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AIR QUALITY DIVISIONCHAPTER 6, SECTION 3

OPERATING PERMIT

WYOMING DEPARTMENT OFENVIRONMENTAL QUALITY

AIR QUALITY DIVISION122 West 25th Street

Cheyenne, Wyoming 82002

PERMIT NO. 3-2-094-1

Issue Date: August 16,2013Expiration Date: Decemher 20, 2016Effective Date: August 16, 2013Replaces Permit No.: 3-2-094

In accordance with the provisions ofW.S. §35-ll-203 through W.S. §35-1l-2l2 and Chapter 6,Section 3 of the Wyoming Air Quality Standards and Regulations,

Western Sugar CooperativeTorrington Factory

Section 15, Township 24 North, Range 61 WestGoshen County, Wyoming

(Amended January 17, 2013)

is authorized to operate a stationary source of air contaminants consisting of emission unitsdescribed in this permit. The units described are subject to the terms and conditions specified inthis permit. All terms and conditions of the permit are enforceable by the State of Wyoming.All terms and conditions of the permit, except those designated as not federally enforceable, areenforceable by EPA and citizens under the Act. A copy of this permit shall be kept on-site at theabove named facility.

Steven A. Dietrich, AdministratorAir Quality Division

Todd Parfitt, DirectorDepartment of Environmental Quality

Date

Date

8- JG-/3

WAQSR CHAPTER 6, SECTION 3 OPERATING PERMIT

WYOMING DEPARTMENT OF ENVIRONMENTAL QUALITYAIR QUALITY DIVISION

TABLE OF CONTENTS(modified August 16, 2013)

General Information 3

Source Emission Points .4

Total Facility Estimated Emissions 5

Facility-Specific Permit Conditions 6Facility-Wide Permit Conditions 6Source-Specific Permit Conditions , 6Testing Requirements 7Monitoring Requirements : 8Recordkeeping Requirements 10Reporting Requirements 12PSD Applicability Demonstration Requirements 14

Alternative Operating Scenario 16

WAQSR Chapter 7, Section 3 Compliance Assurance Monitoring (CAM) Requirements .18WAQSR Chapter 5, Section 3 and 40 CFR 63 SUbP31i JJJJJJ Requirements 19

Compliance Certification and Schedule 20Compliance Certification ", ,." ", 20Compliance Schedule" ", , , , , """" ,." , , 21

General Permit Conditions.., "" , "" " "".", , 22

State Only Permit Conditions , 27

Summary of Source Emission Limits and Requirements 29

• • "I \ l "Abbreviations :: .: 38

Definitions 39

Appendix A: Compliance Assurance Monitoring (CAM) Plan (Amended January 17, 2013)Appendix B: ReservedAppendix C: ReservedAppendix D: Reserved

PermitNo. 3-2-094-1

GENERAL INFORMATIONAmended August 14. 2014

Company Name: Western Sugar Cooperative

Mailing Address: 7555 East Hampden Avenue

City: Denver State: CO Zip: 80231

Plant Name: Torrington Factory

Plant Location: 400 South Main Street, Torrington WyomingSection 15, Township 24 North, Range 61 West, Goshen County, Wyoming

Latitude 1Longitude (WGS84): 42.048098/-104.185227

Plant Mailing Address: P.O. Box 700

City: Torrington State: WY Zip: 82240-0700

Narne of Owner: Western Sngar Cooperative

Responsible Official: reserved

Phone: (307) 532-7141

Plant ManagerlContact: Tom Briggs Phone: (307) 532-6723(Amended February 5,2015)

DEQ Air Quality Contact: District One Engineer Phone: (307) 777-7391Herschler Building122 W. 25th StreetCheyenne, Wyoming 82002

SIC Code: 2063 - Beet sugar

Description of Process: The plant processes sugar beet into sugar and byproducts, Theprocess of producing sugar is separated into five stages: diffusion, juice purification,evaporation, crystallization and pulp manufacture. The remaining pulp is processed bydrying and pressing into animal feed pellets. The finished sugar product is stored in thesugar silos and shipped later in both bulk and packaged form.

Permit No. 3-2-094-1

SOURCE EMISSION POINTSThis table may not include any or all insignificant activities at this facility.

modified August 16, 2013

001 Cleaver Brooks Summer Boiler - Natural Gas Fired 25.0 MMBtu/hr OP-193

002 #1 Union Boiler -Natural Gas I Fuel Oil Fired 87.7 MMBtu/hr OP-193,wv-12915

003 #2 Union Boiler - Natural Gas I Fuel Oil Fired 88.8 MMBtu/hr None

004 Stirling Coal Fired Boilers #3-#6 (Four baghouses 246 MMBtu/hr OP-147,vent to one stack) MD-7227

005/006 Pulp Dryer ~ Natural gas I fuel oil fired dryer with 40.0 ton/hr Nonetwo wet scrubbers and two stacks 100 MMBtu/hr

009 Diffuser Supply Tank Vent 0.05 ton/hr None

020 Pellet Cooler (Cyclone) 20.0 ton/hr AP-3435

038 (2) Sulfur Stoves - Beet End Sulfur Building Vents 0.05 ton/hr None

044 (2) Lime Kilns (Scrubber) 11.46 ton/hr April 6, 1992Waiver

052 Granulator (Sugar Dryer with Inherent Process 40.0 ton/hr AP-409Equipment Scrubber)

054 Coal Handling (Baghouse) 12.54 ton/hr OP-147

057 Slaker Exhaust Fan (Uncontrolled) 10.42 ton/hr None

069 Granulated Packaging (Baghouse) 40.0 ton/hr AP-4516

070 Brown and Powdered Sugar Packaging Facility 3.25 ton/hr None(Baghouse)

071 12/2& Industrial Powdered Sugar (Baghouse) I. 75 ton/hr None

074 #1 Silo Vent (Baghouse) 30 ton/hr MD-296




078 #1-#4 Silo (Baghouse) [scroll conveyor] 30 ton/hr MD-296

079 #5 Silo Vent (Bin vent filter) 30 ton/hr MD-252

080 #6 Silo Vent (Bin vent filter) 30 ton/hr MD-252

090 Sugar Cooler (with Inherent Process Equipment 40.0 ton/hr NoneScrubber)

ASA Ash Staging Area N/A AP-2867

N/A (19) Space Heaters 2.34 MMBtu/hr None(Total)

Fugitive Plant wide Fugitive Emissions N/A None


TOTAL FACILITY ESTIMATED EMISSIONSFor informational purposes only. These emissions are not to be assumed as permit limits.

(modified August 16, 2013)

POLLUTANT•••••

,....; ,': "y" E!VfIS~rgN$('I'PY)". , ..-. _." ..... ' .--'.- •••

CRITERIA POLLUTANT EMISSIONS

Particulate Matter 1132.7

PM10 Particulate Matter 936.3

Sulfur Dioxide (S02) 451.6

Nitrogen Oxides (NOx) 454.2

Carbon Monoxide (CO) 240.9

Volatile Organic Compounds (VOCs) 7.5

HAZARDOUS AIR POLLUTANT (HAP) EMISSIONS 9.8

Emission estimates are from the operating permit application and Ch 6 Sec 2 Waiver wv-12915.


FACILITY·SPECIFIC PERMIT CONDITIONS

Facility-Wide Permit Conditions

(Fl) SULFUR DIOXIDE EMISSIONS INVENTORY [WAQSR Ch 14, Sec 3]The permittee shall comply with the requirements of WAQSR Ch 14, Sec 3, including estimating SO,emissions in accordance with Ch 14 Sec 3(b), and adjusting estimates in accordance with Ch 14 Sec 3(c), ifnecessary.

(F2) FUGITIVE EMISSIONS [WAQSR Ch 3, Sec 2; Ch 6, Sec 2 Permit OP-147](a) The emission of fugitive dust shall be limited by all persons handling, transporting, or storing any

material to prevent unnecessary amounts of particulate matter from becoming airborne to the extentthat the ambient standards are not exceeded.

(b) Excessive fugitive dust emissions during the coal handling and rehandling (coal stacker and frontend loader operation) shall be controlled with water or chemical dust suppressants.

Source-Specific Permit Conditions

(F3) VISIBLE EMISSIONS [WAQSR Ch 3, Sec 2; Ch 6, Sec 2 Permits MD-252, MD-296](a) Visible emissions from. the Diffuser Supply Tank Vent (unit 009), the Sulfur Stoves (unit 038), the

Lime Kilns (unit 044), and the Sugar Cooler (unit 090) shall not exceed 40 percent opacity.(b) Visible emissions from the #5 Silo Vent (unit 079) and #6 Silo Vent (unit 80) shall not exceed 5

percent opacity.(c) Visible emissions of any contaminant discharged into the atmosphere from any other single emission

source shall not exhibit greater than 20 percent opacity except for one period or periods aggregatingnot more than six minutes in anyone hour of not more than 40 percent opacity.

(F4) BOILER AND HEATER EMISSIONS[WAQSR Ch 3, Sec 2; Ch 3, Sec 3; Ch 6, Sec 2 Permits OP'147, MD-7227; Ch 6, Sec3 (h)(i)(A)](a) Emissions from the Stirling Coal Fired Boiler #4 shall not exceed the limits specified in Table I.(b) Emissions from the combined operation of all four Stirling Coal Fired Boilers #3-#6 (unit 004) shall

not exceed the limits specified in Table II.(c) The sulfur content of the coal burned in boilers #3-#6 (unit 004) shall be limited to a maximum of

0.54 percent by weight.(d) NOx emissions from the Cleaver Brooks Summer Boiler (unit 001), Union Boilers (units 002 and

003 as a natural gas fired sources) shall not exceed 0.20 IblMMBtu ofheat input.(e) NOx emissions from the 19 natural gas fired space heaters shall not exceed 0.20 Ib/MMBtu heat

in ut.

0.1 24.6

TPY

357.0

(F5) ASH HANDLING [WAQSR Ch 6, Sec 2 Permit OP-147; Waiver AP-2867](a) The dustless flyash unloading system shall be equipped with sufficient anti-freezeup measures to

ensure trouble free operation during freezing temperatures.(b) For the ash staging area (unit ASA):

(i) Ash from the boilers will be covered with a thin layer of soil from the mud pond.(ii) Ash shall be wetted before it is loaded on trucks for shipment to a landfill,


(iii) Ash from the baghouses will not be stored in the ash staging area.

(F6) PARTICULATE EMISSIONS [WAQSR Ch 3, Sec 2(g) Tables; Ch 6, Sec 3(h)(i)(A); Ch 6, Sec 2 PermitsMD -252, MD-296, Waivers April 6, 1992, AP-4516]Emissions of particulate matter shall not exceed the limits specified in Table Ill.

..•.......... .. 'l'a!lleIll:l'arfictll <>." 'LIlli i,,' >/>.\>,/><• ••••••• .> . ..'

Source I·

WI/Source Description (gr/1)SCF) (lb/hr) (TPY)

005/006 Pulp Dryer with two wet scrubbers and two stacks 31.2

020 Pellet Cooler (Cyclone) 23.0

044 (2) Lime Kilns (Scrubber) 21.0

052Granulator (Sugar Dryer with Inherent Process

31.2Equipment Scrubber)

054 Coal Handling (Baghouse) 17.2

057 Slaker Exhaust Fan 15.4

069 Granulated Packaging (Baghouse) 0.04 3.1

070Brown and Powdered Sugar Packaging Facility

7.46(Baghouse)

071 12/2 & Industrial Powdered Sugar (Baghouse) 5.08

074 1/ 1 Silo Vent (Baghouse) 0.04 4.02 17.61

075 #2 Silo Vent (Baghouse) 0.04 4.02 17.61



078 #1-#4 Silo Baghouse [scroll conveyor] 0.04 1.66 7.24

079 #5 Silo Vent (Bin vent filter) 0.02

080 #6 Silo Vent (Bin vent filter) 0.02

090 Sugar Cooler (Inherent Process Equipment Scrubber) 42.5

(F7) PELLET MILL/COOLER/FAN OPERATION [WAQSR Ch 6, Sec 2 Waiver AP-3435]The permittee shall operate only two fan/cooler/pellet mill combinations at anyone time.

(F8) BAGHOUSE AND BIN VENT FILTER MAINTENANCE[WAQSR Ch 6, Sec 3(h)(i)(A); Ch 6, Sec 2 Permits MD-252 and MD-296)]The permittee shall maintain the Silo Vents Baghouses and Bin Vent filters (units 074, 075, 076, 077, 078,079 and 080) to the extent necessary to meet the opacity limits specified in condition F3 of this permit.

Testing Reguirements

(F9) PARTICULATE AND NOx EMISSIONS TESTING [W.S. 35-11-110] (modified August 16, 2013)(a) The permittee shall measure particulate matter and NOx emissions from the Stirling Coal Fired

Boilers #3-#6 (unit 004) at least once every five years for comparison with the emission limitsspecified in condition F4(a) and F4(b).(i) During the tests, the permittee shall measure individual steam production from Boilers #3-#6

and calculate steam production for the combination of all four Stirling boilers.(ii) Emissions from thc Stirling Boiler #4 shall be estimated by prorating the total measured

emissions by the ratio of steam production from Boiler #4 over the total steam productioncalculated for all four Stirling boilers.

(iii) Test data shall be used to develop particulate and NO, emission factors in lb/MMBtu for theStirling Boiler #4 and for Stirling Boilers #3-#6 (unit 004).


(iv) If tested particulate or NO, emissions are within 90% ofthe limits in condition F4(a) or F4(b),the permittee shall retest the boilers within 24 months.

(b) The permittee shall measure particulate matter emissions from the Pulp Dryer (units 005/006) andfrom the Lime Kilns (unit 044) at least once every five years for comparison with the emission limitsspecified in condition F6 of this permit. The permittee shall measure the scrubber liquid flow rateduring the testing.(i) During the test, the permittee shall collect data to demonstrate the relationship between

particulate matter emissions and the scrubberliquid flow rate. The permittee shall reevaluatethe established range of flow rates that reasonably assure compliance with the emissionlimits specified in Table lll, condition F6 of this permit, and if necessary, revise thecompliance assurance monitoring (CAM) plan (attached as Appendix A of this permit)accordingly.

(ii) The permittee shall submit a revised CAM plan, if necessary, to the Division's OperatingPermit Program, including a summary of the results of the emissions tests, within 60 days ofconducting the tests.

(iii) During subsequent tests, the permittee shall measure scrubber liquid flow rate to determine ifany further revisions are ueeded to the CAM plan.

(c) In the event fuel oil is burned as described in the Alternative Operating Scenario of this permit,testing shall be conducted according to the requirements in condition A2 of the AlternativeOperating Scenario.

(d) For the testing required under paragraphs (a) and (b) of this condition:(i) For particulate emissions, Methods 1-4 and 5 shall be used.(ii) For NOx emissions, Methods 1-4 and 7 or 7E shall be used.(iii) Method 19 shall be used to determine Ib/MMBtu emission factors.(iv) Unless otherwise specified, testing shall be conducted in accordance with WAQSR Ch 5,

Sec 2(h).(e) For the particulate matter and NOx emissions testing conducted under (a) and (b) of this condition,

the pertnittee shall notify the Division of the test date at least 15 days prior to testing. The noticeshall be submitted in accordance with condition G4 of this permit.

(FlO) ADDITIONAL EMISSIONS TESTING [W.S. 35-11-110](a) The Division reserves the right to require additional testing as provided under condition G1 of this

permit, Should testing be required, test methods found at 40 CFR 60, Appendix A, shall be used asfollows:

. (i) For visible emissions, Method 9 shall be used.(ii) For particulate emissions, Methods 1-4 and 5 shall be used.(iii) For S02 emissions, Methods 1-4 and 6 or 6C shall be used ..(iv) For NOx emissions, Methods 1-4 and 7 Or 7E shall be used.(v) For CO emissions, Methods 1-4 and 10 shall be used.(vi) For alternative test methods, or methods used for other pollutants, the approval of the

Administrator must be obtained prior to using the test method to measure emissions.(b) Unless otherwise specified, testing shall be conducted in accordance with WAQSR Ch 5, Sec 2(h).

Monitoring Requirements

(Fll) VISIBLE AND PARTICULATE EMISSIONS MONITORING [WAQSR Ch 6, Sec 3(h)(i)(C)(I); Ch 7,Sec 3](a) Periodic monitoring for visible emissions from the Cleaver Brooks Summer Boiler (unit 001), the #1

Union Boiler (unit 002), the #2 UnIon Boiler (unit 003), and the space heaters, shall consist ofmonitoring the type of fuel used to ensure natural gas is the sole fuel source for these units except asprovided in the Alternative Operating Scenario in this permit.

(b) The permittee shall conduct, at minimum, twice during each campaign period, Method 9observations of the Lime Kilns (unit 044) and the Pulp Dryer (units 0051006) to measure the opacityof visible emissions.(i) The two observations per campaign shall be separated by at least 30 days.


(ii) The observations shall be conducted by a qualified observer certified in accordance withSection 3,1 of Method 9 and shall follow the requirements and procedures of Method 9,

(c) The permittee shall adhere to the compliance assurance monitoring (CAM) plan, attached asAppendix A of this permit, for particulate emissions from the baghouse controlled Stirling CoalFired Boilers #3-#6 (unit 004), Granulated Packaging (unit 069), Brown and Powdered SugarPackaging Facility (unit 070), the 12/2 & Industrial Powdered Sugar (unit 071), #1 Siio Vent (unit074), #2 Silo Vent (unit 075), #3 Silo Vent (unit 076), #4 Silo Vent (unit 077), and the #1-#4 Silo(unit 078), and shall conduct monitoring as follows:(i) The permittee shall conduct, at minimum once daily, visual observations of each baghouse

controlled unit to determine the presence of visible emissions, The visual observations shallbe conducted by a person who is educated on the procedures for determining the presence ofvisible emissions in accordance with Method 22,

(ii) An excursion is defined as the presence of any visible emissions as described in the approvedCAM plan,

(iii) Observation of visible emissions from any unit shall prompt immediate inspection and, ifnecessary, corrective action and reporting.

(iv) The permittee shall perform the testing for particulate emissions from the Stirling Coal FiredBoilers #3-#6 (unit 004) as required by condition F9(a) for comparison with the emissionlimits specified in condition F4(a) and (b),

(v) The permittee shall follow all other applicabie requirements under conditions CAM-l throughCAM-4 of this permit.

(d) The permittee shall adhere to the compliance assurance monitoring (CAM) plan, attached asAppendix A of this permit, for particulate emissions from the wet scrubber controlled Pulp Dryer(units 005/006) and the Lime Kilns (unit 044), and shall conduct monitoring as follows:(i) The permittee shall measure, at least daily, the combined water flow rate in gallons per minute

to the two wet scrubbers controlling particulate matter emissions from the Pulp Dryer (units005/006),

(ii) The permittee shall measure, at least daily, the water flow rate in gallons per minute to the wetscrubber controlling particulate matter emissions from the two Lime Kilns (unit 044)

(iii) An excursion is defined as a scrubber water flow rate outside of the indicator range specifiedin the approved CAM plan,

(iv) Operation outside of the ranges established in the approved CAM plan shall trigger immediatecorrective action.

(v) The permittee shall perform testing for particulate emissions from the Pulp Dryer (units005/006) and Lime Kiins (unit 044) as required by condition F9(b) for comparison with theemission limits specified in condition F6, and to verify the relationship between particulatematter emissions and the scrubber liquid flow rate,

(vi) The permittee shall follow all other applicable requirements under conditions CAM-l throughCAM-4 of this permit.

(e) The permittee shall monitor the Pellet Cooler (unit 020), Granulator (unit 052), Coal Handling (unit054), Siaker Exhaust Fan (unit 057), #5 Silo Vent (unit 079), #6 Silo Vent (unit 080), and SugarCooler (unit 090) as follows:(i) The permittee shall conduct, at minimum, weekly observations of visible emissions from each

unit, The visual observations shall be conducted by a person who is educated on theprocedures for determining the presence of visible emissions in accordance with Method 22,

(ii) Observation of visible emissions from a source shall prompt immediate corrective action,(f) The permittee shall monitor the application of water and dust suppressants used to control excessive

fugitive dust emissions during coal handling and rehandling (coal stacker and front-end loaderoperations) required by condition F2(b) of this permit.

(g) The permittee shall inspect the anti-freezeup measures on the dustless flyash silo unloading systemto ensure the unloading system and the freeze protection is operational prior to the start of eachcampaign,

(h) Prior to the start of each campaign and weekly thereafter until the end ofthe campaign, the permitteeshall inspect the ash staging area and note:(i) Whether ash from the boilers is covered as required by condition F5(b), and(ii) Whether ash from the baghouses is stored in the ash staging area,

Permit No, 3-2-094-1

(FI2) STIRLING BOILER NOx AND PARTICULATE EMISSIONS MONITORING[WAQSR Ch 6, Sec 3(h)(I)(C)(I)](a) For NO, and particulate emissions from the Stirling Boiler #4, the permittee shaU:

(1) Conduct testing and estimate emissions in lb/MMBtu and Ih/hr as described in conditionF9(a).

(ii) Monitor individual steam output from the Stirling Boilers #3"#6, and calculate steamproduction for the combined four boilers, from July I to June 30 every year and determine asteam output ratio for Stirling Boiler #4 for that time period.

(iii) Monitor the amount and Btu content of coal burned in the Stirling Boilers #3-#6 from July Ito June 30 every.year,

(iv) Determine the estimated total NO, and particulate emissions in tpy using the data described in(i) through (iil) above.

(b) For NO, and particulate emissions from the Stirling Coal Fired Boilers #3-#6 (unit 004), thepermittee shall:(i) Conduct testing and estimate emissions in Ib/MMBtu and lblhr as described in condition

F9(a).(ii) Monitor the amount and Btu content of coal burned in the Stirling Boilers #3-#6 from July I

to June 30 every year.(iii) Determine the estimated total NO, and particulate emissions in tpy using the data described in

(i) through (il) ahove.

(F13) SULFUR CONTENT AND SO, MONITORING[WAQSR Ch 6, Sec 3 (h)(i)(C)(I); Ch 6, Sec 2 Permits OP-147, MD-7227](a) The permittee shall determine the sulfur content of each coal shipment for coal burned in the Stirling

Coal Fired Boilers #3-#6 (unit 004)(b) For SO, emissions from the Stirling Coal Fired Boilers #3-#6 (unit 004), the permittee shall:

(i) Track the daily operating hours of Stirling Boilers #3-#6 with an hour meter.(ii) Determine the amount of coal burned daily in the Stirling Boilers #3-#6.(iii) Every 24 hours, calculate the total SO, emitted in lb/day and the average SO, emitted in lblhr,

based on the data in (i) and (ii) above and the sulfur content of the coal burned that day.(iv) Determine the total SO, emissions in tpy from July 1 to June :30 every year by summing the

daily totals in (iii) above.(c) For SO, emissions from the Stirling Boiler #4, the permittee shall:

(i) Monitor the. steam output for the Stirling Boiler #4, and calculate the combined StirlingBoilers #3-#6 steam output, on a 24-hour basis every day that the Stirling Boiier #4 is inoperation, in order to determine a steam production ratio for the Stirling Boiler #4 comparedto the combined boilers.

(ii) Track the daily operating hours of the Stirling Boiler #4 with an hour meter.(iii) Every 24 hours, calculate the total SO, emitted in Ib/day from the Stirling Boiler #4 based on

the daily total determined in F13(b)(iii) and the steam production ratio determined in (i)above.

(iv) Every 24 hours, calculate the average SO, emitted in lblhr by dividing the Ib/day numberfrom (iii) above by the operating hours for that day determined from (ii) above.

(v) Determine the total SO, emissions in tpy from July I to June 30 every year by summing thedaily totals in (iii) above.

(FI4) PELLET COOLER OPERAnON MONITORING [WAQSR Ch 6, Sec 2 Waiver AP-3435]The permittee shall monitor the operating hours of the Pellet Mills to ensure compliance with therequirements in condition F7 of this permit.

Recordkeeping Requirements

(FI5) SULFUR DIOXIDE EMISSIONS INVENTORY RECORDS [WAQSR cs 14, Sec 3(b)](a) The permittee shall maintain all records used in the calculation of SO, emissions for the inventory

required by condition F I, including but not limited to the following:(i) Amount offuel consumed;


(ii) Percent sulfur content of fuel and how the content was determined;(iii) Quantity of product produced;(iv) Emissions monitoring data;(v) Operating data; and(vi) How the emissions are calculated, including monitoring/estimation methodology with a

demonstration that the selected methodology is acceptable under Ch 14, Sec 3.(b) The permittee shall maintain records of any physical changes to facility operations or equipment, or

any other changes (e.g. raw material 01' feed) that may affect emissions projections of SO,.(c) The permittee shall retain all records and support information for compliance with this condition and

with the reporting requirements of condition FI9 at the facility, for a period of at least ten (10)years from the date of establishment, or if the record was the basis for an adjustment to themilestone, five years after the date of an implementation plan revision, whichever is longer.

(FI6) TESTING AND MONITORING RECORDS[WAQSR Ch 6, Sec 3(h)(i)(C)(II); Ch 6, Sec 2 Waiver AP-343s](a) For any testing or monitoring required under conditions F9, FlO, and Fll(c) and (e), other than

Method 9 observations, the permittee shall record, as applicable, the following:(i) The date, place, and time of sampling or measurements;(ii) The date(s) the analyses were performed;(iii) The company or entity that performed the analyses;(iv) The analytical techniques or methods used;(v) The results of such analyses;(vi) The operating conditions as they existed at the time of sampling or measurement.(vii) During particulate matter and NO, emissions testing of the Stirling Coal Fired Boilers #3-#6

(unit 004), the particulate and NO, emission factors determined in lb/MMBtu and allassociated data and calculations;

(viii) During particulate matter emissions testing of the Lime Kilns (unit 044) and Pulp Dryer (unit005/006), the scrubber liquid flow rate; and

(ix) Any corrective actions taken.(b) For any Method 9 observations required by the Division under conditions FlO or FI1(b), the

permittee shall keep field records in accordance with Section 2.2 of Method 9, as well as records ofanycorrective action taken.

(c) For the wet scrubber controlled Pulp Dryer (unit 005/006) and the Lime Kilns (unit 044), thepermittee shall maintain records of the water flow rate monitoring conducted in accordance withcondition Fll(d) of this permit, as well as records of any corrective action taken.

(d) For the compliance assurance monitoring required under condition FI I of this permit, the permitteeshall maintain records of any written Quality Improvement Plan required pursuant to WAQSRChapter 7, Section 3(h), any activities undertaken to implement a Quality Improvement Plan, andother supporting information required to be maintained under WAQSR Chapter 7, Section 3.

(e) For tbe monitoring of the Pellet Mills required under condition F14, the permittee shall keep recordsof the hours of operation.

(1) The permittee shall retain on-site at the facility, the records of each test, measurement, orobservation and support information for a period of at least five years from the date of the test,measurement, or observation.

(FI7) MAINTENANCE, INSPECTION AND FUGITIVE DUST CONTROL RECORDS[WAQSR Ch 6, Sec 3(h)(i)(C)(II)](a) The permittee shall record all maintenance performed on the Silo Vents Baghouses and Bin vent

filters (units 074, 075, 076, 077, 078, 079 and 080), as required by condition F8 of this permit. Therecord of maintenance activities for each unit shall include:(i) The maintenance activity performed;(ii) The date and place the activity was performed;(iii) The company and individual(s) that performed the activity; and(iv) The purpose of the activity.

Permit No. 3-2-094-1 Page J1

(b) The permittee shall record the use of water and dust suppressants to control fugitive dust emissionsduring coal handling and rehandling (coal stacker and front-end loader operations). The recordsshall include:(i) The date(s) of application;(ii) The type ofdust suppressant(s) used; and(iii) The amount of dust suppressant or water applied.

(c) The permittee 'hall record the results of the inspection on the anti-freezeup measures as required bycondition FII(g), documenting the operational status of the flyash unloading system and theantifreeze protection to ensure trouble free operation during freezing temperatures.

(d) The permittee shall maintain a log of inspections of the ash staging area (unit ASA) noting the dateand time of inspection, whether boiler ash is covered as required by condition F5(b), and whetherash from the baghouses is stored in the ash staging area.

(e) The permittee shall retain on-site at the facility the records of each activity for a period of at leastfive years from the date of the activity.

(FI8) STIRLING BOILERS RECORDS [WAQSR Ch 6, Sec 3 (h)(i)(C)(II); Ch 6, Sec 2 Permit MD-7227](a) For NO, and particulate emissions from the Stirling Boiler #4, the permittee shall maintain records

of the monitoring and all calculations required by condition FI2(a), including stearn output, thesteam output ratio, the Btu content of each coal shipment, the amount of coal burned, and theestimated total NO, and particulate emissions in tpy,

(b) For NO, and particulate emissions from the Stirling Boilers #3-#6 (unit 004), the permittee shallmaintain records of the monitoring and all calculations required by condition FI2(b), including theBtu content of each coal shipment, the amount of coal burned, and the estimated total NO, andparticulate emissions in tpy,

(c) The permittee shall retain the "as delivered" quantity and the sulfur and Btu content records of eachcoal shipment for coal burned in the Stirling Coal Fired Boilers #3-#6 (unit 004).

(d) For SO, emissions from the Stirling Boilers #3-#6 (unit 004), the permittee shall maintain records ofthe monitoring and all calculations required by condition FI3(b), including the daily operating hoursand amount of coal burned, the daily total SO, emitted in Iblday, the daily average SO, emitted inlblhr, and the running total SO, emissions for each year (from July I to June 30) in tpy.

(e) For SO, emissions from the Stirling Boiler #4, the permittee shall maintain records of the monitoringand all calculations required by condition FI3(c), including steam ontput, the steam output ratio, thedaily operating hours, the daily total SO, emitted in lb/day, the daily average S02 emitted in Iblhr,and the running total SO, emissions for each year (from July I to June 30) in tpy.

(t) The permittee shall retain on-site at the facility all records kept in accordance with this condition fora period of at least five years from the date of the, measurement or calculation.

Reporting Requirements

(FI9) SULFUR DIOXIDE EMISSIONS IN'VENTORY REPORTS [WAQSR Ch 14, Sec 3(b) and (c)](a) .The permittee shall report calendar year SO, emissions by April 15ili of the following year. The

inventory shall be submitted in the format specified by the Division.(b) Emissions from startup, shutdown, and upset conditions shall be included in the inventory.(c) If the permittee uses a different emission monitoring or calculation method than was used to report

S02 emissions in 1998, the permittee shall adjust reported S02 emissions to be comparable to theemission monitoring or calculation method that was used in 1998. The calculations that are used tomake this adjustment shall be included with the annual emission report.

(d) The annual reports shall reference this permit condition(FI9) and shall be submitted in accordancewith condition G4 of this permit.

(F20) TEST REPORIS [WAQSR Ch 6, Sec 3(h)(i)(C)(IInJ(a) The permittee shall report the results of the emissions tests required under condition F9, and any

additional testing required by the Division under condition FlO, within 45 days of conducting thetests.

(b) The reports shall include the information specified under condition F i6 and reference this permitcondition (F20), and shall be submitted to the Division in accordance with condition G4.


(F21) MONITORING REPORTS [WAQSR Ch 6, Sec 3(h)(i)(C)(III)](a) The following shall be reported to the Division by July 31 each year for the previous 12-month

period from July I to June 30:(i) Documentation that the Cleaver Brooks Summer Boiler (unit 001), the #1 and #2 Union

Boilers (unit 002 and 003), and the space heaters are firing natural gas as specified incondition Fll (a) of this permit, except as allowed under the Alternative Operating Scenario.

(ii) Summary results of the visible emissions monitoring required under condition FII(b) of thispermit; each opacity measurement and any corrective actions taken upon detecting noncompliance with opacity limitations shall be included in the report.

(iii) Results of the visible emissions monitoring required under condition FII(e) of this permit.Only monitoring during which visible emissions are observed and any corrective actionstaken upon observing visible emissions shall be included in the report. Ifno visible emissionsare observed during the reporting period, this shall be stated in the report.

(iv) The results of Compliance Assurance Monitoring (CAM) required under conditions FII(c)and Fll(d) of this permit for wet scrubber and baghouse controlled equipment, which shallinclude the following:(A) Summary results of the visible emissions monitoring required under condition FI 1(c)

of this permit: Only monitoring during which visible emissions are observed and anycorrective actions taken upon observing visible emissions shall be included in thereport. If no visible emissions are observed during the reporting period, this shall bestated in the report.

(B) A report which itemizes all time periods when the water flow rate for the wet scrubbercontrolled sources monitored under condition F11(d) of this permit were outside therange indicated in the CAM plan. If no excursions of the parameter ranges haveoccurred during tile reporting period, this shall be stated in the report.

(C) Summary information on the number, duration, and cause of excursions, as applicable,and thecorrective actions taken;

(D) Summary information on the number, duration, and cause for monitor downtimeincidents; and

(E) A description of the action taken to implement a QIP (if required) during the reportingperiod as specified in Chapter 7, Section 3(h). Upon completion of a QIP, thepermittee shall include in the next summary report documentation that theimplementation of the plan has reduced the likelihood of similar excursions.

(b) The following shall be reported to the Division by July 31 each year for the previous 12-monthperiod from July 1 to June 30:(i) Any exceedances of the coal sulfur content limit in condition F4 of this permit;(ii) The total NO" S02, and particulate emissions in tpy from the Stirling Coal Fired Boiler #4 as

calculated under conditions FI2(a) and FI3(c) of this permit. The report shall also includeany exceedances of the limits in condition F4 ofthis permit.

(iii) The total NO, S02, and particulate emissions in tpy from the Stirling Coal Fired Boilers #3-#6as calculated under condition FI2(b) and F 13(b) of this permit. The report shali also includeany exceedances of the limits in condition F4 of this permit.

(c) Ali instances of deviations from the conditions of this permit must be clearly identified in eachreport.

(d) The annual reports shali reference this permit condition (F2 I) and shall be submitted in accordancewith condition 04 of this permit.

(F22) DUST SUPPRESSION AND OPERATIONS REPORTS [WAQSR Ch 6, Sec 3(h)(i)(C)(III)]The following shall be reported to the Division by July 31 each year for the previous 12-month period fromJuly I to June 30:(a) A summary of any deviations from the ash handling requirements specified by condition F5 of this

permit. If there were no deviations, this shall be stated in the report,(b) A summary of any deviations from the pellet mills/cooler/fan requirements specified by condition F7

of this permit. If there were no deviations, this shall be stated in the report.


(c) The annual report shall reference this permit condition (F22) and shall be submitted in accordancewith condition G4 of this permit.

(F23) GREENHOUSE GAS REPORTS [W.S. 35-11-110]The permittee shall submit to the Division a summary of any report(s) required to be submitted to the EPAunder 40 CFR Part 98.(a) The reports shall be submitted to the Division within 60 days of submission to EPA, in a format as

specified by the Division.(b) The reports shall be submitted in accordance with condition G4(a)(i) of this permit, to the attention

of the Division's Emission Inventory Program. A copy need not.be sent to the DEQ Air Qualitycontact.

(F24) REPORTING EXCESS EMISSIONS & DEVIATIONS FROM PERMIT REQUIREMENTS[WAQSR Ch 6, Sec 3(h)(i)(C)(III)](a) General reporting requirements are described under the General Conditions of this permit. The

Division reserves the right to require reports as provided under condition G1 of this permit.(b) Emissions which exceed the limits specified in this Permit and which are not reported under a

different condition of this permit shall be. reported annually with the emission inventory unlessspecifically supersededby condition G17, condition Gl9, or other condition(s) of this permit. Theprobable cause of such exceedance, the duration of the exceedance, the magnitude of theexceedance, and any corrective actions or preventative measures taken shall be included in thisannual report. For sources and pollutants which are not continuously monitored, if at any timeemissions exceed the limits specified in this permit by 100percent, or if a single episode of emissionlimit exceedance spans a period of 24 hours or more, such exceedance shall be reported to theDivision within one workingday of the exceedance.(Excess. emissions due to an emergency shallbe reported as specified in condition Gl7. Excess emissions due to unavoidable equipmentmalfunction shall be reported as specified in condition Gl9.)

(c) Any other deviation from the conditions of this permit shall be reported to the Division in writingwithin 30 days of the deviation or discovery of the deviation.

Prevention of Significant Deterioration (PSDl Applicability Demonstration Requirements(modified August 16, 2013)

(F2S) PROJECT REQUIREMENTS [WAQSjl. eh 6, Sec 2 Waiverwv-1291S](a) Starting in calendar year 2013.. and lasting S years, the permittee shall track actual NOx

emissions from the #1 Union Boiler (unit 002) to demonstrate that the tube repair project,described in Waiver wv-1291S, does not result in a major modification under WAQSR Ch 6,Sec 4.

(b) The actual emissions from the #1 Union Boiler (unit 002) shall not exceed 49.2 TPY, on acalendar year basis.

(F26) PROJECT ElVIISSIONS MONITORING [WAQSR Ch 6, Sec 2 Waiver wv-1291S;Ch 6Sec 3(h)(i)(C)(I)] .The permittee shall monitor the annual fuel usage and calculate the sum of NOx emissions from the#1 .Union Boiler (unit 002) for both natural gas-firing and fuel oil-firing. The permittee shalldetermine actual NOx emissions using the following methodology, unless an alternate method isapproved by the Division.(a) When natural gas is burned in the boiler, the permittee shall calculate NOx emissions using the

tested emission rate determined during the December 2012 test and the actual natural gasusage for each calendar year.

(b) In the event fuel oil is burned in the boiler for less than 14 days, as authorized by condition Alof this permit, the permittee shall calculate NOx emissions using the actual fuel oil usage foreach calendar year and either the NOx emission limit specified in Table IV or a tested NOxemission rate. Should the permittee choose to test, NOx emissions shall be measured inaccordance with conditions A2(b)(i) and (Ii) aud A2(d).


(c) In the event fuel oil is burned in the boiler for 14 days or more, as authorized by condition AIof this permit, the permittee shall calculate NOx emissions using the actual fuel oil usage foreach calendar year and the NOx emisslon rate established during the testing required hycondition A2(b)(i) and (ii), NOx emissions shall be measured in accordance with conditionsA2(b)(i) and (ii) and A2(d).

(F27) PROJECT RECORDKEEPING REQUIREMENTS[WAQSR Ch 6, Sec 2 Waiver wv-12915; Ch 6 Sec 3(h)(i)(C)(II)](a) The permittee shall maintain a record of the all the calculations and data described in

condition F26 used to determine the annual NOx emissions in tons per calendar year.(b) In the event NOx testing is conducted as specified in condition F26(b) or (c), the permittee shall

maintain records in accordance with condition A3(f).(c) The permittee shall retain these records on-site for at least 5 years from the date they are

generated.

(F28) PROJECT REPORTING REQUIREMENTS [WAQSR Ch 6, Sec 2 Waiver wv-12915; Ch 6 Sec3(h)(i)(C)(IIl)](a) In the event fuel oil is burned in the boiler and NOx testing is condncted, the permittee shall

report the results of the emissions test in accordance with condition A4(b).(b) The permittee shall report the annual NOx emissions in TPY from the #1 Union Boiler (unit

002) to the Division within 60 days after the end of each calendar year. The report shallindicate the duration of time fuel oil was burned in the boiler at any time during the reportingperiod in terms of hours. If no fuel oil was hurned in the boiler during the reporting period,this shall be stated in the report.

(c) The reports shall reference this condition (F28) and be submitted in accordance with conditionG4.

(F29) PROJECT COMPLETION REQUIREMENTS [WAQSR Ch 6, Sec 2 Waiver wv-12915]Upon completion of the five year monitoring period established in condition F25(a), the requirementsof conditions F25, F26 and F28 shall expire. The records required hy condition F27 shall hemaintained for a period of at least five years from the date such records are generated.


ALTERNATIVE OPERATING SCENARIO

(AI) OIL FIRING [WAQSR Ch 3, Sec2 and 3; Ch 6, Sec 3(h)(i)(A); Ch 6, Sec 2 Permit OP-193](a) The permittee may operate the #1 Union Boiler (unit 002), the #2 Union Boiler (unit 003), and the

Pulp Dryer (unit 005/006) as oil fired sources only in the event natural gas availahility is interrupted.(b) The fuel oil burned at the Torrington facility shall contain LO percent or less of suifur and OJ

percent or less of nitrogen. The permittee shall test or document the sulfur content and nitrogencontent of the fuel oil burned in the #1 Union Boiler (unit 002), the #2 Union Boiler (unit 003), andthe Pulp Dryer (unit 0051006) under this alternate operating scenario.

(c) Visible emissions of any contaminant discharged into the atmosphere from the #1 Union Boiler (unit002), the #2 Union Boiler (unit 003), and the Pulp Dryer (unit 0051006), as oil fired sources, shallnot exhibit greater than 20 percent opacity except for one period or periods aggregating not morethan six minutes in anyone hour of not more than 40 percent opacity.

(d) Particulate and NOx emissions from the oil-fired boilers shall not exceed the rates shown in TableIV oflhis permit.

(e) All other conditions of this permit, except condition F1I(a) for the unites) operating under thisAlternative Operating Scenario, shall remain enforceable dnring operation under this AlternativeOperating Scenario.

0.10 lb/MMBtuMaximum two-liour average

#2 Union Boiler (unit 003)

Pulp Dryer Stacks (unit 0051006)

Fuel Oil

Fuel Oil

0.10 lb/MMBtuMaximum two-hour average31.2 lb/hr

0.301b/MMBtu

(A2) PARTICULATE AND NOx EMISSIONS TESTING [W.S. 35-11-110](a) In the event fuel oil is burned for more than 7 days (168 hours) in any of the units listed in condition

AI(a) during any campaign period, the permittee shall conduct daily Method 9 observations on theunlt(s) burning fuel oil to measure the opacity of visible emissions.(i) Method 9 observations shall begin no later than the first day after the 7 day (168 hour) time

period has been exceeded, and shall occur every day thereafter during that campaign periodthat the unites) is burning fuel oiL

(li) The observations of visible emissions shall be determined by a qualified observer certified inaccordance with Section 3.1 of Method 9 and shall follow the requirements and procedures ofMethod 9.

(b) In the event fuel oil is burned for more than 14 days (336 hours) in the #1 Union Boiler (unit 002) orthe #2 Union Boiler (unit 003) during any campaign period, the permittee shall measure particuiateand NOx emissions from the unites) exceeding the 14 day (336 hour) time period for comparisonwith the emission limits in Tahle IV.(i) The testing shall be conducted while the unit is hurning fuel oil, prior to the end of the

campaign period, unless an extension is granted hy the Division. Such an extension must herequested by no later than the 7th day of fuel oil burning,

(ii) Such testing shall not be required if the unit was tested as described by this permit conditionA2 within the last five years and demonstrated compliance with condition AI.

(c) In the event fuel oil is burned for more than 14 days (336 hours) in the Pulp Dryer (unit 005/006)during any campaign period, the permittee shall measure particulate emissions from the Pulp Dryerfor comparison with the emission limit in Table IV.(i) The testing shall be conducted while the unit is burning fuel oil, prior to the end of the

campaign period, unless an extension is granted by the Division. Such an extension must berequested by no later than the 7"' day offuel oil burning,

(li) Such testing shall not be required if the unit was tested as described by this permit conditionA2 within the last five years and demonstrated compliance with condition AI.


(d) Should testing be required under paragraphs (b) 01' (c) ofthis condition, testmethods foundat40CFR 60, AppendixA, shall be used as follows:(i) For particulate emissions, Methods 1-4 and 5 shall be used.(ii) The permittee shall measureNOx emissions from each boiler using the Division's portable

analyzer monitoring protocol, or the EPA reference methods described in condition FlO. TheDivision's monitoring protocol is attached as Appendix C of this penmit.

(e) Unless otherwise specified, testing shall be conducted in accordance with WAQSR Ch 5, Sec 2(h).

(A3) RECORDKEEPING [WAQSR Ch 6, Sec 3(h)(i)(C)(Il); Ch 6, Sec 3(h)(i)(I)(1)](a) The penmittee shall, contemporaneously with making a change from one operating scenarioto

another, record in a log at the site a record of the scenario under which the affected unit is operating.(b) The permittee shall record the hours the units listed in AI(a) operate under this alternative

operating scenario.(c) The permittee shall maintain records of the analyses conducted under conditionAI(b) of this penmit.(d) The permittee shall maintain records of the amount of oil burned under the alterative operating

scenario during each campaign period.(e) For any Method 9 observations required under conditionA2(a), the permittee shall keep field

records in accordance with Section 2.2 of Method 9.(I) For any testing required under condition A2, other than Method 9 observations, the permitteeshall

record, as applicable, the following:(i) The date, place, and time of sampling or measurements;(ii) The date(s) the analyses were performed;(iii) The company or entity that performed the analyses;(iv) The analytical techniques or methods used;(v) The results of such analyses; and(vi) The operating conditions as they existed at the time of sampling or measurement.(vii) Any corrective actions taken.

(g) The permittee shall retain on-site at the facility the records of operating scenarios, oil analyses, andeachtest) measurement, or observation and support information for a period of five years from thedate the records are generated.

(A4) REPORTING [WAQSR Ch 6, Sec 3(h)(i)(C)(III); Ch 6, Sec 2 September 30,1993 Waiver](a) The following shall be reported to the Division by July 31 each year for the previous 12-month

period from July I to June 30:(i) The amount of oil burned in each of theunits listed in condition A I.(ii) The number of hours each unit operated under this alternative scenario.(iii) Documentation of the sulfur and nitrogen content of the fuel oil burned in each unit while

operating under this Alternative Operating Scenario. If the units did not operate under theAlternative Operating Scenario during the reporting period, this shall be stated in the report.

(iv) Results of any visible emissions monitoring required under condition A2(a) of this permit,Each opacity measurement and any corrective actions taken upon detectingnoncompliancewith opacity limitations shall be included in the report.

(b) The penmittee shall report the results of any testing required under conditionA2(b) or (c) within45days of conducting the tests. The reports shall include the information specified under conditionA3(f).

(c) All instances of deviations from the conditions of this permit must be clearly identified in eachreport.

(d) The reports shall be refer to this permit condition (A4) and be submitted in accordance withcondition G4 of this permit.


WAOSR CHAPTER 7, SECTION 3COMPLIANCE ASSURANCE MONITORING (CAM) REOUIREMENTS.

WAQSR Ch 7, Sec 3 is available at http://deq.state.wy.us/aqd/standards.asp, or from the Division uponrequest. (modified August 16, 2013)

(CAM"I) COMPLIANCE ASSURANCE MONITORING REQUIREMENTS [WAQSR Ch 7, Sec 3(b) and(c)]The permittee shall. follow the CAM plan attached as Appendix A of this permit and meet all CAMrequirements of WAQSR Chapter 7, Section 3 as they apply to the Pulp Dryer (unit 005/006), the LimeKilns (nnit 044), and baghouse controlled sources (units 004, 069, 070, 071, 074, 075, 076, 077, 078).Compliance with the source specific monitoring, recordkeeping, and reporting requirements of this permitmeets the monitoring, recordkeeping, and reporting requirements of WAQSR Ch 7, Sec 3, except foradditional requirements specified under conditions CAM"2 through CAM"4.

(t)

(b)

(d)

(c)

(d)

(b).

(e)

(c)

OPERAT.ION OF APPROVED MONITORING [WAQSR Ch 7, Sec 3(g)]At all times, the pel111itteeshallmaintain the 1I10nitorin& ulld~r this section; including but not limitedto, maintaining necessary parts for routine repairs of the monitoring equipment.Except for monitoring malfun~tions, associated repairs,and required quality assurance or controlactivities, the permittee shall collduct all monitoring in continuous operation (or at all requiredintervals) at all times that the pollutant specific emissions llnit is operating.Upon detecting an excursion, the permittee shall restore operation of the pollutant-specific emissionunit to its normal or usual manner of operation as expeditiously as practicable in accordance withgood air pollution control practices. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any corrective actions to restore normal operation andprevent the likely recurrence Ofthe cause ofan excursion.If the permittee identifies a failure to achieve compliance with an emission limit for which themonitoring did not provide an indication of an excursion while providing valid data, or the results ofcompliance 01' performance testing documents a need to modify the existing indicator ranges, thepermittee shall proll1ptly notify the Division and, if necessary, submit a proposed modification tothis permit to address the necessary monitoring changes.

QUALITY IMPROVEMENT PLAN (QIP) REQUIREMENTS [WAQSR Ch 7, Sec 3(h)]If the Division 01' the EPA Administrator determines, based on available information, that the

. permittee has used unacceptable procedures in response to an excursion or exceedance, the permitteemay be required to develop and implement a Quality Improvement Plan (QIP).If required, the permittee shail maintain a written Quality Improvement Plan (QIP) and have itavailable for inspection.The plan shall include procedures for conducting one or more ofthe foilowing:(i) Improved preventative maintenance practices.(ii) Process operation changes.(iii) Appropriate impro~ementst() control methods.(iv) Other steps appropriate to correct control.(v) More frequent or improved monitoring (in conjunction with (i)" (iv) above).If a QIP is required, the permittee shall develop and implement a QIP as expeditiously as practicableand shall notify the Division if the period for completing the QIP exceeds 180 days from the date onwhich the need to implement the QIP was determined.Foilowing implementation of a QIP, upon any subsequent determination under paragraph (a) above,the Division may require the permittee to make reasonable changes to the QIP if the QIP failed toaddress the cause of control device problems, or failed to provide adequate procedures for correctingcontrol device problems as expeditiously as practicable.Implementation of a QIP shall not excuse the permittee from compliance with any existing emissionlimit(s) or any existing monitoring, testing, reporting, 01' recordkeeping requirements that may beapplicable to the facility,

(CAM"4) SAVINGS PROVISIONS [WAQSR Ch 7, Sec 3(j)]Nothing in the CAM regulations shail excuse the permittee from compliance with any existing emissionlimit or standard, or any existing monitoring, testing, reporting 01' recordkeeping requirement that may beapplicable to the facility.

(CAM"3)(a)

(CAM"2)(a)

Permit No. 3"2-094"1

WAQSR CHAPTER 5, SECTION 3 NATIONAL EMISSION STANDARDS FQR HAZARDOUS AIRPOLLUTANTS (NESHAPs) AND 40 CFR 63 SUBPART JJJJJJ REQUIREMENTS FOR INDUSTRIAL,

COMMERCIAL, AND INSTITUTIONAL BOILERS AREA SQURCES(modified August 16, 2013)

SUBPART JJJJJJ REQUIREMENTS [40 CFR 63 Subparts A aud JJJJJJ; and WAQSR Ch 5, Sec 3JThe permittee shall meet all applicable requirements of 40 CFR 63 Subparts A and JJJJJJ and WAQSR,Chapter 5, Section 3 as they apply to any existing, new, or reconstructed industrial, commercial, andinstitutional boiler as identified in §63.11194 (with the exceptions defined in §63.11195), within asubcategory (coal, biomass, oil), as listed iu §63.11200 and defined in §63.11237, located at an areasource. Affected sources at this facility include the Stirling Coal Fired Boilers #3-#6 (uuit 004).

Subpart is available at http://www.gpoaccess.gov/cfr/retrieve.html. or from the Division upon request.

remit No. 3-2-094-1

COMPLIANCECERTIFICATION AN)) SCHEDULE(modified August Iti, 2013)

Compliance Certification [WAQSR Ch 6, Sec 3(h)(iii)(E)]

(Cl) (a) The permittee shall submit by July 31 ~a~h y~ar a certification addressing compliance with therequirements ofthis permit. The c~rtification shall be submitted as a stand-alone document separatefrom anymonitoring reports required U1)derthis permit.

(b) (1) F?r the sulfur dioxide emisslom. inventory, the permittee shall assess compliance withcondition FI o[tqis permit by reviewing ~ecords kept in accordance with condition Fl5 andverifying reports were submitted In accordance with condition F19.

(ii) For the fugitive dust control requirements, the permittee shall access compliance withconditions F2 of this permit by conducting the monitoring required by condition Fll(t) andreviewing the records kept in acc0l'dance with condition F 17(b).

. (iii) For visible emissions from the gas-flied Cleaver Brooks Summer Boiler (unit 001), the #1Union Boiler (unit 002), the #2 Union Boiler (unit 003) and the space heaters, the permitteeshall assess compliance with condition F3 of this permit by verifying natural gas was the salefuel source used as specified in condition FIl(a), except during operation under thealternative operating scenario.

(iv) For visible emissions from the Stirling Coal Fired Boilers #3-#6 (unit 004) and the sourceslisted in condition F6 of this permit, the permittee shan assess compliance with condition F3of this permit by conducting the monitoring required by condition FIl(h), (c), and (e).

(v) For SO, emission and coal sulfur content limitations for the Stirling Coal Fired Boilers #3-#6(unit 004), the permittee shan assess compliance with condition F4(a), (h), and (c) of thispermit hy conducting the monitoring required by condition F13.

(vi) For NOx emissions from the Stirling Coal Fired Boilers #3-#6 (unit 004), the permittee shallassess compliance with condition F4(a) and (b) of this permit by conducting the testingrequired by condition F9(a), and the monitoring reqnired by F12.

(vii) For particulate emissions from the Stirling Coal Fired Boilers #3-#6 (unit 004), the permitteeshall assess compliance with condition F4(a) and (b) of this permit by conducting the testingrequired by condition F9(a) and conducting the monitoring required by condition F12.

(viii) For the ash handling requirements, the permittee shall assess compliance with condition F5 ofthis permit by conducting the monitoring required by condition F11(g) and (h) and reviewingthe records kept in accordance with condition FI7(c) and (d).

(ix) For particulate matter emissions from the sources listed in Table III, the permittee shall assesscompliance with condition F6 of this permit by conducting the testing required by conditionF9(b) and conducting the monitoring required by conditions Fll(c), (d), and (e).

(x) For maintenance performed on the silo and silo vent baghouses and bin vent filters (units 074,075, 076, 077, 078, 079, and 080), the permittee shan assess compliance with condition F8 ofthe permit by reviewing the records kept in accordance with condition F17(a).

(xi) For the Pellet Mills operating honrs, the permittee shall assess compliance with condition F7of this permit by reviewing records kept in accordance with condition FI6(e).

(xii) For the #1 Union Boiler tuhes repair project, the permittee shall assess compliance withcondition F25 hy conducting the testing and monitoring reqnired hy condition F26 andreviewing the records required by condition F27.

(xlii) For the alternative operating scenario, the permittee shall assess compliance with conditionA I of this permit by reviewing records maintained in accordance with condition A3 and, ifnecessary, by conducting the testing required by condition A2.

(xiv) For greenhonse gas reporting, the permittee shall assess compliance with condition F23by verifying that reports were submitted in accordance with condition F23(b).

(xv) For the Stirling Coal Fired Boilers #3-#6, the permittee shan assess compliance with Part 63SUbpart JJJJJJ by conducting any applicable testiug and monitoring required by§§63.11210 through 63.11224 and by reviewing the records reqnired by §63.11225.

(c) The compliance certification shall include:(i) The permit condition or applicahle requirement that is the hasis of the certification;(ii) The cnrrent compliance statns;


(iii) Whether compliance was continuous or intermittent; and(iv) The methods used for determining compliance.

(d) For any permit conditions or applicable requirements for which the source is not in compliance, thepermittee shall submit with the compliance certification a proposed compliance plan and schedulefor Division approval.

(e) The compliance certification shall be submitted to the Division in accordance with condition 04 ofthis permit and to the Assistant Regional Administrator, Office of Enforcement, Compliance, andEnvironmental Justice (8ENF-T), U.S. EPA - Region VIII, 1595 Wynkoop Street, Denver, CO 802021129.

(f) Determinations of compliance or violations of this permit are not restricted to the monitoringrequirements listed in paragraph (b) of this condition; other credible evidence may be used.

Compliance Schedule [WAQSR Ch 6, Sec 3(h)(iii)(C) and (D)]

(C2) The permittee shall continue to comply with the applicable requirements with which the permittee hascertified that it is already in compliance.

(C3) The permittee shall comply in a timely manner with applicable requirements that become effective duringthe term of this permit.


GENERAL PERMIT CONDITIONS

Powers of the Administrator: [W.S. 35-1 H 10]

(GI) (a) The Administrator may require the owner or operator of any point source to complete plans andspecifications for any application for a permit required by the Wyoming Environmental Quality Actor re9ul~tions .made pursuant thereto and require the submission of such reports regarding actual orpotential viclations of the Wyoming Enviroruriental Quality Act or regulations thereunder.

(b) The Administrator may require the owner Or operator of any point source to establish and maintainrecords; make reports; install, use and maintain monitoring equipment or methods; sampleemissions, or provide such other information as may be reasonably required and specified.

Permit Renewal and Expiration: [WAQSR Ch 6, Sec 3(c)(i)(C), (d)(il), (d)(iv)(B), and (h)(i)(B)] [W.S. 35-11206(fj]

(G2) This permit is issued for a fixed term of five years. Permit expiration terminates the permittee's right tooperate unless a timely and complete renewal application is submitted at least six months prior to the dateof permit expiration. If the permittee submits a timely and complete application for renewal, thepermittee's failure to have an operating permit is not a violation of WAQSR Chapter 6, Section 3 until theDivision takes final action on the renewal application. This protection shall cease to apply after acompleteness determination if the applicant fails to submit by the deadline specified in writing by theDivision any additional information identified as being needed to process the application.

Duty to Supplement: [WAQSR Ch 6, Sec 3(c)(ili)]

(G3) The permittee, upon becoming aware that any relevant facts were omitted or incorrect information wassubmitted in the permit application, shall promptly submit such supplementary facts or correctedinformation. The permittee shall also provide additional information as necessary to address anyrequirements that become applicable to the facility after this permit is issued.

Submissions: [WAQSR Ch 6, Sec 3(c)(iv)] [W.S. 35-11-206(c)]

(G4) Any document submitted shall be certified as being true, accurate, and complete by a responsible official.(a) Submissions to the Division.

(i) Any submissions to the Division including reports, certifications, and emission inventoriesrequired under this permit shall be submitted as separate, stand-alone documents and shall besentto:

Administrator, Air Quality Division122 West 25th StreetCheyenne, Wyoming 82002

(ii) Unless otherwise noted elsewhere in this permit, a copy of each submission to theAdministrator under paragraph (a)(i) of this condition shall be sent to the DEQ Air QualityContact listed on page 3 of this permit.

(b) Submissions to EPA.(i) Each certification required under condition Cl ofthis permit shall also be sent to:

Assistant Regional AdministratorOffice of Enforcement, Compliance, and Environmental Justice (8ENF-T)U.S. EPA - Region VIII1595 Wynkoop StreetDenver, CO 80202-1129.

(ii) All other required submissions to EPA shall be sent to:Office of Partnerships and Regulatory AssistanceAir and Radiation Program (8P"AR)U.S. EPA - Region VIII1595 Wynkoop StreetDenver, CO 80202-1129


Changes for Which No Permit Revision Is Required: [WAQSR Ch 6, Sec 3(d)(iii)]

(05) The permittee may change operations without a permit revision provided that:(a) The change is not a modification under any provision oftitle I of the Clean Air Act;(b) The change has met the requirements of Chapter 6, Section 2 of the WAQSR and is not a

modification under Chapter 5, Section 2 or Chapter 6, Section 4 of tbe WAQSR and the changes donot exceed the emissions allowed under the permit (whether expressed therein as a rate of emissionsorin terms of total emissions); and

(c) The permittee provides EPA and the Division with written notification at least 14 days in advance ofthe proposed change. The permittee, EPA, and the Division shall attach such notice to their copy ofthe relevant permit. For each such change, the written notification required shall include a briefdescription of the change within the permitted facility, the date on which the change will occur, anychange in emissions, and any permit term or condition that is no longer applicable as a result of thechange. The permit shield, if one exists for this permit, shall not apply to any such change made.

Transfer of Ownership or Operation: [WAQSR Ch 6, Sec 3(d)(v)(A)(IV)]

(06) A change in owuership or operationai control of this facility is treated as an administrative permitamendment if no other change in this permit is necessary and provided that a written agreement containinga specific date for transfer of permit responsibility, coverage, and iiability between the current and newpermittee has been submitted to the Division.

Reopening for Cause: [WAQSR Ch 6, Sec 3(d)(vii)] [W.S. 35-11-206(I)(ii) and (Iv)]

(07) The Division will reopen and revise this permit as necessary to remedy deficiencies in the followingcircumstances:(a) Additional applicable requirements under the Clean Air Act or the WAQSR that become applicable

to this source if the remaining permit term is three or more years. Such reopening shall becompleted not later than 18 months after promulgation ofthe applicable requirement. No reopeningis required if the effective date of the requirement is later than the date on which the permit is due toexpire, unless the original permit or any of its terms and conditions have been extended.

(b) Additional requirements (including excess emissions requirements) become applicable to an affectedsource under the acid rain program. Upon approval by EPA, excess emissions offset plans shall bedeemed to be incorporated into the permit,

(c) The Division or EPA determines that the permit contains a material mistake or that inaccuratestatements were made in establishing the emissions standards or other terms or conditions of thepermit.

(d) The Division or EPA determines that the permit must be revised or revoked to assure compliancewith applicable requirements.

Annual Fee Payment: [WAQSR Ch 6, Sec 3(f)(i), (ii), and (vi)] [W.S. 35-11-211]

(08) The permittee shall, as a condition of continued operations, submit an annual fee to the Division asestablished in Chapter 6, Section 3 (f) of the WAQSR. The Division shall give written notice of theamount of fee to be assessed and the basis for such fee assessment annually. The assessed fee is dne onreceipt of the notice unless the fee assessment is appealed pursuant to W.S. 35-11-211 (d), 1f any part of thefee assessment is not appealed it shall be paid to the Division on receipt of the written notice. Anyremaining fee which may be due after completion of the appeal is immediately due and payable uponissuance of the Council's decision. Failure to pay fees owed the Division is a violation of Chapter 6,Section 3 (I) and W.S, 35-11-203 and may be cause for the revocation of this permit.

Annuai Emissions Inventories: [WAQSR Ch 6, Sec 3(£)(v)(0)]

(09) The permittee shall submit an annuai emission inventory for this facility to the Division for fee assessmentand compliance determinations within 60 days following the end of the calendar year. The emissionsinventory shall be in a format specified by the Division.


Severability Clause: [WAQSR Ch 6, Sec 3(h)(i)(E)]

(G I0) The provisions of this permit are severable, and if any provision of this permit, or the application of anyprovision of this permit to any circumstance, is held invalid, the application of such provision to othercircumstances, and the remainder of this permit, shall not be affected thereby.

Compliance: [WAQSR Ch 6, Sec 3(h)(I)(f)(I) and (II)] [W.S. 35-11-203(b)]

(GIl) The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes aviolation ofthe Clean Air Act, Article 2 of the Wyoming Environmental Quality Act, and the WAQSR and isgrounds for enforcement action; for permit termination, revocation and reissuance, or modification; or fordenial of a permit renewal application. It shall not be a defense for a permittee in an enforcement action that itwould have been necessary to halt or reduce the permitted activity in order to maintain compliance with theconditions ofthis permit.

Permit Actions: [WAQSR Ch 6,Sec 3(h)(i)(F)(IIl)] [W.S. 35-11-206(1)]

(G12) This permit may he modified, revoked, reopened, and reissued, or terminated for cause. The filing of arequest by the permittee for a permit modification, revocation. and reissuance, or termination, or of anotification of planned changes or anticipated noncompliance does not stay any permit condition.

Property Rights: [WAQSR Ch 6, Sec 3(h)(I)(F)(lV)]

(G13) This permit does not convey any property rights of any sort, or any exclnsive privilege.

Duty to Provide Information: [WAQSR Ch 6, Sec 3(h)(I)(F)(V)]

(G14) The permittee shall furnish to the Division, within a reasonahle time, any information that the Division mayrequest in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating thepermit or to determine compliance with the permit, Upon request, the permittee shall also furnish to theDivision copies of records required to be kept by the permit, including information claimed and shown to beconfidential under W.S. 35-11-1101 (a) of the Wyoming Environmental Quality Act. Upon request by theDivision, the permittee shall also furnish confidential information directly to EPA along with a claim ofconfidentiality.

Emissions Trading: [WAQSR Ch 6, Sec 3(h)(i)(H)]

(G15) No permit revision is required, under any approved economic incentives, marketable permits, emissionstrading and other similar programs or processes for changes that are provided for in this permit.

Inspection and Entry: [WAQSR Ch 6, Sec 3(h)(iii)(B)] [W.S. 35-11-206(c)]

(G16) Authorized representatives of the Division, upon presentation of credentials and other documents as may berequired by law, shall be given permission to:(a) enter upon the permittee's premises where a source is located or emissions related activity is

conducted, 01' where records must be kept under the conditions of this permit;(b) have access to and copy at reasonable times any records that must be kept under the conditions of this

permit;(c) inspect at reasonable times any facilities, equipment (including monitoring and air pollution control

equipment), practices, or operations regulated or required under this permit;(d) sample or monitor any substances or parameters at any location, during operating hours, for the

purpose of assuring compliance with this permit or applicable requirements.

Excess Emissions Due to an Emergency: [WAQSR Ch 6, Sec 3(1)]

(G17) The permittee may seek to establish that noncompliance with a technology-based emission limitation underthis permit was due to an emergency, as defined in Ch 6, Sec 3(1)(1) of the WAQSR. To do so, thepermittee shall demonstrate the affirmative defense of emergency through properly signed,contemporaneous operating logs, orotherrelevant evidencethat:(a) an emergency occurred and that the permittee can identify the cause(s) of the emergency;(b) the permitted facility was, at the time, being properly operated;(c) during the period of the emergency the permittee took all reasonable steps to minimize levels of

emissions that exceeded the emissions standards, or other requirements in this penn it;


(d) The permittee submitted notice of the emergency to the Division within one working day of the timewhen emission limitations were exceeded due to the emergency, This notice must contain adescription ofthe emergency, any steps taken to mitigate emissions, and corrective actions taken.

Diluting and Conceaiing Emissions: [WAQSR Ch I, Sec 4]

(018) No person shali cause or permit the instaliation or use of any device, contrivance, or operational schedulewhich, without resulting in reduction of the total amount of air contaminant released to the atmosphere,shali dilute or conceal an emission from a source. This condition shali not apply to the control of odors.

Unavoidable Equipment Malfunction: [WAQSR Ch I, Sec 5]

(019) (a) Any source beiieving that any emissions in excess of estabiished regulation iimits or standardsresulted from an unavoidable equipment malfunction, shali notify the Division within 24 hours ofthe incident via telephone, electronic mail, fax, or other similar method. A detailed description ofthe circumstances of the incident as described in paragraph 5(a)(i)(A) Chapter I, including acorrective program directed at preventing future such incidents, must be submitted within 14 days ofthe onset of the incident. The Administrator may extend this 14-day time period for cause.

(b) The burden of proof is on the owner or operator of the source to provide sufficient information todemonstrate that an unavoidable equipment malfunction occurred.

Fugitive Dust: [WAQSR Ch 3, Sec 2(1)]

(020) The permittee shali minimize fugitive dust in compliance with standards in Ch 3, Sec 2(1) ofWAQSR forconstruction/demolition activities, handiing and transportation of materials, and agricultural practices.

Carbon Monoxide: [WAQSR Ch 3, Sec 5]

(021) The emission of carbon monoxide in stack gases from any stationary source shall be limited as may benecessary to prevent ambient standards from being exceeded.

Asbestos: [WAQSR Ch 3, Sec 8]

(022) The permittee shali compiy with emission standards for asbestos during abatement, demoiition, renovation,manufacturing, spraying and fabricating activities.(a) No owner or operator shall build, erect, install, or use any article, machine, equipment, process, or

method, the use of which conceals an emission which would otherwise constitute a violation of anapplicable standard. Such concealment includes, but is not iimited to, the use of gaseous dilutants toachieve compliance with a visible emissions standard, and the piecemeal carrying out of anoperation to avoid coverage bya standard that appiies only to operations larger than a specified size.

(b) Ali owners and operators conducting an asbestos abatement project, including an abatement projecton a residential building, shall be responsible for complying with Federal requirements and Statestandards for packaging, transportation, and delivery to an approved waste disposal facility asprovided in paragraph (m) ofCh 3, Scc 8.

(c) The permittee shali follow State and Federal standards for any demolition and renovation activitiesconducted at this faciiity, including:(i) A thorough inspection of the affected facility or part of the facility where the demoiition or

renovation activity will occur shall be conducted to determine the presence of asbestos,including Category I and Category 1I non-friable asbestos containing material. The results ofthe inspection will determine which notification and asbestos abatement procedures areapplicable to the activity.

(ii) The owner or operator shall follow the appropriate notification requirements of Ch 3, Sec8(i)(ii).

(iii) The owner or operator shall follow the appropriate procedures for asbestos emissions control,as specified in Chapter 3, Section 8(i)(iii).

(d) No owner or operator of a facility may install 01' reinstall on a facility component any insulatingmaterials that contain commercial asbestos if the materials are either molded and friable or wetapplied and friable after drying. The provisions of this paragraph do not apply to spray-appliedinsulating materials regulated under paragraph U) ofCh 3, Sec 8.

(e) The permittee shall comply with all other reqnirements ofWAQSR Ch 3, Sec 8.


OpenBurningRestrictions: [WAQSRCh 10, Sec2]

(G23) The permittee conducting an open burn shall comply witb all rules and regulations of the WyomingDepartment of Environmental Quality, Division of Air Quality, and with the Wyoming EnvironmentalQualityAct.(a) No person shall burn prohibited materials using an open burning method, except as may be

authorized by permit. "Prohlbited materials" means substances including, but not limited to;natural or s~nthetiGrubber products, including tires; waste petroleum products, such as 011 or used011 filters; insulated wire; plastic products, including polyvinyl chloride ("PVC") pipe, tubing andconnectors; tar, asphalt, asphalt shingles, or tar paper; railroad ties; wood, wood waste, or lumberthat is painted orchemically treated; explosives or ammunition; batteries; hazardous waste products;asbestos .or asbestos containing materials; or materials which cause dense smoke discharges,excluding refuse and flaring associated with 011 and gas well testing, completions and wellworkovers, ,

(b) No person or organization shall conduct or cause or permit open burning for the disposal of tradewastes, fora salvageoperation, for the destruction of fire hazards if so designated by a jurisdictionalfire authority, or for firefighting training, except when it can be shown by a person or organizationthat such open burning is absolutely necessary and in the public interest. Anyperson or organizationintending to engage in such open burning shall file a requestto do So with the Division.

SulfurDioxide Emission Trading and Inventory Program [WAQSR Ch 14]

(G24) Any BART(Best Available RetrofitTechnology) eligible facility, or facilitywhich has actual emissions ofS02 greater than 100 tpy in calendar year 2000 or'any subsequent year, shall comply with the applicablerequirements of WAQSR Ch 14, Sections I through 3, with the exceptions described in sections2(c) and3(a).

Stratospheric OzoneProtectionRequirements: [40 CFRPart 82]

(G25) The permittee shall complywith all applicable Stratospheric OzoneProtection Requirements, including butnot limitedto:(a) Standardsfor Appliances [40CFR Part 82, SubpartF)

The permittee shall comply with the standards for recycling and emission reduction pursuant to 40CFR Part 82, SUbpart F - Recycling and Emissions Reduction, except as provided for motor vebicleair conditioners (MVACs) in SubpartB:(I) Personsopeningappliances for maintenance, service,repair, or disposal must comply with the

required practices pursuantto §82.156.(ii) Equipment used during the maintenance, service, repair, or disposal of appliances must

complywith the standards for recycling and recovery equipmentpursuant to §82.158.(iii) Persons performingmaintenance, service, repair, or disposal of appliances must be certified

by an approvedteehnician certification programpnrsuantto §82.161.(iv) Persons disposing of small appliances, MVACs, and MVAC-llke appliances must comply

with record keepingrequirements pursuant to §82.l66. ("MYAC-like appliance" is defined at§82.152).

(v) Persons owning commercial or industrial process refrigeration equipment must comply withthe leak repair requirements pursuant to §82.166.

(vi) Owners/operators of appliances normally containing 50 or more pounds of refrigerant mustkeep recordsof refrigerant purchased and added to such appliances pursuant to §82.166.

(vii) The permittee shallcomplywith all other requirements of SubpartF.(b) Standards for Motor Vehicle Air Conditioners [40 CFRPart 82, SubpartB]

If the permittee performs a service on motor (fieet) vehicles when this service involves ozonedepleting substance refrigerant in the MVAC, the permittee is subject to all the applicablerequirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle AirConditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in whichfinal assemblyof the vehicle has not been completed. The term "MVAC" as used in SubpartB doesnot includethe air-tightsealed refrigeration system used as refrigerated cargo, or the system used onpassenger buses usingHCFC-22 refrigerant.

PermitNo. 3-2-094-1 Page26

STATE ONLY PERMIT CONDITIONS(modified August 16, 2013)

The conditions listed in this section are State only requirements and are not federally enforceable.

Ambient Standards

(S I) The permittee shall operate the emission units described in this permit such that the following ambientstandards are not exceeded:

.. ., .I·' eEL.' ·'··i'·'!>·........ .......• , ••······.• '>·'··.21'·;,\;.,/;.J

,c~~Qrd,,+ >';'.,'~,l~''l •.. ". ...•;..•"

I

50 micrograms per cubic meter annual arithmetic meanPM" particulate

24-hr average concentration with not more 2 (a)matter 150 micrograms per cubic meter

than one exceedanceper year

PM,., particulate 15micrograms per cubic meter annual arithmetic mean

matter 35 micrograms per cubic meter 98th percentile 24-hr average concentration2 (b)

53 parts per billion annual average concentration

three-year average of the annnal 98th

Nitrogen dioxide 100 parts per hillion percentile of the daily maximum 1-hr 3average concentration

0.053 parts per million annual arithmetic mean

three-year average of the annual (99 th

75 parts per hillion percentile) of the daily max 1-hr

Sulfur dioxide average 4

0.5 parts per million3-hr hlocks not to be exceeded morethan once per calendar year

10 milligrams per cubic metermax 8-hr concentration with not more than

Carbon one exceedance per year

monoxide5

max 1-h1' concentration with not more than40 milligrams per cubic meter

one exceedance per year

three-year average of the annual fourth-Ozone 0.075 parts per million highest daily maximum 8-hr average 6

concentration

70 micrograms per cubic meter1,Iz hour averagenot to be exceededmorethan two times per year

Hydrogen --7sulfide 1,Iz hour average not to be exceeded more

40 micrograms per cubic meter than two times in any five consecutivedays

0.25 milligrams S03 per 100maximum annual average

Suspended square centimeters per day8

suifate 0.50 milligrams S03 per 100square centimeters per day

maximum 30-day value

Lead and its0.15 micrograms pel' cubic meter

maximum arithmetic 3-month mean10

compounds concentration for a 3Myear period


fudrogen Sulfide: [WAQSR Cb 3, Sec 7]

(S2) Any exit process gas stream containing bydrogen sulfide which is discbarged to the atmospbere from anysource shall be vented, incinerated, flared or otherwise disposed of in sucb a manner tbat ambient sulfurdioxide and bydrogen sulfide standards are not exceeded.

Odors: [WAQSR Cb 2, Sec 11]

(S3) (a)

(b)

The ambient air standard for odors from any source sball be limited to an odor emission at tbeproperty line which is undetectable at seven dilutions witb odor free air as determined by ascentometer as manufactured by tbe Barnebey-Cbeney Company or any other instrument, device, ortechnique designated by tbe Division as producing equivalent results. The occurrence of odors sballboo llleasllred so that .at .Ieast two measurements can be made within a period of one bour, tbesedeterminations being separated by at least 15 minutes.Odor producing materials shall be stored, transported, and bandied in a manner that odors producedfrom sucb materials are confined and tbat accumulation of sucb materials resulting from spillage orother escape is prevented.

PennitNo.3-2-094-1

SUMMARY OF SOURCE EMISSION LIMITS AND REQUIREMENTS

Source Description: Cleaver Brooks Summer Boiler - Natural Gas FiredSource ID#: 001 .Pollutant Emissions Limit/Work Corresponding Testing MOIiitQrllg Reco!:~eepiilg Reporting

Practice Standard Regulatioms) Requirements Requirements Requirements Requirements

Particulate 20 percent opacity [F3] WAQSR Ch 3, Sec 2 Testing if required Verification ofnatural gas Record the results ofany Report any test results [F20][FlO] firing [F I !] additional testing [F16]

Report type of fuel fired [F2!]

Report excess emissions andpermit deviations [F24]

NOx 0.20 IbIMMBtu [F4] WAQSR Ch 3, Sec 3; Testing if required None Record the results of any Report any test results [F20]Ch 6, Sec 3 [FlO] additional testing [F!6]

Report excess emissions andpermit deviations [F24].

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain detaileddescriptions of the compliance requirements. Compliance with the summary conditions in these tables may not be sufficient to meet permit requirements. These tables' may notreflect all emission sources at this facility.


Source ID#: 002

Particulate

NOx

20 percent opacity [F3]

O.IOlblMMBtu [AI]

0.20 lblMMBtu [F4]

0.30 IblMMBtu and fuel oilnitrogen content of0.3 percentor less [AI]

Actual emissions, on calendaryear basis, shall not exceed theemission level of 49.2 TPY[F25]

WAQSR Ch 3, Sec 2;Ch6, Sec3

WAQSR Ch 3, Sec 3;Ch 6, Sec 3

WAQSR Ch 6, Sec 2Permit OP-193;Waiver wv-12915

Testing ifrequired[FlO]

Test ifburn oil [A2]


Test if burn oil [A2]

Verification of natural IRecord the results of anygas firing [FII] additional testing [F16]

Alternative operatingscenario records [A3]

Record the results of anyadditional testing [F16]


. Record NOx emissionsMomtor annual NOxI itort [F27]. .. [F26] mom ormgemISSIOns

Report any test results [F20]

Report type of fuel fired [F2I]


Report the results of any tests ifbum oil [A4]

Report any test results [nO]


Report fuel oil nitrogen contentand any tests [A4]

Annual: NOx emissionsmonitoring [F28]

S02 Fuel oil sulfur content of 1.0percent or less [AI]

WAQSR Ch 6, Sec 3

WAQSR Ch 6, Sec 2Permit OP-193


None Record the results of anyadditional testing [FI6]'



Report excess emissions·andpermit deviations [F24]

Report fuel oil sulfur content andany tests [A4]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain detaileddescriptions of the compliance requirements. Compliance with the summary conditions in these tables may not be sufficient to meet permit requirements. These tables may notreflect all emission sources at this facility.


Source 10#: 003 Source Description: #2 Union Boiler - Natural Gas I Fuel Oil Fired(modified August 16, 2013)

Pollutant Emissions Limit/Work Corresponding.

J~stil1gR.equi(el11ent" .• Monitoring Requirements Recordkecping Reporting.RequirementsPractice Standard Regulationis) •••• Requirements . I

Particulate 20 percent opacity [F3] WAQSR Ch 3, Sec 2; Testing if required Verification of natural gas Record the results of any Report any test results [F20]

0.10 lblMMBtu [AI] Ch 6, Sec 3 [FlO] firing [FII] additional testing [FI6] Report type offuel fired [F21]Test if burn oil [A2] Alternative operating Report excess emissions and

scenario records [A3] permit deviations [F24]

Report the results of any tests ifbum oil [A4]

NOx 0.20 lblMMBtu [F4] WAQSRCh 3, Sec 3; Testing if required None Record the results of any Report any test results [F20]

0.30 lblMMBtu and Ch 6, Sec 3 [flO] additional testing [FI6] Report excess emissions andfuel oil nitrogen WAQSR Ch 6, Sec 2 Test ifburn oil [A2] Alternative operating permit deviations [F24]content of 0.3 percent Permit OP-193 scenario records [A3] Report fuel oil nitrogen contentor less [AI] and any tests [A4]

S02 Fuel oil sulfur content WAQSR Ch 6, Sec 3 Testing if required None Record the results of any Report any test results [F20]Iof 1.0 percent or less WAQSR Ch 6, Sec 2 [FlO] additional testing [FI6] Report excess emissions and[AI] Permit OP-193 Alternative operating permit deviations [F24]

scenario records [A3] Report fuel oil sulfur contentand any tests [A4]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain detaileddescriptions ofthe compliance requirements. Compliance with the summary conditions in these tables may not be sufficient to meet permit requirements. These tables may notreflect all emission sources at this facility.


Source 1D#: 004

Particulate 120 percent opacity [F3]

0.10 Ib/MMBtu, 24.6Ib/hr; 35.4 TPY [F4]

Boiler #4 only: 0.10Ib/MMBtu, 62 lb/hr, 8.9TPY [F4]

WAQSR Ch 3, Sec 2WAQSR Ch 6, Sec 2Permit OP-147

WAQSRCh7,Sec3

Test once every Compliance assurance Record test results [F16]five yeats [F9] monitoring [FII and CAM-I Record CAM results [F16]Testing if required to CAM-4] Record monitoring data and[FlO] Monitor steam output, coal calculations [FI8]

consumption, Btu content ofcoal, and total year-to-dateparticulate emissions [F12]

Report test results [F20]Report CAM, exceedences, andtotal annnal particulate emissions[F21]

Reportexcess emissions andpermit deviations [F24]

Reportexceedances ofcoalsulfer content limit, and totalannual SO, emissions [F21]


Report test results [F20]Report exceedences and totalannllalNOx emissions [F21]

Report excess emissions andpermit deviatiOns [F24]

Record monitoring data andcalculations [FI8]

Record monitoring data andcalculations [F18]

Testing ifrequiredIMonitor coal consumption,[FlO] coal .sulfur content,

operating data, and totalyear-to-date SO, emissions[FI3]

Test once every Monitor steam output, coal -.1Record test results [F16]five years [F9] consumption, Btu content ofTesting if required coal,and total year-to-date[FlO] NOx emissions [F 12]

WAQSR Ch 6, Sec2Permit MD-7227

WAQSRCh3, Sec3;Ch 6, Sec 3

WAQSR Ch 6, Sec 2Permit OP-147 andMD-7227

S02 ICoal limited to 0.54% byweight sulfur content (asdelivered) [F4]

264 lb/hr and 357 TPY[F4]

Boiler #4 only: 66.0lb/hr, 72.0 TPY [F4]

NOx 10.70 Ib/MMBtu, 1722Iblhr, 248 TPY [F4]Boiler #4 only: 0.7Ib/MMBtu, 43.1 Ib/hr,62.0 TPY [F4]

CO IBoiler #4 only: 23.0Ib/hr, 33.2 TPY [F4]

WAQSR Ch 6, Sec 2Penni! MD-7227

Testing if required INone[FlO]

Record the results of anyadditional testing[F16]

Report test results [F20]


HAPs WAQSR Ch 5, Sec 3 and 40 CFR 63 Subparts A and JJJJJJ


PennitNo.3-2-094-1

Source Description: Pulp Dryer - Natural Gas 1Fuel Oil Fireddified Auzust 16. 2013)

Source ID#: 005/006,--

Pollutant Emissions LimitJWork Corresponding Testing l>1ol1itlJri+tg Recordkeeping Reporting Requirements.-

Practice Standard Regnlationfs) Requirements ReCjl'\ire111en l$ Requirements :

Particulate 20 percent opacity [F3] WAQSRCh3,Sec Test once every Method 9 observations Record test results [FI6] Report test results [F20]

31.2 Iblhr [F6] [AI] 2; Ch 7, Sec 3 five years [F9] twice each campaign Record CAM results [F16] Report type of fuel fired [F21]Test if burn oil period [F II] Record visible emissions Report visible emissions monitoring[A2] Compliance Assurance monitoring results [F16] and CAM results [F21]

Monitoring [FII and Alternative operating Report excess emissions and permitCAM-I to CAM-4] scenario records [A3] deviations [F24]

Report hours, oil used, and the resultsof any tests ifburn oil [A4]

NOx Fuel oil nitrogen WAQSRCh3,Sec3; Testing if required None Record the results of any Report test results [F20]content of 0.3 percent Ch 6, Sec 3 [FlO] additional testing [FI6] Report excess emissions and penni!or less [AI] WAQSR Ch 6, Sec 2 Alternative operating deviations [F24]

Permit OP-193 scenario records [A3] Report fuel oil nitrogen content, hours,and any tests [A4]

S02 Fuel oil sulfur content WAQSR Ch 6, Sec3 Testing if required None Record the results of any Report test results [F20]of 1.0 percent or less WAQSR Ch 6, Sec 2 [FlO] additional testing [F16] Report excess emissions and pe:nnit[AI] Permit OP-193 Alternative operating deviations [F24]

scenario records [A3] Report fuel oil sulfur content, hours,and any tests [A4]



Source ID#: 020 Source Description: Pellet Cooler

Particulate [20 percent opacity [F3]

23.0 Iblhr particulate [F6]

Operation ofonly twofan/cooler/pellet millcombinations at anyonetime [F7]

WAQSR Ch 3, Sec 2;Ch 6, Sec 3

WAQSR Ch 6, Sec 2Waiver AP-3435

Testing ifrequired [FlO]IWeekly visibleemissions observations[Fll]

Monitor hours ofoperation [F14]

Record visible emissionsmonitoring results and anyadditional testing [F16J

Record unit operating hours[F16]


Report visible emissionsmonitoring [F21]

Report deviations [F22]

Report excess emissionsandpermit deviations [F24J

Report test results [F20J

Report excess emissionsandpermit deviations [F24]

Report visible emissionsmonitoring and CAM results[F21]Record visible emissions

monitoring results [F16J

Record CAM results [F16]

Record test results [F16]

Compliance AssuranceMonitoring [Fll andCAM-I to CAM-4]

Method 9 observationstwice each campaign

. [period [FII]Testing if required [FIOJ

Test once every fiveyears [F9]

WAQSRCh3,Sec2;Ch 7,Sec 3

21.0 lb/hr particulate [F6]

Particulate [40 percent opacity [F3]



CooldStFSlaker ExhCoal Hand!"latGDsID#: 052. 054. 057 and 090s- - ---- -- ------ - --~--.r-- -_. -------------, --07 ----- - - --~ ---- - -- --- - - ----

Pollutant Emissions Limit I Work Corresponding , Testing Monitoring Rec&OReeping ReportingPractice Standard Regulation/s) Requirements Requirements Requirements Requirements

Particulate 20 percent opacity [F3] WAQSR Ch 3, Sec 2; Testing if required [FlO] Weekly visible Record the results of any Report any test results [F20]Ch 6, Sec 3 emissionsobservations additional testing [FI6]

Unit 090 only [FIl] Report visible emissions40 percent opacity [F3] WAQSR Ch 6, Sec 2 Record visible emissions monitoring [F21]

Permit OP-147 and monitoring results [FI6]Particulate limits: Waiver AP-409 Report excess emissions andSee Table III [F6] permit deviations [F24]

d 12/2 & Industrial Powdered SSource ID#: 069, 070 and 071

d Powdered Suaar Packazinz FacilityBlated PackGDs - --- r - -_. - , 0 =" - -- ---- ---~

u , ---- - --Pollutant Emissions Lirrritl Work Corresponding """i FlesOOg ~?~itbrin~, Reoordk:"~l>ing .' """"""" •• '1'" "PracticeStmdard Regulationis) " ,

'" R~uirements Rf)quir=ents ,,'.,

Particulate 20 percent opacity [F3] WAQSR Ch 3, Sec 2; Testing if required [Fl O] Compliance Assurance Record the results ofany Report any test results [F20]Ch 7, Sec3 Monitoring [Fl I and additional testing [FI6]

Particulate limits: CAM-l to CAM-4] Report CAM results [F21]See Table III [F6] WAQSR Ch 6, Sec 2 Record CAM results [F16]

Waiver AP-4516 Report excess emissions andpermit deviations [F24]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets, contain, detaileddescriptions of the compliance requirements. Compliance with the summary conditions in these tables may not be sufficient to meet permit requirements. These tables may notreflect all emission sources at this facility.


Source ID#: 074, 075, 076, 077, 078, 079 and 08{)Source Description: #1 Silo Vent, #2 Silo Vent, #3 Silo Vent, #4 Silo Vent, #1-#4 Silo, #5 Silo Vent and #6 Silo Vent

Report visible emissionsRecord CAM results [F16] [monitoring [F21]

Particulate 20 percent opacity [F3]

Units 079 and 080 only5 percent opacity [F3]

Particulate limits:See Table III [F6]

Conductmaintenance[F8]

WAQSR Ch 3, Sec 2;Ch6, Sec3

WAQSR Ch 6, Sec 2Permits MD-252 andMD-296


Units 074, 075, 076, 077and 078Compliarrce AssuranceMonitoring [F11 andCAM-I to CAM-4]

Units 079 and 080Weekly visible emissionsobservations [Fll]

Record the results of anyadditional testing [F16]


Particulate 120 percent opacity [F3] IWAQSR Ch 3, Sec 2;Ch 6, Sec 3

Testing ifrequired [F7] [Verification ofnatnral IRecord the results of anygas firing [FII] additional testing [FI6]


Report type offuel fired [F21]


NO x 0.20 Ib/MMBtu [F2] WAQSRCh3,Sec3 Testing if required [F7] [None Record the results of anyadditional testing [FI6]




Source ID#: ASA and Coal area Source Description: Ash Staging Area and Coal HandlinglRehandling

Pollutant Emissions Limit f Work Corresponding Testing 'NIUlrit~riI1g Recordkeeping ReportingPracticeStandard Regulatiou(s) Requirements Requirements: Requirements . Requirements i

Particulate 20 percent opacity [F3] WAQSR Ch3, Sec 2 Testing if required [FlO] Monitor the application Record the results of any Report any test results [F20]

WAQSR Ch 6, Sec 2 ofdust suppressants additional testing [FI6]

Coal handling and Permit OP-147 and used to control fugitive Report deviations from ash

rehandling shall be Waiver AP-2867 dust emissions during Record application of dust handling requirements [F22]

controlled with water or coal handling and suppressants, and log ash

chemical dust rehandling [Fll] inspections [F17] Report excess emissions and

suppressants [F2] permit deviations [F24]

Inspect the anti-

The dustless flyash silo freezeup measures

unloading system shall be prior to the startup of

equipped with sufficient each campaigu [FIl]

anti-freezeup measures[F5(a)] Inspect ash staging

area before each

Ash handling in the ashcampaign and weekly

staging area shall meet thereafter [F 11]

requirements in [F5(b)]

These tables are intended only to highlight and summarize applicable requirements for each source. The corresponding permit conditions, listed in brackets. contain detaileddescriptions of the compliance requirements. Compliance with the summary conditions in these tables may not be sufficient to meet permit requirements. These tables 'may notreflect all emission sources at this facility.


ACFMAQDBACTBtuCAACAMC.F.R.CO'FDEQEPAESPg/hp-hrgalgrH2S

HAP(s)hphrIbMMACTmfrmgMMMVACsN/ANMHC(s)NOxO2

OPPPM

PM"ppmvppmwQIPSCFSCFDSCMSICSO,SO,saxTBDTPDTPHTPYU.S.C.~g

VOC(s)W,S.WAQSR

ABBREVIATIONS

Actual cubic feet per minuteAir Quality DivisionBest available control technology (see Definitions)Britisb Thermal UnitClean Air ActCompliance Assurance MonitoringCode of Federal RegulationsCarbon monoxideDegrees FahrenheitWyoming Department of Environmental QualityUnited States Environmental Protection Agency (see Definitions)Electrostatic PrecipitatorGram(s) per horsepower hourGallon(s)Grain(s)Hydrogen sulfideHazardous air pollutant(s)HorsepowerHour(s)Pound(s)ThousandMaximum availahle control techuology (see Definitions)ManufacturerMil\igram(s)Mil\ionMotor vehicle air conditionersNot applicableNon-methane hydrocarbon(s)Oxides of nitrogenOxygenOperating Permit ProgramParticulate matterParticulate matter less than or equal to a nominal diameter of 10 micrometersParts per mil\ion (by volume)Parts per million (by weight)Quality Improvement PlanStandard cubic foot (feet)Standard cubic foot (feet) per dayStandard cubic meter(s)Standard Industrial ClassificationSulfur dioxideSulfur trioxideOxides of sulfurTo be determinedTon(s) per dayTon(s) per hourTons per yearUnited States CodeMicrogram(s)Volatile organic compound(s)Wyoming StatuteWyoming Air Quality Standards & Regulations (see Definitions)


DEFINITIONS

"Act" means the Clean Air Act, as amended, 42 U.S.C. 7401, et seq.

"Administrator" means Administrator of the Air Quality Division, Wyoming Department of EnvironmentalQuality.

"Applicable requirement" means all of the following as they apply to emissions units at a source subject to Chapter6, Section 3 of the WAQSR (including requirements with future effective compliance dates that have beenpromulgated or approved by the EPA or the State through rulemaking at the time of issuance of the operatingpermIt):

(a) Any standard or other requirement provided for in the Wyoming implementation plan approved orpromulgated by EPA under title I of the Act that implements the relevant requirements of the Act,including any revisions to the plan promulgated in 40 C.F.R. Part 52;

(b) Any standards or requirements in the WAQSR which are not a part of the approved Wyomingimplementation plan and are not federally enforceable;

(c) Any term or condition of any preconstruction permits issued pursuant to regulations approved orpromulgated through rulemaking under title I, including parts C or D of the Act and including Chapter 5,Section 2 and Chapter 6, Sections 2 and 4 of the WAQSR;

(d) Any standard or other requirement promulgated under Section III of the Act, including Section III (d) andChapter 5, Section 2 of the WAQSR;

(e) Any standard or other requirement under Section 112 of the Act, including any requirement concerningaccident prevention under Section 112(r)(7) of the Act and including any regulations promulgated by EPAand the State pursuant to Section liZ of the Act;

(I) Any standard or other requirement of the acid rain program under title IV of the Act or the regulationspromulgated thereunder;

(g) Any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Act concerningenhanced monitoring and compliance certifications;

(h) Any standard or other requirement governing solid waste incineration, under Section 129 of the Act;

(I) Any standard or other requirement for consumer and commercial products, under Section 183(e) of the Act(having to do with the release of volatile organic compounds under ozone control requirements);

Ul Any standard or other requirement of the regulations promulgated to protect stratospheric ozone under titleVI of the Act, unless the EPA has determined that such requirements need not be contained in a title Vpermit;

(k) Any national ambient air quality standard or increment or visibility requirement under part C of title I ofthe Act, but only as it would apply to temporary sources permitted pursuant to Section 504(e) of the Act;and

(I) Any state ambient air quality standard or increment or visibility requirement of the WAQSR.

(m) Nothing under paragraphs (A) through (L) above shall be construed as affecting the allowance program andPhase II compliance schedule under the acid rain provision of Title IV of the Act.

"BACT" or "Best available control technology" means an emission limitation (including a visible emissionstandard) based on the maximum degree of reduction of each pollutant subject to regulation under the WAQSR orregulation under the Federal Clean Air Act, which would be emitted tram or which results for any proposed majoremitting facility or major modification which the Administrator, on a case-by-case basis, taking into account energy,environmental, and economic impacts and other costs) determines is achievable for such source or modificationthrough application or production processes and available methods, systems, and techniques, including fuel cleaningor treatment or innovative fuel combustion techniques for control of such pollutant. If the Administrator determinesthat technological or economic limitations on the application of measurement methodology to a particular class ofsources would make the imposition of an emission standard infeasible) he may instead prescribe a design)


equipment, work practice or operational standard or combination tbereof to satisfy the requirement of Best AvailableControl Technology. Such standard shall, to the degree possible, set forth the emission reduction achievable byimplementation of such design, equipment, work practice, or operation and shall provide for compliance by meanswhich achieve equivalent results. Application of BACT shall not result in emissions in excess of those allowedunder Chapter 5, Section 2 of the WAQSR and any other new source performance standard or national emissionstandards for hazardous air pollutants promulgated by EPA but not yet adopted by the state.

"Department" means the Wyoming Department of Environmental Quality or its Director.

"Director" means the Director of the Wyoming Department of Environmental Quality.

"Division" means the Air Quality Division of the Wyoming Department of Environmental Quality or itsAdministrator.

"Emergency" means any situation arisingfrom sudden and reasonably unforeseeable events beyond the control ofthe. source, including actsof God, which situation requires immediate corrective action to restore normal operation,and that causes the source to exceed a technoiogy-based emission limitation under the permit, due to unavoidableincreases in emissions attributable to the emergency. An emergency sballnot include noncompliance to the extentcaused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, oroperator error.

"EPA" means the Administrator ofthe U.S. Environmental Protection Agency or the Administrator's designee.

"Fuel-burning equipment" means any furnace, boiler apparatus, stack, or appurtenances thereto used in the processof burning fuel or other combustible material for the purpose of producing beat Or power by indirect heat transfer.

"Fugitive emissions" means those emissions which could not reasonably pass through a stack chhnney, vent, orother functionally equivalent opening.

"Insignificant activities" means those activities which are incidental to the facility's primary business activity andwhich result in emissions of less than one ton per year of a regulated pollutant not included in the Section 112 (b)list of hazardous air pollutants or emissions less than 1000 pounds per year of a pollutant regulated pursuant tolisting under Section 112 (b) of the Act provided, however, such emission leveis of hazardous air pollutants do notexceed exemptions based on insignificant emission levels established by EPA through rulernaking for modificationunder Section 112 (g) of the Act.

"MACT" or "Maximum achievable control technology" means the maximum degree of reduction in emissionsthat is deemed achievable for new sources in a category or subcategory that shall not be less stringent than theemission control that is achieved in practice by the best controlled similar source, as determined by theAdministrator. Emi~sion standards promulgated for existing sources in a category or subcategory may be lessstringent than standards for new sources in the same category or subcategory but shall not be less stringent, and maybe more stringent than:

(a) the average emission limitation achieved by the best perfOl'111ing 12 percent of the existing sources (forwhich the Administrator has. emission information), excluding those sources that have, within 18 monthsbefore the emission standard is proposed or within 30 months before such standard is promulgated,whichever is later, first achieved a level of emission rate or emission reduction which complies, or wouldcomply if the source is not subject to such standard, with the lowest achievable emission rate applicable tothe source category and prevailing at the time, in the category or subcategory for categories andsubcategories witb 30 or more sources, or

(b) the average emission limitation achieved by the best performing five sources (for which the Administratorhas or could reasonably obtain emissions information) in the category or subcategory for categories orsubcategories with fewer thau 30 sources,

"MOdification" means any physical change in, or change in the method of operation of, an affected facility whichincreases the amount of any air pollutant (to which any state standards applies) emitted by such facility or whichresults in the emission ofany such air pollutant not previously emitted.

"Permittee" means the person or entity to whom a Chapter 6, Section 3 permit is issued.

"Potential to emit" means the maximum capacity of a stationary source to emit any air pollutant under its physicaland operational design. Any physical or operational limitationoil the capacity of a source to emit an air pollutant,

Permit No. 3·2·094·1

including air pollution control equipment and restrictions on hours of operation or on the type or amount of materialcombusted, stored or processed, shall be treated as part of its design if the limitation is enforceable by EPA and theDivision, This term does not alter or affect the use of this term for any other purposes under the Act, or the term"capacity factor" as used in title IV of the Act or the regulations promulgated thereunder.

"Regulated air pollutant" means the following:

(a) Nitrogen oxides (NOx) or any volatile organic compound;

(b) Any pollutant for which a national ambient ail' quality standard has been promulgated;

(c) Any pollutant that is subject to any standard established in Chapter 5, Section 2 of the WAQSR or SectionIII of the Act;

(d) Any Class I or 11 substance subject to a standard promulgated under or established by title VI of the Act; or

(e) Any pollutant subject to a standard promulgated under Section 112 or other requirements established underSection 112 of the Act, including Sections 112(g), 0), and (1') of the Act, including the following:

(I) Any pollutant subject to requirements under Section 1120) of the Act. If EPA fails to promulgate astandard by the date established pursuant to Section 112(e) of the Act, any pollutant for which asubject source would be major shall be considered to be regulated on the date 18 months after theapplicable date established pursuant to Section 112(e) of the Act; and

(ii) Any pollutant for which the requirements of Section 112(g)(2) of the Act have been met, but onlywith respect to the individual source subject to Section 112(g)(2) requirement.

(I) Pollutants regulated solely under Section 112(1') of the Act are to be regulated only with respect to therequirements of Section 112(1') for permits issued under this Chapter 6, Section 3 of the WAQSR,

"Renewal" means the process by which a permit is reissued at the end of its term.

"Responsible official" means one of the following:

(a) For a corporation:

(i) A president, secretary, treasurer, or vice-president of the corporation in charge of a principalbusiness function, or any other person who performs similar policy 01' decision-making functions forthe corporation; or

(ii) A duly authorized representative of such person if the representative is responsible for the overalloperation of one or more manufacturing) production, or operating facilities applying for orsubject toa permit and either:

(A) the facilities employ more than 250 persons or have gross annnal sales or expendituresexceeding $25 million (in second quarter 1980 dollars); 01'

(B) the delegation of authority to such representative is approved in advance by the Division;

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively;

(c) For a municipality, State, Federal, or other public agency: Either a principai executive officer or rankingelected official. For the purposes of this part, a principal executive officer of a federal agency includes thechief executive officer having responsibility for the overall operations of a principal geographic unit of theagency; or

(d) For affected sources:

(i) The designated representative 01' alternate designated representative in so tar as actions, standards,requirements, or prohibitions under title IV of the Act or the regulations promulgated thereunder areconcerned; and

(ii) The designated representative, alternate designated representative, or responsible official underChapter 6, Section 3 (b)(xxvi) of the WAQSR for all other purposes under this section,

"WAQSR" means the Wyoming Air Quality Standards and Regulations promulgated under the WyomingEnvironmental Quality Act, W,S, §35-II-101, et seq,

Perm it No, 3-2-094-1

APPENDIX ACompliance Assurance Monitoring (CAM) Plan

(Amended January 17, 2013 for the Pulp Dryer (units 005/006) and the Lime Kilns (unit 044))


COMPLIANCE ASSURANCE MONITORING PLANFABRIC FILTERS FOR PM CONTROL

I. Background

A. Emissions Units

Description (iD): Four coal-fired boilers (004)Granulated sugar packaging facility (069)Brown and powdered sugar packaging facility (070)Powdered sugarpulverizing (071)Sugar storage silos 1-4 (074-077)Scrolls and elevators for sugar silos 1-4 (078)

Facility: Western SugarCooperative, Torrington, Wyoming

B. Applicable Regulation, Emission Limit: and Monitoring Requirements

Regulation No.: PermitOP-147 (unit004)WAQSR Chapter 3, Section 2 (units004 and 069-071)Permit MD-296 (units 074-078)Permit30-094 (all units)

Emission LimitsParticulate Matter: 0.10 Ib/MMBtu, 24.6 Ib/hr, 35.4TPY (unit 004) .

E =3.59 pM 2 for P ~ 30 TPH; E = 17.31 pO.16 for P > 30 TPH

(units 069-071)0.04 gr/dscf, 4.02Ib/hr, 17.61 TPY (units074-077)0.04 gr/dscf, 1.66Ib/hr, 7.24 TPY (unit 078)

Monitoring requirements: Weekly visible emissions, preventive and corrective maintenance oncontrol equipment, reliance on November 1999 stack test results forunit 004.

C. ControlTechnology

Four Peabody Baghouses PMTR-10-688 (unit 004)MAC Baghouse Model No. 96-LVB-162 (unit 069)Mikro Pulsaire Baghouse Model No. 83286HI (units 070 & 071)Filtering vent (unit 074)Filtering ventswith fans (units 075-078)

II. Monitoring Approach

A. Indicator

Visible emissions

B. Measurement Approach

Visible emissions from the baghouse exhausts will be monitored daily using EPA ReferenceMethod 22-lIke procedures.

C. IndicatorRange

The indicatorievel is no visible emissions.

07-07-2008 03209406/26/08

:,~;>": ,-i'~! -_"'._ ..:,", __o:,'~:~'·,,: -. !,~')':-'::.~iJ~ :,':~?:':_::;~':;:;i~ __~,:_~D. QIP(Quality Imrinivemerif~iail}Tf1tE~rli61d' in;'>

The QIP threshold is ten excursioris peremission unit in the annual reporting period.

E. Performance Criteria

Data Representativeness:. Measurements "are'made' at the emission point. .

Verlflcatlon of8p:~i~ii8h~t'~;~{U~;:i~~~~a~~~~~~,;!~j;'~',i;;,;';rd~~".. '.

QAlQC Practices and Criteria: .,,;,·"rne:'oJ:,isefVer'wiIf,be> famiiiarwith Method 9 procedures."_ " ,::::_? '~{(Y_):!::':'>~: f'?;t~ :,<::~-: '~i'~~1;:!+~:;:c~r·t\:'i::~;~:;<1/:·;:r\:fl·:~f~X;:t):~'r;;,;: . "

Monitoring FreqLi~l1cy and Data. . .A9I1El,min~terv1eihgd22-like observation will be performedCollection pr06eCit1{e:'Y'; ,.(,,;,·t',;.' "'d~ily"6rlteacli"emissltiifp(jii1C

III, Justification '·"(!.i'~',':'{;:;"";'<;';,'r#jN;,;: ,.; ,,:;,:';:,,::;';.:d,\;"'," !i;';;;~;:;ii,\:D,;, .",;;",,,},

A. Backd"f6dhd'" ·{,J{q';.df::;\\~ir;~~~":'~~:~<; }~~t(j:t~:'""", _-,\:~.%Y:~~~;:ifY":~~V,::,;??"}~::,:>,;q;·;~~:'fr;'~, V: :_:_~:,' ::'}~L:-:}:1{~~;{~-'~~:~~JfJtt:~~_.~i:?~-::~,j~f)Hh\\:, __ , ._":Thisfa6iHtypr6c~sses sugaFb'eels'I(fpN~~9'~r€lJ1ni9~~(i9ar and by-products. Pollutant-specificemission unii 004blJrns coal to prqHtrc~'~I~~r1i;8'fia~te~ti'Ii;:ity for beet processing and sugarprodiiction. ParticulaterriaUer general~~ from J:llli'niIiQcoal is controlled byfour baqhouseseXha'listirig thrOUgh 'a¥llim9n'stack;NQinCiiyi9\latlJaghouse is dedicatedto~ p~rticular boiler.Thflothf,lr t1Ql!oJahl::sp~9ffic;:'~rtils~rorl)lnil~\1aiiiltE!:'$\tg~lt as it is storedor packagEld. Sugardustfrc')m;tf{~se'ilmrs'Slon'unils;isC'on'ti'QUe(ti:lYb&gI16ijse§.,,<;>·, ..

B. 'Ra;iOAdj~~~~~~~~~~~;~j;~;~~~~,~~~;t~~~~!~t;1~,;":;;,I'Visi~l~ emissions isselected as thepeifgrmance indicator since visible emissions are indicative

,;of'O'p'er~lt6'1'f'9f tl1e'Dagfl6Yis'~.rri aP'ta~nef'ri,e¢eS'~~rx'tocompIY wiih pal:ticulatEliemission limits.IJIll1enil1ejBa~ii'dU's&~'are'operatingjjfop6rlY;'II1~re~r~n<,jvlsIbis emissions. Any increase invisIble eiTllssions ilidic~tes clegraded'perfOimanc~"Ofa'particulate control device. Therefore, thepresence ofvisible emissions is usedas a performanceinclicator.

C. ~~:os~l~t;tl.:~~::~;t:~t~,;:::ry\iif~i~m;j~~~~~~W~~iN" 'j'xo~i~i§~;6~~~i.·~:i:' '~kective actionwiH beinitiat~d .bEl irinlii"~ljtl'aW'Eival(Cttl:il1Y6V;)ii~o¢'qul; ." ..... cfdetefOili1 '. r~n required toc()rreSftH'f~lt~ktii:i~-.AII.;ti1rSions'011f'SedocciVi¥1lntad~rr~le''01iEl~rAn'rila '(ao e ofnoViS'ibreemissioh\;'wa~sa!ectedbecatl§~:(1)aht~qreas~'tr1"Y~~'r~'erDts&jiJq· ... < .... id%t~e ofaninbrea~enn particulatE! emiSSIons; and (2) a mOhft6ring te;:c~hjq~e WhichdoiW'h61'require aMeth6d9 certified observer lsdeslred, AithotighMethod22 applies tofugiiIy~sQtjrces" thevi&iblelno visible emissionsobservatioil technique ofMethod 22 can be'ar5~Md\6diJctedernlsslons (Le., Metfiod22-like observations) and is currently the monitoring rTI,etllpd, usedforthese emission points as specified bypermit 30~094. ..

The selected QIP threshoid for baghousevlsibie emissions is ten excursions in an annualreportlnq'perlod, This level is threepercent ofthe total visible emlssioMpQIl"ryfjtions. If the QIPthreshold is exceeded in an annual reporting period, a QIP will be developei{and lrnplernented.

;{ 'i\i ,_"""

(

0')-0')-2008 032094 (

06/26~8

COMPLIANCE ASSURANCE MONITORING PLAN 2012 REVISIONSCRUBBERS FOR PMCONTROL

WESTERN SUGARCOOPERATIVE TORRINGTON FACILTY

I. Background

A. Emissions Units

Description (10): One natural-gas fired pulp dryer with two cyclones and wetscrubbers (005 & 006)Two lime kilns with wet scrubber (044)

Facility: Western Sugar Cooperative, Torrington, Wyoming

B. Applicable Regulation, Emission Limit: and Monitoring Requirements

Regulation No.:

Emission LimitsParticulate Matter:

Monitoring requirements:

C. Control Technology

Permit 3-2-094

E=3.59 pO.62 for P < 30 TPH

E = 17.31 pO.16 for P-> 30 TPH

Scrubber waterfiow.

Pulp dryer controlled by two Stearns-Rogers cyclones and two wetscrubbers thatexhaust in two stacks(005 & 006).

Lime kilns' (two) exhaust primarily goes into the carbonation tank to carbonate the juice. However, aportion of the exhaust is vented and this is controlled by awet scrubber (044).

II. Monitoring Approach

A. IndicatorFlow meter

B. Measurement ApproachMeasure water flow rate to scrubbers using flow meter, A flow meter was installed after the pump onthe pipeline that flows to the two pulp dryerscrubbers during intercampaign in 2004. A fiow meter wasinstalied on the pipeline to the scrubber for the two lime kilns during intercampalgn 2006.

C, Indicator RangePulp dryer scrubbers: 120 to 240 gpm, The standard flow for the two scrubbers is a combined fiow of200 gpm with an acceptable rangeof 120 to 240 gpm, The lower acceptable range of scrubber flow isbased upon the scrubber flow measured during the2012 source testing. Previous source testing alsoIndicated thisflow range was acceptable. Wet scrubber performance requires a minimum level tooperate but Is not critically dependant upon the exact flow rate, The maximum fiowis notconsideredcritical or relevant to emissions levels but has been set to indicate when excessive scrubber fiows arepresent potentially indicating a pump issue or flow meter concern.

Lime kilns' scrubber: 17 gpm minimum (2012 testing flow rate). The standard fiowof 20 grim is basedupon the measured flow rate during the 2006 stacktesting and the actual emission rate that is very lowcompared to the emission limit.

D. OIP (Quality Improvement Plan)ThresholdScrubber flow will be kept within the acceptable range (pulp dryer 120-240 gpm, lime kilns minimum 17gpm). A quality improvement threshold wili be determined if flow excursions outside the range are aproblem. Excursions outside these ranges havenotbeen a problem at Torrington or other WesternSugarfactories for scrubber flow monitoring. A maximum flow will notbe monitored for the lime kilnscrubber,

S:\Oenver Offrce\EnvirOfimenl\Torlingloo\Air\TiU eVCAM\TN_CAM_Scrubbers_2012 .doc Page1of2

, ,

. -- _.,,_..... , ..,. ..:~ ..

CQMP~JANC~A;~~~:~I§n%~L~~Rg'bGN~~~~~2012REvrsroNWESTERN SUGAR'CbbpERATI'VEfbRRINGTON FAclLTY

E. Performance Criteria

Data Representativeness:

">' ,Verification of Oper~fiQnal Status»..-.-,;, .•• '. .;.. _ -,hC. - • ; -, ',:, \. - .-

Flow meter will belocated prior to thescrubbi/flozzles,

, Pulpdryersancflfme kilns scrubbers haveHMh'i~stailed andiifEiO'peraii()hal:~'.)1i;r'i?; ,'.

Thefl~w meMrsiNlrrbSetheckeclmanually ari~recorded at leastonce per dayduring cpsratlon. Date, time and

berecorded." ',:C',' '. "", ,

Monitoring Frequency and DataCollection Procedure:

III. Justification

A. Background " ," .Wet scrubbers are used to control particulates from the pulp dryers and limekiliis;Tnii'pulp dryers andlime kilns Operate only durlriq thebeet-processing campaigns, typically less thans 'rrionthsofthe year,",.);; :i, :-j:>".;L:?~~'1>·n:.'d;~;, l_.__,-~~;'~,;~(fJ.;':h:>\i'! ,~:.;\'.~<:.-~.' >:': ~/_;",.::,-;.' :. \:~'l~{:'V_:~~ft~ "i',', ~:;-:'.:-:.-" -' ,. ' (/ ~'

'8,' Rationale for Selectidh ofPerformance lridicator." ",' ,Based uponstack testing at dfferent flowlevels performed Elt fortheseunits and atoth~rWestern

Sugarfactories bn 9()ilhfiredboj[~rsand pulpdryersb6ti!roJrE!d bysqfupljersWaier'flowrateto.SCfUbb"&H3..•i~'iW'B~~t·IJi~iq~t9~9flB¥uQb~r6liarail()ti;i~·q'tiP~~fesirM11'Was 'coh'iJd8iecfafTorrln9lon atreduced scru6h'er.liow rates:Joib?tti thepuli{dryer arid lRfflme kilns withsfgriifl6iW'Coptrol achlev~d €_~'.belowPerrYiiternission Ifmlts!i Stacktestfri>r was a[so'previouslyperformed at diffefel'lffJoW lever~ onthe .scrubber-controlled coal:f[redtJoi)ers at the FortMorgan CO factory. Thetests showed thatacertain _"minimum level offiow lsnecessary tooperate thescrubbers butthatthe exact flow did noi'niatter aslong as it wa's above thisin:rnimum level (stack testing results onlyvaried slightly at different ievels offlow) further corroborating' these results.

~';,.:!...".-. ;. :-";->?'.. ,C, Rationaie forSell,ctlon oflridicatbrl.evel.•..•. "r, C.'·F \. "i'il.F'''·)'; >;. .. ..."'>.'.'.....

. Th~:s.ElrElHt~£J(I<jjSl1!9fJ~Qg.~' trw average mlniinuniflo\Vyti!t~tJ.d~vrrngsollrc~·testir\g Ih20'12, Thestan~a~9P-9,J¥8tfq.Q!,~BiP'~J~, ,eachl.fgtthecqmrrionprp~~~.~!9the tWo'liurlidrYer~crubbers isbaseduponthe 2ot2~nd 200.5 rck tesitng ~rongwlth thepump-size (210 gpm)andstandard setting(75 '!o). p.,cliicil slandardflov{lia-s been conITrmEld aftefti1e flow m.el~fWas Install<J~'if~-aboUt200gpm, A.maxlniumfkiw hasbeeii's<Jt:al.240gpm although norm'pacts to.~mis~:i6ns' areexpecMcrat hlgHsr

··fs~:~t~e~i!~~~\~!~~;r,~',~(;!1::r~1J1t~.C,.';·.,:~;;J ;; : ittq~;; ·, ;· : ·,';((";)~}:'~\(.f!: :,( .\: ' · •.• ,;·.:i··.':.......... .Asimll<lrJ9.\tiJrJ~tEl,flpplj~§.(9)iJE1'JiMe kilns' scrubbers;with a~l.ar\d'ardflow·oT 20 gprnbased upon therilr?9Ur~g:flow.durr[1g~i~PK te~ting, \y[th a 17 gpm mihlrrium r~n'g-e for thEl20t2sourceleSting, .Actual~qw~:¥re tYpically set<lP5~40 gPr\t' Nomaximum flowhils been set forthissource'due to the very lowemissions for this controlled ~ouroe and limited concerns with hlgherflowrates.'

[V, Schedule...' .... .;'Y."I'/;; '.. ..,••::., '. • ,.i)". . .... . . .. '. 'Western Sugarl~ase.?s'orialop(mition. Thefactory operates onlyduring a limited time'period following theharvest of thesugar beets; generally form late September or early October through December to February,The flow meter for the pulp dryers' and the lime kilns scrubberhave been installed, Stack testing hasdemonstrated compliance with emission limitations using th,es.eflowrates,

( '"o'T,':.=~

S:\Denver Office\Environment\TcirIinglonWr\TIUeVCAM\~N _CAM_Scrubbers_2012 doc Page 2 of2


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