SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Emission Standards and Fuel Specifications

1. The total emissions of air contaminants from any of the sources shall not exceed the 

values stated on the attached table entitled "Emission Sources - Maximum Allowable 

Emission Rates." Standard Permit No. 52617 is hereby consolidated into this permit by

reference. (11/07)

2. The 595 MW coal-fired boiler identified as Emission Point No. (EPN) U-5 shall comply

with all requirements of Environmental Protection Agency (EPA) Regulations on 

Standards of Performance for New Stationary Sources promulgated for Electric Utility

Generating Plants in Title 40 Code of Federal Regulations Part 60 (40 CFR 60), Subparts 

A and Da. (11/07)

Specifically, the facility shall comply with the 70 percent reduction requirement provided 

for in 40 CFR 60.43a(a)(2) and Subpart Da for sulfur dioxide independently of the 30-day

and 3-hour maximum allowable pound per hour emission rates for sulfur dioxide set forth 

in this permit. 

3. Should a permit condition be more stringent than a condition specified in the applicable 

New Source Performance Standards (NSPS), the permit condition shall govern and be the 

standard by which compliance will be demonstrated. 

4. Fuel used in the Auxiliary Boilers A-1 and A-2 shall be limited to pipeline quality sweet 

natural gas containing no more than 0.5 grains of hydrogen sulfide and 20 grains of total 

sulfur per 100 dry standard cubic feet. Use of any other fuel will require an amendment 

to the permit. Operation of Auxiliary Boilers A-1 and A-2 shall be limited to firing not 

more than 58,407,300 standard cubic feet of natural gas each in any consecutive 12-

month period (annual capacity factor of 10.5 percent). 

5. EPN A-1 and A-2 shall comply with all requirements of 40 CFR 60, Subparts A and Dc. 

6. Emissions shall not exceed 10 percent opacity (6-minute average) at the point of 

measurement for the utility boiler, EPN U-5, except during periods of routine 

maintenance, start-up, or shutdown (MSS) or as otherwise allowed by law. During 

periods of MSS, the opacity shall not exceed 20 percent over a six-minute period.

Opacity of emissions from the ash handling facilities described on the maximum 

allowable emission rates table shall not exceed 10 percent (six-minute average), except 

for those periods described in 30 TAC Section 111.111(a)(1)(E). Compliance will be 

determined using Reference Method 9. Disposal of ash must be accomplished in a 

manner that will prevent the ash from becoming airborne. (4/12)
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 2

7. Opacity of emissions from Auxiliary Boilers A-1 and A-2 must not exceed five percent 

averaged over a 6-minute period, except for those periods described in 30 TAC 111, 

§ 111.111(a)(1)(E) of Regulation I.

8. Emissions from the Spruce Unit 1 Utility Boiler exhausting through EPN U-5 shall not 

exceed the heat input-based performance standards identified in the table below. The 

heat input shall be based upon the higher heating value of the fuel. The performance 

standards of this permit condition shall apply at all times except during periods of routine 

MSS. During periods of routine MSS, the holder of this permit shall operate the Spruce 

Unit 1 and associated air pollution control equipment in accordance with good air 

pollution control practices to minimize emissions. The averaging periods identified in the 

table shall be the basis for continuous compliance. (4/12)

Pollutant

Performance

Standard

Averaging

Period

Compliance

Method

Nitrogen Oxides (NOx) 0.30 lb/MMBtu 30-day roll CEMS1

Sulfur Dioxide (SO2) 0.35 lb/MMBtu 30-day roll CEMS1

Sulfur Dioxide (SO2) 0.60 lb/MMBtu 3-hour roll CEMS1

Sulfur Dioxide (SO2) 1.20 lb/MMBtu 1- hour roll CEMS1

Particulate Matter20.03 lb/MMBtu Average of three one 

hour stack sampling 

runs

Stack Sample

Notes: 

1 CEMS - Continuous Emission Monitoring System. CEMS are subject to the requirements 

of Special Condition No. 11. 

2

Particulate Matter emission rate is for front half only as determined by EPA Reference 

Method 5, excluding back half condensable. 

Initial Determination of Compliance

9. Sampling ports and platform(s) shall be incorporated into the design of the steam 

generator stack according to the specifications set forth in the attachment entitled 

"Chapter 2, Stack Sampling Facilities." Alternate sampling facility designs may be 

submitted for approval by the San Antonio Regional Director.

10. The holder of this permit, at his own expense, shall utilize the services of an independent 

contractor to perform stack sampling and other testing as required to establish the actual 

pattern and quantities of air contaminants from EPN U-5. Sampling must be conducted 

in accordance with 40 CFR 60, Appendix A, Test Method 10, "Determination of Carbon 
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 3

Monoxide (CO) Emissions from Stationary Sources;" Method 7, "Determination of 

Nitrogen Oxide (NOx) Emissions from Stationary Sources;" Method 8, "Determination of 

Sulfur Dioxide (SO2) and Sulfuric Acid (H2SO4) Mist Emissions from Stationary

Sources;" Method 5, "Determination of Particulate Matter (PM) Emissions from 

Stationary Sources;" Method 9, "Visual Determination of Opacity from Stationary

Sources;" Method 13A or 13B, "Determination of Total Fluoride Emissions from 

Stationary Sources;" Method 25, "Determination of Total Gaseous Non-Methane Organic 

Emissions as Carbon" and in accordance with 40 CFR 61, Appendix B, Test Method 

101A, "Determination of Mercury (Hg) Emissions from Stationary Sources" and Test 

Method 104, "Determination of Beryllium (Be) Emissions from Stationary Sources." 

Test methods used to determine the concentration of other air contaminants to be sampled 

must be approved for, or any deviation from the specified test methods must be approved 

by, the permitting authority prior to sampling. 

A. The appropriate Texas Commission on Environmental Quality (TCEQ) San 

Antonio Regional Office shall be contacted as soon as testing is scheduled but not 

less than 45 days prior to sampling to schedule a pretest meeting. 

The notice shall include: 

1. Date for pretest meeting. 

2. Date sampling will occur. 

3. Name of firm conducting sampling. 

4. Type of sampling equipment to be used. 

5. Method or procedure to be used in sampling. 

The purpose of the pretest meeting is to review the necessary sampling and testing 

procedures, to provide the proper data forms for recording pertinent data and to review 

the format procedures for submitting the test reports. 

A written proposed description of any deviation from sampling procedures specified in 

permit provisions or TCEQ or EPA sampling procedures shall be made available to the 

TCEQ prior to the pretest meeting. The San Antonio Regional Director shall approve or 

disapprove of any deviation from specified sampling procedures.

Requests to waive testing for any pollutant specified in B of this provision shall be 

submitted to the TCEQ Office of Air, Air Permits Division. Test waivers and 

alternate/equivalent procedure proposals for NSPS testing which must have EPA 

approval shall be submitted to the EPA and copied to the TCEQ Regional Office. 

B. Air contaminants emitted from the Utility Boiler Stack (EPN U-5) to be tested for 

include (but are not limited to) opacity, CO, NOx, SO2, PM, volatile organic 

compounds (VOC), Hg, Be, hydrogen fluoride (HF) and H2SO4. The permitting 
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 4

authority may require additional testing if deemed appropriate. 

C. Sampling shall occur within 60 days after commencement of commercial 

operation, but not later than 180 days after initial start-up of the boiler and at such 

other times as may be required by the Executive Director of the TCEQ. Requests 

for additional time to perform sampling shall be submitted to the TCEQ San 

Antonio Regional Office. Additional time to comply with the applicable 

requirements of 40 CFR 60 and 40 CFR 61 requires EPA approval and requests 

shall be submitted to the EPA and copied to the TCEQ Regional Office. 

D. The plant shall operate at maximum production rates during stack emission 

testing. Primary operating parameters that enable determination of production 

rate shall be monitored and recorded during the stack test. These parameters are 

to be determined at the pretest meeting. If the plant is unable to operate at 

maximum rates during testing, then future production rates may be limited to the 

rates established during testing. Additional stack testing may be required when 

higher production rates are achieved. 

E. Four copies of the final sampling report shall be forwarded within 30 days after 

sampling is completed. Sampling reports shall comply with the attached 

provisions of Chapter 14 of the TCEQ Sampling Procedures Manual. The reports 

shall be distributed as follows: 

One copy to the appropriate TCEQ San Antonio Regional Office. 

One copy to the appropriate local air pollution control program. 

One copy to the Air Enforcement Branch, EPA, Dallas.

Continuous Determination of Compliance

11. The holder of this permit shall install, calibrate and maintain a continuous emission 

monitoring system (CEMS) to measure and record the in-stack concentration of NOx (all, 

as in nitrogen oxide plus nitrogen dioxide), SO2, and CO from the boiler stack (EPN U5). The holder of this permit shall also install, calibrate, and maintain a continuous 

opacity monitoring system (COMS) for measuring the effective opacity of emissions from 

the utility boiler. The COMS may be located where no interference with opacity readings 

will be experienced due to water droplets from the FGD system; however, the location 

must meet the measurement path requirements of 40 CFR 60, Appendix B, Performance 

Specification 1, Section 4.2. The monitoring data collected from the COMS shall be 

reported as effective combined opacity using the procedures contained in EPA document 

NO. EPA625/6.79.005, Section 4.6, pages 4-13 through 4-16. Continuous flow 
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 5

monitoring of each baghouse duct will not be required under normal operating conditions 

provided initial performance testing demonstrates that the flows from each baghouse at or 

near the location of each opacity monitor are within plus or minus 10 percent of equal 

flow. The CEMS and COMS shall meet the design and performance specifications, pass 

the field tests and meet the installation requirements and the data analysis and reporting 

requirements specified in the applicable Performance Specifications No. 1 through 6, 40 

CFR 60, Appendix B. The CEMS shall be zeroed and spanned daily and corrective 

action taken when the 24-hour span drift exceeds two times the amounts specified in 40 

CFR 60, Appendix B. If applicable, 40 CFR 75, Appendix A and B may be used as an 

alternative to 40 CFR 60, Appendix B

The monitoring data collected from the CEMS for NOx, SO2 and CO shall be reduced to 

hourly average concentrations at least once every day using a minimum of four equally

spaced data points over each one-hour period. The individual average concentrations of 

NOx, SO2 and CO shall be reduced to units of the permit allowable emission rate in ppm, 

lb/MMBtu and lb/hr as appropriate at least once every week. All monitoring data and 

quality assurance data shall be maintained by the source for a period of two years and 

shall be made available to the TCEQ San Antonio Regional Office in accordance with the 

conditions of 40 CFR 60.7(b) and (c). The data from the CEMS and COMS shall be used 

to demonstrate continuous compliance with the provisions of this permit. The CEMS and 

COMS required by this permit shall be subject to all future quality assurance 

requirements as they are published in the TCEQ Sampling Procedures Manual and the 

Federal Register. 

A. Excess emission reports for CEMS shall be submitted quarterly following the 

provisions of 40 CFR 60.7(c). The report must include a summary of exceedances

and monitor downtime by cause. Specific reporting requirements for SO2, NOx 

and opacity are described in 40 CFR 60.49(a) and shall be complied with by the 

permittee. 

B. If applicable, each CEMS will be required to meet the design and performance 

specifications, pass the field tests, and meet the installation requirements and data 

analysis and reporting requirements specified in the applicable performance 

specifications in 40 CFR Part 75, Appendix A and B, as an acceptable alternative 

to applicable parts of Special Condition 11 and 11 A. (11/07)

C. During the initial compliance test required in Special Conditions No. 10, the 

holder of this permit shall demonstrate that at the allowable opacity, the allowable 

emission rate for Be and Hg will not be exceeded. Compliance with the opacity

limitation for EPN U-5 shall be the best evidence of compliance with the 

allowable Be and Hg emission rates.
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 6

D. During the initial compliance test required in Special Conditions No. 10, the 

holder of this permit shall demonstrate that at the allowable emission rate for 

SO2, the allowable emission rate for HF will not be exceeded. Compliance with 

the allowable emission rate for SO2 shall be the best evidence of compliance with 

the allowable HF emission rate. 

E. During the initial compliance test required in Special Conditions No. 10, the 

holder of this permit shall demonstrate that at the allowable emission rate for CO, 

the allowable emission rate for VOC will not be exceeded. Compliance with the 

allowable emission rate for CO shall be the best evidence of compliance with the 

VOC allowable emission rate. 

Recordkeeping Requirements

12. The following records shall be maintained by the source at the site for a period of two 

years and shall be made available to the Executive Director or his designated 

representative upon request:

A. Hours of operation of Auxiliary Boilers A-1 and A-2.

B. Amount of fuel fired in Auxiliary Boilers A-1 and A-2 on a daily basis to ensure 

the 10.5 percent capacity factor authorized is not exceeded.

C. Monitoring and quality assurance records required by Special Conditions No. 11

in accordance with the conditions of 40 CFR 60.7(b) and (c). 

13. A copy of this permit shall be kept at the plant site and made available at the request of 

personnel from the TCEQ or any air pollution control agency with jurisdiction.

14. The holder of this permit shall physically identify and mark in a conspicuous location all 

equipment that has the potential of emitting air contaminants as follows:

A. The facility identification numbers as submitted to the Emissions Inventory

Section of the TECQ.

B. The EPNs as listed on the Maximum Allowable Emission Rates Table.
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 7

Routine Maintenance, Startup, and Shutdown

15. This permit authorizes the emissions from the planned maintenance, startup, and shutdown 

(MSS) activities listed in Attachment A, Attachment B, or the MAERT attached to this 

permit. Attachment A identifies the inherently low emitting (ILE) planned maintenance 

activities that this permit authorizes to be performed. Attachment B identifies the planned 

MSS activities that are non-ILE planned maintenance activities that this permit authorizes

to be performed. (4/12)

16. The holder of this permit shall minimize emissions during planned MSS activities by

operating the facility and associated air pollution control equipment in accordance with 

good air pollution control practices, safe operating practices, and protection of the facility. 

(4/12)

17. Emissions during planned startup and shutdown activities will be minimized by limiting the 

duration of operation in planned startup and shutdown mode as follows: (4/12)

A. A planned cold startup of the electric generating facility (EGF), Spruce Unit 1, is 

defined as the period that begins with the first stage metal temperature being less than 

300 degrees Fahrenheit, and a hot startup event is defined as a startup that is not a 

cold startup. Startup commences when the Induced Draft Fan is placed in service and 

is complete when the boiler is released to dispatch. A planned cold start event 

shall not exceed 840 minutes in duration and a hot startup event shall not exceed 480 

minutes in duration. Extended startups lasting longer than either a cold or hot start 

duration are allowed provided the total hours of extended startups does not exceed 

600 hours per unit per year.

B. A planned shutdown of the EGF, Spruce Unit 1, is defined as the period that 

commences when dispatched requests a shutdown due to market conditions or when 

plant personnel request a shutdown for maintenance, and ends when fuel is no longer 

fired. A planned shutdown event shall not exceed 360 minutes in duration. 

18. When a planned maintenance activity identified in Attachment B is associated with a VOC 

liquid storage facility and may result in VOC emissions from that facility, the permit holder 

shall not open that facility to the atmosphere in connection with the planned maintenance 

activity until the VOC liquids are removed from that facility to the maximum extent 

practicable. (4/12)

19. No vacuum pump on a vacuum truck that is used to move solids (such as ash) during 

planned maintenance activities shall be operated unless the vacuum system exhaust is 

routed to a filtering system. (4/12)
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 8

20. Vacuum trucks that are used to move liquids during planned maintenance activities shall 

utilize submerged loading. (4/12)

21. Compliance with the emissions limits for planned MSS activities identified in the MAERT 

attached to this permit may be demonstrated as follows. (4/12)

A. For each pollutant emitted during ILE planned maintenance activities, the permit 

holder shall annually confirm the continued validity of the estimated potential to emit 

represented in the permit application for all ILE planned maintenance activities. The 

total emissions from all ILE planned maintenance activities (See Attachment A) shall 

be considered to be no more than the estimated potential to emit for those activities 

that are represented in the permit application.

B. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions are measured using a CEMS, as per Special Condition No. 22A, 

the permit holder shall compare the pollutant’s short-term (hourly) emissions during 

planned MSS activities as measured by the CEMS to the applicable short-term 

planned MSS emissions limit in the MAERT.

C. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions occur through a stack, but are not measured using CEMS as per 

Special Condition No. 22A, the permit holder shall determine the total emissions of 

the pollutant through the stack that result from such non-ILE planned MSS activities 

in accordance with Special Condition No. 22B.

D. For each pollutant emitted during non-ILE planned MSS activities (See Attachment 

B) whose emissions do not occur through a stack, the permit holder shall do the 

following for each calendar month.

(1) Determine the total emissions of the pollutant from such non-ILE planned MSS 

activities in accordance with Special Condition No. 22B.

(2) Once monthly emissions have been determined in accordance with Special 

Condition No. 21D(1) for 12 months after the MSS permit amendment has been 

issued, the permit holder shall compare the sum of the rolling 12-month 

emissions for the pollutant for all non-ILE planned MSS activities to the annual 

emissions limit for the pollutant in the MAERT.

22. The permit holder shall determine the emissions during planned MSS activities for use in 

Special Condition No. 21 as follows. (4/12)

A. For each pollutant whose emissions during normal facility operations are measured 

with a CEMS that has been certified to measure the pollutant’s emissions over the 
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 9

entire range of a planned MSS activity, the permit holder shall measure the emissions 

of the pollutant during the planned MSS activity using the CEMS.

B. For each pollutant not described in Special Condition No. 22A, the permit holder 

shall calculate the pollutant’s emissions during all occurrences of each type of 

planned MSS activity for each calendar month using the frequency of the planned 

MSS activity identified in work orders or equivalent records and the emissions of the 

pollutant during the planned MSS activity as represented in the planned MSS permit 

application. In lieu of using the emissions of the pollutant during the planned MSS 

activity as represented in the planned MSS permit application to calculate such 

emissions, the permit holder may determine the emissions of the pollutant during the 

planned MSS activity using an appropriate method, including but not limited to, any

of the methods described in paragraphs 1 through 4 below, provided that the permit 

holder maintains appropriate records supporting such determination:

(1) Use of emission factor(s), facility-specific parameter(s), and/or engineering 

knowledge of the facility’s operations.

(2) Use of emissions data measured (by a CEMS or during emissions testing) 

during the same type of planned MSS activity occurring at or on a similar 

facility, and correlation of that data with the facility’s relevant operating 

parameters, including, but not limited to, electric load, temperature, fuel input, 

and fuel sulfur content.

(3) Use of emissions testing data collected during a planned MSS activity occurring 

at or on the facility, and correlation of that data with the facility’s relevant 

operating parameters, including, but not limited to, electric load, temperature, 

fuel input, and fuel sulfur content.

(4) Use of parametric monitoring system (PEMS) data applicable to the facility. 

23. With the exception of the emission limits in the MAERT attached to this permit, the permit 

conditions relating to planned MSS activities do not become effective until 60 days after 

issuance of the permit amendment that added such conditions. (4/12) 

Permits by Rule and Standard Permits

24. The following maintenance activities at the site are currently authorized by permits by rule 

(PBR) under 30 TAC Chapter 106. The standard permit identified below was issued under 

30 TAC Chapter 116. (4/12)
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 10

Description PBR/Standard 

Permit No.

Brazing, Soldering, and Welding 106.227

Enclosed Dry Abrasive Blasting 106.263

Solvent Cleaning-Parts Degreaser 106.454

Hand-Held Equipment for Buffing, 

Polishing, Cutting, Drilling, Sawing, 

Grinding, Turning, or Machining 

Wood, Metal or Plastic

106.265

Standard Permit for Pollution Controls 52617

Date: April 10, 2012
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 11

Attachment A

Permit Nos. 18426 and PSDTX742M1

Inherently Low Emitting (ILE) Planned Maintenance Activities

Planned Maintenance Activity Emissions

NH3/Urea VOC NOx CO PM SO2

Miscellaneous particulate filter 

maintenance1 X

Maintenance of storage vessels 

storing material with vapor 

pressure <0.5 psia

X X

Catalyst handling and 

maintenance X

Water based washing X

Organic chemical usage, not 

authorized by “manual surface 

coating or solvent cleaning 

operations” or by “use and 

disposal of aerosol products”

X

Boiler general maintenance2

X

Management of sludge from 

pits, ponds, sumps, and water 

conveyances3 

X

Inspection, repair, replacement, 

adjusting, testing, and 

calibration of analytical 

equipment, process instruments 

including sight glasses, meters, 

gauges, CEMS, PEMS. 

X X X X

Deslagging of boiler4

X X X X

Material handling system 

maintenance5 X

Small equipment and fugitive 

component repair/replacement 

in VOC and inorganic service6

X X

Notes:
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 12

1. Includes, but is not limited to, baghouse filters, ash silo/transfer filters, coal handling 

filters, process-related building air filters, and combustion turbine air intake filters.

2. Includes pre-heater basket handling and maintenance, refractory change-out, fan 

maintenance and balancing, damper, air heater, and soot blower maintenance, and any

other general boiler maintenance that does not exceed the worst-case emissions 

representation in the application.

3. Includes, but is not limited to, management by vacuum truck/dewatering of materials in 

open pits and ponds, and sumps, tanks and other closed or open vessels. Materials 

managed include water and sludge mixtures containing miscellaneous VOCs such as 

diesel, lube oil, and other waste oils.

4. Includes, but is not limited to, explosive blasting, clinker shooting, and other boiler 

deslagging activities; does not include dry abrasive blasting that may occur in boilers. 

5. Material handling system equipment includes, but is not limited to, silos, transport 

systems, coal bunkers, coal crushing equipment, coal handling, nuvafeeders, hoppers, 

FGD sludge handling system. Materials handled include coal, ash, limestone, gypsum, 

mercury, and sorbents. 

6. Includes, but is not limited to, (i) repair/replacement of pumps, compressors, valves, 

pipes, flanges, transport lines, filters and screens in natural gas, fuel oil, diesel oil, 

ammonia, lube oil, and gasoline service, (ii) vehicle and mobile equipment maintenance 

that may involve small VOC emissions, such as oil changes, transmission service, and 

hydraulic system service, and (iii) off-line NOx control device maintenance (including 

maintenance of the anhydrous ammonia systems and aqueous ammonia systems 

associated with SCR systems and SNCR systems)
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 13

Attachment B

Permit Nos. 18426 and PSDTX742M1

Non-Inherently Low Emitting Planned MSS Activities

Planned Maintenance Activity

Emissions

EPN NH3/Urea VOC NOX CO PM SO2

Combustion optimization1

U-5 X X X X X

Vacuum truck solids loading2

MSSFUG4 X

Vacuum truck solids 

unloading MSSFUG4 X

Maintenance of storage 

vessels storing gasoline or 

other material with vapor 

pressure >0.5 psia that 

requires clearing of the vessels 

to allow for entry of personnel 

MSSFUG4 X X

Flue gas conditioning system 

maintenance - unit online U-5 X X

Flue gas conditioning system 

maintenance fugitives - unit 

offline3

MSSFUG4 X X

NOx control device 

maintenance - unit online U-5 X X

PM control device 

maintenance - unit online U-5 X

SO2 control device 

maintenance - unit online U-5 X

Smoke test of boiler U-5 X X X X

Smoke test of boiler fugitives MSSFUG4 X X X X

Use of fans during 

maintenance - unit offline U-5 X

Main unit Planned Startup and 

Planned Shutdown U-5 X X X X X X
SPECIAL CONDITIONS

Permit Numbers 18426 and PSDTX742M1

Page 14

Notes:

1. Includes, but is not limited to, (i) leak and operability checks (e.g., turbine overspeed tests, troubleshooting), (ii) balancing, and (iii) tuning activities that occur 

during seasonal tuning or after the completion of initial construction, a combustor 

change-out, a major repair, maintenance to a combustor, or other similar 

circumstances.

2. Includes site-wide solids vacuuming operations (e.g., SCR, baghouse, ESP, ducts, 

furnace, loop seals, stripper coolers, and airlocks).

3. Includes, but is not limited to, maintenance of anhydrous ammonia systems and 

aqueous ammonia systems used to condition flue gas before it is controlled by a 

PM control device.

4. Emission point MSSFUG represents permitted site-wide MSS fugitive emissions 

for J.T. Deely Units 1 and 2, and Spruce Units 1 and 2. MSSFUG emissions are 

quantified in the maximum allowable emissions rate table in Permit No. 70492

and PSDTX1037.