                 United States Environmental Protection Agency
                                   Region 7
                          Air and Radiation Division
                      Air Permitting and Standards Branch
                            11201 Renner Boulevard
                               Lenexa, KS 66219

                        SYNTHETIC MINOR SOURCE PERMIT 

                        Permit Number R7-TMNSR-2023-001
                                       
In accordance with the provisions of the Clean Air Act (CAA) and the Federal Minor New Source Review Program in Indian Country, 40 CFR 49.151-49.161,   

                  Sac & Fox Tribe of the Mississippi in Iowa

is authorized to operate air emissions units and to conduct other air pollutant emitting activities in accordance with the permit conditions listed in this permit.

This source is authorized to operate at the following location:

                        Meskwaki Bingo Casino Hotel
                        1504 305[th] Street
                        Tama, Iowa 52339

Meskwaki Bingo Casino Hotel is located in Tama County, within the exterior boundaries of the Sac & Fox Tribe of the Mississippi in Iowa (Meskwaki Nation) Indian Settlement.

This permit places enforceable restrictions on the potential to emit of the existing operations at the Meskwaki Bingo Casino Hotel so that the provisions and requirements for major sources under the NSR and title V programs in 40 CFR parts 51 and 71 do not apply. 

Terms and conditions not otherwise defined in this permit have the meaning assigned to them in 40 CFR Part 49. All terms and conditions of the permit are enforceable by the U.S. Environmental Protection Agency and citizens under the CAA.
            
      This permit shall become effective on _____________, 2023.
      
      Issued this _____ day of ______________, 2023, by
                  
                  
      _________________________________________
      DeAndre Singletary
      Air and Radiation Division 


                               Table of Contents

SECTION I	- FACILITY DESCRIPTION	3
(A)	General Source Information	3
(B)	Adminstrative Revsion Request 	5
    (C)	   Emission Unit (EU) Descriptions..........................................................................5

SECTION II	- UNIT-SPECIFIC REQUIREMENTS	10
(A)	Engine-generators (RICE) .	10
(B)	Natural Gas Combustion Units (NGCU, including units asscoiated with cooking food)	14
(C)	Yard Storage Tank EU-YT-02R Dispensing Gasoline.	16

SECTION III	- FACILITY-WIDE REQUIREMENTS	16
(A)	Facility-wide NOx Emission Limitation, Monitoring and Recordkeeping Requirements.	16
(B)	Startup, Shutdown, Maintenance and Malfunction.	17
(C)	Records Retention Requirements.	17
(D)	Reporting Requirements.	18

SECTION IV	- GENERAL PERMIT REQUIREMENTS	19
(A)	Definitions	19
(B)	Issuance and Effective Date of Permit	19
(C)	Construction without a Permit	19
(D)	Construction Approval	20
(E)	Modifications to Existing Permitted Emissions Units/Limits	20
(F)	Compliance with Permit Requirements	20
(G)	National Ambient Air Quality Standards (NAAQS) / Prevention of Deterioration (PSD) Protection	21
(H)	Submittals	21
(I)	Severability	22
(J)	Entry and Inspection	22
(K)	Circumvention	22
(L)	Reservation	22
(M)	Permit Revision, Reopening, Revocation and Reissuance, or Termination	23




- FACILITY DESCRIPTION


General Source Information


Owner:	Sac & Fox Tribe of the Mississippi in Iowa 
	1504 305th Street
	Tama, Iowa 52339

Facility:	Meskwaki Bingo Casino Hotel
			1504 305th Street
			Tama, Iowa 52339

County: 		Tama

Reservation:	Sac & Fox Tribe of the Mississippi in Iowa (Meskwaki Nation) Indian Settlement

SIC Code:	7011 (Hotels and Motels)

NAICS Code:		721120 (Casino Hotels)

 ICIS Facility ID: 	#0700007000811121


The Sac & Fox Tribe of the Mississippi in Iowa owns and operates the Meskwaki Bingo Casino Hotel (MBCH).  

The MBCH facility includes the operation of six diesel-fired engine-generators (also referred to as RICE(s), Reciprocating Internal Combustion Engine (s)) and one natural gas fired backup RICE. Four of the diesel-fired RICE(s) are non-emergency RICE used for peak load management, storm avoidance, and emergency backup power. Two diesel-fired RICE(s) are used as backup units only. This synthetic minor source permit previously incorporated the replacement of an existing non-emergency type RICE with a new non-emergency RICE manufactured and installed in 2019. The new RICE was certified by the manufacturer to meet EPA Tier 4 emissions requirements. Additionally, MBCH has several storage tanks for fuel, several natural gas combustion units (NGCUs) consisting of boilers, furnaces, and water heaters used for space heating and water heating at the hotel/casino, collections of units associated with the cooking units, and four (4) induced draft cooling towers that provide comfort cooling for the MBCH buildings.

Air pollutants emitted from this facility's operations include nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides (SOx), volatile organic compounds (VOC), particulate matter (PM), PM with aerodynamic diameter equal to or less than 10 microns (PM10), PM with aerodynamic diameter equal to or less than 2.5 microns (PM2.5), hazardous air pollutants (HAP), and greenhouse gases (GHG).  The uncontrolled potential emissions of NOx are above the major source thresholds established under the Prevention of Significant Deterioration (PSD) permitting program regulations and the federal operating permit program regulations at 40 CFR Part 71 (Title V or Part 71).

A synthetic minor source permit was issued on September 10, 2019, under the authority of the Tribal Minor New Source Review Permit Program (TMNSR) at 40 CFR Part 49, (Permit Number R7-TMNSR-2019-002).  Under 40 CFR 49.158, a synthetic minor source permit may be obtained under this program to establish a synthetic minor source for nonattainment major New Source Review (NSR), PSD and Title V purposes and/or a synthetic minor HAP source for CAA standards established for maximum achievable control technology (MACT) and Title V purposes. Hence, the 2019 permit established federally enforceable nitrogen oxide (NOx) emission limitations for RICE-generators and several NGCUs operating at the facility to avoid PSD and/or Title V permitting requirements for major sources in 40 CFR parts 51 and 71 by limiting and monitoring the hours of operation and fuel usage of those emission units.  Table (B)(2) and Technical Support Document (TSD) of this permit contains the list of all NGCUs located at the site.

In 2020 and 2022 MBCH submitted permit applications to incorporate two new projects  -  laundry dryer and HVAC/heating replacement  -  into the synthetic minor source permit. The PTE for both projects by themselves were below the minor source thresholds (Table 1 of 40 CFR Part 49.153). However, a modification of the synthetic minor source permit was needed to revise the compliance formula. In addition, revisions also being made to make some requirements more robust and relevant with the new project scope. Thus, this current permitting action incorporates these changes at the facility into the synthetic minor permit issued in 2019 to MBCH.

The MBCH facility is currently under contract to serve as a peaking power plant throughout the year and must be available to operate upon demand. Regardless of the extent that such contract (or another similar contract in the future) affects the MBCH operations, the facility is required to comply with the conditions of this permit unless and until the permit is modified.

Emission Unit (EU) Descriptions

Engine-Generators (also referred as RICE(s), Reciprocating Internal Combustion Engine (s))

EU-ID#
                              Source Description
                  Control Device(s) -  Pollutants Controlled
                Control Device Efficiency / Emission Standards 
                  Generator Location  -  Power Usage Location
                        Applicable Federal Regulations
EU-EG-02
Diesel Fired RICE:
Detroit Diesel 16V149; 
Serial #: 16E0012327; 1800 rpm; 2-cycle; 16-cylinder; Rated Capacity: 2,340 hp (1,746 kW); 
Rated Heat Input: 16.6 MMBTU/hr; Rated Fuel Consumption: 121 gal/hr.

Year of Installation: 1994
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                                 ppmv on a dry
                       basis at 15% O2 per Subpart ZZZZ
                                 Central Plant
                                   - Casino 2
                                       
                                       
                              MACT Subpart ZZZZ,
                                       
                                MACT Subpart A
EU-EG-03
Diesel Fired RICE:
MTU Detroit Diesel 16V4000; 
Serial #: 5272002228; 1800 rpm; 16-cylinder; Rated Capacity: 
2,937 hp (2,190 kW); 
Rated Heat Input: 18.8 MMBTU/hr; 
Rated Fuel Consumption: 137 gal/hr

Year of Installation: 2005
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                                 ppmv on a dry
                       basis at 15% O2 per Subpart ZZZZ
                                 Central Plant
                                   - Casino 1
                              MACT Subpart ZZZZ,
                                       
                                MACT Subpart A
EU-EG-04
Diesel Fired RICE: 
MTU Detroit Diesel 20V4000; 
Serial #: 528100382; 1800 rpm; 4-cycle; 20-cylinder; 4.49 Liters per Cylinder; Rated Capacity: 4,036 hp (3,021 kW); Rated Heat Input: 26.2 MMBTU/hr; Rated Fuel Consumption: 191 gal/hr.

Year of Installation: 2006
                            Oxidation Catalyst  -  
                                      CO
                            CO reduction >= 70% or
                                 limited to 23
                ppmv on a dry basis at 15% O2 per Subpart ZZZZ 
         / NSPS Subpart IIII Table 1 standards for HC, NOx, CO, and PM
                             per 40 CFR 60.4204(a).
                                 Central Plant
                                - Central Plant
                              NSPS Subpart IIII, 
                                       
                                NSPS Subpart A,
                                       
                    MACT Subpart ZZZZ (applicability only)
EU-EG-05R
Diesel Fired RICE: 
Cat 3516C; 
Serial #: LY600124; 78.1 Liters; 4.88 Liters per Cylinder; Rated Capacity: 2,941 hp (2,194 kW); 
Rated Heat Input: 19.1 MMBTU/hr; Rated Fuel Consumption: 140 gal/hr

Year of Installation: 2019
                    Selective Catalytic Reduction  -  NOx;
                            Oxidation Catalyst  -  
                                      CO
              Tier 4 standards for PM, NOx, NMHC(VOC), and CO per
                        60.4201(a) and 40 CFR 1039.101
                                 Central Plant
                                    - Hotel
                              NSPS Subpart IIII,
                                        
                                NSPS Subpart A,
                                       
                    MACT Subpart ZZZZ (applicability only)
EU-EG-EMER
Three (3) emergency diesel fired RICE and one natural gas (NG) fired RICE. Combined rated capacity of 615 HP. 

Per 40 CFR 49.153(c)(9)(ii), emergency RICE with total maximum rated capacity < 1000 HP, is considered as exempt units from Tribal NSR permitting.

NOTE: The details of the emergency RICE is found in the Technical Support Document (TSD) - Appendix A, of this permit. 
                                     N.A.
                                     N.A.
                               North Roof Tower
                              NSPS Subpart JJJJ,
                                        
                                NSPS Subpart A,
                                       
                    MACT Subpart ZZZZ (applicability only)
*N.A. means not applicable. 
               
Natural Gas Combustion Units (NGCU)  -  Details are listed in the Technical Support Document (TSD).
               

EU ID
Type of Emission Units
Locations 
Natural Gas Meter #
Exempt Units - Yes or No; Citation for Exemption Category
                               Non-Exempt Units
EU-NG-DRY**
     Collection of three Girabau Dryers and Compact all-in-one kit (Press)
                                (total 4 units)
                                       
                    Combined Rated Capacity: 1.66 MMBtu/hr
                                 Hotel Laundry
#9743221
                                     No; 
                      40 CFR 40.153(c) is not applicable
EU-NG-CCP

    Collection of Boilers, Radiant heaters at one location (total 48 units)
                                       
                   Combined Rated Capacity: 27.685 MMBtu/hr
                             Casino Central Plant 
                                       
#9743221
                                     No; 
the boilers/heaters are > 10 MMBtu/hr. Hence 40 CFR 49.153(c)(11) is not applicable.
EU-NG-CMEC
                     Collection of Boilers at one location
                                (total 3 units)
                                       
                    Combined Rated Capacity: 2.175 MMBtu/hr
                                Casino Old Mech.
#9743221
                                       
                                       
                                       
                                       
                                       
                                       
                                     No; 
The combined total maximum from all units at the site > 10 MMBtu/hr, hence, 
40 CFR 40.153(c)(11)(iii)-Furnaces or boilers used for space heating that uses gaseous fuel is not applicable
EU-NG-NT
Collection of Boilers, Heaters and Fireplace Heating at one location (total 15 units)
                                       
                    Combined Rated Capacity: 9.14 MMBTU/hr
                                   Hotel  - 
                                  North Tower
#1343357
                                       
EU-NG-EB
                                  One Heater 
                                       
                        Rated Capacity: 0.075 MMBtu/hr
                                 East Building
#450057898
                                       
EU-NG-WH;
EU-NG-RT**
       Collection of heaters/HVACs and Radiant Heaters at two locations
                                (total 19 units)
                                       
                    Combined Rated Capacity: 2.43 MMBtu/hr*
                                       
                           Locations: Warehouse/Rec;
                        Roof top units (East Building)
                             1[st] and 2[nd] Floor
 #96216026
                                       
                                 Exempt Units 
EU-NG-C1 
 through 
EU-NG-C6
(Several units at each location)
Each ID# represents collection of NGCUs associated with the cooking of food at one of six (6) locations in the Casino.
                                       
                    Combined Rated Capacity: 7.709 MMBtu/hr
                                Six locations: 
       Casino  -  Café; Food Court; Buffet; Steakhouse; Bingo; Banquet
                                   # 9743221
                                     Yes; 
40 CFR 49.153(c)(3)  -  cooking food, except wholesale businesses for cooking and selling food.
Totals maximum rated capacity of all NGCUs (Non Exempt + Exempt)   = 50.874 MMBtu/hr
Total NG flow rate capacity from all the gas flow meters (Non Exempt + Exempt)  = 0.05 MMscf/hr (million standard cubic feet/hour). 
Note that gas meter # 1343357 also supplies natural gas to EU-EG-09 (emergency RICE)
*NOTE: 40 CFR 40.153(c)(12)  -  Air Conditioning units used for human comfort that do not exhaust pollutants from any manufacturing or other industrial process is not applicable for this group of units because these cannot be categorized as A/C units for human comfort. 
**New units installed since original permit was issued.

Fuel Storage Tanks for Engines and Yard

                                    EU-ID#
                              Source Description
                               Fuel Storage Type
                             Location  -  Purpose
                        Applicable Federal Regulations
                                   EU-ET-02
                   Engine Sub-base Storage Tank Aboveground
                           Installation Year: 1994.
                              Capacity 2000 gals
                                    Diesel
                          Central Plant  -  fueling 
                           Engine Generator EU-EG-02
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      NA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                   EU-ET-03
                   Engine Sub-base Storage Tank Aboveground 
                            Installation Year: 2005
                              Capacity 3000 gals
                                    Diesel
                          Central Plant  -  fueling 
                           Engine Generator EU-EG-03
                                       
                                   EU-ET-04
                   Engine Sub-base Storage Tank Aboveground 
                            Installation Year: 2006
                              Capacity 4000 gals
                                    Diesel
                          Central Plant  -  fueling 
                           Engine Generator EU-EG-04
                                       
                                   EU-ET-05
                   Engine Sub-base Storage Tank Aboveground.
                            Installation Year: 2019
                              Capacity 3,500 gals
                                    Diesel
                          Central Plant  -  fueling 
                          Engine Generator EU-EG-05R
                                       
                                   EU-ET-06
                   Engine Sub-base Storage Tank Aboveground.
                            Installation Year: 1993
                               Capacity 150 gals
                                    Diesel
                          Warehouse/Rec  -  fueling 
                           Engine Generator EU-EG-06
                                       
                                   EU-ET-07
                   Engine Sub-base Storage Tank Aboveground.
                            Installation Year: 1993
                               Capacity 150 gals
                                    Diesel
           East of GC Building  -  fueling Engine Generator EU-EG-07
                                       
                                   EU-YT-01R
Yard Storage Tank: Aboveground Double-Wall with Interstitial Leak Gauge Monitor.
                            Installation Year: 2019
                               Capacity 500 gals
                                    Diesel
                  Central Plant Parking Lot (northwest side)
                     -  fueling MBCH vehicles and equipment
                                       
                                   EU-YT-02R
Yard Storage Tank: Aboveground Double-Wall with Interstitial Leak Gauge Monitor.
                            Installation Year: 2019
                               Capacity 500 gals
                                   Gasoline
                  Central Plant Parking Lot (northwest side)
                     -  fueling MBCH vehicles and equipment
                    40 CFR Part 63 Subparts A & CCCCCC



Cooling Towers

                                    EU-ID#
                                 Manufacturer
                                     Model
                                   Serial #
                           Water Throughput Capacity
                                   (gal/hr)
                               Control Device(s)
                                   Location
                        Applicable Federal Regulations
                                   EU-CT-01
                             Baltimore Aircoil Co.
                                     3455A
                                  U053781504
                       Manufacture Date: Post April 2006
                                    98,400
                                       
                                      N.A
                                       
                          Central Plant  -  east unit
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                     None 
                                   EU-CT-02
                             Baltimore Aircoil Co.
                                     3455A
                                  U053781503
                      Manufacturer Date: Post April 2006
                                    98,400
                                       
                                 Central Plant
                                       
                                   EU-CT-03
                             Baltimore Aircoil Co.
                                     3455A
                                  U053781502
                      Manufacturer Date: Post April 2006
                                    98,400
                                       
                                Central Plant 
                                       
                                   EU-CT-04
                             Baltimore Aircoil Co.
                                     3455A
                                  U053781501
                       Manufacture Date: Post April 2006
                                    98,400
                                       
                          Central Plant  -  west unit
                                       
 N.A. means not applicable since there are no control devices. 
*  A construction proposal submittal to MBCH for the four cooling towers is dated August 8, 2005.  Nameplates on each of the cooling towers shows the CTI Certification Validation Number 92-11-06 which according to https://www.cti.org/downloads/win07journalfinal.pdf is associated with a date of May 1, 2006.
 -  UNIT-SPECIFIC REQUIREMENTS

RICE (s) shall comply with the following requirements:
           
 Emission Unit ID
 Fuel Type 
 Applicable Federal Regulations*
                               Non-Emergency RICE
 EU-EG-02
 Diesel 
 (Installed 1994)
 
 MACT (40 CFR Part 63) Subparts ZZZZ & A (General Provisions)
 EU-EG-03
 Diesel
(Installed 2005)
 
 EU-EG-04
 Diesel
(Installed 2006)
 NSPS (40 CFR Part 60) Subparts IIII & A (General Provisions). 
 
 MACT ZZZZ. 
 For EU-EG-04 there is an applicable limit per MACT ZZZZ.
 EU-EG-05R
 Diesel
(Installed 2019)
 
                                 Emergency RICE
 EU-EG-EMER 
(Consists of EU-EG-06, EU-EG-07 and EU-EG-09)

 Diesel (EU-EG-06), Diesel (EU-EG-07), 
 

 
 Natural Gas (EU-EG-09)

 MACT (40 CFR Part 63) Subparts A (General Provisions) & ZZZZ
 [EU-EG-06 and 07, installed 1993]
 

 NSPS (40 CFR Part 60) Subparts A (General Provisions) & JJJJ (natural gas).
 [EU-EG-09, installed 2022]
           * RICE following requirements via NSPS Subpart IIII or JJJJ, hence is not subject to any additional requirements from MACT Subpart ZZZZ. They are complying with rules by following NSPS requirements as applicable. 
 	        

Emission Limitations

                    The permittee shall not emit more than 74 tons of nitrogen oxides (NOx) per year from the diesel fired RICE(s), listed in the above table, as determined on a 12-month rolling sum basis. Note that this limit is applicable for both non-emergency and emergency type diesel fired RICE.

The permittee shall operate each RICE (both diesel & natural gas fired; includes both emergency and non-emergency type) with a non-resettable, totaling hour meter for monitoring the amount of time each RICE is operated.

In addition to the hour meter for each RICE (both diesel & natural gas fired; includes both emergency and non-emergency type), the permittee shall install, maintain and use a clock that is readily observable at the location where each RICE operation is started and stopped.
                    
If a non-resettable, totalizing hour-meter fails the permittee shall replace it within 60 days.
 
The permittee shall operate each diesel fired RICE, listed in the above table, using fuels limited to diesel, biodiesel, and renewable diesel only.

The permittee shall operate each diesel fired engine RICE identified in the above table, using diesel fuel that meets the requirements in 40 CFR 80.510(b) for Non-Road (NR) diesel fuel:

 Sulfur content: 15 ppm maximum for NR diesel fuel.

 Cetane index or aromatic content: minimum cetane index of 40; or a maximum aromatic content of 35 volume percent.

The permittee shall comply with all applicable Emission and Operating Limitations in 40 CFR Part 60 Subpart A and Subpart IIII for RICE identified as EU-EG-04 and EU-EG-05R (see above table insert). [Note that EU-EG-04 also has a limit under MACT Subpart ZZZZ.]

The permittee shall comply with all applicable Emission and Operating Limitations in 40 CFR Part 63 Subpart A and Subpart ZZZZ for RICE identified as EU-EG-02, EU-EG-03, and EU-EG-04 (see above table insert)
                   
For Emergency Type RICEs - both for the diesel natural gas fired RICEs (see above table for unit ID): 
                    
 The permittee shall operate each emergency RICE, according 40 CFRs Part 63.636640(f)(1) through (4) and Part 60.4243(d)(1) through (3) for MACT Subpart ZZZZ and NSPS Subpart JJJJ (applicable to natural gas fired RICE), respectively. 
               
 Failure to operate the any emergency type RICE per these requirements in Section II. (A) (1) (ix). a. of this document, pertaining to MACT Subpart ZZZZ and NSPS Subpart JJJJ, will result in the RICE being designated as non-emergency and subject to all applicable non-emergency RICE standards stated in the mentioned subparts. 
                          
 The definition of emergency with respect to RICE is specified in 40 CFRs 63.6675 (MACT Subpart ZZZZ) or 60.4248 (NSPS Subpart JJJJ). Note that term "RICE" and "stationary RICE" is synonymous, in the context of this permit. 
                          

 Emergency type RICE may be operated for up to 50 hours per calendar year in non-emergency situations as described at 40 CFR Part 60.4243(d)(3) for spark ignition ICE (natural gas fired). 

Monitoring, Recordkeeping and Reporting Requirements 

The permittee shall maintain for each RICE: all specifications and standard procedures for operation and maintenance developed by the manufacturer, vendor, or permittee to verify the maximum NOx emission rate, to verify the specifications listed in SECTION I (B) (1), and to reference during operation and maintenance procedures.

The permittee shall maintain the following for each hour meter associated with the operation of each RICE:  all specifications and standard procedures for operation and maintenance developed by the manufacturer, vendor, or permittee to verify the specifications, including the manufacturer's model number, and to reference during operation and maintenance procedures.

The permittee shall verify that the accuracy of each hour meter is within the manufacturer's design specification at least every five (5) years.

For each shipment of diesel fuel received, the permittee shall obtain and maintain a purchase receipt and a fuel supplier certification, certifying that the diesel fuel received meets the requirements in 40 CFR 80.510(b) for NR diesel fuel.

The permittee shall maintain an operational log that includes the following records in a hard copy or electronic form suitable and readily available for expeditious review:

 For each transfer of fuel to each sub-base storage tank that supplies fuel to a RICE: Emission Unit ID #, fuel type, quantity (gallons), date, time, identification of person(s) overseeing the transfer, and all observations and/or measurements made to determine amount of fuel in the tank before and after the transfer.
                         
 For each operation of a RICE: Emission Unit ID #, date, time and hour meter reading at both the beginning and end of each operation, identification of person(s) overseeing the operation, and the purpose of the operation.
                         
 Time of operations (hours/month) for each of the RICE.

 Fuel usage (gallons/month) for each of the diesel fired RICE calculated by multiplying the time of operation (hours/month) by the maximum fuel consumption rate at 100% load (gallons/hour) as specified in the 2019 application and shown in the table below: 

                                       
                              Non-Emergency RICE
                                Emergency RICE
                                      EU 
                                     ID #
                                   EU-EG-02
                                   EU-EG-03
                                   EU-EG-04
                                      EU-
                                    EG-05R
                                   EU-EG-06
                                   EU-EG-07
                 maximum fuel consumption rate (gallons/hour)
                                     121.0
                                     137.0
                                     191.0
                                     140.0
                                      9.0
                                      9.0
                         
 Date and description of all maintenance, repair, rebuild or replacement activities conducted for each RICE emission unit listed in SECTION I (B) (1); including but not limited to 40 CFR Part 63 Subpart ZZZZ required maintenance, lubrication service, cooling system service, fuel system service, overhauling, rebuilding, and swapping out components or parts.

 Date and description of all maintenance, repair, rebuild or replacement activities conducted for each emissions control and monitoring device associated with each RICE emission unit listed in SECTION I (B), Table (1) & (2), of this permit.

Within fifteen days of the end of each month, the permittee shall calculate and record the number of hours that each RICE was operated on a 12-month rolling sum basis, determined by adding the number of hours that the RICE operated for the month and then adding the number of hours that the engine-generator operated for the previous 11 months.

Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all RICE (s) (except for natural gas fired emergency RICE) using the following equation (1):

        NOx Emissions (tons/month)  = 
                   
                        [ (# Hours EU-EG-02 * 48.9 lb/hr) + 
                        (# Hours EU-EG-03 * 44.9 lb/hr) + 
                        (# Hours EU-EG-04 * 71.9 lb/hr) + 
                        (# Hours EU-EG-05R * 4.06 lb/hr) + 
                        (# Hours EU-EG-06 * 6.42 lb/hr) + 
                        (# Hours EU-EG-07 * 6.42 lb/hr)  ] * 1.1 * 1 ton/2,000 lbs.........      (1)
                   
                   Where: 
                    
                   EU-EG-06 and EU-EG-07 are designated as emergency RICE (diesel fired)
                   
                    # Hours refers to the number of hours that a specific RICE is operated for the month
                    
                    lb/hr factors associated with EU-EG-02, EU-EG-03, EU-EG-04, and EU-EG-05R are emission factors derived from engine specifications provided in the January 2019 permit application.
                    
                    lb/hr factors associated with EU-EG-06 and EU-EG-07 are emission factors derived from AP-42, Chapter 3, Table 3.3-1.
                    
                    1.1 is a safety factor that provides a 10% increase to each of the lb/hr emission factors in the equation to account for potential differences in emissions between the stack tested RICE unit, used to derive the lb/hr emission factors and the permitted RICE.

Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all RICEs (only diesel fired type) on a 12-month rolling sum basis. This is determined by adding the NOx emissions from all applicable RICE for any month and then adding the NOx emissions for the previous 11 months.

For the RICEs mentioned in the table insert above, in Section II (A) of this document, the permittee shall comply with all applicable Compliance, Testing, Notifications, Reports, and Records requirements in:
                    
 40 CFR Part 60 Subpart A (General Provisions), Subpart IIII and Subpart JJJJ, as applicable based on the fuel category.

 40 CFR Part 63 Subpart A (General Provisions) and Subpart ZZZZ, as applicable. 


Natural Gas Combustion Units (NGCUs) - Refer to Technical Support Document, Appendix A, for the details of all NGCUs.   

Emission Limitations

The permittee shall not emit more than 21 tons of nitrogen oxides (NOx) per year from all NGCUs (listed in TSD), as determined on a 12-month rolling sum basis.

The permittee shall operate each NGCU using only pipeline grade natural gas. The amount of natural gas consumed shall be recorded by one of four flow meters. The designation of gas meters for each NGCU is given in TSD, Appendix A.
                        
Monitoring, Recordkeeping and Reporting Requirements

The permittee shall operate all the identified gas meters with non-resettable flow measuring devices installed for monitoring the amount of natural gas being consumed collectively by the group of NGCUs. 
                    
The permittee shall maintain documentation for each NGCU as related to maintenance activities: 

 All specifications and standard procedures for operation and maintenance developed by the manufacturer, vendor, or permittee to verify the specifications, including the heat input and fuel input capacities, and to reference during operation and maintenance procedures.

 Date and description of any maintenance, repair, rebuild or replacement activities related to the emission units. Maintenance includes but is not limited to lubrication, cooling system, overhauling, rebuilding unit and swapping out components or parts. 

 Date and description of all maintenance, repair, rebuild/repair for each gas flow meter. 

The permittee shall maintain documentation for all emission units and gas flow meters containing the manufacturer model number, serial number, and the owner's operation and maintenance manuals

The permittee shall maintain an operational log that includes the following records:

 Natural Gas flow meter readings at the beginning and end of operations each month for each of the flow meters associated the four groups of NGCUs.

 Amount of natural gas consumed each month (MMscf/month) from each of the four groups of NGCUs as determined from the flow meter readings for each of the flow meters. The total amount of natural gas consumed each month is determined by summing the amounts of natural gas from each gas meter, active at the site.

 Maintain and log the natural gas quality reports, as available, depicting heating value and quality of the natural gas.

 Maintain and preserve documentation of expected fuel consumption for any the natural gas fired RICE ~ 100% load, such as manufacturer's specification sheet, owner's manual, engine certifications, 

The permittee shall maintain all records, logs, documentation in a hard copy or electronic form suitable and readily available for expeditious review.
                    
Within fifteen days of the end of each month, the permittee shall calculate and record the NOx emissions from all NGCUs, using the following equation (2) and its sub equations (2a) and (2b). Furthermore, emissions will be recorded on a 12-month rolling sum basis. Rolling sum totals is determined by adding NOx emissions from all the NGCU (i.e., collective NOx emissions from all units), for each consecutive 12 months.

      NOx Emissions (tons/month) (all NGCUs) = 

[NOx emissions from natural gas fired RICE] + [NOx emissions from natural gas fired Boilers/HVAC/Heating] (tons/month).............................................................................. (2)

Where, 
NOx emissions from natural gas fired RICEs tons/month= i=1nEFRICEeq lbMMScfx Fuel ConsumptionRICEMMScfhrxHours of OperationRICE hrx(1 ton2000)..................(2a)

                             
              n = no. of RICEs at the site connected to natural gas meter
  Fuel ConsumptionRICE (MMScf/hr) = Fuel consumption specified in the RICE's manufacture specifications at 100% load rate
            Hours of Operation (hrs) = Operating Hours for each RICE, as read from the non-resettable hour meter.
    EFRICEeq   (lb/MMScf) = Equivalent NOx emission factor for RICE without the natural gas consumption from the HVAC/Boilers/Heaters. It is calculated per equation below box:  


              EFRICEeq   =  EFRICE lbMMBtuxHV (MMBtuMMScf) - EFB/H lbsMMScf
               
                                            				
				EFRICE = NOx emission factor for natural gas fired RICE                                                     
                     HV = Heating value of Natural gas of 1050 MMBtu/MMScf (based on AP-42 Table)
                    EFB/H   = NOx emission factor natural gas fired uncontrolled small boilers 
                 
                  NOTE: EFRICEeq was calculated to be 2220.5 lb/MMscf for the EU-EG-09 (new natural gas fired RICE). Per AP-42 Table 3.2-3, uncontrolled NOx emission factor for 4-stoke rich-burn engines 2.21 lb/MMBtu was used for EU-EG-09 at 95-105% load capacity. For other RICE category - 4 stroke lean burn as 4.08 lb/MMBtu or 2 stroke lean burn as 3.17 lb/MMBtu with same load capacity. Detailed calculation can be found in the TSD. 


Where, 

NOx emissions from Boilers&HVAC&Heating tons/month= EFB/H lbsMMScfxFNG MMScfx(1 ton/2000)........................................................................(2b)

                                                  
    EFB/H = NOx emission factor of 100 lb/MMscf for uncontrolled Small Boilers (<100 MMBtu/hr).
     FNG  = the total amount of natural gas (MMscf/month) consumed by all NGCU determined by summing the amounts derived from each of the four natural gas flow meters. Refer to TSD for the detailed list of all NGCUs.


Yard Storage Tank - EU-YT-02R Dispensing Gasoline.

Emissions Limitations

The permittee shall comply with all applicable Emission and Operating Limitations in 40 CFR Part 63 Subpart A and Subpart CCCCCC, National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities.

Monitoring, Recordkeeping and Reporting Requirements

The permittee shall comply with all applicable Compliance, Testing, Notifications, Reports, and Records requirements in 40 CFR Part 63 Subpart A and Subpart CCCCCC, National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities.

- FACILITY-WIDE REQUIREMENTS

Facility-wide NOx Emission Limitation, Monitoring and Recordkeeping Requirements.

NOx Emissions Limitation

NOx emissions from all emission units at this facility shall not exceed 95 tons per year as determined on a 12-month rolling sum basis.

NOx Monitoring and Recordkeeping Requirements 

Within fifteen days of the end of each month, the permittee shall calculate and record the facility-wide NOx emissions on a 12-month rolling sum basis, which shall be determined by calculating the emissions (tons) for the month using the following equation and then adding the emissions (tons) calculated for the previous 11 months.

             ENOx-All = NOx Emission from RICE + NOx Emissions (all NGCUs).............(3) 
                   
                   Where:
                   ENOx-All = NOx emissions (tons/month) from all emission units at this facility, i.e., facility wide.
                   NOx Emissions from RICE is calculated from Equation (1) in tons/month 
                  NOx Emissions (all NGCUs) is calculated from Equation (2) in tons/month

Startup, Shutdown, Maintenance and Malfunction.

At all times, including periods of startup, shutdown, maintenance and malfunction, the permittee shall operate each emission unit, including any associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions and considering the manufacturer's recommended operating procedures. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the EPA, which may include, but is not limited to, monitoring results, review of installation, operation and maintenance procedures, and inspection of the source.  Emissions during the processes of startups, shutdowns, maintenance, and malfunctions shall be included in calculating the total tons per year emitted from all emission units listed in SECTION I (B) at this facility.


Records Retention Requirements.

The permittee shall keep all records required by this permit, including the following, on-site for a minimum of five (5) years, and readily available for inspection by the reviewing authority.

All specifications and standard procedures for operation and maintenance developed by the manufacturer, vendor, or permittee for all emission units listed in SECTION I (B) at this facility and associated emission control and monitoring devices.

All information pertaining to any testing, maintenance, repair, rebuild or replacement activities conducted for each emission unit listed in SECTION I (B).

All information pertaining to any testing, maintenance, repair, rebuild or replacement activities conducted for each emissions control and monitoring device associated with each emission unit listed in SECTION I (B).

All information used to calculate the NOx emissions from all RICE(s) for each month.

All information used to calculate the NOx emissions from all RICE(s) on a 12-month rolling sum basis for each month.

All information used to calculate the NOx emissions from all NGCUs for each month.

All information used to calculate the NOx emissions from all NGCUs on a 12-month rolling sum basis for each month.

The permittee shall keep all records legible and maintained in an orderly manner.


Reporting Requirements.

Annual Reports: Once each year no later than April 1[st], the permittee shall submit an annual report to EPA covering the period from January 1 to December 31 of the previous year that includes the following:

An evaluation of the permittee's compliance with each requirement in SECTION II.
                    
The NOx emissions from all RICE(s) for each month.

The 12-month rolling sums of NOx emissions from all RICE(s) for each month.
                     
The NOx emissions from all NGCU for each month.

The 12-month rolling sums of NOx emissions from all NGCU for each month.

The report shall include emissions from startups, shutdowns, and malfunctions.

A brief description of each proposed modification, if any, and the date of permit application or administrative permit revision request if one has been submitted to EPA.

All reports shall be certified to truth and accuracy by the person primarily responsible for Clean Air Act compliance for the permittee.

Deviation Reporting. The permittee shall promptly submit a report to EPA any deviations of permit requirements, including those attributable to upset conditions, the probable cause of such deviation, and any corrective actions or preventative measures taken.

               A "prompt" deviation report is one that is postmarked or submitted to CEDRI as follows:

Within 30 days from the discovery of any deviation of the emission limits or operational limits that are left uncorrected for more than 24 hours after discovering the deviation; and

By April 1st for the discovery of a deviation of recordkeeping or other permit conditions during the preceding calendar year that do not affect the permittee's ability to meet the emission limits.


- GENERAL PERMIT REQUIREMENTS


Definitions

Terms and conditions in this permit have the meaning assigned to them in 40 CFR 49.152 unless other regulations or statutes are referenced or applicable.

Issuance and Effective Date of Permit

EPA is issuing this permit pursuant to the Federal Minor New Source Review Program in Indian Country, 40 CFR 49.151-49.161.

The Effective Date is specified on the first page of this permit.

Construction without a Permit

If the permittee constructs or operates any source or modification not in accordance with the terms of any approval to construct, the permittee shall be subject to appropriate enforcement action.

Construction Approval

Nothing in this permit shall alter the requirement for the permittee to obtain a construction permit prior to beginning construction or modification of an emission unit.

Approval for construction or installation shall not relieve the permittee of the responsibility to comply fully with applicable provisions of any other requirements of federal law or regulation, including Title V of the CAA.

Modifications to Existing Permitted Emissions Units/Limits

For proposed modifications, as defined at 40 CFR 49.152(d), that would increase an emissions unit's allowable emissions of pollutants above its existing permitted annual allowable emissions limit, the permittee shall first obtain a permit modification pursuant to the TMNSR regulations approving the increase. For a proposed modification that is not otherwise subject to review under the PSD or TMNSR regulations, such proposed increase in the annual allowable emissions limit shall be approved through an administrative permit revision as provided at 40 CFR 49.159(f).

Compliance with Permit Requirements

The permittee shall comply with each term and condition in this permit.  Failure to comply with any term or condition of this permit constitutes a violation of the permit, and may constitute a violation of the CAA and serve as grounds for:

An enforcement action under Section 113 of the CAA; or

Termination, revocation and reissuance, or modification of this synthetic minor permit.

This permit currently requires monthly calculations of emissions.  Should EPA determine that calculated emissions are approaching or exceeding an emission limit, or should EPA determine that the permittee is failing to maintain adequate monitoring and recordkeeping requirements, EPA may revise, reopen or modify the permit to require daily calculations of emissions and/or require additional control technologies and emission reduction measures.  A revision that requires more frequent reporting of daily calculations of emissions is an administrative permit revision under the TMNSR program, 40 CFR 149.159(f) (2).

It is not a defense in an enforcement action for violation of this permit that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

Compliance with the terms of this permit does not relieve or exempt the permittee from compliance with other applicable Clean Air Act requirements or other applicable federal requirements, tribal, state or local laws or regulations.

National Ambient Air Quality Standards (NAAQS) / Prevention of Deterioration (PSD) Protection

The permitted source must not cause or contribute to a NAAQS violation or, in an attainment area, must not cause or contribute to a PSD increment violation.

Submittals

In lieu of submitting a hard copy to the address below, the annual and deviation reports required by this permit in (D) that do not contain "Confidential Business Information (CBI)" can be submitted electronically via CEDRI, which is located on EPA's Central Data Exchange repository at  https://cdx.epa.gov/ 

Any test plans, reports, certifications, notifications and other information pertaining to compliance with this permit that is not submitted via CEDRI shall be addressed to:

                  Iowa State Coordinator Air Branch
                  Enforcement & Compliance Assurance Division (ECAD)
                  U.S. Environmental Protection Agency, Region 7
                  11201 Renner Boulevard
                  Lenexa, KS 66219
                  
The permittee shall submit permit applications, applications for permit amendments, and other applicable permit information, which includes but is not limited to applications and information regarding installation of control equipment, replacement of an emissions unit, and requests for changes that contravene current permit terms, to:

                  Tribal Air Permits Coordinator (Rumela Bhadra)
                  Air Permits and Planning Branch (APPB)
                  Air and Radiation Division (ARD)
                  U.S. Environmental Protection Agency, Region 7
                  11201 Renner Boulevard
                  Lenexa, KS 66219
                  Email: bhadra.rumela@epa.gov 
                  Phone: (913) 551-7366
                  
The permittee shall send a copy of the written annual report required under SECTION III (C)(1) to Meskwaki Natural Resources at the following address:

			Environmental Director
			Meskwaki Nation Department of Natural Resources	
			Sac & Fox Tribe of the Mississippi in Iowa
			1826 340[th] Street, Tama, IA 52339
			Office Phone: (641) 484-3511
			
                  
Severability

The terms and conditions in this permit are distinct and severable. Each permit term and condition is independent of the permit as a whole and remains valid regardless of a challenge to any other part of this permit. If any term or condition in this permit is held invalid, such invalidity shall not affect the validity or application of other terms or conditions.

Entry and Inspection

Upon presentation of proper credentials, you, as the permittee, shall allow a representative of the EPA to:

Enter upon your premises where a source is located or emissions-related activity is conducted or where records are required to be kept under the conditions of the permit;

Have access to and copy, at reasonable times, any records that are required to be kept under the conditions of the permit;

Inspect, during normal business hours or while the source is in operation, any facilities, equipment (including monitoring and air pollution control equipment), practices or operations regulated or required under the permit;

Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the permit or other applicable requirements; and

Record any inspection by use of written, electronic, magnetic and photographic media.

Circumvention

The permittee shall not build, erect, install or use any article, machine, equipment or process, the use of which conceals any emission which would otherwise constitute a violation of an applicable standard.

Reservation

The permit does not convey any property rights of any sort or any exclusive privilege.

Permit Revision, Reopening, Revocation and Reissuance, or Termination

EPA may revise, reopen, revoke and reissue, or terminate this permit for cause.  The EPA may reopen this permit for a cause on its own initiative, e.g., if this permit contains a material mistake or the permittee fails to assure compliance with the applicable requirements.

The filing by the permittee of a request for a permit revision, revocation and reissuance, or termination or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

The permittee shall furnish to the reviewing authority, within a reasonable time, any information that the reviewing authority may request in writing to determine whether cause exists for revising, revoking and reissuing or terminating the permit or to determine compliance with the permit. For any such information claimed to be confidential, you must also submit a claim of confidentiality in accordance with 40 CFR Part 2, Public Information, Subpart B -- Confidentiality of Business Information.

