SPECIAL CONDI TI ONS P ermit Numbers 18426 and PSDTX 742M1 **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
- M aximum Allowable Emission Rates." Standard Permit No. 52617 is hereby consolidated into this permit by reference
. ( 11/07 ) 2. The 5 9 5 MW coal
- fired boiler identified as Emission Point No. (EPN) U
- 5 shall comply with all requirements of Environmental Prote ction 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

sha ll comply

with the 70 percent reduction requirement provided for in 40 CFR 60.43a(a)(2) and Subpart Da for sulfur dioxide in dependently 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 Aux iliary 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 air bo rne. (4 /12)SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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 con dition 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 p ractices 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 (NO x ) 0.30 lb/MMBtu 30
- day roll CEMS 1 Sulfur Dioxide (SO 2 ) 0.35 lb/MMBtu 30
- day roll CEMS 1 Sulfur Dioxide (SO 2 ) 0.6 0 lb/MMBtu 3
- hour roll CEMS 1 Sulfur Dioxide (SO 2 ) 1.2 0 lb/MMBtu 1
- hour roll CEMS 1 Particulate Matter2 0.03 lb/MMBtu Average of three one hour stack sampling runs Stack S ample

Notes: 1 CEMS
- Continuous Emission Monitoring Sy stem. C EMS are subject to the requirements of Special Condition No. 1 1
. 2 Particulate Matter emission rate is for front half only as determined by E PA Reference Method 5, excluding back half condensabl e. **Initial Determination o f 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." Alt ernate 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 CarbonSPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 3 Monoxide (CO) Emissions from Stationary Sources;" Meth od 7, "Determination of Nitrogen Oxide (NOx) Emissions from Stationary Sources;" Method 8, "Determination of Sulfur Dioxide (SO2) and Sulfuric Acid (H2SO4) Mist Emissions f rom Stationary Sources;" Method 5, "Determination of Particulate Matter (PM) Emissio ns 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 Emissio ns 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 ( T CEQ) San Antonio R egional O ffice shall be contacted as soon as testing is scheduled but not less than 45 day s prior to sampling to schedule a pretest meeting. The notice shall include: 1. Date for pretest meeting. 2. Date sampling will o ccur. 3. Name of firm conducting sampling. 4. Ty pe 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 T CEQ 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 s hall be submitted to the T CEQ 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 cont aminants 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 permittingSPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 4 authority

may require addition al testing if deemed appropriate. C. Sampling shall occur within 60 day s 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 T CEQ . Requests for additional time to perform sampling shall be submitted to the TCEQ San Antonio Regional O ffice. Additional time to comply with the applicable requirements of 40 CFR 60 and 40 CFR 61 requires EPA approval and requests shall be subm itted 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. I f 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 te sting 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 T CEQ 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 o f Compliance**  11
. The holder of this permit shall install, calibrate and maintain a continuous emission monitoring sy stem (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 U
5). The holder of this permit shall also install, calibrate, and maintain a continuous opacity monitoring sy stem (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, S ection 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 flowSPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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, Appe ndix 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 CF R 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 averag e 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 accor dance 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 sub mitted 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 w ith 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 analy sis and reporting requirements specified in the applicable p erformance 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 permi t 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.SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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 emis sion rate for SO2 shall be the best evidence of c ompliance 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 s hall be maintained by the source at the site for a period of two ye ars 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 o f 40 CFR 60.7(b) an d (c). 13
. A copy

of this permit shall be kept at the plant site and made available at the request of personnel from the T CEQ or any air pollution control agency with jurisdiction. 14
. The holder of this permit shall phy sically identify and mark in a c onspicuous 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 T ECQ
. B. The EPNs as listed on the Maximum Allowable Emission Rates Table.SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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. Attachm ent 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
- ILEplanned 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 operat ing 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 star tup 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 i s 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 shutd own of the EGF , Spruce Unit 1 , is d efined 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 min utes 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 sy stem. (4 /12)SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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 n o more than the estimated potential to emit for those activities that are represented in the permit application. B. For each pollutant emitted during non
- ILEplanned MSS activities (See Attachment B) whose emissions are measured using a CEMS, as pe r 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 pol lutant emitted during non
- ILEplanned 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
- ILEplanned MSS activities in accordance with Special Condition No. 22B. D. For each pollutant emitted during non
- ILEplanned MSS activities (See Attachment B) whose emissions do not occur through a stack, the permit hol der shall do the following for each calendar month. (1) Determine the total emissions of the pollutant from such non
- ILEplanned MSS activities in accordance with Special Condition No. 22B. (2) Once monthly

emissions have been determined in accordance wi th 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
- ILEplanned MSS activities to the annual e missions 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 operatio ns are measured with a CEMS that has been certified to measure the pollutant’s emissions over theSPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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 ty pe 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 plann ed 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 knowled ge of the facility ’s operations. (2) Use of emissions data measured (by a CEMS or during emissions testing) during the same ty

pe of planned MSS activity occurring at or on a similar facility , and correlation of that data with the facility ’s relev ant 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 o f 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 sy stem (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)SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 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 5 2617

Date: April 10, 2012SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 11

Attachment A Permit Nos. 18426 and PSDTX 742M1 Inherently

L ow Emitting (ILE) P lanned Maintenance Activities Planned Maintenance Activity Emissions NH 3 /Ur ea VOC NOx CO PM SO 2 Miscellaneous particulate filter maintenance 1 X Maintenance of storage vessels storing material with vapor pressure <0.5 psia X X Cataly st 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 maintenance 2 X Management of sludge from pits, ponds, sumps, and water conveyances 3 X In spectio n, repair, replacement, adjusting, testing, and calibration of analy

tical equipment, process instruments including sight glasses, meters, gauges, CEMS, PEMS. X X X X Deslagging of boiler 4 X X X X Material handling sy stem maintenance 5 X Small equipment and fugitive component repair/replacement in VOC and inorganic service 6 X X Notes:SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 12
1. In cludes, but is not limited to, baghouse filters, ash silo/transfer filters, coal handling filters, process
- related building air filters, and combusti on turbine air intake filters. 2. In cludes 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 wor st - case emissions representation in the application. 3. In cludes, 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 m ixtures containing miscellaneous VOCs such as diesel, lube oil, and other waste oils. 4. In cludes, but is not limited to, explosive blasting, clinker shooting, and other boiler deslagging activities; does not include dry abrasive blasting that may occur in bo ilers. 5. Material handling sy stem equipment includes, but is not limited to, silos, transport sy stems, coal bunkers, coal crushing equipment, coal handling, nuvafeeders, hoppers, FGD sludge handling sy stem. Materials handled include coal, ash, limestone, gyp sum, mercury , and sorbents. 6. In cludes, 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, (i i) vehicle and mobile equipment maintenance that may involve small VOC emissions, such as oil changes, transmission service, and hydraulic sy stem service, and (iii) off
- line NOx control device maintenance (including maintenance of the anhydrous ammonia sy s tems and aqueous ammonia sy stems associated with SCR sy stems and SNCR sy stems)SPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 13
Attachment B Permit Nos. 18426 and PSDTX 742M1 Non
- Inherently

L ow Emitting Planned MSS Activities Planned Maintenance Activity Emissions EPN NH 3 /Urea VOC NO X CO PM SO 2 Combustion optimization 1 U
- 5 X X X X X Vacuum truck solids loading 2 MSSFUG 4 X Vacuum truck solids unloading MSSFUG 4 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 MSSFUG 4 X X Flue gas conditioning sy stem maintenance
- unit online U
- 5 X X Flue gas conditioning sy stem maintenance fugitives
- unit offline 3 MSSFUG 4 X X NOx control device maintenance
- unit on line U
- 5 X X PM control device maintenance
- unit online U
- 5 X S O 2 control device maintenance
- unit online U
- 5 X Smoke test of boiler U
- 5 X X X X Smoke test of boiler fugitives MSSFUG 4 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 XSPE CIAL CONDITIONS

P ermit Numbers 18426 and PSDTX 742M1 Page 14

Notes: 1. In cludes, but is not limited to, (i) leak and operability checks (e.g., turbine over
speed tests, troubleshooting), (ii) balancing, and (iii) tuning activit ies 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. In cludes site
- wide solids vacuuming operations (e.g., SCR, baghouse, ESP, ducts, furnace, loop seals, stripper coolers, and airlocks). 3. In cludes, but is not limited to, maintenance of anhydrous ammonia sy stems and aqueous ammonia sy stems used to condition flue gas before it is controlled by a PM control device. 4. Emissio n 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
.