

Plant Number:  82-02-006

Company:  MidAmerican Energy Company  -  Riverside Generating Station

Contact Person:
Responsible Party:
Douglas Haiston
Same
Unit Manager



(563) 333-8503

DHHaiston@midamerican.com 



6001 State Street

Bettendorf, IA 52722



                          Project/Process Description
                                       
                                LNG Vaporizers
                                       

 Equipment Location:	6001 State Street
 			  	Bettendorf, IA 52722	
 				
 Project Number: 18-194
 
 Project Description: (1) Modify NESHAP applicability and (2) Create a "Collection of Air Permits" for the LNG Vaporizers (EU-70 and EU-71) at Plant Number 82-02-006.
 
 Date:  07/03/2018               
 
 
 
 
 
 
 

 
 

--------------------------------------------------------------------------------

The permits in this document are issued in accordance with 567 Iowa Administrative Code Chapter 22, and are issued subject to the terms and conditions contained in this document.  Issuance of the permits in this document shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.  If any permit contained in this document is modified, superseded, expires, or for any other reason changes or ceases to exist, the status of that permit shall not affect the validity or enforceability of any other permit contained in this document.

                                                                               
                                                                               
                                     Under the Direction of the Director of the
                                                Department of Natural Resources

                                       
               "Collection of Air Permits" Description Table
                                       

                                       
                                     EP ID
                                     EU ID
                                 Description 
                                   Maximum 
                                    Design
                                   Capacity
                             CE Description and ID
                                 Stack Testing
                                 Permit Number
                                       
                                     EP-70
                                     EU-70
LNG Vaporizer #1
                         23.196 MMBtu/hr, natural gas
                                       
                                     None
                                      No
                                       
                                  06-A-027-S2
                                       
                                     EP-71
                                     EU-71
LNG Vaporizer #2
                         23.196 MMBtu/hr, natural gas
                                       
                                     None
                                      No
                                       
                                  06-A-028-S2


                               PERMIT CONDITIONS


1. Emission Limits  -  Per Emission Point  

The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in any permit contained in this "Collection of Air Permits."  The following emission limits for each of the listed emission points shall not be exceeded:

                                     EP ID
                                   Pollutant
                                   lb/hr[1]
                                 Other Limits
                                Reference/Basis

EP-70

EP-71

Particulate Matter (PM)  -  State
                                      NA
                                0.6 lb/MMBtu[1]
                           567 IAC 23.3(2)"b"(3)

Opacity
                                      NA
                                  40%[2], [3]
                            567 IAC 23.3(2)"d"

Sulfur Dioxide (SO2)
                                      NA
                                   500 ppmv
                            567 IAC 23.3(3)"e"

Nitrogen Oxides (NOx)
                                    2.0[5]
                                      NA
                                See Footnote 4

[1] The emission limit is expressed as the average of three (3) runs.

[2] The emission limit is based on a six (6) minute average

[3] An exceedance of the indicator opacity of 25% will require the owner or operator to promptly investigate the emission unit and make corrections to operations or equipment associated with the exceedance.  If exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).

[4] The emission limit was established under Project Number 06-005 to demonstrate this project was not a significant increase for purposes of the Prevention of Significant Deterioration (PSD) program.


2. Compliance Demonstration(s) 
                                       
                       Compliance Demonstration Table  

                                     EP ID
                                   Pollutant
                            Compliance Methodology
                                   Frequency
                                Test Run Time 
                                  Test Method

EP-70

EP-71


PM - State
                                       
                                     None
                                       
                                      NA
                                       
                                    1 hour
40 CFR 60, Appendix A, Method 5 
40 CFR 51 Appendix M, Method 202

Opacity
                                     None
                                      NA
                                    1 hour
40 CFR 60, Appendix A, Method 9

SO2
                                     None
                                      NA
                                    1 hour
40 CFR 60, Appendix A, Method 6C

NOx
                                     None
                                      NA
                                    1 hour
40 CFR 60, Appendix A, Method 7E


Stack testing is not required for the emission points described in this "Collection of Air Permits" this time.

If stack testing is required by a construction permit, the owner or the owner's authorized agent shall use the test method and run time listed in the "Compliance Demonstration Table" unless another testing methodology is approved by the Department prior to testing. 

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each stack test shall consist of three (3) separate runs.  The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department.  

Per 567 IAC 25.1(7)"a", at the Department's request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration.  A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration.  Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any.  It shall be the responsibility of the owner to coordinate and schedule the pretest meeting.  A representative of the Department shall be allowed to witness the test(s).  The Department shall reserve the right to impose additional, different, or more detailed testing requirements.



2. Compliance Demonstration(s) (Continued)

The owner shall be responsible for the installation and maintenance of test ports.  The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


3.  Emission Point Characteristics

This emission points shall conform to the specifications listed below:

                                     EP ID
                                 Stack Height
                            (feet, from the ground)
                                Discharge Style
                            Stack Outlet Dimension 
                                   (inches)
                             Exhaust Temperature 
                                     (°F)
                            Exhaust Flowrate (scfm)
                                     EP-70
                                      36
                             Vertical, obstructed
                                      24
                                      245
                                     4,800
                                     EP-71
                                      36
                             Vertical, obstructed
                                      24
                                      245
                                     4,800

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point.  The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions.  If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.


4.  Federal Standards

 New Source Performance Standards (NSPS):

 The following subparts apply to the small industrial steam generating units described in this "Collection of Air Permits":

                                     EU ID
                                    Subpart
                                     Title
                                     Type
                           State Reference (567 IAC)
                          Federal Reference (40 CFR)
                                     EU-70
                                       
                                     EU-71
                                       
                                       A
General Provisions
                                      NA
                                    23.1(2)
                              §60.1  -  §60.19
                                       
                                     Dc[1]
Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units
                       Gas-fired steam generating units
                               23.1(2)"lll"
                             §60.40c  -  §60.48c
      
      [1] At the time of this permit issuance, the Department has adopted by reference amendments to NSPS, Subpart Dc through January 20, 2011. However, Plant No. 82-02-006 must comply will all applicable amendments to Subpart Dc.

            
 National Emission Standards for Hazardous Air Pollutants (NESHAP):

 The LNG vaporizers described in this "Collection of Air Permits" are of the source category, but not subject to 40 CFR Part 63, Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources), because each of these units meets the definition of "gas-fired boiler" in  §63.11237 of Subpart JJJJJJ.





5.  Operating Requirements and Associated Recordkeeping

Unless specified by a federal regulation, all records as required by these permits shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department.  Records shall be legible and maintained in an orderly manner.  The operating requirements and associated recordkeeping requirements for these permits shall be:

 The steam generating units described in this "Collection of Air Permits" shall combust only natural gas.

 The owner or operator shall operate and maintain steam generating units described in this "Collection of Air Permits" according to good engineering practices.
            
 The owner or operator shall maintain records of all inspection and maintenance activities and any action resulting from these.

 The owner or operator shall comply with the applicable standards in 40 CFR Part 60, Subpart Dc [§60.40c - §60.48c], including those not specifically mentioned in this permit.

 Per 40 CFR §60.48c(g)(1), the owner or operator shall record and maintain records of the amount of fuel combusted by each of the steam generating units described in this "Collection of Air Permits" during each operating day.  As an alternative to this requirement, the owner or operator may elect to:
            
 Record and maintain records of the amount of fuel combusted by each steam generating unit during each calendar month [40 CFR §60.48c(g)(2)]; or
            
 Record and maintain records of the total amount of each steam generating unit fuel delivered to the property during each calendar month [40 CFR §60.48c(g)(3)].


6.  Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.


7.  Department Review

These permits are issued under the authority of 567 Iowa Administrative Code (IAC) 22.3.  The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20  -  35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.  These permits are issued based on information submitted by the applicant.  Any misinformation, false statements or misrepresentations by the applicant or by the applicant's representative(s) shall cause the affected permit or permits to be void.  

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions.  The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.


8.  Owner and Operator Responsibility

These permits are for the construction and operation of specific emission unit(s), control equipment, and emission point(s) as described in these permits and in the applications for these permits.  The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in these permits conform to the design in the application (i.e. type, maximum rated capacity, etc.).  No person shall construct, install, reconstruct or alter any of the emission unit(s), or emission point(s), or the associated control equipment without the required amended permit(s).

Any owner or operator of the specified emission unit(s), emission point(s), or associated control equipment, including any person who becomes an owner or operator subsequent to the issuance date of the affected permit(s), is responsible for assuring that the installation, operation, and maintenance of the equipment listed in the permit(s) is in compliance with the provisions of the permit(s) and all other applicable requirements  and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


9.  Transferability

Unless the equipment is portable, these permit(s) are not transferable from one location to another or from one piece of equipment to another.  See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)"f").  


10.  Construction

 General Requirements:
      It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted.  
      
      In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment.  If a proposed project is not timely completed, the owner or operator shall seek a permit amendment in order to revert back to the most recent previous version of the permit.  The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.
      
      The permit or amendment shall become void if any one of the following conditions occurs:
 the construction or implementation of the proposed project, as it affects each emission point permitted herein, is not initiated within eighteen (18) months after the permit issuance date; or
  the construction or implementation of the proposed project, as it affects each emission point permitted herein, is not completed within thirty-six (36) months after the permit issuance date; or
 the construction or implementation of the proposed project, as it affects each emission point permitted herein, is not completed within a time period specified elsewhere in the permit.

 Changes to Plans and Specifications:
The owner or operator shall amend the permit or amendment prior to startup of the equipment if:
 Any changes are made to the final plans and specifications submitted for the proposed project; or
 The permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.

 Amended Permits:
The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s) and emission point, together with any previous amendment to the permit, until one of the following conditions occurs:
          The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission point permitted herein; or
          This current amendment becomes void.


11.  Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise.  Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period.  

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A.  If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1.  

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of the first working day following the onset of the incident (See Permit Condition 12.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 12.B.2).


12.  Notification, Reporting, and Recordkeeping

These requirements shall apply to each permit included in this "Collection of Air Permits." 

 The owner or operator shall furnish the Department the following written notifications:
          Per 567 IAC 22.3(3)"b":
             The date construction, installation, or alteration is initiated postmarked within thirty (30) days following initiation of construction, installation, or alteration.
             The actual date of startup, postmarked within fifteen (15) days following the start of operation.
          Per 567 IAC 22.3(3)"f," when portable equipment for which a permit has been issued is to be transferred from one location to another, the Department shall be notified:
          At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance area for the NAAQS.
          At least seven (7) days before equipment relocation.
          Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership within thirty (30) days of the occurrence.  The notification shall include the following information:
             The date of ownership change; the name, address, and telephone number of the responsible official, the contact person, and the owner of the equipment both before and after the ownership change; and the construction permit number(s) of the equipment changing ownership.
          Unless specified per a federal regulation, the owner or the owner's authorized agent shall notify the Department in writing not less than thirty (30) days before a required test or performance evaluation of a continuous emission monitor [567 IAC 25.1(7)].  The notification shall include:
             The time; the place; the name of the person who will conduct the tests; and other information as required by the Department.
         If the owner or operator does not provide timely notice to the Department, the Department shall not consider the test results or performance evaluation results to be a valid demonstration of compliance with the applicable rules or permit conditions.  Upon written request, the Department may allow a notification period of less than thirty (30) days.
      
 The owner or operator shall furnish the Department with the following reports:
 Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight (8) hours or at the start of the first working day following the onset of the incident.  The report may be made by electronic mail, in person or by telephone.
 Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition.
 Operation of this emission unit(s) or control equipment outside of those operating parameters specified in Permit Condition 5 in accordance to the schedule set forth in 567 IAC 24.1.
 Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days following the end of the calendar quarter, on forms provided by the Director.
 Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether successful or not, postmarked not later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements.  In that case, the more stringent reporting requirement shall be met.

 All data, records, reports, documentation, construction plans, and calculations required under each permit in this "Collection of Air Permits" shall be available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)









12.  Notification, Reporting, and Recordkeeping (Continued)

 Information regarding any permit in this "Collection of Air Permits" shall be sent to the attention of the following individuals based on the type of information being submitted:  change in ownership (Air Quality Bureau Records Center), permit correspondence (Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office).  The addresses are:

Air Quality Bureau
Iowa Department of Natural Resources
502 East 9th Street
Des Moines, IA  50319
Telephone:  (515) 725-8200
Fax:  (515) 725-9501
Washington Field Office #6
Iowa Department of Natural Resources
1023 West Madison Street
Washington, IA 52353
Telephone: (319) 653-2135
Fax: (319) 653-2856


13.  Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7.  Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7.  In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment.  The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.


14.  Permit History

                                  Project No.
                                  Permit No.
                                  Description
                                 Stack Testing
                                     Date
                                       
                                    06-005
                                       
                                   06-A-027
                     Original Permit for Emission Point 70
                              (LNG Vaporizer #1)
                                       
                                      Yes
                                       
                                  01/20/2006
                                       
                                    06-005
                                       
                                   06-A-028
                     Original Permit for Emission Point 71
                              (LNG Vaporizer #2)
                                       
                                      Yes
                                       
                                  01/20/2006
                                       
                                    06-353
                                  06-A-027-S1
                                       
                       Modify Recordkeeping Requirement
                                       
                                      Yes
                                       
                                  06/29/2006
                                       
                                  06-A-028-S1
                                       
                                       
                                       
                                       
                                       
                                    18-194
                                       
                                  06-A-027-S2
(1) Modify NESHAP applicability and (2) Create a "Collection of Air Permits" for the LNG vaporizers (EU-70 and EU-71) at Plant Number 82-02-006
                                       
                                       
                                      No
                                       
                                       
                                  07/03/2018
                                       
                                       
                                  06-A-028-S2

                                       
                                       

                                       
                                 END OF PERMIT
                                       
