Text

Renewable Operating Permit
	ML23156A634
Person / Time
Site:	Cook
Issue date:	06/05/2023
From:	Ferneau K; Indiana Michigan Power Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	AEP-NRC-2023-33
	Download: ML23156A634 (1)
	v • d • e

Indiana Michigan Power INDIANA Cook Nuclear Plant One Cook Place MICHIGAN Bridgman, Ml 49106 POWER indianamichiganpower.com An AEP Company BOUNDLESS ENERGY June 5, 2023 AEP-NRC-2023-33 1 0 CFR 50.4 Docket Nos.: 50-315 50-316 U . S . Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 RENEWABLE OPERATING PERMIT

References:

1. Renewable Operating Permit MI-ROP-B4252-2023, issued from Michigan Department of Environment, Great Lakes, and Energy - Air Quality Division, to American Electric Power (AEP) Cook Nuclear Plant, dated May 1 8 , 2023.

2. Renewable Operating Permit Staff Report, issued from Michigan Department of Environment, Great Lakes, and Energy - Air Quality Division, to AEP Cook Nuclear Plant, dated February 27, 2023.

By Reference 1, Indiana Michigan Power Company, the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, was issued a new Renewable Operating Permit MI-ROP-B4252-2023 by Michigan Department of Environment, Great Lakes, and Energy - Air Quality Division. By Reference 2, the Michigan Department of Environment, Great Lakes, and Energy - Air Quality Division provided a staff report for CNP that sets forth the requirements and basis for the new Renewable Operating Permit terms and conditions. Reference 1 and 2 are provided, as enclosures to this letter, in accordance with C N P ' s T echni c al Spe c i fi cation, Environ m ental Protection Plan, Section 3 .4 , Reporting Related to the Renewable Operating Permit.

U. S. Nuclear Regulatory Commission AEP-NRC-2023-33 Page 2 This letter contains no new commitments. Should you have any questions regarding this notification, please contact Chris A. Blosser, Environmental Manager, at (269) 465-5901, extension 2579.

Sincerely, dl, } ow<<c" Kelly J. Ferneau Site Vice President KMH/sjh

Enclosures:

1. Renewable Operating Permit MI-ROP-B4252-2023, dated May 1 8 , 2023.

2. Renewable Operating Permit Staff Report, dated February 27, 2023.

U. S. Nuclear Regulatory Commission AEP-NRC-2023-33 Page 3 c: J. B. Giessner -- NRC Region Il l NRC Resident Inspector N. Quilco - MPSC R. M. Sistevaris -- AEP Ft. Wayne S. P. W a ll - NRC Washington, D . C .

A. J. Williamson - AEP Ft Wayne

ENCLOSURE 1 TO AEP-NRC-2023-33 Renewable Operating Permit MI-ROP-B4252-2023 Dated May 1 8 , 2023

MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY AIR QUALITY DIVISION EFFECTIVE DA TE: May 1 8 , 2023 I S S U E D TO AEP Cook Nuclear Plant State Registration Number (SRN): B4252 LOCATED AT One Cook Place, Bridgman, Berrien County, Michigan 49106 RENEWABLE OPERATING PERMIT Permit Number: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 Administratively Complete ROP Renewal Application Due Between November 1 8 , 2026 and November 1 8 , 2027 This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 4 5 1 , as amended (Act 4 5 1 ) . Pursuant to Rule 2 1 0 ( 1 ) of the administrative rules promulgated under Act 4 5 1 , this ROP constitutes the permittee's authority to operate the stationary source identified above in accordance with the general conditions, special conditions and attachments contained herein. Operation of the stationary source and all emission units listed in the permit are subject to all applicable future or amended rules and regulations pursuant to Act 451 and the federal Clean Air Act.

SOURCE-WIDE PERMIT TO INSTALL Permit N u m b e r : MI-PTI-B4252-2023 This Permit to Install (PTI) is issued in accordance with and subject to Section 5 5 05 (1) of Act 4 5 1 . Pursuant to Rule 2 1 4 a of the administrative rules promulgated under Act 4 5 1 , the terms and conditions herein, identified by the underlying applicable requirement citation of Rule 2 0 1 ( 1 ) ( a ), constitute a federally enforceable PTI. The PTI terms and conditions do not expire and remain in effect unless the criteria of Rule 201(6) are met. Operation of all emission units identified in the PTI is subject to all applicable future or amended rules and regulations pursuant to Act 451 and the federal Clean Air Act.

Michigan Department of Environment, Great Lakes, and Energy 21./

Brad Myott, Field Operations Manager

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI NO: MI-PT1-B4252-2023 TABLE OF CONTENTS AUTHORITY AND ENFORCEABILITY 3 A. GENERAL CONDITIONS 4 Permit Enforceability 4 General Provisions 4 Equipment & Design 5 Emission Limits 5 Testing/Sampling 5 Monitoring/Recordkeeping 6 Certification & Reporting 6 Permit Shield .t 7 Revisions 8 Reopenings 8 Renewals 9 Stratospheric Ozone Protection 9 Risk Management Plan 9 Emission Trading 9 Permit to Install (PTI) 10 B. SOURCE-WIDE CONDITIONS 11 C. EMISSION UNIT SPECIAL CONDITIONS 12 E M I S S I O N U N I T

SUMMARY

TABLE 12 EU-BOILER1 14 D. FLEXIBLE GROUP SPECIAL CONDITIONS 17 FLEXIBLE GROUP

SUMMARY

TABLE 17 FG-EMERDIESELS 19 FG-ENGINES 21 F G - M A C T Z Z Z Z < 5 0 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 FG-MACTZZZZ>500 28 FG-MACTJJJJJJ 32 FG-NSPSIIII 36 FG-RULE287(2)(c) 39 FG-COLDCLEANERS 41 E. NON-APPLICABLE REQUIREMENTS 44 APPENDICES 45 Appendix 1 . Acronyms and Abbreviations 45 Appendix 2. Schedule of Compliance 46 Appendix 3. Monitoring Requirements 46 Appendix 4. Recordkeeping 46 Appendix 5. Testing Procedures 46 Appendix 6. Permits to Install 46 Appendix 7. Emission Calculations 46 Appendix 8. Reporting 47 Page 2 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 AUTHORITY AND E N F O R C E A B I LI TY For the purpose of this permit, the permittee is defined as any person who owns or operates an emission unit at a stationary source for which this permit has been issued. The department is defined in Rule 104(d) as the Director of the Michigan Department of Environment, Great Lakes, and Energy (EGLE) or his or her designee.

The permittee shall comply with all specific details in the permit terms and conditions and the cited underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most stationary sources for which an ROP has been issued. These general conditions are included in Part A of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units which are represented as a flexible group, or the entire stationary source which is represented as a Source-Wide group. Special conditions are identified in Parts B, C, D and/or the appendices.

In accordance with Rule 2 1 3 ( 2 )( a ) , all underlying applicable requirements are identified for each ROP term or condition. All terms and conditions that are included in a PTI are streamlined, subsumed and/or is state only enforceable will be noted as such.

In accordance with Section 5507 of Act 451, the permittee has included in the ROP application a compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements with which the source is in compliance, the source will continue to comply with these requirements. For applicable requirements with which the source is not in compliance, the source will comply with the detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the stationary source will meet the requirements on a timely basis, unless the underlying applicable requirement requires a more detailed schedule of compliance.

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law.

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 A. G E N E RA L C O N D I T I O N S Permit Enforceability

All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted.

(R 3 3 6 . 1 2 1 3 ( 5 ))

Those conditions that are hereby incorporated in a state-only enforceable Source-Wide PTI pursuant to Rule 2 0 1 ( 2 )( d ) are designated by footnote one. (R 336.1213(5)(a), R 336.1214a(5))

Those conditions that are hereby incorporated in a federally enforceable Source-Wide PTI pursuant to Rule 201(2)(c) are designated by footnote two. (R 336.1213(5)(b), R 336.1214a(3))

General Provisions

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of Act 4 5 1 , and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of the ROP. All terms and conditions of this ROP that are designated as federally enforceable are enforceable by the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the provisions of the federal Clean Air Act (CAA). Any terms and conditions based on applicable requirements which are designated as "state-only" are not enforceable by the USEPA or citizens pursuant to the CAA.

(R 3 3 6 . 1 2 1 3 ( 1 )( a ))

2. It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this ROP. (R 3 3 6 . 1 2 1 3 ( 1 )( b ) )

3. This ROP may be modified, revised, or revoked for cause. The filing of a request by the permittee for a permit modification, revision, or termination, or a notification of planned changes or anticipated noncompliance does not stay any ROP term or condition. This does not supersede or affect the ability of the permittee to make changes, at the permittee's own risk, pursuant to Rule 2 1 5 and Rule 2 1 6 . (R 3 3 6 . 1 2 1 3 ( 1 )( c ))

4. The permittee shall allow the department, or an authorized representative of the department, upon presentation of credentials and other documents as may be required by law and upon stating the authority for and purpose of the investigation, to perform any of the following activities: (R 3 3 6 . 1 2 1 3 ( 1 ) ( ) )

a. Enter, at reasonable times, a stationary source or other premises where emissions-related activity is conducted or where records must be kept under the conditions of the ROP.

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the ROP.

c. Inspect, at reasonable times, any of the following:

i. Any stationary source.

ii. Any emission unit.

iii. Any equipment, including monitoring and air pollution control equipment.

iv. Any work practices or operations regulated or required under the ROP.

d. As authorized by Section 5526 of Act 4 5 1 , sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the ROP or applicable requirements.

5. The permittee shall furnish to the department, within a reasonable time, any information the department may request, in writing, to determine whether cause exists for modifying, revising, or revoking the ROP or to determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies of any records that are required to be kept as a term or condition of this ROP. For information which is claimed by the permittee to be confidential, consistent with the requirements of the 1976 PA 442, MCL § 1 5 . 2 3 1 et seq., and known as the Freedom of Information Act, the person may also be required to furnish the records directly to the USEPA together with a claim of confidentiality. (R 3 3 6 . 1 2 1 3 ( 1 )( e ))

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023

6. A challenge by any person, the Administrator of the USEPA, or the department to a particular condition or a part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other condition or part of this ROP. (R 336.1213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of Act451. ( R 3 3 6 . 1 2 1 3 ( 1 )( g ))

8. This ROP does not convey any property rights or any exclusive privilege. (R 3 3 6 . 1 2 1 3 ( 1 )( h ))

Equipment & Design

9. Any collected air contaminants shall be removed as necessary to maintain the equipment at the required operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I 2

and II areas requires the use of material handling methods specified in Rule 370(2). (R 336.1370) 1 0 . Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance with the Michigan Air Pollution Control rules and existing law. (R 3 3 6 . 1 9 1 0 )

Emission Limits

11. Unless otherwise specified in this ROP, the permittee shall comply with Rule 3 0 1 , which states, in part, "Except as provided in Subrules 2, 3, and 4 of this rule, a person shall not cause or permit to be discharged into the outer air from a process or process equipment a visible emission of a density greater than the most stringent of the following:" (R 3 3 6 . 1 3 0 1 ( 1 ) )

a. A 6-minute average of 20% opacity, except for one 6-minute average per hour of not more than 27% opacity.

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

The grading of visible emissions shall be determined in accordance with Rule 303.

12. The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that cause, alone or in reaction with other air contaminants, either of the following:

1

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property.

(R 336.1901(a))

1

b. Unreasonable interference with the comfortable enjoyment of life and property. (R 336.1901(b))

Testing/Sampling

13. The department may require the owner or operator of any source of an air contaminant to conduct acceptable performance tests, at the owner's or operator's expense, in accordance with Rule 1 0 0 1 and Rule 1003, under 2

any of the conditions listed in Rule 1 0 0 1 ( 1 ) . (R 336.2001)

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and Rule 1 0 0 3 . (R 336.2001(2), R 336.2001(3), R 336.2003(1))

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the applicable reference test method within 60 days following the last date of the test. (R 336.2001(5))

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI NO: MI-PT1-B4252-2023 Monitoring/Recordkeeping 1 6. Records of any periodic emission or parametric monitoring required in this ROP shall include the following information specified in Rule 2 13 (3)(b )( i ), where appropriate. (R 3 3 6 . 1 2 1 3 ( 3 ) ( b ) )

a. The date, location, time, and method of sampling or measurements.

b. The dates the analyses of the samples were performed.

c. The company or entity that performed the analyses of the samples.

d. The analytical techniques or methods used.

e. The results of the analyses.

f. The related process operating conditions or parameters that existed at the time of sampling or measurement.

1 7 . All required monitoring data, support information and all reports, including reports of all instances of deviation from permit requirements, shall be kept and furnished to the department upon request for a period of not less than 5 years from the date of the monitoring sample, measurement, report or application. Support information includes all calibration and maintenance records and all original strip-chart recordings, or other original data records, for continuous monitoring instrumentation and copies of all reports required by the ROP.

(R 3 3 6 . 1 2 1 3 ( 1 )(e), R 336.1213(3)(b)(ii))

Certification & Reporting

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be submitted to the department as a term or condition of this ROP shall contain an original certification by a Responsible Official which state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

19. A Responsible Official shall certify to the appropriate AQD District Office and to the USEPA that the stationary source is and has been in compliance with all terms and conditions contained in the ROP except for deviations that have been or are being reported to the appropriate AQD District Office pursuant to Rule 213(3)(c). This certification shall include all the information specified in Rule 213(4)(c)(i) through (v) and shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. The USEPA address is: USEPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Jackson Boulevard, Chicago, Illinois 60604-3507. (R 336.1213(4)(c))

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special conditions, or more frequently if specified in an applicable requirement or in this ROP. (R 336.1213(4)(c))

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise described in this ROP. (R 336.1213(3)(c))

a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting consistent with the requirements of Rule 9 1 2 as detailed in Condition 25. All reports submitted pursuant to this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii).

b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to Rule 9 1 2 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe reasons for each deviation and the actions taken to minimize or correct each deviation.

c. For deviations that do not exceed the emissions allowed under the ROP, prompt reporting means the reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe the reasons for each deviation and the actions taken to minimize or correct each deviation.

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023

22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in Rule 213(3)(c)(iii) as either of the following: (R 336.1213(3)(c))

a. Submitting a certification by a Responsible Official with each report which states that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete.

b. Submitting, within 30 days following the end of a calendar month during which one or more prompt reports of deviations from the emissions allowed under the ROP were submitted to the department pursuant to Rule 213(3)(c)(ii), a certification by a Responsible Official which states that; "based on information and belief formed after reasonable inquiry, the statements and information contained in each of the reports submitted during the previous month were true, accurate, and complete." The certification shall include a listing of the reports that are being certified. Any report submitted pursuant to Rule 213(3)(c)(ii) that will be certified on a monthly basis pursuant to this paragraph shall include a statement that certification of the report will be provided within 30 days following the end of the calendar month.

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the permittee shall submit certified reports of any required monitoring to the appropriate AQD District Office. All instances of deviations from ROP requirements during the reporting period shall be clearly identified in the reports. (R 336.1213(3)(c)(i))

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing the emissions inventory forms provided by the department. (R 3 3 6 . 1 2 1 2 ( 6 ) )

25. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an applicable standard or limitation, as required in Rule 9 1 2 , to the appropriate AQD District Office. The notice shall be provided not later than two business days after the start-up, shutdown, or discovery of the abnormal conditions or malfunction. Notice shall be by any reasonable means, including electronic, telephonic, or oral communication.

Written reports, if required under Rule 9 1 2 , must be submitted to the appropriate AQD District Supervisor within 1 0 days after the start-up or shutdown occurred, within 1 0 days after the abnormal conditions or malfunction has been corrected, or within 30 days of discovery of the abnormal conditions or malfunction, whichever is first. The written reports shall include all of the information required in Rule 912(5) and shall be certified by a Responsible Official in a 2

manner consistent with the CAA. (R 336.1912)

Permit Shield

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements as of the date of ROP issuance if either of the following provisions is satisfied. (R 336.1213(6)(a)(i),

R 336.1213(6)(a)(ii))

a. The applicable requirements are included and are specifically identified in the ROP.

b. The permit includes a determination or concise summary of the determination by the department that other specifically identified requirements are not applicable to the stationary source.

Any requirements identified in Part E of this ROP have been identified as non-applicable to this ROP and are included in the permit shield.

27. Nothing in this ROP shall alter or affect any of the following:

a. The provisions of Section 303 of the CAA, emergency orders, including the authority of the USEPA under Section 303 of the CAA. (R 336.1213(6)(b)(i))

b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at the time of this ROP issuance. (R 336.1213(6)(b)(ii))

c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA.

(R 336.1213(6)(b)(iii))

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023

d. The ability of the USEPA to obtain information from a source pursuant to Section 114 of the CAA.

(R 336.1213(6)(b )(iv))

28. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the following:

a. Operational flexibility changes made pursuant to Rule 2 1 5 . (R 3 3 6 . 1 2 1 5 ( 5 ))

b. Administrative Amendments made pursuant to Rule 2 1 6 ( 1 )(a)(i)-(iv). (R 3 3 6 . 1 2 1 6 ( 1 )(b)(iii))

c. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved by the department. (R 3 3 6 . 1 2 1 6 ( 1 )( c )( iii ))

d. Minor Permit Modifications made pursuant to Rule 216(2). (R 336.1216(2)(f))

e. State-Only Modifications made pursuant to Rule 216(4) until the changes have been approved by the department. (R 336.1216(4)(e))

29. Expiration of this ROP results in the loss of the permit shield. If a timely and administratively complete application for renewal is submitted not more than 1 8 months, but not less than 6 months, before the expiration date of the ROP, but the department fails to take final action before the end of the ROP term, the existing ROP does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original ROP term until the department takes final action. (R 336.1217(1)(c), R 336.1217(1)(a))

Revisions

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the ROP pursuant to Rule 2 1 6 , the permittee must comply with Rule 2 1 5 . (R 3 3 6 . 1 2 1 5 , R 3 3 6 . 1 2 1 6 )

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to Rule 2 1 6 ( 1 ) . (R 336.1219(2))

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by the department in accordance with the time frames specified in Rule 2 1 6 . (R 336.1210(10))

33. Pursuant to Rule 2 1 6 ( 1 )( b )( ii i ) , Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the department takes final action , the permittee shall comply with both the applicable requirements governing the change and the RO P terms and conditions proposed in the application fo r the modification. D uring this time period, the permittee may choose to not comply with the existing ROP terms and conditions that the application seeks to change. H owever, if the permittee fails to comply with the ROP terms and conditions proposed in the application during thi s time period, the terms and conditions in the ROP are enforceable. (R 3 3 6 . 1 2 1 6 ( 1 ) ( c ) ( i i i ) ,

R 3 3 6 . 1 2 1 6 ( 2 )( d ) , R 336.1216(4)(d))

Reopenings

34. A ROP shall be reopened by the department prior to the expiration date and revised by the department under any of the fo llowing circumstances:

a. If additional requirements become applicable to this stationary source with three or more years re m aining in the term of the ROP, but not if the effective date of the new app li cable req uirement is later th a n the R O P expiration date. (R 336.1217(2)(a)(i))

b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source.

(R 336.1217(2)(a)(i))

c. If the departmen t determines that the ROP contains a material mistake, information required by any applicable requirement was omitted, or inaccurate statements w ere made in establishing emission limits or the terms or conditions of the ROP. (R 336.1217(2)(a)(iii))

d. If the department determines that the ROP must be revised to ensure compliance with the applicable requirements. (R 336.1217(2)(a)(iv))

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PT1-B4252-2023 Renewals

35. For renewal of this ROP, an administratively complete application shall be considered timely if it is received by the department not more than 1 8 months, but not less than 6 months, before the expiration date of the ROP.

(R 3 3 6 . 1 2 1 0 ( 9 ))

Stratospheric Ozone Protection

36. If the permittee is subject to Title 40 of the Code of Federal Regulations (CFR), Part 82 and services, maintains, or repairs appliances except for motor vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or recycling and recovery equipment, the permittee shall comply with all applicable standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F.

37. If the permittee is subject to 40 CFR Part 82 and performs a service on motor (fleet) vehicles when this service involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed by the original equipment manufacturer. The term MVAC as used in Subpart B does not include the air-tight sealed refrigeration system used for refrigerated cargo or an air conditioning system on passenger buses using Hydrochlorofluorocarbon-22 refrigerant.

Risk Management Plan

38. If subject to Section 1 1 2 ( r ) of the CAA and 40 CFR Part 68, the permittee shall register and submit to the USE PA the required data related to the risk management plan for reducing the probability of accidental releases of any regulated substances listed pursuant to Section 1 1 2 ( r )( 3 ) of the CAA as amended in 40 CFR 68.130. The list of substances, threshold quantities, and accident prevention regulations promulgated under 40 CFR Part 68, do not limit in any way the general duty provisions under Section 1 1 2 ( r )( 1 ).

39. If subject to Section 1 1 2 ( r ) of the CAA and 40 CFR Part 68, the permittee shall comply with the requirements of 40 CFR Part 68, no later than the latest of the following dates as provided in 40 CFR 6 8 . 1 0(a):

a. June 2 1 , 1999,

b. Three years after the date on which a regulated substance is first listed under 40 CFR 6 8 . 1 3 0 , or

c. The date on which a regulated substance is first present above a threshold quantity in a process.

40. If subject to Section 1 1 2 ( r ) of the CAA and 40 CFR Part 68, the permittee shall submit any additional relevant information requested by any regulatory agency necessary to ensure compliance with the requirements of 40 CFR Part 68.

41. If subject to Section 1 1 2 ( r ) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance with all applicable requirements of Section 1 1 2 ( r ) as detailed in Rule 213(4)(c)). (40 CFR Part 68)

Emission Trading

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or regional emission trading program that has been approved by the Administrator of the USEPA as a part of Michigan's State Implementation Plan. Such activities must comply with Rule 215 and Rule 216.

(R 3 3 6 . 1 2 1 3 ( 1 2 ))

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ROP No: Ml-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 Permit to Install (PTI)

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt from the 2

PTI requirements by any applicable rule. (R 3 3 6 . 1 2 0 1 ( 1 ) )

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence indicates the process or process equipment is not performing in accordance with the terms and conditions of the PTI or is violating the department's rules or the CAA. (R 336.1201 (8), Section 551 O of Act 4 5 1 )

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by the PTI. If a new owner or operator submits a written request to the department pursuant to Rule 2 1 9 and the department approves the request, this PTI will be amended to reflect the change of ownership or operational control. The request must include all of the information required by Subrules ( 1 )( a ) , (b) and (c) of Rule 2 1 9 . The written request shall be sent to the appropriate AQD District Supervisor, EGLE. (R 336.1219)

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and conditions have been approved has not commenced within 18 months of the original PTI issuance date, or has been interrupted for 1 8 months, the applicable terms and conditions from that PTI, as incorporated into the ROP, shall become void unless otherwise authorized by the department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall notify the department via the Supervisor, Permit Section, EGLE, AQD, P. 0. Box 30260, Lansing, Michigan 48909, if it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment allowed by the terms and conditions from that PTI? (R 336.1201 (4))

Footnotes:

1 This condition is state-only enforceable and was established pursuant to Rule 2 0 1 ( 1 )( b ) .

2 This condition is federally enforceable and was established pursuant to Rule 2 0 1 ( 1 ) ( a ) .

Page 1 0 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI NO: MI-PT1-B4252-2023 B. SOURCE-WIDE CONDITIONS Part B outlines the Source-Wide Terms and Conditions that apply to this stationary source. The permittee is subject to these special conditions for the stationary source in addition to the general conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in the table. If there are no Source-Wide Conditions, this section will be left blank.

Page 1 1 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 C. E M I S S I O N U N I T SPECIAL CONDITIONS Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If there are no conditions specific to individual emission units, {his section will be left blank.

EMISSION UNIT

SUMMARY

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

Emission Unit ID Emission Unit Description Installation Flexible Group ID (Including Process Equipment & Control Date/

Devlce(s))

Modification ,.

.. Date EU-1ABEDG 1-OME-150AB - Unit 1 AB emergency 01-01-1971 FG-EMERDIESELS diesel generator engine (35.088 FG-MACTZZZZ>500 MM BTU/hr).

EU-1CDEDG 1-OME-150CD -- U ni t 1 CD emergency 01-01-1971 FG-EMERDIESELS diesel generator engine (35.088 FG-MACTZZZZ>500 MMBTU/hr).

EU-2ABEDG 2-OME-150AB -- Unit 2 AB emergency 01-01-1971 FG-EMERDIESELS diesel generator engine (35.088 FG-MACTZZZZ>500 MMBTU/hr).

EU-2CDEDG 2-OME-150CD -- Unit 2 CD emergency 01-01-1971 FG-EMERDIESELS diesel generator engine (35.088 FG-MACTZZZZ>500 MM BTU/hr).

EU-BOILER1 Alternate plant space heating boiler - No. 2 06-10-2009 FG-MACTJJJJJJ fuel oil (28.56 MMBTU/hr heat input).

EU-12-EP-DG-1 5,000 kW supplemental diesel generator 1 . 02-16-2005 FG-ENGINES FG-MACTZZZZ>500 EU-12-EP-DG-2 5,000 kW supplemental diesel generator 2. 02-16-2005 FG-ENGINES FG-MACTZZZZ>500 EU-SECDIESELGEN Detroit Diesel generator set - 550 kW, full 01-01-1971 FG-MACTZZZZ<500 load fuel consumption - 37.5 gph, estimated heat input @ 1 3 8, 0 0 0 BTU/gal -

5 , 1 7 5 , 0 0 0 BTU/hr.

EU-DSLFIREPUMP1 Cummins Model NTA855 - 400 hp, fuel 12-01-1992 FG-MACTZZZZ5500 consumption 20.9 gph, estimated heat input

@ 1 3 8 , 0 0 0 BTU/gal - 2,884,200 BTU/hr.

EU-DSLFIIREPUMP2 Cummins Model NTA855 -- 400 hp, fuel 12-01-1992 FG-MACTZZZZ<500 consumption 20.9 gph, estimated heat input

@ 1 3 8 , 0 0 0 BTU/gal - 2,884,200 BTU/hr.

EU-TRGCTRDSLGEN Detroit Diesel 550 hp diesel engine 1 2 . 7 L 01-01-2001 FG-MATZZZZ<500 displacement Model Series YDDXL, estimated fuel consumption @ 138,000 BTU/gal - 2 3 . 0 gal/hr, estimated heat input

- 3 , 1 7 4 , 0 0 0 BTU/hr.

Page 1 2 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 Emission Unit ID Emission Unit Description Installation Flexible Group ID (Including Process Equipment & Control Date/

Devlce(s))

Modification Date EU-MAINGATEDSLGEN Mitsubishi 16.0 liter displacement 400 kW 12-01-2004 FG-MACTZZZZ<500 generator electrical output, estimated fuel consumption: 30.2 gph, estimated heat input @ 138,000 BTU/gal - 4, 1 6 7, 6 0 0 BTU/hr.

EU-COMTWRPRGEN 33 kW Kohler propane fired generator set 10-01-2002 FG-MACTZZZZ<500 Model 30RZG, 4.3 L GM Vortec spark ignition engine, estimated heat input -

370,000 BTU/hr.

EU-DRYCASKDSLGEN Generac 80 kW diesel generator set, 1 3 2 hp 10-01-2011 FG-NSPSIIII

@ 1 8 0 0 RPM, fuel consumption - 6 . 5 gph, heat input @ 138,000 BTU/gal - 897,000 BTU/hr.

EU-U1 DISGENERATOR 2020 Model Year Cummins C 1 5 D6 24.3 hp 06-01-2021 FG-NSPSIIII Diesel Engine 1 5 kW Emergency Generator used for igniting hydrogen flares in an emergency. Installed as exempt under Rule 285(2)(g). EPA Certificate of Conformity LKBXL02.2FCC-043 EU-U2DISGENERATOR 2020 Model Year Cummins C 1 5 D6 24.3 hp 07-01-2021 FG-NSPSIIII Diesel Engine 1 5 kW Emergency Generator used for igniting hydrogen flares in an emergency. Installed as exempt under Rule 285(2)(g). EPA Certificate of Conformity LKBXL02.2FCC-043 EU-PAINTSHOP Paint shop that supports plant operations. 06-01-1998 FG-RULE287(2)(c)

Emission controls include a spray booth with filtration and a limitation of 200 gallons or less per month of paints and coatings being used.

EU-COLDCLEANER1 A parts cleaner station with closeable 01-01-1980 FG-COLDCLEANERS covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

EU-COLDCLEANER2 A parts cleaner station with closeable 01-01-1980 FG-COLDCLEANERS covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

EU-COLDCLEANER3 A parts cleaner station with closeable 01-01-1980 FG-COLDCLEANERS covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

EU-COLDCLEANER4 A parts cleaner station with closeable 01-01-1980 FG-COLDCLEANERS covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

EU-COLDCLEANER5 A parts cleaner station with closeable 01-01-1980 FG-COLDCLEANERS covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

Page 1 3 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 EU-BOILER1 E M I S S I O N UNIT CONDITIONS DESCRIPTION Alternate plant space heating boiler -- No. 2 fuel oil (28.56 MMBTU/hr heat input).

Flexible Group ID: FG-MACT JJJJJJ POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

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

1. SO% 0.31 lb/MMBTU?:.<< Hourly EU-BOILER1 SC V. 1 R 336.1401 SCVl.1

2. SO, 20 tpy 12-month rolling time EU-BOILER1 SC Vl.2 R 336.1205(1 )(a)(ii)(D) period as determined R 336.1401 at the end of each 40 CFR 52.21(c) and (d) calendar month

3. NOx 0 . 1 5 lb/MMBTU2 Hourly EU-BOILER1 SCV.1 R 336.2803 R 336.2804

4. NOx 1 1 tpy° 12-month rolling time EU-BOILER1 S C V l. 2 R 336.1205(1 )(a)(ii)(D) period as determined R 336.2803 at the end of each R 336.2804 calendar month 40 CFR 52.21(c) and (d)

Equivalent to using fuel oil with a 0.30% sulfur content and higher heating value of 136,000 BTU/gal.

a In accordance with Rule 2 1 3 ( 2 ) and Rule 2 1 3 ( 6 ) , compliance with this streamlined emission limit shall be considered compliance with the SO2 emission limit in/established by R 3 3 6 . 1 4 0 1 ; and also compliance with the SO2 emission limit in/established by 40 CFR Part 60.42c(d), an additional applicable requirement that has been subsumed within this condition.

5. Visible emissions from EU-BOILER1 shall not exceed a six-minute average of 20 percent opacity, except as 2

specified in R 3 3 6 . 1 3 0 1 ( 1 ) ( a ) . (R 3 3 6 . 1 3 0 1 , R 3 3 6 . 1 3 3 1 , 40 CFR 60.43c)

II. MATERIAL LIMIT{S)

1. The sulfur content of the No. 2 fuel oil used in EU-BOILER1 shall not exceed 0.30 percent by weight.2 (R 3 3 6 . 1 2 0 1 ( 3 ) , R 336.1225, R 3 3 6 . 1 4 0 1 )

111. PROCESS/OPERATIONAL RESTRICTION(S)

1. The SOa emission limits shall apply at all times, including periods of start-up, shut-down, and malfunctions.?

(R 336.1205, R 336.1401)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA Page 14 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 V. TESTING/SAMPLING

1. Upon request of the AQD District Supervisor, the permittee shall verify NOx and SOz emission rates from EU-BOILER1 by testing at owner's expense, in accordance with the Department requirements. Testing shall be performed using an approved EPA Method listed in:

Pollutant Test Method Reference NOx 40 CFR Part 60, Appendix A SO 40 CFR Part 60, Appendix A An alternate method, or a modification to the approved EPA Method, may be specified in an AQD approved Test Protocol and must meet the requirements of the federal Clean Air Act, all applicable state and federal rules and regulations, and be within the authority of the AQD to make the change. No less than 30 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The AQD must approve the final plan prior to testing, including any modifications to the method in the test protocol that are proposed after initial submittal. The permittee must submit a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days following the last date of the test.

(R 336.1213(3), R 336.2001, R 336.2003, R 336.2004)

VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 3 3 6 . 1 2 1 3 ( 3 )( b )( i i ))

1. The permittee shall keep records of, in a satisfactory manner, the maximum Sulfur content, density, and higher heating value of the fuel from each supplier. If supplier certification is used for this purpose, records of certification must contain the name of the supplier and a statement from the supplier that the oil complies with the 2

requirements of 40 CFR 60.48c. (R 336.1205, R 336.1225, R 3 3 6 . 1 3 3 1 , R 336.1702, R 3 3 6 . 1 9 0 1 )

2. The permittee shall keep in a satisfactory manner, calculated on a monthly basis, 12-month rolling time period emission calculation records for SO2 and NO for E U - B O I L E R 1 . All records shall be kept on file and made available to the Department upon request.? (R 336.1205(1)(a))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

4. The permittee shall submit any performance test reports to the AQD Technical Programs Unit and District Office, in a format approved by the AQD. (R 336.1213(3)(c), R 336.2001(5))

See Appendix 8 Page 1 5 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 VIII. STACK/VENT RESTRICTION(S The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust Minimum Height Underlying Applicable Diameter/ Dimensions Above Ground Requirements (inches) (feet) 2 2

1. SVBOILER1 24 22 R 336.1225 R 336.2803 R 336.2804 40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENT(S)

1. The facility shall comply with all the applicable provisions of 40 CFR Part 60, Subpart De - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. (40 CFR Part 60, Subpart De)

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 2 0 1 ( 1 )( b ) .

2 This condition is federally enforceable and was established pursuant to Rule 2 0 1 ( 1 ) ( a ) .

Page 1 6 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 D. FLEXIBLE GROUP SPECIAL C O N D I T I O N S Part D outlines the terms and conditions that apply to more than one emission unit. The permittee is subject to the special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If there are no special conditions that apply to more than one emission unit, this section will be left blank.

FLEXIBLE GROUP

SUMMARY

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

Flexible Group ID Flexible Group Description Associated Emission Unit IDs FG-EMERDIESELS Four 3,500 kW large bore emergency diesel generators EU-1ABEDG located inside the main building. EU-1CDEDG EU-2ABEDG EU-2CDEDG FG-ENGINES Two 5,000 kW large bore supplemental diesel EU-12-EP-DG-1 generators. EU-12-EP-DG-2 FG-MACTZZZZ<500 40 CFR Part 63, Subpart Z.Z:Z.Z - National Emission EU-SECDIESELGEN Standards for Hazardous Air Pollutants for Stationary EU-DSLFIREPUMP1 Reciprocating Internal Combustion Engines (RICE), EU-DSLFIREPUMP2 located at an area source of HAP emissions, existing EU-TRGCTRDSLGEN emergency, spark ignition (SI) RICE equal to or less EU-MAINGATEDSLGEN than 500 bhp. A RICE is existing if the date of EU-COMTWRPRGEN installation is before June 1 2 , 2006.

FG-MACTZZZZ>500 40 CFR Part 63, Subpart ZZZZ - National Emission EU-1ABEDG Standards for Hazardous Air Pollutants for Stationary EU-1CDEDG Reciprocating Internal Combustion Engines (RICE), EU-2ABEDG located at an area source of HAP emissions, existing EU-2CDEDG emergency, spark ignition (SI) RICE greater than 500 EU-12-EP-DG-1 brake hp. A RICE is existing if the date of installation is EU-12-EP-DG-2 before June 1 2 , 2006.

FG-MACTJJJJJJ Requirements for an existing large ( 2 1 0 MMBTU/hr) oil EU-BOILER1 fired industrial, commercial, or institutional boiler that is equipped with an oxygen trim system and is located at an area source of hazardous air pollutants per 40 CFR Part 63, Subpart J J J J J J .

F G - N S P S I II I Emergency reciprocating internal combustion engines EU-DRYCASKDSLGEN (RICE) at the facility subject to 40 CFR Part 60, Subpart EU-U1 D I S G E N E RA TOR 11 11 . Standards of Performance for Stationary EU-U2DIS GENERATOR Compression Ignition Internal Combustion Engines.

EU-DRYCASKDSLGEN is rated at 1 3 2 HP (80 kilowatts (kW)) diesel-fueled emergency engine with a model year of 2 0 1 1 or later, and a displacement of 4.5 liters/cylinder.

EU-U1DISGENERATOR and EU-U2DISGENERA TOR are each rated at 24.3 hp (15 kw) diesel-fueled emergency engines with a model year of 2 0 1 1 or later, and displacements of 1 . 6 5 liters/cylinder.

Page 1 7 of 47

ROP No: MI-ROP-84252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 Flexible Group ID Flexible Group Description Associated Emission Unit IDs FG-RULE287(2)(c) Any emission unit that emits air contaminants and is EU-PAINTSHOP exempt from the requirements of Rule 201 pursuant to Rule 278, Rule 278a and Rule 287(2)(c). Emission units installed/modified before December 20, 2016, may show compliance with Rule 287 in effect at the time of installation/modification.

FG-COLDCLEANERS Any cold cleaner that is grandfathered or exempt from EU-COLDCLEANER1 Rule 201 pursuant to Rule 278, Rule 278a and Rule EU-COLDCLEANER2 2 8 1 ( 2 ) ( ) or Rule 285(2)(r)(iv). Existing cold cleaners EU-COLDCLEANER3 were placed.into operation prior to July 1 , 1979. New EU-COLDCLEANER4 cold cleaners were placed into operation on or after EU-COLDCLEANER5 July 1 , 1979.

Page 1 8 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 FG-EMERDIESELS FLEXIBLE GROUP C O N D I T I O N S DESCRIPTION Four 3,500 kW large bore emergency diesel generators located inside the main building.

Emission Units: EU-1ABEDG, E U - 1 C D E D G , EU-2ABEDG, EU-2CDEDG POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT{S)

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

1. SO% 0.33 lb/MMBTU2.° 24-hour average EU-1ABEDG SC V. 1 , SC Vl. 1 R 336.1401 EU-1CDEDG 40 CFR 52.21(c) and (d)

EU-2ABEDG EU-2CDEDG This is equivalent to using oil with a 0.3% sulfur content and heat value of 1 8 , 0 0 0 BTUs per pound.

2. Visible emissions from the emergency generators in FG-EMERDIESELS shall not exceed a 6-minute average of 2

20% opacity, except as specified in Rule 3 0 1 ( 1 )( a ) . (R 3 3 6 . 1 3 0 1 )

II. MATERIAL LIMIT(S)

NA Ill. PROCESS/OPERATIONAL RESTRICTION($)

1. The permittee sha ll not operate the emergency generators in FG-EMERDIESELS when electric power is 2

available, except during periods of maintenance checks and operator training. (R 336.1225, R 336.1702, 40 CFR 52.21(c) and (d))

IV. DESIGN/EQUIPMENT PARAMETER{$)

NA V. TESTING/SAMPLING Records sha ll be maint a ined on file for a period of five years. (R 3 3 6 . 1 2 1 3 ( 3 )( b )( i i ))

1. Upon request of the AQD District Supervisor, the permittee shall verify SOz emission rates from one or more representative units of FG-EMERDIESELS by testing at owner's expense, in accordance with the De p art ment requirements. Testing shall be performed using an approved EPA Method listed in:

Pollutant Test Method Reference

$Oz 40 CFR Part 60, A endi x A An alternate method, or a modification to the approved EPA Method, may be specified in an AQD approved Test Protocol and must meet the requirements of the federal Clean Air Act, all a pp licable state and federal rules and regulations, and be within the authority of the AQD to ma k e the change. No less than 30 days prior to te s ting, the permittee sha ll submit a complete test plan to the AQD Technical Programs Unit and District Office. The Page 1 9 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PTl-84252-2023 AQD must approve the final plan prior to testing, including any modifications to the method in the test protocol that are proposed after initial submittal. The permittee must submit a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days following the last date of the test.

(R 3 3 6 . 1 2 1 3 ( 3 ) , R 336.2001, R 336.2003, R 336.2004)

VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for diesel fuel oil used in FG-EMERDIESELS, demonstrating that the fuel meets the requirement of SC 1. 1 . The certification or test data shall include the name of the oil supplier or laboratory, the sulfur content, and the heating value of the fuel oil. The permittee shall keep all records on file and make them available to the department upon request. (R 3 3 6 . 1 2 1 3 ( 3 ))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 2 1 and 22 of Part A. (R 3 3 6 . 1 2 1 3 ( 3 )( c )( i i ))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

4. The permittee shall submit any performance test reports to the AQD Technical Programs Unit and District Office, in a format approved by the AQD. (R 336.1213(3)(c), R 336.2001(5))

See Appendix 8 VIII. STACK/VENT RESTRICTION(S)

NA IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable requirements of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR Part 63, Subparts A and ZZZZ for Stationary Reciprocating Internal Combustion Engines. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 2 0 1 ( 1 ) ( b ) .

2 This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a).

Page 20 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 FG-ENGINES FLEXIBLE GROUP C O N D I T I O N S DESCRIPTION Two 5,000 kW large bore supplemental diesel generators.

Emission Units: E U - 1 2 - E P - D G - 1 , EU-12-EP-DG-2 POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

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

1. NOx 5 1 5 lb/1000 Hourly FG-ENGINES SC V.1 R 336.1205(1)(a) 2 gal SCVl.1 S C V l .4 II. MATERIAL LIMIT(S)

1. The permittee shall burn only diesel fuel in FG-ENGINES.' (R 336.1224, R 336.1225)

2. If any electricity produced by FG-ENGINES is sold to a utility power distribution system, the sulfur content of the diesel fuel used in FG-ENGINES shall not exceed 0.05 percent by weight on an annual average. The annual average shall be calculated as specified in 40 CFR 72.7()(3). (40 CFR 72.7)

3. The combined diesel fuel use for all units included in FG-ENGINES shall not exceed 1 3 6 , 0 0 0 gallons per 12 2

month rolling time period. (R 336.1205(1)(a), R 336.1224, R 336.1225, R 336.1702(a), 40 CFR 52.21(c) and (d))

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall operate FG-ENGINES in accordance with manufacturer's recommendations for safe and 2

proper operation to minimize emissions during periods of start-up, shutdown, and malfunction. (R 3 3 6 . 1 9 1 2 )

2

2. The total capacity from each unit included in FG-ENGINES shall not exceed 5 MW. (40 CFR 72.7)

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Verification of the NOx emission limit (515 pounds NOx per 1000 gallon fuel used) from one or more representative units of FG-ENGINES, by testing at owner's expense, in accordance with Department requirements may be required. No less than 60 days prior to testing, a complete test plan shall be submitted to the AQD. The final plan must be approved by the AQD prior to testing. Verification of the emission factor includes 2

the submittal of a complete report of the test results to the AQD within 60 days following the last date of the test.

(R 336.1205(1)(a), R 336.2001, R 336.2003, R 336.2004)

Page 21 of 47

h ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI NO: MI-PT1-B4252-2023

2. Testing shall be performed using an approved EPA Method listed in:

Pollutant Test Method Reference NOx 40 CFR Part 60, A endix A An alternate method, or a modification to the approved EPA Method, may be specified in an AQD approved Test Protocol and must meet the requirements of the federal Clean Air Act, all applicable state and federal rules and regulations, and be within the authority of the AQD to make the change. No less than 30 days prior to testing, the permittee shall submit a complete test plan to the AQD Technical Programs Unit and District Office. The AQD must approve the final plan prior to testing, including any modifications to the method in the test protocol that are proposed after initial submittal. The permittee must submit a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days following the last date of the test.

(R 336.1213(3), R 336.2001, R 336.2003, R 336.2004)

VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 3 3 6 . 1 2 1 3 ( 3 )( b )( i i ))

1. The permittee shall install, calibrate, maintain, and operate in a satisfactory manner, a device to monitor and record the fuel use for FG-ENGINES on a monthly basis. (R 336.1205(1)(a), R 336.1220, R 336.1224, R 336.1225, R 336.1702(a), 40 CFR 52.21(c) and (d))

2. The permittee shall keep, in a satisfactory manner, records of the date, duration and description of any malfunction, any maintenance performed, and any testing results for FG-ENGINES. All records shall be kept on 2

file and made available to the Department upon request. (R 3 3 6 . 1 9 1 2 )

3. If any electricity produced by FG-ENGINES is sold to a utility power distribution system, the permittee shall keep records of the sulfur content calculated in percent by weight, on an annual average as required by SC 11 . 2 . All 2

records shall be kept on file and made available to the Department upon request. (40 CFR 72.7)

4. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling time period fuel use records for 2

FG-ENGINES . The records must indicate the total amount of fuel use in FG-ENGINES. (R 3 3 6 . 1 2 0 5 ( 1 )( a ) ,

R 336.1224, R 336.1225, R 336.1702(a), 40 CFR 52.21(c) and (d))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

4. The permittee shall submit any performance test reports to the AQD Technical Programs Unit and District Office, in a format approved by the AQD. (R 336.1213(3)(c), R 336.2001(5))

See Appendix 8 VIII. STACK/VENT RESTRICTION(S)

1. The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards 2

to the ambient air. (R 336.1225, 40 CFR 52.21(c) and (d))

Page 22 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 IX. OTHER REQUIREMENT(S)

1. The permittee shall not replace or modify FG-ENGINES, or any portion of FG-ENGINES, unless all of the following conditions are met:? (R 336.1201 a ( 1 ))

a. The permittee shall update the general permit submitting a new Process Information Form (EQP5787) to the Permit Section and District Supervisor identifying the existing and new equipment a m i n i m u m of 1 0 days before the equipment is replaced or modified.

b. The permittee shall continue to meet all general permit to install applicability criteria after the replacement or modification is complete.

c. The permittee shall keep all records of the date and description of the replacement or modification.

2. The permittee shall comply with all applicable requirements of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR Part 63, Subparts A and ZZZZ for Stationary Reciprocating Internal Combustion Engines. (40 CFR Part 63, Subparts A and ZZZZ)

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 2 0 1 ( 1 )( b ) .

2 This condition is federally enforceable and was established pursuant to Rule 2 0 1 ( 1 ) a ) .

Page 23 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 FG-MACTZZZZ<500 FLEXIBLE GROUP CONDITIONS DESCRIPTION 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE), located at a area source of HAP emissions, existing emergency, compression ignition (Cl) RICE equal to or less than 500 brake hp. A RICE is existing if the date of installation is before J u n e 1 2 , 2006.

Emission Units: EU-SECDIESELGEN, EU - D S L F I R E P U M P 1 , EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGEN, EU-COMTWRPRGEN POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

NA II. MATERIAL LIMIT(S)

1. The permittee shall burn only diesel fuel in each engine with a maximum sulfur content of 1 5 ppm ( 0 . 0 0 1 5 percent) by weight and a minimum Cetane index of 40 or a maximum aromatic content of 35 volume percent.

(40 CFR 63.6604(b), 40 CFR 1090.305)

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee must comply with the requirements in Item 4 of Table 2d of 40 CFR Part 63, Subpart ZZZZ which apply to each engine in FG-MACTZZZZ<500 as specified in the following:

a. Chan g e oil and fi lter every 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months of operation or annually, whichever comes fi rst, except as allowed in S C 11 1. 2;

b. Inspect the air cleaner every 1 , 0 0 0 hours0 days 0 hours 0 weeks 0 months of operation or annually, w hiche v er comes fi rst, and replace as necessary; and

c. Inspect all hoses and belts every 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months of operation or annuall y , w hichever comes fi rst, and replace as necessary.

If t he emergency engine is being operated du ring an emergen c y and it is not possible to shut down the e n g ine to p erform the management practice requirements on the s c hedule re q uired, or if pe rf orming the work practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice sh ould be performed as soon as practicable after the emergency h as ended or the unacceptable risk under Federal, State or local law has been abated. Sources must report any failure to perform the management practice on the sche d ule required and the Federal, State or local law or whi c h the risk was deemed unacceptable. (40 CFR 63.6603(a), 40 CFR Part 63, Subpart zZZZ, Table 2d.4)

2. The permittee m ay utilize an oil analysis program in o rder to extend the specified oil change requirement in SC 111 .1. The o il analysis mus t be performed at the same frequency specified for c h anging the o il in S C 111 .1.

(40 CFR 63.6625(i))

Page 24 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023

3. The permittee shall operate and maintain each engine in FG-MACTZZZZS500 and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (40 CFR 63.6605, 40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR Part 63, Subpart 'ZZZ2., Table 6.9)

4. For each engine in FG-MACTZZZZ<500, the permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply.

(40 CFR 63.6625(h))

5. The permittee may operate each engine in FG-MACTZZZZ<500 for no more than 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year for the purpose of necessary maintenance checks and readiness testing, provided that the tests are recommended by Federal, State, or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The permittee may petition the Department for approval of additional hours to be used for maintenance checks and readiness testing. A petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency internal combustion engines beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year. (40 CFR 63.6640(f)(2))

6. Each engine in FG-MACTZZZZ<500 may be operated for up to 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per calendar year in non-emergency situations. The 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months of operation in non-emergency situations are counted as part of the 1 0 0 hours0 days 0 hours 0 weeks 0 months per 1

calendar year for maintenance and testing provided in SC 111.5. The 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per calendar year for non emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for the permittee to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (40 CFR 63.6640(f)(4))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall equip and maintain each engine in FG-MACTZZZZS500 with non-resettable hours meters to track the operating hours. (40 CFR 63.6625(f))

V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. If using the oil analysis program, the permittee must at a m i n i m u m analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows:

Total Base Number is less than 30% of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20% from the viscosity of the oil when new; or percent water content (by volume) is greater than 0 . 5 . If all these condemning limits are not exceeded, the permittee is not required to change the oil. If any of the limits are exceeded, the permittee must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the permittee must change the oil within 2 business days or before commencing operation, whichever is later. The permittee must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (40 CFR 63.6625(i))

VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. For each engine in FG-MACTZZZZ<500, the permittee shall keep in a satisfactory manner the following:

a. A copy of each notification and report that was submitted to comply with 40 CFR Part 63, Subpart ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted, Page 25 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PTl-84252-2023

b. Records of the occurrence and duration of each malfunction of operation or the air pollution control and monitoring equipment,

c. Records of performance tests and performance evaluations,

d. Records of all required maintenance performed on the air pollution control and monitoring equipment,

e. Records of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.

The permittee shall keep all records on file and make them available to the department upon request. (40 CFR 63.6655(a), 40 CFR 63.6660)

2. For each engine in FG-MACTZZZZ<500, the permittee shall keep in a satisfactory manner, records to demonstrate continuous compliance with the operation and maintenance of the engine according to the manufacturer's emission-related operation and maintenance instructions; or develop and follow a maintenance plan that provides to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The permittee shall keep all records on file and make them available to the department upon request. (40 CFR 63.6655(d), 40 CFR 63.6660, 40 CFR Part 63, Subpart ZZZ.Z, Table 6.9)

3. For each engine in FG-MACTZZZZ<500, the permittee shall keep in a satisfactory manner, records of the maintenance conducted to demonstrate that the engine and after-treatment control device (if any) were operated and maintained according to the developed maintenance plan. The permittee shall keep all records on file and make them available to the department upon request. (40 CFR 63.6655(e), 40 CFR 63.6660)

4. The permittee shall monitor and record, the total hours of operation for each engine in FG-MACTZZZZ<500 on a monthly basis, and the hours of operation during emergency and non-emergency service that are recorded through the non-resettable hour meter for each engine in FG-MACTZZZZ<500 on a calendar year basis, in a manner acceptable to the AQD District Supervisor. The permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. The permittee shall keep all records on file and make them available to the department upon request. (R 3 3 6 . 1 2 1 3 ( 3 ) 40 CFR 63.6655(f), 40 CFR 63.6660)

5. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for diesel fuel oil used in FG-MACTZZZZ<500, demonstrating that the fuel meets the requirement of SC 1 1. 1 . The certification or test data shall include the name of the oil supplier or laboratory, the sulfur content, and cetane index or aromatic content of the fuel oil. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3), 40 CFR 1090.305)

6. The permittee's records must be in a form suitable and readily available for expeditious review according to 40 CFR 6 3 . 1 0 ( b )( 1 ) . (40 CFR 63.6660(a))

7. As specified in 40 CFR 6 3 . 1 0 ( b ) ( 1 ) , the permittee must keep each record for 5-years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. (40 CFR 63.6660(b))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 2 1 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

Page 26 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PT1-B4252-2023 See Appendix 8 VIII. STACK/VENT RESTRICTION($)

NA IX. OTHER REQUIREMENT{S)

1. The permittee shall comply with all applicable requirements of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR Part 63, Subparts A and ZZZZ for Stationary Reciprocating Internal Combustion Engines. (40 CFR Part 63, Subparts A and ZZZZ)

Page 27 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 FG-MACTZZZZ>500 FLEXIBLE GROUP CONDITIONS DESCRIPTION 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE), located at an area source of HAP emissions, existing emergency, compression ignition (Cl) RICE greater than 500 brake hp. A RICE is existing if the date of installation is before June 1 2 , 2006.

Emission Units: EU-1ABEDG, E U - 1 C D E D G , EU-2ABEDG, EU-2CDEDG, E U - 1 2 - E P - D G - 1 , EU-12-EP-DG-2 POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

NA II. MATERIAL LIMIT(S)

1. The permittee shall burn only diesel fuel in each engine with a maximum sulfur content of 1 5 ppm ( 0 . 0 0 1 5 percent) by weight and a minimum Cetane index of 40 or a maximum aromatic content of 35 volume percent.

(40 CFR 63.6604(b), 40 CFR 1090.305)

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee must comply with the requirements in Item 4 of Table 2d of 40 CFR Part 63, Subpart ZZZZ which apply to each engine in FG-MACTZZZZ>500 as specified in the following:

a. Change oil and filter every 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months of operation or annually, whichever comes first, except as allowed in SC 11 1. 2 ;

b. Inspect the air cleaner every 1 , 0 0 0 hours0 days 0 hours 0 weeks 0 months of operation or annually, whichever comes first, and replace as necessary; and

c. Inspect all hoses and belts every 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months of operation or annually, whichever comes first, and replace as necessary.

If the emergency engine is being operated during an emergency and it is not possible to shut down the engine to perform the management practice requirements on the schedule required, or if performing the work practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State or local law has been abated. Sources must report any failure to perform the management practice on the schedule required and the Federal, State or local law or which the risk was deemed unacceptable. (40 CFR 63.6603(a), 40 CFR Part 63, Subpart Z:Z:Z.Z., Table 2d.4)

2. The permittee may utilize an oil analysis program in order to extend the specified oil change requirement in SC 111 . 1 . The oil analysis must be performed at the same frequency specified for changing the oil in SC 11 1. 1 .

(40 CFR 63.6625())

Page 28 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023

3. The permittee shall operate and maintain each engine in FG-MACTZZZZ>500 and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (40 CFR 63.6605, 40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR Part 63, Subpart ZZZZ, Table 6.9)

4. For each engine in FG-MACTZZZZ>500, the permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply.

(40 CFR 63.6625(h))

5. The permittee may operate each engine in FG-MACTZZZZ>500 for no more than 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year for the purpose of necessary maintenance checks and readiness testing, provided that the tests are recommended by Federal, State, or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The permittee may petition the Department for approval of additional hours to be used for maintenance checks and readiness testing. A petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency internal combustion engines beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year. (40 CFR 63.6640(f)(2))

6. Each engine in FG-MACTZZZZ>500 may be operated for up to 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per calendar year in non-emergency situations. The 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months of operation in non-emergency situations are counted as part of the 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year for maintenance and testing provided in SC 111.5. The 50 hours per calendar year for non emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for the permittee to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (40 CFR 63.6640(f)(4))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall equip and maintain each engine in FG-MACTZZZZ>500 with non-resettable hours meters to track the operating hours. (40 CFR 63.6625(f))

V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. If using the oil analysis program, the permittee must at a m i n i m u m analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows:

Total Base Number is less than 30% of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20% from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all these condemning limits are not exceeded, the permittee is not required to change the oil. If any of the limits are exceeded, the permittee must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the permittee must change the oil within 2 business days or before commencing operation, whichever is later. The permittee must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine.

(40 CFR 63.6625(i))

VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. For each engine in FG-MACTZZZZ>500, the permittee shall keep in a satisfactory manner the following:

a. A copy of each notification and report that was submitted to comply with 40 C FR Part 63, Subpart ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted, Page 29 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023

b. Records of the occurrence and duration of each malfunction of operation or the air pollution control and monitoring equipment,

c. Records of performance tests and performance evaluations,

d. Records of all required maintenance performed on the air pollution control and monitoring equipment,

e. Records of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.

The permittee shall keep all records on file and make them available to the department upon request.

(40 CFR 63.6655(a), 40 CFR 63.6660)

2. For each engine in FG-MACTZZZZ>500, the permittee shall keep in a satisfactory manner, records to demonstrate continuous compliance with the operation and maintenance of the engine according to the manufacturer's emission-related operation and maintenance instructions; or develop and follow a maintenance plan that provides to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The permittee shall keep all records on file and make them available to the department upon request. (40 CFR 63.6655(d), 40 CFR 63.6660, 40 C F R Part 63, Subpart ZZZZ, Table 6.9)

3. For each engine in FG-MACTZZZZ>500, the permittee shall keep in a satisfactory manner, records of the maintenance conducted to demonstrate that the engine and after-treatment control device (if any) were operated and maintained according to the developed maintenance plan. The permittee shall keep all records on file and make them available to the department upon request. (40 CFR 63.6655(e), 40 C F R 63.6660)

4. The permittee shall monitor and record, the total hours of operation for each engine in FG-MACTZZZZ>500 on a monthly basis, and the hours of operation during emergency and non-emergency service that are recorded through the non-resettable hour meter for each engine in FG-MACTZZZZ>500 on a calendar year basis, in a manner acceptable to the AQD District Supervisor. The permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3), 40 CFR 63.6655(f), 40 CFR 63.6660)

5. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for diesel fuel oil used in FG-MACTZZZZ>500, demonstrating that the fuel meets the requirement of SC 1 1. 1 . The certification or test data shall include the name of the oil supplier or laboratory, the sulfur content, and cetane index or aromatic content of the fuel oil. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3), 40 CFR 1090.305)

6. The permittee's records must be in a form suitable and readily available for expeditious review according to 40 CFR 6 3 . 10 ( b ) ( 1 ). (40 CFR 63.6660(a))

7. As specified in 40 CFR 6 3. 1 0 ( b ) ( 1 ) , the permittee must keep each record for 5-years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. (40 CFR 63.6660(b))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

Page 30 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 See Appendix 8 VIII. STACKNENT RESTRICTION(S)

NA IX. OTHER REQUIREMENT{$)

1. The permittee shall comply with all applicable requirements of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR Part 63, Subparts A and ZZZZ for Stationary Reciprocating Internal Combustion Engines. (40 CFR Part 63, Subparts A and ZZZZ)

Page 31 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 FG-MACTJJJJJJ FLEXIBLE GROUP CONDITIONS DESCRIPTION Requirements for an existing large (210 MMBTU/hr) oil-fired industrial, commercial, or institutional boiler that is equipped with an oxygen trim system and is located at an area source of hazardous air pollutants per 40 CFR Part 63, Subpart JJJJJJ.

Emission Unit: EU-BOILER1 POLLUTION CONTROL EQUIPMENT Oxygen analyzer and trim systems I. EMISSION LIMIT(S)

NA II. MATERIAL LIMIT{S)

NA Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. Each boiler in FG-MACT JJJJJJ with an oxygen trim system that maintains an optimum air-to-fuel ratio must conduct a tune-up every 5 years as specified in SC 11 1. 3 . Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The permittee may delay the burner inspection and inspection of the system controlling the air-to-fuel ratio until the next scheduled unit shutdown , but the permittee must inspect each b urner and system controlling the air-to-fuel ratio at least once every 72 months. (40 CFR 63.11223(c), 40 CFR Part 63, Subpart JJJJJJ, Table 2.14)

2. For each boiler in FG-MACTJJJJJJ, the permittee must conduct the tune-up while b urning the type of fuel (or fuels in the case of boilers that routinely b urn tw o types of fuels at the same time) that provided the majority of the heat input to the b oiler over the 12 months p rior to the tune-u p . (40 CFR 6 3 . 1 1 2 2 3 ( a ))

3. The permittee must conduct a tune-up of each boiler in FG-MACT J J JJJJ to demonstrate continuous compliance as specified below:

a. A s applicable , inspect the b urner, and clean or replace any component s of the burner as necessa ry .

(40 CFR 6 3 . 1 1 2 2 3 ( b )( 1 ))

b. I nspect the flame p att ern, as a p p li cable, and adjust the burner as necessa ry to optimize the flame pattern.

The adjustment should be consistent with the manufacturer's s p ecifications, if available.

(40 CFR 63.11223(b)(2))

c. Inspect the system controlling the air-to-fuel ratio, as ap pl icable, and ensure that it is correctly calibrated and functioning properly. (40 CFR 6 3 . 1 1 2 2 3 ( b )( 3 ))

d. O ptimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject.

(40 CFR 63.11223(b)(4))

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ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PT1-B4252-2023

e. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. (40 CFR 63.11223(b)(5))

f. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. (40 CFR 63.11223(b)(7))

4. At all times, the permittee must operate and maintain each boiler in FG-MACTJJJJJJ, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the permittee to make any further efforts to reduce emissions if levels required by 40 CFR Part 63, Subpart JJJJJJ have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (40 CFR 63.11205(a))

IV. DESIGN/EQUIPMENT PARAMETER(S)

NA V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee must maintain the records specified below:

a. The permittee must keep a copy of each notification and report that was submitted to comply with 40 CFR Part 63, Subpart JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted. (40 CFR 6 3 . 1 1 2 2 5 ( c ) ( 1 ))

b. The permittee must keep records to document conformance with the work practices, emission reduction measures, and management practices required by 40 CFR 6 3 . 1 1 2 2 3 , as listed below:

i. Records must identify each boiler in FG-MACTJJJJJJ, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. (40 CFR 63.11225(c)(2)(i))

ii. For operating units that combust non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR 2 4 1 . 3 ( b ) ( 1 ) , the permittee must keep a record which documents how the secondary material meets each of the legitimacy criteria under 40 CFR 2 4 1 . 3 ( ) ( 1 ) . If the permittee combusts a fuel that has been processed from a discarded non-hazardous secondary material pursuant to 40 CFR 241.3(b)(4), the permittee must keep records as to how the operations that produced the fuel satisfies the definition of processing in 40 C F R 2 4 1 . 2 and each of the legitimacy criteria in 40 CFR 2 4 1 . 3 ( d )( 1 ) . If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR 2 4 1 . 3 ( c ) , the permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary material as fuel per 40 C F R 2 4 1 . 4 , the permittee must keep records documenting that the material is a listed non-waste under 40 CFR 2 4 1 . 4 ( a ) . (40 CFR 63.11225(c)(2)(ii))

iii. The permittee must maintain a copy of the energy assessment report for each boiler in FG-MACTJJJJJJ.

(40 CFR 63.11225(c)(2)(iii))

c. Records of the occurrence and duration of each malfunction of the boiler. (40 CFR 63.11225(c)(4))

Page 33 of 47 J

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023

d. Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR 6 3 . 1 1 2 0 5 ( a ) , including corrective actions to restore the malfunctioning boiler to its normal or usual manner of operation. (40 CFR 6 3.1 1 225(c )(5 ))

2. The permittee must maintain on-site and submit, if requested by the Administrator, a report containing the information listed below.

a. The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of each boiler in FG-MACT JJJJJJ.

(40 CFR 63.11223(b)(6)(i))

b. A description of any corrective actions taken as a part of the tune-up of each boiler in FG-MACT JJJJJJ.

(40 CFR 6 3 . 1 1 2 2 3 ( b )( 6 )( i i ))

c. The type and amount of fuel used over the 1 2 months prior to the tune-up of each boiler in FG-MACT JJJJJJ, but only if the unit was physically and legally capable of using more than one type of fuel during that period.

Units sharing a fuel meter may estimate the fuel use by each unit. (40 CFR 63.11223(b)(6)(iii))

3. The permittee must keep the records in a form suitable and readily available for expeditious review. The permittee must keep each record for 5 years following the date of each recorded action. The permittee must keep each record on-site or be accessible from a central location by computer or other means that instantly provide access at the site for at least 2 years after the date of each recorded action. The permittee may keep the records off site for the remaining 3 years. (40 CFR 63.11225(d))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 3 3 6 . 1 2 1 3 ( 3 )( c )( i i ) )

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

4. The permittee must prepare, by March 1 of the year after the calendar year during which a tune-up is completed, and submit to the delegated authority upon request, a 5-year compliance report containing the information specified below:

a. Company name and address. (40 CFR 6 3 . 1 1 2 2 5 ( b )( 1 ))

b. Statement by a responsible official, with the official's name, title, phone number, email address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of 40 CFR Part 63, Subpart JJJJJJ. The permittee's notification must include the following certifications of compliance, as applicable, and signed by a responsible official: (40 CFR 63.11225(b)(2))

i. "This facility complies with the requirements in 40 CFR 63.11223 to conduct 5-year tune-up, as applicable, of each boiler in FG-MACTJJJJJJ." (40 CFR 63.11225(b)(2)(i))

ii. For units that do not qualify for a statutory exemption as provided in Section 1 2 9 ( g )( 1 ) of the Clean Air Act: "No secondary materials that are solid waste were combusted in any affected unit."

(40 CFR 6 3 . 1 1 2 2 5 ( b )( 2 )( i i ))

See Appendix 8 Page 34 of 47 t

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 VIII. STACK[VENT RESTRICTION(S NA IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources as specified in 40 CFR Part 63, Subparts A and JJJJJJ. (40 CFR Part 63, Subparts, A and JJJJJJ)

Page 35 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI NO: MI-PT1-B4252-2023 FG-NSPSIIII EMISSION UNIT CONDITIONS DESCRIPTION Emergency reciprocating internal combustion engines (RICE) at the facility subject to 40 CFR Part 60, Subpart 1111 -

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines.

EU-DRYCASKDSLGEN is rated at 1 3 2 HP (80 kilowatts (kW)) diesel-fueled emergency engine with a model year of 2 0 1 1 or later, and a displacement of 4 .5 liters/cylinder.

E U - U 1 D I S G E N E R A T O R and EU-U2DISGENERATOR are each rated at 24.3 hp ( 1 5 kW) diesel-fueled emergency engines with a model year of 2 0 1 1 or later, and displacements of 1 . 6 5 liters/cylinder.

Emission Units: EU-DRYCASKDSLGEN, EU-U1DISGENERATOR, EU-U2DISGENERATOR POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

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

1. NMHC + NOx 4.0 Hourly EU-DRYCASKDSLGEN SC V. 1 40 CFR 8 9 . 1 1 2 ( a ) ,

g/kW-hr S C V l. 2 40 CFR 1039

2. NMHC + NOx 7. 5 Hourly EU-U1 DISGENERATOR, SC V. 1 40 CFR 60.4202; g/kW-hr and S C V l. 2 40 CFR Part 60, or EU-U2DIS GENERATOR, Subpart 1111, Table 2 5.6 each individually g/hp-hr

3. co 3.5 Hourly EU-DRYCASKDSLGEN SCV.1 40 CFR 8 9 . 1 1 2 ( a ) ,

a/kW-hr S C V l. 2 40 CFR 1 0 3 9

4. co 6.6 Hourly EU-U1 DISGENERATOR, SC V. 1 40 CFR 60.4202; g/kW-hr and S C V l. 2 40 CFR Part 60, or EU-U2DISGENERATOR, Subpart 1111, Table 2 4.9 each individually g/hp-hr

5. PM 0.2 Hourly EU-DRYCASKDSLGEN SCV.1 40 CFR 89.112(a),

q/kW-hr S C V l. 2 40 CFR 1 0 3 9

6. PM 0.40 Hourly E U - U 1 DI S G E N E RA TOR, SC V. 1 40 CFR 60.4202; g/kW-hr and S C V l. 2 40 CFR Part 60, or EU-U2DIS GENERATOR, Subpart 1111, Table 2 0.30 each individually g/hp-hr II. MATERIAL LIMIT(S)

1. The permittee shall burn only diesel fuel in each engine in FG-NSPSIIII with a maximum sulfur content of 1 5 ppm

( 0 . 0 0 1 5 percent) by weight and a minimum Cetane index of 40 or a maximum aromatic content of 35 volume percent. (40 CFR 60.4207, 40 CFR 1090.305)

Page 36 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 III. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee may operate each engine in F G - N S P S II II for no more than 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year for the purpose of necessary maintenance checks and readiness testing, provided that the tests are recommended by Federal, State, or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine.

The permittee may petition the Department for approval of additional hours to be used for maintenance checks and readiness testing. A petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency internal combustion engines beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year. (40 CFR 60.4211 (f)(2))

2. The permittee may operate each engine in F G - N S P S I II I up to 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per calendar year in non-emergency situations, but those 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months are counted as part of the 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year provided for maintenance and testing as provided in 40 CFR 6 0 .4 2 1 1 (f)(2). Except as provided in 40 CFR 6 0 .4 2 1 1 (f)(3)(i), the 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (40 CFR 60.4211 (f)(3))

3. If the permittee purchased a certified engine, according to procedures specified in 40 CFR Part 60, Subpart 111 1 ,

for the same model year, the permittee shall meet the following requirements for each engine in F G - N S P S I II I :

a. Operate and maintain the certified engine and control device according to the manufacturer's emission-related written instructions,

b. Change only those emission-related settings that are permitted by the manufacturer, and

c. Meet the requirements as specified in 40 CFR 1 0 6 8 , as they apply to the engine.

If not operating and maintaining the certified engine and control device according to the manufacturer's emission related written instructions, the engine will be considered a non-certified engine. (40 CFR 60.4211(a) & (c))

4. If the permittee purchased a non-certified engine or a certified engine operating in a non-certified manner, the permittee shall keep a maintenance plan for each engine in F G - N S P S I [ l l and shall, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. (40 CFR 60.4211 (g)(3))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee must equip and maintain each engine in FG-NSPSIIII with non-resettable hours meters to track the operating hours. (40 CFR 60.4209)

V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 3 3 6 . 1 2 1 3 ( 3 )( b )( i i ))

1. If any engine in FG-NSPSll II is not installed, configured, operated, and maintained according to the manufacturer's emission-related written instructions, or the permittee changes emission-related settings in a way that is not permitted by the manufacturer, the permittee must demonstrate compliance as follows:

a. Conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after an engine and control device is no longer installed, configured, operated, and maintained in accordance with the manufacturer's emission-related written instructions, or within 1 year after you change emission-related settings in a way that is not permitted by the manufacturer.

b. If a performance test is required, the performance tests shall be conducted according to 40 CFR 6 0 .4 2 1 2 .

No less than 30 days prior to testing, a complete test plan shall be submitted to the AQD. The permittee must submit a complete report of the test results to the AQD Technical Programs Unit and District Office within 60 days following the last date of the test. (40 CFR 60.4211 (g)(1) & (2), 40 CFR 60.4212)

Page 37 of 47

ROP NO: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall keep, in a satisfactory manner, the following records for each engine in F G - N S P S I I I l :

a. For each certified engine: The permittee shall keep records of the manufacturer certification documentation.

b. For each uncertified engine: The permittee shall keep records of testing required in SC V . 1 .

The permittee shall keep all records on file and make them available to the Department upon request.

(40 CFR 6 0 . 4 2 1 1 )

2. The permittee shall keep, in a satisfactory manner, the following records of maintenance activity for each engine in FG-NSPSIIII:

a. For each certified engine: The permittee shall keep records of the manufacturer's emission-related written instructions, and records demonstrating that the engine has been maintained according to those instructions, as specified in SC 1 11 . 3 .

b. For each uncertified engine: The permittee shall keep records of a maintenance plan, as required by SC 11 1 . 4 ,

and maintenance activities.

The permittee shall keep all records on file and make them available to the Department upon request.

(40 CFR 6 0 . 4 2 1 1 )

3. The permittee shall monitor and record, the total hours of operation for each engine in F G - N S P S I III on a monthly and 12-month rolling time period basis, and the hours of operation during emergency and non-emergency service that are recorded through the non-resettable hour meter for each engine in F G - N S P S I I I I , on a calendar year basis, in a manner acceptable to the AQD District Supervisor. The permittee shall document how many hours are spent for emergency operation of each engine in FG-NSPSIIII, including what classified the operation as emergency and how man y hours are spent for non-emergency operation. (40 CFR 6 0 . 4 2 1 1 , 40 CFR 60.4214) 4 . The permittee shall keep, in a satisfactory m anner, fuel supplier certification records or fuel sample test data, for diesel fuel oil used in FG-NSPSIIII, demonstrating that the fuel meets the requirement of 40 CFR 1090 .305. T he certification or test data shall include the name of the oil supplier or laboratory, the sulfur content, and cetane index or aromatic content of the fuel oil. (R 3 3 6 . 1 2 1 3 ( 3 ) , 40 C F R 60.4207(b), 40 CFR 1090.305)

VII. REPORTING 1 . The permittee shall submit a notification speci fy ing whether each engine of FG - N SPSIIII will be operated in a certified or a non-certified manner to the AQD District Supervisor, in wri ti ng, w ithin 30 days following the initial startup of the en g ine a nd within 30 days of switching the manner of operation. (R 336.1213(3), 40 CFR Part 60, Subpart 1111)

VIII. STACK/VENT RESTRICTION(S)

NA IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with the provisions of the federal Standards of Performance for New Stationary Sources as specified in 40 CFR Part 60 , S u bparts A and 11 11 , as they apply to each engine of FG-NSPSIIII (40 CFR Part 60, Subparts A and 1111)

2. The permittee shall comply with the provisions of the National Emission Standards for H azardous Air Pollutants as specified in 40 CFR Part 6 3, Subparts A and ZZZZ , as they apply to each engine of FG-NSPSIIII (40 CFR 63.6590(c), 40 CFR Part 63, Subparts A and ZZZZ)

Page 38 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PT1-B4252-2023 FG-RULE287(2)(c)

FLEXIBLE GROUP C O N D I T I O N S DESCRIPTION Any emission unit that emits air contaminants and is exempt from the requirements of Rule 201 pursuant to Rule 278, Rule 278a and Rule 287(2)(c). Emission units installed/modified before December 20, 2 0 1 6 , may show compliance with Rule 287 in effect at the time of installation/modification.

Emission Units installed on or after December 20, 2 0 1 6 : NA Emission Units installed prior to December 20, 2 0 1 6 : EU-PAINTSHOP POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

NA II. MATERIAL LIMIT(S)

Material Limit Time Period/Operating Equipment Underlying Scenario Applicable Requirement

1. Coatings 200 Gallons/month Calendar month Each emission R 336.1287(2)(c)(i)

(minus water as unit applied)

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

NA IV. DESIGN/EQUIPMENT PARAMETER(S)

1. Any exhaust system installed on or after December 20, 2 0 1 6 , that serves only coating spray equipment shall be equipped with a dry filter control or water wash control which is installed, maintained, and operated in accordance with the manufacturer's specifications, or the permittee develops a plan which provides to the extent practicable for the maintenance and operation of the equipment in a manner consistent with good air pollution control practices for minimizing emissions. All emission units installed before December 20, 2016, with an exhaust system that serves only coating spray equipment must have a properly installed and operated particulate control system. (R 336.1213(2), R 336.1287(2)(c)(ii), R 3 3 6 . 1 9 1 0 )

V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA Page 39 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. The permittee shall maintain records of the following information for each emission unit for each calendar month using the methods outlined in the EGLE, AQD Rule 287(2)(c), Permit to Install Exemption Record form (EOP 3562) or in a format acceptable to the AQD District Supervisor. (R 336.1213(3))

a. Volume of coating used, as applied, minus water, in gallons. (R 336.1287(2)(c)(iii))

b. Documentation of any filter replacements or maintenance of water wash control for exhaust systems serving coating spray equipment or other documentation included in a plan developed by the owner or operator of the equipment. (R 3 3 6 . 1 2 1 3 ( 3 ))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 3 3 6 . 1 2 1 3 ( 3 ) ( c ) ( i i ))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

See Appendix 8 VIII. STACK/VENT RESTRICTION(S)

NA IX. OTHER REQUIREMENT(S)

NA Page 40 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 FG-COLDCLEANERS FLEXIBLE GROUP C O N D I T I O N S DESCRIPTION Any cold cleaner that is grandfathered or exempt from Rule 201 pursuant to Rule 278, Rule 278a and Rule 281 (2)(h) or Rule 285(2)(r)(iv). Existing cold cleaners were placed into operation prior to July 1 , 1979. New cold cleaners were placed into operation on or after July 1 , 1 979.

Emission Units: EU-COLDCLEANER1, EU-COLDCLEANER2, EU-COLDCLEANER3, EU-COLDCLEANER4, EU-COLDCLEANER5 POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

NA II. MATERIAL LIMIT{S)

1. The permittee shall not use cleaning solvents containing more than five percent by weight of the following halogenated compounds: methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride, chloroform, or any combination thereof. (R 3 3 6 . 1 2 1 3 ( 2 ))

Ill. PROCESS/OPERATIONAL RESTRICTION{S)

1. Cleaned parts shall be drained for no less than 15 seconds or until dripping ceases. (R 3 3 6 . 1 6 1 1 (2)(b),

R 336.1707(3)(b))

2. The permittee shall perform routine maintenance on each cold cleaner as recommended by the manufacturer.

(R 3 3 6 . 1 2 1 3 ( 3 ))

IV. DESIGN/EQUIPMENT PARAMETER($)

1. The cold cleaner must meet one of the following design requirements:

a. The air/vapor interface of the cold cleaner is no more than ten square feet. (R 336.1281 (2)(h))

b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general in-plant environment. (R 336.1285(2)(r)(iv))

2. The cold cleaner shall be equipped with a device for draining cleaned parts. (R 3 3 6 . 1 6 1 1 (2)(b),

R 336.1707(3)(b))

3. All new and existing cold cleaners shall be equipped with a cover and the cover shall be closed whenever parts are not being handled in the cold cleaner. (R 3 3 6 . 1 6 1 1 (2)(a), R 336.1707(3)(a))

4. The cover of a new cold cleaner shall be mechanically assisted if the Reid vapor pressure of the solvent is more than 0.3 psia or if the solvent is agitated or heated. (R 336.1707(3)(a))

5. If the Reid vapor pressure of any solvent used in a new cold cleaner is greater than 0.6 psia; or, if any solvent used in a new cold cleaner is heated above 1 20 degrees Fahrenheit, then the cold cleaner must comply with at least one of the following provisions:

Page 41 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023

a. The cold cleaner must be designed such that the ratio of the freeboard height to the width of the cleaner is equal to or greater than 0 . 7 . (R 336.1707(2)(a))

b. The solvent bath must be covered with water if the solvent is insoluble and has a specific gravity of more than 1 . 0 . (R 336.1707(2)(b))

c. The cold cleaner must be controlled by a carbon adsorption system, condensation system, or other method of equivalent control approved by the AQD. (R 336.1707(2)(c))

V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. For each new cold cleaner in which the solvent is heated, the solvent temperature shall be monitored and recorded at least once each calendar week during routine operating conditions. (R 336.1213(3))

2. The permittee shall maintain the following information on file for each cold cleaner: (R 3 3 6 . 1 2 1 3 ( 3 ))

a. A serial number, model number, or other unique identifier for each cold cleaner.

b. The date the unit was installed, manufactured or that it commenced operation.

c. The air/vapor interface area for any unit claimed to be exempt under Rule 2 8 1 ( 2 )( h ) .

d. The applicable Rule 2 0 1 exemption.

e. The Reid vapor pressure of each solvent used.

f. If applicable, the option chosen to comply with Rule 707(2).

3. The permittee shall maintain a current listing from the manufacturer of the chemical composition of each material, including the weight percent of each component, used in each cold cleaner. The data may consist of Safety Data Sheets, manufacturer's formulation data, or both as deemed acceptable by the AQD District Supervisor. The permittee shall keep all records on file and make them available to the Department upon request. (R 3 3 6 . 1 2 1 3 ( 3 ) )

4. The permittee shall maintain written operating procedures for each cold cleaner. These written procedures shall be posted in an accessible, conspicuous location near each cold cleaner. (R 3 3 6 . 1 6 1 1 (3), R 336.1707(4))

5. As noted in Rule 6 1 1 ( 2 ) ( c ) and Rule 707(3)(c), if applicable, an initial demonstration that the waste solvent is a safety hazard shall be made prior to storage in non-closed containers. If the waste solvent is a safety hazard and is stored in non-closed containers, verification that the waste solvent is disposed of so that not more than 20 percent, by weight, is allowed to evaporate into the atmosphere shall be made on a monthly basis.

(R 336.1213(3), R 3 3 6 . 1 6 1 1 ( 2 )( c ) , R 336.1707(3)(c))

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336.1213(3)(c)(ii))

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for reporting period July 1 to December 31 and September 1 5 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Conditions 1 9 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 1 5 for the previous calendar year.

(R 336.1213(4)(c))

Page 42 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 See Appendix 8 VIII. STACKIVENT RESTRICTION(S)

NA IX. OTHER REQUIREMENT(S)

NA Page 43 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTl-84252-2023 E. NON-APPLICABLE REQUIREMENTS At the time of the ROP issuance, the AQD has determined that no non-applicable requirements have been identified for incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to Rule 213(6)(a)(ii).

Page 44 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 APPENDICES Appen drIX 1 Acronyms an d Abbr revia!tons ti Common Acronyms Pollutant / Measurement Abbreviations AOD Air Quality Division acfm Actual cubic feet per minute BACT Best Available Control Technology BTU British Thermal Unit CAA Clean Air Act *c Degrees Celsius CAM Compliance Assurance Monitoring co Carbon Monoxide CEM Continuous Emission Monitoring CO>>e Carbon Dioxide Equivalent CEMS Continuous Emission Monitoring System dscf Dry standard cubic foot CFR Code of Federal Regulations dscm Dry standard cubic meter COM Continuous Opacity Monitoring *F Degrees Fahrenheit Department/ Michigan Department of Environment, gr Grains department Great Lakes, and Energy HAP Hazardous Air Pollutant EGLE Michigan Department of Environment, Hg Mercury Great Lakes, and Energy hr Hour EU Emission Unit HP Horsepower FG Flexible Group H>>S Hydrogen Sulfide GACS Gallons of Applied Coating Solids kW Kilowatt GC General Condition lb Pound GHGs Greenhouse Gases m Meter HVLP High Volume Low Pressure* mg Milligram ID Identification mm Millimeter IRSL Initial Risk Screening Level MM Million ITSL Initial Threshold Screening Level MW Megawatts LAER Lowest Achievable Emission Rate NMOC Non-methane Organic Compounds MACT Maximum Achievable Control Technology NO, Oxides of Nitrogen MAERS Michigan Air Emissions Reporting System ng Nanogram MAP Malfunction Abatement Plan PM Particulate Matter MSDS Material Safety Data Sheet PM10 Particulate Matter equal to or less than 1 0 NA Not Applicable microns in diameter NAAQS National Ambient Air Quality Standards PM2.5 Particulate Matter equal to or less than 2 . 5 microns in diameter NESHAP National Emission Standard for Hazardous pph Pounds per hour Air Pollutants ppm Parts per million NSPS New Source Performance Standards ppmv Parts per million by volume NSR New Source Review ppmw Parts per million by weight PS Performance Specification % Percent PSD Prevention of Significant Deterioration psia Pounds per square inch absolute PTE Permanent Total Enclosure psig Pounds per square inch gauge PTI Permit to Install scf Standard cubic feet RACT Reasonable Available Control Technology sec Seconds ROP Renewable Operating Permit SO, Sulfur Dioxide SC Special Condition TAC Toxic Air Contaminant SCR Selective Catalytic Reduction Temp Temperature sos Safety Data Sheet THC Total Hydrocarbons SNCR Selective Non-Catalytic Reduction tpy Tons per year SRN State Registration Number g Microgram TEO Toxicity Equivalence Quotient um Micrometer or Micron USEPA/EPA United States Environmental Protection voe Volatile Organic Compounds Agency yr Year VE Visible Emissions I

For HVLP applicators, the pressure measured at the gun air cap shall not exceed 1 0 psig.

Page 45 of 47

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8, 2028 PTI No: MI-PTI-B4252-2023 Appendix 2. Schedule of Compliance The permittee certified in the ROP application that this stationary source is in compliance with all applicable requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of Compliance is not required. (R 336.1213(4)(a), R 3 3 6 . 1 1 1 9 ( a )( i i ))

Appendix 3. Monitoring Requirements Specific monitoring requirement procedures, methods or specifications are detailed in Part A or the appropriate Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Therefore, this appendix is not applicable.

Appendix 4. Recordkeeping Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Therefore, this appendix is not applicable.

Appendix 5. Testing Procedures There are no specific testing requirement plans or procedures for this ROP. Therefore, this appendix is not applicable.

Appendix 6. Permits to Install The following table lists any PTls issued or ROP revision applications received since the effective date of the previously issued ROP No. MI-ROP-B4252-2018. Those ROP revision applications that are being issued concurrently with this ROP renewal are identified by an asterisk (*). Those revision applications not listed with an asterisk were processed prior to this renewal.

Source-Wide PTI No MI-PTI-B4252-2018a is being reissued as Source-Wide PTI No. MI-PTI-B4252-2023.

Permit to ROP Revision Description of Equipment or Change Corresponding Install Application Number Emission Unit(s) or Number Flexible Group(s)

NA NA NA NA Appendix 7. Emission Calculations There are no specific emission calculations to be used for this ROP. Therefore, this appendix is not applicable.

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=

ROP No: MI-ROP-B4252-2023 Expiration Date: May 1 8 , 2028 PTI No: MI-PTI-B4252-2023 Appendix 8. Reporting A. Annual, Semiannual, and Deviation Certification Reporting The permittee shall use EGLE, AQD, Report Certification form (EQP 5736) and EGLE, AQD, Deviation Report form (EOP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting Section of the Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Alternative formats must meet the provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor.

B. Other Reporting Specific reporting requirement formats and procedures are detailed in Part A or the appropriate Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Therefore, Part B of this appendix is not applicable.

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ENCLOSURE 2 TO AEP-NRC-2023-33 Renewable Operating Permit Staff Report Dated February 27, 2023

Michigan Department of Environment, Great Lakes, and Energy Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number 84252 STAFF REPORT MI-ROP-B4252-2023 AEP Cook Nuclear Plant State Registration Number (SRN): 84252 Located at One Cook Place, Bridgman, Berrien County, Michigan 4 9 1 0 6 Permit Number: MI-ROP-B4252-2023 Staff Report Date: February 27, 2023 This Staff Report is published in accordance with Sections 5506 and 5 5 1 1 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451).

Specifically, Rule 2 1 4 ( 1 ) of the administrative rules promulgated under Act 4 5 1 , requires that the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).

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TABLE OF CONTENTS FEBRUARY 27, 2023 - STAFF REPORT 3 MARCH 30, 2023 - STAFF REPORT ADDENDUM 8 Page 2 of 8

Michigan Department of Environment, Great Lakes, and Energy Air Quality Division State Registration Number ROP Number RENEWABLE OPERATING PERMIT 84252 M I-ROP-84252-2023 FEBRUARY 27, 2023

STAFF REPORT Purpose Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with an ROP pursuant to Title V of the federal Clean Air Act; and Michigan's Administrative Rules for Air Pollution Control promulgated under Section 5506(1) of Act 4 5 1 . Sources subject to the ROP program are defined by criteria in Rule 2 1 1 ( 1 ) . The ROP is intended to simplify and clarify a stationary source's applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.

This Staff Report, as required by Rule 2 1 4 ( 1 ) , sets forth the applicable requirements and factual basis for the draft ROP terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft ROP pursuant to Rule 2 1 2 ( 5 ) , and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.

General Information Stationary Source Mailing Address: AEP Cook Nuclear Plant One Cook Place Bridgman, Michigan 49106 Source Registration Number ( S R N ) : 84252 North American Industry Classification System 2 2 1 1 1 3 - Nuclear Electric Power Generation (NAICS) Code:

Number of Stationary Source Sections: f Is Application for a Renewal or Initial Issuance? Renewal Application Number: 202200102 Responsible Official: Joel Gebbie, SVP - Chief Nuclear Officer 269-465-5901 X 2499 AQD Contact - District Inspector: Matt Deskins, Senior Environmental Quality Analyst 269-303-8326 AQD Contact - ROP Writer: Matt Karl, Senior Environmental Quality Analyst 517-282-2126 Date Application Received: May 4, 2022 Date Application Was Administratively Complete: May 4, 2022 ls Application Shield in Effect? Yes Date Public Comment Begins: February 27, 2023 Deadline for Public Comment: March 29, 2023 Page 3 of 8

Source Description AEP (American Electric Power) Cook Nuclear Plant is a two-unit nuclear power plant located in Bridgman, Berrien County, Michigan, on the shore of Lake Michigan. The facility is bordered with Lake Michigan to the west and I-94 to the east. Grand Mere State Park is a mile to the north and the nearest city is Bridgman which is approximately 2 miles to the south. Nuclear reactor #1 went online in 1975 and reactor #2 in 1978. Reactor #1 can produce 1 , 0 4 8 megawatts (MW) and reactor #2 1 , 1 0 7 MW. In addition to the two nuclear steam supply system fed electric turbine generators, the facility also has several fuel oil-fired emergency generators and fire pumps, a small #2 distillate oil fired auxiliary boiler that is used primarily for building heating when both units are out of service, one propane fired emergency generator, and a paint shop that supports the maintenance of the overall facility. These sources are distributed throughout the facility and in an emergency, would be run continuously until such time as external power could be restored to the facility for safety and security reasons. I n 2 0 2 1 , under a permit to install exemption rule the facility installed two diesel engine emergency generator sets to ignite hydrogen flares in the case of an emergency.

The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System (MAERS) for the year 2 0 2 1 .

TOTAL STATIONARY SOURCE EMISSIONS Pollutant - Tons per Year Carbon Monoxide (CO) 2.4 Lead (Pb) 0 . 5 x 10° Nitrogen Oxides (NO,) 9.2 PM10* 0.5 Sulfur Dioxide (SO,) 0.6x10' Volatile Organic Compounds (VOCs) 0.4

PM 1 O = particulate matter with an aerodynamic diameter of 1 O micrometers or less.

See Parts C and D in the ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.

Regulatory Analysis The following is a general description and history of the source. Any determinations of regulatory non applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP.

The stationary source is in Berrien County, which is currently designated by the United States Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.

The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR) Part 70, because the potential to emit of nitrogen oxides (NOx) exceeds 1 0 0 tons per year.

The stationary source is a minor source of HAP emissions because the potential to emit of any single HAP regulated by Section 1 1 2 of the federal Clean Air Act, is less than 1 O tons per year and the potential to emit of all HAPs combined are less than 25 tons per year.

No emission units at the stationary source were subject to the Prevention of Significant Deterioration (PSD) regulations of The Michigan Air Pollution Control Rules Part 1 8 , Prevention of Significant Deterioration of Air Quality or 40 CFR 52.21 because the process equipment was either constructed/installed prior to June 1 9 , 1978, the promulgation date of the PSD regulations or the potential to emit any regulated pollutant was not greater than 250 tons per year.

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Emission units installed after June 19, 1978 were not subject to PSD regulations of The Michigan Air Pollution Control Rules Part 18, Prevention of Significant Deterioration of Air Quality or 40 CFR 52.21 because the equipment did not result in a significant increase in emissions of a regulated pollutant.

EU-BOILER1 at the stationary source is subject to the Standards of Performance for Small Industrial Commercial-Institutional Steam Generating Units promulgated in 40 CFR Part 60, Subparts A and De.

EU-DRYCASKDSLGEN, E U - U 1 D I S G E N E R A T O R and EU-U2DISGENERATOR at the stationary source are subject to the Standards of Performance for Stationary Compression Internal Combustion Engines promulgated in 40 CFR Part 60, Subparts A and 11 1 1.

FG-EMERDIESELS, FG-ENGINES, EU-SECDIESELGEN, EU-DSLFIREPUMP1, EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGEN, EU-COMTWRPRGEN, EU-DRYCASKDSLGEN, E U - U 1 D I S G E N E R A T O R and EU-U2DISGENERATOR at the stationary source are subject to the National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR Part 63, Subparts A and ZZZZ. The engines FG-EMERDIESELS, FG-ENGINES, EU-SECDIESELGEN, EU-DSLFIREPUMP1, EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGEN, and EU-COMTWRPRGEN are considered "existing" stationary R I C E because they were installed prior to June 1 2 , 2006. The engines EU-DRYCASKDSLGEN, E U -U 1 DI S G E N E R A T O R and EU-U2DISGENERATOR are considered "new" stationary R I C E because they were installed after June 6, 2006 and are subject to regulation under 40 CFR Part 60, Subpart 1 11 1 as noted above.

The emergency diesel engine generator sets E U - 1 A B E D G , E U - 1 C D E D G , EU-2ABEDG, and EU-2CDEDG which are subject to 40 CFR Part 63, Subpart ZZZZ may be called on to operate beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per year as allowed in 40 CFR 63.6640(f)(2). Due to the nature of the operations of this facility (nuclear power plant) the emergency engines may operate close to or exceeding 1 0 0 hours0 days 0 hours 0 weeks 0 months per year due to the enhanced requirements of the plant Technical Specifications and/or by the Nuclear Regulatory Commission (NRC) requirements. This is allowed as long as the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency internal combustion engines beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per calendar year.

EU-BOILER1 at the stationary source is subject to the National Emission Standard for Hazardous Air Pollutants for Industrial, Commercial, or Institutional Boilers promulgated in 40 CFR Part 63, Subparts A and JJJJJJ.

The AQD's Rules 287 and 290 were revised on December 20, 2016. FG-RULE287(2)(c) and FG-RULE290 are flexible group tables created for emission units subject to these rules. Emission units installed before December 20, 2 0 1 6 , can comply with the requirements of Rule 287 and Rule 290 in effect at the time of installation or modification as identified in the tables. However, emission units installed or modified on or after December 20, 2 0 1 6 , must comply with the requirements of the current rules as outlined in the tables.

The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals."

No emission units have emission limitations or standards that are subject to the federal Compliance Assurance Monitoring rule pursuant to 40 CFR Part 64, because all emission units at the stationary source do not have a control device.

Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source.

Part A contains regulatory citations for general conditions.

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Source-Wide Permit to Install (PTI}

Rule 2 1 4 a requires the issuance of a Source-Wide PTI within the ROP for conditions established pursuant to Rule 2 0 1 . All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.

The following table lists all individual PTls that were incorporated into previous ROPs. PTls issued after the effective date of ROP No. MI-ROP-B4252-2018 are identified in Appendix 6 of the ROP.

PTI Number I 460-93A I 260-038 [34-05 Streamlined/Subsumed Requirements The following table lists explanations of any streamlined/subsumed requirements included in the ROP pursuant to Rules 213(2) and 2 1 3 ( 6 ) . All subsumed requirements are enforceable under the streamlined requirement that subsumes them.

Emission Condition Streamlined Subsumed Limit/ Stringency Analysis Unit/Flexible Number I Limit/ Requirement Group ID Requirement EU-BOILER1 SC 1 . 1 R 336.1401 40 CFR 60.42c(d) The boiler is subject to

( 0 . 3 1 lb/MMBTU) (0.50 lb/MMBTU) 40 CFR Part 60, Subpart De, which includes an emission limit for SO, of 0.50 lb/MM BTU for this category of boiler.

However, when the facility permitted this boiler, they accepted a limit of 0 . 3 1 lb/MMBTU which is, of course, a stricter limit.

Non-applicable Requirements Part E of the ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the ROP Application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the ROP pursuant to Rule 2 1 3 ( 6 ) ( a ) ( i i ) .

Processes in Application Not Identified in Draft ROP There were no processes listed in the ROP Application as exempt devices under Rule 212(4). Exempt devices are not subject to any process-specific emission limits or standards in any applicable requirement.

Draft ROP Terms/Conditions Not Agreed to by Applicant The following table lists terms and/or conditions of the draft ROP that the AQD and the applicant did not agree upon and outlines the applicant's objections pursuant to Rule 2 1 4 ( 2 ) . The terms and conditions that the AQD believes are necessary to comply with the requirements of Rule 2 1 3 shall be incorporated into the ROP.

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Emission Unit/ Permit Term(s) and/or Applicant's Objection Flexible Group ID Condition(s) in Dispute FG-EMERDIESELS Process/Operational AQD returned condition 11 1. 1 to the language Restriction Special established in PTI No. 460-93A F G - E M E R D I E S EL S Condition (SC) 11 1. 1 SC 11 1. 1 . from the improperly revised language in MI-ROP-B4252-2018.

The applicant does not agree that SC 11 1. 1 notes that the emergency generators can operate in excess of 1 0 0 hours0 days 0 hours 0 weeks 0 months per year for non-emergency purposes, specifically for "readiness testing."

However, PTI No. 460-93A, F G - E M E R DI E S EL S , SC 11 1. 1 allows operation for the non-emergency purposes of maintenance and operator training, which covers "readiness testing." Additionally, FG-MACTZZZZ>500 contains the R I C E MACT (40 CFR Part 63, Subpart ZZZZ) conditions that apply to the emergency generators in FG-EMERDIESELS. FG-MACTZZZZ>500, SC 11 1. 5 covers "readiness testing" beyond 1 0 0 hours0 days 0 hours 0 weeks 0 months per year.

SC 11 1. 1 was improperly revised during the drafting of MI-ROP-B4252-2018 to add language specifying that the emergency generators can operate for "readiness testing under the plant Technical Specifications and/or by Nuclear Regulatory Commission (NRC) requirements." This renewal removes this additional language and returns the condition to the original language of PTI No. 460-93A. To change the language, the source should apply to the AQD Permits Section and request the change through the new source review (NSR) process. The AQD will keep the language as established in PTI No. 460-93A and will not return the condition to the incorrect version contained in MI-ROP-B4252-2018 during this ROP renewal.

Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP.

Action taken by EGLE, AD The AQD proposes to approve this ROP. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD's proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft ROP and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is Brad Myott, Field Operations Manager. The final determination for ROP approval/disapproval will be based on the contents of the ROP Application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.

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Michigan Department of Environment, Great Lakes, and Energy Air Quality Division State Registration Number ROP Number RENEWABLE OPERATING PERMIT 84252 MI-ROP-B4252-2023 MARCH 30, 2023 - STAFF REPORT ADDENDUM Purpose A Staff Report dated February 27, 2023, was developed to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by Rule 2 1 4 ( 1 ) of the administrative rules promulgated under Act 4 5 1 . The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in Rule 2 1 4 ( 3 ) . In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments.

General Information Responsible Official: Quinton S. Lies, Site Vice President 269-465-5901 x2492 AQD Contact -- District Inspector: Matt Deskins, Senior Environmental Quality Analyst 269-303-8326 AQD Contact - ROP Writer: Matt Karl, Senior Environmental Quality Analyst 517-282-2126 Summary of Pertinent Comments No pertinent comments were received during the 30-day public comment period.

However, comments were received by USEPA regarding a lack of recordkeeping for material contents to demonstrate compliance on the AQD Cold Cleaner template in another ROP.

Changes to the February 27, 2023 Draft ROP Due to the comment received by USEPA on the AQD Cold Cleaner template, the following change has been made to the flexible group conditions for FG-COLDLEANERS:

In Section VI Monitoring/Recordkeeping, added the following special condition as the third condition:

"The permittee shall maintain a current listing from the manufacturer of the chemical composition of each material, including the weight percent of each component, used in each cold cleaner. The data may consist of Safety Data Sheets, manufacturer's formulation data, or both as deemed acceptable by the AQD District Supervisor. The permittee shall keep all records on file and make them available to the Department upon request. (R 3 3 6 . 1 2 1 3 ( 3 ))

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AEP-NRC-2023-33, Renewable Operating Permit

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