OKLAHOMA DEPARTMENT OF ENVIRONMENTAL · PDF fileOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... (Unit 1 Coal Storage Silos) ... Coal, Limestone and Ash Handling

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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM June 28, 2011

TO: Phillip Fielder, P.E., Permits & Engineering Group Manager

THROUGH: Kendal Stegmann, Sr. Environmental Manager, Compliance & Enforcement

THROUGH Phil Martin, P.E., Engineering Section

THROUGH: Peer Review

FROM: Iftekhar Hossain, P.E., Engineering Section

SUBJECT: Evaluation of Permit Application No. 2003-062-TVR

AES Shady Point, LLC

Coal-fired Cogeneration Plant

Section 2, Township 8N, Range 25E, LeFlore County, Oklahoma.

Latitude: 31.195 N and Longitude: 94.647 W

Located 10 miles northeast of Poteau, Oklahoma

I. INTRODUCTION

AES Shady Point (AES) has requested renewal of Title V Operating Permit for their coal-fired

cogeneration plant (SIC 4911) in LeFlore County in Oklahoma. AES was issued the initial Title

V Operating Permit No. 96-290-TV (PSD) on August 13, 1998. AES submitted an application to

renew the existing permit on February 11, 2003. The facility is a cogeneration plant located in

an attainment area. The facility originally applied for construction under Permit No. 86-045-C

(PSD) since facility emissions exceeded the Prevention of Significant Deterioration (PSD)

thresholds. The facility then applied for a modification after a request to increase emissions.

The facility was constructed in 1987 and operated under Permit No. 86-045-O (PSD) until

issuance of the Title V Permit No. 96-290-TV (PSD). There have not been any modifications or

additions of new emission sources since issuance of the initial Title V permit other than a minor

modification for adding a coal hopper and associated conveyor system for operational flexibility.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Part 70

permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups

(EUGs) as outlined in the “Equipment” section.

PERMIT MEMORANDUM 2003-062-TVR DRAFT Page 2

II. FACILITY DESCRIPTION

The facility combusts coal or coal blended with other materials such as biomass, petroleum coke

etc. to produce steam in four circulating fluid bed (CFB) boilers. The steam is used primarily for

the generation of 360 megawatt (MW) of electricity, and secondarily is used for the production

of up to 200 tons per day (TPD) of carbon dioxide (CO2) from an amine adsorption/steam

stripping operation. The four steam boilers, each rated at approximately 600,000 lb/hr of steam at

1,890 psig and 1,000oF, supply steam to serving two extracting/condensing steam turbines.

The CFB boilers have been designed to operate on coal and coal-blended products. Natural gas

is used for start-ups to obtain the necessary temperature for coal combustion. Sulfur dioxide

(SO2) control is accomplished by injecting a calculated quantity of limestone into the fireboxes.

Following a cyclone and baghouse for particulate matter (PM) control, flue gas proceeds through

a separate duct from each boiler to a common stack. When the CO2 facility is in operation, a

portion of the flue gas from the boilers is compressed and scrubbed in a multi-stage scrubber

using a caustic solution to remove SO2 from the flue gas stream. Purified flue gas is then

scrubbed with monoethanolamine (MEA) compound for the adsorption of CO2. Stripped flue

gases are then vented to the atmosphere.

Coal arrives by both railcar and truck and limestone arrives primarily by truck with both being

stored in a single dome 300 feet in diameter and 130 feet tall, as well as outside coal storage.

Both materials are conveyed to the processing building. Crushing and screening are conducted

in totally-enclosed systems that are exhausted to baghouses. The materials are then conveyed to

the main building where the coal storage silos, limestone silos, and boilers are located. Ash from

the boilers and baghouses is conveyed to four storage silos each equipped with a baghouse.

Emission Units (EUs) have been arranged into Emission Unit Groups (EUGs) with only one

operating scenario.

III. EQUIPMENT

EUG 1: Facility Wide Requirements EU Point

None None

EUG 2: Combustion Sources

EU Point Make/Model MW Lb/hr Steam Const Date

B-02-01A SV-02-001 CBF Boiler 1A 90 600,000 1987

B-02-01B SV-02-001 CBF Boiler 1B 90 600,000 1987

B-02-02A SV-02-001 CBF Boiler 2A 90 600,000 1987

B-02-02B SV-02-001 CBF Boiler 2B 90 600,000 1987


EUG 3: CO2 Plant

EU Point Name/Equipment Const Date

B-03-01 SV--03-001 CO2 Absorber Vent 1987

B-03-02 SV--03-002 CO2 Dryer Vent 1987

B-03-03 SV--03-003 CO2 Condenser Vent 1987

EUG 4: Ash Transfer & Loading


TO-04-001 SV-04-001 Bed Ash Surge Bin Baghouse Vent 1A 1987

TO-04-002 SV-04-002 Bed Ash Surge Bin Baghouse Vent 1B 1987

TO-04-003 SV-04-003 Bed Ash Surge Bin Baghouse Vent 2A 1987

TO-04-004 SV-04-004 Bed Ash Surge Bin Baghouse Vent 2B 1987

TO-04-005 SV-04-005 Bin Collector to Vacuum Producer Unit 1A 1987

TO-04-006 SV-04-006 Bin Collector to Vacuum Producer Unit 1B 1987

TO-04-007 SV-04-007 Bin Collector to Vacuum Producer Unit 2A 1987

TO-04-008 SV-04-008 Bin Collector to Vacuum Producer Unit 2B 1987

TO-04-009 SV-04-009 Ash Silo Unit 1A Baghouse Vent 1987

TO-04-010 SV-04-010 Ash Silo Unit 1B Baghouse Vent 1987

TO-04-011 SV-04-011 Ash Silo Unit 2A Baghouse Vent 1987

TO-04-012 SV-04-012 Ash Silo Unit 2B Baghouse Vent 1987

TO-05-017 SV-04-013 Ash Re-injection System 1987

TO-04-018 FE-04-001 Truck Loading from Bed Ash Surge Bin 1A 1987

TO-04-019 FE-04-002 Truck Loading from Bed Ash Surge Bin 1B 1987

TO-04-020 FE-04-003 Truck Loading from Bed Ash Surge Bin 2A 1987

TO-04-021 FE-04-004 Truck Loading from Bed Ash Surge Bin 2B 1987

EUG 5A: Limestone Unloading EU Point Name/Equipment Const Date

LU-5A-001 FE-05-001 Truck Unloading Building 1987

LU-5A-002 SV-10002X CD10002X (Limestone Truck Unloading System) 1987

LU-5A-004 FE-05-002 Railcar Unloading Building 1987

LU-5A-005 SV-10001X CD10001X (Limestone Railcar Unloading System) 1987

LU-5A-006 FE-05-003 Emergency Truck Unloading to Outside Pile 1987

LU-5A-007 FE-05-004 Outside Pile to Dome 1987

EUG 5B: Limestone Transfer & Conveying


LT-5B-002 SV-10003X CD10003X (Sample Tower Limestone Transfer

System)

1987

LT-5B-023 SV-10004X CD10004X Baghouse Vent (Live Storage Limestone

Transfer System)

1987

LT-5B-024 SV-11002X CD11002X Baghouse Vent (Limestone Crusher

System)

1987

LT-5B-025 SV-11003X CD11003X Baghouse Vent (Limestone Reclaim 1987



System)

LT-5B-015 SV-04-003 Limestone Transfer to 1AA Limestone/Sand Silo (vent

into the boiler house)

1987

LT-5B-016 SV-04-004 Limestone Transfer to 1AB Limestone Silo (vent into

the boiler house)

1987

LT-5B-017 SV-04-005 Limestone Transfer to 1BA Limestone Silo (vent into

the boiler house)

1987

LT-5B-018 SV-04-006 Limestone Transfer to 1BB Limestone Silo (vent into

the boiler house)

1987

LT-5B-019 SV-04-007 Limestone Transfer to 2AA Limestone/Sand Silo (vent

into the boiler house)

1987

LT-5B-020 SV-04-008 Limestone Transfer to 2AB Limestone Silo (vent into

the boiler house)

1987

LT-5B-021 SV-04-009 Limestone Transfer to 2BA Limestone Silo (vent into

the boiler house)

1987

LT-5B-022 SV-04-010 Limestone Transfer to 2BB Limestone Silo (vent into

the boiler house)

1987

EUG 6A: Coal Unloading


CH-6A-001 FE-06-001 Truck Unloading Building (Coal Unloading) 1987

CH-6A-002 SV-10002X CD10002X Baghouse Vent (Coal Truck Unloading

System).

1987

CH-6A -004 FE-06-002 Rail Car Unloading Building (Coal Unloading) 1987

CH-6A -005 SV-10001X CD10001X Baghouse Vent (Coal Railcar Unloading

System)

1987

EUG 6B: Coal Handling


CH-6B-002 SV-10003X CD10003X (Sample Tower Coal Transfer System) 1987

CH-6B -004 SV-10004X CD10004X Baghouse Vent (Live Storage Coal Transfer

System)

1987

CH-6B-021 SV-10007X CD10007X Baghouse Vent (Coal Crusher System) 1987

CH-6B-022 SV-10008X CD10008X Baghouse Vent (Unit 1 Coal Storage Silos) 1987

CH-6B-023 SV-10010X CD10008X Baghouse Vent (Unit 2 Coal Storage Silos) 1987

CH-6B -005 FE-06-003 Dome Storage Activities (Coal Inside Building Drop Fugitive) 1987

CH-6B-024 FE-06-004 Telescopic Chute to Outside Pile (Fugitive Outside) 1987

CH-6B-025 FE-06-005 Outside Pile to Reclaim Hopper (Fugitive Outside) 1987


EUG 7: Truck & Maintenance Vehicle Traffic

EU Name/Equipment Const Date

PR-07-001 Paved Roads - Coal Trucks 1987

PR-07-002 Paved Roads - Limestone Trucks 1987

PR-07-003 Paved Roads - Ash Trucks 1987

UR-07-004 Unpaved Roads – Coal Maintenance Between Delivery Pile and Dead

Storage Pile

1987

UR-07-005 Paved Roads – Coal Maintenance Between Delivery Pile and

Emergency Hopper

1987

UR-07-006 Unpaved Roads – Coal Maintenance Between Dead Storage Pile and

Emergency Hopper

1987

UR-07-007 Unpaved Roads – Coal Dead Storage Pile Maintenance 1987

UR-07-008 Unpaved Roads – Truck Unloading on Dead Storage Pile 1987

UR-07-009 Unpaved Roads – Reclaim Emergency Limestone Storage to

Emergency Hopper

1987

UR-07-010 Unpaved Roads - Grader 1987

EUG 8: Material Storage

EU Name/Equipment Const Date

WE-08-001 Coal Dead Storage Pile 1987

WE-08-002 Coal Delivery Pile 1987

WE-08-003 Bed Ash Pile 1987

WE-08-004 Fly Ash Pile (Cover with tarps/temporary outage pile) 1987

EUG 9: Storage Tank


TK-01-001 TK-01-001 Monoethanolamine (MEA) 1987

TABLE 1: BOILER MAIN STACK PARAMETERS Stack Height

(feet)

Diameter

(feet)

Temperature

(degrees F)

Flowrate

(ACFM)

SV-02-001 350 17 325 285,000

IV. PERMITS/PSD REVIEW

The facility was constructed in 1987 and operated under Permit No. 86-045-O (PSD) until

issuance of the Title V Permit No. 96-290-TV (PSD). The PSD review was done in details in

Permit Number 86-045-O (PSD). Since the renewal of the Title V permit does not trigger a new

PSD review. The original PSD review conducted in support of Permit No.86-045-C(PSD) issued

on January 8, 1987 is incorporated by reference and not repeated here.


Best Available Control Technology (BACT)

BACT for the facility was determined prior to issuance of the EPA "top-down" BACT

determination policy. The discussion below is the summary of that BACT determination.

BACT Controls as Installed

Circulating Fluid Bed Boilers (Steam Generating Units)

o PM – Cyclones and Fabric Filters

o SO2 – Limestone Injection

o NOx – Temperature Control

o VOC and CO – Good Combustion Practices

Coal, Limestone and Ash Handling (PM only sources)

o Minimize transfer points

o Storage in Silos and dead storage pile

o Use of baghouses

o Wet dust suppression

o Enclosure of material handling systems as practicable

Additional Particulate Matter Sources Control

Additional PM emissions resulted from coal, limestone, and ash storage/handling activities. PM

emissions resulted from the following operations:

unloading of coal and limestone

conveying and transfer points for coal, limestone, and ash

storage piles and silos for coal, and storage silos for limestone and ash

crushers for coal and limestone

unloading of coal, limestone, and ash silos

filling and reclaiming the dead coal storage pile

BACT for these PM emissions from materials handling and storage activities at the facility

consisted of a combination of one or more of the following engineering design and operating

practices to minimize the emissions of fugitive dust in the material storage and handling systems:

minimize the number of material transfer points

storage in silos and dead storage pile

use of enclosed transfer points

use of dry dust collection systems (baghouses)

use of wet dust suppression systems

enclosure of material handling system components as practicable

A more detailed account of these applications to control additional particulate matter emissions is

listed in the specific conditions of the permit.


V. EMISSIONS LIMITATIONS

The following emissions estimates reflect continuous operations (8760 hr/yr) with the CO2

absorber operating as required in the specific conditions of Permit No. 96-290-TV (PSD). Note

that individual lb/hr emission limitations for each boiler were removed in the Title V permit.

During the evaluation of current permit application it was determined that the emission limitations

for each boiler shall be on individual lb/hr basis as per the original PSD review done on 86-045-O

(PSD). Therefore, individual lb/hr emission limitations for each boiler have been reestablished in

this permit.

Emissions Rate

(Per Boiler Unit)

Emissions

(Per Boiler Unit)

Total Emissions

(All Four Units)

Pollutant lb/MMBTU % Reduction lb/hr(i)

TPY(j)

lb/hr(i)

TPY(j)

SO2(a)

1.20/0.60(h)

90/70(h)

590.5 2,586 2,363.0

10,346

NOx(b)

0.50 65 382.5 1,625 1,530

6,701

PM(c)

0.03 99

PM(d)

0.2 22.6 99.0 90.4 396

CO(e)

152.5 668.0 610.0 2,672

VOC(f)

0.064 4.9 21.5 19.6 85.8

Fluorides(g)

3.2 14.0 12.8 56.1

Be(g)

0.0053 0.023 0.0212 0.093

Pb(g)

0.49 2.15 1.96 8.58

Hg(g)

0.11 0.482 0.44 1.93

(a) basis: 0.75 lb/MMBTU heat input

(b) basis: 0.20 lb/MMBTU heat input

(c) basis: 0.03 lb/MMBTU heat input front half only limit (per NSPS, Subpart Da)

(d) basis: 0.2 lb/MMBTU heat input front and back half limit (per OAC: 252:100-19)

(e) basis: 0.20 lb/MMBTU heat input

(f) basis: 6 ppm, wet basis

(g) quantity of trace elements in coal based on “Trace Elements Coal,” CRC Press Inc.,

1983, Vol. 1. Removal efficiencies based on CFR manufacturer’s data

(h) NSPS Subpart Da: for 0.60 to 1.2 lb/MMBTU, 90% minimum reduction is applicable

for 30-day rolling averages. At less than 0.60 lb/MMBTU, 70% minimum reduction

is applicable for 30-day rolling averages

(i) lb/hr limits are based on 30-day rolling average.

(j) TPY limits are based on a 12 month rolling limit

VI. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified on Part 1b of the forms in the application and

duplicated below were confirmed by the initial operating permit inspection. Records are

available which confirm the insignificance of the activities. Appropriate recordkeeping on

activities indicated below with “*”, is required.

* Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel

which are either used exclusively for emergency power or for peaking power service not


exceeding 500 hours/year. One emergency diesel power generator, an emergency boiler

feedwater pump, and a diesel firewater pump are located on site with annual operating hours

recorded to demonstrate hours of operation below 500 hours for each engine annually.

* Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period.

One 3,000 gallon gasoline tank for facility vehicles is located on site and records are kept which

demonstrate the facility uses much less than the 2,175 gallons/day. A one-time determination,

based on historical usage rates and equipment specifications, will be maintained on file

demonstrating that the facility could not reasonably exceed the insignificant activities threshold.

This information will be recalculated upon a significant increase in vehicular operation.

* Emissions from storage tanks constructed with a capacity less than 39,894 gallons which

store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The 4000-

gallon diesel fuel tank will be required to maintain records of tank capacity and contents. A one-

time determination, based on historical usage rates, will be maintained on file demonstrating that

the facility is in compliance with the insignificant activity threshold. This information will be

recalculated upon a significant increase in diesel fuel usage, including any potential installation

of additional tanks which may be used in the future.

* Sanitary sewage collection and treatment facilities other than incinerators and Publicly

Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also

included (i.e., lift stations). The facility operates a sanitary sewage collection and treatment

facility.

* Activities that have the potential to emit no more than 5 TPY (actual) of any criteria

pollutant. This includes disposal of wastes generated from boiler cleaning, emergency engines,

storage pile activities and fugitive emissions from the MEA stream which generate emissions

below 5 TPY. Occasionally, coal, limestone and/or gravel containing oils from small spills are

mixed with the boiler coal feed. Emissions from oils are insignificant due to emissions less than

5 TPY. Occasionally test burns may be conducted to determine viability of alternative fuels such

as, but not limited to, wood, chicken litter and tire derived fuel.

VII. TRIVIAL ACTIVITIES

* Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons

per year of electrodes. However, welding is conducted as a part of routine maintenance and is

considered a trivial activity and recordkeeping will not be required in the Specific Conditions.

* Torch cutting and welding of under 200,000 tons of steel fabricated per year.

However, torch cutting is conducted as a part of routine maintenance and is considered a trivial

activity and recordkeeping will not be required in the Specific Conditions.

* Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets,

including hazardous waste satellite (accumulation) areas. The facility maintains exhaust systems

for several of the listed sources.


VIII. OKLAHOMA AIR QUALITY RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air

Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Operating Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of

regulated pollutants. Emission inventories have been submitted and fees paid for the past years.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

This facility meets the definition of a major source since it has the potential to emit regulated

pollutants in excess of 100 TPY. As such, a Title V (Part 70) operating permit is required. Any

planned changes in the operation of the facility which result in emissions not authorized in the

permit and which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require

prior notification to Air Quality Division (AQD) and may require a permit modification.

Insignificant activities mean individual emission units that either are on the list in Appendix I or

whose actual calendar year emissions do not exceed the following limits

5.0 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any

threshold less than 10 TPY for a HAP that the EPA may establish by rule

OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for affirmative defense, as

described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional

reporting may be required in the case of ongoing emission events and in the case of excess

emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Prohibition of Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.


OAC 252:100-19 (Control of Emission of Particulate Matter) [Applicable]

OAC 252:100-19-4 of this subpart limits particulate emissions from indirectly-fired units based

on their heat input. The boilers are each rated at 829 MMBTUH which provides a PM allowable

rate of 0.2 lb/MMBTU for combined front and back half particulate matter. Based on stack test

data each boiler has demonstrated compliance with this Subpart.

.

OAC 252:100-19-12 of this subchapter also limits emissions of PM from industrial processes

based on their process weight rates. All industrial processes (i.e. crushing, conveying, screening)

are controlled by dust collection equipment. The specific conditions will include routine

monitoring and maintenance of the dust collection equipment to ensure compliance. The facility

is in compliance for each emission point subject to this Subpart.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences that

consist of not more than one six-minute period in any consecutive 60 minutes, not exceed three

such periods in any consecutive 24 hours. In no case shall the average of any six-minute period

exceed 60% opacity. The facility maintains an opacity monitor to demonstrate continuing

compliance of emissions from the boiler stack. Coal and limestone storing and processing

maintains compliance by annual certification for points subject to NSPS standards and by facility

work practices for all other points. Where NSPS is more stringent than these regulations then

NSPS takes the precedence.

OAC 252:100-29 (Control of Fugitive Dust) [Applicable]

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originate in such a manner as to damage or to interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. The facility maintains compliance by use of water sprays

and enclosures. Individual fugitive emission sources remaining on the facility shall be evaluated

at the property line for compliance with this subchapter.

OAC 252:100-31 (Control of Emission of Sulfur Compounds) [Applicable]

This subchapter limits SO2 emissions from new solid fuel burning equipment to 1.2 lb/MMBTU

and requires CEMS for SO2 emissions. NSPS Subpart Da, which affects the boilers, is more

stringent than these regulations and therefore takes precedence.

OAC 252:100-33 (Control of Emission of Nitrogen Oxides) [Applicable]

This subchapter limits NOx emissions from new solid fuel burning equipment with a rated heat

input greater than 50 MMBTUH to 0.7 lb/MMBTU. NSPS Subpart Da is more stringent than this

regulation and therefore takes precedence.

OAC 252:100-37 (Control of Emission of Volatile Organic Materials) [Applicable]

Part 3 requires storage tanks with a capacity of 400 gallons or more to be equipped with a

permanent submerged fill pipe or with an organic vapor recovery system. The MEA tank and

the diesel tank are exempt since they both have true vapor pressures that are below the


exemption level of 1.5 psia. The gasoline tank is equipped with a permanent submerged fill

pipe.

Part 5 limits the organic solvent content of coating or other operations. This facility does not

normally conduct coating or painting operations except for routine maintenance of the facility

and equipment which is exempt.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

Areas of Concern (AOC). Any work practice, material substitution, or control equipment

required by the Department prior to June 11, 2004, to control a TAC, shall be retained unless a

modification is approved by the Director. Since no AOC has been designated anywhere in the

state, there are no specific requirements for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.

To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data required to demonstrate compliance with any federal or state emission

limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained,

and submitted as required by this subchapter, an applicable rule, or permit requirement. Data

from any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.

The following Oklahoma Air Quality Rules are not applicable to this facility:

OAC 252:100-7 Minor Facilities not in source category

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-21 Wood-waste Burning not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-35 Control of Carbon Monoxide not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Solid Waste Landfills not in source category


IX. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable]

The facility was found to be subject to PSD as a result of being a major new stationary source of

air pollution during the evaluation of Permit Application No. 86-045-O (PSD). Full PSD review

was then required for the pollutants SO2, NOx, PM, CO, VOC, fluorides, Be, Pb, and Hg. Full

PSD review of the above pollutants can be found in the Permit No. 86-045-O (PSD).

NSPS, 40 CFR Part 60 [Applicable]

The facility is subject to Subparts A, Da, Y, and OOO.

Subpart Da applies to electric utility steam generating plants with a design capacity in excess of 73

megawatts (MW) (250 MMBTU/hr) heat input of fossil fuel and which commenced construction

or modification after September 18, 1978. Each of the four boiler units at the AES Shady Point

power plant has a design capacity of 90 MW and commenced construction in 1988. Subpart Da

specifies standards for emissions of PM, SO2, and NOx, as well as installation of continuous

monitoring equipment to monitor those emissions. NOx emissions are subject to a limitation of 0.5

lb/MMBTU of coal burned. SO2 must meet a dual standard of emissions rates and emissions

reductions: 90% or greater reduction of potential emissions for emissions between 1.2 lb/MMBTU

and 0.6 lb/MMBTU, or 70% reduction below 0.6 lb/MMBTU. 40 CFR 60.47a requires the owner

or operator to install, calibrate, and maintain CEMS for emissions of NOx, SO2, and CO2 or O2

(diluent gases). The CEMS assure compliance with NOx and SO2 standards promulgated in

Subpart Da. In addition, Subpart Da was amended on May 18, 2005 to add standards for Hg

emissions for coal fired units for which construction, modification, or reconstruction commenced

after January 30, 2004. The four coal-fired boiler units will not be subject to this rulemaking

based upon their construction date. Subpart Da was amended again on June 13, 2007 to modify

certain record-keeping and reporting requirements, but the modifications do not affect the AES

Shady Point Facility.

Subpart Kb applies to storage tanks with a capacity greater than or equal to 75 cubic meters that

store volatile organic liquids (VOL) for which construction, reconstruction, or modification

commenced after July 23, 1984. The MEA tank stores VOL but only has a capacity of 16,000

gallons. Therefore, Subpart Kb is not applicable.

Subpart Y affects the following facilities in coal processing plants which have the capacity to

process more than 200 tons per day of coal: thermal dryers, pneumatic coal cleaning equipment

(air tables), coal processing and conveying equipment (including breakers and crushers), coal

storage systems, and coal transfer and loading systems. Any such facility which commenced

construction or modification after October 24, 1974, is subject to the requirements of Subpart Y.

Subpart Y specifies an opacity limitation of 20% for affected facilities.

Subpart OOO applies to the following facilities in non-metallic minerals processing plants: each

crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation,

storage bin, and enclosed truck or railcar loading station. Affected facilities that commenced

construction, reconstruction, or modification after August 31, 1983 are subject to Subpart OOO.

No owner or operator may discharge into the atmosphere gases which contain in excess of 0.05


g/dscm (0.022 gr/dscf), or (2) exhibit greater than 7% opacity unless stack emissions are

discharged through a wet scrubber. Fugitive emissions from crushers without capture devices are

subject to a 15% opacity limit and conveyors and other affected fugitive sources are subject to a

10% opacity limitation.

Subpart HHHH (Coal-Fired Electric Steam Generating Units). Subpart HHHH established a

“mercury budget” for states and coal-fired electric generating units; however, this rule has since

been vacated.

Subparts Cb & E cover Solid Waste Incineration which are not applicable.

NESHAP, 40 CFR Part 61 [Not Applicable]

The facility emits trace amounts of some of the regulated pollutants including but not limited to:

arsenic, asbestos, beryllium, benzene, and mercury. However, none of the processes located at

the facility are affected processes.

NESHAP, 40 CFR Part 63 [Subpart ZZZZ is Applicable]

Subpart Q applies to industrial cooling towers which use chromium-based water treatment

chemicals and are located at major sources of HAP. AES does not use chromium-based water

treatment chemicals in their cooling towers. Therefore, Subpart Q is not applicable.

Subpart ZZZZ Reciprocating Internal Combustion Engines (RICE). This subpart was signed on

February 26, 2004, and affects RICE with a site rating greater than 500 brake horsepower that

are located at a major source of HAPs: existing, new, and reconstructed spark ignition 4 stroke

rich burn (4SRB) RICE, any new or reconstructed spark ignition 2 stroke lean burn (2SLB) or 4

stroke lean burn (4SLB) RICE, or any new or reconstructed compression ignition (CI) RICE.

The total horsepower rating for all three engines located at the facility (1,180-hp emergency

diesel power generator, 890-hp emergency boiler feedwater pump and 420-hp diesel firewater

pump) is 2,490-hp. However, stationary RICE >500-hp which operate exclusively as emergency

power/limited use units are not subject to any requirements of this subpart, including initial

notification requirements pursuant to 40 CFR 63.6590(b)(3). The 420-hp emergency diesel

firewater pump is subject to this subpart.

Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial,

Commercial and Institutional Boilers and Process Heaters at major sources of HAPs. EPA has

published various actions regarding implementation of this rule as detailed following:

- September 13, 2004 EPA promulgated standards for major sources

- June 19, 2007 US Court of Appeals for the district of Columbia vacated and remanded

the standards

- March 21, 2011 EPA promulgated new standards

- May 18, 2011 EPA published notice of delay of the effective dates until judicial review

or EPA reconsideration is completed, whichever is earlier

Section 112(j) of the Clean Air Act addresses situations where EPA has failed to promulgate a

standard as required under 112(e) (1) and (3). 112(j) requires case-by-case MACT determination


applications to be submitted to the permitting authority within specified time frames. Since

112(j) appears to only address situations where EPA has failed to promulgate standards and not

situations in which complete rules are subsequently vacated, confusion existed as to the

requirements for these sources. On March 30, 2010, EPA proposed a rule to amend 112(j) to

clarify what applies under 112(j). In the proposed rule, EPA clarifies that the intent was that

vacated sources should be treated similar to sources where EPA has failed to promulgate a

standard. The rule, as proposed, will require case-by-case MACT applications to be submitted to

the permitting authority within 90 days after promulgation of these amendments or by the date

which the source’s permitting authority requests such application. Final action on the amendment

is scheduled for the fall of 2011. Compliance with this subpart will be determined based on the

requirements of the amended 112(j).

CAM, 40 CFR Part 64 [Applicable]

Compliance Assurance Monitoring (CAM) as published in the Federal Register on October 22,

1997, CAM applies to any pollutant specific emission unit at a major source that is required to

obtain a Title V permit, if it meets all of the following criteria:

It is subject to an emission limit or standard for an applicable regulated air pollutant

It uses a control device to achieve compliance with the applicable emission limit or standard

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY

Combustion Sources

Control devices are used to achieve compliance with the applicable emission limits for SO2 and

PM. However, the boilers are subject to NSPS Subpart Da and, therefore, are required to install

and maintain CEMS systems for demonstrating compliance with the SO2 standards. For PM the

following opacity correlation is developed.

The applicant cited the reference, Continuous Emission Monitoring (James A. Jahnke, Second

Edition), and testing results: PM of 0.015 lb/MMBTU and opacity of 6.53%. According to

Bouguer’s Law, absorbance is exponentially related to concentration of particles:

Tr = e -naQl

Where:

Tr = transmittance

n = number of particles

a = area of the particles

Q = light extinction coefficient

l = path length

It is assumed that the particle size will be relatively constant, PM10. Smaller particles are the

best able to pass through baghouse, and would be the most prevalent during any malfunction. It

will also be assumed that the stack flows will be relatively constant on an actual cubic feet

(ACF) per MMBTU basis since the plant closely monitors excess combustion air supply and

discharge temperature. Light extinction coefficient should also be reasonably constant, and path


length (the stack diameter) will be constant. The terms “a”, “Q”, and “l” may be treated as

constants, collectively listed as “C” following.

If the emissions on a lb/MMBTU basis are linear with concentration of particles, then several of

the above variables do not have to be known. It can be said that the concentration when PM

emissions = 0.03 lb/MMBTU is 18.75 times as high as when PM emissions equal 0.0016

lb/MMBTU. This will yield an equation to be solved for the opacity when PM emissions are

0.03 lb/MMBTU.

0.9878 = e –C(0.0016)

Taking the natural logarithm of each side yields:

-0.0123 = -C(0.0016)

C = 7.672

The equation can now be solved for the transmittance when PM emissions are 0.03 lb/MMBTU:

Tr = e –(7.672)(0.03)

= 0.794

Opacity = 1 – Tr = 100% - 79.4% = 20.6%

Therefore, any opacity recorded which is less than 20.6% should indicate that PM emissions are

less than 0.03 lb/MMBTU. The “indicator point” for CAM may be set at the limit of 20%

opacity. The CAM requirements for the boilers are detailed in the Specific Conditions.

CO2 Plant Vent

The CO2 vent has potential emissions above the 100 TPY level requiring monitoring, however,

all emissions, except for MEA, are currently monitored at the boiler stack prior to being sent to

the CO2 plant which meets the exemption in 40 CFR Part 64.2(b)(vi), described above for the

boilers. MEA is emitted at minor levels not requiring monitoring.

Coal, Limestone, and Ash Handling, Crushing and Transferring Equipment

This equipment is exempt from the monitoring requirements based on either being uncontrolled

or controlled with potential emissions below 100 TPY.

Accidental Release Prevention, 40 CFR Part 68 [Not Applicable]

The facility conducted a review on September 10, 2004 of the 112(r) program requirements to

confirm the status of the facility has not changed. The facility burns commercial natural gas fuel

[at start-up] in the boilers along with the coal. Natural gas is a listed substance in CAAA 90

Section 112(r). However, this substance is not stored on site. The small quantity which is in the

pipelines on the facility is much less than the 10,000 pound threshold. Ammonia is used at the

facility as a refrigerant to condense CO2. It is not used or stored in amounts above the threshold

quantities. Hydrogen is also used at the facility as a coolant for the generators, but is not used or

stored in amounts above the threshold quantities. Hydrochloric Acid is used in the Water


Treatment area in concentrations below the 37% threshold for reportable quantities of 15,000

pounds or more. As described above, there are no regulated substances under Section 112(r)

which are stored or otherwise used onsite above the threshold reportable quantities. Therefore,

the facility is excluded from all requirements of Part 68, including the Risk Management Plan.

Acid Rain, 40 CFR Part 72 [Not Applicable]

Not applicable per 40 CFR 72.2 and 72.6(b) based on being a “qualifying cogeneration facility”

within the meaning of section 3(18)(B) of the Federal Power Act.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030.

This facility does not utilize any Class I & II substances.


IX. COMPLIANCE

Performance Testing

Performance testing was conducted on the source on February 6-19, 1991 to show compliance with

the permit limitations of Permit 86-045-O (PSD). The following table shows the results of the

testing:

Comparison of Emissions of Each Boiler Unit with Permit Limitations

Pollutant

Permit

lb/hr Per Unit

Unit 1A

Emissions

lb/hr

Unit 1B

Emissions

lb/hr

Unit 2A

Emissions

lb/hr

Unit 2B

Emissions

lb/hr

SO2 590.5 290.8 121.4 125.5 192.9

TSP

22.6 18.33 19.3 18.2 17.4

NOx 382.5 66.8 241.6 73.9 121.5

CO 152.5 118.2 95.9 108.3 80.2

VOC 4.9 0.26 0.23 1.03 0.18

Fluorides 3.2 0.003* 0.002 0.006 0.006

Be 0.0053 1.53E-4 1.36E-4 1.39E-4 1.41E-4

Pb 0.49 0.004 0.004 0.005 Not detectable

Hg 0.11 0.0033 0.0064 0.0017 0.0019

test results based on two samples since one sample jar broken during shipment. Use of two

samples is allowed in such cases by 40 CFR 60.8.

Performance testing of the CO2 absorber vent stack consisted on testing for ethanolamine

emissions. Although the permit specified emissions limitations for the vent for all pollutants, the

concentration of all other pollutants at the absorber vent can be no greater than the concentration at

the boiler baghouse outlets whence the processed gas comes. Emissions were determined to be

0.92 lb/hr compared to the permit limitation of 2.0 lb/hr. The absorber unit vent was therefore in

compliance with emissions limitations.

In addition to emissions limitations on a basis of lb/hr, some pollutants had additional standards.

NOx, SO2, and PM also had emissions limitations of the basis of lb/MMBTU. Compliance with

these standards constituted compliance with emissions reductions standards for NOx and PM.

Comparison of Emissions of Each Boiler Unit with Permit Limitations

(lb/MMBTU Basis)

Pollutant

Permit

Limitations

lb/hr Per Unit

Unit 1A

Emissions

lb/hr

Unit 1B

Emissions

lb/hr

Unit 2A

Emissions

lb/hr

Unit 2B

Emissions

lb/hr

SO2 1.2 0.328 0.132 0.141 0.224

TSP 0.030 0.0206 0.0256 0.021 0.021

NOx 0.5 0.076 0.263 0.084 0.14

Compliance by the four boiler units with emissions limitations for all pollutants was demonstrated.


Additional performance testing was conducted on those emissions points subject to NSPS Subparts

Y and OOO. The cogeneration plant included several identical emissions units on the coal, ash,

and limestone handling systems. For the additional emissions points subject to Subparts Y and

OOO, the permittee was allowed the option of conducting performance testing on one

representative emissions point of each category to demonstrate that all identical sources are in

compliance with emissions limitations.

Performance testing for those facilities subject to Subpart Y consisted of opacity observations.

Performance standards for facilities subject to Subpart OOO were somewhat more complex. Each

emissions point was required to receive, at minimum, 3 hours of opacity observations. Stack

emissions received Method 5 performance testing except as noted below.

Performance testing was not conducted on three affected facilities. The coal reclaimer baghouse

had recently suffered fire damage and was therefore not operable for performance testing. It was no

longer an active emission point and performance testing was postponed until repairs were

conducted. The baghouse on the limestone rail car receiving station was only operated

intermittently and was not tested. Instead, the fans servicing the baghouse were activated to

determine that the baghouse was operated at a pressure drop of 3 inches WC during operations,

which was indicative of sufficient PM collection efficiency. A waiver of the performance testing

requirement for this emission point was allowed under 40 CFR 60.8 when the owner or operator

can show to the satisfaction of the Administrator "by other means" than a performance test that an

affected facility is in compliance with emissions limitations. Similarly, a waiver was allowed for

the bottoms ash handling systems when it was shown that similar baghouses operating under more

severe loading achieved emissions of 0.028 g/DSCM, compared to the standard of 0.05 g/DSCM.

Since there was no forced-air system on the storage dome, the openings in the dome roof were not

"vents" as defined by Subpart OOO. Those openings were, therefore, subject to the standards of

10% opacity for transfer points on conveyor belts and other fugitive emissions from affected

facilities other than crushers where a capture system is not used. The 10% opacity standard was

also applicable to the conveyor vents.

Comparison of Minor Particulate Matter Emissions Points with Applicable Standards

Source

Emissions Limitations Test Results

Opacity, % g/DSCM Opacity g/DSCM

Coal storage dome 10% --- 10% ---

Coal conveyors 20% --- 0% ---

Coal crusher baghouse 20% --- 0% ---

Coal storage silos 20% --- 0% ---

Limestone storage dome 10% --- 0% ---

Limestone reclaimer baghouse 7% 0.05 0% 0.0041

Limestone crusher 7% 0.05 0% 0.0076


Source

Emissions Limitations Test Results

Opacity, % g/DSCM Opacity g/DSCM

Limestone reclaimer tunnel vent

Head Pulley 10% --- 0% ---

Heel Pulley 10% --- 0% ---

Limestone receiving baghouse 7% 0.05 0% 0.0072

Crushed limestone silos baghouse 7% 0.05 0% ---

Ash Silo 20% 5%

Continuous Emissions Monitoring Systems (CEMS)

CEMS systems were required for the measurement of opacity, NOx, SO2, and diluent gases

(oxygen) from the boilers. The permittee was required to install, calibrate, and certify these

systems using the methods and procedures of 40 CFR 60, Appendix B.

A single opacity monitor was allowed for the main boiler stack rather than requiring opacity

monitors for each individual unit. That monitor was installed, calibrated, and certified using the

methods and procedures of Performance Specification 1 of Appendix B to 40 CFR 60. The facility

was therefore in compliance with the continuous emissions monitoring requirements of NSPS

Subpart Da and Permit No. 86-045-O (PSD).

Conclusions on Performance Tests

The applicant demonstrated compliance with applicable state and federal ambient air quality

standards and air pollution control regulations. Operating Permit No. 86-045-O (PSD) was issued

on June 17, 1991. Subsequently, Title V Operating Permit No. 96-290-TV (PSD) was issued on

August 13, 1998. Individual lb/hr emission limitations for each boiler were removed in the Title V

permit. During the evaluation of current permit application it was determined that the emission

limitations for each boiler shall be on individual lb/hr basis. Therefore, individual lb/hr emission

limitations for each boiler have been reestablished in this permit.

Tier Classification and Public Review

The permit has been determined to be a Tier II based on being a Title V renewal application. The

Notice of Filing was published in the Poteau Daily News & Sun on March 14, 2006 . This facility is

located within 50 miles of the Oklahoma - Arkansas border. The state of Arkansas has been

notified of the draft permit.

The applicant will publish the “Notice of Draft Permit” in a daily newspaper in LeFlore County,

Oklahoma. The notice will state that the draft permit will be available for public review at the

local Public Library and also at the Air Quality Division’s Main Office in Oklahoma City,

Oklahoma. The draft permit will also be available for public review on the Air Quality Section

of the DEQ Web Page at http://www.deq.state.ok.us.

http://www.deq.state.ok.us/


The applicant has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant owns the real property.

Inspection

A full compliance inspection was conducted on January 19, 2011 by Ms. Brandie Czerwinski

and Mr. Rene Koesler, Environmental Programs Specialists of DEQ of the Regional Office at

Tulsa. Ms. Bobbie Hull, Environmental Coordinator, and Mr. Jim Channels, CEM Technician,

with AES Shady Point, LLC (AES) represented the company during the inspection. Records

indicated that the facility was operating as described in the permit application and supplemental

materials, and that all emission units were in compliance with all applicable regulations, except

for PM emissions of the boilers. The company has submitted a compliance plan to bring the

boilers in compliance for PM emissions.

RATA Testing

All testing required by the initial PSD permit was completed and demonstrated compliance. The

facility continues to monitor emissions as required by NSPS and conducts annual testing of the

equipment for verification. RATA tests on January 19, 2011, shown below demonstrate that the

continuous emission monitors are operating as required.

Exhaust

Component

Relative Accuracy

Standard

Boiler Unit Results

1-A 1-B 2-A 2-B

SO2 20% by RM 7.749% 5.161% 10.096% 2.128%

NOx 20% by RM 1.218% 1.268% 1.196% 0.335%

O2 20% by RM 0.044% 0.073% 0.055% 0.097%

NOTE: RM = reference method.

Compliance Plan

Inconsistency had existed in regards to appropriate PM testing methods to demonstrate

compliance with the demonstration methods and previous permit PM stack emission limits. In

order to clearly demonstrate compliance with the clarified PM compliance limits for the Shady

Point facility, AES proposes to upgrade the existing baghouse bag filters according to the

following schedule.

Baghouse Bag Replacement Schedule

Unit Installation Date

One Boiler 2011

One Boiler 2012

Two Boilers 2013

Testing Schedule

Each Boiler Baghouse Within 60 days of installation of each set of bags

Common Stack Within 60 days of complete installation of all 4

boiler baghouse upgrades


The compliance demonstration shall be an ODEQ approved EPA reference method test. AES

shall provide a testing protocol 30 days prior to each test.

Fees Paid

Title V operating permit renewal fee of $1,000.

X. SUMMARY

The applicant has demonstrated compliance with all applicable requirements. Ambient air

quality standards are not threatened at this site. There are noncompliance issues of PM

emissions of four boilers. The compliance and enforcement section of the Air Quality Division

concurs on issuance of this permit pending the said noncompliance issue. Issuance of the permit

is recommended, contingent on public and the EPA review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS


Coal-fired Cogeneration Plant Permit Number 2003-062-TVR

The permittee is authorized to operate in conformity with the specifications submitted to Air

Quality on February 11, 2003, and all other supplemental information. The Evaluation

Memorandum, dated June 28, 2011, is attached to this permit to explain the derivation of

applicable permit requirements and estimates of emissions; however, it does not contain operating

limitations or permit requirements. Continuing operations under this permit constitutes acceptance

of, and consent to, the conditions contained herein:

1. Facility is authorized to combust coal and coal blended products with the following points

of emissions: [OAC 252:100-8-6(a)&(f)]

EUG 2: Boilers 1A, 1B, 2A, and 2B have the following combined emissions limitations Emissions Rate Emissions Per Boiler Unit Total Emissions

(All Four Units)

Pollutant lb/MMBTU % Reduction lb/hr(i)

TPY(j)

lb/hr(i)

TPY(j)

SO2(a)

1.20/0.60(h)

90/70(h)

590.5 2,586 2,363.0

10,346

NOx(b)

0.50 65 382.5 1,625 1,530

6,701

PM(c)

0.03 99

PM(d)

0.2 22.6 99.0 90.4 396

CO(e)

152.5 668.0 610.0 2,672

VOC(f)

0.064 4.9 21.5 19.6 85.8

Fluorides(g)

3.2 14.0 12.8 56.1

Be(g)

0.0053 0.023 0.0212 0.093

Pb(g)

0.49 2.15 1.96 8.58

Hg(g)

0.11 0.482 0.44 1.93

Opacity 20%

(a) basis: 0.75 lb/MMBTU heat input

(b) basis: 0.20 lb/MMBTU heat input

(c) Front half emissions for NSPS Da compliance

(d) Combined front and back half PM emissions for OAC: 252:100-19 compliance

(e) basis: 0.20 lb/MMBTU heat input

(f) basis: 6 ppm, wet basis

(g) quantity of trace elements in coal based on “Trace Elements Coal,” CRC Press Inc., 1983,

Vol. 1. Removal efficiencies based on CFR manufacturer’s data

(h) NSPS Subpart Da: for 0.60 to 1.2 lb/MMBTU, 90% minimum reduction is applicable for

30-day rolling averages. At less than 0.60 lb/MMBTU, 70% minimum reduction is

applicable for 30-day rolling averages.

(i) lb/hr and opacity limits based on 30-day rolling average.

(j) TPY limits are based on a 12-month rolling average.

SPECIFIC CONDITIONS 2003-062-TVR DRAFT Page 2

EUG 4: Ash Transfer & Loading – These sources do not have total emission limits but

have opacity limits as shown.

OPERATION

ASH MAX

OPACITY

Conveying 20%

Loading 20%

EUG 5A: Limestone Unloading, – These sources do not have total emission limits but have

opacity limits as shown.

OPERATION

LIMESTONE

NSPS

SUBPART

MAX

OPACITY

MAX STACK

PM (G/DSCM)

Unloading NA 20% NA

EUG 5B: Limestone Transfer & Conveying, – These sources do not have total emission

limits but have opacity limits as shown.

OPERATION

LIMESTONE

NSPS

SUBPART

MAX

OPACITY

MAX STACK

PM (G/DSCM)

Conveying OOO 7% 0.05

Crushing OOO 7% 0.05

Fugitive Emissions OOO 10% --

EUG 6A: Coal Unloading – These sources do not have total emission limits but have

opacity limits as shown.

OPERATION

COAL

NSPS

SUBPART

MAX

OPACITY

MAX STACK

PM (G/DSCM)

Unloading Y 20% NA

EUG 6B: Coal Transfer & Conveying

OPERATION

COAL

NSPS

SUBPART

MAX

OPACITY

MAX STACK

PM (G/DSCM)

Conveying Y 20% NA

Crushing Y 20% NA


EUG 7: Truck & Maintenance Vehicle Traffic. These sources do not have total emission

limits.

EUG 8: Material Storage: These sources do not have total emission limits but have opacity

limits as shown.

OPERATION

COAL NSPS

SUBPART

MAX

OPACITY

MAX STACK

PM (G/DSCM)

Stockpiling NA 20% NA

EUG 9: Storage Tank: The MEA tank is insignificant and does not have emission limits.

2. AES shall meet the following Compliance Plan requirements:

(a) AES shall install new baghouse fabric filters (bags) in each of the existing baghouses.

The new bags shall be designed to meet the particulate matter limits of S.C. #1. The

new bags shall be installed no later than the following dates:

Unit Installation Date

One Boiler 2011

Two Boilers 2012

One Boiler 2013

(b) AES shall demonstrate compliance with the particulate matter limitations according to

the following schedule:

Testing Schedule

Each Boiler Baghouse Within 60 days of installation of each set of bags

Common Stack Within 60 days of complete installation of all 4

boiler baghouse upgrades

(c) The compliance demonstration required under S.C. 2(b) shall be an ODEQ approved

EPA reference method test. AES shall provide a testing protocol 30 days prior to each

test.

3. The permittee shall maintain the required continuous monitoring systems using the methods

and procedures set forth in 40 CFR 60.13, 60.47a, 40 CFR 60 Appendix B, and 40 CFR 60

Appendix F, and shall record the output of the systems: [40 CFR 60.40 Subpart Da]

(a) the opacity of emissions discharged to the atmosphere

(b) sulfur dioxide emissions to the atmosphere

(c) nitrogen oxides emissions to the atmosphere


(d) the oxygen content of flue gases at each location where sulfur dioxide and nitrogen

oxide emissions are monitored

4. Since sulfur dioxide control is effected in the fluid bed of the boilers by limestone injection

and not with a discrete control device, the permittee shall maintain an "as-fired" fuel

monitoring system meeting the requirements of Method 19 (40 CFR 60 Appendix A) to

determine potential sulfur dioxide emissions. [40 CFR 60.40 Subpart Da]

5. Compliance with the SO2 lb/MMBTU emissions limitations and percentage reduction

requirements under 40 CFR 60.43a and NOx lb/MMBTU emissions limitations under 40

CFR 60.44a shall be determined on the basis of the average emissions rate for 30 successive

boiler operating days, a 30-day rolling average. At the conclusion of a boiler operating day,

data points from the leading day are deleted and data points for the new day are added to

develop new rolling average values for both SO2 and NOx lb/MMBTU emissions rates and

the SO2 reduction percentage. [40 CFR 60.43Da and 60.44Da]

6. Compliance with the NOx and SO2 lb/hr emission limits shall be determined on the basis of

the average emission rate for 30 successive boiler operating days, a 30-day rolling average.

7. SO2 and NOx CEMS monitoring results to show compliance with lb/MMBTU limits for each

24 hour period, as well as other items specified in NSPS Subpart Da, 40 CFR 60.51Da, shall

be reported to Air Quality Division every calendar quarter.

8. Compliance with the 0.50 lb/MMBTU emission limitation for NOx constitutes compliance

with the 65% reduction requirement for NOx. [40CFR60.44 Da(a)(2)]

9. Compliance with the 0.03 lb/MMBTU emission limitation for particulate matter front half

constitutes compliance with the 99% reduction requirement for particulate matter front half as

required by 40 CFR Part 60 Subpart Da. [40 CFR 60.42Da(a)(2)]& [OAC 252:100-8-6(a)]

10. At such times as directed by Air Quality Division, the permittee shall conduct performance

testing and furnish a written report documenting compliance with emissions limitations of

Specific Conditions No. 1. Performance testing by the permittee shall use the following test

methods specified in 40 CFR 60: [OAC 252:100-43]

Reference: Method

Method 1: Sample and Velocity Traverses for Stationary Sources

Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate

Method 3 or 3A: Gas Analysis for Carbon Dioxide, Excess Air, and Dry Molecular

Weight

Method 4: Determination of Moisture in Stack Gases

Method 5B, 17 and/or

202 or OTM 28:

Determination of Particulate Matter Emissions from Stationary

Sources

Method 6 or 6C: Determination of Sulfur Dioxide Emissions from Stationary Sources

Method 7 or 7E: Determination of Nitrogen Oxides Emissions from Stationary Sources

Method 9: Visual Determination of Opacity


Method 10: Determination of Carbon Monoxide Emissions From Stationary

Sources

Method 13 or 13B: Determination of Total Fluoride Emissions From Stationary Sources

Method 22: Determination of Fugitive Emissions from Stationary Materials

Processing Sources

Method 25 or 25A: Determination of Total Gaseous Non-Methane Hydrocarbon

Emissions From Stationary Sources

Method 12: Determination of Lead Emissions From Stationary Sources

Method 101A: Determination of Particulate and Gaseous Mercury Emissions From

Stationary Sources

Method 104: Determination of Beryllium Emissions From Stationary Sources

11. At least once during the term of this permit, the permittee shall conduct performance testing

on the four coal-fired boilers and submit a written report of results. [OAC 252:100-43]

(A) Performance testing by the permittee shall use the following test methods specified in

40 CFR 60.

Method 1: Sample and Velocity Traverses for Stationary Sources.

Method 2: Determination of Stack Gas Velocity and Volumetric

Flow Rate.

Method 3: Gas Analysis for Carbon Dioxide, Excess Air, and Dry

Molecular Weight.

Method 4: Determination of Moisture in Stack Gases.

Method 5B, 17 and/or

202 or OTM 28:

Determination of Particulate Matter Emissions from

Stationary Sources

A copy of the test plan shall be provided to AQD at least 30 days prior to each test

date.

(B) Performance testing shall be conducted while each boiler is operating within 10%

of the rate at which operating permit authorization will be sought.

(C) The testing reports shall include ash content of the coal being burned during

testing; coal supplier ash analysis will be acceptable.

12. Compliance Assurance Monitoring Requirements and Specifications: [40 CFR Part 64]

Parameter Indicator No. 1

Indicator Opacity

Measurement

Approach

Opacity shall be monitored using a continuous opacity monitor

Indicator Range An excursion is defined as an opacity greater than 20% except for

one six-minute period per hour not to exceed 27% opacity.

Data

Representativeness

The opacity monitoring system shall consist of a continuous opacity

monitor which has been certified using the methods and procedures


Parameter Indicator No. 1

Performance Criteria of 40 CFR Part 60, Appendix B, Performance Specification 1.

QA/QC Practices and

Criteria

Filter (attenuator) audit conducted at least once annually.

Monitoring Frequency Opacity is monitored at least once every 15 seconds

Data Collection

Procedure

Data are recorded by Continuous Parameter Monitoring System

(CPMS) or Data Acquisition Handling System computer

Averaging Period Six-minute averages

13. Each boiler as listed in Specific Condition 1, EUG 2, located at the cogeneration plant

which is used as steam generating unit for electric utility for which construction is

commenced after September 18, 1978, is subject to NSPS, 40 CFR Part 60, Subpart Da,

“Standards of Performance for Electric Utility Steam Generating Units,” and shall comply

with all applicable requirements therein.

a. §60.40Da Applicability and designation of affected facility.

b. §60.41Da Definitions.

c. §60.42 Da Standard for particulate matter (PM).

d. §60.43 Da Standard for sulfur dioxide (SO2).

e. §60.44 Da Standard for nitrogen oxides (NO).

f. §60.45 Da Standard for mercury (Hg).

g. §60.47 Da Commercial demonstration permit.

h. §60.48 Da Compliance provisions.

i. §60.49 Da Emission monitoring.

j. §60.50 Da Compliance determination procedures and methods.

k. §60.51 Da Reporting requirements.

l. §60.52 Da Recordkeeping requirements.

14. The coal handling and processing equipment, listed in Specific Condition 1, EUG 6A and 6B,

located at the cogeneration plant on which construction, reconstruction, or modification was

commenced after October 24, 1973, is subject to 40 CFR 60, Subpart Y, "Standards of

Performance for Coal Preparation Plants," and shall comply with all applicable requirements

therein.

a. 60.252: Standard for particulate matter (met through periodic monitoring)

b. 60.253: Monitoring of operation

c. 60.254: Test methods and procedures – completed during initial compliance

demonstration

15. Each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging

operation, storage bin, enclosed truck or railcar loading station, listed in Specific Condition 1,

EUG 5B, located at the cogeneration plant which processes a non-metallic mineral and on

which construction, reconstruction, or modification was commenced after August 31, 1983, is

subject to 40 CFR 60, Subpart OOO, "Standards of Performance for Nonmetallic Minerals

Processing Plants," and shall comply with all applicable requirements therein.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=42d7ae09ff0ce45cd0a2a6abdb686c97&rgn=div6&view=text&node=40:6.0.1.1.1.10&idno=40



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a. 60.672: Standard for particulate matter

b. 60.673: Reconstruction – completed during initial compliance demonstration

c. 60.674: Monitoring of operations – completed during initial compliance

demonstration

d. 60.675: Test methods and procedures – completed during initial compliance

demonstration

e. 60.676: Reporting and recordkeeping

16. The 420-hp diesel firewater pump is subject to the requirements for existing compression

ignition (CI) RICE engine located at a major source. The owner/operator shall comply with

applicable requirements of the NESHAP, 40 CFR Part 63, Subpart ZZZZ in accordance

with the timeline provided in the federal regulations. The requirements are including, but

not limited to, the following:

(a) § 63.6585 Am I subject to this subpart?

(b) § 63.6590 What parts of my plant does this subpart cover?

(c) § 63.6595 When do I have to comply with this subpart?

(d) § 63.6603 What emission limitations and operating limitations must I meet if I own

or operate an existing stationary RICE located at an area source of HAP emissions?

(e) § 63.6605 What are my general requirements for complying with this subpart?

(f) § 63.6612 By what date must I conduct the initial performance tests or other initial

compliance demonstrations if I own or operate an existing stationary RICE with a

site rating of less than or equal to 500 brake HP located at a major source of HAP

emissions or an existing stationary RICE located at an area source of HAP

emissions?

(g) § 63.6615 When must I conduct subsequent performance tests?

(h) § 63.6620 What performance tests and other procedures must I use?

(i) § 63.6625 What are my monitoring, installation, collection, operation, and

maintenance requirements?

(j) § 63.6630 How do I demonstrate initial compliance with the emission limitations

and operating limitations?

(k) § 63.6635 How do I monitor and collect data to demonstrate continuous

compliance?

(l) § 63.6640 How do I demonstrate continuous compliance with the emission

limitations and operating limitations?

(m) § 63.6645 What notifications must I submit and when?

(n) § 63.6650 What reports must I submit and when?

(o) § 63.6655 What records must I keep?

(p) § 63.6660 In what form and how long must I keep my records?

(q) § 63.6665 What parts of the General Provisions apply to me?

(r) § 63.6675 What definitions apply to this subpart?

17. Individual fugitive sources not subject to a specific opacity requirement shall be evaluated

at the property line for visible emissions by a Method 22. [OAC 252:100-29]


18. The permittee shall be authorized to operate the facility continuously (24 hours per day,

every day of the year). [OAC 252:100-8-6(a)]

19. No later than 30 days after each anniversary date of the issuance of this permit, the

permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region

6, a certification of compliance with the terms and conditions of this permit.

[OAC 252:100-8-6 (c)(5)(A) & (D)]

20. The records of operations shall be maintained on-site for at least five years after the date of

recording and shall be provided to regulatory personnel upon request. Required records

may be kept in digital format. [OAC 252:100-8-6 (a)(3)]

a. Records as required by Specific Condition 2.

b. Records as required by NSPS, 40 CFR Part 60, Subparts Da, Y, and OOO.

c. Records as required by NESHAP, 40 CFR Part 63, Subpart ZZZZ.

21. The following records shall be maintained on site to verify Insignificant Activities. No

recordkeeping is required for those operations which qualify as Trivial Activities.

[OAC 252:100-8-6 (a)(3)(B)]

a. Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel

fuel which are either used exclusively for emergency power or for peaking power

service not exceeding 500 hours/year: Hours of operation (Annual).

b. For fuel storage/dispensing equipment operated solely for facility owned vehicles (A

one- time determination, based on historical usage rates and equipment

specifications, will be maintained on file demonstrating that the facility could not

reasonably exceed the insignificant activities threshold. This information will be

recalculated upon a significant increase in vehicular operation). Throughput

(monthly and cumulative annual).

c. For the 4000-gallon diesel storage tank, and any VOC storage tanks with a capacity

of less than 39,894 gallons and a true vapor pressure less than 1.5 psia that may be

added in the future: A one-time determination, based on historical records of the

capacity of the tanks, vapor pressure of material stored and the contents of the tanks

will be maintained on file to demonstrate compliance.

d. For activities (except for trivial activities) that have the potential to emit less than 5

TPY (actual) of any criteria pollutant: the type of activity and the amount of

emissions or a surrogate measure of the activity (annual).

Test burns of individual blending materials limited to emissions of

5 TPY of any criteria pollutant, and

2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons

per year for single HAP that the EPA may establish by rule are considered

insignificant activities.

Trivial activities, and those insignificant activities which have been specifically identified

as not requiring recordkeeping, are not subject to this requirement.


22. All volatile organic compound (VOC) tanks with a capacity of 400 gallons or more and

storing a liquid which has a vapor pressure of 1.5 psia or greater shall be equipped with a

permanent submerged fill pipe or an organic vapor recovery system. [OAC 252:100-37]

23. This permit supersedes and cancels all previously issued Air Quality permits for this facility.

If a conflict should arise concerning a previous Air Quality permit and the current Title V

permit (Permit No. 2003-062-TVR), then Permit No. 2003-062-TVR shall take precedence.

24. Permit Shield - All applicable regulations have been properly translated into the Specific

Conditions of this permit.

OAC 252:100-7 Minor Facilities not in source category

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-21 Wood-waste Burning not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-35 Control of Carbon Monoxide not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Solid Waste Landfills not in source category

OOO – Ash not applicable, initial testing only and no longer has a testing compliance

requirement (applicability is addressed in the attached permit memorandum dated

June 28, 2011).

Y -- (applicability is addressed in the attached permit memorandum dated June 28,

2011).

ZZZZ -- (applicability is addressed in the attached permit memorandum dated June 28,

2011).

PSD – metals (applicability is addressed in the attached permit memorandum dated June

28, 2011).

HHHH-- (applicability is addressed in the attached permit memorandum dated June 28,

2011).

Kb -- (applicability is addressed in the attached permit memorandum dated June 28,

2011).

The following Federal Air Quality Rules are not applicable to this facility:

40 CFR Part 61 National Emission Standards for Hazardous Air

Pollutants No affected processes

40 CFR Part 63

Subpart DDDDD

Industrial and Commercial Institutional Boilers

and Process Heaters Exempt

40 CFR Part 63

Subpart Q Cooling Towers No affected sources

40 CFR Part 72 Acid Rain Not an affected source

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the

Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean

Air Act (excluding state-only requirements). This permit is valid for operations only at the

specific location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. 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 order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 Page 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official,

and shall contain the following language: “I certify, based on information and belief formed

after reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,


reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]


E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the 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 preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]


(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

1. 5 tons per year of any one criteria pollutant.

2. 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the


permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure

to meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.


(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia

or greater under actual conditions shall be equipped with a permanent submerged fill pipe

or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must


comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by


DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

DEQ Form #100-890 Revised 10/20/06

PART 70 PERMIT AIR QUALITY DIVISION

STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2003-062-TVR

AES Shady Point, L.L.C.,

having complied with the requirements of the law, is hereby granted permission to operate

the Cogeneration Plant in Section 2, T8N, R25E, LeFlore County, Oklahoma, subject to

standard conditions dated July 21, 2009, and specific conditions, both attached.

This permit shall expire five (5) years from the date below, except as authorized under

Section VIII of the Standard Conditions.

________________________________ _

Division Director, Air Quality Division Issuance Date


Mrs. Bobbie Hull, Environmental Coordinator

P.O. Box 1740

Panama, OK 74951

Re: Part 70 Operating Permit No. 2003-062-TVR

AES Shady Point – Coal Fired Cogeneration Plant

Section 2 - T8N - R25E, LeFlore County, Oklahoma.

Dear Ms. Hull:

Air Quality Division has completed the initial review of your operating permit application

referenced above. This application has been determined to be a Tier II. In accordance with 27A

O.S. §2-14-302 and OAC 252:002-31 the enclosed draft permit is now ready for public review.

The requirement for public review includes the following steps which you must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instruction enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of this draft permit and a copy of the application at a convenient

location within the county of the facility.

3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any

additional comments or requested changes, which you may have on the draft permit.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me or the permit writer at (405) 702-4100.

Sincerely,

Phillip Fielder, P.E.

Permits and Engineering Group Manager


Enclosure

Arkansas Dept. of Pollution Control and Ecology

P. O. Box 8913

Little Rock, AR 72219-8913

RE: Part 70 Operating Permit No. 2003-062-TVR

AES Shady Point – Coal Fired Cogeneration Plant

Section 2 - T8N - R25E, LeFlore County, Oklahoma.

Permit Writer: Iftekhar Hossain

Dear Sir / Madame:

The subject facility has requested a Part 70 operating permit under 40 CFR Part 70. Air Quality

Division has completed the initial review of the application and prepared a draft permit for

public review. Since this facility is within 50 miles of the Oklahoma-Arkansas border, a copy

of the proposed permit will be provided to you upon request. Information on all permits in active

review and a copy of this draft permit are available for review by the public in the Air Quality

Section of DEQ Web Page: http://www.deq.state.ok.us.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me or contact the permit writer at (405) 702-4100.

Sincerely,

Phillip Fielder, P.E.

Permits and Engineering Group Manager


Documents

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL · PDF fileOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... (Unit 1 Coal Storage Silos) ... Coal, Limestone and Ash Handling