DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY OPERATING PERMIT

Transcription

1 DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY OPERATING PERMIT Permit No. AQ0173TVP02 Issue Date: July 26, 2011 Expiration Date: <Five Years> The Department of Environmental Conservation, under the authority of AS and 18 AAC 50, issues an operating permit to the Permittee, Golden Valley Electric Association, Inc., for the operation of the. This permit satisfies the obligation of the owner and operator to obtain an operating permit as set out in AS (b). As set out in AS (c), the Permittee shall comply with the terms and conditions of this operating permit. Citations listed herein are contained within 18 AAC 50 dated April 13, 2011, Register 198. All Federal regulation citations are from those sections adopted by reference in this version of regulation in 18 AAC unless otherwise specified. Upon effective date of this permit, Operating Permit No. AQ0173TVP01, Revision 2 expires. This Operating Permit becomes effective <insert date 30 days after issue date>. John F. Kuterbach, Manager Air Permits Program C:\Documents and Settings\mgmorgan\Desktop\AQ0173TVP02 PN2 Draft Permit SOB docx

2 Permit No. AQ0173TVP02 Issued: July 26, 2011 Table of Contents Section 1. Stationary Source Information...1 Identification...1 Names and Addresses... 1 Section 2. Emission Unit Inventory and Description...2 Section 3. State Requirements...3 Section 4. Visible Emissions Standards...3 Visible Emissions Monitoring, Recordkeeping and Reporting...3 Particulate Matter Emissions Standards... 8 PM Monitoring, Recordkeeping and Reporting... 8 Sulfur Compound Emission Standards Requirements BACT, Owner Requested Limits, and Other Title I Permit Requirements Insignificant Emission Units...24 Conditions for Coal-Fired Boilers, Including Standard Operating Conditions for Boilers in Operation before July Section 5. Performance Audits for COMS...31 Section 6. Federal Requirements...33 Emission Units Subject to Federal New Source Performance Standards (NSPS), Subpart A...33 Steam Generating Units Subject to NSPS Subpart Dc...41 Non-Metallic Mineral Processing Subject to NSPS Subpart OOO...43 Emission Units/Stationary Sources Subject to Federal National Emission Standards for Hazardous Air Pollutants (NESHAPs) General Provisions...44 Stationary Reciprocating Internal Combustion Engines Subject to 40 C.F.R. Part 63, Subpart ZZZZ (EU ID 5)...45 NESHAP for Area Sources: Industrial, Commercial, and Institutional Boilers, 40 C.F.R. 63, Subpart JJJJJJ (EU IDs 3 and 4)...46 Section 7. General Conditions...48 Standard Terms and Conditions...48 NESHAPs Applicability Determinations...51 Halon Prohibitions, 40 C.F.R Open Burning Requirements...54 Section 8. General Source Testing and Monitoring Requirements...55 Section 9. General Recordkeeping and Reporting Requirements...58 Recordkeeping Requirements...58 Reporting Requirements...58 Section 10. Permit Changes and Renewal...62 ii

3 Permit No. AQ0173TVP02 Issued: July 26, 2011 Section 11. Compliance Requirements...65 General Compliance Requirements...65 Section 12. Permit As Shield from Inapplicable Requirements...67 Section 13. Visible Emissions Forms...69 Visible Emissions Field Data Sheet...69 Visible Emissions Observation Record...70 Section 14. Material Balance Calculation...71 Section 15. ADEC Notification Form...72 iii

4 Permit No. AQ0173TVP02 Issued: July 26, 2011 List of Abbreviations Used in this Permit AAC...Alaska Administrative Code ADEC...Alaska Department of Environmental Conservation AS...Alaska Statutes ASTM...American Society for Testing and Materials BACT...Best Available Control Technology BHp...Boiler Horsepower C.F.R....Code of Federal Regulations The Act...Clean Air Act CO...Carbon Monoxide dscf...dry standard cubic foot EPA...US Environmental Protection Agency EU...Emission Unit gr./dscf...grain per dry standard cubic foot (1 pound = 7000 grains) GPH...gallons per hour HAPs...Hazardous Air Pollutants [HAPs as defined in AS ] ID...Emission Unit Identification Number kpa...kilopascals LAER...Lowest Achievable Emission Rate MACT...Maximum Achievable Control Technology as defined in 40 C.F.R. 63. MMBtu/hr...Million British thermal units per hour MMSCF...Million standard cubic feet MR&R...Monitoring, Recordkeeping, and Reporting NESHAPs...Federal National Emission Standards for Hazardous Air Pollutants [NESHAPs as contained in 40 C.F.R. 61 and 63] NO X...Nitrogen Oxides NSPS...Federal New Source Performance Standards [NSPS as contained in 40 C.F.R. 60] O & M...Operation and Maintenance O 2...Oxygen PAL...Plantwide Applicability Limitation PM-10...Particulate Matter less than or equal to a nominal ten microns in diameter ppm...parts per million ppmv, ppmvd Parts per million by volume on a dry basis psia...pounds per Square Inch (absolute) PSD...Prevention of Significant Deterioration PTE...Potential to Emit SIC....Standard Industrial Classification SO 2...Sulfur dioxide TPH...Tons per hour TPY...Tons per year VOC...volatile organic compound [VOC as defined in 40 C.F.R (s)] VOL...volatile organic liquid [VOL as defined in 40 C.F.R b, Subpart Kb] vol%...volume percent wt%...weight percent iv

5 Section 1. Stationary Source Information Identification Names and Addresses Permittee: Golden Valley Electric Association, Inc. P.O. Box Fairbanks, Alaska Stationary Source Name: Location: North; West Physical Address: Mile 2.5 Healy Spur Road, Healy, Alaska Owner(s): GVEA (owner of Unit No. 1 system) P.O. Box Fairbanks, Alaska Operator: Permittee s Responsible Official Designated Agent: Stationary Source and Building Contact: Fee Contact: Permit Contact: Process Description: SIC Code: Alaska Industrial Development and Export Authority AIDEA (owner of Unit 2 HCCP system) 813 West Northern Lights Boulevard Anchorage, Alaska Golden Valley Electric Association P.O. Box Fairbanks, Alaska Ms. Kathryn Lamal Vice President of Power Supply Ms. Kristen DuBois Environmental Officer P.O. Box Fairbanks, Alaska Mr. David Hoffman Plant Manager (907) Ms. Kristen DuBois Environmental Officer P.O. Box Fairbanks, Alaska Ms. Kristen DuBois Environmental Officer P.O. Box Fairbanks, Alaska Electrical Services Establishments engaged in the generation, transmission, and/or distribution of electric energy for sale Page 1 of 74

6 Section 2. Emission Unit Inventory and Description Emission units listed in Table A have specific monitoring, record keeping, or reporting conditions in this permit. Emission unit descriptions and ratings are given for identification purposes only. EU ID 1 Unit #1 2 HCCP Table A - Emission Units Inventory Emission Unit Name Emission Unit Description Rating/Size 3 Auxiliary Heater #1 4 Auxiliary Heater #2 5 Diesel Generator #1 6 Crusher System (dust collector #1) Foster-Wheeler Boiler pulverized coal fired steam generator with a 12 module ICA baghouse TRW Integrated Entrained Combustion System pulverized coal-fired steam generator, Joy Activated Recycle Spray Dryer Absorber, and Joy Pulse Jet Fabric Filter Cleaver Brooks CB Standby process and building heater Cleaver Brooks CB 800 Standby process and building heater Electro-Motive Diesel EMD E4 Standby diesel electric generator set Crusher System: 2 grizzlies, 1 primary Stamler crusher, 2 belt feeders, 2 secondary crushers, 2 hoppers, and the #1 conveyor belt (tail-end), all commonly vented to dust collector #1 (baghouse/exhaust fan). 327 MMBtu/hr MMBtu/hr MMBtu/hr MMBtu/hr MW tons/hr Lime Storage Silo Limestone Storage Silo with baghouse 314 tons Flyash Storage Silo Flyash Storage Silo with baghouse 570 tons Trona Handling Trona Handling System: System Mill, trona silo, and baghouse 50 ton Coal Handling System (dust collector #2) Firewater Pump Engine Fugitive Emission Sources Coal Handling System: #1 conveyor belt (head-end), #2a conveyor belt, #2b conveyor belt, one bucket elevator, #3 conveyor belt, #4 conveyor belt, two 600 ton HCCP coal storage silos, two Unit #1 bunkers, all commonly vented to dust collector #2 (baghouse/exhaust fan). Note: When HCCP is not operational, dust is collected at the Emission Unit #1 transfer points via a temporary dust collector (baghouse/exhaust fan). Caterpillar Diesel Model 3406B 11 Haul Road (located on GVEA property) 12 Coal Storage Pile 240 tons of coal/hr hp 1997 Construction Date ¼ mi. from Usibelli Coal Mine property line to coal pile Up to a 30 day coal supply w/ both EU IDs 1 and 2 operating [18 AAC (a)] [40 C.F.R. 71.5(c)(3)] Page 2 of 74

7 Section 3. State Requirements Visible Emissions Standards 1. Industrial Process and Fuel-Burning Equipment Visible Emissions. The Permittee shall comply with the following: 1.1 Do not cause or allow visible emissions, excluding condensed water vapor, emitted from EU IDs 3 through 6, 9 and 10 listed in Table A to reduce visibility through the exhaust effluent by more than 20 percent averaged over any six consecutive minutes. [18 AAC (j), (a)(1) & (a)(5); and 18 AAC (j)] [40 C.F.R. 71.6(a)(1)] 1.2 For EU IDs 6, 9 and 10 monitor, record and report in accordance with Conditions 2-4. [18 AAC (j), 7/25/08; 18 AAC (j) and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)] 1.3 For EU IDs 3 through 5, as long as each emission unit does not exceed 400 hours of total (emergency and non-emergency hours combined) operation per calendar year, monitoring shall consist of an annual certification of compliance with the opacity standard. Otherwise, monitor, record, and report visible emissions in accordance with Conditions 2-4. The Permittee shall report under Condition 103 if any of EU IDs 3 through 5 exceeds 400 operating hours, and becomes subject to Conditions 2-4, and if such unit exceeds 800 hours, and becomes subject to Condition 2.1g. Visible Emissions Monitoring, Recordkeeping and Reporting EU IDs 3 through 6, 9 and 10 [18 AAC (j), 7/25/08; 18 AAC (j) and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)] 2. Visible Emissions Monitoring. The Permittee shall observe the exhaust of EU IDs 3 through 6, 9 and 10 for visible emissions using either the Method 9 Plan under Condition 2.1or the Smoke/No-Smoke Plan 1 under Condition 2.2. The Permittee may change visibleemissions plans for an emission unit at any time unless prohibited from doing so by Condition 2.3. The Permittee may elect to continue a visible emission monitoring schedule in effect from the previous permit at the time a renewed permit is issued if applicable. [18 AAC (j); 18 AAC (j) and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(i)] 2.1 Method 9 Plan. For all 18-minute observations in this plan, observe exhaust, following 40 C.F.R. 60, Appendix A-4, Method 9, adopted by reference in 18 AAC (a), for 18 minutes to obtain 72 consecutive 15-second opacity observations. 1 In this permit, for monitoring visible emissions, the term smoke also means visible emissions that are not products of combustion. Page 3 of 74

8 EU IDs 6 through 10 a. First Method 9 Observation. Unless electing to continue a visible emission monitoring schedule in effect from the previous permit, observe exhaust for 18 minutes within six months after the issue date of this permit. For any emission unit, observe exhaust for 18 minutes within 14 calendar days after changing from the Smoke/No-Smoke Plan of Condition 2.2. For any emission units replaced during the term of this permit, observe exhaust for 18 minutes within 30 days of startup. b. Monthly Method 9 Observations. After the first Method 9 observation, perform 18-minute observations at least once in each calendar month that an emission unit operates. c. Semiannual Method 9 Observations. After observing emissions for three consecutive operating months under Condition 2.1b, unless a six-minute average is greater than 15 percent and one or more observations are greater than 20 percent, perform 18-minute observations at least semiannually. Semiannual observations must be taken between four and seven months after the previous set of observations. d. Annual Method 9 Observations. After at least two semiannual 18-minute observations, unless a six-minute average is greater than 15 percent and one or more individual observations are greater than 20 percent, perform 18-minute observations at least annually. Annual observations must be taken between 10 and 13 months after the previous observations. e. Increased Method 9 Frequency. If a six-minute average opacity is observed during the most recent set of observations to be greater than 15 percent and one or more observations are greater than 20 percent, then increase or maintain the 18-minute observation frequency for that emission unit to at least monthly intervals, until the criteria in Condition 2.1c for semiannual monitoring are met. EU IDs 3 through 5 (Fuel Burning Equipment) f. First Method 9 Observation. Observe exhaust while firing on liquid fuel per Condition 2.1 within 30 days after the end of a calendar month in which the cumulative hours of operation on liquid fuel for the past calendar year exceed 400 hours, except (i) when an 18-minute Method 9 observation has already been conducted in accordance with Condition 2.1 in the same calendar year period, and (ii) the emission unit appears to not have excess visible emissions while in operation on liquid fuel. Page 4 of 74

9 g. Second Method 9 Observation. Observe exhaust per Condition 2.1 within 30 days after the end of a calendar month in which the cumulative hours of operation for the past calendar year exceed 800 hours. h. Increased Method 9 Frequency. If a six-minute average opacity is observed during the most recent set of observations to be greater than 15 percent and one or more observations are greater than 20 percent, then increase or maintain the 18-minute observation frequency for that emission unit to at least monthly intervals, until a six-minute average opacity observed during the most recent set of observations is not greater than 15 percent or no observation is greater than 20 percent. Observations are not required under this Condition 2.1h if the emission unit is not otherwise operated during the month. 2.2 Smoke/No Smoke Plan. Observe the exhaust for the presence or absence of visible emissions, excluding condensed water vapor. a. Initial Monitoring Frequency. Observe the exhaust during each calendar day that an emission unit operates. b. Reduced Monitoring Frequency. After the emission unit has been observed on 30 consecutive operating days, if the emission unit operated without visible smoke in the exhaust for those 30 days, then observe emissions at least once in every calendar month that an emission unit operates. c. Smoke Observed. If smoke is observed, either begin the Method 9 Plan of Condition 2.1 or perform the corrective action required under Condition Corrective Actions Based on Smoke/No Smoke Observations. If visible emissions are present in the exhaust during an observation performed under the Smoke/No Smoke Plan of Condition 2.2, then the Permittee shall either follow the Method 9 plan of Condition 2.1 or a. initiate actions to eliminate smoke from the emission unit within 24 hours of the observation; b. keep a written record of the starting date, the completion date, and a description of the actions taken to reduce smoke; and c. after completing the actions required under Condition 2.3a, (i) take Smoke/No Smoke observations in accordance with Condition 2.2. (A) (B) at least once per day for the next seven operating days and until the initial 30 day observation period is completed; and continue as described in Condition 2.2b; or Page 5 of 74

10 (ii) if the actions taken under Condition 2.3a do not eliminate the smoke, or if subsequent smoke is observed under the schedule of Condition 2.3c(i)(A), then observe the exhaust using the Method 9 Plan unless the Department gives written approval to resume observations under the Smoke/No Smoke Plan; after observing smoke and making observations under the Method 9 Plan, the Permittee may at any time take corrective action that eliminates smoke and restart the Smoke/No Smoke Plan under Condition 2.2a. 3. Visible Emissions Recordkeeping. The Permittee shall keep records as follows: 3.1 When using the Method 9 Plan of Condition 2.1, a. the observer shall record [18 AAC (j); 18 AAC (j), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(ii)] (i) (ii) (iii) (iv) (v) the name of the stationary source, emission unit and location, emission unit type, observer's name and affiliation, and the date on the Visible Emissions Field Data Sheet in Section 13; the time, estimated distance to the emissions location, sun location, approximate wind direction, estimated wind speed, description of the sky condition (presence and color of clouds), plume background, and operating rate (load or fuel consumption rate) on the sheet at the time opacity observations are initiated and completed; the presence or absence of an attached or detached plume and the approximate distance from the emissions outlet to the point in the plume at which the observations are made; opacity observations to the nearest five percent at 15-second intervals on the Visible Emissions Observation record in Section 13, and the minimum number of observations required by the permit; each momentary observation recorded shall be deemed to represent the average opacity of emissions for a 15-second period. b. for EU IDs 3 through 6, 9 and 10, to determine the six-minute average opacity, divide the observations recorded on the record sheet into sets of 24 consecutive observations; sets need not be consecutive in time and in no case shall two sets overlap; for each set of 24 observations, calculate the average by summing the opacity of the 24 observations and dividing this sum by 24; record the average opacity on the sheet. c. for EU IDs 3 through 6, 9 and 10 calculate and record the highest 18- consecutive-minute averages observed. 3.2 If using the Smoke/No Smoke Plan of Condition 2.2, record the following information in a written log for each observation and submit copies of the recorded information upon request of the Department: a. the date and time of the observation; Page 6 of 74

11 b. from Table A, the ID of the emission unit observed; c. whether visible emissions are present or absent in the exhaust; d. a description of the background to the exhaust during the observation; e. if the emission unit starts operation on the day of the observation, the startup time of the emission unit; f. name and title of the person making the observation; and g. operating rate (load or fuel consumption rate). 4. Visible Emissions Reporting. The Permittee shall report visible emissions as follows: [18 AAC (j); 18 AAC (j), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(iii)] 4.1 in each stationary source operating report under Condition 103, include for the period covered by the report: a. which visible-emissions plan of Condition 2 was used for each emission unit; if more than one plan was used, give the time periods covered by each plan; b. for each emission unit under the Method 9 Plan, (i) (ii) copies of the observation results (i.e. opacity observations) for each emission unit that used the Method 9 Plan, except for the observations the Permittee has already supplied to the Department; and a summary to include: (A) (B) (C) number of days observations were made; highest six-minute average observed; and dates when one or more observed six-minute averages were greater than 20 percent; c. for each emission unit under the Smoke/No Smoke Plan, the number of days that Smoke/No Smoke observations were made and which days, if any, that smoke was observed; and d. a summary of any monitoring or record keeping required under Conditions 2 and 3 that was not done; 4.2 report under Condition 102: a. the results of Method 9 observations that exceed an average of 20 percent opacity for any six-minute period; and b. if any monitoring under Condition 2 was not performed when required, report within three days of the date the monitoring was required. Page 7 of 74

12 Particulate Matter Emissions Standards 5. Industrial Process and Fuel-Burning Equipment Particulate Matter. The Permittee shall not cause or allow particulate matter emitted from EU ID(s) 3 through 5 listed in Table A to exceed 0.05 grains per cubic foot of exhaust gas corrected to standard conditions and averaged hourly, EU ID 9 listed in Table A to exceed 0.05 grains per cubic foot of exhaust gas corrected to standard conditions and averaged over three hours, and EU ID(s) 6 and 10 listed in Table A to exceed 0.02 grains per cubic foot of exhaust gas corrected to standard conditions and averaged hourly. [18 AAC (j), (b)(1), & (c); and 18 AAC (j)] [40 C.F.R. 71.6(a)(1)] [AQC Permit #9431-AA001, Conditions 45, 46, 47, and Exhibit B] 5.1 For EU IDs 3 through 5, as long as each emission unit does not exceed 400 hours of total (emergency and non-emergency hours combined) operation per calendar year, monitoring shall consist of an annual certification of compliance with the particulate matter standard. Otherwise, for emission units 3 and 4, monitor, record and report in accordance with Conditions 8, 9 and 10, and for emission unit 5, monitor, record and report in accordance with Conditions 6, 7 and 10. PM Monitoring, Recordkeeping and Reporting Diesel Engines (EU ID 5) [18 AAC (j), 7/25/08; 18 AAC (j), 12/1/04 and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)] 6. Particulate Matter Monitoring for Diesel Engines. The Permittee shall conduct source tests on the diesel engine, EU ID 5, to determine the concentration of particulate matter (PM) in the exhaust of the emission unit in accordance with this Condition 6. [18 AAC (j); 18 AAC (j), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(i)] 6.1 Except as provided in Condition 6.4 within six months of exceeding the criteria of Conditions 6.2a or 6.2b, either a. conduct a PM source test according to requirements set out in Section 8; or b. make repairs so that emissions no longer exceed the criteria of Condition 6.2; to show that emissions are below those criteria, observe emissions as described in Condition 2.1 under load conditions comparable to those when the criteria were exceeded. 6.2 Conduct the test according to Condition 6.1 if a. 18 consecutive minutes of Method 9 observations result in an 18-minute average opacity greater than 20 percent; or b. for an emission unit with an exhaust stack diameter that is less than 18 inches, 18 consecutive minutes of Method 9 observations result in an 18-minute average opacity that is greater than 15 percent and not more than 20 percent, unless the Department has waived this requirement in writing. Page 8 of 74

13 6.3 During each one-hour PM source test run, observe the exhaust for 60 minutes in accordance with Method 9 and calculate the average opacity that was measured during each one-hour test run. Submit a copy of these observations with the source test report. 6.4 The automatic PM source test requirement in Conditions 6.1 and 6.2 is waived for an emission unit if a PM source test on that unit has shown compliance with the PM standard during this permit term. 7. Particulate Matter Reporting for Diesel Engines. The Permittee shall report as follows: 7.1 report under Condition 102 [18 AAC (j); 18 AAC (j), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(iii)] a. the results of any PM source test that exceeds the PM emissions limit; or b. if one of the criteria of Condition 6.2 was exceeded and the Permittee did not comply with either Condition 6.1a or 6.1b, this must be reported by the day following the day compliance with Condition 6.1 was required; 7.2 report observations in excess of the threshold of Condition 6.2b within 30 days of the end of the month in which the observations occur; 7.3 in each operating report under Condition 103, include for the period covered by the report: a. the dates, EU ID, and results when an observed 18-minute average was greater than an applicable threshold in Condition 6.2; b. a summary of the results of any PM testing under Condition 6; and c. copies of any visible emissions observation results (opacity observations) greater than the thresholds of Condition 6.2, if they were not already submitted. Liquid-Fired Heaters and Boilers (EU IDs 3 and 4) 8. Particulate Matter Monitoring. The Permittee shall conduct source tests on EU IDs 3 and 4 to determine the concentration of PM in the exhaust of EU IDs 3 and 4 as follows: [18 AAC (j), 18 AAC (j)(4), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(i) & (c)(6)] 8.1 Conduct a PM source test according to the requirements set out in Section 8 no later than 90 calendar days after any time corrective maintenance fails to eliminate visible emissions greater than the 20 percent opacity threshold for two or more 18-minute observations in a consecutive six-month period. 8.2 During each one-hour PM source test run, observe the exhaust for 60 minutes in accordance with Method 9 and calculate the average opacity that was measured during each one-hour test run. Page 9 of 74

14 8.3 The PM source test requirement in Condition 8 is waived for an emission unit if: a. a PM source test during the most recent semiannual reporting period on that unit shows compliance with the PM standard since permit issuance, or b. if a follow-up visible emission observation conducted using Method-9 during the 90 days shows that the excess visible emissions described in Condition 2.1e no longer occur. 9. Particulate Matter Recordkeeping. The Permittee shall keep records of the results of any PM testing and visible emissions observations conducted under Condition 8. [18 AAC (j), 18 AAC (j)(4), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)(ii) & (c)(6),] 10. Particulate Matter Reporting. The Permittee shall report as follows: [18 AAC (j),, 18 AAC (j)(4), and 18 AAC (c),] [40 C.F.R. 71.6(a)(3)(iii) & (c)(6),] 10.1 In each operating report required by Condition 103, include a. the dates, EU ID(s), and results when an 18-minute opacity observation was greater than the applicable threshold criterion in Condition 2.1e. b. a summary of the results of any PM testing and visible emissions observations conducted under Condition Report as excess emissions, in accordance with Condition 102, any time the results of a source test for PM exceeds the PM emission limit stated in Condition 5. For Baghouses (EU IDs 6 through 10) 11. Particulate Matter Monitoring. The Permittee shall monitor particulate matter emissions from EU ID(s) 6 through 10 to determine the concentration of particulate matter (PM) in the exhaust in accordance with the following If the criteria of Condition 11.2a or 11.2b is exceeded, [18 AAC (j), and 18 AAC (j)(4),] [40 C.F.R. 71.6(a)(3)(i) & (c)(6),] a. perform an inspection of the bags and baghouse assembly to ascertain the integrity of the system; (i) (ii) (iii) take steps to clean the bags of excess trapped dust; if any bags are found with holes or tears or deterioration which renders them ineffectual, the bags shall be replaced within 24 hours; if after cleaning the bags of excess dust or replacing torn or deteriorated bags, 18 consecutive minutes of Method 9 observations result in an 18- minute average opacity greater than 20 percent, conduct a PM source test within six months according to the requirements set out in Section 8 to confirm whether or not the PM emission limits in Conditions 5, 15 and 60 are being maintained; Page 10 of 74

15 b. maintain the results of baghouse inspections, records of bags replaced, and repairs conducted at the source for inspection at the request of the Department Monitor according to Condition 11.1 if a. 18 consecutive minutes of Method 9 observations result in an 18-minute average opacity greater than 20 percent, or b. for an emission unit with an exhaust stack diameter that is less than 18 inches, 18 consecutive minutes of Method 9 observations result in an 18-minute average opacity that is greater than 15 percent and not more than 20 percent, unless the Department has waived this requirement in writing. 12. Particulate Matter Recordkeeping. The Permittee shall keep records of the results of any PM testing conducted under Condition 11.1a(iii). 13. Particulate Matter Reporting. The Permittee shall report as follows: [18 AAC (j), and 18 AAC (j)(4)] [40 C.F.R. 71.6(a)(3)(ii) & (c)(6)] [18 AAC (j) and 18 AAC (j)(4)] [40 C.F.R. 71.6(a)(3)(iii) & (c)(6)] 13.1 In each facility operating report required by Condition 103, include a. a summary of the results of any PM testing conducted under Condition 11.1a(iii) Report as excess emissions, in accordance with Condition 102, any time the results of a source test for PM exceeds the PM emission limit stated in Conditions 5, 15 and 60. Sulfur Compound Emission Standards Requirements 14. Sulfur Compound Emissions. The Permittee shall not cause or allow sulfur compound emissions, expressed as SO 2, from EU IDs 3 though 5 to exceed 500 ppm averaged over three hours. For Fuel Oil2 (EU IDs 3 though 5) [18 AAC (j) & 18 AAC (c), and 18 AAC (j)] [40 C.F.R. 71.6(a)(1)] 14.1 The Permittee shall do one of the following for each shipment of fuel: a. If the fuel grade requires a sulfur content less than 0.5 percent by weight, keep receipts that specify fuel grade and amount; or b. If the fuel grade does not require a sulfur content less than 0.5 percent by weight, keep receipts that specify fuel grade and amount; and 2 Oil means crude oil or petroleum or a liquid fuel derived from crude oil or petroleum, including distillate and residual oil, as defined in 40 C.F.R b, effective 7/1/07. Page 11 of 74

16 (i) (ii) test the fuel for sulfur content; or obtain test results showing the sulfur content of the fuel from the supplier or refinery; the test results must include a statement signed by the supplier or refinery of what fuel they represent Fuel testing under Condition 14.1 must follow an appropriate method listed in 18 AAC or another method approved in writing by the Department If a load of fuel contains greater than 0.75 percent sulfur by weight, the Permittee shall calculate SO 2 emissions in ppm using either Section 14 or Method 19 of 40 C.F.R. 60, Appendix A-7, adopted by reference in 18 AAC (a) The Permittee shall report as follows: a. If SO 2 emissions calculated under Condition 14.3 exceed 500 ppm, the Permittee shall report under Condition 102. When reporting under this condition, include the calculation under Section 14. b. The Permittee shall include in the report required by Condition 103 (i) (ii) a list of the fuel grades received at the stationary source during the reporting period; for any grade with a maximum fuel sulfur greater than 0.5 percent sulfur, the fuel sulfur of each shipment; and (iii) for fuel with a sulfur content greater than 0.75 percent, the calculated SO 2 emissions in ppm. [18 AAC (j); 18 AAC (j), and 18 AAC (c)] [40 C.F.R. 71.6(a)(3)] BACT, Owner Requested Limits, and Other Title I Permit Requirements 15. The Permittee shall limit short term emissions and calendar year emissions from EU IDs 1 through 8 and 10, as indicated in Table B. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Exhibit B] 15.1 As applicable, the Permittee shall calculate and record the hourly average, 3-hour average, 30-day rolling average, annual average, and the monthly and calendar year summation of emissions of NO X and SO 2 for EU IDs 1 through 5, PM for EU IDs 1 through 8 and 10, CO for EU IDs 2 and 4, and beryllium for EU ID 2. a. Use continuous emission monitors to determine emissions of NO X from EU IDs 1 and 2 and AP-42 NO X emission factors for EU IDs 3 through 5. b. Use continuous emissions monitors to determine emissions of SO 2 from EU IDs 1 and 2 and the sulfur content of the fuel and the amount of fuel used to calculate emissions of SO2 from EU IDs 3 through 5. Page 12 of 74

17 c. Use source test results to determine emissions of PM from EU IDs 1 and 2 and AP-42 PM emission factors for EU IDs 3 through 8 and 10. d. Use AP-42 emission factors, along with the hours of operation and/or amount of fuel used, to calculate the emissions of CO for EU IDs, and continuous emission monitors to determine emissions from EU ID 2. e. Use the results from the quarterly beryllium analysis to ensure the beryllium concentration limit is not exceeded for EU ID As applicable, the Permittee shall report the hourly average, 3-hour average, 30-day rolling average, annual average, and the monthly and calendar year summation of emissions from EU IDs 1 through 8 and 10, as indicated in Table B, for each month of the reporting period with each facility operating report required by Condition Notify the Department per Condition 102 should the short term emissions and/or calendar year emissions from EU IDs 1 through 8 and 10 exceed the limit for that contaminant as indicated in Table B. Page 13 of 74

18 Table B - BACT and Owner Requested Emission Limits Pollutant Emission Unit ID Emission Unit Description Short Term Emission Limits Calendar Year Emission Limits (tpy) PM 1 Unit # gr/dscf, hourly average (36.7 lb/hr at full load) 2 HCCP lb/mmbtu, hourly average (13.2 lb/hr at full load) 3 Aux #1 Heater 0.05 gr/dscf, hourly average (0.8 lb/hr at full load) 20% load factor, annual average 4 Aux #2 Heater 0.05 gr/dscf, hourly average (1.5 lb/hr at full load) 45% load factor, annual average 5 Diesel Generator # gr/dscf, hourly average (2.1 lb/hr at full load) 20% load factor, annual average 6 Primary Crusher 0.02 gr/dscf, hourly average (2.05 lb/ hr at 12,000 cfm) 7 Limestone Storage Silo 0.02 gr/dscf, hourly average (0.14 lb/hr at 800 cfm) Spent Limestone/ Flyash Storage Silo 0.02 gr/dscf, hourly average (0.86 lb/hr at 5000 cfm) Coal Handling System 0.02 gr/dscf, hourly average (3.43 lb/hr at 20,000 cfm) 5.01 Fugitive Sources 1 Total PM for all emission units Page 14 of 74

19 Pollutant Emission Unit ID Emission Unit Description Short Term Emission Limits Calendar Year Emission Limits (tpy) NO X 1 Unit # HCCP lb/mmbtu, 30-day rolling average Auxiliary #1 Heater 20 lb NOx/1000 gal distillate fuel, annual average 20% load factor, annual average 4 Auxiliary #2 Heater 20 lb NOx/1000 gal distillate fuel, annual average 45% load factor, annual average 5 Diesel Generator #1 Not to exceed 370 lb NOx/1000 gal, annual average; 20% load factor, annual average Total NO X for all emission units 1453 SO 2 1 Unit #1 258 lb/hr, 24-hour average, calendar day 367 lb/hr, 3-hour average 2 HCCP lb/mmbtu, annual average 0.10 lb/mmbtu (65.8 lb/hr), 3-hour average 3 Aux #1 Heater 0.3% S in oil, annual average 0.5% S in oil, 3-hour average 4 Aux #2 Heater 0.3% S in oil, annual average 0.5% S in oil, 3-hour average 5 Diesel Generator #1 0.3% S in oil, annual average 0.5% S in oil, 3-hour average Total SO 2 for all emission units 749 CO 2 HCCP 0.20 lb/mmbtu, hourly average (132 lb/hr) Aux #2 Heater 5 lb/1000 gal, hourly average (0.8 lb/hr) 2 Total CO for EU IDs 2 and Beryllium 2 HCCP Not to exceed 114 ppm in fuel, annual average [AQC Permit #9431-AA001, Conditions 45, 46, 47, and Exhibit B] Page 15 of 74

20 16. Permittee shall operate EU ID 3 at no more than 20% of annual load capacity and combust only distillate fuel. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 6] 16.1 For EU ID 3, monitor and record the monthly hours of operation, operational load, and type of fuel combusted Report in the operating report of Condition 103 the monthly hours of operation totals, the monthly operational load totals, the calendar year-to-date totals, and the type of fuel combusted Report in accordance with Condition 102 whenever the load (%) multiplied by the operating hours exceeds 20% of the annual load capacity (i.e., greater than 0.20 X 8760 hrs X 10.4 MMBtu/hr) per calendar year or if other than distillate fuel is combusted Permittee may monitor, record, and report gallons of fuel combusted instead of operation load if only distillate fuel with a heating value of approximately 134,716 Btu/gallon is combusted in EU ID 3. Report in accordance with Condition 102 whenever the gallons combusted in EU ID 3 exceed 135,253 gallons per calendar year. 17. Permittee shall operate EU ID 4 at no more than 45% of annual load capacity and combust only distillate fuel. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 7] 17.1 For EU ID 4, monitor and record the monthly hours of operation, operational load, and type of fuel combusted Report in the operating report required by Condition 103 the monthly hours of operation totals, the monthly operational load totals, the calendar year-to-date totals, and the type of fuel combusted Report in accordance with Condition 102 whenever the load (%) multiplied by the operating hours exceeds 45% of the annual load capacity (i.e., greater than 0.45 X 8760 hrs X 23.0 MMBtu/hr) per calendar year or if other than distillate fuel is combusted Permittee may monitor, record, and report gallons of fuel combusted instead of operation load if only distillate fuel with a heating value of approximately 134,716 Btu/gallon is combusted in EU ID 4. Report in accordance with Condition 102 whenever the gallons combusted in EU ID 4 exceed 672,978 gallons per calendar year. Page 16 of 74

21 18. Permittee shall operate EU ID 5 at no more than 20% of annual load capacity. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 5] 18.1 For EU ID 5, monitor and record the monthly hours of operation and operational load Report in the operating report required by Condition 103 the monthly hours of operation totals, the monthly operational load totals, and the calendar year-to-date totals Report in accordance with Condition 102 whenever the load (%) multiplied by the operating hours exceeds 20% of the annual load capacity (i.e., greater than 0.20 X 8760 hrs X MMBtu/hr) per calendar year Permittee may monitor, record, and report gallons of fuel combusted instead of operation load if only distillate fuel with a heating value of approximately 134,716 Btu/gallon is combusted in EU ID 5. Report in accordance with Condition 102 whenever the gallons combusted in EU ID 5 exceed 420,480 gallons per calendar year. 19. Permittee shall operate a certified continuous opacity monitor on EU ID 1 consistent with Performance Specification 1 as described in 40 C.F.R. Part 60, Appendix B. If a new opacity monitor is to be installed, the selection, siting, and installation shall be approved by the Department. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [Construction permit #9831-AC018, Condition 21.3, AQC Permit #9431-AA001, Condition 10] 19.1 Monitor, record, and report in accordance with Section Permittee shall install and operate a continuous emission monitoring system on the EU ID 1 boiler exhaust duct to measure and record the calendar year emissions of SO 2 and oxides of nitrogen discharged to the atmosphere. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [Construction permit #9831-AC018, Condition 25.1, and AQC Permit #9431-AA001, Conditions 51 and 52] 20.1 Monitor, record, and report in accordance with the applicable parts of Condition Consistent with prudent utility practices, Permittee shall schedule one of its two routine EU ID 1 maintenance shutdowns (typically 2 to 8 weeks in duration) and its major maintenance shut-downs during the June, July, or August time period. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 56] 21.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the requirements of Condition 21. Page 17 of 74

22 22. Permittee shall install, certify, and operate, a continuous emission monitoring system on the EU ID 2 exhaust duct to measure and record the opacity, sulfur dioxide, oxides of nitrogen, and oxygen or carbon dioxide of emissions discharged to the atmosphere. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Conditions 11, 13, 14, 15, and Exhibit D] 22.1 Monitor, record, and report in accordance with the applicable parts of Conditions 31, 54 and Permittee shall install and operate, an as fired fuel monitoring system upstream of the EU ID 2 coal pulverizers meeting the requirements of 40 C.F.R. 60, Appendix A, Method 19 to determine potential sulfur dioxide emissions of the EU ID 2 system. Permittee shall analyze the fuel sulfur content of composite samples monthly. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 12] 23.1 Monitor, record, and report in accordance with the applicable parts of Conditions 31, 54 and Permittee shall not request from the Department amendments to this permit, which would result in calendar year emission levels which would exceed 1,439 tpy for NO x or 721 tpy for SO 2 for the combined operation of EU ID(s) 1 and 2. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 48] 25. If the EU ID 2 demonstration technology successfully reduces emissions as expected, Permittee shall request from the Department immediately, upon the completion of the demonstration test phase, through an application for amendment to this permit, reductions in the SO 2 and /or NO X calendar year emissions limits to reflect achieved calendar year emission levels while allowing for reasonable operational variability. In addition, Permittee shall, in applications for permit renewals from the Department, continue to seek lower calendar year emission limits representative of achieved calendar year emission levels allowing for reasonable operational variability. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 49] 25.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the requirements of Condition 25. Page 18 of 74

23 26. If EU IDs 1 and/or 2 are operating and generating a NO x or other pollutant plume (exclusive of water vapor, steam, and ice crystal plumes) or a sulfate or other pollutant haze which impairs visibility and which is reasonably attributable to the operation of EU ID(s) 1 and/or 2, and is observed or otherwise detected within Denali National Park and Preserve (DNPP) boundaries by observers trained in pollutant plume and haze identification, Permittee shall, upon notification by National Park Service (NPS) or an order by the Department, immediately implement the procedures as follows: [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 50] 26.1 All notifications of plume or haze observation or detection reasonably attributable to the operation of EU IDs 1 and/or 2 shall be relayed to the Permittee by the Park Superintendent or his or her designated representative The Park Superintendent or his or her designated representative shall notify Permittee s Healy Plant Superintendent by telephone of plume or haze observation or detection, which is reasonably attributable to the operation of EU ID(s) 1 and/or 2 if the Park Superintendent determines that the report of such plume or haze observation or detection is credible Upon receipt of a notification of plume or haze observation or detection, Permittee will investigate the situation and proceed within 90 minutes of notification as follows: a. If the Permittee concurs with the NPS determination in Condition 26.2 above, Permittee will reduce the combined emissions from EU IDs 1 and/or 2 to the level of EU ID 1 emissions prior to construction of EU ID 2 (approximately 200 lb/hour NOx and 150 lb/hour SO2) for a minimum of twelve (12) hours. This period of time will be extended for additional twelve (12) hour periods by mutual agreement of the parties, as defined in this condition, if the plume and/or haze persist, or conditions conducive to plume and/or haze formation persist. At any time during this period of reduced emissions, Permittee may resume full operations upon a determination, by the mutual agreement of the parties, as defined in this condition, that the plume and/or haze is no longer detectable and conditions conducive to plume and/or haze formation no longer exist. The phrase by mutual agreement of the parties, as used in this condition, means that Permittee s Healy Plant Superintendent and the Park Superintendent, or their designated representatives, will discuss the issue requiring decision and undertake to reach agreement on the decision; if such decision cannot be agreed upon, Permittee may proceed to resume operations, and both parties will keep a record of the disagreement. b. If Permittee does not concur with the Park Superintendent s determination in Condition 26.2 above within 90 minutes or if the Park Superintendent does not concur with Permittee s decision to resume operations in Condition 26.3a above, the Park Superintendent or his or her designated representative may notify air quality control personnel in the Department. The Department may then order Permittee to reduce the combined emissions as set forth in Condition 26.3a above if, after an opportunity for consultation with Permittee Page 19 of 74

24 and the Park Superintendent, the Department concurs with the NPS determination based on an observation or detection made or confirmed by appropriately trained person or persons. Because this process depends on prompt decision-making and communication, telephone transactions are contemplated. c. For purposes of any order issued under Condition 26.3b above, Permittee hereby waives rights to advance notice and opportunity for hearing provided by AS (Compliance Orders) and stipulates to the imposition of any emergency order under AS In emergency conditions (defined as the loss of a significant portion of Permittee s generating resources and/or the Alaska Intertie), Permittee will undertake the reductions in Condition 26.3a when the emergency conditions end. 27. Permittee shall provide reasonable technical and administrative support for any related ongoing studies that the US Department of Energy and the US Department of the Interior agree to pursue. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 53] 27.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the requirements of Condition At the request of the NPS, Permittee shall provide NPS with fly ash and slag ash, as available, FOB Healy plant site, at no charge. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 54] 28.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the requirements of Condition The Permittee shall comply with its obligations as described by the provisions of Healy Clean Coal Project Memorandum of Agreement, Section III and Addendum No. 1. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Condition 57] 29.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the applicable requirements of Condition 29. Page 20 of 74

25 30. Each continuous emission monitoring system (CEMS) required under this permit must be installed, maintained, operated, and calibrated as specified in the applicable Performance Specification set out in Title 40 Code of Federal Regulations Part 60, Appendix B when the monitored emission unit is operating. A continuous emission monitoring system quality assurance plan must be developed and approved for each monitor required by this permit, conforming with Part 40 C.F.R. 60 Appendix F, and The Quality Assurance Handbook for Air Pollution Measurement Systems Volume Ill, (EPAJ600/ b). An alternate emission monitoring plan may be proposed if it can be shown to ensure continuous compliance. [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a)] [AQC Permit #9431-AA001, Exhibit D] 30.1 Compliance shall consist of an annual certification, in accordance with Condition 104, that the facility has met the requirements of Condition The Permittee shall monitor, record, and report according to Condition 103 the following information: 31.1 For EU ID 1: [18 AAC (j) and 18 AAC (j)] [40 C.F.R. 71.6(a), (c)(6)] [AQC Permit #9431-AA001, Exhibits C & D] a. Measure SO 2 emissions continuously, and record the 60-minute average and three hour average SO 2 emission concentration uncorrected and corrected to either 12.5% CO 2 or 7% O2 in accordance with 40 C.F.R. Part 60, Appendix A, Method 19. b. Calculate the 60-minute average SO 2 emission rates based on the methodology set out in 40 C.F.R. 60, Appendix A, Method 19, and the Permittee s CEMS operation and maintenance plan. c. Calculate and record the 3-hour and 24-hour SO 2 emissions rates on a calendar day basis. d. Record and report monthly emissions of SO 2 to the nearest 0.1 ton. e. Record the date, time, duration, and average SO 2 emission rate for any period exceeding 258 lb/hr for a 24-hour or greater averaging period, or 367 lb/hr for a 3-hour or greater averaging period. For the 3-hour averaging period, also record the SO 2 concentration. f. Attach to the facility operating report in Condition 103, a list of excess SO 2 emissions with the date, time, duration, and average SO 2 emission rate for any period exceeding an average 258 lb/hr for 24-hours or more, and for any period exceeding an average 367 lb/hr for 3-hours or more. g. Measure and record the 60-minute average emission rate of NO X. Report monthly emissions to the nearest 0.1 ton. Page 21 of 74