DE 

DAN WYANT 

DIRECTOR 

STATE OF MICHIGAN 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

LANSING 

RICK SNYDER 

GOVERNOR 

July 8, 3013 

Mr. Barry Marietta, EQ-Supervisor EM&R 

DTE Electric Company 

One Energy Plaza 

Detroit, Michigan 48226 

Dear Mr. Marietta: 

This letter is in reference to your Permit to Install application for modifications at the Monroe Power Plant(State 

Registration Number B2816) located at 3500 East Front Street, Monroe, Michigan. This application, identified as 

No. 27-13, has been evaluated and approved by the Air Quality Division (AQD), pursuant to the delegation of 

authority from the Michigan Department of Environmental Quality (DEQ). 

This approva is based upon and subject to compliance with all administrative rules promulgated pursuantto Part 55, 

Air Pollution Control, of the Natural Resources and Environmenta Protection Act, 1994 PA 51, as amended 

(Act 451), and conditions stipulated in the attached supplement. Please review these conditions thoroughly so that 

you may take the actions necessary to ensure compliance with all of these conditions. 

Also, Permit to Insta Nos. 93-09B and 63-11 have been voided because the equipment is now covered by Permit to 

Install No. 27-13. 

The equipmen covered by this permit is also subject to the requirements of the Renewable Operating Permit 

Program. Submittal of the M-001 and C-001 forms may be required prior to commencing operation. Additional 

information is included in the M-001 form instructions. The forms and instructions are available on the |ntennet, or 

they can be obtained by contacting the Jackson District Office at 517-780-7690. The AQD permit web page is 

located at http:I/www.deq.state.mi. uslaps. 

A change that is subject to Rule 215nubru/ea(1).(2).or(3)of Act 451 requires the submitta of the forms to the 

appropriate AQD District Office. If a change is made pursuant to Rule 216, please submit the required forms to the 

Kalamazoo District Office at the address provided in the M-001 form instructions. 

To help us improve the service we provide our customers, we encourage you to complete a Permit to Install 

Customer Service Survey on the following Web page: 

htbz6lwnww.michigon.gov/documents/deq/DEOEvai29-pU'nuotomermanice_2D72OS_7.htm | 

Please contac me if you have any questions regarding this permit. 

Sincerely, 

Julie L. Brunner, P.E. 

Permit Section, Air Quality Division 

517'373-7088 

bnunnerj1 miohigen.gov 

Attachment 

cc/att: Mr. i Andn*wFadmne/i. DIE Energy 

Mr. Scott Miller, DEQ 

CONSTITUTION HALL ^os WEST mLEoAN STREET ^puBOX 30473` LANSING, MICHIGAN 48909-7973 

www.mmhigan.gov/deq~(800)s62-9278 
MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY 

AIR QUALITY DIVISION 

June 25, 2013 

PERMIT TO INSTALL 

27-13 

ISSUED TO 

DTE Electric Company 

LOCATED AT 

3500 East Front Street 

Monroe, Michigan 

IN THE COUNTY OF 

Monroe 

STATE REGISTRATION NUMBER 

B2816 

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

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

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

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

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

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

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

to Install is allowed pursuant to Rule 336.1201(6). 

DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203: 

June 19, 2013 

DATE PERMIT TO INSTALL APPROVED: 

June 25, 2013 

SIGNATURE: 

(2. 

DATE PERMIT VOIDED: SIGNATURE: 

DATE PERMIT REVOKED: SIGNATURE: 

DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit enn 27-13 Page 1 of 101 

PERMIT TO INSTALL 

Table of Contents 

Section Page 

Alphabetical Listing of Common Abbreviations /Acnonyms----------------------------3 

Genena|Cunditions----------------------------------------.--------. 4 

3pecedConditions-------------------------------------------------6 

Emission Unit Summary Table------------------------------------------'8 

Special Conditions for EU-UN[T1-G1---------------------------------------. Q 

Special Conditions for EU-UN[T2-S1--------------------------------------'18 

Special Conditions for EU-UN|T3-S1--------------------------------------'2S 

Special Conditions for EU-UN[T4-S1--------------------------------------'38 

Emission Unit EU-VVFGD-QP1------------------------------------------47 

Emission Unit EU-VVFGO-QP2------------------------------------------5O 

Emission Unit EU-VVFGU-QP3----------.-------------------------------. 53 

Emission UnitEU-VVFGD-QP4------------------------------------------5O 

Special Conditions for EU-CA8CADES-81-----------------------------------'5S 

Special Conditions for EU-TRANSFERHS-S1----------------------------------G3 

Special Conditions for EU-OUK8PERHG-G1-----------------------------------. G7 

Special Conditions for EU-COALUN LOAD-Si ----------------------------------7D 

Special Conditions for EU-CRUSHERH8-81----------------------------------'72 

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

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

Special Conditions for EU-LK8ESTONE-81--------------------.---------------81 

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

Special Conditions for EU-HYDRATEOL|K8E-81--------------------------------'87 

Flexible Group Summary Toble------------------------------------.-----8O 

Special Conditions for 1-4-------------------------------------91 
DTE Electric Company, Monroe Power Plant (132816) I 

Permit No. 27-13 

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

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

Appendices............................................................................................................ 

June 25, 2013 

Page 2 of 101 

95 

97 

99 
~ ~ 

DTE Electric Company Monroe Power Plant (82818) 

Permit No. 27-13 

June 25, 2013 

Page 3 of 101 

Common Abbreviations / Acronyms 

Common Acronyms Pollutant I Measurement Abbreviations 

AQD Air Quality Division BTU British Thermal Unit 

BACT Best Available Control Technology °C Degrees Celsius 

CAAA Clean Air Act CO Carbon Monoxide 

CEM Continuous Emission Monitoring dscf Dry standard cubic foot 

CFR Code of Federal Regulations dscm Dry standard cubic meter 

CO2e Carbon Dioxide Equivalent °F Degrees Fahrenheit 

COM Continuous Opacity Monitoring gr Grains 

EPA Environmental Protection Agency Hg Mercury 

EU Emission Unit hr Hour 

FG Flexible Group H2S Hydrogen Sulfide 

GACS Gallon of Applied Coating Solids hp Horsepower 

GC General Condition lb Pound 

GHGs Greenhouse Gases kW Kilowatt 

HAP Hazardous Air Pollutant m Meter 

HVLP High Volume Low Pressure * mg Milligram 

ID Identification mm Millimeter 

LAER Lowest Achievable Emission Rate MM Million 

MACT Maximum Achievable Control Technology MW Megawatts 

MAERS Michigan Air Emissions Reporting System ng Nanogram 

MAP Malfunction Abatement Plan NO Oxides of Nitrogen 

MDEQ Michigan Department of Environmental PM Particulate Matter Quality (Department) 

MSDS Material Safety Data Sheet PMIO PM with aerodynamic diameter ~10 microns 

NESHAP National Emission Standard for PM2.5 PM with aerodynamic diameter ~ 2.5 microns Hazardous Air Pollutants 

NSPS New Source Performance Standards pph Pounds per hour 

NSR New Source Review ppm Parts per million 

PS Performance Specification ppmv Parts per million by volume 

PSD Prevention of Significant Deterioration ppmw Parts per million by weight 

PTE Permanent Total Enclosure psia Pounds per square inch absolute 

PTI Permit to Install psig Pounds per square inch gauge 

RACT Reasonably Available Control scf Standard cubic feet Technology 

ROP Renewable Operating Permit sec Seconds 

SC Special Condition SO2 Sulfur Dioxide 

SCR Selective Catalytic Reduction THC Total Hydrocarbons 

SRN State Registration Number tpy Tons per year 

TAC Toxic Air Contaminant pg Microgram 

TEQ Toxicity Equivalence Quotient VOC Volatile Organic Compound 

VE Visible Emissions yr Year 

* For Hi hVolumeLowPnassune(HVLP)app|icators.UxypressurenneaaunadattheHVLpgunairuopnhaUnot 

exceed ten (10) pounds per square inch gauge (psig). 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 4 of 101 

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

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

extent such action is exempt from the Permit to Install requirements by any applicable rule. 

(R336.1201(1)) 

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

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

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

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

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

48909-7760, if it is decided not to pursue the installation, construction, reconstruction, relocation, or 

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

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

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

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

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

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

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

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

Act 451, PA 1994) 

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

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

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

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

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

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

Environmental Quality. (R 336.1219) 

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

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

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

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

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

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

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

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

abnormal condition or malfunction. Written reports, if required, must be filed with the Department within 

10 days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or 

malfunction has been corrected, or within 30 days of discovery of the abnormal condition or malfunction, 

whichever is first. The written reports shall include all of the information required in Rule 912(5). 

(R 336.1912) 

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

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

Clean Air Act. 

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

units of government as required by law. 

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

and the rules promulgated thereunder. 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 5 of 101 

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

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

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

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

determined in accordance with R 336.1303. (R 3361301) 

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

than 27 percent opacity. 

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

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

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

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

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

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

(R 336.1370) 

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

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

R 336.2001. (R 336.2001) 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 6 of 101 

SPECIAL CONDITIONS 

EMISSION UNIT SUMMARY TABLE 

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

Emission Unit ID Emission Unit Description Installation Date! Flexible Group ID 

____________________ (Process Equipment & Control Devices) Modification Date 

EU-UNIT1-S1 Boiler Unit No. I - Coal-fired boiler nominally 01-01-1968 / FG-ProjectPCl-4 

rated 817 MW (gross) with low-NOx burners, 03-03-2006 I 

Reduced Emissions Fuel (REF) sorbent 12-21-2010 

system, sulfur trioxide (SO3) and ammonia flue 

gas conditioning systems, selective catalytic 

reduction (SCR), dry wire electrostatic 

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

flue gas desulfurization (FGD). Fires No. 2 

EU-UNIT2-S1 Boiler Unit No. 2 - Coal-fired boiler nominally 01-01-1969 I FG-ProjectPCl-4 

rated 823 MW (gross) with low-NOx burners, 03-23-2005 I 

REF sorbent system, sulfur trioxide (SO 3) and 12-21-2010 

ammonia flue gas conditioning systems, (to be 

installed) selective catalytic reduction (SCR), 

dry wire electrostatic precipitators (ESP), and 

(to be installed) wet flue gas desulfurization 

EU-U NIT3-S1 Boiler Unit No. 3 - Coal-fired boiler nominally 06-01-1969 / FG-ProjectPCl-4 

rated 823 MW (gross) with low-NOx burners, 8-28-2006 I 

REF sorbent system, sulfur trioxide (30 3) and 08-02-2010 

ammonia flue gas conditioning systems, 

selective catalytic reduction (SCR), dry wire 

electrostatic precipitators (ESP), and wet flue 

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

EU-UNIT4-S1 Boiler Unit No. 4 - Coal-fired boiler nominally 06-01-1 969 I FG-ProjectPCl-4 

rated 817 MW (gross) with low-NOx burners, 11-15-2005/ 

REF sorbent system, sulfur trioxide (SO 3) and 08-02-2010 

ammonia flue gas conditioning systems, 

selective catalytic reduction (SCR), dry wire 

electrostatic precipitators (ESP), and wet flue 

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

EU-WFGD-QPI 252. hp diesel fuel-fired FGD quench pump 11-21-2006/ FG-ProjectPCl-4 

and a 350 gallon elevated storage tank for 08-02-2010 

diesel fuel servicing the Unit 3 stack. 

EU-WFGD-QP2 252 hp diesel fuel-fired FGD quench pump 11-21-2006 / FG-ProjectPCl-4 

and a 350 gallon elevated storage tank for 08-02-2010 

diesel fuel servicing the Unit 4 stack. 

EU-WFGD-QP3 252 hp diesel fuel-fired FGD quench pump TBD FG-ProjectPCl-4 

and a 350 gallon elevated storage tank for 

diesel fuel servicing the Unit 1 stack. 

EU-WFGD-QP4 252 hp diesel fuel-fired FGD quench pump TBD FG-ProjectPCl-4 

and a 350 gallon elevated storage tank for 

diesel fuel servicing the Unit 2 stack. 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 7 of 101 

Emission Unit ID Emission Unit Description Installation Date / Flexible Group ID (Process Equipment & Control Devices) Modification Date 

EU-CASCADES-Si This emission unit represents coal handling 01-01-1968/ FG-ProjectPC1-4 

activity in the Cascades room. Coal handling 11-01-1980/ 

activity emissions are limited by an enclosure, 08-02-2010 

wet dust suppression, and baghouse dust 

collectors. 

EU-TRANSFERHS-S1 This emission unit represents coal handling 01-01-1968 / FG-ProjectPC1-4 

activity in the Transfer House. Coal handling 11-01-1980/ 

activity emissions are limited by an enclosure, 08-02-2010 

wet dust suppression, and baghouse dust 

collectors. 

EU-DUMPERHS-S1 This emission unit represents coal handling 01-01-1968 / FG-ProjectPC1-4 

activity in the Dumper House. Coal handling 11-01-1980/ 

activity emissions are limited by an enclosure, 08-02-2010 

wet dust suppression, and baghouse dust 

collectors. 

EU-COALUNLOAD-S1 This emission unit represents the coal 01-01-1968 / FG-ProjectPC1-4 

unloading activities from Great Lakes ships 11-01-1980 / 

and includes storage and pile maintenance. 08-02-2010 

Coal handling activity emissions are limited by 

enclosures and wet dust suppression 

methods. 

EU-CRUSHERHS-S1 This emission unit represents coal handling 01-01-1968 / FG-ProjectPC1-4 

activity in the Crusher House. Coal handling 1-07-2005/ 

activity emissions are limited by an enclosure 08-02-2010 

and baghouse dust collectors. 

EU-REFHS&BL-S1 This emission unit represents coal and sorbent 06-13-2011 NA 

handling activity in the REF Transfer House 

and Refined Coal Plant Building including an 

8,500 gallon Mersorb storage tank, a 750 ton 

S-Sorb solid storage silo, associated 

conveyors, and any trucking and unloading 

activities. Sorbent handling activity inside the 

Refined Coal Plant Building includes two pug 

mills, two day bins, and mixing operations. 

Coal and sorbent handling activity emissions 

are limited by enclosures, baghouse dust 

collectors, wet dust suppression methods, or 

bin vent filters. 

EU-PETCOKE-S1 This emission unit represents petroleum coke TBD FG-ProjectPC1-4 

handling activity, including roadway traffic and 

pile maintenance. Emissions are limited by 

partial enclosures, including a portable wind 

screen, and wet dust suppression. 

EU-LIMESTONE-Si This emission unit represents limestone 02-01-2008 / FG-ProjectPC1-4 

handling activities and includes the ship 08-02-2010 / 

unloading process, storage and pile 12-21-2010 

maintenance, and reclaim activities - including 

any trucking activities, and the Prep building. 

Limestone handling activity emissions are 

limited by enclosures, wet dust suppression 

methods, or bin vent filters. 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 8 of 101 

Emission Unit ID Emission Unit Description - Installation Date I Flexible Group ID 

____________________ (Process Equipment & Control Devices) Modification Date 

EU-GYPSUMHAND-S1 This emission unit represents gypsum 02-01-2008 / FG-ProjectPCl-4 

handling activity in the gypsum dewatering 08-02-2010/ 

building and the gypsum storage and loading 12-21-2010 

building. Gypsum handling activity emissions 

are limited by a building enclosure. 

EU-HYDRATEDLIME-S1 Storage and handling of hydrated lime. 02-01-2008 / FG-ProjectPCl-4 

Hydrated lime is delivered via truck and is 08-02-2010 / 

stored in a silo. 12-21-2010 

EU-SOUTHAUX-S1 South Auxiliary Boiler 01-01-1 968 / FGAUXBOILERS-S1 

08-02-2010 I 

12-21-2010 

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

08-02-2010 / 

12-21-2010 

EU-DIESEL11-1-S2 Diesel Generator Peaking Unit DG 11-1 - 10-24-1969/ FGPEAKERS-S2 

3,960 hp (2.75 MW), 2-cycle compression 08-02-2010 I 

ignition internal combustion engine 12-21-2010 / 

3-9-2012 

EU-DIESEL11-2-S2 Diesel Generator Peaking Unit DG 11-2 - 10-24-1969/ FGPEAKERS-S2 

3,960 hp (2.75 MW), 2-cycle compression 08-02-2010 / 

ignition internal combustion engine 12-21-2010 / 

3-9-2012 

EU-DIESELI 1-3-S2 Dies& Generator Peaking Unit DG 11-3 - 10-24-1 969 / FGPEAKERS-52 

3,960 hp (2.75 MW), 2-cycle compression 08-02-2010 / 

ignition internal combustion engine 12-21-2010 / 

EU-DIESEL1I-4-S2 Diesel Generator Peaking Unit DG 11-4 - 10-24-1969/ FGPEAKERS-S2 

3,960 hp (2.75 MW), 2-cycle compression 08-02-2010 / 

ignition internal combustion engine 12-21-2010 / 

3-9-2012 

EU-DIESELI1-5-S2 Diesel Generator Peaking Unit DG 11-5 10-24-1 969 / FGPEAKERS-S2 

3,960 hp (2.75 MW), 2-cycle compression 08-02-2010 / 

ignition internal combustion engine 12-21-2010 / 

3-9-2012 

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

by R 336.1278 to R 336.1290. 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 9 of 101 

The following conditions apply to: EU-UNITI-S1 

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

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

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

Flexible Group ID: 1-4 

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

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

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

I. EMISSION LIMITS 

Time Period I Testing! Underlying Applicable Pollutant Limit Operating Equipment Monitoring 

1. Opacity 10 percent* 6-minute average EU-UNIT1-S1 SC V.1, R 336.1301(1)(c), R 336.2810, 

except one 6- SC VI.2 40 CFR 52.21(j) 

minute average 

per hour of not 

more than 20 

2. PM 0.011 lb/MMBtu Test protocol will EU-UNIT1-S1 SC V.1, R 336.1224, 

heat input* specify averaging SC Vl.3 R 336.1225, 

time or24-hr R 336.1331(1)(c), 

rolling average as R 336.2810, 

determined each 40 CFR 52.21(j) 

hour the boiler 

3. PM 0.12 pounds per Test protocol will EU-UNIT1-S1 SC V.10 R 336.1331(1) 

1,000 pounds of specify averaging 

exhaust gases, time. 

on a wet basis, 

corrected to 50% 

L PM1O 0.024 lb/MMBtu Test protocol will EU-UNITI-S1 SC V.2 R 336.2810, 

heat input* specify averaging 40 CFR 52.21(j) 

5. PM1O 183.0 pph* Test protocol will EU-UNIT1-S1 SC V.2 R 336.2803, 

specify averaging R 336.2804, 

time. R 336.2810, 

heat i n put* average as SC Vl.8 R 336.2810, 

determined each 40 CFR 52.21(j), 

hour the boiler R 336.2902(2)(c), 

heat i n p ut** average as SC Vl.8 

determined each 

hour the boiler 
DTE Electric Company, Monroe Power Plan (B2816) June 25, 2013 

Permit No. 27-13 Page iOof1U1 

Pollutant Limit Operating Equipment Monitoring 

average as SC Vl.6, R 336.2804, 

determined each SCVI.8 R336.2810, 

operates R 336.2902(2)(c), 

heat in put* average as SC Vl.9 40 CFR 52,21(j) 

determined each 

ton/month* average as SC VI.6, R 336.2810, 

heat input average as SC Vl.10 40 CFR52.21(j) 

excluding determined each 

periods of start- calendar day the 

up and boiler operates 

12. CO 27,446.4 lb/day* 30-day rolling EU-UNIT1-S1 SC Vl.4, R 336.2804, 

average as SC Vl.6, R 336.2810, 

determined each SC Vl.10 40 CFR 52.21(d) and (j) 

calendar day the 

13. VOC 0.0034 lb/MMBtu Test protocol will EU-UNIT1-S1 SC V.4 R 336.1122(f), 

heat input* specify averaging R 336.1224, 

time. R 336.1225, 

R 336.2810, 

14. VOC 25.9 pph* Test protocol will EU-UNIT1-S1 SC V.4 R 336.1122(f), R 336.1224, 

specify averaging • R 336.1225, 

R 336.2810, 

15. Lead (Pb) 1.69 x 10 Test protocol will EU-UNITI-S1 SC V.5 R 336.1901, 

lb/MMBtu heat specify averaging R 336.2810, 

16. Lead (Pb) 0.13 pph* Test protocol will EU-UNIT1-S1 SC V.5 R 336.1901, 

specify averaging R 336.2804, 

time. R336.2810, 

17. Sulfuric 0.005 lb/MMBtu Test protocol will EU-UNIT1-S1 SC V.6 R 336.1224, 

acid mist heat input* specify averaging R 336.1225, 

(H2SO4 ) time. R 336.2810, 

40CFR52.21(j) ________ 

18. Hydrogen 

_________ 

0.0024 lb/MMBtu 

_________ 

Test protocol will 

_________ 

EU-UNIT1-S1 

_______ 

SC V.7 R 336.1224, 

Chloride heat input* specify averaging 

. 

R 336.1225 

19. Hydrogen 0.00023 Test protocol will EU-UNIT1-S1 SC V.8 R 336.1224, 

Fluoride lb/MMBtu specify averaging R 336.1225, 

(HF) heat i n put* time. R 336.2810, 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 11 of 101 

Time Period I Testing ' Underlying Applicable 

Pollutant Limit Operating Equipment Monitoring Requirements 

20. Mercury 0.02 lb/GW-hr 12-month rolling EU-U NIT1-S1 SC V.9, R 336.1224, 

(Hg) gross energy average as SC Vl.5, R 336.1228, 

outp ut* determined each SC Vl.7, R 336.1229(2)(b), 

21. Mercury 143.1 lb/year* 12-month rolling EU-UNIT1-S1 SC V.9, R 336.1224, 

(Hg) time period as SC Vl.5, R 336.1228, 

determined at the SC Vl.6, R 336.1229(2)(b), 

end of each SC Vl.7, R 336.2503(2) 

2. Arsenic 6.3 x 10 Test protocol will EU-UNIT1-S1 SC V.5 R 336.1224, 

(As) lbfMMBtu heat specify averaging R 336.1225(2) 

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

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

U. MATERIAL LIMITS 

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. 

2. The permittee shall only combust bituminous u0al, aubbiturninous coal, and up to 23.652 tons per calendar 

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

after start-up and shakedown of the wet FGD system is completed. (Ri326.12O6(1)(m)and (1)(b), 

R 336.1224, R 336.1225, R 336.1702(a), R 336.1901.Ri336.2810,40CFR|52-21(j)) 

IQ. PROCESS/OPERATIONAL RESTRICTIONS 

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

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

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

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

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

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

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

submibo|, the MAP or amended MAP shell be considered approved. Until an amended plan is opproved, 

the permittee shall implement corrective procedures or operational changes to achieve compliance with all 

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

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

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

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

entering the SCR drops below the operating temperature of the SCR system. (R|336.1Q12. R 336.2810, 

40 CFR 5221(j)) 

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

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

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

standard industry practices. (R 336.1911, R%36-1912. R336.2D03. R 336.2804. R 336.2810. 

40 CFR 52.21(c), (d), and (j)) 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 12 of 101 

IV. DESIGN/EQUIPMENT PARAMETERS 

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

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

2. The permittee shall not operate EU-UNIT1-S1 unless the low-NOx burners, overtire air, SO 3 and ammonia 

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

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

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

SC 111.1. (R 336.1224, R 336.1225, R 336.1901, R 336.1910, R 336.2810, 40 CFR 52.21(j)) 

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

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

device in accordance with an approved MAP for EU-UNIT1-S1 as required in SC 111.1. (R 336.1225, 

R 336.1910) 

V. TESTING/SAMPLING 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(R 336.2001, R 336.2003, R 336.2004, R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 

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

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

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

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

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

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

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

R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j)) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 13 of 101 

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

rates from EU-UN|T1-S1 by testing at owner's oxpense, in accordance with Department roquirenlente, will 

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

prior to besting, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and 

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

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

District Office within 60 days following the last date of the test. (R 336.1225 ' R 336'1901, R 336.2001, 

Fl33G'2003.Fl33G.2004.Ri336'2OU4.R336.281O.4DCFR|62.21(d) and U)\ 

6. VVithin18Odayaaftarsbart-upandshakedovvnofthevvetFGOaysbann.vahfinatonofHoSC4 emission rates 

from EU-UN|T1-S1 by testing at owner's expense, in accordance with Department requirement , will be 

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

prior to baotinQ, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and 

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

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

District Office within 00 days following the last date of the test. (R 336'1224 ' R 336.2001, R 336.2003, 

R 336.2004, R 336.2810,40CFR52'310)) 

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

from EU-UN|T1-S1 by testing at owner's expense, in accordance with Department requirements, will be 

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

prior to testinQ. the permittee shall submit a complete test plan to the AQD Technical Programs Unit and 

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

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

District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, 

R 336.2003, R 336.2004) 

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

EU-UN[T1-G1 by testing at owner's expense, in accordance with Department requirements, will be required. 

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

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

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

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

within 00 days following the last date of the test. (R 336.1224, R 336.1225, R 336.2001, R 336.2003, 

R|3J6.2U04,R 336,2810,40CFR52'21h\) 

S. Within 180 days after start-up and shakedown of the wet FGD system, verificationofbobs|Hgen1isaionnstao 

from EU-UN[T1-S1 by testing at owner's expanse, in accordance with Department requinaments, will be 

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

prior to besting, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and 

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

includes the submittal of a complete report of the test results to the AQD within 80 days following the last 

date of the test.' (R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2001, R 336.2003, R 336.2004) 

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

EU-UN|T1'81 by testing at owner's exponse, in accordance with Department n*quiramonts, will be required. 

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

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

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

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

following the last date of the test. (R 336'1205(1)(a) and (1)(b), R 336.1213(3). R 336.2001, R 336.2003, 

R 336.2004) 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 14 of 101 

VI. MONITORING/RECORDKEEPING 

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

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

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

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

R 336.1225, R 336.1702, R 336.1901) 

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

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

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

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

and record the visible emissions before the wet FGD from EU-UNIT1-S1 on a continuous basis. The 

permittee shall install and operate the COM system to meet the timelines, requirements and reporting 

detailed in Appendix A and correlate pre-wet FGD visible emissions to post-wet FGD visible emissions on 

an annual basis. If the permittee installs a PM CEM per SC Vl.3.c., this special condition is void. 

(R 336.1301, R 336.2810, 40 CFR 52.21(j)) 

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

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

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

than 50% of the emission limit specified in SC 1.2 for four consecutive quarters, the permittee may reduce 

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

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

greater than 50% of the emission limit specified in SC 1.2 for any single semi-annual or annual test, then 

quarterly testing shall be required. 

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

later than January 1, 2015. 

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

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

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

requirements: 

i. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

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

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

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

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

procedures: 

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

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

than two hours. 

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

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

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

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

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

requirements: 
DTE Electric Company,Monroe Power Plant (B281G) June 25, 2013 

Permit No. 27-13 Page 15 of 101 

The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

Supen/isor, require verification of the presence of visible emissions by taking 6-minute visible 

emission readings for EU-UNIT1-S1 a minimum of once per calendar day when the boiler is 

operating. Either a certified or non-certified reader shall take each visible emission reading during 

routine operating conditions. If the permittee observes any visible emissionn, the permittee shall 

immediately implement the following procedures: 

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

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

than two hours. 

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

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

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

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

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

permittee shall also meet the following requirements: 

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

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

ii. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

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

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

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

conditions. If the permittee observes any visible ernissiona, the permittee shall immediately 

implement the following procedures: 

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

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

than two hours. 

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

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

(R 3361305 R 336.1301, R 3361303, R 336.1331, R 3361901, R 3361911, R 336.2010, 

40CFR52.21(j)) 

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

record the SO2 , NOx, and CO ernisaions, and oxygen or carbon dioxide (0 2or CO2) content of the exhaust 

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

the Umo|inea, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52.21(j),R|33G.2902(2)(o),4Q CFR 51(Appendix S)) 

5. Within 180 days after start-up and shakedown of the wet FGD sysbsm, the permittee shall instoU, naUbnyte, 

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

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

tinne|inea, requirements and reporting detailed in Appendix B attached. (R 336.1224, R 336.1228, 

R 336.1229(2)(b), R 336.2503(2)) 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 16 of 101 

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

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

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

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

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

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

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

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

rate and mass records for EU-UNITI-S1, as described in emission limits SC 1.6, 1.7, and 1.8, respectively. 

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

40 CFR 51 (Appendix S)) 

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

rate and mass records for EU-UNIT1-S1, as described in emission limits SC 1.9, and 1.10. (R 336.2803, 

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

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

mass records for EU-UNITI-S1, as described in emission limits SC 1.11 and 1.12. (R 336.2804, R 336.2810, 

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

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

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

mercury mass emission rate records for EU-UNITI-S1, as described in emission limits SC 1.20 and SC 1.21. 

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

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

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

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

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

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

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

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

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

b. Monitoring data; 

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

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

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

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

defined in SC 111.2; . 

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

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

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

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

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

r 

 ` 

DTE Electric Company, Monroe Power Plant (B281O) June 25, 2013 

Permit No. 27-13 Page 17 of 101 

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

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

quarter as specified in 40 CFR 607(c) and (d). The Summary Report shall follow the format of Figure 1 in 

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

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

includes the date, time, nlagnitude, cause and corrective actions of all occurrences during the reporting 

period. 

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

System (CEK88/CERMS), and if applicable Predictive Emission Monitoring System (PEyWS), downtime 

and corrective action. 

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

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

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

period, the permittee shall report that fact. 

(R 336'1205, R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2803, R 336'28¢4, R 336.2810, 

Fl33G.2982(2)(c).40CFR|51 (Appendix S),4OCFRS2-21(o).(d), and (j),40 CFR 60.7(c) and (d)) 

2. Within 30 days after completion of the instnUadon, constnucdon, reconatnucUon, relooation, ormodification of 

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

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

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

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

VIII. STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack & Vent ID DiameterlDimensions Above Ground 

R 336.1225, R 336.1901, 

1. SVO15-001 336 579 R336.2803, R 336.2804, 

[±SV015001* 336 805 R 336.2803, R 336.2804, 

* The stackheig in SC VIII.2 applies untilstart-up of the wet FGD. 
IDTE Electric Company, Monroe Power Plant (132816) Junn25.2013 

Permit No. 27-13 Page 18 of 101 

IX. OTHER REQUIREMENTS 

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

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

The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain 

Program, as it applies to EU-UNIT1-Sl. (40CFR Parts 72'76) 

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

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

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

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

Footnotes: 

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 19 of 101 

The following conditions apply to: EU-UNIT2-S1 

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

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

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

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Low-NOx burners, overfire air, REF sorbent system, 303and ammonia 

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

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

I. EMISSION LIMITS 

Time Period / Testing I Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements Scenario Method 

1. Opacity 10 percent* 6-minute EU-UNIT2-S1 Sc V.1, R 336.1301(1)(c), 

average except SC V1.2 R 336.2810, 40 CFR 52.21(j) 

one 6-minute 

average per 

hour of not more 

than 20 percent 

2. PM 0.011 Test protocol will EU-UNIT2-S1 Sc V.1, R 336.1224, 

lb/MMBtu specify SC VI.3 R 336.1225, 

heat input* averaging time R 336 1331 (1)(c), 

or 24-hr rolling R 336.2810, 

average as 40 CFR 52.21(j) 

determined each 

hour the boiler 

operates 

3. PM 0.12 pounds Test protocol will EU-UNIT2-S1 Sc V.10 R 336.1331(1) 

per 1,000 specify 

pounds of averaging time. 

exhaust 

gases, on a 

wet basis, 

corrected to 

50% excess 

ai r** 

PM10 0.024 Test protocol will EU-UNIT2-S1 SC V.2 R 336.2810, 

lb/MMBtu specify 40 CFR 52.21(j) 

henut* Jtime.____ 

5. PM10 183.0 pph* Test protocol will EU-UNIT2-S1 SC V.2 R 336.2803, 

specify R 336.2804, 

averaging time. R 336.2810, 

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

S02 0.107 24-hour rolling EU-UNIT2-S1 SC Vl.4, R 336.1401, 

lb/MMBtu average as SC VI.8 R 336.2810, 

heat input* determined each 40 CFR 52.21(j), 

hour the boiler R 336.2902(2)(c), 

operates 
June 25, 2013 

Page 20 of 101 

DTE Electric Company, Monroe Power Plant (B2816) 

Permit No. 27-13 

Time Period I Testing I Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements 

heat input** average as SC Vl.8 

determined each 

hour the boiler 

average as SC V!.6, R 336.2804, 

determined each SC Vl.8 R 336.2810, 

hour the boiler 40 CFR 52.21(c), (d), and (j), 

operates R 336.2902(2)(c), 

heat i nput* average as SC Vl.9 40 CFR 52.21(j) 

determined each 

ton/month*** average as TEMP - SC 40 CFR 52.21(d) 

determined each VL3, 

calendar month SC VL4 

tonlmonth* average as SC VI.6, R 336.2810, 

12. CO 0.15 lb/MMBtu 30-day rolling EU-UNIT2-S1 SC VL4, R 336.2810, 

heat input average as SC Vl.10 40 CFR 52.21(j) 

excluding determined each 

periods of calendar day the 

start-up and boiler operates 

13. CO 27,446.4 30-day rolling EU-UNIT2-S1 SC VI.4, R 336.2804, 

lb/day* average as SC Vl.6, R 336.2810, 

determined each SC Vl.10 40 CFR 52.21(d) and (j) 

calendar day the 

14. VOC 0.0034 Test protocol will EU-UNIT2-S1 SC V.4 R 336.1122(f), 

lbfMMBtu heat specify R 336.1224, 

i nput* averaging time. R 336.1225, 

R 336.2810, 

15. VOC 25.9 pph* Test protocol will EU-UNIT2-S1 SC V.4 R 336.1122(f), R 336.1224, 

specify R336.1225, 

averaging time. R 336.1702(a), 

R 336.2810, 

16. Lead (Pb) 1.69 x 10 Test protocol will EU-UNIT2-S1 SC V.5 R 336.1901, 

lb/MMBtu heat specify R 336.2810, 

17. Lead (Pb) 0.13 pph* Test protocol will EU-UNIT2-S1 SC V.5 R 336.1901, 

specify R 336.2804, 

averaging time. R 336.2810, 
DTE Electric Company , Monroe Powe Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 21 of 101 

Time Period I Testing I Underlying Applicable 

Pollutant Limit Operating Equipment Monitoring Re uirements 

18. Sulfuric acid 0.005 Test protocol will EU-UNIT2-S1 SC V.6 R 336.1224, 

mist (H2SO4) lb/MMBtu heat specify R 336.1225, 

i nput* averaging time. R 336.2810, 

19. Hydrogen 0.0024 Test protocol will EU-UNIT2-S1 SC V.7 R 336.1224, 

Chloride lb/MMBtu heat specify R 336.1225 

20. Hydrogen 0.00023 Test protocol will EU-UNIT2-S1 SC V.8 R 336.1224, 

Fluoride (HF) lb/MMBtu specify R 336.1225, 

heat input* averaging time. R 336.2810, 

21. Mercury (Hg) 0.02 lb/GW-hr 12-month rolling EU-UNIT2-S1 SC V.9, R 336.1224, 

gross energy average as SC VI.5, R 336.1228, 

output* determined each SC Vl.7, R 336.1229(2)(b), 

22. Mercury (Hg) 144.2 lb/year* 12-month rolling EU-UNIT2-S1 sc V.9, R 336.1224, 

time period as SC Vl.5, R 336.1228, 

determined at SC VI.6, R 336.1229(2)(b), 

the end of each SC Vl.7, R 336.2503(2) 

23. Arsenic (As) 6.3 x 10 Test protocol will EU-UNIT2-S1 SC V.5 R 336.1224, 

lb/MMBtu heat specify R 336.1225(2) 

*~ These emission limits apply after SCR and wet FGD systems are 

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

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

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

N' MATERIAL LIMITS 

1. The permittee shall only use No. 2 fuel oil for the initial stabilization, and overfiring. 

Start-up is defined in SC Ill 2 (R 336 7 and (1)~ R ~'~~~C~ 5 ~~ 

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

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

after start-up and shakedown of the SCR and wet FGD system is completed (R 336 1205(l)(a) and (1)(b), 

|& 

, , 

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

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

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

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

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

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

and approval. If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended 

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

corrective procedures or operational changes to achieve compliance with all applicable emission limits. 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 22 of 101 

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

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

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

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

temperature of the SCR system. (R 336.1912, R 336.2810, 40 CFR 52.21(j)) 

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

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

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

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

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

IV. DESIGN/EQUIPMENT PARAMETERS 

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

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

2. The permittee shall not operate EU-UNIT2-S1 unless the low-NOx burners, overfire air, SO 3 and ammonia 

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

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

Satisfactory manner includes operating and maintaining each control device in accordance with an 

approved MAP for EU-UNIT2-S1 as required in SC 111.1. (R 336.1224, R 336.1225, R 336.1901, 

R 336.1910, R 336.2810, 40 CFR 52.210)) 

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

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

device in accordance with an approved MAP for EU-UNIT2-S1 as required in SC 111.1. (R 336.1225, 

R 336.1910) 

V. TESTING/SAMPLING 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

R 336.2004, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j)) 

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

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

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

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

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

approved by the AQD prior to testing. Verification of emission rates includes the submittal of a complete 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 23 of 101 

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

last date of the test. (R 336.2001, R 336.2003, R 336.2004, R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 

4. Within 180 days after start-up and shakedown of the SCR and wet FGD syeteme, verification of VOC 

emission rates from EU-UN|T2-S1 by testing at owner's expense, in accordance with Department 

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

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

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 336'1224, 

R 336.1702(a), R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.210)) 

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

emission rates from 'EU-UN|T2-S1 by testing at owner's expenea, in accordance with Department 

raquiromenbs, will be required. The permittee must complete the test once everyfive years, thereafter. No 

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

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

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

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

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

6. Within 180 days after and H2SO4 

emission rates from EU-UNIT2-S1 by testing at owners expense in accordance with Department 

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

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

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

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

Programs Unit and District Office within 60 days followin g the last date of the test. (R 336.1224, R 336.2001, 

R 336 20¢3. R 33G'2884, R 33G'2818, 4C| CFRS2 21(j)) 

7 Within 180 days after start-up and shakedown of the SCR and wet FGD systems verification of HCI 

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

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

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

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

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

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

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

8. Within 180 of the SCR of HF 

emission rates from EU-UNIT2-S1 by testing at owners expense in accordance with Department 

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

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

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

of emission rate includes the submittal of a compl of the test results to the AQD Technical 

Programs Unit and District Office within 60 days following the last date of the best (R 336.i224 ' 

R 336.1225, R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52'210)) 

9. Within 180 days after start-up and sha~~~~t~ SCR w~~~D' systems, ~~~~~~~|Hg 

emission rates from EU-UN|T2-G1 testing at owner s axpenne. in accordance with Department 

requirements, will be required. The permitteemustconnp|ebathehsstonoeovo five years.thereafter No 

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

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

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

following the last date of the bast. / (R 336'1224, R 336.1228. R 336.1229(2)(b), R 336.2001, R 336.3002, 

R 336.2004) 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 24 of 101 

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

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

required. The permittee must complete the test once every five years, or more frequently upon request of 

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

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

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

60 days following the last date of the test. (R 336.1205(1)(a) and (1)(b), R336.1213(3), R336.2001, 

R 336.2003, R 336.2004) 

VI. MONITORING/RECORDKEEPING 

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

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

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

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

R 336.1225, R 336.1702, R 336.1901) 

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

conduct visible emission observations using federal Reference Test Method 9 (40 CFR Part 60 (Appendix 

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

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

and record the visible emissions before the wet FGD from EU-UNIT2-S1 on a continuous basis. The 

permittee shall install and operate the COM system to meet the timelines, requirements and reporting 

detailed in Appendix A and correlate pre-wet FGD visible emissions to post-wet FGD visible emissions on 

an annual basis. If the permittee installs a PM GEM per SC VI.3.c., this special condition is void. 

(R 336.1301, R 336.2810, 40 CFR 52.21(j)) 

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

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

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

emission rates are less than 50% of the emission limit specified in SC 1.2 for four consecutive quarters, the 

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

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

If PM emissions are greater than 50% of the emission limit specified in SC 1.2 for any single semi-annual or 

annual test, then quarterly testing shall be required. 

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

later than January 1, 2015. 

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

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

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

requirements: 

i. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

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

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

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

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

procedures: 

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

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

than two hours. 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 25 of 101 

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

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

b. The permittee shall instoU, oa|ibrato, maintain and operate in a satisfactory manner, a PM Predictive 

Emission Monitoring System (PEMS) per the requirements of Performance Specification1G(AppendixB 

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

requirements: 

The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

Supervisor, require verification of the presence of visible emissions by taking 6-minute visible 

emission readings for EU-UNIT2-S1 anini um of once per calendar day when the boiler is 

operating. Either a certified or non-certified reader shall take each visible emission reading during 

routine operating conditions. If the permittee observes any visible emissions, the permittee shall 

immediately implement the following procedures: 

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

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

than two hours. 

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

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

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

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

operate the CEM to meet the Unno|inea, requirements and reporting detailed in Appendix B. The 

permittee shall also meet the following requirements: 

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

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

ii. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

accordance with Procedure 2 of 40 CFR Part 60 (AppendixF). This alternative monitoring ahaU, 

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

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

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

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

conditions. If the permittee observes any visible omissions, the permittee shall immediately 

implement the following procedures: 

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

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

than two hours. 

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

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

(R 336.1205, R 336.1301, R 336.1303, R 336.1331, R 336'1901, R 336.1811, R 336.2810, 

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

record the SO2 , NOx, and CO emissions, and oxygen or carbon dioxide (0 2 orCO2) content of the exhaust 

gas from EU'UN|T2-S1 on a continuous basis. The permittee shall install and operate each CEM to meet 

the time|ines, requirements and reporting detailed in Appendix B attached. (R 336.1205, R 336.2810, 

40 CFR 52'21(j),R336.2902(2)(c),40 CFR 51 (Appendix S)) 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 26 of 101 

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

calibrate, maintain and operate in a satisfactory manner a device to monitor and record the mercury 

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

to meet the timelines, requirements and reporting detailed in Appendix B attached. (R 336.1224, 

R 336.1228, R 336.1229(2)(b), R 336.2503(2)) 

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

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

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

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

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

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

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

8. The permittee shall keep, in a satisfactory manner, hourly and 24-hour rolling average SO 2emission rate 

and mass records for EU-UNIT2-S1, as described in emission limits SC 1.6, 1.7, and 1.8, respectively. 

(R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j), R 336.2902(2)(c), 40 CFR 51 

(Appendix S)) 

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

rate and mass records for EU-UNIT2-S1, as described in emission limits SC 1.9, 1.10, and 1.11. 

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

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

mass records for EU-UNIT2-S1, as described in emission limits SC 1.12 and 1.13. (R 336.2804, R 336.2810, 

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

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

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

mercury mass emission rate records for EU-UNIT2-S1, as described in emission limits SC 1.21 and SC 1.22. 

If the monitoring required by Monitoring/Recordkeeping SC V1.4 is only capable of detecting gaseous 

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

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

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

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

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

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

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

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

b. Monitoring data; 

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

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

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

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

defined in SC 111.2; 

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

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

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

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

R 336.2802(4), R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j)) 
DTE Electric Company, Monroe Power Plant (132816) 

Permit No. 27-13 

June 25, 2013 

Page 27 of 101 

VII. REPORTING 

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

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

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

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

A report of each exoeedanoe above the limits specified in the emission limits of this permit. This 

includes the date. Ume, nnegnhude, cause and corrective actions of all occurrences during the reporting 

period. 

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

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

and corrective action. 

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

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

e. If no exceedances or CEPW8/CERMS, and if applicable PE[NS, downtime occurred during the reporting 

period, the permittee shall report that fact. 

(R 336.1205 R 336.1224, R 336'1228 R 336.1 ' R 336.2803. R 336.2804 R 336.2810. 

2. Within 30 days after completion of the inate|etion, construction, ruoonatnction, nelooation, or modification of 

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

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

instaUotion, oonabuction, naconatruotion, na|ooation, or modification is considered to occur not later than 

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

VIII. STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack & Vent ID DiameterIDimensions Above Ground 

R 336.1225, R 336.1901, 

1. SVO15-002 336 579 R 336.2803, R 336.2804, 

2. SV015002* 336 805 R 336.2803, R 336.2804, 

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

IX. OTHER REQUIREMENTS 

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

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

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

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

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

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

by the initial compliance date. (40 CFR Part 63 Subparts A and UUUUU) 
June 25 2013 

Page 28 of 101 

DTE Electric Company, Monroe Power Plant (B2818) 

Permit No. 27-13 

4. The start-up and shakedown period for the wet FGD shall not exceed 180 days. (R 336.2803, R 336-2804, 

5. The start-up and shakedown period for the SCR shall not exceed 180 days. (R 336'2803, R 336.2804, 

R 33G.281O,4OCFR52'21(o),(d). and (j)) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company Monroe Power Plant (B281S) June 25, 2013 

Permit No. 27-13 Page 29 of 101 

The following conditions apply to: EU-UNIT3-S1 

DESCRIPTION: Coal-fired cell burner boiler nominally rated at a maximum heat input of 7624 MMBtu per hour 

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

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

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Lovv NOxburners. overfire air, REF sorbent system, 8O ` and ammonia 

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

wet flue gas desulfurization (FGD). 

L EMISSION LIMITS 

Time Period I Testing ' Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements 

1. Opacity 10 percent 6-minute EU-UNIT3-S1 SC V.1, R 336.1301(1)(c), 

average except SCVI.2 R336.2810, 

one 6-minute 40 CFR 52.21(j) 

average per 

hour of not more 

2. PM 0.011 lb/MMBtu Test protocol will EU-UNIT3-S1 SC V.1, R 336.1224, 

heat input specify SC VI.3 R 336.1225, 

averaging time R 336.1331(1)(c), 

or 24-hr rolling R 336.2810, 

average as 40 CFR 52.21(j) 

determined each 

hour the boiler 

3. PM1O 0.024 lbIMMBtu Test protocol will EU-UNIT3-S1 SC V.2 R 336.2810, 

heat input specify 40 CFR 52.21(j) 

L PM1O 183.0 pph Test protocol will EU-UNIT3-S1 SC V.2 R 336.2803, 

specify R 336.2804, 

averaging time. R 336.2810, 

heat input average as SC Vl.8 R 336.2810, 

determined each 40 CFR 52.21(j), 

hour the boiler R 336.2902(2)(c), 

average as SC Vl.6, R 336.2804, 

determined each SCVI.8 R336.2810, 

operates R 336.2902(2)(c), 

heat input average as SC Vl.9 40 CFR 52.21(j) 

determined each 
DTE Electric Company, Monroe Power Plan (B2816) June25.2013 

Permit No. 27-13 Page 30 of 101 

Time Period! Testing! 

- Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements 

8. NOx 222.6 ton/month 12-month rolling EU-UNIT3-S1 SC Vl.4, R 336.2803, 

average as SC Vl.6, R 336.2804, 

determined each SC Vl.9 R 336.2810, 

9. CO 0.15 lb/MMBtu 30-day rolling EU-UNIT3-S1 SC Vl.4, R 336.2810, 

heat input average as SC Vl.10 40 CFR 52.21(j) 

excluding periods determined each 

of start-up and calendar day the 

10. CO 27,446.4 lb/day 30-day rolling EU-UNIT3-S1 SC Vl.4, R 336.2804, 

average as SC Vl.6, R 336.2810, 

determined each SC Vl.10 40 CFR 52.21(d) and (j) 

calendar day the 

11. VOC 0.0034 lb/MMBtu Test protocol will EU-UNIT3-S1 SC V.4 R 336.1122(f), 

heat input specify R 336.1224, 

averaging time. R 336.1225, 

R 336.1702(a), 

R 336.2810, 

12. VOC 25.9 pph Test protocol will EU-UNIT3-S1 SC V.4 R 336.1122(f), 

specify R336.1224, 

averaging time. R 336.1225, 

R 336.1702(a), 

13. Lead (Pb) 1.69 x 10 Test protocol will EU-UNIT3-S1 SC V.5 R 336.1901, 

lb/MMBtu heat specify R 336.2810, 

14. Lead (Pb) 0.13 pph Test protocol will EU-UNIT3-S1 SC V.5 R 336.1901, 

specify R336.2804, 

averaging time. R 336.2810, 

15. Sulfuric acid 0.005 lb/MMBtu Test protocol will EU-UNIT3-S1 SC V.6 R 336.1224, 

mist (H2SO4) heat input specify R 336.1225, 

averaging time. R 336.2810, 

16. Hydrogen 0.0024 lb/MMBtu Test protocol will EU-UNIT3-S1 SC V.7 R 336.1224, 

Chloride heat input specify R 336.1225 

17. Hydrogen 0.00023 lb/MMBtu Test protocol will EU-UNIT3-S1 SC V.8 R 336.1224, 

Fluoride (HF) heat input specify R 336.1225, 

averaging time. R 336.2810, 

18. Mercury (Hg) 0.02 lb/GW-hr 12-month rolling EU-UNIT3-S1 SC V.9, R 336.1224, 

gross energy average as SC Vl.5, R 336.1228, 

output determined each SC Vl.7, R 336.1229(2)(b), 

19. Mercury (Hg) 144.2 lb/year 12-month rolling EU-UNIT3-S1 SC V.9, R 336.1224, 

time period as SC Vl.5, R 336.1228, 

determined at SC Vl.6, R 336.1229(2)(b), 

the end of each SC Vl.7, R 336.2503(2) 
DTE Electric Compony, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 31 of 101 

Time Period I Testing I Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements 

20. Arsenic (As) 6.3 x 10 Test protocol will EU-UNIT3-S1 SC V.5 1 R 336.1224, 

U. MATERIAL LIMITS 

1. The permittee shall only use No. 2 fuel oil for the initial start-up fuel, flame stabilization, and overfiring. 

Start-up is defined in SC 111.2. (R 336'120G(i)(m) and (1)(8).R33G.2Q1O,4OCFR 52'21(j)) 

2. The permittee shall only combust bituminous coal, uubbdunninVus 000, and up to 23,652 tons per calendar 

month of petroleum coke in EU-UNIT3-S1. (R336.1205(1)(o) and (1)(b),R 336.1224, R336.1225, 

R 336.1702(a), R 336.1901, R 336'2310.40CFR5221(j)) 

UL PROCESS/OPERATIONAL RESTRICTIONS 

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

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

address or inadequately addresses an event that meets the characteristics of a n!o|function, the permittee 

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

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

permittee shall submit the MAP and any amendments to the MAP to UleADD District Supervisor for review 

and approval. If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended 

MAP shall be considered approved. Unbl an amended plan is approved, the permittee shall implement 

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

(R 336.1224, R336.1225,R336'1331,R336.1702(m).R336'1910,Ri336.1911,R336.1912,R336'2802, 

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

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

for the SCR of05O°F. Shutdown is defined as that period of time beginning when the flue gas temperature 

entering the SCR drops below the operating temperature of the SCR system. (8i336'1812, R 33$'3810, 

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

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

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

standard industry practices. (R336.1911 ' R33G'1912' R|336'2803, R 336.2804, R336'3B1O ' 

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

IV. 

1. The maximum design heat input rate of EU-UNIT3-S1 shall not exceed 7.624 million British thermal units 

per hour (MMBtu/hr) on a fuel heat input basis. (R 336.1 205(1 )(a) and (1)(b)) 

2. The permittee shall not operate EU-UNIT3-S1 unless the low-NOx bunnens, overfire air, 8O3 and ammonia 

flue gas conditioning systems, SCR system, E8P, and wet FGD system are installed, maintained, and 

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

device in accordance with an approved MAP for EU-UNIT3-S1 as required in SC 111.1. (R336.1224. 

R 336.1225, R 336.1901, R 336.1810,0336'2810,40CFR|52.310)) 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 32 of 101 

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

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

device in accordance with an approved MAP for EU-UNIT3-S1 as required in SC 111.1. (R 336.1225, 

R 336.1910) 

V. TESTING/SAMPLING 

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

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

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

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

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

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

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

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

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

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

R 336.2004, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21(c), (d), and (j)) 

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

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

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

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

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

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

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

40 CFR 51 (Appendix S)) 

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

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

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

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

in accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

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

6. The permittee shall verify the H 2SO4 emission rates from EU-UNFT3-S1 by testing at owner's expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.21(j)) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 33 of 101 

7. The permittee sha l l verify the HQ emission rates from EU-UNIT3-S1 by test i ng at owner's expenae, in 

accordance with Department requirements. The permittee must complete the test once every five years, 

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

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

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

Technical Programs Unit and District Office within 60 days following the last date of the test. (R 336.1324. 

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

8. The permittee shall verify the HF emission rates from EU-UNIT3-S1 by test i ng at owner's expense, in 

accordance with Department requirements The permittee must complete the test once every five years. 

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

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

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

Programs Unit and District Offi in 60 days following the last date of the test. (R 336.1224, R 336.1225, 

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

B. The permittee shall verify the tota Hg emission rates from EU-UNIT3-S1 by testing at owner's expenae, in 

accordance with Department requirements. The permittee must complete the five 

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

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

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

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

R 336 2004) 

~~ ` 

VI 

Records shall be maintained on file for a period of five years (R 336 1201 (3)) 

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

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

otherwise specified in any nlonitohn ping special condition (Fl33G'12O5' R336.1224. 

R 336.1225, R 336.1702, R 336.1901) 

2. The permittee shall conduct visible emission observations using federal Reference Test Method 9 (40 CFR 

Part 60 (Appendix A)), or an alternate method approved by the AQD, on a calendar day basis each day the 

boiler operates or the permittee shall install, calibrate , maintain d operate in sbafouto manner a 

COM system to monitor and record the visible emissions before the wet FGD from EU-UNIT3-S1 on a 

continuous basis. The permittee shall install and operate the COM system to meet the time|inee, 

requirements and reporting detailed in Appe A and correlate pre-wet FGD visible emissions to post-wet 

FGD visible emissions on an annual basis If t i installs a PM {}EM per SC V1 3 c ' this special 

condition is void (R 336 1301, R 336 2810, 40 CFR 52 210)) 

3. Prior to the implementation of a continuous monitoring system as specified in (a), (b) or (c) below, the 

permittee shall perform PM emission testing as specified in SC \(1 on a quarterly basis. If the PM 

emission rates are less than 50% of the emission limit specified in SC 1.2 for four consecutive quarters, the 

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

annual basis until an acceptable continuousmonitoring ta as specified in (a) ' (b). or (c) is 

implemented If PM emissions are greater than 50% of the emission limit specified in SC | 2 for any single 

semi-annual or annual test, then quarterly testing shall be required. 

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

later than January 1.2O15. 

a. The permittee shall instaU, calibrate, maintain and operate in a satisfactory manner, a Contin uous 

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

or an alternative method approved by the AQD for PM. The permittee shall also meet the following 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 34 of 101 

The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT3-S1 a 

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

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

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

procedures: 

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

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

more than two hours. 

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

determine the opacity using federal Reference Test Method 9 (40 CFR Part 60 

(Appendix A)). 

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

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

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

requirements: 

The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

Supervisor, require verification of the presence of visible emissions by taking 6-minute visible 

emission readings for EU-UNIT3-S1 a minimum of once per calendar day when the boiler is 

operating. Either a certified or non-certified reader shall take each visible emission reading during 

routine operating conditions. If the permittee observes any visible emissions, the permittee shall 

immediately implement the following procedures: 

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

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

than two hours. 

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

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

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

and record the PM emissions from EU-UNIT3-S1 on a continuous basis. The permittee shall install and 

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

permittee shall also meet the following requirements: 

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

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

ii. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

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

for EU-UNIT3-S1 a minimum of once per calendar day when the boiler is operating. Either a 

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

conditions. If the permittee observes any visible emissions, the permittee shall immediately 

implement the following procedures: 

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

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

than two hours. 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 35 of 101 

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

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

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

40CFR5221(j)) 

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

record the SO2 , NOx, and CO emisoions, and oxygen or carbon dioxide (0 2or CO2) content of the exhaust 

gas from EU-UNIT3-S1 on a continuous basis. The permittee shall install and operate each CEM to meet 

the t/me|ines, requirements and reporting detailed in Appendix B attached. (R 336'1205, R 336.2810, 

40 CFR 52'21(j), R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 

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

record the mercury emissions from EU-UN|T3-G1 on a continuous basis. The permittee shall install and 

operate an Hg monitor to meet the timelines, requirements and reporting detailed in Appendix B attached. 

(F{336.1224,R33G'122D,R3%G.1228(2)(b),Fl336'2S03(2)) 

6. The permittee shall insta|, uo|ibrote, maintain and operate in a satisfactory manner a device to monitor and 

record the exhaust gas flow rate from EU-UNIT3-S1 on a continuous basis. The monitor shall be operated 

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

R!33G.2902(2)(o),4OCFRS1(Appendix S)) 

7. The permittee shall inataU, ce|ibrete, maintain and operate in a satisfactory manner a device to monitor and 

record the gross energy output from EU-UNIT3-S1 on a continuous basis. The monitor shall be operated in 

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

8. The permittee shall koep, in a satisfactory manner, hourly and 24-hour rolling average SO 2emission rate 

records for EU-UN|T3'S1, as described in emission limits SC 1.5 and 1.6, respectively. (R 336.2803, 

R 336.2804, R 336.2810,40CFR 52'21(c),(d).and (j),R 336'29O2(2)(c),40CFR51 (Appendix S)) 

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

rate and mass records for EU-UNIT3-S1, as described in emission limits 8{} 1.7, and 1.8. (R 336.2803. 

R 336.2804, R 336.2810.40CFR 52.21(c),(d)' and U>\ 

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

mass records for EU-UNIT3-S1, as described in emission limits GC|.3 and |.1O. (R 336.2804.R336.2@18. 

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

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

mercury mass emission rate records for EU-UNIT3-S1, as described in emission limits SC 1.18 and SC 1.19. 

If the monitoring required by yNnnitoring/Raoonjkeaping SC V|.4 is only capable of detecting gaseous 

nnen:ury, the permittee shall use the testing required by Testing/Sampling SC V.9 to develop a correction 

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

data, the correction factor may be adjusted upon review and approval of the ADD District Supervisor. 

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

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

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

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

a. Compliance tests and any tes ng required under the special condition of this permit; 

b. Monitoring data; 

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

d. Identification, type and the amounts of all fuels combusted in EU-UNIT3-S1 on a calendar month basis; 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 36 of 101 

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

f. Records of the duration of all times EU-UNIT3-S1 is operated under start-up or shutdown conditions as 

defined in SC 111.2; 

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

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

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

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

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

VII. REPORTING 

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

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

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

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

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

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

period. 

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

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

and corrective action. 

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

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

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

period, the permittee shall report that fact. 

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

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

VIII. STACK/VENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height 

Stack & Vent ID Diameter/Dimensions Above Ground Underlying Applicable 

_ inches feet Requirements _ 

R 336.1225, R 336.1901, 

1. SVO16-003 336 579 R 336.2803, R 336.2804, 

40 CFR52.21(c)and(d) 

IX. OTHER REQUIREMENTS 

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

as it applies to EU-UNIT3-S1. (40 CFR Part 97) 

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

Program, as it applies to EU-UNIT3-S1. (40 CFR Parts 72 - 76) 
DTE Electric Company, Monroe Power Plant (B281S) June 25, 2013 

Permit No. 27-13 Page 37 of 101 

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

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT3-S1, 

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

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 38 of 101 

The following conditions apply to: EU-UNIT4-S1 

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

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

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

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Low-NOx burnars, overfire air, REF sorbent system, SD a ond ammonia 

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

wet flue gas desulfurization (FGD). 

I. EMISSION LIMITS 

Time Period I Testing I 

- Underlying Applicable Pollutant Limit Operating Equipment Monitoring Re uirements 

1. Opacity 10 percent 6-minute EU-UNIT4-S1 SC V.1, R 336.1301(1)(c), 

average except SC Vl.2 R 336.2810, 

one 6-minute 40 CFR 52.21(j) 

of not more than 

2. PM 0.011 lb/MMBtu Test protocol will EU-UNIT4-S1 SC V.1, R 336.1224, 

heat input specify SCVI.3 R336.1225, 

averaging time R 336.1331 (1 )(c), 

or 24-hr rolling R 336.2810, 

average as 40 CFR 52.21(j) 

determined each 

hour the boiler 

3. PM1O 0.024 lb/MMBtu Test protocol will EU-UNIT4-S1 SC V.2 R 336.2810, 

heat input specify 40 CFR 52.21(j) 

L PM1O 183.0 pph Test protocol will EU-UNIT4-S1 SC V.2 R 336.2803, 

specify R 336.2804, 

averaging time. R 336.2810, 

heat input average as SC Vt.8 R 336.2810, 

determined each 40 CFR 52.21(j), 

hour the boiler R 336.2902(2)(c), 

average as SC Vl.6, R 336.2804, 

determined each SC Vl.8 R 336.2810, 

operates R 336.2902(2)(c), 

heat input average as SC Vl.9 40 CFR 52.21(j) 

determined each 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 39 of 101 

Time Period I Testing I Undeilying Applicable Pollutant Limit Operating Equipment Monitoring 

8. NOx 222.6 ton/month 12-month rolling EU-UN lT4-S1 SC VIA, R 336.2803, R 336.2804, 

average as SCVI.6, R336.2810, 

determined each SC Vl.9 40 CFR 52.21(c), (d), and U) 

9. CO 0.15 lbIMMBtu 30-day rolling EU-UNIT4-S1 SC Vl.4, R 336.2810, 

heat input average as SC Vl.10 40 CFR 52.21(j) 

excluding periods determined each 

of start-up and calendar day the 

10. CO 27,446.4 lb/day 30-day rolling EU-UNIT4-S1 SC Vl.4, R 336.2804, 

average as SC VI.6, R 336.2810, 

determined each SC Vl.10 40 CFR 52.21(d) and U) 

calendar day the 

11. VOC 0.0034 lb/MMBtu Test protocol will EU-UNIT4-S1 SC V.4 R 336.1122(f), R 336.1224, 

heat input specify R 336.1225, 

averaging time. R 336.1702(a), 

12. VOC 25.9 pph Test protocol will EU-UNIT4-S1 SC V.4 R 336.1122(f), R 336.1224, 

specify R336.1225, 

averaging time. R 336.1702(a), 

13. Lead (Pb) 1.69 x 10 Test protocol will EU-UNIT4-S1 SC V.5 R 336.1901, 

Ib/MMBtu heat specify R 336.2810, 

14. Lead (Pb) 0.13 pph Test protocol will EU-UNIT4-S1 SC V.5 R 336.1901, 

specify R336.2804, 

averaging time. R 336.2810, 

15. Sulfuric acid 0.005 lb/MMBtu Test protocol will EU-UNIT4-S1 SC V.6 R 336.1224, 

mist (H2SO4) heat input specify R 336.1225, 

averaging time. R 336.2810, 

16. Hydrogen 0.0024 lb/MMBtu Test protocol will EU-UNIT4-S1 SC V.7 R 336.1224, 

Chloride heat input specify R 336.1225 

17. Hydrogen 0.00023 Test protocol will EU-UNIT4-S1 SC V.8 R 336.1224, 

Fluoride (HF) lb/MMBtu specify R 336.1225, 

heat input averaging time. R 336.2810, 

18. Mercury (Hg) 0.02 lb/GW-hr 12-month rolling EU-UNIT4-S1 SC V.9, R 336.1224, 

gross energy average as SC Vl.5, R 336.1228, 

output determined each SC Vl.7, R 336.1229(2)(b), 

19. Mercury (Hg) 143.1 lb/year 12-month rolling EU-UNIT4-S1 SC V.9, R 336.1224, 

time period as SC Vl.6, R 336.1228, 

determined at SC Vl.5, R 336.1229(2)(b), 

the end of each SC Vl.7, R 336.2503(2) 

20. Arsenic (As) 6.3 x 10 Test protocol will EU-UNIT4-S1 SC V.5 R 336.1224, 

lb/MMBtu heat specify R 336.1225(2) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page4Oof1O1 

- 

U' MATERIAL LIMITS 

1. The permittee shall only use No. 2 fue oil for the initial start-up fuel, flame stabhzetion, and overfiring. 

Start-up is defined in SC 111.2. /R33$'1205(1)(a) and (1)(b),B33G'2Q1M,48CFR 52.21(j)) 

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

month of petroleum coke in EU-UNIT4-S1. (R336.1205(1)(a) and (1)(b), R 336.1224, R336.1225 ' 

R 336.1702(a), R 336.1901, R 336.2810,40CFR52.21(j)) 

III. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-UNIT4-S1 unless a MAP as described in Rule 911(2), for operation of 

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

address or inadequately addresses an event that meets the characteristics of a nna|funudm1, the permittee 

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

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

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

and approval. If the AQD does not notify the permittee within 90 days of submittal, the MAP or amended 

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

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

(Ri336.1224.R336'1225, R336.1331, R336'1702(m). R336.1910, R336.1811, RL336'1912. R336.2003, 

R 336.2804, R 336.2810, 40 CFR 52'21(c)°(d).and (j)\ 

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

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

for the SCR ofG50"F. Shutdown is defined as that period of time beginning when the flue gas temperature 

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

3. The permiftee shall not operate EU-UNIT4-S1 unless an acceptable plan that describes how emissions will 

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

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

standard industry practices. (R 336.1911, R 336.1912, R 336.2803, .Fi 336'2804. R 336.2810, 

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

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The maximum design heat input rate of EU-UNIT4-S1 shall not exceed 7 ' 624 million British therma units 

per hour (MMBtU/hr) on a fuel heat input basis. (R 336.1 205(1)(a) and (1)(b)) 

2. The permittee shall not operate EU-UNIT4-S1 unless the low-NOx burners, overfire air, GOnond ammonia 

flue gas conditioning uyotenns. SCR system, ESP, and wet FGD system are insialled, maintakled, and 

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

device in accordance with an approved MAP for EU-UN!T4-S1 as required in SC 111.1. (R 336.1224, 

R 336.1225, R 336.1901, R 336'1910,R336.2810,40CFRL52,21(j)) 

3. The permittee shall not operate EU-UNIT4-S1 unless the REF sorbent system is inoto||ed, mahltained, and 

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

device in accordance with an approved MAP for EU-UNIT4-S1 as required in SC 111.1. (R 336.1225, 

R 336.1910) 
DTE Electric Company Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 41 of 101 

V. 

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

The permittee shall verify the visible emissions and PM emission rates from EU-UNIT4-Sl by testing at 

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

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

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

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

AQD Technical Programs Unit and District Office within 00 days following the last date of the test. 

(R33G.1224,R33G'2D01,R336'2003.R336.2DO4,R33G.2Q10,48CFR 52'21(j)) 

2. The permi~~Um~~ e P M 1Oem~~~~ f~B~N~~1~~~~~~~s~~~~ 

accordance Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

R 336.2004, R 336.2803, R 336'2804,R 336.2810, 40 CFR 52.21(c), (d), and U\) 

3. The permittee shall verify the PM2.5 emission rates from EU-UNIT4-S1 by test ing at owner's expense, in 

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

for the next ten years of operation after the modification. No less than 80 days prior to test ing, the 

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

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

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

80 days following the last date of the test. (R 336.2001, R 336'2003, R]36°2U04. R 336-2902(2)(n)^ 

40 CFR 51 (Appendix S)) 

4. The permittee shall verify testi ng at owner's expense, in 

accordance with Department requirements -

Th permittee must complete the test o every five years 

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

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

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

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

5. The pe rmittee shall verify the Pb and As emission rates from EU-UNIT4-S1 by testing at owner's expense, 

in accordance with Department requirements The permittee must complete the test once every five years 

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

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 33G1225,R 336.1901, 

R33G.2O01,R33G.20O3,FK33G'2004,R 336'2804,B|336.2B10.4gCFRS221(d) and .(])) 

S The permittee shallVehfvfhe H 2SO4emission rates from BU'UN[T4-G1 by test at owner's expense in 

accordance with Department requirements The permittee must complete the test once every five years 

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

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.2001, 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 42 of 101 

The permittee shall verify the HCI emission rates from EU-UNIT4-S1 by testing at owner's expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, 

R 336.2001, R 336.2003, R 336.2004) 

8. The permittee shall verify the HF emission rates from EU-UNIT4-S1 by testing at owner's expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 336.1224, R 336.1225, 

R 336.2001, R 336.2003, R 336.2004, R 336.2810, 40 CFR 52.210)) 

9. The permittee shall verify the total Hg emission rates from EU-UNIT4-S1 by testing at owner's expense, in 

accordance with Department requirements. The permittee must complete the test once every five years. 

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

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

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

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

R 336.2004) 

Vl. MONITORING/RECORDKEEPING 

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

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

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

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

R 336.1225, R 336.1702, R 336.1901) 

2. The permittee shall conduct visible emission observations using federal Reference Test Method 9 

(40 CFR Part 60 (Appendix A)), or an alternate method approved by the AQD, on a calendar day basis each 

day the boiler operates or the permittee shall install, calibrate, maintain and operate in a satisfactory manner 

a COM system to monitor and record the visible emissions before the wet FGD from EU-UNIT4-S1 on a 

continuous basis. The permittee shall install and operate the COM system to meet the timelines, 

requirements and reporting detailed in Appendix A and correlate pre-wet FGD visible emissions to post-wet 

FGD visible emissions on an annual basis. If the permittee installs a PM CEM per SC VI.3.c., this special 

condition is void. (R 336.1301, R 336.2810, 40 CFR 52.21(j)) 

3. Prior to the implementation of a continuous monitoring system as specified in (a), (b) or (c) below, the 

permittee shall perform PM emission testing as specified in SC V.1 on a quarterly basis. If the PM emission 

rates are less than 50% of the emission limit specified in SC 1.2 for four consecutive quarters, the permittee 

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

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

emissions are greater than 50% of the emission limit specified in SC 1.2 for any single semi-annual or 

annual test, then quarterly testing shall be required. 

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

later than January 1, 2015. 

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

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

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

requirements: 
DTE Electric Company Monroe Power Plant (B2D1G) June 25, 2013 

Permit No. 27-13 Page 43 of 101 

The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

frequencies are approved in writing by the AQD District Gupen/isor, require verification of the 

presence of visible emissions by taking 6-minute visible emission readings for EU-UNIT4-S1 a 

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

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

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

procedures: 

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

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

than two hours. 

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

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

b. The permittee shall install, ca|ibrate, maintain and operate in a sat manner, a PM Predictive 

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

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

requirements: 

i. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

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

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

8uparvisor, require verification of the presence of visible emissions by taking 6-minute visible 

emission readings for EU-UNIT4-S1 a minimum of once per calendar day when the boiler is 

operating. Either a certified or non-certified reader shall take each visible emission reading during 

routine operating conditions. iftha permittee observes any visible emissions, the permittee shall 

immediately implement the following procedures: 

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

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

than two hours. 

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

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

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

and record the PM emissions from EU-UNIT4-S1 on a continuous basis. The permitteeohcd| install and 

operate the CEM to meet the Unne|inee, requirements and reporting detailed in Appendix B. The 

permittee shall also meet the following requirements: 

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

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

ii. The MAP required in SC 111.1 shall include provisions for alternative monitoring in the event that the 

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

accordance with Procedure 2 of 40 CFR Part 60 (AppendixF). This alternative monitoring shaU, 

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

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

for EU-UNIT3-S1 a minimum of once per calendar day when the boiler is operating. Either a 

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

conditions. If the permittee observes any visible ennisaions, the permittee shall immediately 

implement the following procedures: 

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

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

than two hours. 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 44 of 101 

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

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

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

40 CFR 52.21(j)) 

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

record the SO2 , NOx, and CO emissions, and oxygen or carbon dioxide (0 2 or CO2) content of the exhaust 

gas from EU-UNIT4-S1 on a continuous basis. The permittee shall install and operate each CEM to meet 

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

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

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

record the mercury emissions from EU-UNIT4-S1 on a continuous basis. The permittee shall install and 

operate an Hg monitor to meet the timelines, requirements and reporting detailed in Appendix B attached. 

(R 336.1224, R 336.1228, R 336.1229(2)(b), R 336.2503(2)) 

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

record the exhaust gas flow rate from EU-UNIT4-S1 on a continuous basis. The monitor shall be operated 

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

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

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

record the gross energy output from EU-UNIT4-S1 on a continuous basis. The monitor shall be operated in 

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

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

records for EU-UNIT4-S1, as described in emission limits SC 1.5 and 1.6, respectively. (R 336.2803, 

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

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

rate and mass records for EU-UNIT4-S1, as described in emission limits SC 1.7, and 1.8. (R 336.2803, 

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

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

mass records for EU-UNIT4-S1, as described in emission limits SC 1.9 and 1.10. (R 336.2804, R 336.2810, 

40 CFR 52.21(d) and (j)) 

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

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

mercury mass emission rate records for EU-UNIT4-S1, as described in emission limits SC 1.18 and SC 1.19. 

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

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

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

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

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

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

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

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

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

b. Monitoring data; 

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

d. Identification, type and the amounts of all fuels combusted in EU-UNIT4-S1 on a calendar month basis; 

e. Total gigawatt-hours of energy produced on a monthly basis; 
DTE Electric Company, Monroe Power Plant (B2816) 

Permit No. 27-13 

June 25, 2013 

Page 45 of 101 

f. Records of the duration of all times EU-UN|T4-S1 is operated under start-up or shutdown conditions as 

defined in SC 111.2; 

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

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

available to the Department upon request. (R 336'1205(1)(a), R 336'1224, R 336.1225 R 336.1228, 

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

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

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

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

quarter as specified in 40 CFR 80.7(c) and (d). The Summary Report shall follow the format of Fi ure 1 in 

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

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

includes the date, time, nnagnhude, cause and corrective actions of all occurrences during the reporting 

period. 

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

System (CEyW8/CERMG), and if applicable Predictive Emission Monitoring System (PEW1G), downtime 

and corrective action. 

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

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

e. If no exceedances or CEMS/CERMS, and if applicable PEW1S, downtime occurred during the reporting 

period, the permittee shall report that fact. 

(R 336.1205 R 336.1224, R 336.1228, R 3361229(2)(b),R 336.2803 R 336.2804 R 336.2810, 

VIII. STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack & Vent ID Diameter/Dimensions Above Ground Requirements 

R 336.1225, R 336.1901, 

1. SVO16-004 336 579 R 336.2803, R 336.2804, 
June 25 2013 

Page 46 of 101 

IDTE Electric Company, Monroe Power Plant (132816) 

Permit No. 27-13 

IX. OTHER REQUIREMENTS 

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

as it applies to EU-UN 1T4-S1. (40 CFRPort 97) 

The permittee shall comply with all of the applicable requirements contained in the federal Acid Rain 

Program, as it applies to EU-UNIT4-S1. (4MCFRParts 72 - 76) 

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

Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart UUUUU, as they apply to EU-UNIT4-S1, 

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

Footnotes: 

'This condition is state only enforceable and was established pursuant to Rule 20 1 (1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 47 of 101 

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel 

fuel servicing theUnit 3 stack. 

Flexible Group ID: FG-ProjectPCl-4 

L EMISSION LIMITS 

Time Period! 

- 

Monitoring! Underlying Applicable Pollutant Limit Operating Equipment Testing Requirements 

1. Opacity 20 percent 6-minute EU-WFGD-QPI GC 13 R 336.1301(1)(c), 

average except R 336.2810, 

one 6-minute 40 CFR 52.21(j) 

average per 

hour of not more 

2. PM 0.40 g/hp-hr Test protocol will EU-WFGD-QP1 40 CFR R 336.2810, 

specify 60.4211, 40 CFR 52.21(j), 

3. PM1O 0.40 g/hp-hr Test protocol will EU-WFGD-QPI CC 13 R 336.2803, R 336.2804, 

specify R336.2810, 

specify 40 CFR 51 (Appendix S) 

specify 60.4211, R336.2810, 

i. CO 2.60 g/hp-hr Test protocol will EU-WFGD-QPI 40 CFR R 336.2804, 

specify 60.4211, R 336.2810, 

averaging time. CC 13 40 CFR 52.21(d) and U) 

|L MATERIAL LIMITS 

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-VVFGO-QP1. 

(R 3361205(1)(a) and (1)(b), ft 336.1401 ' R33&2Q03. R33GiOO4, R 336.2810, R 336.2982(2)(c), 

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60'4207) 
DTE Electric Company, Monroe Power Plant (62816) June 25, 2013 

Permit No. 27-13 Page 48 of 101 

Ill. PROCESS/OPERATIONAL RESTRICTIONS 

1. The permittee shall operate and maintain EU-WFGD-QP1 according to the manufacturer's written 

instructions or procedures that are approved by the manufacturer to ensure compliance with the applicable 

emission standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211) 

2. The permittee shall not operate EU-WFGD-QP1 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar 

month. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e)) 

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP1 unless permitted by the manufacturer in writing. (40 CFR 60.4211) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall equip and maintain EU-WFGD-QP1 with a non-resettable hour meter to track the 

number of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.21(j), 40 CFR 60.4209(a)) 

V. TESTING/SAMPLING 

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

m 

VI. MONITORING/RECORDKEEPING 

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

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

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

otherwise specified in any monitoring/record keeping special condition. (R 336.1205, R 336.1901, 

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

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP1. 

The record shall include the time and duration of operation, and the reason the engine was in operation. 

The permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b)) 

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

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

VII. REPORTING 

m 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 49 of 101 

VIII. STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Above Underlying Applicable 

_____________________ Diameter (inches) Ground (feet) Requirements 

R 336.1225, R 336.1901, 

IX. ER REQUIREMENTS 

1 The permittee shall comply with all prov isions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and U||. as they apply to EU-VVFED-QP1. 

(4O CFR Part 60 Subparts A and |Y|1) 

2. The permittee shall provide written notification of construction and operation to comply with the federa l 

Standards of Performance for New Stationary Sournes, 40 CFR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7) 

3. The permitteeshaUconnpk/vvitheUopp|icob|eprovisionnoftheNabona Emission Standards for Hazardous 

Air PoUutants, as specified in 40 CFR, Part 63. Subpart A and Subpart ZZZZ. for Stationary Reciprocating 

Internal Combustion Engines upon start-up (40 CFR Part 63, Subparts A and ZZZZ) 

~ is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 50 of 101 

The following conditions apply to: EU-WFGD-QP2 

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 4 stack. 

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: NA 

L EMISSION LIMITS 

Time Period! Monitoring! Underlying Applicable Pollutant Limit Operating Equipment Testing Method Requirements 

1. Opacity 20 percent 6-minute EU-WFGD-QP2 GC 13 R 336.1301 (1 )(c), R 336.2810, 

average except 40 CFR 52.21 (j) 

one 6-minute 

average per 

hour of not more 

2. PM 0.40 g/hp-hr Test protocol will EU-WFGD-QP2 40 CFR 60.4211, R 336.2810, 

specify GC 13 40 CFR 52.21(j), 

3. PM1O 0.40 g/hp-hr Test protocol will EU-WFGD-QP2 CC 13 R 336.2803, R 336.2804, 

specify R336.2810, 

. PM2.5 0.40 g/hp-hr Test protocol will EU-WFGD-QP2 GC 13 R 336.2902(2)(c), 

specify 40 CFR 51 (Appendix S) 

5. NMHC + 7.80 g/hp-hr Test protocol will EU-WFGD-QP2 40 CFR 60.4211, R 336.2803, R 336.2804, 

NOx specify GC 13 R 336.2810, 

. CO 2.60 g/hp-hr Test protocol will EU-WFGD-QP2 40 CFR 60.4211, R 336.2804, 

specify GCI3 R336.2810, 

averaging time. 40 CFR 52.21(d) and (j), 

|i MATERIAL LIMITS 

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP2. 

{R 336'1205(1)(a) and (1)(b), R 336.14O1 ' R 336'2803, R 336'2804, Fi33G'2810, R 336.2902(2)(c), 

40 CFR 51 (Appendix 5),40CFRS2'21(:},(d),and (j).40CFR 60.4207\ 
DTE Electric Company, Monroe Power Plant (B281S) June 25, 2013 

Permit No. 27-13 Page 51 of 101 

|U. PROCESS/OPERATIONAL RESTRICTIONS 

1. The permittee shall operate and maintain EU-WFGD-QP2 according to the manufacturer's written 

instructions or procedures that are approved by the manufacturer to ensure compliance with the applicable 

emission standards in 40 CFR 60.4205(o). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b). 

40 CFR 60.4206, 40 CFR 60.4211) 

2. The permittee shall not operate EU-WFGD-QP2 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar 

month. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j),40 CFR 60.4211(e)) 

3. The permittee shall not change or revise the operating inobuctiona, procedures or settings for 

EU-WFGD-QP2 unless permitted by the manufacturer in writing. (40 CFR 60.4211) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall equipand maintain with a non-resettable hour meter to track the 

number of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 5221 (d)` 

40 CFR 52'21H),4OCFR 60.4209(a)) 

V. 

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

\8. 

Records shall be maintained on file for a period of five year . (R 336'1201(3)) 

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

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

otherwise specified in any monitoring/recordkeeping special condition. (R 336'1205. R 336.1901, 

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21 U)) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP2. 

The record shall include the time and duration of operation, and the reason the engine was in operation. 

The permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336'2810,40 CFR S2.21(d).40 CFR S2'21(j),4O CFR $0.4214(b)) 

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppnl for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

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

VII. REPORTING 
June 25, 2013 

Page 52 of 101 

DTE Electric Company, Monroe Power Plan (B2816) 

Permit No. 27-13 

VU' STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust I Minimum Height Above Underlying Applicable 

Diameter (inches) I Ground (feet) Requirements 

R 336.1225, R 336.1901, 

IX. OTHER REQUIREMENTS 

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 80 Subparts A and UU, as they apply to EU-WFGD-QP2. 

(40 CFR Part 60 Subparts A and 1111) 

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 {}FR 60.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (48 CFR G8,7) 

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

Air PnUutantm, as specified in 40 CFR, Part 63. Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ) 

Footnotes: 

Thi condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
June 25, 2013 

Page 53 of 101 

DTE Electric Company, Monroe Power Plan (82816) 

Permit No. 27-13 

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diese 

fuel servicing the Unit 1 stack. 

Flexible Group ID: FG-FrojectPCl-4 

L EMISSION LIMITS 

- 

Time Period! Monitoring! Underlying Applicable 

Pollutant Limit Operating Equipment Testing Method Requirements 

1, Opacity 20 percent 6-minute average EU-WFGD-QP3 GC 13 R 336.1301(1)(c), 

except one 6- R 336.2810, 40 CFR 52.21(j) 

minute average 

per hour of not 

more than 27 

2. PM 0.15 g/hp-hr Test protocol will EU-WFGD-QP3 40 CFR 60.4211, R 336.2810, 

specify averaging GC 13 40 CFR 52.21(j), 

3. PM1O 0.15 g/hp-hr Test protocol will EU-WFGD-QP3 GC 13 R 336.2803, R 336.2804, 

specify averaging R 336.2810, 

specify averaging 40 CFR 51 (Appendix S) 

NOx specify averaging GC 13 R 336.2810, 

CO 2.60 g/hp-hr Test protocol will EU-WFGD-QP3 40 CFR 60.4211, R 336.2804, 

specify averaging GC 13 R 336.2810, 

IL MATERIAL LIMITS 

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP3. 

(R 336.1205(1)(a) and (1)(b), R 336'1401, R336.2D03, R336'2@O4, R33G.2810, R 336.2902(2)kd' 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 54 of 101 

Ill. PROCESSIOPERATIONAL RESTRICTIONS 

1. The permittee shall operate and maintain EU-WFGD-QP3 according to the manufacturer's written 

instructions or procedures that are approved by the manufacturer to ensure compliance with the applicable 

emission standards in 40 CFR 60.4205(c). (R 336.2810, 40 CFR 52.21(j), 40 CFR 60.4205(b), 

40 CFR 60.4206, 40 CFR 60.4211) 

2. The permittee shall not operate EU-WFGD-QP3 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the end of each calendar 

month. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4211(e)) 

3. The permittee shall not change or revise the operating instructions, procedures or settings for 

EU-WFGD-QP3 unless permitted by the manufacturer in writing. (40 CFR 60.4211) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall equip and maintain EU-WFGD-QP3 with a non-resettable hour meter to track the 

number of minutes and hours the engine operates. (R 336.2804, R 336.2810, 40 CFR 52.21(d), 

40 CFR 52.210), 40 CFR 60.4209(a)) 

V. TESTING/SAMPLING 

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

NA 

VI. MONITORING/RECORDKEEPING 

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

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

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

otherwise specified in any monitoring/record keeping special condition. (R 336.1205, R 336.1901, 

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

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP3. 

The record shall include the time and duration of operation, and the reason the engine was in operation. 

The permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52.21(j), 40 CFR 60.4214(b)) 

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401, R 336.2803, 

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

VII. REPORTING 

m 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 55 of 101 

VIII. STACK/VENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Above I Underlying Applicable 

I Diameter (inches) I Ground (feet) Requirements 

R336.1225, R336.1901, 

SVWFGDQP3 6 34 R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d) 

IX. OTHER REQUIREMENTS 

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and ||U, as they apply to EU-WFGD-QP3. 

(40 CFR Part 60 Subparts A and 1111) 

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sounces, 40 CFR 00.7. The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60.7) 

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

Air Po||ubsnts, as specified in 40 CFR, Part 63. Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Co buedoMEnginen.uponshart-up (40 CFR Part 63, Subparts A and ZZZZ) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(l)(b). 
DTE Electric Company, Monroe Power Plant (B2816) 

Permit No. 27-13 

June 25 2013 

Page 56 of 101 

The following conditions apply to: EU-WFGD-QP4 

DESCRIPTION: 252 hp diesel fuel-fired FGD quench pump and a 350 gallon elevated storage tank for diesel 

fuel servicing the Unit 2 stack. 

Flexible Group ID: 1-4 

I. EMISSION LIMITS 

Pollutant Limit 

Time Period! 

. Operating Equipment Monitoring! Underlying Applicable 

Testing Method Requirements 

1. Opacity 20 percent 6-minute EU-WFGD-QP4 GC 13 R 336.1301(1)(c), 

average except R 336.2810. 40 CFR 52.21(j) 

one 6-minute 

average per 

hour of not more 

2. PM 0.15 g/hp-hr Test protocol will1EU-WFGD-QP4 40 CFR 60.4211, R 336.2810, 

specify GC 13 40 CFR 52.21(j), 

3. PM10 0.15 g/hp-hr Test protocol will EU-WFGD-QP4 GC 13 R 336.2803, R 336.2804, 

specify R 336.2810, 

specify 40 CFR 51 (Appendix S) 

5. NMHC + 3.00 g/hp-hr Test protocol will EU-WFGD-QP4 40 CFR 60.4211, R 336.2803, R 336.2804, 

NOx specify GC 13 R 336.2810, 

3. CO 2.60 g/hp-hr Test protocol will EU-WFGD-QP4 40 CFR 60.4211, R 336.2804, 

specify GCI3 R336.2810, 

averaging time. 40 CFR 52.21(d) and (j), 

K MATERIAL LIMITS 

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in EU-WFGD-QP4. 

(R 336,1205(1)(a) and (1)(b), R 336.1401, R|336.2O03. R336.28b4, Fl33G.2D1[\ R 336.29O2(2)(c) ' 

40 CFR 51 (Appendix S), 40 CFR 52.21(c), (d), and (j), 40 CFR 60.4207) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 57 of 101 

III. PROCESS/OPERATIONAL RESTRICTIONS 

1. The permittee shall operate and maintain EU-WFGD-QP4 according to the manufacturer's written 

instructions or procedures that are approved by the manufacturer to ensure compliance with the applicable 

emission standards in 40 CFR 00.4205(o). (R336'2810 ' 40 CFR 52'21(j), 40 CFR 68.4205(b). 

40 CFR 60.4206, 40 CFR 60.4211) 

2. The permittee shall not operate EU-WFGD-QP4 for more than 30 minutes per hour, nor a total of 200 hours 

at full load equivalent rate per 12-month rolling time period as determined at the and of each calendar 

month. (R 33G.2804,R336'2O10,40 CFR S2'21(d).4O CFR 52.21(j) ' 4D CFR 8D.4211(e)) 

3. The permittee shall not change or revise the operating instruotions, procedures or settings for 

EU-WFGD-QP4 unless permitted by the manufacturer in writing. (40 CFR 60.4211) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall equip and maintain EU-WFGD-QP4 with a non-resettable hour meter to track the 

number of minutes and hours the engine operates. (R 336'2804. R 336'2810, 40 CFR 52.21 (d), 

40 CFR 5%'21(j)' 4O CFR 60.42O9(s)) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years (R336.12O1(3)) 

NA 

VI. MONITORINGIRECOROKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1 201 (3)) 

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

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

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901, 

R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52'210\) 

2. The permittee shall monitor and record in a satisfactory manner, the hours of operation of EU-WFGD-QP4. 

The record shall include the time and duration of openstion, and the reason the engine was in operation. 

The permittee shall keep all records on file and make them available to the Department upon request. 

(R 336.2804, R 336.2810, 40 CFR 52.21(d), 40 CFR 52'21(j),40 CFR 60.4214(b)) 

3. The permittee shall keep records, in a satisfactory manner, of the fuel supplier certification and/or analysis 

including the sulfur content in ppm for each delivery of the diesel fuel oil. (R 336.1401. R336.2803, 

VII. REPORTING 
June 25.2U13 

Page 58 of 101 

DTE Electric Company Monroe Power Plant (B281G) 

Permit No. 27-13 

VIII. 

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

to the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Above Underlying Applicable 

Diameter (inches) Ground (feet) Requirements _____________________ 

R 336.1225, R 336.1901, 

1. SV-WFGD-QP4 6 34 R 336.2803, R 336.2804, 

IX. OTHER REQUIREMENTS 

1 The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and U||, as they apply to EU-WFGD-QP4. 

(40 CFR Part 60 Subparts A and 1111) 

2. The permittee shall provide written notification of construction and operation to comply with the federal 

Standards of Performance for New Stationary Sources, 40 CFR 80I The permittee shall submit this 

notification to the AQD District Supervisor within the time frames specified in 40 CFR 60.7. (40 CFR 60J) 

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

Air PoUutento, as specified in 40 CFR, Part 63 Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR Part 63, Subparts A and ZZZZ) 

Footnotes: 

'Thisnonditionksatatoonhanfon;eabeandvvaseotab(kshadpunsuondtoRu|e2O1(1)(b) 
DTE Electric Company Monroe Power Plan (B2816) June 25, 2013 

Permit No. 27-13 Page 59 of 101 

The following conditions apply to: EU-CASCADES-SI 

DESCRIPTION: This emission unit represents coal handling activity in the Cascades room. Coal handling 

activity emissions are limited by an enclosure, wet dust suppression, and baghouse dust collectors. 

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Cascade room dust collector (SV-Dl), Cascade room dust collector 

(SV-O2). Cascade room dust collector (SV-D3), Cascade room dust collector (SV-D4). Cascade room dust 

collector (SV-D5), Cascade room dust collector (5VcD6), enc|osuras, water sprays, and/or dust suppressants. 

I. EMISSION LIMITS 

Pollutant Limit Operating Equipment Monitoring Reuirements 

1. Opacity 10 percent Test protocol Exhaust vents SC Vl.3 R 336.1301(1)(c) 

will specify SV-D1, SV-D2, 

2. Opacity 5 percent Test protocol Exhaust vents SC Vl.3 R 336.1301(1)(c), 

will specify SV-D4, SV-D5, R 336.2810, 

3. PM 0.O2Ogr/dscf Test protocol SV-D1, GC 13 R336.1331(1)(c) 

of exhaust will specify SV-D2, 

. PM 0.004 gr/dscf Test protocol SV-D4, GC 13 R 336.1331(1)(c), 

of exhaust will specify SV-D5, R 336.2810, 

5. PM1O 5.95 pph Test protocol SV-D1 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

will specify 40 CFR 51 (Appendix S) 

7. PM1O 5.95 pph Test protocol SV-D2 GC 13 R 336.2803, R 3362804, 

will specify 40 CFR 52.21 (c) and (d) 

will specify 40 CFR 51 (Appendix 5) 

9. PM1O 5.95 pph Test protocol SV-D3 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

10. PM2.5 5.95 pph Test protocol SV-D3 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix 5) 

11. PM1O 1.19 pph Test protocol SV-D4 GC 13 R 336.2803, R 336.2804, 

will specify R 336.2810, 

12. PM2.5 1.19 pph Test protocol SV-D4 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

13. PMIO 1.19 pph Test protocol SV-D5 GC 13 R 336.2803, R 336.2804, 

will specify R 336.2810, 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 60 of 101 

Time Period 1 Testing 1 Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements Scenario Method 

14. PM2.5 1.19 pph Test protocol SV-D5 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

avera in time. 

15. PM10 1.21 pph Test protocol SV-D6 GC 13 R 336.2803, R 336.2804, 

will specify R 336.2810, 

avera in time. 40 CFR 52.21 (c), d) and W 

16. PM2.5 1.21 pph Test protocol SV-D6 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

averagingtime. 

II. MATERIAL LIMITS 

Ill. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-CASCADES-S1 unless a program for continuous fugitive dust control for 

all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control.. 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524) 

2. The permittee shall not operate EU-CASCADES-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

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

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, 

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

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-CASCADES-S1 unless the associated enclosures, 

water sprays, and fabric filters are installed, maintained and operated in a satisfactory manner. The 

permittee shall equip each fabric filter with broken bag leak detectors, or an alternative monitoring 

method approved in writing by the AQD District Supervisor. Satisfactory manner includes operating and 

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

in SC 111.2. (R336.1901, R336.1910, R336.1911, R336.2803, R336.2804, R336.2810, 

40 CFR 52.21 (c), (d), and (j)) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 61 of 101 

2. The permittee shaU not operate EU-CASCADES-G1 unless the external conveyor hoods or enclosures 

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

and maintaining each control device in accordance with an approved MAP for EU-CASCADES-S1 

as required in SC 111.2. (R336.1901, R336.1910. R 336.1911. R336'2803, R336'2804, Ri336.2818, 

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

V. TESTINGISAMPLING 

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

The permittee shall verify the PM2.5 emission rates from EU-CASCADES-S1 or a representative emission 

unit by testing at owner's expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less 

than 80 days prior to bssting, the permittee shall submit a complete test plan to the AQD Technical 

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

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

Programs Unit and District Office within 60 days following the last date of the test. (R 336.2001, R 336.2002. 

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

Vi 

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

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

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

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detootors, or alternative 

monitoring meaeunaa, as approved by the AQD District Supervisor on each fabric filter of 

EU-CASCADES-S1. (R 336.1901, R33G.1910, R 336.1911, R 336'2003, R 336'2804, H!33G.201Q ' 

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

If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC |\(1, the permittee shall perform and document non-certified vis observations 

as required in Emission Limit SC 1.1 and 1.2 on a daily basis when EU-CASCADES-S1 is operating. If 

during the observation there are any visible emissions detected from an emission point, a USEPA Method 9 

certified visible emissions observation shall be conducted for a minimum of 15 minutes to determine the 

actual opacity from that emission point. Records of the non-certified visible emissions observations, USEPA 

Method 9 observations that are performed, the reason for any visible emissions observed and any corrective 

actions taken shall be kept on file and in a format acceptable to the AQD. (Bi336'13U1(1)(m). R 336'2810. 

40 CFRS2.21(j)\ 

VII. REPORTING 

1. Within 30 days after completion of the inotaUobnn, construction, reoonstn/ution, relouoUon, or modification 

authorized by this Permit to |nstaU, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supen/ieor, in vvhbng, of the activity. Completion of the insteUation, constnuotion, 

naoonstruwtion, ne|ocation, or modification is considered to occur not later than commencement of trial 

operation of EU-CASCADES-S1. (Ri33Q'120i(7)(b)) 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 62 of 101 

VIII. STACKNENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground (feet) Requirements 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

R336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

|X. OTHER REQUIREMENTS 

Footnotes: 

'Thisoonditionissbateonk/enhznzoebloondvvasamtabUehedpunsuanthoRuka2U1(1)(b\ 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 63 of 101 

The following conditions apply to: EU-TRANSFERHS-S1 

DESCRIPTION: This emission unit represents coal handling activity in the Transfer House. Coal handling 

activity emissions are limited by an enclosure, wet dust suppression, and baghouse dust collectors. 

Flexible Group ID: FG-ProjectPC1 -4 

POLLUTION CONTROL EQUIPMENT: Transfer house 1 dust collector (SV -DC01/DC22), Transfer house 1 

dust collector (SV-DCO2/DC23), Transfer house 2 dust collector (SV- DC21), Transfer house 2 dust collector 

(SV-DC15), Transfer house 9 dust collector (SV-DC17), Transfer house 11 dust collector (SV- DC19), Transfer 

house 3 dust collector (SV- DC04), enclosures, water sprays, and/or dust suppressants. 

1. EMISSION LIMITS 

Time Period / Testing" 

Pollutant Limit Operating Equipment Monitoring Underlying Applicable 

Requirements Scenario Method 

1. Opacity 5 percent Test protocol Each individual fabric SC VI.3 R 336.1301(1)(c), 

will specify filter in R 336.2810, 

averaging time. EU-TRANSFERHS-S1 40 CFR 52.21 (j) 

(vents SV-DC01/DC22, 

SV-DCO2/DC23, 

SV-DC21, SV-DC15, 

SV-DC17, SV-DC19, 

SV-DC04 

2. PM 0.010 gr/dscf Test protocol SV-DC01/DC22, GC 13 R 336.1331(1)(c) 

of exhaust will specify SV-DCO2/DC23, 

gases averaging time. SV-DC21, SV-DC15 

3. PM 0.020 gr/dscf Test protocol SV-DC17, GC 13 R 336.1331(1)(c) 

of exhaust will specify SV-DC19 

gases averaging time. 

PM 0.004 gr/dscf Test protocol SV-DC04 GC 13 R 336.1331(1)(c), 

of exhaust will specify R 336.2810, 

gases averaging time. 40 CFR 52.21 (j) 

5. PM10 1.93 pph Test protocol SV-DC01 /DC22 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

averaging time. 

. PM2.5 1.93 pph Test protocol SV-DC01 /DC22 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

averaging in time. 

7. PM10 1.93 pph Test protocol SV-DCO2/DC23 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

averaging time. 

8. PM2.5 1.93 pph Test protocol SV-DCO21DC23 SC V.11 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

averaging time. 

9. PM 10 1.29 pph Test protocol SV-DC21 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

averaging timer 

10. PM2.5 1.29 pph Test protocol SV-DC21 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

averag ingtime. 
DTE Electric Company, Monroe Power Plant (B281S) June 25, 2013 

Permit No. 27-13 Page 64 of 101 

Pollutant Limit Operating Equipment Monitoring Reuirements 

11. PM1O 1.54 pph Test protocol SV-DC15 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

12. PM2.5 1.54 pph Test protocol SV-DC15 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

13. PM1O 2.40 pph Test protocol SV-DCI7 GC 13 R 336.2803, R 336.2804, 

will specify 40 CFR 52.21 (c) and (d) 

14. PM2.5 2.40 pph Test protocol SV-DC17 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

15. PM1O 2.74 pph Test protocol SV-DC19 GC 13 R 336.2803, R 336.2804, 

will specify R 336.2810, 

16. PM2.5 2.74 pph Test protocol SV-DC19 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

will specify 336.2810, 

18. PM2.5 0.89 pph Test protocol SV-DCO4 SC V.1 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix 5) 

IL MATERIAL LIMITS 

NA 

III. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate E dust 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequateiy addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 80 days of oubmitta|, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

appnoved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R33G.2803, 

Ri3%G.2004,R!33G.281Q,4OCFR 52'21(o),(d). and U\, Act 451 Section 324'5S24) 

2. The permittee shall not operate EU'TRAN3FERH8-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is imp|emonted, updated as naceoaary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a ma|funobun, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 deys, if new equipment is installed or upon 

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

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

apprnved, the permittee shall implement corrective procedures or operational changes to achieve 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 65 of 101 

compliance with all applicable emission limits. (Fl33G'1331 ° @336'181[, B336'1911" R336.2800. 

Ri336.28O4 ' R336.2O10,4OCFR 52.31(o),(d).and (j)) 

The permittee shall not operate the Transfer House 1 and Transfer House 2 portions of 

EU-TRANSFERHS-81 for more than 12 hours per calendar day. (R 336.1205(1)(a).R 336.2803, 

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

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-TRANGFERHG-G1 unless the associated enclosures, 

water sprays, and fabric filters are insta|led, maintained and operated in a satisfactory manner. The 

permittee shall equipeach fabric filter with broken bag leak dab*cbors, or an alternative monitoring method 

approved in writing by the AQD District Supervisor. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-TRANSFERHS-Sl as required in SC 111.2. 

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c), and (d)) 

2. The permittee shall not operate EU-TRANSFERHG-S1 unless the external conveyor hoods or 

enclosures are insbaUed, maintained and operated in a satisfactory manner. Satisfactory manner 

includes operating and maintaining each control device in accordance with an approved MAP for 

EU-TRANSFERH8-G1 as required in SC 111.2. (R336'1801. R336'1910, R 336.1911, Fl336'2803, 

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

V. 

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

The permittee shall verify the PM2.5 emission rates from EU-TRANGFERHS-S1 or a representative 

emission unit by testing at owner's expense, in accordance with Department requirements. The permittee 

must complete the test once every five years for the next ten years of operation after the modification. No 

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

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

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

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

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

VI. 

Records shall be maintained on file for a period of five years. (R 338.1201(3)) 

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

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

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative monitoring 

nneesunas, as approved by the AQD District Supervisor on each fabric filter of EU-TRAN8FERHS-S1. 

(R 3361901, R 336.1910, R 336'1911. R336.2803, R 336.2804, 40 CFR 52.31 (c) and (d ) ) 

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC }\(1. the permittee shall perform and document non-certified visible emissions observations 

as required in Emission Limit SC 1.1 on a daily basis when EU-TRANGFERH8-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual 

opacity from that emission point. Records of the non-certified visible emissions observations, USEPA 

Method 9 observations that are performed, the reason for any visible emissions observed and any corrective 

actions taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 
DTE Electric Company, Monroe Power Plant (52816) June 25, 2013 

Permit No. 27-13 Page 66 of 101 

4. The permittee shall keep, in a satisfactory manner, daily records of the Transfer House 1 

and Transfer House 2 portions of EU-TRANSFERHS-S1. (R 336.1205(1)(a), R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)) 

VII.REPORTING 

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

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-TRANSFERHS-S1. (R 336.1201(7)(b)) 

VIII. STACK/VENT RESTRICTIONS 

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

to the ambient air unless otherwise noted with an asterisk(*) indicating a non-vertical discharge: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground (feet) Requirements inches 

R 336.1901, R 336.2803, 

1. SV-DC01/DC22* 55 40 R 336.2804, 

40 CFR_52.21_(c)_and_(d) 

R 336.1901, R 336.2803, 

2. SV-DCO2/DC23* 55 40 R 336.2804, 

40 CFR 52.21 (c) and (d) 

R 336.1901, R 336.2803, 

3. SV-DC21* 51 16 R 336.2804, 

40 CFR_52.21_(c)_and_(d) 

R 336.1901, R 336.2803, 

4. SV-DC15* 30 50 R 336.2804, 

40 CFR 52.21 (c) and (d) 

R 336.1901, R 336.2803, 

5. SV-DC17* 30 46 R 336.2804, 

40 CFR 52.21 (c) and (d) 

R 336.1901, R 336.2803, 

6. SV-DC19* 30 121 R 336.2804, 

40 CFR 52.21 (c) and (d) 

R 336.1901, R 336.2803, 

7. SV-DC04 41 20 R 336.2804, 

40 CFR 52.21 c and (d) 

IX. OTHER REQUIREMENTS 

NA 

Footnotes: 

ss condition is state only enforceable and was established pursuant to Rule 201(1)(b). Thi
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 67 of 101 

The following conditions apply to: EU-DUMPERHS-S1 

DESCRIPTION: This emission unit represents coal handling activity in the Dumper House. Coal handling 

activity emissions are limited by an enclosure, wet dust suppression, and/or baghouse dust collectors. 

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Dumper house dust collector (SV-DC24), enclosures and dust 

suppressants. 

L EMISSION LIMITS 

Time Period / Testing I Underlying Applicable 

Pollutant Limit Operating Equipment Monitoring 

1. Opacity 5 percent Test protocol will SV-DC24 SC VI.3 R 336.1301(1)(c) 

specify averaging 

2. PM 0.005 gr/ dscf Test protocol will SV-DC24 GC 13 R 336.1331(1)(c) 

of exhaust specify averaging 

3. PM1O 6.44 pph Test protocol will SV-DC24 GC 13 R 336.2803, R 336.2804, 

specify averaging 40 CFR 52.21 (c) and (d) 

t. PM2.5 6.44 pph Test protocol will SV-DC24 SC V.1 R 336.2902(2)(c), 

specify averaging 40 CFR 51 (Appendix S) 

|I. MATERIAL LIM1TS 

NA 

III. PROCESSIOPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-DUMPERHS-S1 unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisorfor review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

The permittee shall not operate EU-DU&1PERHS-S1 unless a MAP as described in Rule 911(2). for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a rna|function, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 daya, if new equipment is installed or upon 

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

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 68 of 101 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, 

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

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-DUMPERHS-S1 unless the associated enclosures, 

water sprays, and fabric filters are installed, maintained and operated in a satisfactory manner. The 

permittee shall equip each fabric filter with broken bag leak detectors, or an alternative monitoring 

method approved in writing by the AQD District Supervisor. Satisfactory manner includes operating 

and maintaining each control device in accordance with an approved MAP for EU-DUMPERHS-S1 

as required in SC 111.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

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

2. The permittee shall not operate EU-DUMPERHS-S1 unless the external conveyor hoods are 

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

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

required in SC 111.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

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

V. TESTING/SAMPLING 

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

The permittee shall verify the PM2.5 emission rates from EU-DUMPERHS-S1 or a representative emission 

unit by testing at owner's expense, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less 

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

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

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

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

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

VI. MONITORING/RECORDKEEPING 

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

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

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

otherwise specified in any monitoring/record keeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak detectors, or alternative 

monitoring measures, as approved by the AQD District Supervisor on each fabric filter of 

EU-DUMPERHS-S1. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

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

3. If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations 

as required in Emission Limit SC 1.1 on a daily basis when EU-DUMPERHS-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual 

opacity from that emission point. Records of the non-certified visible emissions observations, USEPA 

Method 9 observations that are performed, the reason for any visible emissions observed and any corrective 

actions taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c)) 
June 25, 2013 

Page 69 of 101 

DTE Electric Company, Monroe Power Plant (B2816) 

Permit No. 27-13 

VII. REPORTING 

NA 

VIII. STACKJVENT RESTRICTIONS 

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

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground (feet) Requirements 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

IX. OTHER REQUIREMENTS OTHER REQUIREMENTS 

NA 

Footnotes: 

This condition is state only enforceable and was established pursuant to Rule 201(1)8A.~ 
DTE Electric Company, Monroe Power Plant (132816) June 25 2013 

Permit No. 27-13 Page 7Oof1O1 

The following conditions apply to: EU-COALUNLOAD-S1 

DESCRIPTION: This emission unit represents the coal unloading activities from Great Lakes ships and 

includes storage and pilennaintenanoe. Coal handling activity emissions are limited by an enclosures and wet 

dust suppression methods. 

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Coal handling activity emissions are limited by an enclosures and wet 

suppression methods. 

I. EMISSION LIMITS 

Time Period I Testing I Underlying 

Pollutant Limit Operating Equipment Monitoring Applicable 

1. Opacity 10 percent Test protocol The drop points and SC Vl.2 R 336.1301(1)(c) 

will specify transfer points of 

U. MATERIAL LIMITS 

Ill. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-COALUNLOAD-Sl unless a program for continuous fugitive dust control 

for all material handling operations is implemented, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AOD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

mppnnved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

R 336'2804, R 336.2810, 40 CFR 52.21 (c), (d), and N\. Act 451 Section 324'5524) 

2. The permittee shall not operate EU-COALUNLOAD'S1 unless a MAP as described in Rule 911(2),for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a nnelfunction, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

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

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

00 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

appnovod, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R336'1331, Fl336.191o, R 336.1911 ' Q33G.2UO3, 

R 336.2804, R 33G.2O1O,40CFRS2'21(o)' (d). and U)\ 
DTE Electric Company, Monroe Power Plan (B2816) June 25, 2013 

Permit No. 27-13 Page 71 of 101 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-COALUNLOAD-Sl unless the associated enclosures and 

water sprays are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-COALUNL{}AO-S1 as required in SC 111.2. (FK33Q.1901. R 336'1918. R 336.1911, R336.3QO3, 

R33S.28Q4.4OCFR52.31(C) and (d)) 

2. The permittee shall not operate EU-COALUNLOAO-S1 unless the external conveyor hoods or 

enclosures are instaUed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-COALUNLOAD-S1 as required in SC 111.2. (R 336.1901. R336'1910 ' R 336'1911, R33G.20o3. 

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

V. 

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

VI. MONITORING/RECORDKEEPING 

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

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

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

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-C(]ALUNL(]AD-G1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (FK33G'1301(1)(u)) 

VII. REPORTING 

VIII. STACK/VENT RESTRICTIONS 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201 (1)(b). 
DTE Electric Company, Monroe Power Plant (8281G) June 25, 2013 

Permit No. 27-13 Page 72 of 101 

The following conditions apply to: EU-CRUSHERHS-S1 

DESCRIPTION: This emission unit represents coal handling activity in the Crusher House. Coal handling 

activity emissions are limited by an enclosure and baghouse dust collectors. 

Flexible Group ID: FG'ProjeotPC1-4 

POLLUTION CONTROL EQUIPMENT: Transfer house 4 dust collecto 

I. EMISSION LIMITS 

Time Period I Testing I Underlying Applicable Pollutant Limit Operating Equipment Monitoring Requirements 

1 Opacity 5 percent Test protocol will Each individual fabric SC Vl.3 R 336.1301(1 )(c), 

specify averaging filter in R 336.2810, 

time. EU-CRUSHERHS-S1 40 CFR 52.21 (j) 

2. PM 0.004 gr / dscf Test protocol will Each individual fabric GC 13 R 336.1331, R 336.2810, 

of exhaust specify averaging filter in 40 CFR 52.21 (j) 

3. PMIO 0.99 pph Test protocol will SV-DCO5 GC 13 R 336.2803, R 336.2804, 

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

L

specify averaging 40 CFR 51 (Appendix S) 

II. MATERIAL LIMITS 

III. PROCESSIOPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-CRUSHERHS-S1 unless a program for continuous fugitive dust control 

for all material handling operations is imp|emonted, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

mpproved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R|336.1901, R 336.2803, 

R 336'2804. R 336'2810. 40 CFR 52.21 (c), (d), and (j), Act 451 Section 324'5524\ 
DTE Electri Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 73 of 101 

2. The permittee shall not operate EU-CRUSHERHS-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is innp|ennented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a rna|function, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 deyn, if new equipment is installed or upon 

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

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

appnoved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R336.1331 ` R!33G.191O" R 338.1911 ' R33G.2Q03. 

R 336.2804, R 336.2810, 40 CFR 52'21(o).(d),and (j)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-CRUSHERHS-Sl unless the associated enclosures and 

fabric filters are installed, maintained and operated in a satisfactory manner. The permittee shall equip each 

fabric filter with broken bag leak detectnrs, or an alternative monitoring method approved in writing by the 

AQD District Supervisor. Satisfactory manner includes operating and maintaining each oontnol device in 

accordance with an approved MAP for EU-CFlUGHERHS-S1 as required in S{} 111.2. (R 33$.1901, 

R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and U)) 

2. The permittee shall not operate EU-CRUSHERHS-S1 unless the external conveyor hoods or enclosures are 

insta|led, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-CRU8HERHS-G1 as required 

in SC 111.2. (R336.1901, R336'1810, R 336.1911, R336.2803, R336.2804. R|336.2810, 

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

V. 

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

The permittee shall verify the PM2.5 emission rates from EU-CRUSHERHS-S1 or a representative emission 

unit by testing at owner's expanaa, in accordance with Department requirements. The permittee must 

complete the test once every five years for the next ten years of operation after the modification. No less 

than 60 days prior to teat/ng, the permittee shall submit a complete test plan to the AQD Technical 

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

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

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

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

VI. 

Records shall be maintained on file for a period of five years. (R 336-1201(3)) 

1. The permiftee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall keep monitoring records from the broken bag leak dotectuns, or alternative 

monitoring measures, as approved by the AQD District Supervisor on each fabric filter of 

EU-CRUSHERHS-S1. (R 336'1901, R33Q.19i8 ' R 336'1911. R33S'2803, R33G'2O04, R 336'2010, 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 74 of 101 

If the permittee does not install a bag leak detection system per the alternative monitoring requirements 

outlined in SC IV.1, the permittee shall perform and document non-certified visible emissions observations 

as required in Emission Limit SC 1.1 on a daily basis when EU-CRUSHERHS-S1 is operating. If during the 

observation there are any visible emissions detected from an emission point, a USEPA Method 9 certified 

visible emissions observation shall be conducted for a minimum of 15 minutes to determine the actual 

opacity from that emission point. Records of the non-certified visible emissions observations, USEPA 

Method 9 observations that are performed, the reason for any visible emissions observed and any corrective 

actions taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 

40 CFR 52.21 (j)) 

VII. REPORTING 

1. Within 30 days after completion of the installation, construction, reconstruction, relocation, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in writing, of the activity. Completion of the installation, construction, 

reconstruction, relocation, or modification is considered to occur not later than commencement of trial 

operation of EU-CRUSHERHS-S1. (R 336.1201(7)(b)) 

Vlll. STACK/VENT RESTRICTIONS 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted with an asterisk (*) indicating a non-vertical discharge: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground (feet) Requirements inches 

R 336.1901, R 336.2803, 

1. SV-DC05* 30 40 R 336.2804, 

40 CFR 52.21 (c) and (d) 

IX. OTHER REQUIREMENTS 

NA 

Footnotes: 

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25 2013 

Permit No. 27-13 Page 75 of 101 

The following conditions apply to: EU-REFHS&BL-S1 

DESCRIPTION: This emission unit represents coa and sorbent handling activity in the REF Transfer House 

and Refined Coal Plant Building including an 8,500 gallon Mersorb storage tank, a 750 ton S-Sorb solid storage 

si|o, associated conveyors, and any trucking and unloading activities. Sorbent handling activity inside the 

Refined Coal Plant Building includes two pug mills, two day bins, conveying and mixing operations. Coal and 

sorbent handling activity emissions are limited by ano|oaures, baghouse dust collectors, wet dust suppression 

methods, or bin vent filters. 

Flexible Group ID: NA 

POLLUTION CONTROL EQUIPMENT: REF Transfer house dust collector #1 (SV-REFDC01), Refined Coal 

Plant Building Transfer dust collector #2 (SV-REFDCO2), storage silo with a bin vent filter (SV-REFBV), 

enclosures and dust suppressants 

I. EMISSION LIMITS 

Pollutant Limit Operating Equipment Monitoring Re urements 

1. Opacity 5 percent Test protocol Each individual SC VI.2 R 336.1301(1)(c), 

will specify fabric filter and bin 40 CFR 60.254(b)(1) 

averaging time. vent filter in 

2. PM 0.004 gr/ dscf Test protocol Each individual GC 13 R 336.1205, 

of exhaust will specify fabric filter and bin R 336.1331(1)(c), 

gases averaging time. vent filter in 40 CFR 60.254(b)(2) 

3. PM1O 0.21 pph Test protocol Each individual GC 13 R 336.1205, 

will specify fabric filter R 336.2803, R 336.2804, 

averaging time. SV-REFDCO1 and 40 CFR 52.21 (c) and (d) 

I. PM2.5 0.21 pph Test protoàol Each individual GC 13 R 336,1205 

will specify fabric filter 

averaging time. SV-REFDCO1 and 

5. PM1O 0.041 pph Test protocol SV-REFBV GC 13 R 336.1205, 

will specify R 336.2803, R 336.2804, 

3. PM2.5 0.041 pph Test protocol SV-REFBV GC 13 R 336.1205 

will specify 

U. MATERIAL LIMITS 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 76 of 101 

U[ PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-REFHS&BL-S1 unless a program for continuous fugitive dust control for 

all material handling operations is imp|ernenbad, updated as neoeooery, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

apprVved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371. R 336.1372 ' R 336.2803, R 336.2804, 

40 CFR52.21 (c) and (d), Act 451 Section 324.5524) 

2. The permittee shall not operate EU-REFHS&BL-S1 unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is innplemented, updated as naceasary, and kept at the 

facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the 

MAP to the AQD District Supervisor for review and approval. If the.AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

appnoved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336'1331, R 336'1910, Ri336'1911 ' Ri33G'2003 ' 

R 336.2804, 40 CFR 52.21 (c) and (d)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

The permittee shall not operate any portion of EU-REFHS&BL-S1 unless the associated enclooupae, fabric 

fibara, and bin vent filter are inmta|led, maintained and operated in a satisfactory manner. Satisfactory 

manner includes operating and maintaining each control device in accordance with an approved MAP 

for EU-REFHS&BL-S1 as required in SC 111.2. (R336.1910, R336.1911, R336'2803, R336.28$4. 

2. The permittee shall not operate EU-REFHS&BL-S1 unless the external conveyor hoods or enclosures are 

inata|led, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-REFHS&BL-S1 as required in 

SC 111.2. (R 336.1810,R 336.1911, R 336.2803, R 336.2804, 40 CFR 52.21 (c) and (d)) 

V. TESTINGISAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1201 (3)) 

NA 

VI. MONITORINGIRECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336'1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Su 

and make them available by the 30th day of the calendar nlonth, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1301) 
DTE Electric Company, Monroe Power Plant (62816) June 25, 2013 

Permit No. 27-13 Page 77 of 101 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-REFHS&BL-Sl is operating. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that 

emission point. Records of the non-certified visible emissions observations, USEPA Method 9 observations 

that are performed, the reason for any visible emissions observed and any corrective actions taken shall be 

kept on file and in a format acceptable to the AQD. (R 336'1301(1)(o),40 CFR 60.254) 

VII. REPORTING 

VIII STACK/VENT RESTRICTIONS 

The exhaust gase from the stacks liste in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted with an asterisk (*) indicating a non-vertical discharge: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground (feet) Requirements 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

R 336.1901, R 336.2803, 

R 336.2804, 

IX. OTHER REQUIREMENTS 

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and Y, as they apply to EU-REFHS&BL-S1. 

(40 CFR Part 60 Subparts A and Y) 

Footnotes: 

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
June 25 2013 

Page 78 of 101 

DTE Electric Conlpany, Monroe Power Plant (B2816) 

Permit No. 27-13 

The following conditions apply to: EU-PETCOKE-S1 

DESCRIPTION: This emission unit represent petroleum coke handling activity, including roadway traffic and 

pile maintenance. Emissions are limited by partial enclosures, including a portable wind scraen, and wet dust 

suppression. 

Flexible Group ID: F8-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: 

suppressants. 

Partial enolonureo, including a portable wind eoreen, and dust 

L EMISSION LIMITS 

Time Period! Testing! Underlying Applicable Pollutant Limit Operating Equipment Monitoring 

1. Opacity 10 percent Test protocol The drop points and SCVI.2 R 336.1301(1)(c), 

will specify transfer points of R 336.2810, 

II. MATERIAL LIMITS 

Ill. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate 1 unless a program for continuous fugitive dust control for 

all material handling operations is hnplemanbsd, updated as nmcessory, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

appnovod, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

R 33$.2804. R 336.2810, 40 CFR 52.21 (c), (d), and (j). Act 451 Section 324'5524) 

The permittee shall not operate EU-PETCOKE-Sl unless a MAP as described in Rule 911(2), for operation 

of the process and emission control equipment is implemenbed, updated as necessary, and kept at the 

facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a mo|function, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the 

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

00 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operaUonol changes to achieve 

compliance with all applicable emission limits. (FK336.1331. Fk33G'1910, Fl336.1911, R 336'2803 ` 

R 336.2Q04,Ri336.2O1y,40CF8LS2'21(o),(d), and (j)) 

3. The permittee shall not operate the wheeled traffic portion ofEU-PBCOKE-S1 for more than 16 hours per 
~ 

DTE Electric Company, Monroe Power Plant (132816) 

Permit No. 27-13 

June 25, 2013 

Page 79 of 101 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The permittee shall not operate any portion of EU-PETCOKE-S1 unless the assoc i ated enclosures and 

water sprays are insba|ed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for EU-PETCOKE-S1 

as required in SC 111.2. (R336.1901, R336'1910, R|336.1911. R336'2803 ' Fl336.2804, R336.2010. 

The permittee shall not operate EU-PETCOKE-S1 unless the enclosures are inata{ked, maintained and 

operated in a satisfactory manner. Satisfactory manner includes operating and maintaining each control 

device in accordance with an approved MAP forEU-PETC(]KE-G1 as required in SC 111.2. /R336.1981 ` 

R 336.1910, R 336.1911, R 336.2803, R 336'2804, R 336.2810, 40 CFR 52.21 (c), (d) and 0)) 

3. The permittee shall not operate the haul truck activities associated with EU-pETC(]KE-31 unless the wheel 

wash system is installed, maintained, and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP forEU-PETCOKE-81 

as required in SC 111.2. (R336.1901. R336.1910. R 336.1911, R336.2803, R336'2804, R336.2010, 

40 CFR 52.21 (c), (d) and A)) 

V. 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

NA 

VI. MONITORINGIRECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar nznth, for the previ ous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-PETCC)KE-S1 is operat i ng. If during the observation there 

are any visible emissions detected from an emission point, a USEPA Method 9 certified visible emissions 

observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from that 

emission point. Records of the non-certified visible emissions oboervationa. USEPA Method 9 observations 

that are performed, the reason for any visible emissions observed and any corrective actions taken shall be 

kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810. 40 CFR 52.21 (j)) 

3. The permittee shall keep, in a satisfactory nnanner, daily records of the hours of operation of the wheeled 

traffic portion ofEU-PETCUKE-81. (R 336'1205(1)(a). R 336.2803, R 336'2804, 40 CFR 52.21 <c\ and (d)) 

VII. REPORTING 

Within 30 days after completion of the instoUabon, construction, reoonetnucUon, nalonabon, or modification 

authorized by this Permit to Install, the permittee or the authorized agent pursuant to Rule 204, shall notify 

the AQD District Supervisor, in vvrting, of the activity. Completion of the inataUaUon, nonstnuction, 

naconotruoUon, na|ucation, or modification is considered to occur not later than commencement of trial 

operation of EU-PETCOKE-Sl. (R33G.12O1(7)(b)) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 80 of 101 

VIII. STACKNENT RESTRICTIONS 

IX. OTHER REQUIREMENTS 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201 (1 )(b). 
DTE Electric Company, Monroe Power Plant (B2818) June 25, 2013 

Permit No. 27-13 Page 81 of 101 

The following conditions apply to: EU-LIMESTONE-SI 

DESCRIPTION: This emission unit represents limestone handling activities and includes the ship unloading 

proneaa, storage and pile mainbsnonoa, and reclaim activities — including any trucking activities, and the Prep 

building. Limestone handling activity emissions are limited by enclosures, wet dust suppression methods, or bin 

vent filters. 

Flexible Group ID: FG-ProjectPC 1-4 

POLLUTION CONTROL EQUIPMENT: Three silos with a bin vent filter (SV-26A).enclosures and dust 

suppressants. Limestone handling activity emissions are limited by enclosures, wet suppression methods, or 

bin vent filters. 

L EMISSION LIMITS 

Time Period I Testing I Underlying Applicable 

Pollutant Limit Operating Equipment Monitoring Re uirements 

1. Opacity 10 percent Test protocol Any exterior drop SC VI.2 R 336.1301(1 )(c), 

will specify points and transfer R 336.2810, 

averaging points of 40 CFR 52.21 (j), 

'. Opacity 5 percent Test protocol The bin vent filter in SC VI.3 R 336.I301(l)(c), 

will specify EU-LIMESTONE-SI R 336.2810, 

averaging (SV-26A) 40 CFR 52.21 (j), 

3. PM 0.004 gr/ dscf Test protocol SV-26A GC 13 R 336.1331, R 336.2810, 

of exhaust will specify 40 CFR 52.21 (j) 

gases averaging 

will specify R 336.2810, 

5. PM2.5 0.0046 pph Test protocol SV-26A CC 13 R 336.2902(2)(c), 

will specify 40 CFR 51 (Appendix S) 

averaging 

!L MATERIAL LIMITS 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 82 of 101 

UL PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-LIMESTONE-SI unless a program for continuous fugitive dust control 

for all material handling operations is hnplemenbad, updated as necessary, and kept at the facility. If at any 

time the fugitive dust control program fails to address or inadequately addresses an event, the permittee 

shall amend the fugitive dust control program within 45 days after such an event occurs. The permittee 

shall also amend the fugitive dust control program within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program and 

any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust contro program shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j), Act 4G1 Section 324'5524) 

2. The permittee shall not operate EU-LIMESTONE-S1 unless a MAP as described in Rule 911(2) ` for 

operation of the process and emission control equipment is innp|ernenbad, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a nne|function, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the 

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

opproved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (Fk336'1331, RL336'1910 ' R!336'1911. R336'2803, 

R 336.2804, R 336'2810,4BCFFk52'21(c),(d), and N)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The permittee shall not operate any portion of EU-LIMESTONE-Sl unless the associated bin vent filters and 

water sprays, are installed, maintained and operated in a satisfactory manner. Satisfactory manner includes 

operating and maintaining each control device in accordance with an approved MAP for 

EU-LIMESTONE-S1 as required in SC 111.2. (R 336.1901, R 336'1910, R|336'1911. R 336'2803, 

R 336.2804, R 33G.20t0 ' 4OCFRi52'21(o).(d),and U)) 

2. The permittee shall not operate EU-LIMESTONE-Sl unless the external conveyor hoods are installed, 

maintained and operated in a satisfactory manner. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-LIMESTONE-Sl as required in SC 111.2. 

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFRS2.21 (c), (d) and #)) 

V. 

Records shall be maintained on file for a period of five years. (R 336.1201 (3)) 

NA 

VI. 

Records shall be maintained on file for a period of five years. (R 336'1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205.R 336'1901) 
= 

DTE Electric Company, Monroe Power Plant (132816) Juna25.2013 

Permit No. 27-13 Page 83 of 101 

The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-LIMESTONE-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions obsen/otions. USEPA Method 9 

observations that are perfonned, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336'1301(1)(n), R 336.2810, 

40CFR52'21O).40CFR60'676)) 

The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.2 on a daily basis when EU-LIMESTONE'81 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are perfonnad, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336'1301(1)(c), R 336.2810, 

40CF052'21(j),40CFR60'676) 

VII. REPORTING 

VIII. STACKNENT RESTRICTIONS 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID DiameterlDimensions Above Ground 

R 336.1901, R 336.2803, 

i.SV-26A 12 145 R336.2804, 

IX. OTHER REQUIREMENTS 

1. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 80 Subparts A and 000, as they apply to EU-LIMESTONE_S1. 

(40 CFR Part 60 Subparts A and 000) 

Footnotes: 

1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 84 of 101 

The following conditions apply to: EU-GYPSUMHAND-S1 

DESCRIPTION : This emission unit represents gypsum handling activity in the gypsum dewatering building and 

the gypsum storage and loading building. Gypsum handling activity emissions are limited by a building 

enclosure. 

Flexible Group ID: FG-ProjectPC1-4 

POLLUTION CONTROL EQUIPMENT: Loading operations take place in a building. 

1. EMISSION LIMITS 

Time Period I Testing I Underlying Applicable Y g pp Pollutant Limit Operating Equipment Monitoring Requirements Scenario Method 

1. Opacity 7 percent Test protocol will The gypsum storage SC VI.2 R 336.1301(1)(c), 

specify and handling building R 336.2810, 

averaging time. portion of 40 CFR 52.21 (j), 

EU-GYPSUMHAND-Si 40 CFR 60.672(e) 

11. MATERIAL LIMITS 

III. PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU-GYPSUMHAND-S1 unless a program for continuous fugitive dust 

control for all material handling operations is implemented, updated as necessary, and kept at the facility. If 

at any time the fugitive dust control program fails to address or inadequately addresses an event, the 

permittee shall amend the fugitive dust control program within 45 days after such an event occurs. The 

permittee shall also amend the fugitive dust control program within 45 days, if new equipment is installed or 

upon request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program 

and any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1371, R 336.1372, R 336.1901, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j), Act 451 Section 324.5524) 

2. The permittee shall not operate EU-GYPSUMHAND-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the 

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j)) 
DTE Electric Company, Monroe Power Plant (B2818) June 25, 2013 

Permit No. 27-13 Page 85 of 101 

3. The permittee shall not operate the haul truck activities associated with EU-GYPSUMHAND-S1 for more 

than 16 hours per calendar day. (R 336'1305(1)(a),R336'2803.R336'2804.40CFR 52.21 (c) and (d)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The permittee shall not operate EU-GYP8UMHAND-S1 unless the associated enclosures are inata|led, 

maintained and operated in a satisfactory manner. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-GYPSUMHAND-Sl as required in SC 111.2. 

(R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336L2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j)) 

2. The permittee shall not operate the haul truck activities associated with EU-GYPSUKAHANO-81 unless the 

wheel wash system is inabaUed, nooinbained, and operated in a satisfactory manner. Satisfactory manner 

includes operating and maintaining each control device in accordance with an approved MAP for 

EU-GYPSUK8HANO-G1 as required in SC 111.2. (R336.1901, R336'1$10, R 336.1911, R336-2803, 

R 336.2804, R 336.2810.40CFR 52.21 (c), (d) and (j)) 

V. 

Records shall be maintained on file for a period of five years. (R 336.1 201(3)) 

VI. 

Records shall be maintained on file for a period of five years. (R 336.1 201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar nnonth, for the previous calendar month, unless 

otherwise specified in any mon itoring/record keeping special condition. (R 336.1205, R 336'1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-GYPSUK8HANO-G1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions oboervaUona. USEPA Method 9 

observations that are porfonmed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(o), R 33$'2810, 

40 CFRS2.21(j)' 4UCFRGD'67G) 

3. The permittee shall keep, in a satisfactory manner, daily records of the hours of operation for the haul truck 

activities associated with EU-GYPGUK8HANO-S1. (R 336'1205(1)(a), R 336.2803, R 336.2804, 

40 CFR 52.21 (c) and (d)) 

VII. REPORTING 

VIII. STACKIVENT RESTRICTIONS 

NA 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 86 of 101 

X. OTHER REQUIREMENTS 

1 The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary 

Sources as specified in 40 CFR Part 60 Subparts A and 000. as they apply to EU-GYP8UyWHAND-81. 

(40 CFR Part 60 Subparts A and 000) 

Footnotes: 

1This condition is state only enforceable and was established pursuant to Rule 201 (1)(b). 
DTE Electric Company, Monroe Power Plan (B2816) June 25, 2013 

Permit No. 27-13 Page 87 of 101 

The following conditions apply to: EU-HYDRATEDLIME-S1 

DESCRIPTION: Storage and handling of hydrated lime. Hydrated lime is delivered via truck to facility and is 

stored in a silo. 

Flexible Group ID: FG-ProjectPCl-4 

POLLUTION CONTROL EQUIPMENT: Bin vent filters (SV-26B), enclosures and dust suppressant . 

I. EMISSION LIMITS 

Time Period I Testing I Underlying Applicable Pollutant Limit Operating Equipment Monitoring 

1. Opacity 10 percent Test protocol will Any exterior drop points SC VI.2 R 336.1301(1)(c), 

specify averaging and transfer points of R 336.2810, 

2. Opacity 5 percent Test protocol will The bin vent filter in SC Vl.3 R 336.1301(1)(c), 

specify averaging EU-HYDRATEDLI ME-Si R 336.2810, 

3. PM 0.004 gr/ Test protocol will SV-26B GC 13 R 336.1331, R 336.2810, 

dscf of specify averaging 40 CFR 52.21 ) 

exhaust time. 

specify averaging R 336.2810, 

5. PM2.5 0.045 pph Test protocol will SV-26B GC 13 R 336.2902(2)(c), 

specify averaging 40 CFR 51 (Appendix 5) 

|i MATERIAL LIMITS 

UL PROCESS/OPERATIONAL RESTRICTIONS 

The permittee shall not operate EU'HyDRAFEDL|yWE-S1 unless a program for continuous fugitive dust 

control for all materia handling operations is implemented, updated as necessary, and kept at the facility. If 

at any time the fugitive dust control program fails to address or inadequately addresses an ev8nt, the 

permittee shall amend the fugitive dust control program within 45 days after such an event occurs. The 

permittee shall also amend the fugitive dust control program within 45 doye, if new equipment is installed or 

upon request from the AQD District Supervisor. The permittee shall submit the fugitive dust control program 

and any amendments to the fugitive dust control program to the AQD District Supervisor for review and 

approval. If the AQD does not notify the permittee within 90 days of submittal, the fugitive dust control 

program or amended fugitive dust control program shall be considered approved. Until an amended plan is 

appromad, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 3361371, R 336'1372, R 336.1901, R 336.2803, 

R 33G.2D04,R33$'3810.4OCFRS2'21(o),(d), and (j), Act 451 Section 324'S524\ 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 88 of 101 

2. The permittee shall not operate EU-HYDRATEDLIME-S1 unless a MAP as described in Rule 911(2), for 

operation of the process and emission control equipment is implemented, updated as necessary, and kept 

at the facility. If at any time the MAP fails to address or inadequately addresses an event that meets the 

characteristics of a malfunction, the permittee shall amend the MAP within 45 days after such an event 

occurs. The permittee shall also amend the MAP within 45 days, if new equipment is installed or upon 

request from the AQD District Supervisor. The permittee shall submit the MAP and any amendments to the 

MAP to the AQD District Supervisor for review and approval. If the AQD does not notify the permittee within 

90 days of submittal, the MAP or amended MAP shall be considered approved. Until an amended plan is 

approved, the permittee shall implement corrective procedures or operational changes to achieve 

compliance with all applicable emission limits. (R 336.1331, R 336.1910, R 336.1911, R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d), and (j)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The permittee shall not operate any portion of EU-HYDRATEDLIME-S1 unless the bin vent filters are 

installed, maintained and operated in a satisfactory manner. Satisfactory manner includes operating and 

maintaining each control device in accordance with an approved MAP for EU-HYDRATEDLIME-S1 as 

required in SC 111.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 

40 CFR 52.21 (c), (d), and (j)) 

2. The permittee shall not operate EU-HYDRATEDLIME-S1 unless the associated enclosures are installed, 

maintained and operated in a satisfactory manner. Satisfactory manner includes operating and maintaining 

each control device in accordance with an approved MAP for EU-HYDRATEDLIME-S1 as required in 

SC 111.2. (R 336.1901, R 336.1910, R 336.1911, R 336.2803, R 336.2804, R 336.2810, 40 CFR 52.21 (c), 

(d) and (j)) 

V. TESTING/SAMPLING 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

NA 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.1901) 

2. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.1 on a daily basis when EU-HYDRATEDLIME-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2810, 

40 CFR 52.21 (j)) 

3. The permittee shall perform and document non-certified visible emissions observations as required in 

Emission Limit SC 1.2 on a daily basis when EU-HYDRATEDLIME-S1 is operating. If during the observation 

there are any visible emissions detected from an emission point, a USEPA Method 9 certified visible 

emissions observation shall be conducted for a minimum of 15 minutes to determine the actual opacity from 

that emission point. Records of the non-certified visible emissions observations, USEPA Method 9 

observations that are performed, the reason for any visible emissions observed and any corrective actions 

taken shall be kept on file and in a format acceptable to the AQD. (R 336.1301(1)(c), R 336.2803, 

R 336.2804, R 336.2810, 40 CFR 52.21 (c), (d) and (j)) 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 89 of 101 

VII. REPORTING 

VIII. STACKNENT RESTRICTIONS 

The exhaust gasesfnomU1aabacksUstedinthetabobelovxsha|bed unobstructed vertically upwards 

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack and Vent ID Diameter/Dimensions Above Ground 

V-26B 18 145 R336.2804, 

IX. OTHER REQUIREMENTS 

NA 

Footnotes: 

'This is state only enforceable and was established pursuant to Rule 201 (1)(b). _ ` 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 90 of 101 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions. 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FG-ProjectPCl-4 The project is to increase the capacity to use EU-UNIT1-S1, 

subbituminous coal and add petroleum coke to provide EU-UNIT2-S1, 

additional fuels for Units 1, 2, 3, and 4; installation of EU-UNIT3-Si, 

four (4) wet FGD quench pumps; modifications to the EU-UNIT4-S1, 

fuel handling systems; the installation of new material EU-WFGD-QP1, 

handling systems for limestone and gypsum; and the EU-WFGD-QP2, 

installation of a new fuel handling system for petroleum EU-WFGD-QP3, 

coke. This results in a minor nonattainment source EU-WFGD-QP4, 

modification by use of the actual-to-projected-actual EU-CASCADES-Si, 

applicability test. EU-TRANSFERHS-Si, 

EU-COALUN LOAD, 

FGAUXBOILERS-S1 North and South Auxiliary Boilers EU-NORTHAUX-Si, 

FGPEAKERS-S2 Five diesel fuel-fired generator peaking units that are EU-DIESELI I-i-S2, 

limited use stationary reciprocating internal combustion EU-DIESEL1 I -2-S2, 

engines. EU-DIESEL11-3-S2, 

EU-DIESEL1 1-4-S2, 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 91 of 101 

The following conditions apply to: FG-ProjectPCl-4 

DESCRIPTION: The project is to increase t he capacity to use subbiturninous coal and add petroleum coke to 

provide additional fuels for Units 1, 2, 3, and 4; installation of four (4) wet FGD quench pumps: modifications to 

the fuel handlinsystems: the installation of new material handling systems for limestone and gypsum: and the 

installation of a new fuel handling system for petroleum coke. This results in a minor nonattainment source 

modification by use of the actual-to-pr jected-actual applicability test. 

Emission Units: EU-UN[T1-S1. EU-UN[T2-51, D-QP1, 

EU-WFGO-QP2, EU-VVFGD-QP3, EU-NFGD^QP4, EU'CASCADES'S1, EU-|HANSFEMMb-Sl. 

EU-DUMPERHS-S1, EU'COALUNLOAD-G1, EU-CRUSHERHG-S1, EU-PETC[)KE'81, EU-L|[NE8TQNE-S1, 

EU-GYpSU[NHANO-G1 ' and EU-HYDRATEL|N|E-G1 

POLLUTION CONTROL EQUIPMENT: NA 

I.EMISSION LIMITS 

NA 

U' MATERIAL LIMITS 

NA ~ ~` 

;IL PROCESS/OPERATIONAL RESTRICTIONS 

NA 

IV[ ^ ' 

NA 

V - ' 

Records shall be maintained on file for a period of five years (R 336 1201(3)) ' ^` 

NA 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptabletoMheAQDQisthctSupenioor 

and make them available by the 30th day of the calendar month, for the previous unless 

otherwise specified in any nnonitorinQ/nacordhaoping special condition. (R 336.1205, R 336.1901, 

R 336.2902(2)(c), 40 CFR 51 (Appendix 5)) 

2. The permittee shall calculate and keep records of pK42.5 and SO 2emissions from EU-UN|T1-81. 

EU-UN|T2-81, EU-UN|T3-S1, EU-UN|T4-G1, EU4NFGD-C)P1, EU-WFGD-QP2, EU-WFGD-QP3, and 

EU-WFGD-QP4 in tons per calendar year. The recordkeeping period shall begin on the first day of the 

month during which EU-UN[T3-81 and EU-UN!T4-81 commences operation (after the modification) and 

continues for consecutive calendar months. The calculations and records shall be kept in the format 

described in Appendix C. or an alternative format acceptable to the AQD Permit Section Supervisor. The 

requirement to calculate and keep records shall end ten years after EU-UN|T1-G1 ' EU-UN|T2-S1. 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 92 of 101 

EU-UNIT3-S1, EU-UNIT4-S1, EU-WFGD-QP1, EU-WFGD-QP2, EU-WFGD-QP3, and EU-WFGD-QP4 

completes the modification as approved by the AQD Permit Section Supervisor. The permittee shall keep 

all records on file and make them available to the Department upon request. (R 336.2902(2)(c), 

40 CFR 51 (Appendix S)) 

The permittee shall calculate and keep records of PM2.5 emissions from EU-CASCADES-S1, 

EU-TRANSFERHS-S1, EU-DUMPERHS-S1, EU-COALUNLOAD-S1, EU-CRUSHERHS-S1, 

EU-PETCOKE-Sl, EU-LIMESTONE-S1, EU-GYPSUMHAND-S1, and EU-HYDRATELIME-S1 in tons per 

calendar year. The recordkeeping period shall begin on the first day of the month during which 

EU-CASCADES-S1, EU-TRANSFERHS-S1, EU-DUMPERHS-S1, EU-COALUNLOAD-Sl, 

EU-CRUSHERHS-S1, EU-PETCOKE-S1, EU-LIMESTONE-Sl, EU-GYPSUMHAND-S1, and 

EU-HYDRATELIME-S1 commences operation (after the modification) and continues for consecutive 

calendar months. The calculations and records shall be kept in the format described in Appendix C, or an 

alternative format acceptable to the AQD Permit Section Supervisor. The requirement to calculate and keep 

records shall end ten years after EU-CASCADES-S1, EU-TRANSFERHS-S1, EU-DUMPERHS-S1, 

EU-COALUNLOAD-S1, EU-CRUSHERHS-SI, EU-PETCOKE-S1, EU-LIMESTONE-Sl, 

EU-GYPSUMHAND-S1, and EU-HYDRATELIME-S1 completes the modification/installation as approved by 

the AQD Permit Section Supervisor. The permittee shall keep all records on file and make them available to 

the Department upon request. (R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 

VII. REPORTING 

1. The permittee shall submit records of PM2.5 and SO 2 emissions from FG-ProjectPC1-4 in tons per calendar 

year to both the AQD Permit Section Supervisor and the AQD District Supervisor within 60 days following 

the end of each calendar year identified in FG-ProjectPC1-4 SC VI.2 and SC VI.3. In addition, the records 

shall identify the following: 

a. Exceedences of the yearly actual emission of PM2.5 and SO 2 above the baseline actual emissions 

(BAE) by a significant amount, and 

b. Identify if the year's actual emissions differ from the pre-construction projection. The pre-construction 

projection is the sum of the projected actual emissions from each existing emission unit and the 

potential emissions from each new emission unit included in the Hybrid Applicability Test used for 

FG-ProjectPC1-4. 

The report shall contain the name, address, and telephone number of the facility (major stationary source); 

the annual emissions as calculated pursuant to FG-ProjectPC1-4, SC VI.2 and SC VI.3, and any other 

information the owner or operator wishes to include (i.e., an explanation why emissions differ from the 

pre-construction projection). (R 336.2902(2)(c), 40 CFR 51 (Appendix S)) 

VIII. STACKNENT RESTRICTIONS 

IX. OTHER REQUIREMENTS 

zl 

Footnotes: 

es This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
IDTE Electric Company, Monroe PowerPlant (B2816) June 25, 2013 

Permit No. 27-13 Page 93 of 101 

The following conditions apply to: FGAUXBOILERS-S1 

DESCRIPTION: North and south auxiliary boilers. 

Emission Unit: EU-NDRTHAUX-S1,EU-SOUTHAUX-S1 

POLLUTION CONTROL EQUIPMENT: NA 

V. EMISSION LIMITS 

Pollutant Limit 

Time Period! 

Operating 

- 

Equipment 

Monitoring! 

Testing Underlying Applicable 

Re uirements 

1. NOx 33.3 pph per boiler Test protocol will EU-NORTHAUX-S1, GC 13 R 336.2804, 

specify averaging EU-SOUTHAUX-S1 40 CFR 52.21(d) 

2. SO2 0.33 pph per boiler Test protocol will EU-NORTHAUX-S1, GC 13 R 336.1401, 

specify averaging EU-SOUTHAUX-S1 R 336.2803, 

time. R 336.2804, 

IL MATERIAL LIMITS 

1. The permittee shall only burn No. 2 fuel oil with a maximum sulfur content of 15 ppm in 

FBAUXBO|LERS-81. (R 336.1401, R 336.2803, R 336.2804,40 CFR 52.21(c) and (d)) 

Ill. PROCESS/OPERATIONAL RESTRICTIONS 

1. The permittee shall not burn any fuel in the two auxiliary boilers other than No. 2 fuel oil without prior 

notification to and approval by the AQD. 2 (R 336.1201(3)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. NA 

V. 

Records shall be maintained on file for a period of five years. (R 336.1201 (3)) 

VI. 

Records shall be maintained on file for a period of five years. (R 33G.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any nnonitohng/naoundkneping special condition. (R 336.1401, G33G.2Q03, 

R 336.2804, 40 CFR 52.21(c) and (d)) 

2. The permittee shall record the monthly fuel oil usage rates in gallons. (R 336'1401" R 336.2803, 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 age 94 of 101 

3. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of 

delivery, analytical results from laboratory testing, or any other records adequate to demonstrate compliance 

with the percent sulfur limit in fuel oil. (R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d)) 

4. The permittee shall monitor and record in a satisfactory manner, the monthly hours of operation for each 

auxiliary boiler in FGAUXBO|LERS-G1. The permittee shall keep all records on file fore period of at least 

five years and make them available to the Department upon request. (R 336'2803. R 336.2804, 

40 CFR 52.21(c) and (d)) 

VII. REPORTING 

VII!. STACKNENT RESTRICTIONS 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Stack & Vent ID DimensiOns Above Ground 

1. SVOI5-003 108 231 R 336.2803, R 336.2804, 

IX. OTHER REQUIREMENTS 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B281G) June 25, 2013 

Permit No. 27-13 Page 95 of 101 

The following conditions apply to: FGPEAKERS-S2 

^^ 

`^ 

DESCRIPTION: Five diesel fuel-fired generator peaking units that are limited use stationary reciprocating 

internal combustion engines. 

Emission Units: EU-DIEGEL11'1-82. EU-D|ESEL11-2'82. EU-D|ESEL1i-3-S2. EU-O|ESEL11-4-S2. 

EU-D|ESEL11-5-S2 

I. EMISSION LIMITS 

Pollutant Limit Time Period! 

Operating Scenario Equipment 

Monitoring! 

Testing 

Method 

- Underlying Applicable 

Requirements 

1. NOx 90.2 pph per Test protocol EU-DIESELI1-1-S2, GC 13 R 336.2804, 

unit will specify averaging EU-DIESEL11-2-S2, 40 CFR 52.21(d) 

time. EU-DIESELI 1-3-S2, 

2. SO2 0.043 pph per Test protocol EU-DIESEL11-1-S2, GC 13 R 336.1401, 

unit will specify averaging EU-DIESEL1 1-2-S2, R 336.2803, 

time. EU-DIESEL1I-3-S2, R 336.2804, 

YX' MATERIAL LIM1TS 

1. The permittee shall only burn diesel fuel with a maximum sulfur content of 15 ppm in FGPEAKERS-S2. 

(R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d)) 

IQ' PROCESS/OPERATIONAL RESTRICTIONS 

1. The ittee shall not operate each diesel generator in FGPEAKERS-S2 for more than 89.9 hours per 

12-month rolling time period as determined at the and of each calendar month. (R 336.2804, 

40 CFR 52.21(d), 40 CFR 63.6600(c)) 

IV. DESIGN/EQUIPMENT PARAMETERS 

1. The permittee shall equip and maintain each diesel generator in FGPEAKERS-S2 with a non-resettable 

hour meter to track the number of minutes and hours the engine operates. (R 336.2804, 40 CFR 52.21(d), 

40 CFR 63.6600(c)) 

V. 

Records shall be maintained on file for a period of 5 years. (R 336.1201(3)) 

NA 
DTE Electric Company, Monroe Power Plant (82816) June 25, 2013 

Permit No. 27-13 Page 96 of 101 

VI. MONITORING/RECORDKEEPING 

Records shall be maintained on file for a period of 5 years. (R 336.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor 

and make them available by the 30th day of the calendar month, for the previous calendar month, unless 

otherwise specified in any monitoring/recordkeeping special condition. (R 336.1401, R 336.2803, 

R 336.2804, 40 CFR 52.21(c) and (d)) 

2. The permittee shall record the monthly fuel usage rates in gallons. (R 336.1401, R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d)) 

3. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of 

delivery, analytical results from laboratory testing, or any other records adequate to demonstrate compliance 

with the percent sulfur limit in fuel oil. (R 336.1401, R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d)) 

4. The permittee shall monitor and record in a satisfactory manner, the hours of operation for each unit in 

FGPEAKERS-S2. The record shall include the time and duration of operation. The permittee shall keep all 

records on file for a period of at least five years and make them available to the Department upon request. 

(R 336.2804, 40 CFR 52.21(d), 40 CFR 63.6600(c)) 

VII. REPORTING 

m 

VIII. STACK/VENT RESTRICTIONS 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted: 

Maximum Exhaust Minimum Height Underlying Applicable Y g Stack & Vent ID Dimensions Above Ground pp Requirements inches (feet 

1. SV-DIESEL11-1 32 20 R 336.2803, R 336.2804, 

20 

40 CFR 52.2 1 c and (d) 

2. SV-DIESELII-2 32 R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d) 

3. SV-DIESEL11-3 32 20 R 336.2803, R 336.2804, 

40 CF R 52.21(c) and (d) 

4. SV-DIESEL11-4 32 20 R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d) 

5. SV-DIESEL1 1-5 32 20 R 336.2803, R 336.2804, 

40 CFR 52.21(c) and (d) 

IX. OTHER REQUIREMENTS 

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous 

Air Pollutants, as specified in 40 CFR, Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating 

Internal Combustion Engines, upon start-up. (40 CFR 63.6595, 40 CFR Part 63, Subparts A and 7777) 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 97 of 101 

The following conditions apply to: FGUNITSI&2TEMP 

DESCRIPTION: Two coal-fired cell burner boilers nominally rated at 1,570 megawatts total (net). 

Emission Units: EU-UNIT1-S1, EU-UNIT2-S1 

POLLUTION CONTROL EQUIPMENT: Low-NOx bumes, dry wire electrosta c precipitator UEGFq, selective 

catalytic reduction (SCR) — except Unit 2, SO 3flue gas conditioning system, and ammonia flue gas conditioning 

system 

L EMISSION LIMITS 

Pollutant Limit Time Period! Operating Equipment 

Monitoring! Underlying Applicable 

Scenario Method Requirements 

ton/month TEMP SCVI.4 calendar month 

Ii' MATERIAL LIMITS 

NA 

I0' PROCESS/OPERATIONAL RESTRICTIONS 

NA 

IV. DESIGNIEQUIPMENT PARAMETERS 

NA 

V. 

Records shall be maintained on file for a period of five years. (R 336.1201(3) ) 

VI' 

Records shall be maintained on file for a period of five years. (R 336.1201(3)) 

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Su pervisor 

and make them available by the 30th day of the calendar nnonth, for the prev ious calendar mnnth, unless 

otherwise — eo~edinanyn~onitohng~noordkeepinQnpenio|oondiUon (~~ 336^2004,4QCF~~S2'21(d0 

,.~ 

2. The permittee shall insto||, ca|ibnate, maintain and operate in a satisfactory manner a continuous opacity 

monitoring system (COMS) to monitor and record the visible emissions from FGUNITS1&2TEMP on a 

continuous basis. The permittee shall install and operate the COM system to meet the tirU8|inao, 

requirements and reporting detailed in Appendix A. (R336'1301, R 336.2101, R 336'2159, 

40 CFR Part 60, 40 CFR Part 75) 
DTE Electric Company, Monroe Power Plant (B2816) June 25, 2013 

Permit No. 27-13 Page 98 of 101 

3. The permittee shall install, calibrata, maintain and operate in a satisfactory manner device(s) to monitor and 

record the NOx emissions, and oxygen or carbon dioxide (0 2or CO2) content of the exhaust gas from 

FGUNITS1&2TEMP on a continuous basis. The permittee shall install and operate each CEM to meet the 

timo|ines, requirements and reporting detailed in Appendix B attached. (R 336'2803. R 336'2804 ' 

40 CFR52.21(c) and (d),4DCFRPart G0,40CFR Part 7S) 

4. The permittee shall keop, in a satisfactory manner, monthly and 12-month rolling average NOx emission 

rate records for FGUNITSI&2TEMP, as described in emission limits SC 1.1. (R 336.2803, R336.2OU4' 

40 CFR 52.21(c) and (d)) 

VII. REPORTING 

1. For the COMS and NOx CEMS, the permittee shall submit to the District Supervisor and the Technical 

Programs Unit Supervisor, AQD, and to the Chief of the Air Compliance Branch, USEPA, within 30 days of 

the end of the calendar quarter, a written report for each calendar quarter which shall include all of the 

following information: 

a. Excess emissions and the nature and cause of excess emissions, if known, as follows: 

i For opacity measunaments, the report shall consist of the megnitude, in actual percent opacity, of 

all 6-minute averages of opacity more than the applicable opacity standard for each hour of 

operation (all allowable exceptions are to be deducted prior to determining the excess averages of 

opacity). Average values shall be obtained by integration over the averaging period or by 

arithmetically averaging a minimum of 24 equally spaoed, instantaneous opacity measurements 

per 6 minutes. 

For gaseous measunarnents, the report shall consist of emission nvenagea, in the units of the 

applicable etondard, for each averaging period during which the applicable standard was 

exceeded. 

b. The date and time identifying each period during which the continuous monitoring system was 

inoperative, except for zero and span checks, and the nature of repairs or adjustments made. 

c. If the monitoring system has not been inoperative, napaired, or adjuotad, and if no excess emissions 

occurred, a statement attesting to this fact. 

2. The permittee shall report NOx emissions, volumetric flow, and opacity data in accordance with 

40 CFR Part 75 (Continuous Emission Monitoring). (40 CFR Part 75) 

VIII. STACK/VENT RESTRICTIONS 

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 

to the ambient air unless otherwise noted: 

Stack & Vent ID Maximum Exhaust Minimum Height Above Underlying Applicable 

I______________________ 

Dimensions (inches) Ground (feet) Requirements 

IX. OTHER REQUIREMENTS 
+° 

DTE Electric Company, Monroe Power Plant (B281O) June 25, 2013 

Permit No. 27-13 Page 99 of 101 

APPENDIX A 

Continuous Opacity Monitoring System (COMS) Requirements 

1. The permittee shall submit two copies of a Monitoring Plan to the AQD, for review and approval. The 

Monitoring Plan shall include drawings or s ons showing proposed locations and descriptions of the 

required COMS. 

2. The permittee shall submit two copies of a complete test plan for the COMS to the AQD for approval. 

3. Within 30 calendar days after test plan opprova|, the permittee shall complete the installation and testing of 

the COMS. 

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final report 

demonstrating the COMS complies with the requirements of Performance Specification (PS) 1. 

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

G. The COMS shall be inata|kad, ca|ibnabad, nnoinboined, and operated in accordance with the procedures set 

forth in40CFRSO.13 and PG1of Appendix B.4OCFR Part GO. 

7. Until such time as the US EPA promulgates quality assurance requirements for COMS under Appendix F to 

40 CFR Part 60, the permittee shall perform an annual audit of the COMS using the procedures set forth in 

EPA Publication 450/4-92-010. "Performance Audits Procedures for Opacity Monitors," or a procedure 

acceptable to the AQD. The results of the annual audit shall be submitted to the AQD within the quarterly 

EER for the quarter in which the annual audit is conducted. Upon promulgation of COMS quality assurance 

requirements under Appendix F of Part 60, the permittee shall follow such procedures. 

& In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an excess emission 

report (EER) and summary report in an acceptable format to Air Quality Division, within 30 days following 

the end of each calendar quarter. The Summary Report shall follow the format of Figure 1 in 

40 CFR 60.7(d). The EER shall include the following information: 

a. A report of each exoemdance above 10 percent. This includes the dahe, hrne, mognhudo, cause and 

corrective actions of all occurrences during the reporting period. 

b. A report of all periods of COMS downtime and corrective action. 

c. A report of the total operating time of boilers during the reporting period. 

d. If no exceedances or COMS downtime occurred during the reporting pehod, the permittee shall report 

that fact. 

All monitoring data is shall be kept on file for a period of at least five years and made available to the AQD 

upon request. 
^

I ^^ 

DTE Electric Company Monroe Power Plant (B281O) June 25, 2013 

Permit No. 27-13 Page 100 of 101 

APPENDIX B 

NOx, 50a CO, PM, C0u102' Mercury Monitoring 

Continuous Emission Monitoring and Continuous Emission Rate Monitoring System (CEMS/CERMS) 

Requirements 

1. Within 30 calendar days after permit issuance, the permittee shall submit two copies of a Monitoring Plan to 

the AQD for review and approval. The Monitoring Plan shall include drawings or specifications showing 

proposed locations and descriptions of the required CEMS/CERMS. 

2. Within 150 calendar days after permit issuanca, the permittee shall submit two copies of a complete test 

plan for the CEMS/CERMS to the AQD for approval. 

3. Within 180 calendar days after permit issuance, the permittee shall complete the installation and testing of 

the CEMS/CERMS with the exception of the mercury CEMS which must be installed within 365 days after 

permit issuance. 

4. Within 60 days of completion of testing, the permittee shall submit to the AQD two copies of the final report 

demonstrating the CEMS/CERMS complies with the requirements of the corresponding Performance 

Specifications (PS) in the following table: 

Pollutant Applicable PS 

CO 4 

CO2/O2 3 

CERMS 6 

PM 11 

Mercury 12A* 

5. The span value shall be 2.0 times the lowest emission standard or as specified in the federal regulations. 

6. The CEMS/CERMS shall be inahaUed, ca|\brated, mointained, and operated in accordance with the 

procedures set forth in 40 CFR 60.13 and PS 2, 3, O. 11, and 12A (see No. 4 above) of Appendix B to 

40 CFR Part 60 or 40 CFR Part 75, Appendices A and B, as applicable. 

7. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the CEMS/CERMS 

set forth in Appendix F of 40 CFR Part 60 or 40 CFR Part 75, Appendix B. Within 30 days following the end 

of each calendar quarter, the permittee shall submit the results to the AQD in the format of the data 

assessment report (Figure 1, Appendix F of 40 CFR Part 60). 

8. When a mercury CEM is used, and daily calibration and cylinder gas audits are performed using elemental 

mercury, a single point converter check must be performed weekly using a NIST traceable source of 

oxidized mercury. 

Q. The permittee shall keep all monitoring data on file for a period of at least five years and make them 

available to the AQD upon request. 
DTE Electric Company, Monroe Power Plant (132816) June 25, 2013 

Permit No. 27-13 Page 101 of 101 

APPENDIX C 

Recordkeeping Provisions for a Nonattainment Source Using 

Actual-to-Projected-Actual Applicability Test 

All information in this appendix shall be maintained pursuant to R 336.2902 and 40 CFR 51 (Appendix S) for ten 

years after the modification, and shall be made available to the Department upon request. 

1. Project Description: 

The project is to increase the capacity to use subbitunlinous coal and add petroleum coke to provide 

additional fuels for EU-UN|T1-S1. EU-UN|T2-S1. EU-UN|T3-G1 and EU-UN|T4-81; installation of four (4) 

wet FGD quench pumps(EU-WFGD-QP1, EU-WFGD-QP2, EU-WFGD-QP3, and EU-WFGD-QP4); 

modifications to the fuel handling systems (EU'CASCADES-81. EU'TRAN8FERH8'S1. 

EU-DU/NPERHS-G1. EUCOALUNLOAO-S1. and EU-CRUSHERHS-G1); the installation of new material 

handling systems for limestone and gypsum (EU-L|KAE8TJNE-S1. EU-GYPSUMHAND-S1. and 

EU-HYDRATEL|yNE-81); and the installation of a new fuel handling system for petroleum coke 

(EU-PETC{]KE-G1). 

2. Applicability Test Description: 

Minor modifications are not subject to nonattainment. The hybrid applicability test 

as described in the table below was used to demonstrate that nonattainment does not apply to these 

modifications. 

3. Emission Projections: 

Emissions (tpy) 

Emission 

Unit/Flexible Pollutant 

Baseline 

Actual 

Emissions 

Projected 

Actual 

Emissions 

Excluded 

Emissions 

(tpy) 

Reason for Exclusion 

FG-ProjectPCl-4 PM2.5 5,315 2,730 381 FG-ProjectPCi-4 was capable 

of accommodating emissions 

up to 381 tpy. There is no 

projected emissions increase, 

therefore the project is less 

than the significant level of 10 

FG-ProjectPCi-4 SO2 117,940 11,753 1,757 FG-ProjectPCi-4 was capable 

of accommodating emissions 

up to 1,757 tpy. There is no 

projected emissions increase, 

therefore the project is less 

than the significant level of 40 
Page 1 of 76 

Michigan Department of Environmental Quality 

Air Quality Division

EFFECTIVE DATE: October 1, 2009 

REVISION DATE(S): July 25, 2011 

ISSUED TO 

Detroit Edison Monroe Power Plant 

State Registration Number (SRN): B2816 

LOCATED AT 

3500 East Front Street, Monroe, Michigan 48161 

RENEWABLE OPERATING PERMIT 

Permit Number: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

Administratively Complete ROP Renewal Application Due Between April 1, 2013 and April 1, 

2014 

This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of 

Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, 

as amended (Act 451). Pursuant to Michigan Air Pollution Control Rule 210(1), this ROP constitutes the 

permittee’s authority to operate the stationary source identified above in accordance with the general

conditions, special conditions and attachments contained herein. Operation of the stationary source and 

all emission units listed in the permit are subject to all applicable future or amended rules and regulations 

pursuant to Act 451 and the federal Clean Air Act. 

SOURCE-WIDE PERMIT TO INSTALL 

Permit Number: MI-PTI-B2816-2009a 

This Permit to Install (PTI) is issued in accordance with and subject to Section 5505(5) of Act 451. 

Pursuant to Michigan Air Pollution Control Rule 214a, the terms and conditions herein, identified by the 

underlying applicable requirement citation of Rule 201(1)(a), constitute a federally enforceable PTI. The 

PTl terms and conditions do not expire and remain in effect unless the criteria of Rule 201(6) are met.

Operation of all emission units identified in the PTI is subject to all applicable future or amended rules and 

regulations pursuant to Act 451 and the federal Clean Air Act. 

Michigan Department of Environmental Quality 

______________________________________ 

Scott Miller, Jackson District Supervisor 
ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 2 of 76 

TABLE OF CONTENTS

Section 1................................................................................................................................................. 4

A. GENERAL CONDITIONS................................................................................................................... 6

Permit Enforceability ................................................................................................................................ 6

General Provisions................................................................................................................................... 6

Equipment & Design ................................................................................................................................ 7

Emission Limits........................................................................................................................................ 7

Testing/Sampling ..................................................................................................................................... 7

Monitoring/Recordkeeping ....................................................................................................................... 8

Certification & Reporting .......................................................................................................................... 8

Permit Shield ........................................................................................................................................... 9

Revisions ............................................................................................................................................... 10

Reopenings............................................................................................................................................ 10

Renewals............................................................................................................................................... 11

Stratospheric Ozone Protection ............................................................................................................. 11

Risk Management Plan.......................................................................................................................... 11

Emission Trading ................................................................................................................................... 11

Permit To Install (PTI) ............................................................................................................................ 12

B. SOURCE-WIDE CONDITIONS ........................................................................................................ 13

C. EMISSION UNIT CONDITIONS ....................................................................................................... 14

EMISSION UNIT SUMMARY TABLE..................................................................................................... 14

D. FLEXIBLE GROUP CONDITIONS................................................................................................... 16

FLEXIBLE GROUP SUMMARY TABLE................................................................................................. 16

FG-BLR-1-4-S1...................................................................................................................................... 17

FG-COALHANDLING-S1....................................................................................................................... 23

FGAUXBOILERS-S1 ............................................................................................................................. 25

FGRULE290-S1..................................................................................................................................... 27

FGCOLDCLNRS-S1 .............................................................................................................................. 30

E. NON-APPLICABLE REQUIREMENTS ............................................................................................ 32

APPENDICES ....................................................................................................................................... 33

Appendix 1.1: Abbreviations and Acronyms.......................................................................................... 33

Appendix 1.2. Schedule of Compliance................................................................................................. 34

Appendix 1.3. Monitoring Requirements ............................................................................................... 34

Appendix 1.4. Recordkeeping ............................................................................................................... 35

Appendix 1.5. Testing Procedures ........................................................................................................ 35

Appendix 1.6. Permits to Install............................................................................................................. 35

Appendix 1.7. Emission Calculations .................................................................................................... 36

Appendix 1.8. Reporting........................................................................................................................ 36

Appendix 1.9. Acid Rain Requirements................................................................................................. 36

Appendix 1.10. CAIR Sulfur Dioxide Budget Requirements .................................................................. 52

Appendix 1.11. CAIR Annual Nitrogen Oxide Budget Permit................................................................. 55

Appendix 1.12. CAIR Ozone Nitrogen Oxide Budget Permit ................................................................. 58

SECTION 2............................................................................................................................................ 61
ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 3 of 76 

AUTHORITY AND ENFORCEABILITY ................................................................................................. 62

A. GENERAL CONDITIONS................................................................................................................. 63

Permit Enforceability .............................................................................................................................. 63

General Provisions................................................................................................................................. 63

Equipment & Design .............................................................................................................................. 64

Emission Limits...................................................................................................................................... 64

Testing/Sampling ................................................................................................................................... 64

Monitoring/Recordkeeping ..................................................................................................................... 65

Certification & Reporting ........................................................................................................................ 65

Permit Shield ......................................................................................................................................... 66

Revisions ............................................................................................................................................... 67

Reopenings............................................................................................................................................ 67

Renewals............................................................................................................................................... 68

Stratospheric Ozone Protection ............................................................................................................. 68

Risk Management Plan.......................................................................................................................... 68

Emission Trading ................................................................................................................................... 68

Permit To Install (PTI) ............................................................................................................................ 69

B. SOURCE-WIDE CONDITIONS ........................................................................................................ 70

C. EMISSION UNIT CONDITIONS ....................................................................................................... 71

EMISSION UNIT SUMMARY TABLE..................................................................................................... 71

D. FLEXIBLE GROUP CONDITIONS................................................................................................... 71

FLEXIBLE GROUP SUMMARY TABLE................................................................................................. 71

FGPEAKERS-S2 ................................................................................................................................... 72

E. NON-APPLICABLE REQUIREMENTS ............................................................................................ 74

APPENDICES ....................................................................................................................................... 75

Appendix 2.1: Abbreviations & Acronyms.............................................................................................. 75

Appendix 2.2. Schedule of Compliance................................................................................................. 76

Appendix 2.3. Monitoring Requirements ............................................................................................... 76

Appendix 2.4. Recordkeeping ............................................................................................................... 76

Appendix 2.5. Testing Procedures ........................................................................................................ 76

Appendix 2.6. Permits to Install............................................................................................................. 76

Appendix 2.7. Emission Calculations .................................................................................................... 76

Appendix 2.8. Reporting........................................................................................................................ 76
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 4 of 76 

STATE OF MICHIGAN 

RENEWABLE OPERATING PERMIT 

Section 1 

ISSUED TO 

 DETROIT EDISON 

MONROE POWER PLANT 

State Registration Number (SRN): B2816

LOCATED AT 

3500 E. FRONT ST. 

 MONROE, MI 48161 

Permit No: MI-ROP-B2816-2009a 

Effective Date: October 1, 2009 

Expiration Date: October 1, 2014
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 5 of 76 

AUTHORITY AND ENFORCEABILITY

For the purpose of this permit, the permittee is defined as any person who owns or operates an 

emission unit at a stationary source for which this permit has been issued. The department is defined in 

Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her 

designee. 

The permittee shall comply with all specific details in the permit terms and conditions and the cited 

underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable 

and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most

stationary sources for which an ROP has been issued. These general conditions are included in Part A 

of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units

which are represented as a flexible group, or the entire stationary source which is represented as a 

source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices. 

In accordance with Rule 213(2)(a), all underlying applicable requirements will be identified for each ROP 

term or condition. All terms and conditions that are included in a PTI, are streamlined or subsumed, or is 

state only enforceable will be noted as such. 

In accordance with Section 5507 of Act 451, the permittee has included in the ROP application a 

compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements 

with which the source is in compliance, the source will continue to comply with these requirements. For 

applicable requirements with which the source is not in compliance, the source will comply with the 

detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. 

Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the 

stationary source will meet the requirements on a timely basis, unless the underlying applicable 

requirement requires a more detailed schedule of compliance. 

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 6 of 76 

A. GENERAL CONDITIONS 

Permit Enforceability 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5))

• Those conditions that are hereby incorporated in a state only enforceable Source-wide PTI pursuant to Rule 

201(2)(d) are designated by footnote one. (R 336.1213(5)(a), R336.1214a(5))

• Those conditions that are hereby incorporated in federally enforceable Source- wide PTI No. MI-PTI-B2816-

2009a pursuant to Rule 201(2)(c) are designated by footnote two. (R 336.1213(5)(b), R 336.1214a(3))

General Provisions 

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of 

Act 451, and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of 

the ROP. All terms and conditions of this ROP that are designated as federally enforceable are enforceable by 

the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the 

provisions of the federal Clean Air Act (CAA). Any terms and conditions based on applicable requirements 

which are designated as “state only” are not enforceable by the USEPA or citizens pursuant to the CAA. 

(R 336.1213(1)(a))

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or 

reduce the permitted activity in order to maintain compliance with the conditions of this ROP. 

(R 336.1213(1)(b))

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit 

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make 

changes, at the permittee’s own risk, pursuant to Rule 215 and Rule 216. (R 336.1213(1)(c))

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation 

of credentials and other documents as may be required by law and upon stating the authority for and purpose 

of the investigation, to perform any of the following activities (R 336.1213(1)(d)): 

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity is 

conducted or where records must be kept under the conditions of the ROP. 

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

ROP. 

c. Inspect, at reasonable times, any of the following: 

i. Any stationary source. 

ii. Any emission unit. 

iii. Any equipment, including monitoring and air pollution control equipment. 

iv. Any work practices or operations regulated or required under the ROP. 

d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the ROP or applicable requirements. 

5. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to 

determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies 

of any records that are required to be kept as a term or condition of this ROP. For information which is claimed 

by the permittee to be confidential, consistent with the requirements of the 1976 PA 442, MCL §15.231 et seq., 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 7 of 76 

and known as the Freedom of Information Act, the person may also be required to furnish the records directly 

to the USEPA together with a claim of confidentiality. (R 336.1213(1)(e))

6. A challenge by any person, the Administrator of the USEPA, or the department to a particular condition or a 

part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any 

other condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of 

Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

Equipment & Design 

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370)

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance 

with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

Emission Limits 

11. Except as provided in Subrules 2, 3, and 4 of Rule 301, states in part; “a person shall not cause or permit to be 

discharged into the outer air from a process or process equipment a visible emission of a density greater than 

the most stringent of Rule 301(1)(a) or (b) unless otherwise specified in this ROP.” The grading of visible 

emissions shall be determined in accordance with Rule 303. (R 336.1301(1) in pertinent part): 

a. A 6-minute average of 20 percent opacity, except for one 6-minute average per hour of not more than 27 

percent opacity. 

b. A limit specified by an applicable federal new source performance standard. 

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or in reaction with other air contaminants, either of the following: 

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.1 

(R 336.1901(a)) 

b. Unreasonable interference with the comfortable enjoyment of life and property. 1 (R 336.1901(b)) 

Testing/Sampling 

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner’s or operator’s expense, in accordance with Rule 1001 and Rule 1003, under 

any of the conditions listed in Rule 1001(1). (R 336.2001)

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and 

Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1))

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days following the last date of the test. (R 336.2001(4))
Section 1 ROP No: MI-ROP-B2816-2009a 

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Monitoring/Recordkeeping 

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following 

information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)): 

a. The date, location, time, and method of sampling or measurements. 

b. The dates the analyses of the samples were performed. 

c. The company or entity that performed the analyses of the samples. 

d. The analytical techniques or methods used. 

e. The results of the analyses. 

f. The related process operating conditions or parameters that existed at the time of sampling or 

measurement. 

17. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records, for continuous monitoring instrumentation and copies of all reports required by the ROP. 

(R 336.1213(1)(e), R 336.1213(3)(b)(ii))

Certification & Reporting 

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be 

submitted to the department as a term or condition of this ROP shall contain an original certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

19. A responsible official shall certify to the appropriate AQD District Office and to the USEPA that the stationary 

source is and has been in compliance with all terms and conditions contained in the ROP except for deviations 

that have been or are being reported to the appropriate AQD District Office pursuant to Rule 213(3)(c). This 

certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and shall state that, based 

on information and belief formed after reasonable inquiry, the statements and information in the certification are 

true, accurate, and complete. The USEPA address is: USEPA, Air Compliance Data - Michigan, Air and 

Radiation Division, 77 West Jackson Boulevard, Chicago, Illinois 60604. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special 

conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt 

reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise 

described in this ROP. (R 336.1213(3)(c))

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to 

this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to 

Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the 

semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and 

the actions taken to minimize or correct each deviation. 

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 
Section 1 ROP No: MI-ROP-B2816-2009a 

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22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in 

Rule 213(3)(c)(iii) as either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible official with each report which states that, based on information 

and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports 

of deviations from the emissions allowed under the ROP were submitted to the department pursuant to 

Rule 213(3)(c)(ii), a certification by a responsible official which states that, “based on information and belief 

formed after reasonable inquiry, the statements and information contained in each of the reports submitted 

during the previous month were true, accurate, and complete”. The certification shall include a listing of the 

reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a 

monthly basis pursuant to this paragraph shall include a statement that certification of the report will be 

provided within 30 days following the end of the calendar month. 

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate AQD District Office. All 

instances of deviations from ROP requirements during the reporting period shall be clearly identified in the 

reports. (R 336.1213(3)(c)(i))

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine 

the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6))

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required in Rule 912, to the appropriate AQD District Office. The notice shall 

be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal conditions 

or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, or oral communication. 

Written reports, if required under Rule 912, must be submitted to the appropriate AQD District Supervisor within 10 

days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been 

corrected, or within 30 days of discovery of the abnormal conditions or malfunction, whichever is first. The written 

reports shall include all of the information required in Rule 912(5) and shall be certified by a responsible official in a 

manner consistent with the CAA. (R 336.1912)

Permit Shield 

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements 

as of the date of ROP issuance, if either of the following provisions is satisfied. (R 336.1213(6)(a)(i), 

R 336.1213(6)(a)(ii))

a. The applicable requirements are included and are specifically identified in the ROP. 

b. The permit includes a determination or concise summary of the determination by the department that other 

specifically identified requirements are not applicable to the stationary source. 

Any requirements identified in Part E of this ROP have been identified as non-applicable to this ROP and are 

included in the permit shield. 

27. Nothing in this ROP shall alter or affect any of the following: 

a. The provisions of Section 303 of the CAA, emergency orders, including the authority of the USEPA under 

Section 303 of the CAA. (R 336.1213(6)(b)(i))

b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at 

the time of this ROP issuance. (R 336.1213(6)(b)(ii))

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. 

(R 336.1213(6)(b)(iii)) 
Section 1 ROP No: MI-ROP-B2816-2009a 

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d. The ability of the USEPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

28. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the 

following: 

a. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5))

b. Administrative Amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii))

c. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved 

by the department. (R 336.1216(1)(c)(iii))

d. Minor Permit Modifications made pursuant to Rule 216(2). (R 336.1216(2)(f))

e. State-Only Modifications made pursuant to Rule 216(4) until the changes have been approved by the 

department. (R 336.1216(4)(e))

29. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration 

date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP 

does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original 

ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))

Revisions 

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the 

ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to 

Rule 216(1). (R 336.1219(2))

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the time frames specified in Rule 216. (R 336.1210(9))

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the 

department takes final action, the permittee shall comply with both the applicable requirements governing the 

change and the ROP terms and conditions proposed in the application for the modification. During this time 

period, the permittee may choose to not comply with the existing ROP terms and conditions that the application 

seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the 

application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(iii), 

R 336.1216(2)(d), R 336.1216(4)(d))

Reopenings 

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under 

any of the following circumstances: 

a. If additional requirements become applicable to this stationary source with three or more years remaining in 

the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 

expiration date. (R 336.1217(2)(a)(i))

b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. 

(R 336.1217(2)(a)(ii))

c. If the department determines that the ROP contains a material mistake, information required by any 

applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or 

the terms or conditions of the ROP. (R 336.1217(2)(a)(iii))

d. If the department determines that the ROP must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv))
Section 1 ROP No: MI-ROP-B2816-2009a 

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Renewals 

35. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by 

the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. 

(R 336.1210(7))

Stratospheric Ozone Protection 

36. If the permittee is subject to Title 40 of the Code of Federal Regulations (CFR), Part 82 and services, 

maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of appliances 

containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaimer, 

appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall 

comply with all applicable standards for recycling and emissions reduction pursuant to 40 CFR, Part 82, 

Subpart F. 

37. If the permittee is subject to 40 CFR, Part 82, and performs a service on motor (fleet) vehicles when this 

service involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified 

in 40 CFR, Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term “motor vehicle” as used 

in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using 

Hydrochlorofluorocarbon-22 refrigerant. 

Risk Management Plan 

38. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall register and submit to the 

USEPA the required data related to the risk management plan for reducing the probability of accidental

releases of any regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 40 CFR, 

Part 68.130. The list of substances, threshold quantities, and accident prevention regulations promulgated 

under 40 CFR, Part 68, do not limit in any way the general duty provisions under Section 112(r)(1). 

39. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall comply with the requirements 

of 40 CFR, Part 68, no later than the latest of the following dates as provided in 40 CFR, Part 68.10(a): 

a. June 21, 1999, 

b. Three years after the date on which a regulated substance is first listed under 40 CFR, Part 68.130, or 

c. The date on which a regulated substance is first present above a threshold quantity in a process. 

40. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 

40 CFR, Part 68. 

41. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall annually certify compliance with 

all applicable requirements of Section 112(r) as detailed in Rule 213(4)(c)). (40 CFR, Part 68)

Emission Trading 

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the USEPA as a part of 

Michigan’s State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. 

(R 336.1213(12))
Section 1 ROP No: MI-ROP-B2816-2009a 

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Permit To Install (PTI) 

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt 

from the PTI requirements by any applicable rule. 2 (R 336.1201(1)) 

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence 

indicates the process or process equipment is not performing in accordance with the terms and conditions of 

the PTI or is violating the department’s rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451) 

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or 

operates the process or process equipment at the location authorized by the PTI. If a new owner or operator 

submits a written request to the department pursuant to Rule 219 and the department approves the request, 

this PTI will be amended to reflect the change of ownership or operational control. The request must include all 

of the information required by Subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the 

appropriate AQD District Supervisor, MDEQ. 2 (R 336.1219) 

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and 

conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, 

the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the

department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall 

notify the department via the Supervisor, Permit Section, MDEQ, AQD, P. O. Box 30260, Lansing, Michigan 

48909, if it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment 

allowed by the terms and conditions from that PTI. 2 (R 336.1201(4)) 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 1 ROP No: MI-ROP-B2816-2009a 

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B. SOURCE-WIDE CONDITIONS 

Part B outlines the Source-Wide Terms and Conditions that apply to this stationary source. The permittee is 

subject to these special conditions for the stationary source in addition to the general conditions in Part A and any 

other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in 

the table. If there are no Source-Wide Conditions, this section will be left blank. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

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C. EMISSION UNIT CONDITIONS 

Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit 

Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General 

Conditions in Part A and any other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no conditions specific to individual emission units, this section will be left blank. 

EMISSION UNIT SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute 

enforceable conditions.

Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification Date

Flexible Group ID 

EU-UNIT1-S1 Boiler Unit No. 1 Coal-fired boiler nominally 

rated 775 MW (Net) with Low-NOx burners, 

SO3 & Ammonia flue gas conditioning 

systems, dry wire electrostatic precipitators 

(ESP), and Selective Catalytic Reduction 

(SCR). Fires #2 fuel oil for boiler ignition. 

01/01/1968/ 

03/03/2006 

FG-BOILERS1-4-

S1

EU-UNIT2-S1 Boiler Unit No. 2 Coal-fired boiler nominally 

rated 785 MW (Net) with Low-NOx burners, 

SO3 & Ammonia flue gas conditioning 

systems, and dry wire electrostatic 

precipitators (ESP). Fires #2 fuel oil for boiler 

ignition. 

01/01/1969/ 

03/23/2005 

FG-BOILERS1-4-

S1

EU-UNIT3-S1 Boiler Unit No. 3 Coal-fired boiler nominally 

rated 785 MW (Net) with Low-NOx burners, 

SO3 & Ammonia flue gas conditioning 

systems, dry wire electrostatic precipitators 

(ESP), and Selective Catalytic Reduction 

(SCR). Fires #2 fuel oil for boiler ignition. 

06/01/1969/ 

8/28/2006 

FG-BOILERS1-4-

S1

EU-UNIT4-S1 Boiler Unit No. 4 Coal-fired boiler nominally 

rated 795 MW (Net) with Low-NOx burners, 

SO3 & Ammonia flue gas conditioning 

systems, dry wire electrostatic precipitators 

(ESP), and Selective Catalytic Reduction 

(SCR). Fires #2 fuel oil for boiler ignition. 

06/01/1969/ 

11/15/2005 

FG-BOILERS1-4-

S1

EU-CASCADES-S1 This emission unit represents coal handling 

activity in the Cascades room. Coal handling 

activity emissions are limited by an enclosure, 

water sprays, and baghouse dust collectors. 

01/01/1968/ 

11/01/1980 

FGCOALHANDLINGS1

EU-TRANSFERHSS1 This emission unit represents coal handling 

activity in the Transfer House. Coal handling 

activity emissions are limited by an enclosure, 

water sprays, and baghouse dust collectors. 

01/01/1968/ 

11/01/1980 

FGCOALHANDLINGS1

EU-DUMPERHS-S1 This emission unit represents coal handling 

activity in the Dumper House. Coal handling 

activity emissions are limited by an enclosure, 

water sprays, and baghouse dust collectors. 

01/01/1968/ 

11/01/1980 

FGCOALHANDLINGS1
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Emission Unit ID Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification Date

Flexible Group ID 

EU-CRUSHERHS-S1 This emission unit represents coal handling 

activity in the Crusher House. Coal Handling 

activity emissions are limited by an enclosure, 

water sprays, and baghouse dust collectors. 

01/01/1968/ 

1/07/2005 

FGCOALHANDLINGS1

EU-SOUTHAUX-S1 South Auxiliary Boiler 01/01/1968 FGAUXBOILERSS1

EU-NORTHAUX-S1 North Auxiliary Boiler 01/01/1968 FGAUXBOILERSS1 

EU-PARTSCLNRSS1 

Parts Cleaning Stations 

NA 

FGPARTSCLNRS-S1

EU-LIMESTONE-S1 

This emission unit represents Limestone 

handling activity in the Prep building and the 

limestone storage. Limestone handling activity 

emissions are limited by enclosures, sprays, 

or baghouses dust collectors. 

02/01/2008 FG-RULE290-S1 

EU-GYPSUM-HANDS1 

This emission unit represents gypsum 

handling activity in the Water Treatment 

building and the Gypsum storage & loading 

building. Gypsum handling activity emissions 

are limited by enclosures, sprays, or 

baghouses dust collectors. 

02/01/2008 FG-RULE290-S1 
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D. FLEXIBLE GROUP CONDITIONS

Part D outlines the terms and conditions that apply to more than one emission unit. The permittee is subject to the 

special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and 

conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no special conditions that apply to more than one emission unit, this section will be left blank. 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute 

enforceable conditions. 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FGAUXBOILERS-S1 North and South Auxiliary Boilers EU-NORTHAUX-S1, EUSOUTHAUX-S1 

FG-BLR-1-4-S1 Boilers 1, 2, 3, and 4 EU-UNIT1-S1, EU-UNIT2-

S1, EU-UNIT3-S1, EUUNIT4-S1 

FG-COALHANDLING-S1 Coal handling system EU-M-CASCADES-S1, 

EU-M-TRANSFERHSS1, 

EU-M-DUMPERHS-S1, 

EU-M-CRUSHERHS-S1

FG-RULE290-S1 Material Handling of limestone and gypsum 

EU-LIME-HAND-S1 

EU-GYPSUM-HAND-S1

FG-PARTSCLNRS-S1 Parts Cleaners EU-PARTSCLNRS-S1 
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FG-BLR-1-4-S1 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Four coal-fired cell burner boilers nominally rated at 3,140 Megawatts total (net). 

Emission Units: EU-UNIT1-S1, EU-UNIT2-S1, EU-UNIT3-S1, EU-UNIT4-S1 

POLLUTION CONTROL EQUIPMENT

Low-NOx burners, Dry Wire Electrostatic Precipitator (ESP), Selective Catalytic Reduction (SCR) – except Unit 2, 

SO3 Flue Gas Conditioning System, and Ammonia Flue Gas Conditioning System 

I. EMISSION LIMIT(S)

Pollutant Limit 

Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

1. Sulfur Dioxide (SO2) 

1.6 pounds per 

million BTUs 

heat input 2, 3

24-hour 

period FG-BLR-1-4-S1 S.C. VI.1 R 336.1401 

2. Sulfur Dioxide (SO2) 

0.323 pounds 

per million 

BTUs heat 

input per boiler

3

24-hour 

calendar day 

period 

FG-BLR-1-4-S1 S.C. VI.1 R 336.1213(2), 

R 336.1401 

3. Sulfur Dioxide (SO2) 

See Appendix 9 

– Acid Rain 

Permit and 

Appendix 10 - 

CAIR SO2 

Budget Permit 

Annual 

EU-UNIT1-S1, 

EU-UNIT2-S1, 

EU-UNIT3-S1, 

EU-UNIT4-S1 

S.C. VI.1 

40 CFR 72, 

40 CFR 97, 

R 336.1420 

4. Nitrogen Oxides (NOx) 

See Appendix 9 

– Acid Rain 

Permit and 

Appendix 11 – 

CAIR Annual 

NOx Budget 

Permit 

Annual 

EU-UNIT1-S1, 

EU-UNIT2-S1, 

EU-UNIT3-S1, 

EU-UNIT4-S1 

S.C. VI.1 

40 CFR 76, 

40 CFR 97, 

R 336.1821 

5. Nitrogen Oxides (NOx) 

See Appendix 

12 –CAIR 

Ozone NOx 

Budget Permit

Ozone 

Season 

EU-UNIT1-S1, 

EU-UNIT2-S1, 

EU-UNIT3-S1, 

EU-UNIT4-S1 

S.C. VI.1 40 CFR 97, 

R 336.1821 
Section 1 ROP No: MI-ROP-B2816-2009a 

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Pollutant Limit 

Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

6. Particulate matter 

0.12 pounds 

per 1,000 

pounds of 

exhaust gases, 

on wet basis, 

corrected to 

50% excess air

per boiler 2

NA FG-BLR-1-4-S1 S.C. V.1 R 336.1331(1) 

3

 – On or after the flue gas desulfurization system has started up for a unit, that unit shall not exceed the SO2 

emission limit of 0.323 pound per million BTUs heat input based upon a 24 hour calendar day average. 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

1. N/A N/A N/A N/A N/A N/A 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. Permittee shall not burn any fuel in the boilers other than No. 2 fuel oil and coal, or inject raw materials into the 

flue gases without prior notification to and approval by the AQD, except as authorized by permit. 2

 (R 336.1201(3))

2. The ESP, Ammonia and SO3 flue gas conditioning systems, and low-NOx burners for the FGBoilers1-4-S1 

shall be installed and operated in a satisfactory manner. 2 (R 336.1910)

3. The permittee shall equip and maintain EU-UNIT1-S1, EU-UNIT3-S1, and EU-UNIT4-S1 each with an SCR 

system. 2

 (R 336.1910)

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Once during the term of this permit, or more frequently upon request of AQD, permittee shall verify the PM 

emission rate from FG-BLR-1-4-S1 by testing, utilizing U.S. EPA Reference Method 17 or other AQD approved 

test method. Verification of emission rates includes the submittal of a complete report of the test results within 

60 days of test completion. (R 336.205(1)(a) and (b), R 336.1213(3), R 336.2001, R 336.2003, 

R 336.2004) 

2. The permittee shall submit a complete test protocol to the AQD for approval at least 30 days prior to the 

anticipated test date. (R 336.1213(3))

3. The permittee shall notify the AQD no less than 7 days prior to the anticipated test date. (R 336.2001(3))

See Appendix 5 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 19 of 76 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Permittee shall continue to monitor and record the opacity, gas flow, NOx, and SO2 from the Boilers on a 

continuous basis in accordance with 40 CFR Part 75. On or after a flue gas desulfurization system has started 

up for a unit, permittee may monitor and record opacity with an equivalent emission monitoring system that is 

approved by AQD.2 (40 CFR Part 75, 40 CFR Part 60, R 336.2101, R 336.2159)

2. Permittee shall continue the existing program for monitoring, logging, and recording the ESP operating data.2

 (R 336.1201(3)) 

3. Except as provided in S.C. VI.7 of this table, the permittee shall utilize COMS-recorded opacity as an indicator 

of the emission unit’s compliance with the particulate matter emission limit. An excursion of the PM emission 

limit shall be defined as 2 or more consecutive 1-hour block average opacity values greater than 20%. This 

condition does not affect compliance with R 336.1301. (40 CFR 64.6(c)(1)(i and ii) and (2))

4. Except for units operating flue gas desulphurization systems, the permittee shall operate the COMS during all 

required periods when the coal-fired boiler is operating. Data recorded during monitoring malfunctions, repair 

activities and QA/QC operations shall not be used for 40 CFR Part 64 compliance. (40 CFR 64.6(c)(3), 

64.7(c)) 

5. Upon detecting CAM exceedances(s)/excursion(s), the permittee shall restore operation of the emission unit, 

control device, and associated pollutant capture system equipment to normal/compliant operation. CAM 

exceedances/excursions trigger initial inspections, corrective action(s), and recordkeeping of the probable 

cause & corresponding resolution. (40 CFR 64.7(d)) 

6. Except as provided in S.C. VI.7 of this table, the permittee shall perform an annual COMS audit using certified 

filters to ensure accurate opacity readings. (40 CFR 64.6(c)(1)(iii)) 

7. Once a flue gas desulfurization system has started up for a unit, the permittee shall notify the AQD and submit 

that unit’s proposed new CAM plan. The CAM plan revision shall be submitted and implemented no later than 

180 days after the start up of the flue gas desulfurization system for that unit. 

 (40 CFR 64.4(e)) 

8. The permittee shall keep in a satisfactory manner, monthly and previous 12-month CO calculation records for 

EU-UNIT1-S1, EU-UNIT3-S1, and EU-UNIT4-S1.2

 (R 336.1205(1)(a) and (b), 40 CFR 52.21 (c) and (d), 40 

CFR 52.21(j))

See Appendices 1.3 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for reporting period July 1 to December 

31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for the previous calendar year. 

 (R 336.1213(4)(c))

4. For the COMS and for the SO2 CEMS, the permittee shall submit to the District Supervisor and the Technical 

Programs Unit Supervisor, Air Quality Division, and to the Chief of the Air Compliance Branch, U.S. 

Environmental Protection Agency, within 30 days of the end of the calendar quarter, a written report for each 

calendar quarter which shall include all of the following information: 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 20 of 76 

i. Excess emissions and the nature and cause of excess emissions, if known, as follows: 

A. For opacity measurements, the report shall consist of the magnitude, in actual percent opacity, of 

all 6-minute averages of opacity more than the applicable opacity standard for each hour of 

operation (all allowable exceptions are to be deducted prior to determining the excess averages of 

opacity). Average values shall be obtained by integration over the averaging period or by 

arithmetically averaging a minimum of 24 equally spaced, instantaneous opacity measurements 

per 6 minutes. 

B. For gaseous measurements, the report shall consist of emission averages, in the units of the 

applicable standard, for each averaging period during which the applicable standard was 

exceeded. 

ii. The date and time identifying each period during which the continuous monitoring system was 

inoperative, except for zero and span checks, and the nature of repairs or adjustments made. 

iii. If the monitoring system has not been inoperative, repaired, or adjusted, and if no excess 

emissions occurred, a statement attesting to this fact.2

 

(R 336.2170(1)(a), (b) and (c)) 

5. The permittee shall submit to the Chief of the Air Compliance Branch, U.S. Environmental Protection Agency 

and the District Supervisor of the Air Quality Division, within 30 days of the end of the calendar quarter, a 

written report for each calendar quarter which shall include sulfur dioxide monthly emission rate averages. 2

 (R336.1401, Clean Air Act Section 114(a))

6. Permittee shall report sulfur dioxide, nitrogen oxide and carbon dioxide emissions, volumetric flow, and opacity 

data in accordance with 40 CFR, Part 75 (Continuous Emission Monitoring). (R 336.1213(3)) 

7. Semiannually or more frequently report Compliance Assurance Monitoring (CAM) summary information on the 

number, duration, and cause of exceedances/excursions in the reporting period, and the corrective actions 

taken in response. If there were no excursions/exceedances in the reporting period, then this report shall 

include a statement that there were no excursions/exceedances. (40 CFR 64.9(a)(2)(i), R 336.1213(3)(c))

8. Semiannually report or more frequently report Compliance Assurance Monitoring (CAM) summary information 

on monitor downtime in the reporting period. If there were no periods of monitor downtime in the reporting 

period, then this report shall include a statement that there were no periods of monitor downtime. (40 CFR 

64.9(a)(2)(ii), R 336.1213(3)(c)) 

See Appendix 1.8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV015-001 336 2 805 2 40 CFR 52.21 (c) and (d) 

2. SV015-002 336 2 805 2 40 CFR 52.21 (c) and (d) 

3. SV016-001 360 4 578 4 40 CFR 52.21 (c) and (d), R 

336.1213(2) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 21 of 76 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

4. SV016-002 360 4 578 4 40 CFR 52.21 (c) and (d), R 

336.1213(2) 

5. SV016-003 360 4 578 4 40 CFR 52.21 (c) and (d), R 

336.1213(2) 

6. SV016-004 360 4 578 4 40 CFR 52.21 (c) and (d), R 

336.1213(2) 

4

 – On or after the flue gas desulphurization has started operation for any unit, all exhaust gases for that unit shall 

be discharged unobstructed vertically upwards to the ambient air from a stack with a maximum diameter of 360 

inches at an exit point not less than 578 feet above ground level. 

IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with the acid rain permitting provisions of 40 CFR 72.1 to 72.94 as outlined in a 

complete Phase II Acid Rain Permit issued by the AQD. Phase II Acid Rain Permit No. MI-AR-1733-2008 is 

hereby incorporated into this ROP as Appendix 1.9. (R 336.1299(d))

2. The permittee shall not allow the emission of an air pollutant to exceed the amount of any emission allowances 

that an affected source lawfully holds as of the allowance transfer deadline pursuant to Rule 299(d) and 40 

CFR Part 72.9(c)(1)(i). (R 336.1213)(10))

3. The permittee shall comply with the CAIR SO2 Trading Program provisions of 40 CFR Part 97.201 through 

97.288, as adopted and modified by R 336.1420, and as outlined in any complete CAIR SO2 permit issued by 

the AQD. CAIR SO2 Permit No. MI-SO2-1733-2009 is hereby incorporated into this ROP as Appendix 1.10. 

 (R 336.1420)

4. The permittee shall hold allowances for compliance deductions in the source’s compliance account as of the 

allowance transfer deadline in an amount not less than the total SO2 emissions for the control period from the 

source pursuant to 40 CFR Part 97.254. (40 CFR Part 97.254)

5. The permittee shall comply with the CAIR NOx Annual Trading Program provisions of 40 CFR Part 97.101 

through 97.188, as adopted and modified by R 336.1802a, 336.1803, 336.1821, and 336.1830 through 

336.1834, and as outlined in any complete CAIR NOx Annual permit issued by the AQD. CAIR NOx Annual 

Permit No. MI-NOA-1733-2009 is hereby incorporated into this ROP as Appendix 1.11. (R 336.1821)

6. The permittee shall hold allowances for compliance deductions in the source’s compliance account as of the 

allowance transfer deadline in an amount not less than the total NOx emissions for the control period from the 

source pursuant to 40 CFR Part 97.154. (40 CFR Part 97.154)

7. The permittee shall comply with the CAIR NOx Ozone Trading Program provisions of 40 CFR Part 97.301

through 97.388, as adopted and modified by R 336.1802a, 336.1803, and 336.1821 through 336.1826, and as 

outlined in any complete CAIR NOx Annual permit issued by the AQD. CAIR NOx Ozone Permit No. MI-NOO1733-2009 is hereby incorporated into this ROP as Appendix 1.12. (R 336.1821)

8. The permittee shall hold allowances for compliance deductions in the source’s compliance account as of the 

allowance transfer deadline in an amount not less than the total NOx emissions for the control period from the 

source pursuant to 40 CFR Part 97.354. (40 CFR Part 97.354)

9. The permittee shall implement and maintain a malfunction abatement/preventative maintenance program

approvable by the AQD.2

 (R 336.1911) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 22 of 76 

10. The permittee shall have a protocol describing reasonable measures to minimize carbon monoxide emissions 

from EU-UNIT1-S1, EU-UNIT3-S1, and EU-UNIT4-S1 approved by the AQD. Alternate formats or revisions to

the approved protocol must be approved by the AQD District Supervisor. 2

 (R336.1201(3)) 

11. The permittee shall maintain and operate EU-UNIT1-S1, EU-UNIT3-S1, and EU-UNIT4-S1 in a satisfactory 

manner using efficient combustion practices. Satisfactory operation includes operating EU-UNIT1-S1, EUUNIT3-S1, and EU-UNIT4-S1 according to the procedures outlined in the malfunction abatement/preventative 

maintenance plan specified in S.C. IX(5) and the carbon monoxide minimization plan specified in S.C. IX(6). 2 

(R336.1910, R336.1911, 40 CFR 52.21(j)) 

12. The permittee shall properly maintain the monitoring systems, including maintaining necessary parts for routine 

repairs of the monitoring equipment. (40 CFR 64.7(b)) 

13. The permittee shall promptly notify AQD for the need to modify the CAM Plan if the existing plan is found to be 

inadequate and shall submit a proposed modification to the ROP if necessary. (40 CFR 64.7(e)) 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 23 of 76 

FG-COALHANDLING-S1 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Coal handling system 

Emission Unit: EU-CASCADES-S1, EU-TRANSFERHS-S1, EU-DUMPERHS-S1, EU-CRUSHERHS-S1 

POLLUTION CONTROL EQUIPMENT

Enclosures, Water Sprays, Foam Sprays, and/or Dust Collectors

I. EMISSION LIMIT(S) 

Pollutant Limit 

Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

1. Particulate Matter 

0.10 pounds 

per 1000 

pounds of 

exhaust gases 2

N/A FGCOALHANDLING

-S1 S.C. III R 336.1331(1) 

II. MATERIAL LIMIT(S)

Material Limit 

Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

N/A N/A N/A N/A N/A N/A 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. Permittee shall not operate the facility unless the malfunction abatement plan specified in Appendix 1.3.4 has 

been implemented and is maintained. (R 336.1911)

2. Permittee shall not operate the coal and air handling systems unless the pollution control equipment is installed 

and operating properly. 2 (R 336.1910)

3. Permittee shall not operate the coal conveyor bypass (emergency reclaim system) unless the emergency 

reclaim pollution control equipment is installed and operating properly. 2 (R 336.1910)

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. NA 

See Appendix 5 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 24 of 76 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Permittee shall maintain and operate 2 high volume air samplers, one at the existing east monitoring site 

located at the edge of the plant property at the shore of Lake Erie, and the other at the Detroit Edison 

monitoring station which is located at the end of Dunbar Road. 2

 (R 336.1201(3))

See Appendix 1.3 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for reporting period July 1 to December 

31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. Report shall be 

postmarked or received by appropriate AQD district office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

4. Data from the high volume air samplers shall be provided to the AQD within 30 days following the end of the 

month in which the data were collected. If there is any excursion of the primary or secondary TSP levels, the 

facility shall include a summary of the excursion, the investigation, and the corrective action taken.

See Appendix 1.8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. NA NA NA NA 

IX. OTHER REQUIREMENT(S)

1. The coal handling system shall be operated in a manner which will minimize the fugitive particulate 

emissions.2 (R 336.1910)

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

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Page 25 of 76 

FGAUXBOILERS-S1 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION: North and south auxiliary boilers.

Emission Unit: EU-NORTHAUX, EU-SOUTHAUX 

POLLUTION CONTROL EQUIPMENT

NA 

I. EMISSION LIMIT(S)

Pollutant Limit Time Period/ Operating 

Scenario Equipment Monitoring/ Testing Method

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

1. # 2 Fuel Oil 

0.5% sulfur by 

weight with 

heat value of 

18,000 Btu/lb 

*,2

As-fired FG-AUXBOILERS VI.2 

R 336.1401 

40 CFR 52.21 

(c) and (d) 

* - This is equivalent to 0.56 lb SO2/mmBtu of heat input. Compliance with this limit shall be considered compliance 

with the limit of R336.1401, which has been subsumed under this streamlined requirement. 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. Permittee shall not burn any fuel in the two auxiliary boilers other than No. 2 fuel oil without prior notification to 

and approval by the AQD.2 (R 336.1202(3))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. NA 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. NA 

See Appendix 5 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall record the monthly fuel oil usage rates in gallons. (R 336.1213(3)(b)) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 26 of 76 

2. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of delivery, 

analytical results from laboratory testing, or any other records adequate to demonstrate compliance with the 

percent sulfur limit in fuel oil. (R 336.1213(3)(b)) 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. SV015-003 108 2

 231 2 R 336.201(3) 

IX. OTHER REQUIREMENT(S)

1. NA 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 27 of 76 

FGRULE290-S1 

FLEXIBLE GROUP CONDITIONS 

DESCRIPTION

Any emission unit that emits air contaminants and is exempt from the requirements of Rule 201 pursuant to Rules 

278 and 290. 

Emission Unit: 

POLLUTION CONTROL EQUIPMENT

I. EMISSION LIMIT(S)

1. Each emission unit that emits only noncarcinogenic volatile organic compounds or noncarcinogenic materials 

which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone if the total uncontrolled 

or controlled emissions of air contaminants are not more than 1,000 or 500 pounds per month, respectively. 

(R 336.1290(a)(i)) 

2. Each emission unit that the total uncontrolled or controlled emissions of air contaminants are not more than 

1,000 or 500 pounds per month, respectively, and all the following criteria listed below are met: 

(R 336.1290(a)(ii)) 

a. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and 

noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of 

ozone, with initial threshold screening levels greater than or equal to 2.0 micrograms per cubic meter, the 

uncontrolled or controlled emissions shall not exceed 1,000 or 500 pounds per month, respectively. 

(R 336.1290(a)(ii)(A)) 

b. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and 

noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of 

ozone, with initial threshold screening levels greater than or equal to 0.04 microgram per cubic meter and 

less than 2.0 micrograms per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 

10 pounds per month, respectively. (R 336.1290(a)(ii)(B)) 

c. For carcinogenic air contaminants with initial risk screening levels greater than or equal to 0.04 microgram 

per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 10 pounds per month, 

respectively. (R 336.1290(a)(ii)(C)) 

d. The emission unit shall not emit any air contaminants, excluding non-carcinogenic volatile organic 

compounds and noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to 

the formation of ozone, with an initial threshold screening level or initial risk screening level less than 0.04 

microgram per cubic meter. (R 336.1290(a)(ii)(D)) 

3. Each emission unit that emits only noncarcinogenic particulate air contaminants and other air contaminants that 

are exempted under Rule 290(a)(i) and/or Rule 290(a)(ii), if all of the following provisions are met: 

(R 336.1290(a)(iii)) 

a. The particulate emissions are controlled by an appropriately designed and operated fabric filter collector or 

an equivalent control system which is designed to control particulate matter to a concentration of less than 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 28 of 76 

or equal to 0.01 pound of particulate per 1,000 pounds of exhaust gases and which does not have an 

exhaust gas flow rate more than 30,000 actual cubic feet per minute. (R 336.1290(a)(iii)(A)) 

b. The visible emissions from the emission unit are not more than 5 percent opacity in accordance with the 

methods contained in Rule 303. (R 336.1290(a)(iii)(B)) 

c. The initial threshold screening level for each particulate air contaminant, excluding nuisance particulate, is 

more than 2.0 micrograms per cubic meter. (R 336.1290(a)(iii)(C))

II. MATERIAL LIMIT(S)

NA 

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The provisions of Rule 290 apply to each emission unit that is operating pursuant to Rule 290. (R 336.1290)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA 

V. TESTING/SAMPLING

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records of the following information for each emission unit for each calendar 

month using the methods outlined in the DEQ, AQD Rule 290, Permit to Install Exemption Record form 

(EQP 3558) or an alternative format that is approved by the AQD District Supervisor. (R 336.1213(3)) 

a. Records identifying each air contaminant that is emitted. (R 336.1213(3)) 

b. Records identifying if each air contaminant is controlled or uncontrolled. (R 336.1213(3)) 

c. Records identifying if each air contaminant is either carcinogenic or non-carcinogenic. (R 336.1213(3)) 

d. Records identifying the ITSL and IRSL, if established, of each air contaminant that is being emitted under 

the provisions of Rules 290(a)(ii) and (iii). (R 336.1213(3)) 

e. Material use and calculations identifying the quality, nature, and quantity of the air contaminant emissions 

in sufficient detail to demonstrate that the actual emissions of the emission unit meet the emission limits 

outlined in this table and Rule 290. (R 336.1213(3), R 336.1290(c)) 

2. The permittee shall maintain an inventory of each emission unit that is exempt pursuant to Rule 290. This 

inventory shall include the following information. (R 336.1213(3)) 

a. The permittee shall maintain a written description of each emission unit as it is maintained and operated 

throughout the life of the emission unit. (R 336.1290(b), R 336.1213(3)) 

b. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), 

the permittee shall maintain a written description of the control device, including the designed control 

efficiency and the designed exhaust gas flow rate. (R 336.1213(3)) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 29 of 76 

3. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), the 

permittee shall perform a monthly visible emission observation of each stack or vent during routine operating 

conditions. This observation need not be performed using Method 9. The permittee shall keep a written record 

of the results of each observation. (R 336.1213(3))

See Appendix 4 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1.8 

VIII. STACK/VENT RESTRICTION(S)

NA 

IX. OTHER REQUIREMENT(S)

NA 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 30 of 76 

FGCOLDCLNRS-S1 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Any cold cleaner that is grandfathered or exempt from Rule 201 pursuant to Rule 278 and Rule 281(h) or Rule 

285(r)(iv). Existing cold cleaners were placed into operation prior to July 1, 1979. New cold cleaners were placed 

into operation on or after July 1, 1979. 

Emission Unit: 

I. EMISSION LIMIT(S)

NA 

II. MATERIAL LIMIT(S)

1. The permittee shall not use cleaning solvents containing more than five percent by weight of the following 

halogenated compounds: methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, 

carbon tetrachloride, chloroform, or any combination thereof. (R 336.1213(2))

III. PROCESS/OPERATIONAL RESTRICTION(S)

1. Cleaned parts shall be drained for no less than 15 seconds or until dripping ceases. (R 336.1611(2)(b), 

R 336.1707(3)(b)) 

2. The permittee shall perform routine maintenance on each cold cleaner as recommended by the manufacturer. 

(R 336.1213(3))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The cold cleaner must meet one of the following design requirements: 

a. The air/vapor interface of the cold cleaner is no more than ten square feet. (R 336.1281(h)) 

b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general in-plant 

environment. (R 336.1285(r)(iv)) 

2. The cold cleaner shall be equipped with a device for draining cleaned parts. (R 336.1611(2)(b), 

R 336.1707(3)(b)) 

3. All new and existing cold cleaners shall be equipped with a cover and the cover shall be closed whenever parts 

are not being handled in the cold cleaner. (R 336.1611(2)(a), R 336.1707(3)(a)) 

4. The cover of a new cold cleaner shall be mechanically assisted if the Reid vapor pressure of the solvent is 

more than 0.3 psia or if the solvent is agitated or heated. (R 336.1707(3)(a)) 

5. If the Reid vapor pressure of any solvent used in a new cold cleaner is greater than 0.6 psia; or, if any solvent 

used in a new cold cleaner is heated above 120 degrees fahrenheit, then the cold cleaner must comply with at 

least one of the following provisions: 

a. The cold cleaner must be designed such that the ratio of the freeboard height to the width of the cleaner is 

equal to or greater than 0.7. (R 336.1707(2)(a)) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 31 of 76 

b. The solvent bath must be covered with water if the solvent is insoluble and has a specific gravity of more 

than 1.0. (R 336.1707(2)(b)) 

c. The cold cleaner must be controlled by a carbon adsorption system, condensation system, or other method 

of equivalent control approved by the AQD. (R 336.1707(2)(c))

V. TESTING/SAMPLING

NA 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii)) 

1. For each new cold cleaner in which the solvent is heated, the solvent temperature shall be monitored and 

recorded at least once each calendar week during routine operating conditions. (R 336.1213(3)) 

2. The permittee shall maintain the following information on file for each cold cleaner: (R 336.1213(3)) 

a. A serial number, model number, or other unique identifier for each cold cleaner. 

b. The date the unit was installed, manufactured or that it commenced operation. 

c. The air/vapor interface area for any unit claimed to be exempt under Rule 281(h). 

d. The applicable Rule 201 exemption. 

e. The Reid vapor pressure of each solvent used. 

f. If applicable, the option chosen to comply with Rule 707(2). 

3. The permittee shall maintain written operating procedures for each cold cleaner. These written procedures 

shall be posted in an accessible, conspicuous location near each cold cleaner. (R 336.1611(3), R 336.1707(4)) 

4. As noted in Rule 611(2)(c) and Rule 707(3)(c), if applicable, an initial demonstration that the waste solvent is a 

safety hazard shall be made prior to storage in non-closed containers. If the waste solvent is a safety hazard 

and is stored in non-closed containers, verification that the waste solvent is disposed of so that not more than 

20 percent, by weight, is allowed to evaporate into the atmosphere shall be made on a monthly basis. 

(R 336.1213(3), R 336.1611(2)(c), R 336.1707(3)(c))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 1.8 

VIII. STACK/VENT RESTRICTION(S)

NA 

IX. OTHER REQUIREMENT(S)

NA 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 32 of 76 

E. NON-APPLICABLE REQUIREMENTS

At the time of the ROP issuance, the AQD has determined that no non-applicable requirements have been 

identified for incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to 

Rule 213(6)(a)(ii). 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 33 of 76 

APPENDICES

Appendix 1.1: Abbreviations and Acronyms 

The following is an alphabetical listing of abbreviations/acronyms that may be used in this permit. 

AQD Air Quality Division MM Million 

acfm Actual cubic feet per minute MSDS Material Safety Data Sheet 

BACT Best Available Control Technology MW Megawatts

BTU British Thermal Unit NA Not Applicable 

°C Degrees Celsius NAAQS National Ambient Air Quality Standards 

CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air 

Pollutants 

CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds 

CEM Continuous Emission Monitoring NOx Oxides of Nitrogen 

CFR Code of Federal Regulations NSPS New Source Performance Standards 

CO Carbon Monoxide NSR New Source Review 

COM Continuous Opacity Monitoring PM Particulate Matter 

department Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns in 

diameter 

dscf Dry standard cubic foot pph Pound per hour 

dscm Dry standard cubic meter ppm Parts per million

EPA United States Environmental Protection Agency ppmv Parts per million by volume 

EU Emission Unit ppmw Parts per million by weight 

°F Degrees Fahrenheit PS Performance Specification 

FG Flexible Group PSD Prevention of Significant Deterioration 

GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute 

gr Grains psig Pounds per square inch gauge 

HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure 

Hg Mercury PTI Permit to Install 

hr Hour RACT Reasonable Available Control Technology 

HP Horsepower ROP Renewable Operating Permit 

H2S Hydrogen Sulfide SC Special Condition 

HVLP High Volume Low Pressure * scf Standard cubic feet 

ID Identification (Number) sec Seconds 

IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction 

ITSL Initial Threshold Screening Level SO2 Sulfur Dioxide 

LAER Lowest Achievable Emission Rate SRN State Registration Number 

lb Pound TAC Toxic Air Contaminant 

m Meter Temp Temperature 

MACT Maximum Achievable Control Technology THC Total Hydrocarbons 

MAERS Michigan Air Emissions Reporting System tpy Tons per year 

MAP Malfunction Abatement Plan μg Microgram 

MDEQ Michigan Department of Environmental Quality VE Visible Emissions 

mg Milligram VOC Volatile Organic Compounds 

mm Millimeter yr Year 

*For HVLP applicators, the pressure measured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig). 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 34 of 76 

Appendix 1.2. Schedule of Compliance 

The permittee certified in the ROP application that this stationary source is in compliance with all applicable 

requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of 

Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii)) 

Appendix 1.3. Monitoring Requirements 

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements 

identified and referenced in FGBOILERS1-4-S1. 

1.3.1 Continuous Emission Monitoring Systems (SO2)

The Continuous Emissions Monitoring Systems (CEMS) performance specifications defined in 40 CFR Part 75, 

Appendix B are adopted. The Certified SO2 monitor will be used to determine sulfur dioxide emissions. The data 

reduction procedures defined in R 336.2175 will be used to determine SO2 lbs/mmBtu. After the last day of each 

calendar month, the permittee shall generate and record from the CEMS data recording system a monthly average 

SO2 emission rate (lbs. SO2/mmBtu) from validated data reported for Part 75 for the previous month. 

1.3.2 Continuous Emissions Monitoring System (Title IV)

The CEMS performance specifications defined in 40 CFR Part 75, Appendix B are adopted. 

Methods of measurement, frequency of measurement and recordkeeping methods for CEMS required under 40 

CFR 75 are outlined in the most recent version of the Acid Rain Program - Detroit Edison Monroe Power Plant 

Monitoring Plan. 

Data Reporting: AQD may approve alternative data reporting or reduction procedures if it can be demonstrated 

that such procedures are at least as accurate as the procedures identified in R336.2175. 

1.3.3 Continuous Opacity Monitoring Systems

The Continuous Opacity Monitoring System (COMS) performance specifications defined in 40 CFR Part 60, 

Appendix B, are adopted. 

Cycling time for opacity: complete a minimum of one cycle of sampling/analysis for each successive 10-second 

period and one cycle of data recording for each successive 6-minute period. (R 336.2152)

Zero and Drift: The COMS must be subjected to the manufacturer’s zero and span check at least once daily. 

(R 336.2153)

Location: The location of the COMS or the monitoring devices must be such that representative measurement of 

emissions or process parameters are obtained. (R 336.2155)

Alternative Systems: AQD may approve the use of an alternative monitoring system if one is available that meets 

COMS objectives and if, because of physical limitations or other reasons, COMS cannot be installed or give 

accurate measurements. (R 336.2159) 

Monitoring and reporting requirements shall not apply during any period of monitoring system malfunction if it can 

be demonstrated to the satisfaction of AQD that the cause of the malfunction could not have been avoided by any 

reasonable action and necessary repairs are being made as expeditiously as practicable. 

(R 336.2190) 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 35 of 76 

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements 

identified and referenced in FG-COALHANDLING-S1. 

1.3.4 Fugitive Dust and Dust Collector – Emission Control Program

1. Once per day the permittee shall observe the dust collectors and controls to ensure proper operation. 

2. Once per day, the permittee shall perform a non-certified visible emissions observation of the dust collectors’ 

discharge to ensure there are no visible emissions being emitted. 

3. The facility shall keep daily records of the observations and shall be maintained on file for a period of 5 years 

and shall be made available upon request to AQD. 

4. In the event of visible emissions or a malfunction, permittee shall follow the procedures in the dust collector 

malfunction abatement plan. 

5. The facility shall keep records of all dust control measures done on the facility’s roadways and coal piles, 

including but not limited to, of watering, any surfactants applied, or any other measures used to control fugitive 

dust. 

Appendix 1.4. Recordkeeping 

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate source-wide, 

emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 1.5. Testing Procedures 

There are no specific testing requirement plans or procedures for this ROP. Therefore, this appendix is not 

applicable. 

Appendix 1.6. Permits to Install

The following table lists any PTIs issued since the effective date of previously issued ROP No. 199600201.

Permit to Install 

Number Description of Equipment 

Corresponding 

Emission Unit(s) or 

Flexible Group(s) 

349-00 Boiler 1 FG-BLR-1-4-S1 

375-00 Boiler 2 FG-BLR-1-4-S1 

376-00 Boiler 3 FG-BLR-1-4-S1 

377-00 Boiler 4 FG-BLR-1-4-S1 

68-05 Boiler 2 FG-BLR-1-4-S1 

222-05 Boiler 4 FG-BLR-1-4-S1 

330-05 Boiler 1 FG-BLR-1-4-S1 

194-06 Boiler 3 FG-BLR-1-4-S1 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 36 of 76 

Appendix 1.7. Emission Calculations 

There are no specific emission calculations to be used for this ROP. Therefore, this appendix is not applicable. 

Appendix 1.8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting Section of 

the Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Specific reporting requirement formats and procedures are detailed in Part A or the appropriate Source-Wide, 

Emission Unit and/or Flexible Group Special Conditions. Therefore, Part B of this appendix is not applicable. 

Appendix 1.9. Acid Rain Requirements 

The actual Acid Rain Permit as required by Title IV is on the following pages. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 37 of 76 

Michigan Department Of Environmental Quality 

Air Quality Division

PHASE II ACID RAIN PERMIT 

Permit No. MI-AR-1733-2009 

Permittee Detroit Edison – Monroe Power Plant 

Address 3500 Front Street, Monroe, MI 

SRN B2816 

ORIS code 1733 

Issue Date October 1, 2009 

Effective: Issuance date of this facility’s Renewable Operating Permit at 

the facility in accordance with 40 CFR 72.73. 

Expiration This permit shall expire when the facility’s Renewable 

Operating Permit expires, in accordance with 40 CFR 72.73. 

ROP No. MI-ROP-B2816-2009 

The Acid Rain Permit Contents 

1. A statement of basis prepared by the Air Quality Division (AQD) containing: 

References to statutory and regulatory authorities, and with comments, notes, and justification 

that apply to the source in general; 

2. Terms and conditions including: 

A table of sulfur dioxide allowances to be allocated during the term of the permit, if applicable, 

authorized by this permit during Phase II. Unless they are subject to sections 405(g)(2) or (3) of 

the Clean Air Act, new units are not allocated allowances in 40 CFR part 73 and must obtain 

allowances by other means (sec. 403(e) of the Clean Air Act).; 

Comments, notes and justifications regarding permit decisions and changes made to the permit 

application forms during the review process, and any additional requirements; and, 

Any applicable nitrogen oxides compliance plan. Unless they are coal fired utility units regulated 

pursuant to sections 404, 405, or 409 of the Clean Air Act, new units are not subject to the acid 

rain nitrogen oxides requirements [40 CFR 76.1(a)].

3. The permit application that this source submitted, as corrected by the AQD. The owners and 

operators of the source must comply with the standard requirements and special provisions set 

forth in the application. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 38 of 76 

Statement of Basis 

 

Statutory and Regulatory Authorities. 

In accordance with the Natural Resources and Environmental Protection Act, 1994 PA 451 and Titles IV 

and V of the Clean Air Act, the Michigan Department of Environmental Quality, Air Quality Division 

(AQD), issues this permit pursuant to the provisions of R 336.1210 to R 336.1218, and R 336.1299(d). 

For further information contact: 

 Brian Carley 

 Environmental Quality Specialist 

Michigan Department of Environmental Quality 

Air Quality Division 

301 Louis Glick Highway 

Jackson, Michigan 49201 

Telephone: (517) 780-7843 

Facsimile: (517) 780-7437 

 There are no comments, notes and/or justification that apply to the source in general for this 

section. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 39 of 76 

Terms and Conditions: 

Phase II Sulfur Dioxide Allowance Allocation and Nitrogen Oxides Requirements for each affected 

unit. 

 2009 2010 2011 2012 2013 

SO2

allowances 23,830 23,882 23,882 23,882 23,882 

Unit 1 

NOx limit 

NOx limit Pursuant to 40 CFR 76.11, the State of Michigan 

Department of Environmental Quality, Air Quality Division 

approves a NOx emissions averaging plan for this unit, effective 

from calendar years 2009 through 2013. Under the plan, this 

unit’s NOx emissions shall not exceed the annual average 

alternative contemporaneous emission limitation of 0.51 

lb/mmBtu. In addition, this unit shall not have an annual heat 

input less than 39,094,000 mmBtu. 

Under the plan, the actual Btu-weighted annual average NOx 

emission rate for the units in the plan shall be less than or equal 

to the Btu-weighted annual average NOx emission rate for the 

same units had they each been operated, during the same 

period of time, in compliance with the applicable emission 

limitations under 40 CFR 76.5, 76.6, or 76.7, except that for any 

early election units, the applicable emission limitations shall be 

under 40 CFR 76.7. If the designated representative

demonstrates that the requirement of the prior sentence (as set 

forth in 40 CFR 76.11(d)(1)(ii)(A)) is met for a year under the 

plan, then this unit shall be deemed to be in compliance for that 

year with its alternative contemporaneous annual emission 

limitation and annual heat input limit. 

In addition to the described NOX compliance plan, this unit shall 

comply with all other applicable requirements of 40 CFR part 

76, including the duty to reapply for a NOX compliance plan and 

requirements covering excess emissions. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 40 of 76 

Terms and Conditions: (continued) 

 2009 2010 2011 2012 2013 

SO2

allowances 24,731 24,785 24,785 24,785 24,785 

Unit 2 

NOx limit 

NOx limit Pursuant to 40 CFR 76.11, the State of Michigan 

Department of Environmental Quality, Air Quality Division 

approves a NOx emissions averaging plan for this unit, effective 

from calendar years 2009 through 2013. Under the plan, this 

unit’s NOx emissions shall not exceed the annual average 

alternative contemporaneous emission limitation of 0.51 

lb/mmBtu. In addition, this unit shall not have an annual heat 

input less than 50,700,000 mmBtu. 

Under the plan, the actual Btu-weighted annual average NOx 

emission rate for the units in the plan shall be less than or equal 

to the Btu-weighted annual average NOx emission rate for the 

same units had they each been operated, during the same 

period of time, in compliance with the applicable emission 

limitations under 40 CFR 76.5, 76.6, or 76.7, except that for any 

early election units, the applicable emission limitations shall be 

under 40 CFR 76.7. If the designated representative

demonstrates that the requirement of the prior sentence (as set 

forth in 40 CFR 76.11(d)(1)(ii)(A)) is met for a year under the 

plan, then this unit shall be deemed to be in compliance for that 

year with its alternative contemporaneous annual emission 

limitation and annual heat input limit. 

In addition to the described NOX compliance plan, this unit shall 

comply with all other applicable requirements of 40 CFR part 

76, including the duty to reapply for a NOX compliance plan and 

requirements covering excess emissions. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 41 of 76 

Terms and Conditions: (continued) 

 2009 2010 2011 2012 2013 

SO2

allowances 23,151 23,200 23,200 23,200 23,200 

Unit 3 

NOx limit 

NOx limit Pursuant to 40 CFR 76.11, the State of Michigan 

Department of Environmental Quality, Air Quality Division 

approves a NOx emissions averaging plan for this unit, effective 

from calendar years 2009 through 2013. Under the plan, this 

unit’s NOx emissions shall not exceed the annual average 

alternative contemporaneous emission limitation of 0.51 

lb/mmBtu. In addition, this unit shall not have an annual heat 

input less than 54,404,000 mmBtu. 

Under the plan, the actual Btu-weighted annual average NOx 

emission rate for the units in the plan shall be less than or equal 

to the Btu-weighted annual average NOx emission rate for the 

same units had they each been operated, during the same 

period of time, in compliance with the applicable emission 

limitations under 40 CFR 76.5, 76.6, or 76.7, except that for any 

early election units, the applicable emission limitations shall be 

under 40 CFR 76.7. If the designated representative

demonstrates that the requirement of the prior sentence (as set 

forth in 40 CFR 76.11(d)(1)(ii)(A)) is met for a year under the 

plan, then this unit shall be deemed to be in compliance for that 

year with its alternative contemporaneous annual emission 

limitation and annual heat input limit. 

In addition to the described NOX compliance plan, this unit shall 

comply with all other applicable requirements of 40 CFR part 

76, including the duty to reapply for a NOX compliance plan and 

requirements covering excess emissions. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 42 of 76 

Terms and Conditions: (continued) 

 2009 2010 2011 2012 2013 

SO2

allowances 25,424 25,478 25,478 25,478 25,478 

Unit 4 

NOx limit 

NOx limit Pursuant to 40 CFR 76.11, the State of Michigan 

Department of Environmental Quality, Air Quality Division 

approves a NOx emissions averaging plan for this unit, effective 

from calendar years 2009 through 2013. Under the plan, this 

unit’s NOx emissions shall not exceed the annual average 

alternative contemporaneous emission limitation of 0.51 

lb/mmBtu. In addition, this unit shall not have an annual heat 

input less than 54,418,000 mmBtu. 

Under the plan, the actual Btu-weighted annual average NOx 

emission rate for the units in the plan shall be less than or equal 

to the Btu-weighted annual average NOx emission rate for the 

same units had they each been operated, during the same 

period of time, in compliance with the applicable emission 

limitations under 40 CFR 76.5, 76.6, or 76.7, except that for any 

early election units, the applicable emission limitations shall be 

under 40 CFR 76.7. If the designated representative

demonstrates that the requirement of the prior sentence (as set 

forth in 40 CFR 76.11(d)(1)(ii)(A)) is met for a year under the 

plan, then this unit shall be deemed to be in compliance for that 

year with its alternative contemporaneous annual emission 

limitation and annual heat input limit. 

In addition to the described NOX compliance plan, this unit shall 

comply with all other applicable requirements of 40 CFR part 

76, including the duty to reapply for a NOX compliance plan and 

requirements covering excess emissions. 

Comments, notes and justifications regarding permit decisions, and changes made to the permit 

application forms during the review process: None.

Permit Application: (attached) 

 Acid Rain Permit Application submitted June 21, 2004 

 Phase NOx Compliance Plan submitted June 21, 2004 

 Phase II NOx Averaging Plan submitted June 21, 2004 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 43 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 44 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 45 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 46 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 47 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 48 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 49 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 50 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 51 of 76 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 52 of 76 

Appendix 1.10. CAIR Sulfur Dioxide Budget Requirements 

Michigan Department Of Environmental Quality 

Air Quality Division

CAIR Sulfur Dioxide Budget Permit 

Permit No. MI-SO2-1733-2009 

Permittee Detroit Edison – Monroe Power Plant 

Address 3500 Front Street, Monroe, MI 

SRN B2816 

ORIS code 1733 

Issue Date May 18, 2009 

Expiration This permit shall expire when the facility’s Renewable 

Operating Permit (ROP) expires in accordance with 40 CFR 

97.221(b). 

ROP No. MI-ROP-B2816-2009 

This permit incorporates automatically the definitions of terms under Air Pollution Control Rule 336.1420. 

This permit incorporates automatically, upon recordation by the EPA Administrator in accordance with 40 

CFR part 97 subpart FFF, GGG, or III every allocation, transfer, or deduction of a SO2 allowance to or 

from the compliance accounts of the CAIR SO2 unit(s) covered by the permit. 

The owners and operators of the source must comply with the standard requirements and special 

provisions set forth in this permit. 

This permit incorporates any attached comments, notes or justifications regarding permit decisions and

changes made to the permit application forms during the review process. 

Units covered under this permit 

AQD Unit ID Unit Type 

1 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

2 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

3 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

4 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

Permit Application: 

 CAIR SO2 Annual Permit application submitted June 27, 2008 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 53 of 76 

Standard requirements

(a) Permit requirements. 

(1) The CAIR designated representative of each CAIR SO2 source required to have a ROP and each CAIR SO2 

unit required to have a ROP at the source shall: 

 (i) Submit to the permitting authority a complete CAIR permit application under § 97.222 in accordance with 

the deadlines specified in § 97.221; and 

 (ii) Submit in a timely manner any supplemental information that the permitting authority determines is 

necessary in order to review a CAIR permit application and issue or deny a CAIR permit. 

(2) The owners and operators of each CAIR SO2 source required to have a ROP and each CAIR SO2 unit required 

to have a ROP at the source shall have a CAIR permit issued by the permitting authority under subpart CCC of 40 

CFR part 97 for the source and operate the source and the unit in compliance with such CAIR permit. 

 

(b) Monitoring, Reporting, and Recordkeeping Requirements. 

(1) The owners and operators, and the CAIR designated representative, of each CAIR SO2 source and each CAIR 

SO2 unit at the source shall comply with the monitoring, reporting, and recordkeeping requirements of subpart HHH 

of 40 CFR part 97. 

(2) The emissions measurements recorded and reported in accordance with subpart HHH of 40 CFR part 97 shall 

be used to determine compliance by each CAIR SO2 source with the CAIR SO2 emissions limitation under 

paragraph (c) of this permit. 

 

(c) Sulfur Dioxide Emission Requirements. 

(1) As of the allowance transfer deadline for a control period, the owners and operators of each CAIR SO2 source 

and each CAIR SO2 unit at the source shall hold, in the source’s compliance account, a tonnage equivalent in 

CAIR SO2 allowances available for compliance deductions for the control period, as determined in accordance with 

§ 97.254(a) and (b), not less than the tons of total sulfur dioxide emissions for the control period from all CAIR SO2 

units at the source, as determined in accordance with subpart HHH of 40 CFR part 97. 

(2) A CAIR SO2 unit shall be subject to the requirements under paragraph (c)(1) of this section for the control 

period starting on the later of January 1, 2010 or the deadline for meeting the unit(s monitor certification 

requirements under § 97.270(b)(1),(2), or (5) and for each control period thereafter. 

(3) A CAIR SO2 allowance shall not be deducted, for compliance with the requirements under paragraph (c)(1) of 

this section, for a control period in a calendar year before the year for which the CAIR SO2 allowance was 

allocated. 

(4) CAIR SO2 allowances shall be held in, deducted from, or transferred into or among CAIR SO2 Allowance 

Tracking System accounts in accordance with subparts FFF, GGG, and III of 40 CFR part 97. 

(5) A CAIR SO2 allowance is a limited authorization to emit sulfur dioxide in accordance with the CAIR SO2 

Trading Program. No provision of the CAIR SO2 Trading Program, the CAIR permit application, the CAIR permit, or 

an exemption under § 97.205 and no provision of law shall be construed to limit the authority of the United States to 

terminate or limit such authorization. 

(6) A CAIR SO2 allowance does not constitute a property right. 

(7) Upon recordation by the Administrator under subpart FFF, GGG, or III of 40 CFR part 97, every allocation, 

transfer, or deduction of a CAIR SO2 allowance to or from a CAIR SO2 source’s compliance account is 

incorporated automatically in any CAIR permit of the source. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 54 of 76 

(d) Excess emissions requirements.

If a CAIR SO2 source emits sulfur dioxide during any control period in excess of the CAIR SO2 emissions 

limitation, then: 

(1) The owners and operators of the source and each CAIR SO2 unit at the source shall surrender the CAIR SO2 

allowances required for deduction under § 97.254(d)(1) and pay any fine, penalty, or assessment or comply with 

any other remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and 

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of 

this subpart, the Clean Air Act, and applicable State law. 

(e) Recordkeeping and Reporting Requirements.

(1) Unless otherwise provided, the owners and operators of the CAIR SO2 source and each CAIR SO2 unit at the 

source shall keep on site at the source each of the following documents for a period of 5 years from the date the 

document is created. This period may be extended for cause, at any time before the end of 5 years, in writing by 

the permitting authority or the Administrator. 

 (i) The certificate of representation under § 97.213 for the CAIR designated representative for the source 

and each CAIR SO2 unit at the source and all documents that demonstrate the truth of the statements in

the certificate of representation; provided that the certificate and documents shall be retained on site at the 

source beyond such 5-year period until such documents are superseded because of the submission of a 

new certificate of representation under § 97.213 changing the CAIR designated representative. 

 (ii) All emissions monitoring information, in accordance with subpart HHH of 40 CFR part 97, provided that 

to the extent that subpart HHH of 40 CFR part 97 provides for a 3-year period for recordkeeping, the 3-year 

period shall apply. 

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or 

required under the CAIR SO2 Trading Program. 

 (iv) Copies of all documents used to complete a CAIR permit application and any other submission under 

the CAIR SO2 Trading Program or to demonstrate compliance with the requirements of the CAIR SO2 

Trading Program. 

(2) The CAIR designated representative of a CAIR SO2 source and each CAIR SO2 unit at the source shall submit 

the reports required under the CAIR SO2 Trading Program, including those under subpart HHH of 40 CFR part 97. 

(f) Liability. 

(1) Each CAIR SO2 source and each CAIR SO2 unit shall meet the requirements of the CAIR SO2 Trading 

Program. 

(2) Any provision of the CAIR SO2 Trading Program that applies to a CAIR SO2 source or the CAIR designated 

representative of a CAIR SO2 source shall also apply to the owners and operators of such source and of the CAIR 

SO2 units at the source. 

(3) Any provision of the CAIR SO2 Trading Program that applies to a CAIR SO2 unit or the CAIR designated 

representative of a CAIR SO2 unit shall also apply to the owners and operators of such unit. 

(g) Effect On Other Authorities. 

No provision of the CAIR SO2 Trading Program, a CAIR permit application, a CAIR permit, or an exemption under 

§ 97.205 shall be construed as exempting or excluding the owners and operators, and the CAIR designated 

representative, of a CAIR SO2 source or CAIR SO2 unit from compliance with any other provision of the 

applicable, approved State implementation plan, a federally enforceable permit, or the Clean Air Act. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 55 of 76 

Appendix 1.11. CAIR Annual Nitrogen Oxide Budget Permit 

Michigan Department Of Environmental Quality 

Air Quality Division

CAIR Annual Nitrogen Oxide Budget Permit 

Permit No. MI-NOA-1733-2009 

Permittee Detroit Edison – Monroe Power Plant 

Address 3500 Front Street, Monroe, MI 

SRN B2816 

ORIS code 1733 

Issue Date May 18, 2009 

Expiration This permit shall expire when the facility’s Renewable 

Operating Permit expires in accordance with Air Pollution 

Control Rule 336.1821. 

ROP No. MI-ROP-B2816-2009 

This permit incorporates automatically the definitions of terms under Air Pollution Control Rule 336.1803. 

This permit incorporates automatically, upon recordation by the EPA Administrator in accordance with Air 

Pollution Control Rule 336.1830, 336.1831 and 336.1834 every allocation, transfer, or deduction of a 

NOx allowance to or from the compliance accounts of the NOx Budget unit(s) covered by the permit. 

The owners and operators of the source must comply with the standard requirements and special 

provisions set forth in this permit. 

This permit incorporates any attached comments, notes or justifications regarding permit decisions and

changes made to the permit application forms during the review process. 

Units covered under this permit 

AQD Unit ID Unit Type 

1 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

2 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

3 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

4 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

Permit Application: 

 CAIR NOx Annual Permit application submitted June 27, 2008 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 56 of 76 

Standard Requirements 

 (a) Permit Requirements. 

(1) The CAIR designated representative of each CAIR NOX source required to have a Renewable Operating Permit 

(ROP) and each CAIR NOX unit required to have a ROP at the source shall: 

(i) Submit to the Michigan Department of Environmental Quality, Air Quality Division (MDEQ-AQD) a 

complete CAIR permit application under R 336.1821(3) in accordance with the deadlines specified in 40 

CFR 97.121; and 

(ii) Submit in a timely manner any supplemental information that the MDEQ-AQD determines is necessary 

in order to review a CAIR permit application and issue or deny a CAIR permit. 

(2) The owners and operators of each CAIR NOX source required to have a ROP and each CAIR NOX unit 

required to have a ROP at the source shall have a CAIR permit issued by the MDEQ-AQD under subpart CC of 40 

CFR part 97 for the source and operate the source and the unit in compliance with such CAIR permit. 

(b) Monitoring, Reporting, and Recordkeeping Requirements. 

(1) The owners and operators, and the CAIR designated representative, of each CAIR NOX source and each CAIR 

NOX unit at the source shall comply with the monitoring, reporting, and recordkeeping requirements of subpart HH 

of 40 CFR part 97. 

(2) The emissions measurements recorded and reported in accordance with subpart HH of 40 CFR part 97 shall be 

used to determine compliance by each CAIR NOX source with the CAIR NOX emissions limitation under paragraph 

(c) of this permit. 

(c) Nitrogen Oxides Emission Requirements. 

(1) As of the allowance transfer deadline for a control period, the owners and operators of each CAIR NOX source 

and each CAIR NOX unit at the source shall hold, in the source’s compliance account, CAIR NOX allowances 

available for compliance deductions for the control period under 40 CFR 97.154(a) in an amount not less than the 

tons of total nitrogen oxides emissions for the control period from all CAIR NOX units at the source, as determined 

in accordance with subpart HH of 40 CFR part 97. 

(2) A CAIR NOX unit shall be subject to the requirements under paragraph (c)(1) for the control period starting on 

the later of January 1, 2009 or the deadline for meeting the unit’s monitor certification requirements under 40 CFR 

97.170(b)(1), (2), or (5) and for each control period thereafter. 

(3) A CAIR NOX allowance shall not be deducted, for compliance with the requirements under paragraph (c)(1) of 

this section, for a control period in a calendar year before the year for which the CAIR NOX allowance was 

allocated. 

(4) CAIR NOX allowances shall be held in, deducted from, or transferred into or among CAIR NOX Allowance 

Tracking System accounts in accordance with subparts EE, FF, GG, or II of 40 CFR part 97. 

(5) A CAIR NOX Ozone Season allowance is a limited authorization to emit one ton of nitrogen oxides in

accordance with the CAIR NOX Ozone Season Trading Program. No provision of the CAIR NOX Ozone Season 

Trading Program, the CAIR permit application, the CAIR permit, or an exemption under § 97.105 and no provision 

of law shall be construed to limit the authority of the United States to terminate or limit such authorization. 

(6) A CAIR NOX allowance is a limited authorization to emit one ton of nitrogen oxides in accordance with the CAIR 

NOX Annual Trading Program. No provision of the CAIR NOX Annual Trading Program, the CAIR permit 

application, the CAIR permit, or an exemption under 40 CFR 97.105 and no provision of law shall be construed to 

limit the authority of the United States to terminate or limit such authorization. 

(7) A CAIR NOX allowance does not constitute a property right. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 57 of 76 

(8) Upon recordation by the Administrator under subpart EE, FF, GG, or II of 40 CFR part 97, every allocation, 

transfer, or deduction of a CAIR NOX allowance to or from a CAIR NOX source’s compliance account is 

incorporated automatically in any CAIR permit of the source. 

(d) Excess Emissions Requirements. 

If a CAIR NOX source emits nitrogen oxides during any control period in excess of the CAIR NOX emissions 

limitation, then: 

(1) The owners and operators of the source and each CAIR NOX unit at the source shall surrender the CAIR NOX 

allowances required for deduction under 40 CFR 97.154(d)(1) and pay any fine, penalty, or assessment or comply 

with any other remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and 

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of 

40 CFR part 97, the Clean Air Act, and applicable State rules. 

(e) Recordkeeping and Reporting Requirements.

(1) Unless otherwise provided, the owners and operators of the CAIR NOX source and each CAIR NOX unit at the 

source shall keep on site at the source each of the following documents for a period of 5 years from the date the 

document is created. This period may be extended for cause, at any time before the end of 5 years, in writing by 

the MDEQ-AQD or the Administrator. 

(i) The certificate of representation under § 97.113 for the CAIR designated representative for the source 

and each CAIR NOX unit at the source and all documents that demonstrate the truth of the statements in

the certificate of representation; provided that the certificate and documents shall be retained on site at the 

source beyond such 5-year period until such documents are superseded because of the submission of a 

new certificate of representation under § 97.113 changing the CAIR designated representative. 

(ii) All emissions monitoring information, in accordance with subpart HH of 40 CFR part 97. 

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required 

under the CAIR NOX Annual Trading Program. 

(iv) Copies of all documents used to complete a CAIR permit application and any other submission under

the CAIR NOX Annual Trading Program or to demonstrate compliance with the requirements of the CAIR 

NOX Annual Trading Program. 

(2) The CAIR designated representative of a CAIR NOX source and each CAIR NOX unit at the source shall submit 

the reports required under the CAIR NOX Annual Trading Program, including those under subpart HH of 40 CFR 

part 97. 

(f) Liability. 

(1) Each CAIR NOX source and each CAIR NOX unit shall meet the requirements of the CAIR NOX Annual 

Trading Program. 

(2) Any provision of the CAIR NOX Annual Trading Program that applies to a CAIR NOX source or the CAIR

designated representative of a CAIR NOX source shall also apply to the owners and operators of such source and 

of the CAIR NOX units at the source. 

(3) Any provision of the CAIR NOX Annual Trading Program that applies to a CAIR NOX unit or the CAIR 

designated representative of a CAIR NOX unit shall also apply to the owners and operators of such unit. 

(g) Effect on Other Authorities. 

No provision of the CAIR NOX Annual Trading Program, a CAIR permit application, a CAIR permit, or an 

exemption under § 97.105 shall be construed as exempting or excluding the owners and operators, and the CAIR 

designated representative, of a CAIR NOX source or CAIR NOX unit from compliance with any other provision of 

the applicable, approved State implementation plan, a federally enforceable permit, or the Clean Air Act. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 58 of 76 

Appendix 1.12. CAIR Ozone Nitrogen Oxide Budget Permit 

Michigan Department Of Environmental Quality 

Air Quality Division

CAIR Ozone Nitrogen Oxide Budget Permit 

Permit No. MI-NOO-1733-2009 

Permittee Detroit Edison – Monroe Power Plant 

Address 3500 Front Street, Monroe, MI 

SRN B2816 

ORIS code 1733 

Issue Date May 18, 2009 

Expiration This permit shall expire when the facility’s Renewable 

Operating Permit expires in accordance with Air Pollution 

Control Rule 336.1821. 

ROP No. MI-ROP-B2816-2009 

This permit incorporates automatically the definitions of terms under Air Pollution Control Rule 336.1803. 

This permit incorporates automatically, upon recordation by the EPA Administrator in accordance with Air 

Pollution Control Rule 336.1822, 336.1823 and 336.1834 every allocation, transfer, or deduction of a 

NOx allowance to or from the compliance accounts of the NOx Budget unit(s) covered by the permit. 

The owners and operators of the source must comply with the standard requirements and special 

provisions set forth in this permit. 

This permit incorporates any attached comments, notes or justifications regarding permit decisions and

changes made to the permit application forms during the review process. 

Units covered under this permit 

AQD Unit ID Unit Type 

1 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

2 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

3 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

4 X Stationary Boiler Combined Cycle 

System 

 Combustion 

Turbine 

 Other 

Permit Application: 

 CAIR NOx Ozone Season Permit application submitted June 27, 2008 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 59 of 76 

Standard Requirements 

 (a) Permit Requirements. 

(1) The CAIR designated representative of each CAIR NOX source required to have a Renewable Operating Permit 

(ROP) and each CAIR NOX unit required to have a ROP at the source shall: 

(i) Submit to the Michigan Department of Environmental Quality, Air Quality Division (MDEQ-AQD) a 

complete CAIR permit application under R 336.1821(3) in accordance with the deadlines specified in 40 

CFR 97.321; and 

(ii) Submit in a timely manner any supplemental information that the MDEQ-AQD determines is necessary 

in order to review a CAIR permit application and issue or deny a CAIR permit. 

(2) The owners and operators of each CAIR NOX source required to have a ROP and each CAIR NOX unit 

required to have a ROP at the source shall have a CAIR permit issued by the MDEQ-AQD under subpart CCCC of 

40 CFR part 97 for the source and operate the source and the unit in compliance with such CAIR permit.

(b) Monitoring, Reporting, and Recordkeeping Requirements. 

(1) The owners and operators, and the CAIR designated representative, of each CAIR NOX source and each CAIR 

NOX unit at the source shall comply with the monitoring, reporting, and recordkeeping requirements of subpart 

HHHH of 40 CFR part 97. 

(2) The emissions measurements recorded and reported in accordance with subpart HHHH of 40 CFR part 97 shall 

be used to determine compliance by each CAIR NOX source with the CAIR NOX emissions limitation under 

paragraph (c) of this permit. 

(c) Nitrogen Oxides Emission Requirements. 

(1) As of the allowance transfer deadline for a control period, the owners and operators of each CAIR NOX source 

and each CAIR NOX unit at the source shall hold, in the source’s compliance account, CAIR NOX allowances 

available for compliance deductions for the control period under 40 CFR 97.354(a) in an amount not less than the 

tons of total nitrogen oxides emissions for the control period from all CAIR NOX units at the source, as determined 

in accordance with subpart HHHH of 40 CFR part 97. 

(2) A CAIR NOX unit shall be subject to the requirements under paragraph (c)(1) for the control period starting on 

the later of January 1, 2009 or the deadline for meeting the unit’s monitor certification requirements under 40 CFR 

97.370(b)(1), (2), (3) or (7) and for each control period thereafter. 

(3) A CAIR NOX allowance shall not be deducted, for compliance with the requirements under paragraph (c)(1) of 

this permit, for a control period in a calendar year before the year for which the CAIR NOX allowance was 

allocated. 

(4) CAIR NOX allowances shall be held in, deducted from, or transferred into or among CAIR NOX Allowance 

Tracking System accounts in accordance with subparts EEEE, FFFF, GGGG, or IIII of 40 CFR part 97. 

(5) A CAIR NOX Ozone Season allowance is a limited authorization to emit one ton of nitrogen oxides in

accordance with the CAIR NOX Ozone Season Trading Program. No provision of the CAIR NOX Ozone Season 

Trading Program, the CAIR permit application, the CAIR permit, or an exemption under § 97.305 and no provision 

of law shall be construed to limit the authority of the United States to terminate or limit such authorization. 

(6) A CAIR NOX allowance does not constitute a property right. 

(7) Upon recordation by the Administrator under subpart EEEE, FFFF, GGGG, or IIII of 40 CFR part 97, every 

allocation, transfer, or deduction of a CAIR NOX allowance to or from a CAIR NOX source’s compliance account is 

incorporated automatically in any CAIR permit of the source. 
Section 1 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 60 of 76 

(d) Excess Emissions Requirements. 

If a CAIR NOX source emits nitrogen oxides during any control period in excess of the CAIR NOX emissions 

limitation, then: 

(1) The owners and operators of the source and each CAIR NOX unit at the source shall surrender the CAIR NOX 

allowances required for deduction under 40 CFR 97.354(d)(1) and pay any fine, penalty, or assessment or comply 

with any other remedy imposed, for the same violations, under the Clean Air Act or applicable State law; and 

(2) Each ton of such excess emissions and each day of such control period shall constitute a separate violation of 

40 CFR part 97, the Clean Air Act, and applicable State rules. 

(e) Recordkeeping and Reporting Requirements.

(1) Unless otherwise provided, the owners and operators of the CAIR NOX source and each CAIR NOX unit at the 

source shall keep on site at the source each of the following documents for a period of 5 years from the date the 

document is created. This period may be extended for cause, at any time before the end of 5 years, in writing by 

the MDEQ-AQD or the Administrator. 

(i) The certificate of representation under § 97.313 for the CAIR designated representative for the source 

and each CAIR NOX unit at the source and all documents that demonstrate the truth of the statements in

the certificate of representation; provided that the certificate and documents shall be retained on site at the 

source beyond such 5-year period until such documents are superseded because of the submission of a 

new certificate of representation under § 97.313 changing the CAIR designated representative. 

(ii) All emissions monitoring information, in accordance with subpart HHHH of 40 CFR part 97. 

(iii) Copies of all reports, compliance certifications, and other submissions and all records made or required 

under the CAIR NOX Ozone Trading Program. 

(iv) Copies of all documents used to complete a CAIR permit application and any other submission under

the CAIR NOX Ozone Trading Program or to demonstrate compliance with the requirements of the CAIR 

NOX Ozone Trading Program. 

(2) The CAIR designated representative of a CAIR NOX source and each CAIR NOX unit at the source shall submit 

the reports required under the CAIR NOX Ozone Trading Program, including those under subpart HHHH of 40 CFR 

part 97. 

(f) Liability. 

(1) Each CAIR NOX source and each CAIR NOX unit shall meet the requirements of the CAIR NOX Ozone Trading 

Program. 

(2) Any provision of the CAIR NOX Ozone Trading Program that applies to a CAIR NOX source or the CAIR 

designated representative of a CAIR NOX source shall also apply to the owners and operators of such source and 

of the CAIR NOX units at the source. 

(3) Any provision of the CAIR NOX Ozone Trading Program that applies to a CAIR NOX unit or the CAIR 

designated representative of a CAIR NOX unit shall also apply to the owners and operators of such unit. 

(g) Effect on Other Authorities. 

No provision of the CAIR NOX Ozone Trading Program, a CAIR permit application, a CAIR permit, or an 

exemption under § 97.305 shall be construed as exempting or excluding the owners and operators, and the CAIR 

designated representative, of a CAIR NOX source or CAIR NOX unit from compliance with any other provision of 

the applicable, approved State implementation plan, a federally enforceable permit, or the Clean Air Act.
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a 

Page 61 of 76 

STATE OF MICHIGAN 

RENEWABLE OPERATING PERMIT 

SECTION 2 

Detroit Edison 

Monroe Power Plant 

SRN: B2816 

LOCATED AT 

3500 E. Front St. 

Monroe, MI 48161 

 

Permit Number: MI-ROP-B2816-2009a 

Effective Date: October 1, 2009 

Expiration Date: October 1, 2014 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 62 of 76 

AUTHORITY AND ENFORCEABILITY 

For the purpose of this permit, the permittee is defined as any person who owns or operates an 

emission unit at a stationary source for which this permit has been issued. The department is defined in 

Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her 

designee. 

The permittee shall comply with all specific details in the permit terms and conditions and the cited 

underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable 

and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most

stationary sources for which an ROP has been issued. These general conditions are included in Part A 

of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units

which are represented as a flexible group, or the entire stationary source which is represented as a 

source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices. 

In accordance with Rule 213(2)(a), all underlying applicable requirements will be identified for each ROP 

term or condition. All terms and conditions that are included in a PTI, are streamlined or subsumed, or is 

state only enforceable will be noted as such. 

In accordance with Section 5507 of Act 451, the permittee has included in the ROP application a 

compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements 

with which the source is in compliance, the source will continue to comply with these requirements. For 

applicable requirements with which the source is not in compliance, the source will comply with the 

detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. 

Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the 

stationary source will meet the requirements on a timely basis, unless the underlying applicable 

requirement requires a more detailed schedule of compliance. 

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law. 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 63 of 76 

A. GENERAL CONDITIONS 

Permit Enforceability 

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. 

(R 336.1213(5))

• Those conditions that are hereby incorporated in a state only enforceable Source-wide PTI pursuant to Rule 

201(2)(d) are designated by footnote one. (R 336.1213(5)(a), R336.1214a(5))

• Those conditions that are hereby incorporated in federally enforceable Source- wide PTI No. MI-PTI-B2816-

20082009a pursuant to Rule 201(2)(c) are designated by footnote two. (R 336.1213(5)(b), R 336.1214a(3))

General Provisions 

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of 

Act 451, and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of 

the ROP. All terms and conditions of this ROP that are designated as federally enforceable are enforceable by 

the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the 

provisions of the federal Clean Air Act (CAA). Any terms and conditions based on applicable requirements 

which are designated as “state only” are not enforceable by the USEPA or citizens pursuant to the CAA. 

(R 336.1213(1)(a))

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or 

reduce the permitted activity in order to maintain compliance with the conditions of this ROP. 

(R 336.1213(1)(b))

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit 

modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does 

not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make 

changes, at the permittee’s own risk, pursuant to Rule 215 and Rule 216. (R 336.1213(1)(c))

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation 

of credentials and other documents as may be required by law and upon stating the authority for and purpose 

of the investigation, to perform any of the following activities (R 336.1213(1)(d)): 

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity is 

conducted or where records must be kept under the conditions of the ROP. 

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the 

ROP. 

c. Inspect, at reasonable times, any of the following: 

i. Any stationary source. 

ii. Any emission unit. 

iii. Any equipment, including monitoring and air pollution control equipment. 

iv. Any work practices or operations regulated or required under the ROP. 

d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the ROP or applicable requirements. 

5. The permittee shall furnish to the department, within a reasonable time, any information the department may 

request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to 

determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies 

of any records that are required to be kept as a term or condition of this ROP. For information which is claimed 

by the permittee to be confidential, consistent with the requirements of the 1976 PA 442, MCL §15.231 et seq., 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 64 of 76 

and known as the Freedom of Information Act, the person may also be required to furnish the records directly 

to the USEPA together with a claim of confidentiality. (R 336.1213(1)(e))

6. A challenge by any person, the Administrator of the USEPA, or the department to a particular condition or a 

part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any 

other condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of 

Act 451. (R 336.1213(1)(g))

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

Equipment & Design 

10. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to 

minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370)

11. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance 

with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

Emission Limits 

13. Except as provided in Subrules 2, 3, and 4 of Rule 301, states in part; “a person shall not cause or permit to be 

discharged into the outer air from a process or process equipment a visible emission of a density greater than 

the most stringent of Rule 301(1)(a) or (b) unless otherwise specified in this ROP.” The grading of visible 

emissions shall be determined in accordance with Rule 303. (R 336.1301(1) in pertinent part): 

a. A 6-minute average of 20 percent opacity, except for one 6-minute average per hour of not more than 27 

percent opacity. 

b. A limit specified by an applicable federal new source performance standard. 

14. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, 

alone or in reaction with other air contaminants, either of the following: 

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.1 

(R 336.1901(a)) 

b. Unreasonable interference with the comfortable enjoyment of life and property. 1 (R 336.1901(b)) 

Testing/Sampling 

16. The department may require the owner or operator of any source of an air contaminant to conduct acceptable 

performance tests, at the owner’s or operator’s expense, in accordance with Rule 1001 and Rule 1003, under 

any of the conditions listed in Rule 1001(1). (R 336.2001)

17. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and 

Rule 1003. (R 336.2001(2), R 336.2001(3), R 336.2003(1))

18. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the 

applicable reference test method within 60 days following the last date of the test. (R 336.2001(4))
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 65 of 76 

Monitoring/Recordkeeping 

19. Records of any periodic emission or parametric monitoring required in this ROP shall include the following 

information specified in Rule 213(3)(b)(i), where appropriate (R 336.1213(3)(b)): 

a. The date, location, time, and method of sampling or measurements. 

b. The dates the analyses of the samples were performed. 

c. The company or entity that performed the analyses of the samples. 

d. The analytical techniques or methods used. 

e. The results of the analyses. 

f. The related process operating conditions or parameters that existed at the time of sampling or 

measurement. 

20. All required monitoring data, support information and all reports, including reports of all instances of deviation 

from permit requirements, shall be kept and furnished to the department upon request for a period of not less 

than 5 years from the date of the monitoring sample, measurement, report or application. Support information 

includes all calibration and maintenance records and all original strip-chart recordings, or other original data 

records, for continuous monitoring instrumentation and copies of all reports required by the ROP. 

(R 336.1213(1)(e), R 336.1213(3)(b)(ii))

Certification & Reporting 

21. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be 

submitted to the department as a term or condition of this ROP shall contain an original certification by a 

responsible official which states that, based on information and belief formed after reasonable inquiry, the 

statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

22. A responsible official shall certify to the appropriate AQD District Office and to the USEPA that the stationary 

source is and has been in compliance with all terms and conditions contained in the ROP except for deviations 

that have been or are being reported to the appropriate AQD District Office pursuant to Rule 213(3)(c). This 

certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and shall state that, based 

on information and belief formed after reasonable inquiry, the statements and information in the certification are 

true, accurate, and complete. The USEPA address is: USEPA, Air Compliance Data - Michigan, Air and 

Radiation Division, 77 West Jackson Boulevard, Chicago, Illinois 60604. (R 336.1213(4)(c))

23. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special 

conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

24. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt 

reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise 

described in this ROP. (R 336.1213(3)(c))

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting 

consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to 

this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). 

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to 

Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the 

semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and 

the actions taken to minimize or correct each deviation. 

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the 

reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe 

the reasons for each deviation and the actions taken to minimize or correct each deviation. 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 66 of 76 

26. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in 

Rule 213(3)(c)(iii) as either of the following (R 336.1213(3)(c)): 

a. Submitting a certification by a responsible official with each report which states that, based on information 

and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports 

of deviations from the emissions allowed under the ROP were submitted to the department pursuant to 

Rule 213(3)(c)(ii), a certification by a responsible official which states that, “based on information and belief 

formed after reasonable inquiry, the statements and information contained in each of the reports submitted 

during the previous month were true, accurate, and complete”. The certification shall include a listing of the 

reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a 

monthly basis pursuant to this paragraph shall include a statement that certification of the report will be 

provided within 30 days following the end of the calendar month. 

27. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the 

permittee shall submit certified reports of any required monitoring to the appropriate AQD District Office. All 

instances of deviations from ROP requirements during the reporting period shall be clearly identified in the 

reports. (R 336.1213(3)(c)(i))

28. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine 

the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing 

the emissions inventory forms provided by the department. (R 336.1212(6))

29. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in 

emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable 

standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an 

applicable standard or limitation, as required in Rule 912, to the appropriate AQD District Office. The notice shall 

be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal conditions 

or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, or oral communication. 

Written reports, if required under Rule 912, must be submitted to the appropriate AQD District Supervisor within 10 

days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been 

corrected, or within 30 days of discovery of the abnormal conditions or malfunction, whichever is first. The written 

reports shall include all of the information required in Rule 912(5) and shall be certified by a responsible official in a 

manner consistent with the CAA. (R 336.1912)

Permit Shield 

27. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements 

as of the date of ROP issuance, if either of the following provisions is satisfied. (R 336.1213(6)(a)(i), 

R 336.1213(6)(a)(ii))

a. The applicable requirements are included and are specifically identified in the ROP. 

b. The permit includes a determination or concise summary of the determination by the department that other 

specifically identified requirements are not applicable to the stationary source. 

Any requirements identified in Part E of this ROP have been identified as non-applicable to this ROP and are 

included in the permit shield. 

28. Nothing in this ROP shall alter or affect any of the following: 

d. The provisions of Section 303 of the CAA, emergency orders, including the authority of the USEPA under 

Section 303 of the CAA. (R 336.1213(6)(b)(i))

e. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at 

the time of this ROP issuance. (R 336.1213(6)(b)(ii))

f. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. 

(R 336.1213(6)(b)(iii)) 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 67 of 76 

e. The ability of the USEPA to obtain information from a source pursuant to Section 114 of the CAA. 

(R 336.1213(6)(b)(iv))

29. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the 

following: 

f. Operational flexibility changes made pursuant to Rule 215. (R 336.1215(5))

g. Administrative Amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.1216(1)(b)(iii))

h. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved 

by the department. (R 336.1216(1)(c)(iii))

i. Minor Permit Modifications made pursuant to Rule 216(2). (R 336.1216(2)(f))

j. State-Only Modifications made pursuant to Rule 216(4) until the changes have been approved by the 

department. (R 336.1216(4)(e))

34. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete 

application for renewal is submitted not more than 18 months, but not less than 6 months, before the expiration 

date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP 

does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original 

ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))

Revisions 

35. For changes to any process or process equipment covered by this ROP that do not require a revision of the 

ROP pursuant to Rule 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

36. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to 

Rule 216(1). (R 336.1219(2))

37. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by 

the department in accordance with the time frames specified in Rule 216. (R 336.1210(9))

38. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the 

department takes final action, the permittee shall comply with both the applicable requirements governing the 

change and the ROP terms and conditions proposed in the application for the modification. During this time 

period, the permittee may choose to not comply with the existing ROP terms and conditions that the application 

seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the 

application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(iii), 

R 336.1216(2)(d), R 336.1216(4)(d))

Reopenings 

39. A ROP shall be reopened by the department prior to the expiration date and revised by the department under 

any of the following circumstances: 

a. If additional requirements become applicable to this stationary source with three or more years remaining in 

the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 

expiration date. (R 336.1217(2)(a)(i))

b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. 

(R 336.1217(2)(a)(ii))

c. If the department determines that the ROP contains a material mistake, information required by any 

applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or 

the terms or conditions of the ROP. (R 336.1217(2)(a)(iii))

d. If the department determines that the ROP must be revised to ensure compliance with the applicable 

requirements. (R 336.1217(2)(a)(iv))
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 68 of 76 

Renewals 

40. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by 

the department not more than 18 months, but not less than 6 months, before the expiration date of the ROP. 

(R 336.1210(7))

Stratospheric Ozone Protection 

41. If the permittee is subject to Title 40 of the Code of Federal Regulations (CFR), Part 82 and services, 

maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of appliances 

containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaimer, 

appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall 

comply with all applicable standards for recycling and emissions reduction pursuant to 40 CFR, Part 82, 

Subpart F. 

42. If the permittee is subject to 40 CFR, Part 82, and performs a service on motor (fleet) vehicles when this 

service involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified 

in 40 CFR, Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term “motor vehicle” as used 

in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the 

original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed 

refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using 

Hydrochlorofluorocarbon-22 refrigerant. 

Risk Management Plan 

43. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall register and submit to the 

USEPA the required data related to the risk management plan for reducing the probability of accidental

releases of any regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in 40 CFR, 

Part 68.130. The list of substances, threshold quantities, and accident prevention regulations promulgated 

under 40 CFR, Part 68, do not limit in any way the general duty provisions under Section 112(r)(1). 

44. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall comply with the requirements 

of 40 CFR, Part 68, no later than the latest of the following dates as provided in 40 CFR, Part 68.10(a): 

a. June 21, 1999, 

b. Three years after the date on which a regulated substance is first listed under 40 CFR, Part 68.130, or 

c. The date on which a regulated substance is first present above a threshold quantity in a process. 

45. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall submit any additional relevant 

information requested by any regulatory agency necessary to ensure compliance with the requirements of 

40 CFR, Part 68. 

46. If subject to Section 112(r) of the CAA and 40 CFR, Part 68, the permittee shall annually certify compliance with 

all applicable requirements of Section 112(r) as detailed in Rule 213(4)(c)). (40 CFR, Part 68)

Emission Trading 

47. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or 

regional emission trading program that has been approved by the Administrator of the USEPA as a part of 

Michigan’s State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. 

(R 336.1213(12))
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 69 of 76 

Permit To Install (PTI) 

48. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified 

unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt 

from the PTI requirements by any applicable rule. 2 (R 336.1201(1)) 

49. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence 

indicates the process or process equipment is not performing in accordance with the terms and conditions of 

the PTI or is violating the department’s rules or the CAA. 2 (R 336.1201(8), Section 5510 of Act 451) 

50. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or 

operates the process or process equipment at the location authorized by the PTI. If a new owner or operator 

submits a written request to the department pursuant to Rule 219 and the department approves the request, 

this PTI will be amended to reflect the change of ownership or operational control. The request must include all 

of the information required by Subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the 

appropriate AQD District Supervisor, MDEQ. 2 (R 336.1219) 

51. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and 

conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, 

the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the

department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall 

notify the department via the Supervisor, Permit Section, MDEQ, AQD, P. O. Box 30260, Lansing, Michigan 

48909, if it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment 

allowed by the terms and conditions from that PTI. 2 (R 336.1201(4)) 

Footnotes: 

1

This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2

This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

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Page 70 of 76 

B. SOURCE-WIDE CONDITIONS 

Part B outlines the source-wide terms and conditions that apply to this stationary source. The permittee is subject 

to these special conditions for the stationary source in addition to the General Conditions in Part A and any other 

terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in 

the table. If there are no source-wide conditions, this section will be left blank. 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 71 of 76 

C. EMISSION UNIT CONDITIONS 

Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit 

Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General 

Conditions in Part A and any other terms and conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no conditions specific to individual emission units, this section will be left blank. 

EMISSION UNIT SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID 

Emission Unit Description 

(Including Process Equipment & Control 

Device(s)) 

Installation 

Date/ 

Modification Date

Flexible Group ID 

EU-DIESEL11-1-S2 Diesel Generator Peaking Units DG 11-1 N/A FGPEAKERS-S2 

EU-DIESEL11-2-S2 Diesel Generator Peaking Units DG 11-2 N/A FGPEAKERS-S2 

EU-DIESEL11-3-S2 Diesel Generator Peaking Units DG 11-3 N/A FGPEAKERS-S2 

EU-DIESEL11-4-S2 Diesel Generator Peaking Units DG 11-4 N/A FGPEAKERS-S2 

EU-DIESEL11-5-S2 Diesel Generator Peaking Units DG 11-5 N/A FGPEAKERS-S2 

D. FLEXIBLE GROUP CONDITIONS 

Part D outlines terms and conditions that apply to more than one emission unit. The permittee is subject to the 

special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and 

conditions contained in this ROP. 

The permittee shall comply with all specific details in the special conditions and the underlying applicable 

requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If 

there are no special conditions that apply to more than one emission unit, this section will be left blank. 

FLEXIBLE GROUP SUMMARY TABLE 

The descriptions provided below are for informational purposes and do not constitute 

enforceable conditions. 

Flexible Group ID Flexible Group Description Associated 

Emission Unit IDs 

FGPEAKERS-S2 Diesel Generator Peaking Units EU-DIESEL11-1-S2, EUDIESEL11-2-S2, EUDIESEL11-3-S2, EUDIESEL11-4-S2, EUDIESEL11-5-S2
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 72 of 76 

FGPEAKERS-S2 

FLEXIBLE GROUP CONDITIONS

DESCRIPTION: Five diesel generator peaking units

Emission Units: EU-DIESEL11-1-S2, EU-DIESEL11-2-S2, EU-DIESEL11-3-S2, EU-DIESEL11-4-S2, EUDIESEL11-5-S2 

POLLUTION CONTROL EQUIPMENT

I. EMISSION LIMIT(S) 

Pollutant Limit 

Time Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

NA NA NA NA NA NA 

II. MATERIAL LIMIT(S)

Material Limit 

Time 

Period/ 

Operating 

Scenario 

Equipment Monitoring/ 

Testing Method

Underlying 

Applicable 

Requirements

1. #2 Fuel Oil 

1.0% sulfur by 

weight with a 

heat value of 

18,000 Btu/lb a

As Fired FGPEAKERS-S2 S.C. IV.1 R 336.1401 

a - This is equivalent to 1.11 lb SO2/mmBtu of heat input. Compliance with this limit shall be considered 

compliance with the limit of R336.1401. 

III. PROCESS/OPERATIONAL RESTRICTION(S) 

1. N/A 

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. N/A 

V. TESTING/SAMPLING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. N/A 

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))

1. The permittee shall record the monthly fuel usage rates in gallons. (R 336.1213(3)(b)) 

2. The permittee shall maintain a record of the analysis of the fuel oil. These records may include purchase 

records for ASTM specification fuel oil, specifications or analyses provided by the vendor at the time of delivery, 

analytical results from laboratory testing, or any other records adequate to demonstrate compliance with the 

percent sulfur limit in fuel oil. (R 336.1213(3)(b)) 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 73 of 76 

See Appendix 2.3 

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii)) 

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall 

be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to 

December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i)) 

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be 

postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. 

(R 336.1213(4)(c))

See Appendix 2.8 

VIII. STACK/VENT RESTRICTION(S)

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to 

the ambient air unless otherwise noted: 

Stack & Vent ID Maximum 

Exhaust 

Dimensions 

(inches) 

Minimum Height 

Above Ground 

(feet) 

Underlying Applicable 

Requirements 

1. 

IX. OTHER REQUIREMENT(S)

1. NA 

Footnotes: 

1 This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 

2 This condition is federally enforceable and was established pursuant to Rule 201(1)(a). 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 74 of 76 

E. NON-APPLICABLE REQUIREMENTS 

At the time of ROP issuance, the AQD has determined that no non-applicable requirements have been identified for 

incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to Rule 

213(6)(a)(ii). 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 75 of 76 

APPENDICES

Appendix 2.1: Abbreviations & Acronyms 

The following is an alphabetical listing of abbreviations/acronyms that may be used in this permit. 

AQD Air Quality Division MM Million 

acfm Actual cubic feet per minute MSDS Material Safety Data Sheet 

BACT Best Available Control Technology MW Megawatts

BTU British Thermal Unit NA Not Applicable 

°C Degrees Celsius NAAQS National Ambient Air Quality Standards 

CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air 

Pollutants 

CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds 

CEM Continuous Emission Monitoring NOx Oxides of Nitrogen 

CFR Code of Federal Regulations NSPS New Source Performance Standards 

CO Carbon Monoxide NSR New Source Review 

COM Continuous Opacity Monitoring PM Particulate Matter 

department Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns in 

diameter 

dscf Dry standard cubic foot pph Pound per hour 

dscm Dry standard cubic meter ppm Parts per million

EPA United States Environmental Protection Agency ppmv Parts per million by volume 

EU Emission Unit ppmw Parts per million by weight 

°F Degrees Fahrenheit PS Performance Specification 

FG Flexible Group PSD Prevention of Significant Deterioration 

GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute 

gr Grains psig Pounds per square inch gauge 

HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure 

Hg Mercury PTI Permit to Install 

hr Hour RACT Reasonable Available Control Technology 

HP Horsepower ROP Renewable Operating Permit 

H2S Hydrogen Sulfide SC Special Condition 

HVLP High Volume Low Pressure * scf Standard cubic feet 

ID Identification (Number) sec Seconds 

IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction 

ITSL Initial Threshold Screening Level SO2 Sulfur Dioxide 

LAER Lowest Achievable Emission Rate SRN State Registration Number 

lb Pound TAC Toxic Air Contaminant 

m Meter Temp Temperature 

MACT Maximum Achievable Control Technology THC Total Hydrocarbons 

MAERS Michigan Air Emissions Reporting System tpy Tons per year 

MAP Malfunction Abatement Plan μg Microgram 

MDEQ Michigan Department of Environmental Quality VE Visible Emissions 

mg Milligram VOC Volatile Organic Compounds 

mm Millimeter yr Year 

*For HVLP applicators, the pressure measured at the gun air cap shall not exceed 10 pounds per square inch gauge (psig). 
Section 2 ROP No: MI-ROP-B2816-2009a 

Expiration Date: October 1, 2014 

 PTI No.: MI-PTI-B2816-2009a

Page 76 of 76 

Appendix 2.2. Schedule of Compliance 

The permittee certified in the ROP application that this stationary source is in compliance with all applicable 

requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of 

Compliance is not required. (R 336.1213(4)(a), R 336.1119(a)(ii)) 

Appendix 2.3. Monitoring Requirements 

Specific monitoring requirement procedures, methods, or specifications are detailed in Part A or the appropriate 

source-wide, emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 2.4. Recordkeeping 

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate source-wide, 

emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable. 

Appendix 2.5. Testing Procedures 

There are no specific testing requirement plans or procedures for this ROP. Therefore, this appendix is not 

applicable. 

Appendix 2.6. Permits to Install 

The following table lists any PTIs issued since the effective date of previously issued ROP No. 199600201 

Permit to Install 

Number Description of Equipment 

Corresponding 

Emission Unit(s) or 

Flexible Group(s) 

N/A N/A N/A 

Appendix 2.7. Emission Calculations 

There are no specific emission calculations to be used for this RO Permit. Therefore, this appendix is not 

applicable. 

Appendix 2.8. Reporting 

A. Annual, Semiannual, and Deviation Certification Reporting 

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form 

(EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting section of 

the source-wide, emission unit and/or flexible group special conditions. Alternative formats must meet the 

provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor. 

B. Other Reporting 

Specific reporting requirement formats and procedures are detailed in Part A or the appropriate source-wide, 

emission unit and/or flexible group special conditions. Therefore, Part B of this appendix is not applicable.