July 3, 2018
                                CERTIFIED MAIL
Douglas Haiston
Unit Manager
MidAmerican Energy Company  -  Riverside Generating Station
6001 State Street
Bettendorf, IA 52722

Re:  Plant Number 82-02-006; Project Number 18-194; Issuance of Construction Permits 

Dear Mr. Haiston:

The Department has completed the review of your air construction permit application first submitted on May 14, 2018, and later modified on June 22, 2018, regarding the modification of permits issued to equipment located at your Bettendorf, Iowa facility, for the purpose of restricting HAP emissions below the NESHAP major source thresholds.  A determination has been made that the following permits shall be issued:

                                Emission Unit 
                                  Description
                                     EP ID
                     Control Equipment Description (CE ID)
                                 Stack Testing
                                 Permit Number
Boiler #9 (EU-1)
                                     EP-1
                   Low-NOx Burner & Over-fire Air (CE-2)
                                      No
                                  93-A-339-S3
LNG Vaporizer #1 (EU-70)
                                     EP-70
                                     None
                                      No
                                  06-A-027-S2
LNG Vaporizer #2 (EU-71)
                                     EP-71
                                     None
                                      No
                                  06-A-028-S2
Auxiliary Boiler #1 (EU-87)
                                     EP-87
                                     None
                                      No
                                  13-A-008-S3
Auxiliary Boiler #2 (EU-88)
                                     EP-88
                                     None
                                      No
                                  13-A-009-S3

Your attention is directed toward the permit conditions within these permits, especially Condition 1 (Emission Limits), Condition 2 (Compliance Demonstration), and Condition 5 (Operating Requirements with Associated Recordkeeping and Monitoring).  For modification to these permits, please use the permit numbers listed in this letter and your plant number (82-02-006) for identification.  

Based on the information submitted in this and in previous applications, the Department has made the following determinations:

 Plant Number 82-02-006 is classified as a major stationary source with regard to the Title V Operating Permit program.  As a result of this project (18-194), the Title V operating permit application currently under Department review may need to be modified.  Please contact Julie Duke at Jule.Duke@dnr.iowa.gov or at (515) 725-9539. 

 Plant Number 82-02-006 is one of the 28 listed Prevention of Significant Deterioration (PSD) stationary source categories.  This facility is classified as a "major stationary source" for PSD purposes; however, PSD review was not required for Project Number 18-194 as no emission increases will take place as a result of this project.  Therefore, Project Number 18-194 is considered a "minor modification to a major source."

 Boiler # 9 (EU-1) is of the source category affected by NSPS Subparts D (Standards of Performance for Fossil-Fuel-Fired Steam Generators) and Da (Standards of Performance for Electric Utility Steam Generating Units). However, this unit is not subject to either of this subparts, because its construction date was prior to the applicability date for each of these federal rules and the unit has not been modified since its construction date.

 LNG Vaporizers #1 and #2 (EU-70 and EU-71) and Auxiliary Boilers #1 and #2 (EU-87 and EU-88) are subject to NSPS Subparts A (General Provisions) and Dc (Small Industrial-Commercial-Institutional Steam Generating Units).

 As a result of Project Number 18-194, Plant Number 82-02-006 has become a synthetic minor source for NESHAP purposes.  As a result, the following statements apply to the permitted equipment at Plant 82-02-006:

            
 Boiler #9 (EU-1) is not an affected emission unit under NESHAP, because there are no applicable categories at this time.
            
 LNG Vaporizers #1 and #2 (EU-70 and EU-71) and Auxiliary Boilers #1 and #2 (EU-87 and EU-88) are of the source category, but not subject to NESHAP Subpart JJJJJJ (Industrial, Commercial, and Institutional Boilers Area Sources), because each of these units meets the definition of "gas-fired boiler" in 40 CFR §63.11237 of Subpart JJJJJJ.

Initial compliance testing is waived for this project.  However, the Department maintains the right to require testing of any source of emissions in the future if needed [567 IAC 25.1(7)].

Per 561 IAC 7.4(1), the owner or operator shall file a written notice of appeal within thirty (30) days of receipt of the issued permit(s).  The written notice of appeal shall be filed with the Director of the Department with a copy to the Legal Services Bureau Chief at the following addresses:

Director
Iowa Department of Natural Resources
502 East 9[th] Street
Des Moines, IA  50319
Bureau Chief
Legal Services Bureau
Iowa Department of Natural Resources
502 East 9[th] Street
Des Moines, IA  50319

In addition to the permit, the following document is enclosed: Air Quality Construction Permits Common Acronyms.   
  
For future reference, a status report of all construction permit applications submitted to the Department is available at www.iowadnr.gov/airpermitsearch.  If you have any general air quality construction permitting questions, please call 1-877-AIR-IOWA.  If you have any questions regarding the permits specified in this letter, please contact Rachel Quill at Rachel.Quill@dnr.iowa.gov or at (515) 725-9556.

Sincerely,


Michael Hermsen
Environmental Engineer Senior
Air Quality Bureau, IDNR
ENC
