### NORTH DAKOTA DEPARTMENTof HEALTH ENVIRONMENTAL HEALTH SECTION Gold Seal Center, 918 E. Divide Ave. Bismarck, ND 58501-1947 701.328.5200 (fax) www.ndhealth.gov



## AIRPOLLUTION CONTROL TITLE V PERMIT TO OPERATE

Permittee: Name: Great River Energy 

### Address: 2875 Third Street SW Underwood, ND 58576-9596 

### Source Location: Sec. 8, 9, 16, 17, T146N, R82W McLean County, North Dakota 

### Expiration Date: Permit Number: T5-F82006 

### Source Name: Coal Creek Station 

### Source Type: Electric Generating Unit, Coal September 7, 2019
Pursuant to Chapter 23-25 ofthe North Dakota Century Code, and the Air Pollution Control Rules ofthe State of North Dakota, Article 33-15 of the North Dakota Administrative Code (NDAC), and in reliance on statements and representations heretofore made by the permittee designated above, a Title V Permit to Operate is hereby issued authorizing such permittee to operate the emissions unit(s) at the location designated above. This Title V Permit to Operate is subject to all applicable rules and orders now or hereafter in effect of the North Dakota Department ofHealth and to any conditions specified on the following pages. All conditions are enforceable by EPA and citizens under the Clean Air Act unless otherwise noted.

Renewal No.3 (MinorMod.): 10/21114 Revision No. 1(Admin.): 1130/15

Environmental Health Section Chief's Office 701.328.5150 Division of Air Quality 701.328.5188 

# c;J~ Terry L. 

### 0' lmr, P.E. Director Division ofAir Quality

Division of Municipal Facilities

701.328.5211 Printed on recycledpaper. · Division of Waste Management 701.328.5166 Division of Water Quality 701.328.52101. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12.


### 13. Emission Unit(s) Identification Coal Creek Station Title V Permitto Operate Table ofContents

Continuous EmissionMonitoring (CEM) Identification Restrictions Standards Emission Unit(s) Limits Opacity Limits Monitoring Requirements and Conditions Recordkeeping Requirements Reporting Facility Wide Operating Conditions General Conditions State Enforceable Only Conditions (not Federally enforceable) Phase II Acid RainProvisions AttachmentA

- Compliance Assurance Monitoring (CAM) Plan (EU 1and 2) Page_l_ of 45 PermitNo. T5-F82006

PageNo. 3 5 5 6 8 14 15 22 27 28 35

41 421. Emission Unit(s) Identification: The emission units regulated bythis permit are as follows: A. Point Sources:

Emission Emission Unit Description Unit (EU) Lignite-fired boiler (6,015 x 106 Btulhrheat 1 input) (Unit 1) Lignite-fired boiler (6,022 x 106 Btulhrheat 2 input) (Unit 2) Auxiliary BoilerNo. 91 fired onliquid fuels 3 (172 x 106 Btulhrheat input) Auxiliary BoilerNo. 92 fired onliquid fuels 4 (172 x 106 Btulhrheat input) Diesel fuel oil-fired emergency generator 5 engine (nominal 3,500 hpbuiltpre-2006) Diesel fuel oil-fired emergency fire pump 6 engine (nominal 399 bhpbuiltin2009) Lignite transferhouse 7 Lignite emergency reclaim system 8 Ligniteyard storage silos 9 Lignite yard storage silos 10 Crusherbuilding (two crushers each at 1,500 11 tph) Generation building coal hopper 12 Base ofFalkirkMining Companymine silo 13 Generation building coal hopper 14 Generationbuilding coal hopper 15 Generation building coal hopper 16 Generationbuilding coal hopper 17 Fly ash silo (truck air slide) 20 Fly ash silo (truck air slide) 21 Fly ashrailroad marketing silo 25 Fly ashdome 26 Coal dryer 26 27 CD26 coal crusher 27a Coal dryer crusherbuilding 28 Coal dryertransfertower 29 Auxiliaryboiler area 30 Emission Point (EP) 1 2 3 3 5 6 7 8 9 10 

### 11 12 13 14 15 16 17 20a, 20b, & 20c 21a, 21b, & 21c 25a&25b 26a, 26b, 26c,26d 27 36 37 38 Page_1_ of 46 PermitNo. T5-F82006

AirPollution Control E_quipment ESP and Wet Scrubber ESP and Wet Scrubber None None None None Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter Bagfilters Bagfilters Bagfilters Bagfilters Bagfilter Bagfilter Bagfilter BagfilterEmission Emission UnitDescription Unit {EU) Coal dryer 11 and associated equipment with a 31 maximumrated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 12 and associated equipment with a 32 maximumrated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 13 and associated equipment with a 33 maximum rated capacity ofapproximately 138 tons ofcoal:Q_er hour Coal dryer 14 and associated equipment with a 34 maximum rated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 21 and associated equipment with a 35 maximum rated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 22 and associated equipment with a 36 maximum rated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 23 and associated equipment with a 37 maximumrated capacity ofapproximately 138 tons ofcoal perhour Coal dryer 24 and associated equipment with a 38 maximum rated capacity ofapproximately 138 tons ofcoal perhour Airjig21 39a Airjig 22 39b Lignite rail loading silo 40 Lignite dust collector98 41 Lignite rail loading surge hopper 91 42 Lignite dust collector 99 43 Fluidizedbedpilot dryer 45 B. Fugitive Emissions Sources: 1) Cooling towers No. 91, No. 92, andNo. 93 2) Boombeltconveyor (stackout) 3) Conveyor 909 (stackout) 4) Scrubber building flyash silo (stackout) 5) Coal pile maintenance 6) Coal handling Emission Point{EP) 39

40

41

42

43 44 45 46 47 49 Page_1_ of 46 PermitNo. T5-F82006

AirPollution Control Equipment

Bagfilter

Bagfilter

Bagfilter

Bagfilter

Bagfilter Bagfilter Bagfilter Bagfilter Bagfilter BagfilterPage2._ of 46 PermitNo. T5-F82006

2. Continuous Emission Monitoring (CEM) Identification: Emissions from EU 1 and EU 2 (Units 1 & 2 main stacks) are eachmeasuredby the following monitors: Pollutant Monitored Manufacturer Model Opacity Durag D-R290 so2 Thermo/Electron 43i-ANSCA NOx Thermo/Electron 42i-ANMSDCA C02 Thermo/Electron 41Oi-ANPDCA Flow Sick-Maihak FLOWSIC 100 Note: CEMS for PM, HCl and Hg maybe added. 3. Restrictions: A. Fuel: 1) EU 1 and EU 2 shall be operated using lignite coal as the primary fuel. During startup, distillate fuel oils, used oil or any combination ofthese fuels may be utilized. During unstable firing conditions or ignition support for placing coal elevations in and out of service, distillate fuel oils, used oil or any combinationofthese fuels may be utilized. 2) EU 3 and EU 4 shall be operated using only ultra low sulfur diesel fuel (.:::;15 ppm sulfur), used oil (see Condition 12.C), or any combination ofthese fuels. 3) EU 5 andEU 6 shall be operated using only ultralow sulfur diesel fuel (.:::;15 ppm sulfur). 4) Used oil and hazardous waste may be burned in EU 1 and EU 2 as outlined in Conditions 12.B, 12.C, and 12.D. Fuels other than those listed above may be burned if approved in advance by the Departmentand compliance withthe applicable emission limits is maintained. Applicable Requirement: Permitto Construct B. StackHeights: Emissions shall be vented from the following minimum stackheights.Minimum Stack Emission Point Height {feet) 36 140 37 154 38 230 39 300 40 300 41 300 42 300 43 230 46 110 47 131 48 110 Applicable Requirements: PTC07014 and PTC07016 Applicable Requirement

PTC07016

PTC07014 PTC07016 Page _Q_ of 46 PermitNo. T5-F82006

C. Auxiliary Boilers Annual Capacity Factor: Beginning on the compliance date ofNDAC 33-15- 22 (40 CFR 63), Subpart DDDDD for existing boilers (January 31, 2016 or as amended), EU 3 and EU 4 auxiliary boilers shall be limited to an average annual capacity factor ofno more than 10 percent to maintain status as limited use boilers as defined in 40 CFR 63.7575. Subpart DDDDD requirements wherever stated in this permit become effective on the above compliance date. Applicable Requirements: NDAC 33-15-22-03, SubpartDDDDD andNDAC 33-15-14-6.5.b(l) 4. Standards: The permittee shall complywith all applicable requirements ofthe following subparts. A. NDAC 33-15-12-02, Subpart D - Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction Is Commenced AfterAugust 17, 1971 (for EU 1and EU 2). Applicable Requirement: NDAC 33-15-12-02, Subpart D B. NDAC 33-15-12-02, Subpart Y- Standards ofPerformance for Coal Preparation and Processing Plants (for EU 7throughEU17, EU 28 through EU 30, and EU 39 through EU 45). Applicable Requirement: NDAC 33-15-12-02, Subpart Y C. 40 CFR 60, Subpart IIII: For the emergency fire pump engine (EU 6), the permittee shall comply with all applicable requirements of40 CFR 60, Subpart IIII

- Standards ofPerformance for Stationary Compression Ignition Internal Combustion Engines as incorporated into NDAC 33-15-12-02, Subpart IIII. Note: For engines to be considered emergency stationary RICE under 40 CFR 60, Subpart IIII, operations must comply withthe applicable hours limits (50 and 100 hours per year) specified in 40 CFR 60.4211(£).

### Applicable Requirement: NDAC 33-15-12-02, Subpart IIII Page .1_ 

### of 46 PermitNo. T5-F82006

D. 40 CFR 63, Subpart ZZZZ: For the emergency generator and fire pump engines (EU 5 and EU 6), the permittee shall comply with all applicable requirements of40 CFR 63, Subpart ZZZZ

- National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines as incorporated into NDAC 33-15-22-03, Subpart ZZZZ. For EU 6 SubpartZZZZ requirements include compliance withNDAC 33-15-12-02, Subpart IIII. Note: For engines to be considered emergency stationary RICE under 40 CFR 63, Subpart ZZZZ, operations must comply with the applicable hours limits (50 and 100 hours per year) specified in 40 CFR 63.6640(£). Applicable Requirement: NDAC 33-15-22-03, SubpartZZZZ E. Like-Kind Engine Replacement: This permit allows the permittee to replace the existing engine(s) with a like-kind engine. Replacement is subject to the following conditions. 1) The Department mustbe notified within 10 days after change-out ofthe engine. 2) The replacement engine shall operate in the same manner, provide no mcrease m throughput and have equal or less emissions thanthe engine it is replacing. 3) The date ofmanufacture ofthe replacement engine must be included in the notification. The facility must comply with any applicable federal standards (e.g. NSPS, NESHAP, MACT) triggered by the replacement. 4) The replacement engine is subject to the same state emission limits as the existing engine in addition to any NSPS orMACT emission limit that is applicable. Applicable Requirement: NDAC 33-15-14-03.6 F. 40 CFR 63, Subpart DDDDD: For the auxiliary boilers (EUs 3 and 4), the permittee shall comply with all applicable requirements of40 CFR 63, Subpart DDDDD

- National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters as incorporated into NDAC 33-15-22-03, Subpart DDDDD. Note: The Subpart DDDDD compliance date for existing boilers is January 31, 2016 or as amended by rule. Applicable Requirement: NDAC 33-15-22-03, SubpartDDDDD G. 40 CFR 63, Subpart UUUUU: For the lignite-fired boilers (EUs 1 and 2), the permittee shall comply with all applicable requirements of40 CFR 63, Subpart UUUUU- National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units as incorporated into NDAC 33-15-22-03, Subpart UUUUU.**Page~** of 46 PermitNo. T5-F82006

Note: The Subpart UUUUU compliance date for existing boilers is April 16, 2015 or as amended by rule. Applicable Requirement: NDAC 33-15-22-03, SubpartUUUUU 5. Emission Unit(s) Limits: NDAC Emission Unit Pollutant/ Emission Applicable Description EU EP Parameter Limit* Requirement Lignite-firedboiler 1 1 PM 0.10 lb/10(J Btu** & 33-15-12, SubpartD (Unit 1) 528lb/hr & PTC Condition (3-hr rolling avg.) PM 0.03 lb/106 Btu 33-15-22-03, (effective4/6/15 or as or SubpartUUUUU amendedbyrule) 0.3lb/MWh so2 1.2lb/106 Btu** 33-15-12, SubpartD & 6,336 lb/hr & PTC Condition (3-hr rolling avg.) NOx 5,104lb/hr PTC Condition (12-monthrolling avg.) HCl 0.002 lb/106 Btu 33-15-22-03, (effective 4/16/15 or or SubpartUUUUU as amended by rule) 0.02lb/MWh or S02 Surrogate: 0.2 lb/106 Btu or 1.5lb/MWh Hg 4.0 lb/1012 Btu 33-15-22-03, (effective 4/16/15 or or Subpart UUUUU as amended by rule) 0.04lb/GWh Opacity See Condition (Cond.) 33-15-03-02 & 33- 6.B 15-12, SubpartDEmission Unit Pollutant/ Description 

### EU EP Parameter Lignite-fired boiler 2 2 PM (Unit2)

PM (effective 4/16/15 or as amendedbyrule) so2

NOx

HC1 (effective 4/16/15 or as amendedbyrule)

Hg (effective 4/16115 or as amended byrule) Opacity Page _2_ of 46 PermitNo. T5-F82006

NDAC Emission Applicable

Limit* Requirement 0.10 lb/10°Btu** & 33-15-12, SubpartD 528lb/hr & PTC Condition (3-hr rolling avg.)

0.03 lb/106 Btu 33-15-22-03, or SubpartUUUUU 0.3lb/MWh 1.2lb/106 Btu** 33-15-12, Subpart D

& 6,336 lb/hr & PTC Condition (3-hrrolling avg.) 5,104lb/hr PTC Condition (12-monthrolling avg.) 0.002 lb/106 Btu 33-15-22-03, or SubpartUUUUU 0.02lb/MWh or S02 Surrogate: 0.2 lb/106 Btu or 1.5lb/MWh 4.0 lb/1012 Btu 33-15-22-03, or SubpartUUUUU 0.04lb/GWh See Cond. 6.B 33-15-03-02 & 33- 15-12, SubpartDEmission Unit Pollutant/ Description 

### EU EP Parameter Auxiliary BoilerNo. 91 3 3 PM


### SOz

NOx Opacity Annual Capacity (effective 1131116 or as amended byrule) Auxiliary BoilerNo. 92 4 3 PM


### SOz

NOx Opacity Annual Capacity (effective 1131116 or as amended byrule) Emergency generator 5 5 Opacity engine NOx


# co Emergency fire pump 6 6 Opacity engine NOx


# co Page _lQ_ of 46 PermitNo. T5-F82006

NDAC Emission Applicable

Limit* Requirement 0.41 lb/10° Btu & 33-15-05-02 & PTC 4.5lblhr Condition 3.0 lb/106 Btu 33-15-06 & PTC & Condition 516lblhr (3-hr rolling avg.)

0.7lb/106 Btu PTC Condition See Cond. 6.A 33-15-03-02 See Cond. 3.C 33-15-22-03, Subpart DDDDD 0.41lb/10° Btu & 33-15-03-02 & PTC 4.5lblhr Condition 3.0 lb/106 Btu 33-15-06 & PTC

& 516lblhr Condition (3-hr rolling avg.)

0.7lb/106 Btu PTC Condition See Cond. 6.A 33-15-03-02 See Cond. 3.C 33-15-22-03, SubpartDDDDD See Cond. 6.A 33-15-03-02 See Cond. 4.D 33-15-22-03, SubpartZZZZ See Cond. 4.D 33-15-22-03, SubpartZZZZ See Cond. 6.A 33-15-03-02 See Cond. 4.C 33-15-12-02, Subpart IIII See Cond. 4.C 33-15-12-02, Subpart IIIIEmissionUnit Description 

### EU EP Lignite transferhouse 7 7

Lignite emergency 8 8 reclaim system
Lignite yard storage 9 9 silos
Lignite yard storage 10 10 silos

Crusherbuilding (two 11 11 crushers)

Generationbuilding coal 12 12 hopper

Base ofFalkirkMining 13 13 Company mine silo

Generationbuilding coal 14 14 hopper

Generationbuilding coal 15 15 hopper

Generationbuilding coal 16 16 hopper Pollutant/ Parameter PM Opacity

PM Opacity

PM Opacity

PM Opacity
PM Opacity

PM Opacity
PM Opacity

PM Opacity
PM Opacity

PM Opacity Emission Limit* 3lb/hr See Cond. 6.C 3lb/hr See Cond. 6.C 3lb/hr See Cond. 6.C 3lb/hr See Cond. 6.C 3lb/hr See Cond. 6.C 3 lb/hr See Cond. 6.C
3lb/hr See Cond. 6.C
3lb/hr See Cond. 6.C
3lb/hr See Cond. 6.C
3lb/hr See Cond. 6.C Page_ll_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart Y PTC Condition 33-15-03-02 & 33-15-12, Subpart YEmission Unit Description EU EP Generation building coal 17 17 hopper
Fly ash silo 20 20a, 20b &20c
Fly ash silo 21 21a, 21b & 21c
Fly ash railroad 25 25a& marketing silo 25b

Fly ash dome 26 26a, 26b, 26c, 26d

Coal dryer 26 27 27
CD26 coal crusher 27a Coal dryer crusher 28 36 building

Coal dryertransfer 29 37 tower Auxiliary boiler area 30 38 Pollutant/ Parameter PM Opacity

PM Opacity

PM Opacity

PM Opacity

PM

Opacity
PM Opacity

PM/PM10

Opacity PM/PM10

Opacity PM/PM10

Opacity Page__l2_of 46 PermitNo. T5-F82006

NDAC Emission Applicable

Limit* Requirement 3 lblhr PTC Condition See Cond. 6.C 33-15-03-02 & 33-15-12, Subpart Y 3 lblhr PTC Condition (each emissionpoint) See Cond. 6.A 33-15-03-02 (each emissionpoint) 3 lblhr PTC Condition (each emissionpoint) See Cond. 6.A 33-15-03-02 (each emissionpoint) 3 lblhr 33-15-14-06.5.b(1) (each emissionpoint) See Cond. 6.A 33-15-03-02 (each emissionpoint) 0.4lblhr 33-15-14-06.5.b(1) (EmissionPoints 26a through 26d) See Cond. 6.A 33-15-03-02 (each emissionpoint) 3.1lblhr PTC 04006 See Cond. 6.A 33-15-03-02
0.004 gr/dscf 33-15-15 (BACT) & 0.75 lblhr*** 33-15-02-07 10% 33-15-15 (BACT) 0.004 gr/dscf 33-15-15 (BACT) & 0.59lblhr*** 33-15-02-07 10% 33-15-15 (BACT) 0.004 gr/dscf 33-15-15 (BACT) & 0.90 lblhr*** 33-15-02-07 10% 33-15-15 (BACT)Emission Unit Pollutant/ Emission Description EU EP Parameter Limit* Coal dryer 11 31 39 PMIPM10 0.004 gr/dscf & 5.3 lblhr*** Coal dryer 12 32 Opacity 10% Coal dryer 13 33 40 PMIPMIO 0.004 gr/dscf & 5.3 lblhr*** Coal dryer 14 34 Opacity 10% Coal dryer 21 35 41 PM 7.0 lb.hr
Coal dryer 22 36 Opacity See Cond. 6.A Coal dryer 23 37 42 PM 7.0 lb.hr
Coal dryer 24 38 Opacity See Cond. 6.A Airjig21 39a 43 PMIPM10 0.004 gr/dscf & 1.4lblhr*** Airjig22 39b Opacity 10% Lignite rail loading silo 40 44 PM/PM10 0.004 gr/dscf & 0.08 lblhr*** Opacity 10% Lignite dust collector 98 41 45 PM/PM10 0.004 gr/dscf & 0.13 lblhr*** Opacity 10% Lignite rail loading 42 46 PMIPMIO 0.004 gr/dscf surge hopper 91 & 0.08 lblhr*** Opacity 10% Lignite dust collector 99 43 47 PMIPMIO 0.004 gr/dscf & 0.75 lblhr*** Opacity 10% Fluidizedbed pilot dryer 45 49 PM/PM10 0.005 gr/dscf & 0.30 lblhr*** Opacity 10% * Emission limits are basedon a 1-hour average, unless otherwise noted. Page

## _u_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) PTC07014 & 33-15-14-03.6

33-15-03-02 PTC07014 & 33-15-14-03.6

33-15-03-02 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT) 33-15-15 (BACT) 33-15-02-07 33-15-15 (BACT)

## ** *** 6. This standard does not apply during startup, shutdown and malfunction. Most stringent limit applies. Page _H_ 

### of 46 PermitNo. T5-F82006

Opacity Limits: 

### The following are applicable requirements referred to for the various emission units listed in Condition 5. A. EU 3 through 6, 20 through 27 and EU 35 through 38

- twenty percent (six-minute average), except that a maximum offorty percent (six-minute average) is permissible for not more than one six-minute periodperhour. This standard applies at all times. Applicable Requirement: NDAC 33-15-03-02 B. EU 1 and EU 2- Twenty percent (six-minute average), except that a maximum oftwenty-seven percent (six-minute average) is permissible for not more than one six-minute period per hour. This standard does not apply during startup, shutdown and malfunction, and it will no longer apply at all if, and when, the USEPA grants the Great River Energy petition for alternate monitoring under 40 CFR 60.42(c) and when the PM CEMS are operational. Applicable Requirements: NDAC 33-15-12, Subpart A and Subpart D C. 

### EU 7 through EU 17

- Twenty percent opacity (six-minute average) or greater shall not be discharged into the atmosphere. This standard does not apply during startup, shutdown and malfunction. Applicable Requirements: NDAC 33-15-12, Subpart A and Subpart Y7. MonitoringRequirements and Conditions: A. Requirements Monitoring Emission Unit Pollutant/ Requirement Description EU Parameter (Method) Lignite-firedboiler 1 Opacity O&M/CEM (Unit 1)

PM Compliance Assurance Monitoring (CAM)/Emissions Test orPM CEM so2 CEM

NOx CEM

NOx&CO Tune-up

C02 CEM

HCl Emissions Test or S02 CEM
Hg Emissions Test or HgCEM

Flow FlowMonitor Condition Number 7.B.l, 7.B.2, 7.B.3 & 7.B.4
7.B.1, 7.B.7, 7.B.8, 7.B.l3

7.B.1, 7.B.3 & 7.B.4 7.B.l, 7.B.3 & 7.B.4 7.B.6
7.B.1, 7.B.3 & 7.B.4 7.B.7 & 7.B.8 or 7.B.l

7.B.7 & 7.B.8 or 7.B.1
7.B.1, 7.B.3 & 7.B.4 Page __li_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement 33-15-14-06.5.a.(3)(a), 33-15-12, SubpartD & 33-15-21 40 CFR64, 33-15-14-06.5.a(3)(a) & 33-15-22-03, SubpartUUUUU
33-15-12, Subpart D & 33-15-21 33-15-21
33-15-22-03, Subpart 

## uuuuu 33-15-12, SubpartD & 33-15-21 33-15-14-06.5.a(3)(a) & 33-15-22-03, SubpartUUUUU 33-15-14-06.5.a(3)(a) & 33-15-22-03, Subpart UUUUU 33-15-21Monitoring Emission Unit Pollutant/ Requirement Description EU Parameter (Method) Lignite-fired boiler 2 Opacity O&MICEM (Unit 2)

PM CAM/Emissions Test orPM CEM

so2 CEM

NOx CEM

NOx&CO Tune-up

C02 CEM

HCl Emissions Test or S02CEM

Hg Emissions Test or HgCEMS

Flow FlowMonitor Condition Number 7.B.1, 7.B.2, 7.B.3 & 7.B.4
7.B.1, 7.B.7, 7.B.8, 7.B.13

7.B.l, 7.B.3 & 7.B.4 7.B.l, 7.B.3 & 7.B.4 7.B.6
7.B.1, 7.B.3 & 7.B.4 7.B.7 & 7.B.8

7.B.7 & 7.B.8

7.B.1, 7.B.3 & 7.B.4 Page .lQ_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement 33-15-14-06.5.a.(3)(a), 33-15-12, Subpart D & 33-15-21 40 CFR 64/ 33-15-14-06.5.a.(3)(a) & 33-15-22-03, SubpartUUUUU 33-15-12, Subpart D & 33-15-21 33-15-21
33-15-22-03, Subpart 

# uuuuu 33-15-12, SubpartD & 33-15-21 33-15-14-06.5.a(3)(a) & 33-15-22-03, Subpart UUUUU

33-15-14-06.5.a(3)(a) & 33-15-22-03, SubpartUUUUU 33-15-21Monitoring Emission Unit Pollutant/ Requirement Description EU Parameter (Method) Auxiliary Boiler 3 PM/Opacity Recordkeeping No. 91 

## so2 SulfurAnalysis NOx Emissions Test or Tune-up HAP Tune-up

Hours of Recordkeeping Operation

Annual Recordkeeping Capacity

Factor Auxiliary Boiler 4 PM/ Opacity Recordkeeping No. 92 

## so2 SulfurAnalysis NOx Emissions Testor Tune-up HAP Tune-up

Hours of Recordkeeping Operation

Annual Recordkeeping Capacity

Factor Condition Number 7.B.5 & 7.B.8)b

7.B.l1 7.B.9

7.B.9

7.B.12

7.B.14

7.B.5 & 7.B.8)b

7.B.ll 7.B.9

7.B.9

7.B.12

7.B.14 Page _..11_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement 33-15-14-06.5.a.(3)(a) & 33-15-22-03, Subpart DDDDD 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)
33-15-22-03, Subpart DDDDD 33-15-14-06.5.a.(3)(a)
33-15-22-03, Subpart DDDDD& 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a.(3)(a) & 33-15-22-03, SubpartDDDDD 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)
33-15-22-03, Subpart DDDDD 33-15-14-06-5.a.(3)(a)
33-15-22-03, Subpart DDDDD& 33-15-14-06.5.a(3)(a)Emission Unit Pollutant/ Description EU Parameter Emergency 5 Opacity generator engine NOx



## co

Hours of Operation Emergency fire 6 Opacity pump engine NOx



## co

Hours of Operation Lignite transfer 7 PM/Opacity house Lignite emergency 8 PM/Opacity reclaim system Lignite yard storage 

### 9 PM/ Opacity silos Lignite yard storage 10 PM/ Opacity silos Crusherbuilding 11 PM/Opacity (two crushers) Generation building 12 PM/ Opacity coal hopper Base ofFalkirk 13 PM/Opacity Mining Company mine silo Generationbuilding 14 PM/ Opacity coal hopper Generation building 15 PM/Opacity coal hopper Generationbuilding 16 PM/Opacity coal hopper Monitoring Requirement

(Method) Recordkeeping

As Required

As Required Recordkeeping Recordkeeping

As Required

As Required Recordkeeping 

### O&MNE Observations (VEO) 

### O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO

O&MNEO O&MNEO O&MNEO Condition Number

7.B.5 4.D

4.D

7.B.12 7.B.5

4.C

4.C

7.B.12 7.B.7/7.B.10

7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10

7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 **Page~of** 46 PermitNo. T5-F82006

NDAC Applicable Reguirement 33-15-14-06.5.a.(3)(a) 33-15-22-03, Subpart 

# zzzz 33-15-22-03, Subpart 

# zzzz 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-12-02, Subpart 

### IIII 33-15-12-02, Subpart 

### IIII 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)
33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)
33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)Emission Unit Pollutant/ Description EU Parameter Generation building 17 PM/Opacity coal hopper Fly ash silo 20 PM/Opacity Fly ash silo 21 PM/Opacity Fly ash railroad 25 PM/Opacity marketing silo Fly ash dome 26 PM/Opacity Coal dryer 26 27 PM/Opacity CD26 coal crusher 27a Coal dryer crusher 28 PMIPMro/ building Opacity Coal dryer transfer 29 PM/PMro/ tower Opacity Auxiliary boiler 30 PMIPMro/ area Opacity Coal dryer 11 31 PM/PMro/ Coal dryer 12 32 Opacity Coal dryer 13 33 PM/PMro/ Coal dryer 14 34 Opacity Coal dryer 21 35 PM/PMro/ Coal dryer 22 36 Opacity Coal dryer 23 37 PM/PMro/ Coal dryer 24 38 Opacity Airjig 21 39a PMIPMro/ Airjig22 39b Opacity Lignite rail loading 40 PM/PMro/ silo Opacity Lignite dust 41 PM/PMro/ collector 98 Opacity Lignite rail loading 42 PMIPMro/ surge hopper 91 Opacity Lignite dust 43 PMIPMro/ collector 99 Opacity Fluidizedbedpilot 45 PM/PMro/ dryer Opacity B. Emission Monitoring Conditions Monitoring Requirement

(Method) O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO

O&MNEO

O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO O&MNEO Condition Number 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10

7.B.7/7.B.10

7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.l0 7.B.7/7.B.10 7.B.7/7.B.l0 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.10 7.B.7/7.B.l0 7.B.7/7.B.10 7.B.7/7.B.10 Page__1.2_ of 46 PermitNo. T5-F82006

NDAC Applicable Requirement 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a) 33-15-14-06.5.a.(3)(a)
33-15-14-06.5.a.(3)(a)
33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a) 33-15-14-06.5.a(3)(a)

1) The monitoring shall be in accordance with the following applicable requirements of Chapter 33-15-06, Chapter 33-15-12, Chapter 33-15-21 and Chapter 33-15-22 of thePage 20 of 46 PermitNo. T5-F82006

North Dakota Air Pollution Control Rules. Emissions are calculated using 40 CFR 75, Appendix F and 40 CFR60, Appendix A. a) Section 33-15-06-04 ofthe North DakotaAir Pollution Control Rules, Monitoring Requirements. b) 40 CFR60, SubpartA, Section 60.13, Monitoring Requirements. c) 40 CFR 60, Subpart D, Section 60.45, Emission and Fuel Monitoring. d) Section 33-15-21-09 oftheNorth DakotaAirPollution Control Rules, Monitoring Requirements. e) Upon approval by USEPA ofalternate opacity monitoring, install, certify, operate and maintain PM CEMS per 40 CFR 60 Appendix B, Performance Specification 11 and 40 CFR 60 AppendixF, Procedure 2. f) Install, certify, operate and maintain Hg CEM per 40 CFR 75 or 40 CFR 63, Subpart UUUUU Appendix A (compliance April 16, 2015 or as amended by rule). 2) Within one year ofthe permit renewal date, the permittee shall conduct a performance evaluation ofthe continuous opacitymonitoring system. For the performance evaluation, conformance with the specification for calibration error, Section 13.3 Field Audit Performance Specifications, Paragraph (2) Calibration Error of40 CFR 60, Appendix B, Performance Specification 1 must be demonstrated. The procedures of Section 8.1, Paragraph (3)(ii) Calibration Error Check shall be used to determine conformance with the specification for calibration error. A second performance evaluation shall take place no sooner than two years or later than three years from the date ofthe first performance evaluation. 3) The Departmentmayrequire additional performance audits ofthe CEM system. 4) When a failure of a continuous emission monitoring system occurs, an alternative method, acceptable to the Department, for measuring or estimating emissions must be undertaken as soon as possible. The procedures outlined in 40 CFR 75, Subpart D for substitution are considered an acceptable method. Timely repair of the emission monitoring system must be made. 5) For purposes of compliance monitoring, burning of fuel in compliance with Condition 3.A shall be considered credible evidence of compliance with any applicable opacity, particulate and S02 emission limit. However, results from tests conducted in accordance with the test methods in 40 CFR 50, 51, 60, 61, or 75 will take precedence over burning fuel in compliance with Condition 3.B and 3.C for evidence of compliance or

### Page .11_

### of 46 PermitNo. T5-F82006 noncompliance with any applicable opacity, particulate and 

## so2 emission limit, in the event ofenforcement action. 6) Lignite-fired Boiler Tune-up: Conduct a tune-up on each existing lignite-fired boiler (EU 1 and EU 2) at least each 36 months in accordance with 40 CFR 63, Subpart UUUUU (compliance date: April16, 2015 or as amended). 7) The permittee shall maintain and operate air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. The manufacturer's recommended Operations and Maintenance (O&M) procedures, or a sitespecific O&M procedure (developed from the manufacturer's recommended O&M procedures), shall be followed to assure proper operation and maintenance of the equipment. The permittee shall have the O&M procedures available on-site and provide the Department with a copy when requested. 8) a) 

### Within two years of the permit renewal date, the permittee shall conduct an emissions test to measure particulate emissions, using EPA Test Methods in 40 CFR 60, Appendix A. 

### A test shall consist ofthree runs, with each run at least one hour in length. Other test methods may be used provided they are approved in advance bythe Department. b) Conduct performance tests quarterly for units subject to 40 CFR 63, Subpart UUUUU (beginning April 16, 2015 or as amended by rule). 9) An

### emissions test shall be conducted to measure particulate and NOx emissions when the unit(s) have operated more than 500 hours in a calendar year. The emissions test shall be conducted using EPA Test Methods in 40 CFR 60, Appendix A. A test shall consist of three runs, with each run at least one hour in length. Other test methods may be used provided they are approved, in advance, by the Department. An 

### emissions test will not be required more than once during the term ofthe permit. This test requirement will not be applicable subsequent to the 40 CFR 63, Subpart DDDDD compliance date. Conduct a boiler tune-up once every 24 months per 40 CFR 63, Subpart DDDDD (beginning January 31,2016 or as amended byrule). 1

0) At leastonce per week in which the emission unit is operated, a company representative (need not be certified) shall observe the emission point. If no visible emissions are observed, the date and time shall be recorded. Ifvisible emissions are observed, the permittee must investigate the problem within eight hours. Any 

### problems that are discovered must be corrected as soon as possible. Ifthe correction ofthe emissions is expected to take longer than 24 hours, the permittee shall follow procedures as outlined in Condition 10.H. Following corrective maintenance, a visible emissions observation shall be made.

### Page 22 of 46 PermitNo. T5-F82006

All investigations ofmalfunctions and visible emissions shall be recorded. The permittee shall comply with the visible emissions and particulate emission limits and nothing inthis condition shall be construed as authorizing otherwise. 11) The sulfur analysis for the fuel may be conducted by the permitted orby the source where the fuel is purchased. The permittee shall calculate sulfur dioxide emissionrates from the sulfur content ofthe fuel using EPA emission factors or other methods approved by the Department. 12) A log shall be kept ofthe hours ofoperation. 13) The permittee shall conduct the monitoring, recordkeeping and reporting as required by the applicable subparts of40 CFR 64. Monitoring shall be conducted in accordance with the Compliance Assurance Monitoring (CAM) Plan in Attachment A ofthis permit. The indicatorranges for emission units subjectto CAM are as follows: Indicator Indicator Emission Unit Monitored Range EU 1(ESP) Opacity :::; 20% (Particulate) EU 2 (ESP) Opacity :::; 20% (Particulate) 14) Auxiliary Boiler Annual Capacity Factor: The permittee shall monitor and record the type and amount offuel used by the Auxiliary Boilers (EU 3 and EU 4). Bythe 15th day ofeach January, the permittee shall calculate and record for each limited use boiler the annual capacity factor as defined in §63.7575. These records shall be retained by the permittee for a period offive years and made available to the Department upon request. If the annual capacity factor exceeds 1 0 percent, the permittee shall notify the Department within 15 days after making the calculation. (Compliance date: January 31, 2016 or as amended.) 8. Recordkeeping Requirements: 

### A. The permittee shall maintain compliance monitoring records for all emission units as outlined in Table 1(Monitoring Records), that includes the following information. 1) The date, place (as defined in the permit) and time ofsampling ormeasurement. 2) The date(s) testing was performed. 3) The company, entity, or person that perforn:led the testing. 4) The testing techniques ormethods used.5) The results ofsuchtesting. Page 23 of 46 PermitNo. T5-F82006

6) The unit load thatexisted at the time ofsampling ormeasurement. 7) Records shall be kept as to the type offuel usage. Applicable Requirement: NDAC 33-15-14-06.5.a.(3)(b)[1] B. In addition to requirements outlined in Condition 8.A, recordkeeping for EU 1, EU 2 and EU 7 through EU 17 shall be in accordance with the following applicable requirements ofChapter 33- 15-06, Chapter 33-15-12, Chapter 33-15-14 and Chapter 33-15-21 oftheNorth Dakota AirPollution Control Rules: 1) Section 33-15-06-05 of the North Dakota Air Pollution Control Rules, Reporting and Recordkeeping Requirements. 2) 40 CFR60, SubpartA, Section 60.7, Notification and Recordkeeping. 3) Section 33-15-21-09 of the North Dakota Air Pollution Control Rules, Recordkeeping Requirements. 4) 40 CFR 64, Section 64.9

- Reporting and Recordkeeping Requirements, Paragraph (b) General Recordkeeping Requirements. Applicable Requirements: NDAC 33-15-06, 33-15-12, 33-15-14, and 33-15-21; 40 CFR 64

Emission Unit Description 

### EU Lignite-firedboiler (Unit 1) 1 Table 1 Monitoring Records Pollutant/ Parameter

Opacity

PM

so2 (lb/106 Btu) so2 (lb/hr)

NOx&CO

C02 Compliance Monitoring Record CEMData CAM Data & Emissions TestData or CEM Data

CEMData CEMData & Material Balance Data CEMData& Tune-up Records CEMDataPollutant/ Emission Unit Description 

### EU Parameter HCl Hg Flow Lignite-fired boiler (Unit 2) 2 Opacity PM

S02 (lb/106 Btu) 802 (lblhr)

NOx&CO

C02 HCl Hg Flow Auxiliary Boiler

### No: 91 3 PM/ Opacity 802 NOx

HAP Hours ofOperation

Annual Capacity Factor Page 24 of 46 PermitNo. T5-F82006
Compliance Monitoring Record CEM Dataor Emissions TestData CEMS DataorEmissions Test Data Flow MonitorData CEMData CAMData & Emissions Test Data orCEM Data

CEMData CEMData & Material Balance Data CEMData& Tune-up Records CEMData CEM DataorEmissions Test Data CEMS DataorEmissions Test Data FlowMonitor Data Type ofFuel Usage SulfurAnalysis Emissions TestDataor Tune-up Records Tune-up Records Hours ofOperation Data Fuel Records & CalculationsEmission Unit Description 

### EU AuxiliaryBoilerNo. 92 4

Emergency generatorengine 5

Emergency fire pump engine 6

Lignite transferhouse 7 Lignite emergencyreclaim system 8 Lignite yard storage silos 9 Lignite yard storage silos 10 Crusherbuilding (two crushers) 11 Generation building coal hopper 12 Base ofFalkirkMining Company 13 mine silo Generationbuilding coal hopper 14 Generation building coal hopper 15 Generationbuilding coal hopper 16 Generation building coal hopper 17 Fly ash silo 20 Fly ash silo 21 Fly ashrailroad marketing silo 25 Pollutant/ Parameter PM/ Opacity 

# so2
NOx

HAP Hours ofOperation

Annual Capacity Factor Opacity·

NOx 

# co Hours ofOperation Opacity

NOx 

# co Hours ofOperation PM/Opacity PM/ Opacity PM/ Opacity PM/ Opacity PM/ Opacity PM/ Opacity PM/Opacity PM/ Opacity PM/Opacity PM/ Opacity PM/ Opacity PM/Opacity PM/ Opacity PM/ Opacity Page 25 of 46 PermitNo. T5-F82006 Compliance Monitoring Record Type ofFuel Usage SulfurAnalysis Emissions TestDataor Tune-up Records Tune-up Records Hours ofOperation Data Fuel Records & Calculations Type ofFuelUsage Emissions TestData Emissions TestData Hours ofOperationData Type ofFuelUsage Emissions TestData Emissions Test Data Hours ofOperation Data O&MData&VE Observations (VEO) Data O&MData & VEO Data O&MData & VEO Data O&M Data & VEO Data O&MData& VEO Data O&MData& VEO Data O&MData & VEO Data O&M Data& VEO Data O&M Data& VEO Data O&MData& VEO Data O&MData& VEO Data O&MData & VEO Data O&M Data& VEO Data O&MData& VEO DataEmission UnitDescription Fly ash dome Coal dryer CD26 coal crusher Coal dryer crusher building Coal dryer transfertower Auxiliary boiler area Coal dryer 11 Coal dryer 12 Coal dryer 13 Coal dryer 14 Coal dryer 21 Coal dryer 22 Coal dryer 23 Coal dryer 24 Airjig 21 Airjig 22 Lignite rail loading silo Lignite dust collector 98 Lignite rail loading surge hopper 91 Lignite dust collector 99 Fluidized bed pilot dryer 

### EU 26 27 27a 28 29 30 31 32 33 34 35 36 37 38 39a 39b 40 41 42 43 45 Pollutant/ Parameter PM/Opacity PM/Opacity PM/PMio/Opacity PM/PM10/0pacity PMIPMIO/Opacity PM/PM10/0pacity PM/PM10/0pacity PM/PMio/Opacity PM/PM1o/Opacity
PM/PM1 o/Opacity PM/PM10/0pacity PM/PM10/0pacity PM/PM1o/Opacity PM/PMio/Opacity PM/PM10/0pacity Page 26 of 46 PermitNo. T5-F82006
Compliance Monitoring Record O&M Data & VEO Data O&M Data & VEO Data O&M Data & VEO Data O&M Data & VEO Data O&M Data & VEO Data O&M Data & VEO Data
O&M Data & VEO Data
O&M Data & VEO Data
O&M Data & VEO Data
O&M Data & VEO Data
O&M Data & VEO Data O&MData & VEO Data O&M Data & VEO Data O&M Data & VEO Data O&M Data & VEO Data C. The permittee shall retain records of all required compliance monitoring data and support information for a period of at least five years from the date of the monitoring sampling, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings/computer printouts of continuous compliance monitoring instrumentation, and copies ofall reports required by the permit. Applicable Requirement: NDAC 33-15-14-06-5.a.(3)(b)[2] 9. Reporting: A. For EU 1, EU 2 and EU 7 through EU 17, EU 28 through EU 30, and EU 39 through EU 47, reporting shall be in accordance with the following applicable requirements ofChapter 33-15-06, Chapter 33-15-12, Chapter 33-15-14 and Chapter 33-15-21 ofthe North Dakota Air Pollution Control Rules. 1) Section 33-15-06-05 of the North Dakota Air Pollution Control Rules, Reporting and Recordkeeping Requirements.

### Page 27 of 46 PermitNo. T5-F82006

2) 40 CFR 60, Subpart A, Section 60.7, Notification and Recordkeeping. 3) Section 33-15-21-09 of the North Dakota Air Pollution Control Rules, Reporting Requirements. 4) 40 CFR 64, Section 64.9

- Reporting and Recordkeeping Requirements, Paragraph (a) General Reporting Requirements. 5) Quarterly excess emissions reports for EU 1 and EU 2 shall be submitted by the 30th day following the end ofeach calendar quarter. Excess emissions are defined as emissions which exceed the emission limits for EU 1 and EU 2 as outlined in Condition 5. Excess emissions shall be reported for the following: Parameter Opacity% so2lb/106 

### Btu S02lblhr NOx lblhr Reporting Period (6-minute average) (3-hour rolling average) (3-hour rolling average) (12-monthrolling average) Note: Also report appropriate additional parameters ifCEMS are added for PM, HCl and Hg. B. The permittee shall submit a semi-annual monitoring report for all monitoring records required under Condition 8 on forms supplied or approved by the Department. All instances ofdeviations from the permit must be identified in the report. A monitoring report shall be submitted within 45 days after June 30 and December 31 ofeach year. Applicable Requirement: NDAC 33-15-14-06.5.a(3)(c)[1] and [2] C. The permittee shall submit an annual compliance certification report within 45 days after December 31 ofeach year on forms supplied or approved by the Department. Applicable Requirement: NDAC 33-15-14-06.5.c(5) D. For emission units where the method ofcompliance monitoring is demonstrated by an EPA Test Method or a portable analyzer test, the test report shall be submitted to the Department within 60 days after completion ofthe test. Applicable Requirement: NDCC 33-15-14-06.5.a.(6)(e) E. The permittee shall submit an annual emission inventory report on forms supplied or approved by the Department. This report shall be submitted by March 15 of each year. Insignificant units/activities listed in this permit do not need to be included in the report.

### Page 28 of 46 PermitNo. T5-F82006 Applicable Requirements: NDAC 33-15-14-06.5.c.(7) and NDAC 33-15-23-04 10. Facility Wide Operating Conditions: A. AmbientAir Quality Standards: 

### 1) Particulate and gases. The permittee shall not emit air contaminants in such a manner or amount that would violate the standards ofambient air quality listed in Table 1ofNDAC 33-15-02 at any place beyond the premises on which the source is located. 2) Radioactive substances. The permittee shall not release into the ambient atr any radioactive substances exceeding the concentrations specified inNDAC 33-10. 3) Other air contaminants. The permittee shall not emit any other air contaminants in concentrations that would be injurious to human health or well-being or unreasonably interfere with the enjoyment ofproperty orthat would injure plant or animal life. 4) Disclaimer. Nothing in any other part or section ofthis permit may in any manner be construed as authorizing or legalizing the emission of air contaminants in such manner that would violate the standards in Paragraphs 1), 

### 2) and 3) ofthis condition. Applicable Requirement: NDAC 33-15-02-04 B. Fugitive Emissions: 

### The release of fugitive emtsswns shall comply with the applicable requirements inNDAC 33-15-17. Applicable Requirement: NDAC 33-15-17 C. Open Burning: 

### The permittee may not cause, conduct, or permit open burning ofrefuse, trade waste, or other combustible material, except as provided for in section 33-15-04-02 and may not conduct, cause, or permit the conduct ofa salvage operation by open burning. Any permissible openburning underNDAC 33-15-04-02 must comply withthe requirements ofthat section. Applicable Requirement: NDAC 33-15-04 D. Asbestos Renovation or Demolition: 

### Any asbestos renovation or demolition at the facility shall comply with emission standard for asbestos in NDAC 33-15-13. Applicable Requirement: NDAC 33-15-13-02 E. Requirements for Organic Compounds Gas Disposal: 1) 

### The owner/operator shall incinerate, flare or treat in an equally effective manner any organic compounds, gases and vapors which are generated as wastes as the result of storage, refining, or process operations and which contain hydrogen sulfide before being releasedto the ambient air.Page 29 of 46 PermitNo. T5-F82006

2) Each flare must be equipped and operated with an automatic ignitor or a continuous burning pilot. Applicable Requirement: NDAC 33-15-07-02 F. Rotating Pumps and Compressors: All rotating pumps and compressors handling volatile organic compounds must be equipped and operated with properly maintained seals designed for their specificproduct service and operating conditions. Applicable Requirement: NDAC 33-15-07-01.5 G. Shutdowns/Malfunction/Continuous Emission Monitoring System Failure: 1) Maintenance Shutdowns. In the case ofshutdown ofair pollution control equipment for necessary scheduled maintenance, the intent to shut down such equipment shall be reported to the Department at least twenty-four hours prior to the planned shutdown provided that the air contaminating source will be operated while the control equipment is not in service. Suchpriornotice shall include the following: a) Identification of the specific facility to be taken out of service as well as its location and permitnumber. b) The expected length oftime that the air pollution control equipment will be out of service. c) The nature and estimated quantity of emissions of air pollutants likely to be emitted during the shutdownperiod. d) Measures, such as the use ofoff-shift labor and equipment, that will be taken to minimize the length ofthe shutdownperiod. e) The reasons that it would be impossible or impractical to shutdown the source operation during the maintenance period. f) Nothing in this subsection shall in any manner be construed as authorizing or legalizing the emission ofair contaminants in excess ofthe rate allowed by this article or a permit issued pursuantto this article. Applicable Requirement: NDAC 33-15-01-13.1 2) Malfunctions. a) When a malfunction in any installation occurs that can be expected to last longer than twenty-four hours and cause the emission ofair contaminants in violation of this article or other applicable rules and regulations, the person responsible for

### Page 30 of 46 PermitNo. T5-F82006

such installation shall notify the Department of such malfunction as soon as possible during normal working hours. The notification must contain a statement giving all pertinent facts, including the estimated duration ofthebreakdown. The department shall be notified when the condition causing the malfunction has been corrected. b) Immediate notification to the department is required for any malfunction that would threaten health or welfare, or pose an imminent danger. During normal working hours the Department can be contacted at 701-328-5188. After hours the department can be contacted through the twenty-four-hour state radio emergency number 1-800-472-2121. If calling from out of state, the twenty-four-hour number is 701-328-9921. c) Unavoidable Malfunction. The owner or operator ofa source who believes any excess emissions resulted from an unavoidable malfunction shall submit a written report to the Department which includes evidence that: [1] The excess emissions were causedby a sudden, unavoidable breakdown of technology that was beyond the reasonable control of the owner or operator. [2] The excess emissions could not have been avoided by better operation and maintenance, did not stem from an activity or event that could have been foreseen and avoided, orplanned for. [3] To the extent practicable, the source maintained and operated the air pollution control equipment and process equipment in a manner consistent with good practice for minimizing emissions, including minimizing any bypass emissions. [ 4] Any necessary repairs were made as quickly as practicable, using off-shift labor and overtime as needed and possible. [5] All practicable steps were taken to minimize the potential impact ofthe excess emissions on ambient air quality. [6] The excess emissions are not part of a recurring pattern that may have been caused by inadequate operation or maintenance, or inadequate design ofthe malfunctioning equipment. The report shall be submitted within thirty days ofthe end ofthe calendar quarter in which the malfunction occurred or within thirty days of a written request by the department, whichever is sooner. The burden ofproofis on the owner or operator ofthe source to provide sufficient information to demonstrate that an unavoidable equipment

### Page _ll_

### of 46 PermitNo. T5-F82006

malfunction occurred. The Department may elect not to pursue enforcement action after considering whether excess emissions resulted from an unavoidable equipment malfunction. The Department will evaluate, on a case-by-case basis, the information submitted by the owner or operatorto determine whetherto pursue enforcement action. Applicable Requirement: NDAC 33-15-01-13.2 3) Continuous Emission Monitoring System Failures. When a failure of a continuous emission monitoring system occurs, an alternative method for measuring or estimating emissions must be undertaken as soon as possible. The owner or operator ofa source that uses an alternative method shall have the burden of demonstrating that the method is accurate. Timely repair of the emission monitoring system must be made. The provisions of this subsection do not apply to sources that are subject to monitoring requirements in Chapter 33-15-21 (40 CPR

### 75, Acid Rain Program). Applicable Requirement: NDAC 33-15-01-13.3 H. Noncompliance Due to an Emergency: 

### The permittee may seek to establish that noncompliance with a technology-based emission limitation under this permit was due to an emergency. To do so, the permittee shall demonstrate the affirmative defense of emergency through properly signed, contemporaneous operating logs, or otherrelevant evidence that: 1) An 

### emergency occurred and that the permittee can identify the cause(s) of the emergency; 2) The permitted facility was at the time being properly operated; 3) During the period ofthe emergency the permittee took all reasonable steps to minimize levels ofemissions that exceeded the emissions standards, or other requirements in this permit; and 4) The permittee submitted notice ofthe emergency to the Department within one working day ofthe time when emission limitations were exceeded longer than 24-hours due to the emergency. This notice must contain a description ofthe emergency, any steps taken to mitigate emissions, and corrective actions taken. Those emergencies not reported within one working day, as well as those that were, will be included in the semi-annual report. 5) In any enforcement proceeding, the permittee seeking to establish the occurrence ofan emergency has the burden ofproof. a) Technology-based emission limits are those established on the basis ofemission reductions achievable with various control measures or process changes (e.g., a New Source Performance Standard)rather than those established to attain a health based air quality standard.Page 32 of 46 PermitNo. T5-F82006
b) An "emergency" means any situation ansmg from sudden and reasonably unforeseeable events beyond the control of this source, including acts of God, which requires immediate corrective action to restore normal operation, and that causes this source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, oroperator error. Applicable Requirement: NDAC 33-15-14-06.5.g I. Air Pollution from Internal Combustion Engines: Thepermittee shall comply with all applicable requirements ofNDAC 33-15-08-01- Internal Combustion Engine Emissions Restricted. Applicable Requirement: NDAC 33-15-08-01 J. Prohibition ofAirPollution: 1) The permittee shall notpermit or cause air pollution, as defined in NDAC 33-15-01-04. 2) Nothing in any other part ofthis permit or any other regulation relating to air pollution shall in any manner be construed as authorizing or legalizing the creation or maintenance ofair pollution. Applicable Requirement: NDAC 33-15-01-15 K. Performance Tests: 1) The Department may reasonably require the permittee to make or have made tests, at a reasonable time or interval, to determine the emission of air contaminants from any source, for the purpose of determining whether the permittee is in violation of any standard orto satisfy otherrequirements ofNDCC 23-25. All tests shall be made and the results calculated in accordance with test procedures approved or specified by the Department including the North Dakota Department of Health Emission Testing Guideline. All tests shall be conducted by reputable, qualified personnel. The Department shall be given a copy ofthe test results in writing and signed by the person responsible for the tests. 2) The Department may conduct tests of emissions of air contaminants from any source. Upon request ofthe Department, the permittee shall provide necessary holes in stacks or ducts and such other safe and proper sampling and testing facilities, exclusiye of instruments and sensing devices, as may be necessary for proper determination ofthe emission ofair contaminants. Applicable Requirement: NDAC 33-15-01-12Page _ll_of 46 PermitNo. T5-F82006

3) Except for sources subject to 40 CFR 63,the permittee shall notify the Department by submitting a Proposed Test Plan, orits equivalent, at least 30 calendar days in advance of any tests of emissions of air contaminants required by the Department. The permittee shall notify the Department at least 60 calendar days in advance of any performance testing required under 40 CFR 63. Ifthe permittee is unable to conduct the performance test on the scheduled date, the permittee shall notify the Department as soon as practicable when conditions warrant, and shall coordinate a new test date with the Department. Failure to give the proper notification may prevent the Department from observing the test. If the Department is unable to observe the test because of improper notification, the testresults may be rejected. Applicable Requirements: NDAC 33-15-14-06.5.a(3)(a), NDAC 33-15-12-02 Subpart A (40 CFR 60.8), NDAC 33-15-13-01.2 Subpart A (40 CFR61.13), NDAC 33-15-22-03 Subpart A (40 CFR 63.7) L. Pesticide Use and Disposal: Any use ofa pesticide or disposal ofsurplus pesticides and empty pesticide containers shall comply withthe requirements inNDAC 33-15-10. Applicable Requirements: NDAC 33-15-10-01 andNDAC 33-15-10-02 M. Air Pollution Emergency Episodes: When an air pollution emergency episode is declared by the Department, the permittee shall comply withthe requirements inNDAC 33-15-11. Applicable Requirements: NDAC 33-15-11-01 throughNDAC 33-15-11-04 N. Stratospheric Ozone Protection: The permittee shall comply with any applicable standards for recycling and emissions reduction pursuant to 40 CFR 82, Subpart F, except as provided for MVACs in SubpartB: 1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuantto Section 82.156. 2) Equipment used during the maintenance, service, repair, or disposal ofappliances must comply with the standards for recycling and recovery equipment pursuant to Section 82.158. 3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certificationprogrampursuantto Section 82.161. 4) Persons owning commercial or industrial process refrigeration equipment must comply withthe leakrepair requirements pursuantto Section 82.156. Applicable Requirement: 40 CFR 82

### Page 34 of 46 PermitNo. T5-F82006



### 0. Chemical Accident Prevention: 

### The permittee shall comply with all applicable requirements of Chemical Accident Prevention pursuant to 40 CFR 68. The permittee shall comply with the requirements ofthis partno later than the latest ofthe following dates: 1) Three years after the date on which aregulated substance is first listed under this part; or 2) The date on which a regulated substance is first present above a threshold quantity in a process. Applicable Requirement: 40 CFR 68 P. Air Pollution Control Equipment: 

### The permittee shall maintain and operate air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. The manufacturer's recommended Operations and Maintenance (O&M) procedures, or a site-specific O&M procedure developed from the manufacturer's recommended O&M procedures, shall be followed to assure proper operation and maintenance ofthe equipment. The permittee shall have the O&M procedures available onsite and provide the Department with a copy whenrequested. Applicable Requirement: NDAC 33-15-14-06.5.b(1) Q. Prevention of Significant Deterioration ofAir Quality (40 CFR 52.21 as incorporated by NDAC Chapter 33-15-15): 

### Ifthis facility is classified as a major stationary source under the Prevention ofSignificant Deterioration ofAir Quality (PSD) rules, a Permit to Construct mustbe obtained from the Department for any project which meets the definition of a "major modification" under 40 CFR 52.21(b)(2). Ifthis facility is classified as a major stationary source under the PSD rules and the permittee elects to use the method specified in 40 CFR 52.21(b)(41)(ii)(a) through (c) for calculating the projected actual emissions of a proposed project, then the permittee shall comply with all applicable requirements of40 CFR 52.21(r)(6). Applicable Requirement: NDAC 33-15-15-01.2 11. General Conditions: 

### A. Annual Fee Payment: 

### The permittee shall pay an annual fee, for administering and monitoring compliance, which is determined by the actual annual emissions ofregulated contaminants from the previous calendar year. The Department will send a notice, identifying the amount ofthe annual permit fee, to the permittee ofeach affected installation. The fee is due within sixty days following the date ofsuch notice. Any source that qualifies as a "small business" may petition the Department to reduce or exempt any fee required under this section. Failure to pay the fee in a timely manner or submit a certification for exemption may cause this Department to initiate actionto revoke the permit.

### Page ]2_

### of 46 PermitNo. T5-F82006 Applicable Requirements: NDAC 33-15-14-06.5.a(7) and NDAC 33-15-23-04 B. Permit Renewal and Expiration: 

### This permit shall be effective from the date ofits issuance for a fixed period of 5 years. The permittee's right to operate this source terminates with the expiration ofthis permit unless a timely and complete renewal application is submitted at least six months, but no more than eighteen months, prior to the date of permit expiration. The Department shall approve or disapprove the renewal application within sixty days of receipt. Unless the Department requests additional information or otherwise notifies the applicant of incompleteness, the application shall be deemed complete. For timely and complete renewal applications for which the Department has failed to issue or deny the renewal permit before the expiration date of the previous permit, all terms and conditions of the permit, including any permit shield previously granted shall remain in effect until the renewal permit has been issued or denied. The application for renewal shall include the current permit number, description of any permit revisions and off-permit changes that occurred during the permit term, and any applicable requirements that were promulgated and not incorporated into the permit during the permitterm. Applicable Requirements: NDAC 33-15-14-06.4 and NDAC 33-15-14-06.6 C. Transfer of Ownership or Operation: 

### This permit may not be transferred except by procedures allowed in Chapter 33-15-14 and is to be returned to the Department upon the destruction or change of ownership of the source unit(s), or upon expiration, suspension or revocation ofthis permit. A change in ownership or operational control ofa source is treated as an administrative permit amendment ifno other change in the permit is necessary and provided that a written agreement containing a specific date for transfer ofpermitresponsibility, coverage, and liability betweenthe current and newpermittee has been submitted to the Department. Applicable Requirement: NDAC 33-15-14-06.6.d D. Property Rights: 

### This permit does not convey any property rights ofany sort, or any exclusive privilege. Applicable Requirement: NDAC 33-15-14-06.5.a(6)(d) E. Submissions: 

### 1) Reports, test data, monitoring data, notifications, and requests for renewal shall be submitted to: North DakotaDepartment ofHealth Division ofAir Quality 918 E Divide Avenue, 2nd Floor Bismarck, ND 58501-1947 2) Any document submitted shall be certified as being true, accurate, and complete by a responsible official. Applicable Requirement: NDAC 33-15-14-06.4.d

### Page 36 of 46 PermitNo. T5-F82006

F. Right of Entry: Any duly authorized officer, employee or agent of the North Dakota Department ofHealth may enter and inspect any property, premise or place listed on this permit or where records are kept concerning this permit at any reasonable time for the purpose of ascertaining the state ofcompliance with this permit and the North Dakota Air Pollution Control Rules. The Department may conducttests and take samples ofair contaminants, fuel, processing material, and other materials which affect or may affect emissions ofair contaminants from any source. The Department shall have the right to access and copy any records required by the Department's rules and to inspect monitoring equipment located onthe premises. Applicable Requirements: NDAC 33-15-14-06.5.c(2) and NDAC 33-15-01-06 G. Compliance: The permittee must comply with all conditions of this permit. Any noncompliance with a federally-enforceable permit condition constitutes a violation of the Federal Clean Air Act. Any noncompliance with any State enforceable condition ofthis permit constitutes a violation ofNDCC Chapter 23-25 and NDAC 33-15. Violation ofany condition of this permit is grounds for enforcement action, for permit termination, revocation and reissuance or modification, or for denial of a permit renewal application. Noncompliance may also be grounds for assessment of penalties under the NDCC 23-25. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in orderto maintain compliance with the conditions ofthis permit. Applicable Requirements: NDAC 33-15-14-06.5.a(6)(a) and NDAC 33-15-14-06.5.a(6)(b) H. Duty to Provide Information: The permittee shall furnish to the Department, within a reasonable time, any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. This includes instances where an alteration, repair, expansion, or change in method ofoperation ofthe source occurs. Upon request, the permittee shall also furnish to the Department copies ofrecords that the permittee is required to keep by this permit, or for information claimed to be confidential, the permittee may furnish such recourse directly to the Department along with a claim ofconfidentiality. The permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the permit application, shall promptly submit such.supplementary facts or corrected information. Items that warrant supplemental information submittal include, but are not limited to, changes in the ambient air boundary and changes in parameters associated with emission points (i.e., stack parameters). The permittee shall also provide additional information as necessary to address any requirements that become applicable to the source afterthe date a complete renewal application was submitted butpriorto release ofa draftpermit. Applicable Requirements: NDAC 33-15-14-06.5.a(6)(e), NDAC 33-15-14-06.6.b(3) and NDAC 33-15-14-06.4.b I. 

### Reopening for Cause: The Department will reopen and revise this permit as necessary to remedy deficiencies in the following circumstances: 1) Additional applicable requirements under the Federal Clean Air Actbecome applicable to the permittee with a remaining permit term ofthree or more years. Such a reopening shall be completed no later than eighteen months after promulgation ofthe applicable

### Page 37 of 46 PermitNo. T5-F82006 requirement. No such reopening is required ifthe effective date ofthe requirement is laterthanthe expiration date ofthis permit. 2) The Department or the United States Environmental Protection Agency determines that this permit contains a material mistake or inaccurate statements were made in establishing the emissions standards or other terms or conditions ofthis permit. Applicable Requirement: NDAC 33-15-14,.06.6.f(1)(c) 3) The Department or the United States Environmental Protection Agency determines that the permit must be revised or revoked to assure compliance with the applicable requirements. 4) Reopenings shall not be initiated before a notice ofintent to reopen is provided to the permittee by the Department at least 30 days in advance ofthe date that this permit is to be reopened, except that the Department may provide a shorter time period in the case of an emergency. Proceedings to reopen and issue this permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts ofthis permit for which cause to reopen exists. Such reopening shall be made as expeditiously as practicable. Applicable Requirement: NDAC 33-15-14-06.6.f J. Permit Changes: 

### The permit may be modified, revoked, reopened, and reissued or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or ofa notification ofplanned changes or anticipated noncompliance does not stay any permit condition. Applicable Requirement: NDAC 33-15-14-06.5.a(6)(c) K. Off-Permit Changes: 

### A permit revision is not required for changes that are not addressed or prohibited by this permit, provided the following conditions are met: 1) No such change may violate any term or condition ofthis permit. 2) Each change must comply with all applicable requirements. 3) Changes under this provision may not include changes or activities subject to any requirement under Title IV or that are modifications under any provision ofTitle I ofthe Federal Clean Air Act. 4) A Permitto Construct underNDAC 33-15-14-02 has been issued, ifrequired. 5) Before the permit change is made, the permittee must provide written notice to both the Department and Air Program (8P-AR), Office ofPartnerships & Regulatory Assistance, US EPA Region 8, 1595 Wynkoop Street, Denver, CO 80202-1129, except for changes that qualify as insignificant activities in Section 33-15-14-06. This notice shall describe each change, the date ofthe change, any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result.Page J]_of 46 PermitNo. T5-F82006

6) The permittee shall record all changes that result in emissions of any regulated air pollutant subject to any applicable requirement not otherwise regulated under this permit, andthe emissions resulting from those changes. The record shall reside at the permittee's facility. Applicable Requirement: NDAC 33-15-14-06.6.b(3) L. Administrative Permit Amendments: This permit may be revised through an administrative permit amendment, ifthe revisionto this permit accomplishes one ofthe following: 1) Corrects typographical errors. 2) Identifies a change in the name, address or phone number ofany person identified in this permit, orprovides a similar minor administrative change at the source. 3) Requires more frequent monitoring or reporting by the permittee. 4) Allows for a change in ownership or operational control of the source where the Department determines that no other change in the permit is necessary, provided that a written agreement containing a specific date for transfer of permit responsibility, coverage and liability between the current and new permittee has been submitted to the Department. 5) Incorporates into the Title V permit the requirements from a Permit to Construct when the review was substantially equivalent to Title V requirements for permit issuance, renewal, reopenings, revisions and permit review by the United States Environmental Protection Agency and affected state review, that would be applicable to the change ifit were subject to review as a permit modification and compliance requirements substantially equivalent to Title V requirements for permit content were contained in the Permitto Construct. 6) Incorporates any other type of change which the Administrator of the United States Environmental Protection Agency has approved as being an administrative permit amendment as part ofthe Department's approved Title V operating permitprogram. Applicable Requirement: NDAC 33-15-14-06.6.d M. Minor Permit Modification: This permit may be revised by a minor permit modification, ifthe proposedpermitmodification meets the following requirements: 1) Does not violate any applicable requirement. 2) Does not involve significant changes to existing monitoring, reporting, or recordkeeping requirements in this permit. 3) Does not require or change a case-by-case determination of an emission limitation or other standard, or a source-specific determination for temporary sources of ambient impacts, or a visibility or increment analysis.

### Page 39 of 46 PermitNo. T5-F82006

4) Does not seek to establish or change a permit term or condition for which there is no corresponding underlying applicable requirement and that the source has assumed to avoid an applicable requirement to which the source would otherwise be subject. Such terms and conditions include a federally enforceable emissions cap assumed to avoid classification as a modification under any 'provision ofTitle I ofthe Federal Clean Air Act; and alternative emissions limit approved pursuant to regulations promulgated under Section 112(i)(5) ofthe Federal CleanAir Act. 5) Are not modifications under NDAC 33-15-12, 33-15-13, and 33-15-15 or any provision ofTitle I ofthe Federal Clean Air Act. 6) Are not required to be processed as a significant modification. Applicable Requirement: NDAC 33-15-14-06.6.e(1) N. Significant Modifications: 

### 1) Significant modification procedures shall be used for applications requesting permit modifications that do not qualify as minor permit modifications or as administrative amendments. Every significant change in existing monitoring permit terms or conditions and every relaxation ofreporting or recor<fkeeping permit terms or conditions shall be considered significant. Nothing therein shall be construed to preclude the permittee from making changes consistent with this subsection that would render existing permit compliance terms and conditions irrelevant. 2) Significant permit modifications shall meet all Title V requirements, including those for applications, public participation, review by affected states, and review by the United States Environmental Protection Agency, as they apply to permit issuance and permit renewal. The Department shall complete review of significant permit modifications within nine months after receipt ofa complete application. Applicable Requirement: NDAC 33-15-14-06.6.e(3) 0. Operational Flexibility: 

### The permittee is allowed to make a limited class ofchanges within the permitted facility that contravene the specific terms ofthis permit without applying for a permit revision, provided the changes do not exceed the emissions allowable under this permit, are not Title I modifications and a Permit to Construct is not required. This class ofchanges does not include changes that would violate applicable requirements; or changes to federally-enforceable permit terms or conditions that are monitoring, recordkeeping, reporting, or compliance certification requirements. The permittee is required to send a notice to both the Department and Air Program (8P-AR), Office of Partnerships & 

### Regulatory Assistance, US EPA Region 8, 1595 Wynkoop Street, Denver, CO 80202-1129, at least seven days in advance of any change made under this provision. The notice must describe the change, when it will occur and any change in emissions, and identify any permit terms or conditions made inapplicable as a result ofthe change. The permittee shall attach each notice to its copy ofthis permit. Any permit shield provided in this permit does not apply to changes made underthis provision.Applicable Requirement: NDAC 33-15-14-06.6.b(2) Page 40 of 46 PermitNo. T5-F82006

P. Relationship to Other Requirements: Nothing inthis permit shall alter or affectthe following: 1) The provisions of Section 303 of the Federal Clean Air Act (emergency orders), including the authority ofthe administrator ofthe United States Environmental Protection Agency underthat section. 2) The liability of an owner or operator of a source for any violation of applicable requirements priorto oratthe time ofpermit issuance. 3) The ability ofthe United States Environmental Protection Agency to obtain information from a source pursuantto Section 114 of

**th~** Federal Clean Air Act. 4) Nothing in this permit shall relieve the permittee ofthe requirement to obtain a Permit to Construct. Applicable Requirements: NDAC 33-15-14-06.3 and NDAC 33-15-14-06.5.f(3)(a), (b) and (d) Q. Severability Clause: The provisions ofthis permit are severable, and if any provision ofthis permit, orthe application ofany provision ofthis permit to any circumstance, is held invalid, the application ofsuch provision to other circumstances, and the remainder ofthis permit, shall not be affected thereby. Applicable Requirement: NDAC 33-15-14-06.5.a(5) R. Circumvention: The permittee shall not cause or permit the installation or use ofany device of any means which conceals or dilutes an emission of air contaminants which would otherwise violate this permit. Applicable Requirement: NDAC 33-15-01-08 12. State Enforceable Only Conditions (not Federally enforceable): A. General Odor Restriction: The permittee shall not discharge into the ambient air any objectionable odorous air contaminantwhich exceeds the limits established in NDAC 33-15-16. Applicable Requirement: NDAC 33-15-16 B. Combustion ofUsed Oil Containing PCBs: Burning ofused oil in EU 1and EU 2 containing PCBs is allowed during normal operations subjectto the following: 1) The owner/operator shall file a Notification of Hazardous Waste Activity (EPA Form 8700-12) with the Department indicating used oil fuel activities.

### Page _±L

### of 46 PermitNo. T5-F82006 2) Only oil which contains less than 50 ppm PCB may be burned. Burning of oil which contains PCB is only allowed for used oil generated by Great River Energy, its associated electric system, or its associated mining facilities. 3) Soil, rock and other earthen debris contaminated with mineral oil dielectric fluid which contains less than 50 ppm PCB may be burned during periods ofstable load. Applicable Requirement: NDAC 33-15-14-06.5.b(1) C. Used Oil Combustion: 

### Burning ofused oil in EU 1, EU 2, EU 3 and EU 4 is allowed subject to the following: 1) 

### The burning ofused oil shall comply with NDAC Sections 33-24-05-600 through 33-24- 05-689

- Standards for the Management of Used Oil

- and other applicable rules, regulations, and ordinances. 2) The annual emission inventory reports required by Condition 9.E shall include the amount ofspecificationused oil burned. Applicable Requirement: NDAC 33-15-14-06.5.b(1) D. Hazardous Waste: 

### The burning of hazardous waste in EU 1 and EU 2 shall comply with NDAC Sections 33-24-05-525 through 33-24-05-549- Boilers Industrial Furnaces (BIFs). Applicable Requirement: NDAC 33-15-14-06.5.b(l) 13. Phase II Acid Rain Provisions: Affected Source Unit: 

### Coal Creek Station ORIS Plant Code: 

### 6030 BoilerID: 

### 1 and 2 This section incorporates the definition of terms in NDAC Chapter 33-15-21 by reference effective April1, 2003. A. Permit Requirements 1) The designated representative ofeach affected source and each affected unit at the source shall: a) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR 72 in accordance with the deadlines specified in NDAC 33-15-14- 08.1 and40 CFR 72.30, including application for permitrenewal; and b) Submit in a timely manner any supplemental information that the North Dakota Department of Health, Division of Air Quality, Air Pollution Control Program determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rainpermit.

### Page 42 of 46 Permit No. T5-F82006 2) The owners and operators ofeach affected source and each affected unit at the source shall: a) Operate the unit in compliance with a complete Acid Rain permit application including any application for permit renewal or a superseding Acid Rain permit issued by the North Dakota Department ofHealth, Division ofAir Quality, Air Pollution Control Program and b) Have an Acid Rain permit. Applicable Requirement: NDAC 33-15-21-08.1 B. Monitoring Requirements 1) The owners and operators and, to the extent applicable, designated representative ofeach affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR 75 and 76. 2) The emissions measurements recorded and reported in accordance with 40 CFR 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitations and emissions reductionrequirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. · 3) The requirements of 40 CFR 75 shall not affect the responsibility of the owners and operators to monitor emissions ofother pollutants or other emissions characteristics at the unit under other applicable requirements of the Federal Clean Air Act and other provisions ofthe operating permit for the source. Applicable Requirements: NDAC 33-15-21-08.1, NDAC 33-15-21-09 and 40 CFR 76 C. Sulfur Dioxide Requirements 1) The owners and operators ofeach source and each affected unit at the source shall: a) Hold allowances, as ofthe allowance transfer deadline, in the units compliance subaccount (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide ·for the previous calendar year from the unit; and b) Comply withthe applicable Acid Rain emissions limitations for sulfur dioxide. 2) Each ton of sulfur dioxide emitted in excess ofthe Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation ofthe Federal Clean Air Act. 3) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program.Page 43 of 46 PermitNo. T5-F82006
4) An allowance shall not be deducted in order to comply with the requirements under Condition C.(l)(a) ofthis permit prior to the calendar year for which the allowance was allocated. 5) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision ofthe Acid Rain Program, the Acid Rain permit application, this permit, orthe written exemption under 40 CFR 72.7 and 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. 6) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Applicable Requirements: NDAC 33-15-21-08.1 and 40 CFR73 D. Nitrogen Oxides Requirements NOx Emission Limitations: The owner or operator shall not discharge, or allow to be discharged, emissions ofNOx (annual average basis) to the atmosphere in excess ofthe following limits: BoilerID
1 2 Emission Limitation 0.40 

### lb/106 Btu 0.40 

### lb/106 Btu The owner/operator shall also comply withthe duty under 40 CFR76.9(d) to reapply for an NOx compliance plan prior to expiration of this permit and requirements under 40 CFR 76.13 for calculatingNOx emissions. Applicable Requirements: 40 CFR76.7(a)(1), 40 CFR76.9(d), 40 CFR76.13 andNDAC 33-15-21-10 E. Excess Emissions Requirements 1) The designated representative ofan affected unit that has excess emissions ofS02 in any calendar year shall submit a proposed offset plan, to the Administrator as required under 40 CFR 77, with a copy to the North Dakota Department of Health, Division of Air Quality, Air Pollution Control Program. 2) The owners and operators ofan affected unit that has excess emissions ofNOx or S02 in any calendar year shall: a) Pay to the Administrator without demand the penalty required, and pay to the Administrator upon demand the interest on that penalty, as required by 40 CFR 77; and Comply withthe terms ofan approved offset plan for S02, as required by 40 CFR77.

### Applicable Requirement: NDAC 33-15-21-08.1 F. Recordkeeping and Reporting Requirements Page 44 of 46 PermitNo. T5-F82006

1) Unless otherwise provided, the owners and operators ofthe source and each affected unit at the source shall keep on-site at the source each ofthe following documents for a period of5 years from the date the document is created. This period may be extended for cause, at any time priorto the end of5 years, in writing by the Administrator ofthe U.S. EPA or the North Dakota Department ofHealth, Division ofAir Quality, Air Pollution Control Program: a) The certificate ofrepresentation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth ofthe statements in the certificate ofrepresentation, in accordance with 40 CPR 72.24; provided that the certificate and documents shall be retained on-site at the source beyond such 5-yearperiod until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; b) All emissions monitoring information, inaccordance with 40 CPR75; c) Copies of all reports, compliance certifications, and other submissions and all records made or required underthe Acid Rain Program; and, d) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements ofthe Acid Rain Program. 2) The designated representative ofan affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CPR 72, Subpart I, NDAC 33-15-21-08, and 40 CPR 75. Applicable Requirements: NDAC 33-15-21-08.1 and NDAC 33-15-21-09 G. Liability 1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, this Acid Rain Permit, or a written exemption under 40 CPR 72.7 or 72.8, including any requirement for the payment ofany penalty owed to the United States, shall be subject to enforcement pursuant to Section 113(c) ofthe Federal Clean AirAct. 2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to Section 113(c) oftheFederal Clean Air Act and 18 U.S.C. 1001.

### Page 45 of 46 PermitNo. T5-F82006
3) No permit revision shall excuse any vioiation of the requirements of the Acid Rain Program that occurs priorto the date that the revision takes effect. 4) Each affected source and each affected unit shall meet the requirements ofthe Acid Rain Program. 5) Any provision ofthe Acid Rain Program that applies to an affected source (including a provision applicable to the designated represented ofan affected source) shall also apply to the owners and operators ofsuch source and ofthe affected units atthe source. 6) Any provision ofthe Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative ofan affected unit) shall also apply to the owners and operators ofsuch unit. Except as provided under 40 CFR 72.44 (Phase II repowering extension plan) and 40 CFR 76.11 (NOx averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit shall not be liable for any violation by any other affected unit ofwhich they are not owners or operators or the designated representative and that is located at a source ofwhich they are not owners or operators or the designated representative. 7) Each violation ofa provision ofNDAC 33-15-21-01 through 33-15-21-10 and 40 CFR parts 72, 73, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative ofsuch source or unit, shall be a separate violation ofthe Federal Clean Air Act. Applicable Requirements: NDAC 33-15-21-08.1, NDAC 33-15-21-09, and 40 CFR 73, 76, 77 and 78 H. Effect on Other Authorities No provision ofthe Acid Rain Program, an Acid Rain permit application, this Acid Rain permit condition, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as: 1) Except as expressly provided in Title IV of the Federal Clean Air Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision ofthe Federal Clean Air Act, including the provisions ofTitle I ofthe Federal Clean Air Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; 2) Limiting the number of allowances a unit can hold; provided, that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions oftheFederal Clean Air Act, 3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence reviewrequirements under such State law;Page 46 of 46 PermitNo. T5-F82006 4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commissionunderthe Federal Power Act; or, 5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. Applicable Requirement: NDAC 33-15-21-08.1 I. · Permit Shield Each affected unit operating in accordance with this permit which is issued in compliance with Title IV ofthe Federal Clean Air Act, as provided in 40 CFR 72, 73, 75, 77 and 78, and the regulations implementing Section407 ofthe Federal Clean Air Act, shall be deemed operating in compliance with the Acid Rain Program, except as provided in 40 CFR 72.9(g)(6). The permit shield does nottake effectuntil the effective date ofthe acid rainpermit. Applicable Requirements: NDAC 33-15-21-08.1, NDAC 33-15-21-09, and 40 CFR73, 77 and 78 J. Reopening for Cause In addition to any reasons for reopening for cause previously stated in this permit, the Department will reopen and revise this permit as necessary to remedy deficiencies in the following circumstance: If additional requirements, including excess emissions requirements, become applicable to an affected source under Title IV of the Federal Clean Air Act or the regulations promulgated there under. Upon approval by the administrator ofthe United States Environmental Protection Agency, excess emissions offset plans shall be deemed to be incorporated into the permit. Applicable Requirements: NDAC 33-15-14-06.6.f(l)(b) and 40 CFR70.7(f)(l)(ii)

### AttachmentA ComplianceAssurance Monitoring (CAM) Plan (EU 1 and 2)

### AttachmentA



# ComplianceAssuranceMonitoring (CAM)

Protocolfor ParticulateMass Emissions Coal CreekStation Boilers 1 and 2

GreatRiverEnergy 12300 Elm CreekBlvd. Maple Grove, MN 55369-4718

Revision Date January 9, 2014COMPLIANCE ASSURANCE MONITORING PROTOCOL ELECTROSTATIC PRECIPITATOR (ESP) AND SPRAY TOWER SCRUBBER FORPARTICLE MASS EMISSIONS CONTROL

I. Background A. Emissions Units Description/ Identification: Facility: Unit 1:6,015 mmBtulhrlignite-fired boiler Unit 2: 6,022 mmBtulhr lignite-fired boiler Coal Creek Station Underwood, ND B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulations: NDAC 

### § 33-15, Permitto Construct (PTC) Emissions Limits (both units): Particulate Matter (PM): (1) 0.10 lb/mmBtu [NDAC 33-15-12,Subpart D] (2) 528 lblhr [PTC Condition 1] Current Monitoring Requirements:

C. Control Technologies

II. Monitoring Approach Continuous Opacity Monitoring (COM) and Periodic compliancetesting (1) Electrostatic precipitator (each unit) (2) Spray tower scrubber (each unit)

The key elements ofthe monitoring approach, includingthe indicators to be monitored, indicatorranges, andperformance criteria are presented inTable 1. The primaryperformance indicatoris the measured opacity from the continuous opacity monitoring system (COMS) onthe stack ofeach unit. This CAM Plan does not apply to units continuously monitoring particulate emissions.

1The PTC "lblhr" limit is based on estimatedboilerheat input and NDAC 33-15-12,SubpartD "lb/mmBtu" limit.III. Corrective Action The key elements ofthe corrective actionprocedures are presented inTable 2. Corrective action is designed to discover and correctthe problemthat is creating the opacity increase. Corrective action is initiated before an excursion has occurred and continues until the potential excursion conditionhas beenrectified. The trigger pointthat initiates corrective action is consecutive stack opacity greater than 20 percentbased ona six-minute average, excluding those events defined as startup/shutdown and malfunctions. Initiation ofcorrective action does not create a reporting requirement.

2Table1.MonitoringApproachComplianceIndicatorI.IndicatorStackopacity.MeasurementApproachTheopacityismeasuredusingaContinuousOpacityMonitoringSystem(COMS)atthestackofeachboiler.II.IndicatorRangeAnexcursionisdefinedasameasuredstackopacitygreaterthan20percent,basedonathree-hourrollingaverage,excludingthoseeventsdefinedasstartup/shutdownandmalfunctions.Anexcursiontriggersareportingrequirement.Correctiveactionmustbeinitiatedwhenconsecutivemeasuredstackopacitysix-minuteaveragesaregreaterthan20percentexcludingthoseeventsdefinedasstartup/shutdownandmalfunctions.Correctiveactiondoesnottriggerareportingrequirement.III.PerformanceCriteriaA.DataRepresentativenessOpacityisrelatedtothesizeandconcentrationofparticlesinthefluegas.Asparticulatemassemissionsincrease,itcanbereasonablyexpectedthatstackopacitywillalsoincrease.Eachboilerdischargestoasingle,dedicatedstack.EachstackisequippedwithaCOMSthatmeetstheinstallationandminimumacceptableaccuracyrequirementsof40CFRPart60,PerformanceSpecification1.TheCOMSislocateddownstreamofthescrubberandESPand,therefore,reflectstheperformanceofbothcontroldevicesandscrubberbypassoperation.B.VerificationofOperationalNotapplicable.Monitoringapproachusesexistingequipment.StatusC.QAIQCPracticesandDailyzeroandcalibrationdriftcheck,periodiccleaningofopticalsurfacesandotherCriteriaperiodicQA/QCchecksasspecifiedintheapplicableversionofPerformanceSpecification1.D.MonitoringFrequencyContinuous.DataCollectionProceduresTheCOMScollectsadatapointevery10secondsandthedataloggerreducesthedatatosixminuteaveragesandthree-hourrollingaverages.AThree-houranaverageforcorrectiveaction.3Table 2. Corrective Action Procedures Summary Description

I. Initiation of Corrective Action Corrective action shall be initiated when consecutive six-minute opacity averages I

Procedures

exceeds 20 percent. The plant staff that made the discovery shall immediately notify

the shift team leader, plant environmental coordinator, and air compliance specialist.

II. Time of Completion of Corrective As soon as practically possible.

Action Procedures •

Ill. Corrective Action Description Figure 1 provides a flow chart summarizing the corrective action procedures. Since .

the ESPs provide the bulk of the particulate emissions removal, corrective action will

focus on ESP operation. Corrective action will begin with an inspection ofthe COMS. Plant staff should

verify the opacity monitor readings, to the extent possible, in the event of a possible

COMS malfunction. If it is determined that the opacity monitor readings are accurate,

plant staff must then verify whether or not saturated flue gas conditions exist in the

stack by observing stack temperature. If saturated stack conditions are present, staff

must increase scrubber bypass such that stack temperature increases above saturation.

If saturated stack conditions are not present, corrective action will continue.

Corrective action will include inspection of one or more ESPs, including an

evaluation of the ash removal and rapper systems. Corrective action may also include

one or more of the following to reduce opacity below the trigger level:

(1) Return tripped ESP sections to service

(2) Increase power levels on remaining, in-service sections (to the extent

possible) (3) Reduce unit load (if absolutely necessary)

- - - -------------- -- - -------------------- 4Has opacity trigger been exceeded for

Is COMS

Yes

Perfonn an inspection ofone ormore ESPs, including an evaluation ofthe ash removal and rapper systems. Corrective action may also include one or more ofthe following: (1) Returning tripped ESP sections to nonnal operation (2) Increasing ESP power on remaining inservice sections (to the extent possible) (3) Load reduction, ifabsolutely necessary No

No

No No action required

RepairCOMS

Increase scrubber bypass (to the extent possible)

Has opacity triggerbeen exceeded for three ormore hours?

Report excursion.

Figure 1. Coal CreekStation CAM Corrective Action Procedures

5MONITORING APPROACHJUSTIFICATION

I. Background Coal Creek is a mine-mouthplant adjacent to the Falkirk Coal Mine in Underwood, ND. Units 1and 2 are tangentially fired boilers that discharge through separate, dedicated stacks. Unit 1has a rated heat input of6,015 mmBtu/hr. Unit 2 has a rated heat input of 6,022 mmBtu/hr. Both units bumlignite coal as theirprimary fuel andNumber 2 fuel oil for unit start-up and flame stabilization. Bothboilers are subject to SIP limits (North DakotaAdministrative Code§ 33-15-12, Subpart D and Permitto Constructconditions) for particulate matter. Units 1and 2 have particulate mass limits of0.10 lb/mmBtu and 528 lb/hr. The units also have a stack opacity limit of20 percent, excluding periods of startup and shutdown. Particulate emissions from eachboiler are controlledbytwo ESPs, located downstream ofthe air heater in a side-by-side configuration. EachESP is six fields deep inthe direction ofgas flow and four sections across. The combined specific collection area for the ESPs is 600 fe/1000 acfm. Neitherunit has bypass capabilities for the ESPs. Each unit is also equipped with a spraytower, flue gas desulfurization system downstream ofthe ESP for the control ofS02 emissions. Each scrubber is designed to remove up to 90 percent ofthe S02from the treated gas. The scrubbers can treatup to 70 percent oftheboiler gas flow. The remainder ofthe gas, which bypasses the absorbers, is used for reheating the gas leaving the absorbers and is controlled by bypass damper position. Although the primary function ofthe control device is S02 control, the scrubber does provide some additional particulate removal. Scrubber operation is automatically controlledbased onboiler load and is relatively constant at normal, full load. Stack temperature is normally well above saturation.2Operating experience has shownthat during periods ofmaximum scrubbing, stacktemperature is still above saturation. Each stack is equipped with an existing Continuous Opacity Monitoring System (COMS), as required by NDAC § 33-15-03-02 and§ 33-15-12, Subpart D. Currently, both units must be tested annually for compliance withparticulate mass emissions limits. There are no direct, continuous particulate monitoring requirements oneither ofthe units. The mostrecent particulate compliancetest, conducted during September2002, demonstrated a particulate mass emissionrate of0.08lb/106 Btufor Unit 1 and 0.05 lb/106 Btu for Unit 2. Recent testing suggests that bothunits are able to meettheir particulate mass emissions limits withoutthe operation ofthe scrubber. GRE voluntarily implements a rigorous maintenance program at Coal Creekthat is designed to maintain optimal performance ofthe ESPs. The maintenance program includes a series ofdaily, weekly, monthly, quarterly, and annual inspections ofthe equipment. Additional inspections are conducted during major outages. The details of these inspections are periodically adjusted based onGRE's engineeringjudgementofthe

2 The stack temperature for Units 1and 2 during normal operation is between 180 and 190 degrees F. This is well above stack saturation.

6mechanical condition ofeach control device. Examples ofthe tasks involved with these inspections are as follows: Daily Inspections

- Inspectionprocedure may include a check ofthe ashhandling system operation, verification ofrapper and voltage controller operation, and/or an inspection ofalarm status and shift logs to identify potential operating problems. Weekly Inspections

- Inspectionprocedure may include checks ofthe primary voltage and current readings, verification ofrapper control systems and operation ofrapper drive motors, and/or checks ofthe transformer-rectifier coolant levels. Monthly Inspections- Inspectionprocedure mayinclude a check ofthe penthouse air conditioning system. Quarterly Inspections

- Inspectionprocedure may include verification ofthe automatic voltage controllercabinet ventilating fan operation, cleaning ofthe control cabinet air filters and/or ventilating fans, and/or verification ofash hopper level indicators. Annual Inspections- Inspection may include a thorough maintenance routine of penthouse air conditioning system. Outage Inspections

- Inspectionprocedure may include internal checks for close clearances between discharge electrodes and collectingplates, checks ofrapper hammers for wear and/orbreakage, verification ofhammer and anvil alignment, checks ofthe rapper drive insulators and drive shafts, and/or checks ofthe internal structure for signs ofdeterioration or leakage. II. Rationale for Selection ofPerformance Indicators and Indicator Ranges Thepurpose ofthis section is to provide technicaljustificationin support ofa compliance assurance protocol based onopacity known as "test and cap." Under a test and cap approach, the relationship ofstack opacity to particulate mass concentrationis determined at or very nearthe opacity limit. Ifthe mass concentration is belowthe permit limit, then two opacity triggerpoints are set atthis level. The first triggerpoint is the threshold at which corrective action is to be performed. This triggerpoint indicates that the control device may not be operatingproperly and action should be takento restore normal operation. The second trigger point defines an excursion. Thistriggerpoint is set at the opacity limit as well but has a longer averaging period and causes a reportable event under CAM. The COMS will be used as the primary indicator for each unit at Coal Creek. The selected indicator range will bethe existing stack opacity limit of20 percent. Corrective action will be initiated when consecutive six-minute average stack opacity exceeds 20 percent. As described in Table 2, corrective action begins with an evaluation ofthe

7occurrence to determine the action required to correct the situation. Consecutive sixminute opacity averages that initiate corrective action do nothave to be reported under CAM (the second six-minute average would be reported according to the NSPS standards). An excursion is defined as a three-hour opacity average of20 percent or higher, excluding startup/shutdown and malfunction events. All excursions will be documented and reported on a unit-basis including the associated corrective action. Opacity Monitor Theory ofOperation All opacity monitors operate under a physicsprinciple known as optical extinction. In a basic configuration, a beam oflight ofa specific wavelength is transmitted across a particulate-laden fluid flow. A receiver at some distance from the transmitter measures the amount oflight that is received. Due to reflection and refraction ofthe lightbeam by the particles withinthe fluid, the amount oflight reaching the receiver will be less than the beam's initial intensity. This property is referredto as transmittance and is represented bythe following equation:

Opacity is related to transmittance by the following equation: 0=1-T The physics ofthe opacity meter are based on Lambert's Law, which canbe expressed mathematically by the following equation:

Where: -SmgmmgX 0=1-e 4
0 = opacity offlue gas . Savg =specific surface area ofthe particles (m2/g) mavg = particulate mass concentration (g!Nm3) x =optical path length (m) For a coal-firedboiler equipped with an ESP operating under normal load, the particle size distribution and specific surface area ofthe particles will remainrelatively similar. This means that any change in opacity, as a first-order approximation, will be directly proportionalto the mass concentration.3 Therefore, while opacity is not a direct measurement ofparticulate mass, it canbe used as a surrogate. Ifopacity is increasing, it canbe reasonably expected that the particulate mass concentration is also increasing. Scrubber Issues Although the primary function ofthe scrubbers at Coal Creek is S02removal, particulate removal is a secondary effect ofthe scrubbingprocess. For configurations where a wetimpingement scrubber is downstream ofan ESP, like Coal Creek, additional particulate

3 Parker, K.R., Applied Electrostatic Precipitation

8removal bythe scrubber is relatively small because ofthe device's low collection efficiency offine particles. This is exacerbated bythe fine particle size distribution ofthe flue gas exiting the ESP. As aresult, under normal operation the ESP will remove most ofthe particulate matter. This is confirmed byprevious test data, which suggestthat the scrubbers at Coal Creek are not required to meetthe particulate emissions limit.4 Because oftheirrelative importance to particulate removal, corrective actionprocedures will focus onthe ESPs. The injection ofthe lime slurry into the flue gas stream from the scrubbing process provides sensible cooling ofthe flue gas. Gas temperature decreases while relative moisture content increases. The flue gas is further cooled inthe ductwork leading to the stack and within the stack itself. Excessive scrubbing can decrease flue gas temperature tothe point where the gas becomes saturated. Underthese saturated conditions, water vapor molecules interfere withthe operationofthe COMS, thereby producing excessivelyhigh opacity measurements. Flue gas temperatures suggestthat this is not a problem for eitherunit at Coal Creek. Both stacks operate well above saturation during normal load.5Atmaximum scrubbing condition, the stacks still operate above saturation. Scrubberoperation is controlledbased on generator load and is relatively constant. As a result, stacktemperatures are also relatively constant. Given the possibilitythat saturated stack conditions may occasionally cause false excursions, part ofthe initial corrective action procedure is to check for saturated stack conditions and adjust scrubberbypass as necessary to increase temperature above saturation. The scrubber does not impose any additional restrictions on the application ofa test and cap monitoring approach. Under §64.4(g) ofthe CAM rule, sources may apply a single monitoring approach to multiple control devices. Use ofthe existing COMS as the compliance indicator for CAM is valid because it reflects the performance ofbothcontrol devices. Ifthe ESP or scrubber fail for any reason, the net effect will be the same - an increase in opacity andparticulate emissions. Furthermore, the COMS will automatically account for the changes in opacity as a result ofscrubberbypass operation, thereby fulfilling the bypass monitoringrequirements of§64.3(a)(2).

4A Study ofToxicEmissions from a Coal-FiredPowerPlant Utilizing an ESP/Wet FGD System, U.S. Department ofEnergy, 1992. 5 Flue gas temperature is typically above 180° F during normal operation.

9Opacity and CAM Developing an accurate correlationbetween opacity and particulate mass is difficult, if not impossible, because ofthe variability inthe process factors that affect the particle properties and size distribution. For CAM, however, it is sufficient that the indicator and emissionrate are related so as to provide a reasonable assurance ofcompliance. The previous section on opacity measurementprinciples demonstrates this relationship. Furthermore, the use ofopacity as a CAM indicator for particulate mass, withthe existing opacity limit as the indicatorrange, is considered presumptively acceptable under §64.3(d), providedthere are sufficient datato showthatthis indicatorrange is appropriate. Verification ofOpacity/Mass Relationships Particulate mass emissions tests were conducted at the stack ofeachunitto validate the selection ofthe monitoring approach and indicatorrange. The objective ofthe testing was to derive the opacity/mass relationship for each unit and show that while opacity is maintained at orbelowthe current opacity limit, bothunits also demonstrate a reasonable assurance ofcompliance withthe particulate mass limits. Testing was conducted on Units 1and 2 beginningJune 16, 2003, through June 21, 2003. Additional details onthe results ofthe particulatetesting canbe found inthe final test report.6 The test program was designed to simulate boiler and control device operationunder the normal or "baseline" operating condition and under two additional conditions that simulated varying degrees ofcontrol device failure. Since the ESPs are the primary particulate control devices for bothunits and the most likely cause ofany excursions, tests simulating control device failures were conducted only for the ESPs. Both scrubbers were undernormal, steady-state operation for the duration ofeachtest. Any change in stack opacity andparticulate mass emissions was attributed to the operation ofthe ESPs. The most commontypes ofESP failure (or cause ofreducedperformance) are either grounded fields or close clearances. In orderto simulate these conditions, the ESP ofthe tested unit was "de-tuned" by reducing and/or eliminatingpowerto selectedportions of the precipitator. This effectively increases the particulate mass loading and opacity atthe stack. These "de-tuned" tests included a "high-level" test, where the stack opacity was close to the 20 percent limit, and a "mid-level"test where the stack opacity is approximately halfway betweenthe high-level test and the normal operating duct opacity. Foreachtest, boilers were operated at normal full load. This represents the highest level ofparticulate mass emissions and will produce conservative indicatorranges underthe proposed CAMmonitoring approach. Eachtest consisted ofthree runs using EPA Reference Method 17. Boiler, scrubber and ESP operating data were also taken to demonstrate stable, normal load operation during eachtest.

6 ComplianceAssuranceMonitoringPerformance Testing, Coal Creek Station, Units 1 and2, RMB Consulting & Research, 9/19/03.

10Unit 1Results Table 1 shows a summary ofthe test results for Unit 1. Forthe baseline condition, the data show an opacity oftwo percent and particulate emissions rates of0.003 lb/mmBtu and 18 lb/hr. This suggests that Unit 1operates at less than five percent ofits mass limit during normal operation.

Test Condition Baseline ESP "De-tuned" (Mid) ESP "De-tuned" (High) Stack, Opacity 2 12 17 Particulate Mass Emissions [lb/mmbtu] 0.003 0.032 0.038 Table 3. Unit 1CAM Test Results Particulate Mass Emissions [lblhr]

18 196 229

Forthe "de-tuned"tests, Unit 1boiler was operating under steady, normal load andthe ESP powerlevels where reduced to simulate control device failure. Forthe "mid-level" condition, the data show an opacity of 12 percent and particulate mass emissions rates of 0.032 lb/mmBtu and 196 lb/hr. Forthe "high-level" condition, the data showan opacity of 17 percent and particulate mass emissions rates of0.038lb/mmBtuand 229lb/hr. Figures 2 and 3 showgraphs ofthe opacity/unitmass relationships for Unit 1including the baseline and de-tuned operating conditions. Based ona four-point linear regression, the predicted mass emissions rates at 20 percent opacity are 0.049lb/mmBtu and 296 lb/hr. The data suggestthat, under**t~is** "worst-case" scenario, the particulate mass emissions are approximately 50 percent ofthe mass emissions limits. This suggests a relatively large compliance margin for CAM.

30 --·

25
nit I assEnissio s@2 %=C.0491 mmBu 20 // 

## • 15 // De-tL edC nditio s 

# • 10 / slseline ondit on t'

0.00 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.10 0.11 0.12 0.13 0.14 0.15 Particulate Mass Emlsstons Rate (lblrmtBtu] Figure2. Unit 1Opacity/Mass Relationship [lb/mmBtu]

1130 

### I 25 I Unit I Ma Emissions @ 2 %= 296lb/hr 

### I

# ~ I ! / De-tuned onditions 

# I**~** 

# / 20

15

10 /



# /'•sel**~e** Condition

100 200 300 500 600 Partlculale Mass Emissions Rate [lblhr] Figure3. Unit 1 Opacity/Mass Relationship [lb/hr)
Unit 2 Results Table 4 shows a summary ofthe test results for Unit 2. Forthe baseline condition, the data show an opacity offive percent and particulate emissions rates of0.004 lb/mmBtu and 18 lblhr. This suggests that Unit 2 also operates at less than five percent ofits mass limit during normal operation.
Particulate Particulate Stack Mass Emissions Mass Emissions TestCondition**OQaci~** [lb/mmbtu] [lb/hr] Baseline 5 0.004 28 ESP "De-tuned" (Mid) 14 0.023 151 ESP "De-tuned" (High) 18 0.040 354 Table4. Unit 2 CAM Test Results
For the "de-tuned"tests, Unit 2 boiler was operating under steady, normal load and the ESP powerlevels where reduced to simulate control device failure. Forthe "mid-level" condition, the data showan opacity of 14 percent and particulate mass emissions rates of 0.023 lb/mmBtu and 151 lblhr. Forthe "high-level" condition, the data show an opacity of 18 percent and particulate mass emissions rates of0.040 lb/mmBtu and 354 lblhr. Figures 4 and 5 show graphs ofthe opacity/unitmass relationships for Unit 2 including the baseline and de-tuned operating conditions. Based on a four-point linearregression, the predicted mass emissions rates at 20 percent opacity are 0.040 lb/mmBtu and 341 lblhr. The data suggestthat, underthis "worst-case" scenario, the particulate mass emissions are less than 50 percent ofthe "lb/mmbtu" mass emissions limit and less than 65 percent ofthe "lblhr" emissions limit.

1230

25
nit 2 assEnissio s@2 o/o= .0401 /mmn Btu 20 

# L; ned(pnditi ns 15 

# I

10 

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0.00 0,01 0.02 0.03 O.G4 0.05 0.06 0.07 0.08 0.09 0.10 0.11 0.12 0.13 0.14 0.15 ESP Outlet Particulate Mass ConcentrationJlblmmBtu) Figure 4. Unit 2 Opacity/Mass Relationship [lb/mmBtu]

30 

### I 25 i I Unit 2M'" Emissions@ 2 % = 341 lb/hr 

### J 20 i / 

## • I De-t ned Conditiops' 

### I
/ 

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### I

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I 0 0 100 200 300 400 500 600 Particulate Mass Emissions Rate [lb/hr) Figure 5. Unit 2 Opacity/Mass Relationship [lb/hr) Monitoring Approach Validity The test data showthat the opacity/mass relationships supporttheproposedtest and cap approach using the COMS as the primary indicator with a trigger level of20percent for both corrective action and excursions. In all cases, the opacity/mass relationships predicted mass emissions that were belowthe mass limits ofeachunit at 20 percent opacity. This suggests thatthe selected indicator and indicatorrange meetthe general design criteria outlined in §64.3(a) ofthe CAM Rule and will be sufficientto demonstrate a reasonable assurance ofcompliance during normal operationofeach unit.

13