Text

Notification of Initial Renewable Operating Permit
	ML18134A038
Person / Time
Site:	Cook
Issue date:	05/09/2018
From:	Scarpello M; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2018-36
	Download: ML18134A038 (56)
	v • d • e

a:

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power lndianaMichiganPower.com May 9, 2018 AEP-NRC-2018-36 10 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 NOTIFICATION OF INITIAL RENEWABLE OPERATING PERMIT This letter provides Indiana Michigan Power Company's, the licensee for Donald C. Cook Nuclear Plant (CNP), Units 1 and 2, initial Renewable Operating Permit.

Renewable Operating Permit MI-ROP-84252-2018 is provided as an enclosure to this letter. CNP was exempt from previously requiring a renewable operating permit under the State of Michigan's Rule 208a that allowed a reduced form of a Title V permit for sources that had potential to be above thresholds, but their actual emissions were less than 50% of the thresholds. The State of Michigan has revised their program eliminating Rule 208a, such that all sources that were previously exempt .

under this rule are now required to obtain a full permit. The requirement to provide a copy of MI-ROP-84252-2018 is not specified in the CNP's Environmental Protection Plan, Appendix B.

This letter contains no new commitments. Should you have any questions regarding this notification, please contact Mr. Jon Harner, Environmental Manager, at (269) 465-5901, extension 2102. ,.

7;.rL .

Michael K. S e a ~

Regulatory Affairs Director KMH/db

Enclosure:

Renewable Operating Permit MI-ROP-84252-2018 c: R. J. Ancona - MPSC A. W. Dietrich - Washington, DC MDEQ - RMD/RPS NRC Resident Inspector K. S. -West, NRC, Region Ill A. J. Williamson - AEP Ft. Wayne, w/o enclosures

ENCLOSURE TO AEP-NRC-2018-36 Renewable Operating Permit MI-ROP-84252-2018

STATE OF MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY DEt\ -

KALAMAZOO DISTRICT OFFICE RICK SNYDER C. HEIDI GRETHER GOVERNOR DIRECTOR March 15, 2018 Mr. Jon Harner AEP Cook Nuclear Plant One Cook Place Bridgman, Michigan 49106 SRN: 84252, Berrien County

Dear Mr. Harner:

SUBJECT:

Initial Renewable Operating Permit This letter is in reference to your application for an initial Renewable Operating Permit (ROP) AEP Cook Nuclear, located at One Cook Place, Bridgman, Michigan. This application has been evaluated and the Air Quality Division (AQD) has approved the ROP identified as No. MI-ROP-84252-2018, *pursuant to the delegation of authority from the Department of Environmental Quality (DEQ), following the procedures specified in Rule 214 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451 ).

Your copy of the final Staff Report and ROP are enclosed.

This approval is based upon and subject to compliance with all administrative rules promulgated pursuant to Act 451, all general conditions, special conditions, and

.attachments that define the applicable requirements for the activities at this source, and all standards and requirements of the federal Clean Air Act, as amended, *U.S.C. 7401 et seq. (CAA), consistent with the permit shield provisions in Part A of this ROP.

Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or violation of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in this permit shall be construed to waive any defenses otherwise available to the permittee, including, but not limited to, any challenge to the Credible Evidence Rule (see Federal Register: February 24, 1997, Volume 62, Number 36, Page Number 8314) in the context of any future proceeding.

All terms and conditions of this permit that are required under the CAA or any of its applicable requirements are enforceable by the Administrator of the U.S. Environmental Protection Agency (USEPA) and citizens under the CAA. Any terms*and conditions based on applicable requirements that are defined as "state only" are not enforceable by the USEPA and citizens pursuant to the CAA. Please review all conditions thoroughly so that you may take the actions necessary to ensure compliance with all of these requirem~nts.

7953 ADOBE ROAD

KALAMAZOO, MICHIGAN 49009-5025 www.michigan.gov/deq * (269) 567-3500

Mr. Jon Harner Page2 March 15, 2018 The US EPA has had the opportunity to review this ROP during their formal 45-day comment period pursuant to Rule 214(6). This comment period has elapsed and no objections were received from the USEPA.

Approval of this ROP does not obviate the necessity of obtaining such p*ermits or approvals from other units of government as required by law.

Enclosed is a one page pamphlet titled, "Entry for Inspections." This outlines the legal basis regarding Right of Entry for inspections and includes a list of DEQ, AQD, District Offices.

A copy of the ROP Report Certification and Deviation forms and instructions are enclosed. These forms are also available for downloading frnm the AQD web page at:

. http://www.michigan.gov/deqair. Choose the "Permits" tab, "Renewable Operating Permits," and then "Life After ROP."

This ROP shall expire five years from the effective date unless the renewal requirements specified in Rule 217(1)(a) of Act 451 are satisfied.

Any document or report required to be submitted as a term or condition of this ROP should be mailed to: DEQ, AQD, 7953 Adobe Road, Kalamazoo, Michigan.49009.

Please contact Mr. Matt Deskins at 269-567-3542 if you have any questions regarding this permit.

Sincerely,

~,~~~~

Kalamazoo District Supervisor Afr Quality Division 269-567-3545 MAD:CF Enclosures cc: Mr. Matt Deskins, DEQ cc/enc: Ms. Susan Thelen, DEQ Ms. Kelly Orent, DEQ

Michigan Department of Environmental Quality Air Quality Division State Registration Number ROP Number RENEWABLE OPERATiNG PERMIT 84252 STAFF REPORT MI-ROP-84252-2018 AEP Cook Nuclear Plant SRN: 84252 Located at One Cook Place, Bridgman, Berrien County, Michigan. 49106 Permit Number: MI-ROP-84252-2018 Staff Report Date: December 4, 2017 This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451).

Specifically, Rule 214(1) requires that.the Michigan* Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP) ..

Page 1 of 9

TABLE OF CONTENTS December 4, 2017 STAFF REPORT 3 January 26, 2018 STAFF REPORT ADDENDUM 8 Page 2 of 9

Michigan Department of Environmental Quality Air Quality Division State Registration Number ROP Number RENEWABLE OPERATING PER*M~T 84-252 MI-ROP-84252-2018 DECEMBER 4, 2017 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 of 1990 and Michigan's Administrative Rules for Air Pollution Control pursuant to Section 5506(1) of Act 451. Sources subject to.

the ROP program are defined by criteria in Rule 211 (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 docl)ment.

This Staff Report, as required by Rule 214(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 212(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 (SRN): 84252 North American Industry Classification System 221113 (NAICS) Code:

Number of Stationary Source Sections: 1 Is Application for a Renewal or Initial Issuance? Initial Issuance APPiication Number: 201700047 Responsible Official: Jon Harner, Nuclear Environmental Manager 269-465-5901 AQD

Contact:

Matt Deskins, Environmental Quality Analyst 269-567-3542 Date Application Received: March 21, 2017 Date Application Was Administratively Complete: March 21, 2017 Is Application Shield In Effect? Yes Date Public Comment Begins: December 4, 2017 Deadline for Public Comment: January 3, 2018 Page 3 of 9

Source Description AEP Cook Nuclear Plant (Facility) is a two unit nuclear power plant located in Bridgman, Berrien County, Michigan, on the shore of Lake Michigan. In addition to the two nuclear steam supply system fed electric turbine generators, the Facility also has a number of fuel oil fired emergency generators and fire pumps, a small #2 distil_late oil fired Facility 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 scattered about the Facility and are periodically tested for readiness in accordance with the Technical Specifications for the Facility, and in an emergency situation would be called on to run continuously until such time as external power could be rest_ored to the Facility for safety and security reasons.

The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System For the year 2016.

TOTAL STATIONARY SOURCE EMISSIONS Pollutant Tons per Year Carbon Monoxide (CO) 2.84 Lead (Pb) 0.00 Nitrogen Oxides (NOx) 10.74 Particulate Matter (PM) 0.39 Sulfur Dioxide (S02) 0.21 Volatile OrQanic Compounds (VOC) 0.38 The following table lists HAP emissions:

.... - .. ~. *. ..

lndiv.ich.ial HAPs** ** - .. . .. , Toh$ per Year *_***

NA NA Total Hazardous Air Pollutant (HAP) NA

- As listed pursuant to Section 112(b) of the federal Clean Air Act.

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 located in Berrien County, which is currently designated by the U.S. 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 PM, N02, CM, and voe exceeds 100 tons per year.

The stationary source is considered to be a minor source of HAP emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is less than 10 tons per year and the potential to emit of all HAPs combined are less than 25 tons per year.

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No em1ss1ons units at the stationary source are currently subject to the Prevention of Significant Deterioration (PSD) regulations of the Michigan Air Pollution Control Rules, Part 18, Prevention of Significant Deterioration of Air Quality, or 40 CFR Part 52.21, because the process equipment was constructed/installed prior to June 19, 1978, the promulgation date of the PSD regulations.

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 at the stationary source is subject to the Standards of Performance for Stationary Compression Internal Combustion Engines promulgated in 40 CFR Part 60, Subparts A and 1111.

FG-EMERDIESELS, FG-ENGINES, EU-SECDIESELGEN, EU-DSLFIREPUMP1, EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGEN, EU-DRYCASKDSLGEN, EU-COMTINRPRGEN 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.

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.

FG-EMERDIESELS, FG-ENGINES, EU-SECDIESELGEN, EU-DSLFIREPUMP1, EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGEN, EU-COMTWRPRGEN at the stationary source are subject to the National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE), promulgated in 40 CFR Part 63, Subparts A and ZZZZ (RICE area source MACT). The ROP contains special conditions provided by the Facility in their application for applicable requirements from 40 CFR Part 63, Subparts A and ZZZZ. The AQD is not delegated the regulatory authority for this area source maximum achievable control technology (MACT).

EU-BOILER1 at the stationary source is subject to the National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, or Institutional Boilers promulgated in 40 CFR Part* 63, Subparts A and JJJJJJ (boiler area source MACT). The ROP contains special conditions provided by the Facility in their application for applicable requirements from 40 CFR Part 63, Subparts A and JJJJJJ. The AQD is not delegated the regulatory authority for this area source MACT.

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 under 40 CFR Part 64, because all emission units at the stationary source either do not have a control device or those with a control device do not have potential pre-control emissions over the major source thresholds.

Please refer to Parts 8, C, and D in the draft ROP for detailed regulatory citations for the stationary source.

Part A contains regulatory citations for general conditions.

Source-wide Permit to Install CPTI)

Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.

Page 5 of 9

Streamlined/Subsumed Requirements The following table lists explanations of any streamlined/subsumed requirements included in the ROP pursuant to Rules 213(2) and 213(6). All subsumed requirements are enforceable under the streamlined requirement that subsumes them.

Emis~ion

Condition Streamlined Subsumed

Unit/Flexible * .Number ,'

Limit/

Limit/ :.String~ricy'Analysis Group lb Requirement Requirement EU-BOILER1 SC 1.1 .R 336.1401 40 CFR 60.42c(d) The boiler is subject to 40 (0.31 lb/MMBtu) (0.50 lb/MMBtu) CFR Part 60, Subpart De, which includes an emission limit for S02 of 0.50 lb/MMbtu for this category of boiler.

However, when the Facility permitted this boiler, they accepted a limit of 0.31 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 213(6)(a)(ii).

Processes in Application Not Identified in Draft ROP The following table lists processes that were included in the ROP Application as exempt devices. under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.

PTI Exempt

Description of PTI Rule 212(4)

. PTI Exemption.

Emission Unit ID .: ' * .ExempJ Emission Unit Citation

Rl,lle Citation, . ,

EU-BLASTENC Sand blasting enclosure located in R 336.1212(4)(e) R 336.1285(vi)(C) the paint shop.

Draft ROP Terms/Conditions Not Agreed to by Applicant This draft ROP does not contain any terms and/or conditions that the AQD and the applicant did not agree upon pursuant to Rule 214(2).

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 the MDEQ, AQD 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 Page 6 of 9

decision maker for the AQD is Ms. Mary Douglas, Kalamazoo District Supervisor. 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.

Page 7 of 9

Michigan Department of Environmental Quality Air Quality Division State Registration Number ROP Number IRE~EWABUE O!PERATING PERMnr 84252 January 26, 2018 STAFF REPORT ADDENDUM MI-ROP~B4252-2018 Purpose A Staff Report dated December 4, 2017, was developed in order to set forth the applicable requirements and factual basis for the Draft ROP terms and conditions as required by R 336.1214(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 R 336.1214(3). In addition, this addendum describes any changes to the Draft ROP resulting from these pertinent comments.

General Information Responsible Official: Jon Harner, Nuclear Environmental Manager 269-465-5901 AQD

Contact:

Matt Deskins, Environmental Quality Analyst

-269-567-3542 Summary of Pertinent Comments The AQD received comments during the 30-day public comment period from the USEPA, the Facility, and a citizen. The comments from the citizen were mainly related to things that the AQD does not have regulatory authority of, and did not pertain directly to the equipment or conditions contained in the ROP.

Therefore, those comments will not be included here. The AQD did address their comments, however, and referred them to the appropriate regulatory authority for further information. The following will list the comments made by the USEPA and the Facility followed by the changes made to the ROP.

USEPA COMMENT 1: EU-BOILER1, Page 16: SC 1.6 lists 40 CFR § 60.43c as an underlying applicable requirement. Please verify the applicability of the opacity limit contained in 40 CFR § 60.43c.

MDEQ Changes Made: The reference to 40 CFR 60.43c was removed since it is not applicable.

USEPA COMMENT 2: EU-BOILER1, Page 16: The S02 and NOx ton per year limits in SC 1.2 and 1.4 reference SC Vl.5 as the monitoring/testing method. SC Vl.5, however, requires the recordkeeping for Arsenic, Cadmium, and Chromium concentrations in the blended fuel oil tanks. Please review the testing/monitoring method for SC 1.2 and 1.4 and revise as appropriate. Note that SC Vl.4 requires 12-month rolling emissions calculations.

MDEQ Changes Made: The monitoring/testing method for SC 1.2 and 1.4 was changed from SC Vl.5 to SC Vl.4.

USEPA COMMENT 3: EU-BOILER1, Page 17: SC V.2 references the blend limits specified in SC 11.6, a condition that is not contained in the Draft permit. Please review this reference and revise accordingly.

MDEQ Changes Made: The Table referenced in SC V.2 was changed to reflect SC 11.5; not SC 11.6.

Page 8 of 9

AEP Cook Nuclear Comment 1: Flexible Group EMERDIESELS, Section Ill, Condition 1 (Page 20).

After reviewing the MACT ZZZZ rule language and this language, we believe th~t the language in Condition 111.1 in this Section should be better aligned with the language under FG-MACTZZZZ 111.1 (a)(i) to eliminate the potential issues that the slightly different language potentially brings. To accomplish the alignment, we recommend the following language change to Condition 111.1, under FG-EMERGIESELS:

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. Applicant shall not operate the emergency generators in FG-EMERDIESELS when electric poweris available, except during periods of maintenance checks, operator training, and readiness testing under the plant Technical Specifications and/or NRC requirements.

MDEQ Changes Made: The above language was added to the condition for consistency with the requirements of the MACT ZZZZ.

AEP Cook Nuclear Comment 2: EU-BOILER1, Section V, Condition 2 (Page 17).

In reviewing this condition, we note that it references SC IL6 as it relates tci contaminant concentrations in specification recycled used oil (RUO) that may be combusted in the boiler. In reviewing Section II under EU-Boiler, we cannot find a Condition 6 in this Section of the Permit. In looking at Section II under EU-Boiler and the context of the SC V.2, we believe that the reference in SC V.2 should be to SC 11.5 under

EU-Boiler. Based on our assumption of the intended meaning, we recommend the following change to SC V.2:

2. The permittee shall sample blended fuel oil after each addition of the specification RUO to the blend tanks. Sampling of the blended fuel oil shall not be required if the sampling results of the specification RUO are below the blend limits specified in SC 11.5.2 (R336.1205, R336.1225)

MDEQ Changes Made: This comment was also made by the USEPA and was addressed above under the USEPA Comments.

Changes to the December 4, 2017 Draft ROP See changes that were made above following the comments made by the USEPA and the Facility.

Page 9 of 9

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION EFFECTIVE DATE: March 15, 2018 ISSUED TO AEP Cook Nuclear Plant*

State Registration Number (SRN): B4252 LOCATED AT

.One Cook Place, Bridgman, Michigan 49106

. !RENEWABLE OPERATING PERMIT Permit Number: MI-ROP-84252-2018 Expiration Date: March 15, 2023 Administratively Complete ROP Renewal Application Due Between Septembe*r 15, 2021 and

September 15, 2022 *

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 451, as amended (Act 451). Pursuant to Michigan Air Pollution Control Rule 210(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 Number: MI-PTl-84252-2018 This Permit to Install (PTI) is issued iri accordance with and subject to Section 5505(5) of Act 451. Pursuant to Michigan Air Pollution Control Rule '214a, the terms and conditions herein, identified by the underlying applicable requirement citation of Rule 201 (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 al! applicable future or amended rules and regulations pursuant to Acf451 and the federal Clean Air Act.

Michigan Department of Environmental Quality CO!MJ\ rt arM!J Li~

Mary A Do,as,'i<alamazi18ist;Supervisor

ROP No: MI-ROP--84252.:.2018 Expiration Date: March 15, 2023 PTI No:* MI-PTl-84252-2018 TABLE OF CONTENTS AUTHORITY AND ENFORCEABILITY ................................................................................................... 3 A. GENERAL CONDITIONS .............................................................................:.................................... 4 Permit Enforceability ................. ,............................... ,....................................................... , ........................ 4 General Provisions ..............................................*.....................................................................................4 Equipment & Design ......................... ,........................... :.................................................. :........................ 5 Emission l-imits .......... .-..............................................................................................................................5 Testing/Sampling .............................................................................. ;....................................................... 5

. Monitoring/Recordkeeping .............................. ,......................................: .................................................. 6 Certification & Reporting .......................... :.......................................................................................... ;..... 6 Permit Shield .................. , ................ :........................................................................................................7 Revisions ..................................................................................................................................................8 Reopenings ............. :..................................................................................................................................8 Renewals ................................................... ; .............................................................................................. 9 Stratospheric Ozone Protection ..................................................................................................................9 Risk Management Plan .......................................................................................................... .-.................. 9 Emission Trading ............................................................... : .......'.. ........................................................ ,.... 9 Permit to Install (PTI) ........................................................................... .' .................................................. 1O

8. SOURCE-WIDE CONDITIONS ................ ;.:......................................................................................11 C. EMISSION UNIT CQNDITIONS .................................................;............................ '. .........................*.14-EMIS.SION UNIT

SUMMARY

TABLE ............................................................................................:......... 14 EU-BOILER1 .... , ...................... ~ .......................................................................... :................................... 16 D. FLEXIBLE GROUP CONDITIONS ................................. :................. :............ ;............................ :...... 19 FLEXIBLE GROUP

SUMMARY

TABLE. ................................................................................................. 19 FG-EMERDIESELS ............................ :........................ :..........................................................................20 FG-E.NGINES ........................................................... .'.......................................................................... :.. 22 FG-MACTZZZZ ......................................................................................... .' ............................................. 24 FG-MACTJJJJJj .......... :........................................................ .' ........................................ :...................... 27 FG-NSPSIIII .. ...........................................................................................................................................33 FG-RULE 287(2)(c) .............................................................. :........................................................ : ........ 36 FG-COLD CLEANERS .............................................. : .............................................. .'............................. 38

E. NON-APPLICABLE REQUIREMENTS .............................................................................................40 APPENDICES ********~************************************************************;....................*.............................................41 Appendix 1. Acronyms and Abbreviations ... ;......................................................................................... .41 Appendix 2. Schedule of Compliance ....................................................................................................42 Appendix 3. Monitoring Requirements ..................................................................................................: ..42 Appendix 4. Recordkeeping .................................................................. :........................... : .. .-................. 42 Appendix 5. Testing Procedures ............................................................................................................42 Appendix 6. Permits to lnstall. ............................. :............................... ,.................................................. 42 Appendix 7. Emission Calculations ....................................................................................................... .42 Appendix 8. Reporting ............................................................................................................................42 Page2 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 AUTHORITY AND ENFORCEABILITY 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 Environmental Quality (MDEQ) 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 contjitions are identified in Parts 8, C, D and/or the appendices.

lh accordance with Rule 213(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 complic;1nce, 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 requiren,ents on a timely basis, unless the underlying applicable requirement requires a mo.re 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.

Page 3 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 A~ GENERAL CON!Dil~ON§ Permit Enfowceability

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

(R 336.1213(5))

'° Those conditions that are hereby incorporated in a state-only enforceable Source-Wide PTI pursuant to Rule 201(2)(d) are designated by footnote one. (R 336.12'113(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 336.12"il3(5)(b), R 336.1214a(3))

General Provisioris

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of Act 451, 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 (CM). 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 CM.

(R 336.1213(1)(a)) .

2. It shall not be a defense for the permittee in ari 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 336.1213(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 215 and Rule 216. (R 336.1213(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 336.1213(1 }( d))

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 451, 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 §15.231 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 33S.1213(1)(e))

Page 4 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

6. A challenge by any person, the Administrator of the US EPA, 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.i213(1)(f))

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of Act 451. (R 336.1213(i)(g))

8. This ROP does not convey any property rights or any exclusive privilege. (R 336.i213(i)(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 and II areas requires the use of material handling methods specified in Rule 370(2). 2 (R 336.11370)

10. Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in accordance _

wit_h the Michigan Air Pollution Control rules and existing law. (R 336.1910)

Emission Limits

11. Unless otherwise specified in this ROP, the permittee shall comply with Rule 301, which states, in part, "Except as provided in subruies 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:" 2 (R 336.1301(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: *

a. Injurious effects to human health or safety, animal life, plant life of significant economic value, or property. 1 (R 336.1901(a))

b. Unreasonable interference with the comfortable enjoyment of life and property. 1 (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 1001 and Rule 1003, under any of the conditions listed in Rule 1001 (1). 2 (R 336.2001) *

14. Any required performance testing shall be conducted in accordance with Rule 1001 (2), Rule 1001 (3) and Rule 1003. (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 336.200'1 (5))

Page 5 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 Monitoring/Recordkeeping

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following information specified in Rule 213(3){b)(i), where appropriate: (R 336.1213(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 qompany 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.

17. 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 33S.1213(1}(e), R 336.1213(3)(1:>)(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 states 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 912 as detailed in Condition 25. All reports st,Jbmitted 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 912 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.

Page 6 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PT! No: MI-PTl-84252-2018

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 336.1212(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 912, 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 912, must be submitted to the appropriate AQD District Supervisor within 10 days after the start-up or shutdown occurred, within 1O 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 manner consistent with the CAA. 2 (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))

Page 7 of 43

ROP No: MI-ROP-B4252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTI-B4252-2018

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

(R 336. 'i213(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 215. (R 336. '1215(5))

b. Administrative Amendments made pursuant to Rule 216(1)(a)(i)-(iv). (R 336.12i6(1)(b)(iui))

c. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved by the department. (R 336.i216('i)(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. ii 2il 6(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 18 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 336.12'i7(1)(c), R 336.il217(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 216, the permittee must comply with Rule 215. (R 336.1215, R 336.1216)

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to Rule 216(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 216. (R 336.1210(10))

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a c;:hange has been made, and until the department takes final actiori, the permittee shall comply with both the applicable requirements governing the change arid the ROP terms and conditions proposed in the application for the modification. During this time period, the permittee may choose to not comply with the existing ROP terms and conditions that the application seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the application during this time period, the terms and conditions in the ROP are enforceable. (R 336.1216(1)(c)(iii),

R 336.1216(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 following circumstances:. *

a. If additional requirements become i:ipplicable to this stationary source with three or more years remaining in the term of the ROP, but not if the effective date of the new applicable requirement is later than the ROP 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)(ii))

c. If the department determines that the ROP contains a material mistake, information required by any applicable requirement was omitted, or inaccurate statements were 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))

Page 8 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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 18 months, but not less than 6 months, before the expiration date of the ROP.

(R 336.1210(8)) .

Stratosplheric 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 applicabie 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 sy::;tem used for refrigerated cargo or an air conditioning system on passenger buses using Hydrochlorofluorocarbon-22 refrigerant.

Risk Management Plan

38. If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall register and .Submit to the USEPA the required data related to the risk management plan for reducing the probability of accidental releases of any regulated substances listed. pursuant to Section 112(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 112(r)(1 ).

39. If subject to Section 112(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 68.1 O(a):

a. June21,1999,

b. Three years after the date on which a regulated substance is first listed under 40 CFR 68.130, or

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

40. If subject to Section 112(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 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance with all applicable requirements of Section 112(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 336.1213(12))

Page 9 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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 PTI requirements by any applicable rule. 2 (R 336.1201(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 CM. 2 (R 336.1201 (8), Section 5510 of Act 451)

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 219 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 219. The written request shall be.sent to the appropriate AQD District Supervisor, MDEQ. 2 (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 18 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, MDEQ, AQD, P.O. 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 PTl. 2 (R 336.1201(4))

Footnotes:

1This condition is state-only enforceable and was established pursuant to Rule 201 (1)(b).

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

page 10 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 B. SOURCE-WIDE COND~T~ONS 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 11 of 43

ROP No: MI-ROP-B4252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

. SOURCE~WiDE CONDiT~ONS POLLUTION CONTROL EQUIPMENT I. EMISSION LIMITCS)

Pollutant Umit Time Period/ Opernting Equipment i\llonitoring/ Underlying Scenario Testing Method Applicable ReC11uirements NA NA NA NA NA NA II. MATERIAL LIM!T(S)

Material Limit Time !Period/ Operating Equipment Monitoring/ Underlying Scenario Testing i\llethod Applicable Requerements NA NA NA NA NA NA Ill. PROCESS/OPERATIONAL RESTRICTION(S)

NA 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. Fuel consumption in all equipment shall be monitored based on fuel receipts at the site and plant instrumentation showing fuel flows and/or operational hours to specific equipment as appropriate. (R 336.1213(3)

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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

(R 336.1213(4)(c))

4. An annual report of emissions must be prepared and submitted pursuant to Condition 24 of Part A to the appropriate AQD District Office. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. (R 336.202 and R 336.1212(6))

See Appendix 8 Page 12 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 VIII. STACKNENT 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 Minimum Height Underlying Applicable Exhaust Above Ground Requirements Dimensions (feet)

(inches)

NA NA NA NA IX. OTHER REQUIREMENT{S)

NA Footnotes:

1This condition is state-only enforceable and was established pursuant to Rule 201 (1 )(b).

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

Page 13 of 43

ROP No: MI-ROP-B4252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTI-B4252-2018 C. EMISSION UNIT COND~T~ONS 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 has been used in the table. If there are no conditions specific to individual emission units, this 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/

Device(s)) Modification Date EU-1ABEDG 1-0ME-150AB - Unit 1 AB emergency 01-01-71 FG-EMERDIESELS diesel generator engine (35.088 MM Btu/hr FG-MACTZZZZ heat input).

EU-1CDEDG 1-0ME-150CD - Unit 1 CD emergency 01-01-71 FG-EMERDIESELS diesel generator engine (35.088 MM Btu/hr FG-MACTZZZZ heat input).

EU-2ABEDG 2-0ME-150AB - Unit 2 AB emergency 01-01-71 FG-EMERDIESELS diesel generator engine (35.088 MM Btu/hr FG-MACTZZZZ heat input).

EU-2CDEDG 2-0ME-150CD - Unit 2 CD emergency 01-01-71 FG-EMERDIESELS diesel generator engine (35.088 MM Btu/hr FG-MACTZZZZ heat input).

EU-BOILER1 Alternate plant space heating boiler - No. 2 06-10-09 FG-MACTJJJJJJ fuel oil (28.56 MM Btu/hr heat input) installed under a qeneral permit.

EU-12-EP-DG-1 5,000 kw supplemental diesel generator 1. 02-16-05 FG-ENGINES FG-MACTZZZZ EU-12-EP-DG-2 5,000 kw supplemental diesel generator 2. 02-16-05 FG-ENGINES FG-MACTZZZZ EU-SECDIESELGEN Detroit Diesel generator set - 550 kw, full 01-01-71 FG-MACTZZZZ load fuel consumption - 37.5 gph, estimated heat input@ 138,000 Btu/gal -

5,175,000 Btu/hr.

EU-DSLFIREPUMP1 Cummins Model NTA855 - 400 hp, fuel 12-01-92 FG-MACTZZZZ consumption 20.9 gph, estimated heat input© 138,000 Btu/qal - 2,884,200 Btu/hr.

EU-DSLFIREPUMP2 Cummins Model NTA855 - 400 hp, fuel 12-01-92 FG-MACTZZZZ consumption 20.9 gph, estimated heat input (a), 138,000 Btu/gal - 2,884,200 Btu/hr.

EU-TRGCTRDSLGEN Detroit Diesel 550 hp diesel engine 12.7 L 01-01-01 FG-MACTZZZZ displacement Model Series YDDXL, estimated fuel consumption @ 138,000 Btu/gal - 23.0 gal/hr, estimated heat input -

3,174,000 Btu/hr.

Page 14 of 43

ROP No: MI-ROP-B4252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTI-B4252-2018 Emission Unit ID Emission Unit Description Installation Flexible Group ID (Including Process Equipment & Control Date/

Device(s)) Modification Date EU-MAI NGATEDSLGEN Mitsubishi 16.0 liter displacement 400 kW 12-01-04 FG-MACTZZZZ generator electrical output, estimated fuel consumption: 30.2 gph, estimated heat input@ 138,000 Btu/qal - 4,167,600 Btu/hr.

EU-COMTWRPRGEN 33 kw Kohler propane fired generator set 10-01-02 FG-MACTZZZZ 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, 132 10-01-11 FG-NSPSIIII hp @1800 RPM, fuel consumption - 6.5 gph, heat input @ 138,000 Btu/gal -

897,000 Btu/hr.

EU-PAINTSHOP Paint shop that supports *plant operations. 06-01-98 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 beinq used.

EU-COLDCLEANERS Five parts cleaner stations with closeable Various FG-covers located in the plant and elsewhere CO LDC LEAN ERS on site. They may be relocated from time to time depending on maintenance needs.

Page 15 of43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTI-B4252-2018 EU-B0ILER1 I EMISSION UNIT CONDIT~ONS DESCRIPTION Alternate plant space heating boiler - No. 2 fuel oil (28.56 MM Btu/hr heat input) installed under a general permit.

Flexible Group ID: FG-MACTJJJJJJ POLLUTION CONTROL EQUIPMENT NA

I. EMISSION LIMIT(S)

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

1. S02 0.31 lb/MMBTU 2* Instantaneous EUBOILER1 SC 11.1 R 336.1401 SC Vl.1

2. S02 20 tpy 2 12-month rolling time EUBOILER1 SCVl.2 R 336.1205(1 )(a)(ii)(D) period as determined at SC Vl.4 R 336.1401 the end of each 40 CFR 52.21(c) and calendar month (d)

3. NOx 0.15 lb/MMBTLJ2 Instantaneous EUBOILER1 SCV.2 R 336.2803 R336.2804

14. NOx 11 tpy 2 12-month rolling time EUBOILER1 SCVl.2 R 336.1205(1 )(a)(ii)(D) period as determined at SC Vl.4 R 336.2803 the end of each R 336.2804 calendar month. 40 CFR 52.21 (c) and (d)

5. Arsenic 0.00084 ooh1 Hourlv EUBOILER1 SCV.2 R 336.1225

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

6. Visible emissions from EUB0ILER1 shall not exceed a six-minute *average of 20 percent opacity, except as specified in R 336.1301(1)(a). 2 (R 336.1301, R 336.1331) ii. MATERIAL lll\lllT(S)

1. The sulfur content of the No. 2 fuel oil added to the blended fuel for EUBOILER1 shall not exceed 0.30 percent by weight: 2 (R 336.1225, R 336.1401, R 336.1901)

a. The permittee shall not add to the blended fuel oil tanks for EUBOILER1 any hazardous waste (as defined in state or federal law) or specification recycled used oil (RUO) containing in contaminant that exceeds the following concentrations from the standards specified in the following table. 2 (R 336.1201(3), R 336.1225, R 336.1401)

Contaminant Limit Units Arsenic 5.02 ppmw Cadmium 2.0 2 ppmw Chromium 10.02 ppmw Lead 15.02 ppmw PCB 1.02 ppmw Total Halogen 1000.02 ppmw Sulfur 0.3 2 Weight%

Page 16 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

2. The blended fuel usage rate shall not exceed a maximum of 210 gallons per hour and shall not exceed a maximum usage rate of 919,800 gallons per calendar year. 2 (R 336.1205, R 336.1225, R 336.1401)

3. The specification RUO added to the blended fuel shall not exceed 10,000 gallons per calendar year. 2 (R 336.1205, R 336.1225, R 336.1401, R 336.1702(a), R 336.1901)

4. The facility shall not use any specification RUO from an off-site source. 2 (R 336.1205, R 336.'i225)

5. The specification RUO shall be blended with No. 2 fuel oil prior to use in EUB0ILER1 to the limits specified in the following table. 2 (R 336. 'i 205, R 336. 'i 225)

Contaminant Limit Units Arsenic 0.50 2 ppmw Cadmium 0.20 2 ppmw Chromium 0.202 oomw Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The S02 emission limits shall apply at all time including periods of start-up, shut-down, and malfunctions. 2 (R 336.'i205, R 336.'i401}

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. The permittee shall sample specification RUO prior to the addition to the blend tanks. 2 (R 336.1205, R 336.1225; R 336.1702(a), R 336.1901)

2. The permittee shall sample blended fuel oil after each addition of the specification RUO to the blend tanks.

Sampling of the blended fuel oil shall not be required if the sampling results of the specification RUO are below the blend limits specified in SC 11.5. 2 (R 336.1205, R 336.1225)

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 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 usedfor this purpose, records of certification must contain the name of the supplier and a statement from the supplier that oil complies with the requirements of 40 CFR 60.48c. 2 (R 336.1205, R 336.1225, R 336.1331, R 336.1702, R 336.1901)

2. The permittee shall monitor, in a satisfactory manner, the blended fuel oil usage for EUB01LER1 on a monthly and calendar year time period basis. 2 (R ~36.1205, R 336.1225, R 336.1331, R 336.1702, R 336.1901)

3. The permittee shall monitor, in a satisfactory manner, the RUO addition rate for EUB01LER1 on a monthly and calendar year time period basis. 2 (R 336.'i205, R 336.1225, R 336.1331, R 336.1702, R 336.1901)

4. The permittee shall keep in a satisfactory manner, calculated on a monthly basis, 1i-month rolling time period emission calculation records for S02 and NOx for EUB0ILER1. All records shall be kept on file and made available to the Department upon request. 2 (R 336.1205(1)(a))

5. The permittee shall keep records of, in a satisfactory manner, the Arsenic, Cadmium, and Chromium concentrations in the blended fuel oil tanks as required per SC V.2. All records shall be kept on file and made available to the Department upon request.2 (R 336.1205, R 336.1225, R 336.1901)

Page 17 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursl,Jant to General Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year.

(R 336;1213(4)(c))

See Appendix 8 VIII. STACKNENT 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 Dimensions Above Ground Requirements (inches) (feet)

SVBOILER1 242 222 R 336.1225 R 336,2803 R 336.2804 40 CFR 52.21(c) and (d)

IX. OTHER REQUIREMENT($)

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:

1This condition is state-only enforceable and was established pursuant to Rule 201 (1 )(b).

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

Page 18 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 ID. FllEXIBUE GROUP CONDii~ONS Part D outlines the terms and conditions that apply to more than one emission \jnit. 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 !Ds 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 qenerators. EU.:.12-EP-DG-2 FG-MACTZZZZ Any emergency spark ignition engines and emergency EU-1ABEDG diesel engines subject to 40 CFR 63, Subpart ZZZZ. EU-1CDEDG EU-2ABEDG

EU-2CDEDG EU-12-EP-DG-1 EU-12-EP-DG-2 EU-SEC6IESELGEN EU-0SLFIREPUMP1 EU-DSLFIREPUMP2 EU-TRGCTRDSLGEN EU-MAINGATEDSLGEN EU-COMTWRPRGEN FG-MACTJJJJJJ Alternate plant space heating boiler - No. 2 fuel oil EU-B01LER1 (28.56 MMBtu/hr heat input).

FG-NSPSIIII Any emergency reciprocating internal combustion EU-DRYCASKDSLGEN enqine subject to 40 CFR Part 60, Subpart 1111.

FG-RULE287(2)(c) Paint shop that supports plant operations. Emission EU-PAINTSHOP controls include c! spray booth with filtration and a limitation of 200 gallons or less per month of paints, and coatinqs beinq used.

FG-COLDCLEAN ERS Five parts cleaner stations with closeable covers EU-COLDCLEANERS located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs.

Page 19 of43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG~EMERDIESELS FL!EX~BLE GROUP COND~T~ONS DESCRIPTION Four 3,500 kw large bore emergency diesel generators located inside the main building.

Emission Units: EU-1ABEDG, EU-1 CDEDG, EU-2ABEDG, EU-2CDEDG POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S)

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

1. S02 0.33 lb per millio"n 24-hour average EU-1ABEDG SC V.1 R 336.1401 BTU heat input2* EU-1CDEDG 40 CFR 52.21(c) and (d)

EU-2ABEDG EU-2CDEDG

This is the equivalent to usinq oil with a 0.3% sulfur content and heat value of 18,000 BTUs per pound.

2. Visible emissions from the emergency generators in FG-EMERDIESELS shall not exceed a 6-minute average of 20% opacity, except as specified in Rule 301 (1)(a). 2 (R 336.1301)

II. MATERIAL LIMIT(S)

Material Limit Time Period/ Operating Equipment Monitoring/ Underlying Scenario Testing Method Applicable Requirements NA NA NA NA NA NA Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. Applicant shall not operate the emergency generators in FG-EMERDIESELS when e.lectric power is available, except during periods of maintenance checks, operator training, and readiness testing under the plant Technical Specifications and/or by Nuclear Regulatory Commission (NRC) requirements. 2 (R 336.1225, R 335.1702, 40 CFR 52.21 (c) and (d))

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 S02 emission limit from one or more representative units of FG-EMERDIESELS, 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 ts, the AQD. The final plan must be approved by the AQD prior to testing. Verification of the emission factor includes the submittal of a complete report of the test results to the AQD within 60 days following the last date of the test. (R 336.1213(3)(a)(ii))

Page 20 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No:* MI-PTl-84252-2.018 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

NA 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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

(R 336.1213(4)(c))

See Appendix 8 VIII. STACKNENT 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 Minimum Height Underlying Applicable Exhaust Above Ground Requirements Dimensions (fe~t)

(inches)

NA NA NA NA IX. OTHER REQUIREMENT(S)

NA Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 201 (1)(b).

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

Page 21 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG-ENGINES FLEXIBLE GROUP CONDIT!ONS DESCRIPTION Two 5,000 kw large bore supplemental diesel generators.

Emission Units: EU-12-EP-DG-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 Requ_irements

1. NOx 515 lb2 Per 1000 gal of diesel FG-ENGINES SCV.1 R 336.1205(1)(a) fuel consumed2 SCVl.1 SCVl.4 II. MATERIAL LIMIT{S)

1. The permittee shall burn only diesel fuel in FG-ENGINES. 1 (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(d)(3). 2 (40 CFR Part 72.7)

3. The combined diesel fuel use for all units included in FG-ENGINES shall not exceed 136,000 gallons per 12-month rolling time period. 2 (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)}

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee shall_ operate FG-ENGINES in accordance with manufacturer's recommendations for safe and proper operation to minimize emissions during periods of start-up, shutdown, and malfunction. 2 (R 336.1912)

2. The total capacity from each unit included in FG-ENGINES shall not exceed 5 MW. 2 (40 CFR Part 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 gallons of 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 the submittal of a complete report of the test results tc:i the AQD within 60 days following the last date of the test. 2 (R 336~1205(1)(a), R 336.2001, R 336.2003, R 336.2004)

Page 22 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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 install, calibrate, maintain, and operate in a satisfactory manner, a device to monitor and record the fuel US!3 for FG-ENGINES on a monthly basis. 2 (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. 2 (R 336.1912)

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 11.2.2 (40 CFR 72.7)

4. The permittee shall keep, in a satisfactory manner, monthly and 12-r'nonth rolling time period fuel use records for FG-ENGINES. The records must indicate the total amount of fuel use in FG-ENGINES. 2 (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))

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 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 336.1213(3)(c)(i))

3. Annual certification of compliance pursuant to General Co!lditions 19 and 20 of Part A The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year.

(R 336.1213(4)(c)) . See Appendix 8 VIII. STACKNENT RESTRICTION(S)

1. The exhaust gases from the stacks of FG-ENGINES shall be discharged unobstructed vertically upwards to the ambient air. 2 (R 336.1225, 40 CFR 52.21(c) and (d))

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: 2 (R 336.1213)

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 minimum of 1O 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 records of the date and description of the replacement or modification.

Footnotes:

1 This condition is state only enforceable and was established pursuant to Rule 201 (1 )(b).

2 This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a). Page 23 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: Ml-PTl-84252-2018 FG-MACTZZZZ FLEXIBLE GROUP CONDIT~ONS DESCRIPTION Any emergency spark ignition engines and emergency diesel engines subject to 40 CFR 63, Subpart ZZZZ. Emission Units: EU-1ABEDG, EU-1CDEDG, EU-2ABEDG, EU-2CDEDG, EU-12-EP-DG-1, EU-12-EP-DG-2E U-SECDIESELGEN, EU-DSLFIREPUMP1, EU-DSLFIREPUMP2, EU-TRGCTRDSLGEN, EU-MAINGATEDSLGE N, EU-COMTWRPREGEN POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMiT(S) Pollutant Limit Time Period/ Operating Equipment Monitoring/ Underlying Scenario Testing Method Applicable Re uiremen ts NA NA NA NA NA NA II. MATERIAL LIMIT(S) Material Limit Time Period/ Operating Equipment Monitoring/ Underlying Scenario Testing Method Applicable Re uiremen ts NA NA NA NA NA NA Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. If you own or operate an emergency stationary RICE, you must operate the emergency stationary RI CE according to the requirements in paragraphs (A) through (D) of this section. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operati on, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 ho urs per year, as described in paragraphs (A) through (D) of this section, is prohibited. If you do not operate the eng ine according to the requirements in paragraphs (A) through (D) of this section, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines: (40 CFR 63.6640(f)) .

a. There is no time limit on the use of emergency stationary RICE in emergency situations.

b. You may operate your emergency stationary RICE for any combination of the purposes specified in paragraphs (2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraphs (C) and (D) of this section counts as part of the 100 hours per calendar year allowed by this paragraph (B):

i. Emergency stationary RICE may be operated for 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 owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but 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 RICE beyond 100 hours per calendar year.

ii. Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or Page 24 of 43.

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252.:.2018 other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. iii. Emergency stationary RICE may be operated for periods where there .is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

c. Emergency stationary RICE located at major sources of HAP may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (B) of this section. The 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity.

d. Emergency stationary RICE located at area sources of HAP may be operated for up to 50 hours per**

calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (2) of this section. Except as provided in paragraphs (D)(i) and (ii) of this section, the 50 hours per 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:

i. Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system.

ii. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator. B) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply i_n a local area or region. C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D) The power is provided only to the facility itself or to support the local transmission and distribution system.

                 -E) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distributiori system operator may keep these records on behalf of the engine owner or operator.

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. MON!TORING/RECORDKEEPING Records shall be maintained on file for a period of five years. (R 336.1213(3}(b)(ii})

1. In Accordance with 40 CFR Part 63 for Emergency Spark Ignition Engines and Emergency Diesel Engines, the permittee shall implement either an oil monitoring program as described in 63.6625(i) or U) or change the oil and filter on the machine once per year; inspect spark plugs every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and inspect every 500 operating hours or annually, whichever comes first, all belts and hoses and replace as necessary. (40 CFR Part 63, Subpart zt.zz, Table 2d, 40 CFR Part 63, Subpart ZZZZ) .

Page 25 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 Vil. 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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

(R 336.1213(4)(c)) . See Appendix 8 VIII. STACKNENT 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 Minimum Height Underlying Applicable Exhaust Above Ground Requirements Dimensions (feet)

(inches) NA NA NA NA IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provisions of the National Emission Standards for Hazardous Air Pollutants, as specified in 40 CFR Part 63, Subpart A and Subpart ZZZZ, for Stationary Reciprocating Internal Combustion Engines by the initial compliance date. (40 CFR 63.6595, 40 CFR Part 63, Subparts A and ZZZZ)

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201 (1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a). Page 26 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG-MACTJJJJJJ FLEXJBLE GROUP COND~T~ONS DESCRIPTION Alternate plant space heating boiler - No. 2 fuel oil (28.56 MM Btu/hr heat input). Emission Unit: EU-BOILER1 POLLUTION CONTROL EQUIPMENT NA !. EMISSION Lli\/llT{S) Pollutant limit Time Period/ Operating Equipment Monitoring/ Underlying Scenario Testing Method Applicable Requirements NA NA NA NA NA NA II. MATERIAL LIMIT(S)

1. The boiler shall comply with the definition of the oil subcategory: the boiler burns any liquid fuel and is not in either the biomass or coal subcategories. (40 CFR 63, 63.11200(c), 40 CFR 63.11237)

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. The permittee must comply with each work practice standard, emission reduction measure, and management practice specified in Table 2 to 40 CFR Part 63, Subpart JJJJJJ that applies to the permittee's boiler. An energy assessment completed on or after January 1, 2008 that meets or is amended to meet the energy assessment requirements in Table 2 of 40 CFR Part 63, Subpart JJJJJJ satisfies the energy assessment requirement. A facility that operates l)nder an energy m*anagement program established through energy management systems compatible with ISO 50001, that includes the affected units, also satisfies the energy assessment requirement.

(40 CFR 63.11201(b)) .

2. The permittee must conduct a performance tune-up according to Section 63.11223(b), stated in SC 111.4, and the permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the permittee conducted a tune-up of the boiler. (40 CFR 63.11214(b))

3. For affected sources subject to the work practice standard or the management practices of a tune-up, the permittee must conduct a performan~e tune-up according to paragraph (b) of Section 63.11223, stated in SC 111.4, and keep records as required in Section 63.11225(c), stated in SC Vl.1, to demonstrate continuous compliance.

The permittee must conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. (40 CFR 63.11223(a))

4. The permittee must conduct a tune-up of the boiler biennially to demonstrate continuous compliance as specified in paragraphs (b)(1) through (7) of Section 63.11223, as listed below. Each biennial tune-up must be conducted no more th-an 25 months after the previous tune-up: (40 CFR 63.11223(b))

a. As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the permittee may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. (40 CFR 63.11223(b)(1))

Page 27 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

b. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern.

The adjustment should be consistent with the manufacturer's specifications, if available. (40 CFR 63.11223(b)(2))

c. Inspect the system controlling the air-to-fuel ratio, as applicable, *and ensure that it is correctly calibrated and functioning properly (the permittee may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection.

(40 CFR 63.11223(b)(3))

d. Optimize 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))

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 tal<en using a portable CO analyzer. (40 CFR 63.11223(b)(5))

f. Maintain on-site and submit, if requested by the Administrator, a report containing the information in paragraphs (b)(6)(i) through (iii) of Section 63.11223, as listed below (40 CFR 63.11223(b)(6)):

i. The concentrations of CO in the effluent stream *iri 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 the boiler.

(40 CFR 63.11223(b )(6)(i)) ii. A description of any corrective actions taken as a pgrt of the tune-up of the boiler. (40 CFR 63.11223(b)(6)(ii)) iii. The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, 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))

g. 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))

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The boiler shalf have a heat input capacity of equal to or greater than 1O MM Btu per hour. (40 CFR Part 63, Subpart JJJJJJ)

V. TESTING/SAMPLING Records shall be maintained on file for a period offive 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 in paragraphs (c)(1) through (7) of Section 63.11225, as listed below: (40 CFR 63.11225(c))

a. As required in Section 63.1 O(b)(2)(xiv), the permittee must keep a copy of each notification and report that the permittee submitted to comply with 40 CFR Part 63, Subpart JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status that the permittee submitted.

(40 CFR 63.11225(c)(1))

b. The perniittee must keep records to document conformance with the work practices, emission reduction measures, and management practices required by Sections 63.11214 and 63.11223 as specified in paragraphs (c)(2)(i) through (vi) of Section 63.11225, as listed below: (40 CFR 63.11225(c)(2))

i. Records must identify each boiler, 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 det.ermined not to be solid waste pursuant to 40 CFR Section 241.3(b)(1 ), the permittee must keep a record which documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If the permittee combusts a fuel that has been processed from a discarded non-hazardous secondary material pursuant to 40 CFR Section 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 CFR Section 241.2 and Page 28 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 each of the legitimacy criteria in 40 CFR Section 241.3(d)(1). If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR Section 241.3(c), the permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that com bust non-hazardous secondary materials as fuel per 40 CFR Section 241.4, the permittee must keep records documenting that the material is a listed non-waste under 40 CFR Section 241.4(a). (40 CFR 63.11225(c)(2)(ii)) iii. For each boiler required to conduct an energy assessment, the permittee must keep a copy of the energy assessment report. (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))

d. Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in Section 63.11205(a), stated in SC IX.4, including corrective actions to restore the malfunctioning boiler to its normal or usual manner of operation. (40 CFR 63.11225(c)(5))

2. The permittee's records must be 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 cif 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 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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

(R 336.1213(4)(c)) -4. The permittee must submit a signed certification in the Notification of Compliance Status report that an energy assessment of the boiler and its energy use systems was completed according to Table 2 to 40 CFR Part 63, Subpart JJJJJJ and is an accurate depiction of the permittee's facility. (40 CFR 63.11214(c))

5. The permittee must submit the notifications specified in paragraphs (a)(1) through (5) of .Section 63.11225, as listed below, to the administrator: (40 CFR63.11225(a)) *

a. The permittee must submit all of the notifications in Sections 63.7(b); 63.B(e) and (f); and 63.9(b) through (e),

(g), and (h) that apply to* the permittee by the dates specified in those Sections except as specified in parag*raphs (a)(2) and (4) ofSection 63.11225. (40 CFR63.11225(a)(1))

b. An Initial Notification must be submitted no later than January 20, 2014 or within 120 days after the source becomes subject to the standard. (40 CFR 63.11225(a)(2))

c. The p~rmittee must submit the Notification of Compliance Status no later than 120 days after the applicable compliance date specified in Section 63.11196, stated in SC IX.3. The permittee must submit the Notification of Compliance Status in accordance with paragraphs (a)(4)(i) and (vi) of Section 63.11225, as listed below.

The Notification of Compliance Status must include the information and certification(s) of compliance in paragraphs (a)(4)(i) through (v) of Section 63.11225, as applicable, and signed by a responsible official: (40 CFR 63.11225(a)(4))

i. The permittee must submit the information required in Section 63.9(h)(2), except the information listed in Section 63.9(h)(2)(i)(B), (D), (E), and (F). (40 CFR 63.11225(a)(4)(i))

ii. "This facility complies with the requirements in Section 63.11214 to conduct an initial tune-up of the boiler." (40 CFR 63.11225(a)(4)(ii)) iii. "This facility has had an* energy assessment performed according to Section 63.11214(c)." (40 CFR 63.11225(a)(4)(iii)) iv. For units that do not qualify for a statutory exemption as provided in Section 129(g)(1) of the Clean Air Act: "No secondary materials that are solid. waste were combusted in any affected unit." (40 CFR 63.11225(a)(4)(v)) Page 29 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

v. The notification must be suomitted electronically using the Compliance and Emissions Data R~porting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx).

However, if the reporting form specific to 40 CF.R Part 63, Subpart JJJJJJ is not available in CEDRI at the time that the report is due, the written Notification of Compliance Status must pe submitted to the Administrator at the appropriate address listed in Section 63.13. (40 CFR 63.11225(a)(4)(vi))

6. The permittee must prepare, by March 1 of each year, and submit to the delegated authority upon request, an annual compliance certification report for the previous calendar year containing the information specified in paragraphs (b)(1) through (4) of Section 63.11225. For boilers that are subject only to a requirement to conduct a biennial tune-up according to Section 63.11223(a) and not subject to emission limits or operating limits, the permittee may prepare only a biennial compliance report as specified in paragraphs (b)(1) and (2) of Section 63.11225, as listed below: (40 CFR 63.'11225(b)) *

a. Company name and address. (40 CFR 63.'il1225(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 certification(s) of compliance, as applicable, and signed by a responsible official: (40 CfR 63.11225(b)(2))

i.. "This facility complies with the requirements in Section 63.11223 to conduct a biennial or 5-year tune-up, as applicable, of each boiler." (40 CFR 63.11225(b)(2)(i)) ii. For units that do not qualify for a statutory exemption as provided in Section 129(g)(1) of the Clean Air Act: "No secondary materials that are solid waste were combusted in any affected unit." (40 CFR 63.11225(b )(2)(ii))

7. If the permittee intends to commence or recommence combustion of solid waste, the permittee must provide 30 days prior notice of the date upon which the permittee will commence or recommence combustion of solid waste. The notification must identify: (40 CFR 63.11225(f))

a. The name of the owner or operator of the affected source, the location of the source, the boiler(s) that will commence burning solid waste, and the date of the notice. (40 CFR 63.11225(f)(1))

b. The currently applicable subcategory under 40 CFR Part 63, Subpart JJJJJJ. (40 CFR 63.11225(f)(2))

c. The . date on which the permittee became subject to the currently applicable emission limits.

(40 CFR 63.11225(f)(3))

d. The date upon which the permittee will commence combusting solid waste. (40 CFR S3.11225(f)(4))

8. If the permittee has switched fuels or made a physical change to the boiler and the fuel switch or change resulted in the applicability of a different subcategory within 40 CFR. Part 63, Subpart JJJJJJ, in the boiler becoming subject to 40 CFR Part 63, Subpart JJJJJJ, or in the boiler switching out of 40 CFR Part 63, Subpart JJJJJJ due to a change to 100 percent natural gas, or the permittee has taken a permit limit that resulted in the permittee being subject to 40 CFR Part 63, Subpart JJJJJJ, the permittee must provide notice of the date upon which the permittee switched fuels, made the physical change, or took a permit limit within 30 days of the change. The notification must identify: (40 CFR 63.11225(9))

a. The name of the owner or operator of the affected source, the location of the source, the boiler(s) that have switched fuels, were physically changed, or took a permit limit, and the date of the notice.

(40 CFR 63.11225(9)(1))

b. The date upon which the fuel switch, physical change, or permit limit occurred. (40 CFR 63.11225(g)(2))

See Appendix 8 Page 30 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 VIII. STACKNENT 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 Minimum Height Underlying Applicable Exhaust Above Gro1.J11d Requirements Dimensions (feet) (inches) NA NA NA NA IX. OTHER REQUIREMENT(S)

1. 40 CFR Part 63, Subpart JJJJJJ applies to each existing affected source as defined in paragraph (a)(1) of Section 63.11194, as listed below: (40 CFR 63.11194(a)) .

a. The affected source of 40 CFR Part 63, Subpart JJJJJJ is the collection of all existing industrial, commercial, and institutional bqilers within a subcategory, as listed in Section 63.11200 and defined in Section 63.11237, located at an area source. (40 CFR 63.11194(a)(1))

2. An affected source is an existing source if the permittee commenced construction or reconstruction of the affected source on or before June 4, '2010. (40 CFR 63.11194(b))

3. If the permittee owns or operates an existing affected boiler, the permittee must achieve compliance with the applicable provisions in 40 CFR Part 63, Subpart JJJJJJ as specified in paragraphs (a)(1) and (3) of Section 63.11196, as listed below: (40 CFR 63.11196(a))

a. If the existing affected boiler is subject to a work practice or management practice standard of a tune-up, the permittee must achieve compliance with the work practice or management practice standard no later than March 21, 2014. (40 CFR 63.11196(a)(1))

b. If the existing affected boiler is subject to the energy assessment requirement, the permittee must achieve compliance with the energy assessment requirement no later than March 21, 2014. (40 CFR 63.11196(a)(3))

4. At all times the permittee must operate and maintain any affected source, 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 ariy further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Aoministrator 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))

5. For existing affected boilers that have applicable work practice standards, management practices, or emission reduction measures, the permittee must demonstrate initial compliance no later than the compliance date that is*

specified in Section 63.11196, stated in SC IX.3, and according to the applicable provisions in Section 63. 7(a)(2), except as provided in paragraph U) of Section 63.11210, stated in SC IX.9. (40 CFR 63.1121 O(c))

6. If the permittee owns or operates an industrial, commercial, or institutional boiler and would be subject to 40 CFR Part 63, Subpart JJJJJJ except for the. exemption in Section 63.11195(b) for commercial and industrial solid waste incineration units covered by 40 CFR Part 60 Subpart CCCC or Subpart DODD, and the permittee ceases combusting solid waste, the permittee must be in compliance with 40 CFR Part 6~, Subpart JJJJJJ on the effective date of the waste to fuel switch as specified in Section 60.2145(a)(2) and (3) of Subpart CCCC or Section 60.271 O(a)(2) and (3) of Subpart DODD. (40 CFR 63.11196(d))

7. For affected boilers that ceased burning solid waste consistent with Section 63.11196(d) and for which the initial compliance date has passed, the permittee must demonstrate compliance within 60 days of the effective date of the waste-to-fuel switch as specified in Section 60.2145(a)(2) and (3) of Subpart CCCC or Section 60.271 O(a)(2) and (3) of Subpart DODD. If the permittee has not conducted their compliance demonstration for 40 CFR Part 63, Subpart JJJJJJ within the previous 12 months, the permittee must complete all compliance demonstrations for 40 CFR Part 63, Subpart JJJJJJ before commencing or recommencing combustion of solid waste. (40 CFR 63.11210(9))

Page 31 of 43

ROP No: 'MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

8. For affected boilers that switch fuels or make a physical change tq the boiler that results in the applicability of a different subcategory within 40 CFR Part 63, Subpart JJJJJJ or the boiler becoming *subject to 40 CFR Part 63, Subpart JJJJJJ, the permittee must demonstrate compliance within 180 days of the effective date of the fuel switch or the physical change. Notification of such changes must be submitted according to Section 63.11225(g),

stated in Vll.8. (40 CFR 63.11210(h))

9. For existing affected boilers that have not operated between the effective date of the rule and the compliance date that is specified for the permittee's source in Section 63.11196, the permittee must comply with the applicable provisions as specified in paragraphs U)(2) and (3) of Section 63.11210, as listed below:

(40 CFR 63.1'i210(j))

a. The permittee must complete the initial performance tune-up, if subjecfto the ti.Jne-up requirements in Section 63.11223, by following the procedures described in Section 63.11223(b), stated in SC 111.4, no later than 30 days after the re-start of the affected boiler. (40 CFR 63.1121 O(j)(2))

b. The permittee must complete the one-time energy assessment, if subject to the energy assessment requirements specified in Table 2 of 40 CFR Part 63, Subpart JJJJ_JJ, no later than the compliance date specified in Section 63.11196, stated in SC IX.3. (40 CFR 63.1121 O(j)(3))

10. Table 8 to 40 CFR Part 63, Subpart JJJJJJ shows which parts of the General Provisions in Sections 63.1 through

   . 63.15 apply to the permittee. (40 CFR 63.11235)

Footnotes: 1 This condition is state only enforceable and was established pursuant to Rule 201 (1)(b). 2 This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a). Page 32 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG~NSPS!Ui I EM~SS~ON UNIT CONDIT~ONS DESCRIPTION Any emergency reciprocating internal combustion engine subject to 40 CFR 60, Subpart 1111. Emission Unit: EU-DRYCASKDSLGEN POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S) Pollutant limit Time Equipment Monitoring/ Underlying Applicable Period/Opera~ing Testing Requirements Scenario Method

1. NMHC + 4.0 g/kW-hr Hourly EU- SC V.1 or SC 40 CFR 89.112(a)

NOx DRYCASKDSLGEN Vl.2

2. co 3.5 g/kW-hr Hourly EU- SC V.1 or SC 40 CFR 89.112(a)

DRYCASKDSLGEN Vl.2

3. PM 0.2 g/kW-hr Hourly EU- SC V.1 or SC 40 CFR 89.112(a)

DRYCASKDSLGEN Vl.2 II. MATERIAL LIMIT(S) Material Limit Time Equipment Monitoring/ Underlying Applicable Period/Operating Testing Requirements Scenario Method

1. Diesel Fuel Sulfur Instantaneous EU- SC Vl.3 40 CFR 60.4207(b) content shall DRYCASKDSLGEN 40 CFR 80.510(b) not exceed 15 ppm Ill. PROCESS/OPERATIONAL RESTRICTION(S).

1. The permittee shall operate and maintain stationary Cl ICE that achieve the emission standards as required in 40 CFR.60.4204 and 60.4205 over the entire life of EU-DRYCASKDSLGEN. (40 CFR 60.4206)

2. The permittee shall maintain and operate EU-DRYCASKDSLGEN per the manufacturer's emission related written instructions. (40 CFR 60.4211 (a)(1))

3. The permittee shall operate EU-DRYCASKDSLGEN according to the requirements in 40 CFR 60.4211 (f)(1) through (3). In order for EU-DRYCASKDSLGEN to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency *situations for 50 .hours per year, as described in paragraphs 40 CFR 60.4211 (f)(1) through (3), is prohibited. If the permittee does not operate the engine according to the requirement?

in paragraphs 40 CFR 60.4211 (f)(1) through (3), the engine will not be consi.dered an emergency engine under this subpart and must meet all requirements for non-emergency engines. There is no time limit on the use of EU-DRYCASKDSLGEN in emergency situations. (40 CFR 60.4211(f), 40 CFR S0.4211(f)(1)) 4 .. The permittee may operate EU-DRYCASKDSLGEN for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (f)(3) of this section counts as part ofthe 100 hours per calendar year allowed by this paragraph (f)(2): (40 CFR 60.4211 (f)(2)) Page 33 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

a. EU-DRYCASKDSLGEN may be operated for 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 owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but 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 ICE beyond 100 hours per calendar year.

b. EU-DRYCASKDSLGEN may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.

c. EU-DRYCASKDSLGEN may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

5. The permittee may operate EU-DRYCASKDSLGEN for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (f)(2) of this section. Except as provided in paragraph (f)(3)(i) of this section, 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 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))

a. The 50 hours per year for ncin-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met:

i. The engine is dispatched by th.e local balancing authority or local transmission and distribution system operator; ii. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region.

iii. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. iv. The power is provided only to the facility itself or to support the local transmission and distribution system.

v. The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator.

IV. DESIGN/EQUIPMENT PARAMETER(S)

1. The permittee shall install a non-resettable hour meter on EU-DRYCASKDSLGEN prior to startup of the engine.

(40 CFR 60.4209(a)) V. TESTING/SAMPLING Records shall be maintained on file for a period of five years. (R 336.1213(3)(b)(ii))

1. Within 180 days after issuance of this permit, the permittee shall verify NMHC + NOx, CO, and PM emission rates frqm EU-DRYCASKDSLGEN, by testing at owner's expense, in accordance with Department requirements or by providing manufacturer certification documentation c;is required in SC Vl.2. If testing is to be performed, the permittee must submit a complete stack-testing plan to the AQD. No less than 60 days prior to testing, the permittee must submit a complete stack-testing plan to the AQD. The AQD must approve the final plan prior to testing. Verification of emission rates includes the submittal of a complete report of the test results to the AQD within 60 days following the last date of the test. (R 336.2001, R 336.2003, R 336.2004, 40 CFR 60.4211)

Page 34 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: Ml-PTl-84252-2018 VI. MONITORING/RECORDKEEPING Records shall be maintained on file for a period offive years. (R 336.1213(3)(b )(ii))

1. The permittee shall keep in a satisfactory manner, records of hours of operation recorded through the non-resettable hour meter. The permittee shall document how many hours were spent during emergency operation, non-emergency operation and demand response operation. The permittee shall keep all records on file and make them available to the department upon request. (R 336.1213(3), 40 CFR 60.4214(b))

2. The permittee shall keep, in a satisfactory manner, a record of testing required in SC V.1 or manufacturer certification documentation indicating that EU-DRYCASKDSLGEN meets the applicable emission limitations contained in the federal Standards of Performance for New Stationary Sources 40 CFR Part 60, Subpart 1111. The permittee shall keep all records on file and make them available to the Department upon request.

(40 CFR 60.4211)

3. The permittee shall keep, in a satisfactory manner, fuel supplier certification records or fuel sample test data, for each delivery of diesel fuel oil used in EU-DRYCASKDSLGEN, demonstrating that the fuel sulfur content meets the requirement of 40 CFR 80.51 O(b). The certification or test data shall include the name of the oil supplier or laboratory, and the sulfur content of the fuel oil. (40 CFR 60.4207{a), 40 CFR 80.51 O(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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

{R 336.1213{4){c)) See Appendix 8 VIII. STACK/VENT RESTRICTION(S) NA IX. OTHER REQUIREMENT(S)

1. The permittee shall comply with all applicable provisions of the federal Standards of Performance for New Stationary Sources as set forth in 40 CFR Part 60, Subpart A and Subpart 1111. (40 CFR Part 60, Subpart A and 1111) .

Footnotes: _1 This condition is state only enforceable and was established pursuant to Rule 201 (1)(b). 2 This condition is federally enforceable and was established pursuant to Rule 201 (1 )(a). Page 35 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG-_RULE 287(2)(c) FLEXIBLE GROUP CONDITIONS DESCRIPTION Paint shop that supports plant operations. Emission controls include a spray booth with filtration and a limitation of 200 gallons or less per month of paints, and coatings being used. Emission Unit: EU-PAINTSHOP POLLUTION CONTROL EQUIPMENT NA I. EMISSION LIMIT(S) NA II. MATERIAL LIMIT(S) Material Limit Time Period/ Operating Equipment Underlying Applicable

                                                 *scenario                                     Reauirement

1. Coatings 200 Per month, as r;:1pplied, minus NA R 336.1287(2)(c)(i) aallons water, oer emission unit Ill. PROCESS/OPERATIONAL RESTRICTION(S)

NA IV. DESIGN/EQUIPMENT PARAMETER(S) 1.. Any exhaust system 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 owner or operator 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. (R 336.1287(2)(c)(ii)) V. TESTING/SAMPLING Records shall be maintained on file for a period offive 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 shall maintain records of the following information for each emission unit for each calendar month .

using the methods outlined in the DEQ, AQD Rule 287(2)(c), Permit to Install Exemption Record form (EQP 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 336.1213(3)) *

Page 36 of43

ROP No: MI-ROP-84252~2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. (R 336. 'i213(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 15 for reporting period July 1 to December 31 and September 15 for reporting period January 1 to June 30. (R 33S:i213(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 15 for the previous calendar year.

(R 336.1213{4)(c)) See Appendix 8 VIII. STACKNENT RESTRICTION(S) NA IX. OTHER REQUIREMENT(S) NA Page 37 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 FG-COlD CLEANERS FLEX~BLE GROUP COND~T~ONS DESCRIPTION . Five parts cleaner stations with closeable covers located in the plant and elsewhere on site. They may be relocated from time to time depending on maintenance needs. Emission Unit: EU-COLDCLEANERS 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 336.1213(2))

Ill. PROCESS/OPERATIONAL RESTRICTION(S)

1. Cleaned parts shall be drained for no less than 15 seconds or until dripping ceases. (R336.1611(2)(b),

R 336.1707(3}(b))

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

(R 336.1213(3)) IV. DESIGN/EQUIPMENT PARAMETER(S)

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 336.128'1 (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)rj{iv))

2. The cold cleaner shall be equipped with a device for draining cleaned parts. (R 336.1611(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 336.1611(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 120 degrees Fahrenheit, then the cold cleaner must comply with at least one of the following provisions:

a. The co_ld 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))

Page 38 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018

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 offive years. (R 336.1213(3)(b)(ii)} NA VI. MONITORING/RECORDKEEPING Records shall b.e 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 336.1,213(3})

2. The permittee shall maintain the following information on file for each cold cleaner: {R 336.1213(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 comme*nced operation.

c. The air/vapor interface area for any unit claimed to be exempt under Rule 281 (2)(h).

d. The applicable Rule 201 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 written operating procedures for each cold cleaner. These written procedures shall be posted in an accessible, conspicuous location near each cold cleaner. (R 336.1611 (3), R 336.1707(4))

4. As noted in Rule 611 (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 336.1611(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 15 for reporting period July 1 to December 31 and September 15 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 15 for the previous calendar year.

(R 336.1213(4)(c)) See Appendix 8 VIII. STACKNENT RESTRICTION(S) . NA IX. OTHER REQUIREMENT(S) NA Page 39 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 IE. NON-APPUCABLE 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). Page40 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 APPEND;CES A,ppen d"IX 'i A cronyms an dAbb rev1at1ons Common Acronyms Pollutant/ Measurement Abbreviations AQD Air Quality Division acfm Actual cubic feet per minute BACT Best Avail.able Control Technology BTU British Thermal Unit CAA Clean Air Act oc Degrees Celsius CAM Compliance Assurance Monitoring co Carbon Monoxide CEM Continuous Emission Monitoring C02e Carbon Dioxide Equivalent CFR Code of Federal Regulations dscf Dry standard cubic foot COM Continuous Opacity Monitoring dscm Dry standard cubic meter DepartmenU. Michigan Department of Environmental OF Degrees Fahrenheit department Quality- gr Grains EU Emission Unit HAP Hazardous Air Pollutant FG Flexible Group Hg Mercury GACS Gallons of Applied Coating Solids hr Hour GC General Condition HP Horsepower GHGs Greenhouse Gases H2S Hydrogen Sulfide HVLP High Volume Low Pressure* kW Kilowatt ID Identification lb Pound IRSL Initial Risk Screening Level m Meter ITSL Initial Threshold Screening Level mg Milligram LAER Lowest Achievable Emission Rate mm Millimeter MACT Maximum Achievable Control Technology MM Million MAERS Michigan Air Emissions Reporting System MW Megawatts MAP Malfunction Abatement Plan NMOC Non-methane Organic Compounds MDEQ Michigan Department of Environmental NOx Oxides of Nitrogen Quality ng Nanogram MSDS Material Safety Data Sheet PM Particulate Matter NA Not Applicable PM10 Particulate Matter equal to or less than 10 NAAQS National Ambient Air Quality Standards microns in diameter NESHAP National Emission Standard for Hazardous PM2.5 Particulate Matter equal to or less than 2.5

Air Pollutants microns in diameter NSPS New Source Performance Standards pph Pounds per hour NSR New Source Review ppm Parts per million PS Performance Specification ppmv Parts per million by volume PsD* Prevention of Significant Deterioration ppmw Parts per million by weight PTE Permanent Total Enclosure psia *Pounds per square inch absolute PTI Permit to Install psig Pounds per square inch gauge RACT Reasonable Available Control Technology scf Standard cubic feet ROP Renewable Operating Permit sec Seconds SC Special Condition S02 Sulfur Dioxide SCR Selective Catalytic Reduction TAC Toxic Air Contaminant SNCR Selective Non-Catalytic Reduction Temp Temperature SRN State Registration Number THC Total Hydrocarbons TEQ Toxicity Equivalence Quotient tpy Tons per year USEPA/EPA United States Environmental Protection µg Microgram Agency µm Micrometer or Micron VE Visible Emissions voe Volatile Organic Compounds yr Year
For HVLP applicators, the pressure measured at the gun air cap shall not exceed 1O psig.

Page 41 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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 perinittee 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 336.1119(a)(ii)) Appendix 3. Monitoring Requirements Specific monitoring requirement procedures, methods or specifications are detailed in Part A or the appropriat~ 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/o*r Flexible Group Special Conditions. Therefore, this appendix is not applicable. Appendix 5. Testing Prncedures Specific testing requirement plans, procedures, and averaging times are detailed in the appropriate Source-Wide; Emission Unit and/or Flexible Group Special Conditions. Therefore, this appendix is not applicable. Appendix 6. Permits to Install The following table lists any Permit to Install {PTI) and/or Operate that relate to the identified emission units or flexible groups as of the effective date of this ROP. This includes all PTls and/or Operate that are hereby incorporated into Source-Wide PTI No. MI-PTl-84252-2018.- The PTls issued after the effective date of this ROP, including amendments or modifications, will be identified in Appendix 6 upon renewal.

                                                                                                              < C,orre!SROnd(ng Eroissipn .t 1

Petrilit t<> 1't1stall N~mbe~; Desc~iptio~)~t Eq.uipment * * .

                                                      .               ,_   (  ,,   ..,           0
                                                                                                                    . . * .

Un!t(s}. or * ...

                     . *.,                                                 .;_*,,                                 :: : FlexibhfGroup(sl .

460-93A Four emergency diesel generator engines FG-EMERDIESELS (35.088 MMBtu/hr heat input each). FG-MACTZZZZ 260-038 Alternate plant space heating boiler - No. 2 FG-MACTJJJJJJ fuel oil (28.56 MMBtu/hr heat input) installed under a qeneral permit. 34-05 Two 5,000 kw supplemental diesel FG-ENGINES generators. FG-MACTZZZZ Appendix 7. Emission Calculations Specific emission calculations to be used with monitoring, testing or recordkeeping data are detailed in the appropriate Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Therefore, this appendix is not applicable. Appendix 8. Reporting A. Annual, Semiannual, and Deviation Certification Reporting The permittee shall use the MDEQ, AQD, Report Certification form (EQP 5736) and MDEQ, AQD, Deviation Report form (EQP 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. Page 42 of 43

ROP No: MI-ROP-84252-2018 Expiration Date: March 15, 2023 PTI No: MI-PTl-84252-2018 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. Page 43 of43}}

AEP-NRC-2018-36, Notification of Initial Renewable Operating Permit

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AEP-NRC-2018-36, Notification of Initial Renewable Operating Permit

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Enclosure:

Dear Mr. Harner:

SUBJECT:

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