Record Keeping Requirements. (1) The owner/operator shall keep records in accordance with the requirements set forth in 40 CFR Part 60 §60.7 paragraph (f). (2) The owner/operator shall maintain records of all required monitoring information, which shall include the following: (a) The date and place as defined in the permit, and time of sampling or measurements; (b) The date(s) analyses were performed; (c) The company or entity that performed the analyses; (d) The analytical techniques or methods used; (e) The results of such analyses; and (f) The operating conditions existing at the time of sampling or measurement. (3) The owner/operator shall retain records of all required monitoring data, reports, and support information required by this permit for a period of at least 60 months fr om the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original chart recordings for continuous monitoring instrumentation, and copies of all reportsConstruction Permit No. 1 58 A NPPD Sheldon Station

Permit Type: Attainment Area PSD NSR LLCHD Source #: 00005

Lincoln

- Lancaster County Health Department Page 14 of 14

required by the permit. These records shall be readily accessible and made available for inspection upon request by the Department. (F) Reporting Requirements. (1) The owner/operator shall notify the Department if any 30

- day rolling average exceeds the CO emission limit set forth in paragraph (B)(1) of this condition. The notification shall be submitted to the Department in writing no later than 30 days after the exceedance. (2) The owner/operator shall notify the Department if the monitor downtime exceeds the 5% of the operating time for EU

- 1 during any calendar quarter. The notification shall be submitted to the Department in writing no later than 30 days after the end of the calendar quarter. (3) No later than January 30 th of each year, the owner/operator shall submit a report to the Department containing the following: (a) A statement of the emission limit set forth in paragraph (B)(1) of this condition. (b) The annual average CO emission rate for the previous calendar year, calculated in accordance with paragraph (D)(1)(d) of this condition. (4) The owner/operator shall report all criteria air pollutant and hazardous air pollutant emissions to the Department annually in accordance with the requirements set forth in Condition XI of this permit. (5) The owner/operator shall notify the Department of the intent to conduct any RATAs or performance tests no later than 30 days prior to the scheduled date of testing. (6) The owner/operator shall submit the result of all performance tests required by this permit to the Department within 60 days of the completion of such tests. (G) Additional Applicable Requirements. (1) After April 18, 2016, the owner/operator shall not operate EU

- 1 until such time that the stack height has been increased as specified in paragraph (G) (2) of this condition. (2) T he owner/operator shall increase the height of the stack associated with EU

- 1 to no less than two hundred twenty

- four fee t (224 ft.) above a ground

- level elevation of one thousand four hundred forty feet (1,440 ft.) by July 2, 2016, subject to delays beyond the reasonable control of t he owner/operator.