NPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 1 CONSTRUCTION PERMIT

PERMIT NUMBER: CP06-0001

PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
PERMIT TO MODIFY AN
AIR CONTAMINANT SOURCE
IS HEREBY ISSUED TO:

Nebraska Public Power District
PO Box 499 Columbus, Nebraska 68602-0499

FOR THE SPECIFIC MODIFICATION OF:

Replacing Unit 1 Existing Burner Equipment System with
New Low NO

x Burner Equipment System including Overfire Air Port System

TO BE LOCATED AT:

Gerald Gentleman Station 6089 South Highway 25 Sutherland, Lincoln County, Nebraska 69165

Pursuant to Chapter 14 of the Nebraska Air Qua lity Regulations, the public has been notified by prominent advertisement of this proposed modification of an air contaminant source and the thirty (30) day period allowed for comments has elapsed. This Construction Permit approves the proposed replacement of Unit 1’s existing burner equipment system with new Low NO

x burner equipment system including overfire air port system.

Compliance with this permit shall not be a defen se to any enforcement action for violation of an ambient air quality standard.

This permit is issued with the following conditions:

General Conditions

I. This permit is not transferable to anot her source or location. (Title 129, Chapter 17)

II. Holding of this permit does not relieve the ow ner/operator of the source from the responsibility to comply with all applicable portions of the Nebraska Air Quality Regulations and any other requirements under local, State, or Federal law. (Title 129, Chapter 41)NPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 2 III. Any applicant who fails to submit any relevant facts or who has submitted incorrect information in a permit application shall, upon becoming awar e of such failure or incorrect submittal, promptly submit such supplementary facts or corr ected information. If the source wishes to make changes at the facility that will result in change(s ) to values, specifications, and/or locations of emission points that were indicated in the permit application (or other supplemental information provided by the applicant and reviewed by the Depa rtment in issuance of this permit), the source must receive approval from the Department before the change(s) can be made. In addition, any modification which may result in an adverse change to the air quality impacts predicted by atmospheric dispersion modeling (such as changes in stack parameters or increases in emission rates, potential emissions, or actual emissions) sh all have prior approval from the Department. The source shall provide all necessary information to verify that there are no substantive changes affecting the basis upon which this permit was issued. Information may include, but not be limited to, additional engineering, modeling and ambient air quality studies. (Title 129, Chapter 17, Section 006 , 007 , & 008 )

IV. Approval to construct, recons truct and/or modify the source will become invalid if a continuous program of construction is not commenced within 18 months after the date of issuance of the construction permit, if construc tion is discontinued for a period of 18 months or more, or if construction is not completed within a reasonable period of time. (Title 129, Chapter 17, Section
012 )

V. The owner/operator of the source shall provide a notification to the Department of the date of construction, reconstruction or modification co mmenced, postmarked no later than 30 days after such date, and of the actual date of initial star tup of operation, postmarked within 15 days after such date. (Title 129, Chapter 17, Section 012 & Chapter 7, Section 002.03 )

VI. The permittee shall allow the Department, EPA or an authorized representative, upon presentation of credentials to (Title 129, Chapter 8, Section 012.02 ):

(A) Enter upon the permittee's premises at reasonable times where a source subject to this permit is located, emissions-related activity is conducted or records are kept, for the purpose of ensuring compliance with the permit or applicable requirements;

(B) Have access to and copy, at reasonable tim es, any records, for the purpose of ensuring compliance with the permit or applicable requirements;

(C) Inspect at reasonable times any facilities, pollution control equipment, including monitoring and air pollution control equipment, practices, or operations, for the purpose of ensuring compliance with the permit or applicable requirements;

(D) Sample or monitor at reasonable times substances or parameters for the purpose of ensuring compliance with the permit or applicable requirements.

VII. Applicable regulations: Title 129 - Nebraska Air Qua lity Regulations as amended March 14, 2006.

VIII. This permit may contain abbreviations and sym bols of units of measure which are defined in 40 CFR Part 60.3. Other abbreviations may include, but are not limited to, the following: Best Available Control Technology (BACT), Code of Federal Regulations (CFR), Compilation of Air Pollutant Emission Factors, Volume I, Stationary Point and Area Sources (AP-42), CarbonNPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 3 Monoxide (CO), Continuous Emissions Monitor (CEM), Hazardous Air Pollutant (HAP), Hazardous Air Pollutants (HAPs), Low NO

x Burners (LNB), Maximum Achievable Control Technology (MACT), National Ambient Air Quality Standards (NAAQS), New Source Performance Standards (NSPS), Nitrogen Oxides (NO

x ), Particulate Matter (PM), Particulate Matter less than or equal to 10 micrometers (PM 10 ), Prevention of Significant Deterioration (PSD), Sulfur Dioxide (SO 2 ), Volatile Organic Compounds (VOC).

IX. Open fires are prohibited except as allowed by Title 129, Chapter 30.

X. The source shall not cause or permit fugitive pa rticulate matter to become airborne in such quantities and concentrations that it remains visibl e in the ambient air beyond the property line. (Title 129, Chapter 32)

XI. Application for review of plans or advice furnis hed by the Director will not relieve the source of legal compliance with any provision of these regula tions, or prevent the Director from enforcing or implementing any provision of these regulations. (Title 129, Chapter 37)

XII. If and when the Director declares an air po llution episode as defined in Title 129, Chapter 38,
Sections 003.01B , 003.01C , or 003.01D , the source shall immediately take all required actions listed in Title 129, App. I until the Director declares the air pollution episode terminated.

Specific Conditions

XIII. Specific terms and conditions of this permit:

(A) BACT Emissions Limitation for Unit 1 . Pursuant to Title 129, Chapter 19, the permittee shall adhere to the following requirements, wh ich are deemed by the Department to be BACT. All such controls shall be fully functional during emission unit operation except as allowed during emission unit startup and shutdown periods.

(1) Carbon Monoxide (CO): BACT for CO sh all be the use of combustion controls to maintain a CO emissions limit of 0.50 lb/MMBtu (30-day rolling average). The CO BACT limit does not apply duri ng periods of startup and shutdown. Malfunctions shall be handled as described in Title 129, Chapter 35.

(a) The 30-day rolling average calculation shall be conducted as follows:

(i) The average CO emissions, for each hour, shall be recorded by sampling the lb/MMBtu value by completing a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period anytime Unit 1 is combusting fuel and the monitor is in service and is not malfunctioning or being calibrated. Data for st artup and shutdown shall not be used to calculate the average CO emissions. All data shall be reduced as specified in 40 CFR 60.13(h).

(ii) Daily average CO emission calculations will be calculated by taking the summation of the hourly averages, obtained by Condition XIII.(A)(1)(a)(i), and dividing by the number of hours in which there was a quality assured hourly average, to determine the average CO emissions for a particular day.NPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 4 (iii) The 30-day rolling average will be calculated each day by summing the daily average CO emission rates for the previous 30 days and dividing by 30.

(b) The permittee shall notify the Department, in writing, if any 30-day rolling average exceeds the CO emission limit in Condition XIII.(A)(1) or if monitored downtime exceeds 5% of unit operating time during a quarter. The notifications shall be submitted to the Department within 30 days of either occurrence.

(B) The permittee shall demonstrate initial complia nce, within 180 days after initial startup of Unit 1, with the emissions limit for CO by utilizing the existing CEMS installed on Unit

1.

(1) The existing CEMS shall be certified in accordance with 40 CFR 60 – Appendix B – Performance Specification 4.

(2) Daily calibrations on the existing CEMS shall be conducted in accordance with 40 CFR 60.13 (d)(1).

(C) By January 15 th of each year, the permittee shall calculate the annual average emission rate of CO emissions from the previous year shall be conducted according to the method outlined in Condition XIII.(C)(1).

(1) The annual average calculation shall be conducted as follows:

(a) The average CO emissions, for each hour , shall be recorded by sampling the lb/MMBtu value by completing a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period anytime Unit 1 is combusting fuel and the monitor is in service and is not malfunctioning or being calibrated. Data for startup and shutdown shall not be used to calculate the average CO emissions. All data shall be reduced as specified in 40 CFR 60.13(h).

(b) Annual average CO emission calculations will be calculated by taking the summation of the hourly averages, obtained in Condition XIII.(C)(1)(a) and dividing by the number of hours meeting the criteria described in Condition XIII.(C)(1)(a).

(2) By January 20 th of each year, the permittee shall submit to the Department a letter containing the annual average calculated in accordance with Condition XIII.(C)(1) and information on how the calculated annual average compares to the CO emissions
limitation.

(3) If the annual average emissions rate of CO emissions exceed 90% of the CO emissions limit, the permittee shall monitor its CO emissions with a CEMS that shall be certified and operated in accordance with the following:

(a) 40 CFR 60 – Appendix B – Performance Specification 4

(b) 40 CFR 60 – Appendix FNPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 5 The permittee shall have until June 15th of the year it has been determined that 90% of
the CO emissions limit has been exceeded to install and certify a CEMS in accordance with the specifications listed above. The pe rmittee shall continue to monitor its CO emissions utilizing the methods in Condition XIII.(B) until the CEMS has been certified in accordance with Condition XIII.(C)(3)(a).

(4) If the annual average emissions rate of CO emissions is less than 90% of the CO emissions limit, the permittee shall monito r its CO emissions in accordance with Conditions XIII.(C)(3)(a) and (b), or with its existing CEMS that shall be certified and operated in accordance with the following:

(a) The existing 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 60.13 (d)(1).

(c) A relative accuracy test audit (RATA) shall be performed on the existing CEMS each year in accordance with the following requirements:

(i) 40 CFR 60 – Appendix B – Performance Specification 4

(ii) Test Protocol: At least 45 days prior to the date of testing, the permittee shall develop and submit to the Department a formal “Test Protocol” which shall be approved by the Department prior to commencement of testing. This “Test Protocol” shall include, as a minimum, the following items:

1. A test plan detailing the methods and procedures that will be used for testing;

2. A test schedule describing the tentative agenda as to when testing will occur;

3. A description as to how testing will determine compliance with the permit conditions along with a copy of the permit.

(iii) Pre-Test Notification: The Department shall be notified in writing at least thirty (30) days prior to the dates of testing to allow the Department the option of witnessing portions of the

test.

(iv) Test Methods: Testing shall be done in accordance with Nebraska Title 129, Chapter 34 - Emission Sources; Testing; Monitoring.

(v) Final Test Report: A “Final Report” from emissions performance testing shall contain, as a minimum, the following
items:

1. An executive summary.NPPD-Gerald Gentleman Station-Supplemental BART Information for NCS Unit 1 - Attachment B.DOC Construction Permit-Page 6 2. A description of the source testing conditions, including but not limited to boiler information including, actual achieved firing rate (i.e. MMBtu/hr), quantity of fuel consumed (ton/hr), heating value of the fuel, ambient conditions, etc.

3. Copies of all data sheets from the test run(s).

4. A description and explanati on of any erroneous data or unusual circumstance(s) and the cause for such situation.

5. A final conclusion section describing the outcome of the testing.

6. A copy of the “Final Report,” including test results certified by the tester, shall be provided to the Department within forty-five (45) days after the completion of the tests.

(D) Records shall be maintained on-site for a minimum period of five (5) years. These records shall be clear and readily accessibl e to Department representatives and shall include the following:

(1) Copies of all notifications, reports, test results, and plans submitted to the Department shall be maintained.

(2) Recordkeeping as described in 40 CFR 60.7(f).

The undersigned issues this document on behalf of the Director in accordance with Title 129 – Nebraska Air Quality Regulations.

8/18/06 {Original Signed}

_______________________________________ _______________________________________ Date Shelley Kaderly Air Quality Division Administrator