INFORMATION RELATIVE TO REISSUANCE OF
THE DRAFT TITLE V OPERATING PERMIT
July 2018

FOR:
Cooperative Energy, Moselle Generating Plant
308 Moselle Seminary Road
Moselle, MS 39459    

FACILITY DESCRIPTION
Cooperative Energy’s Moselle Generating Plant is an existing electrical power generating facility located in Moselle, Mississippi (Jones County).  Operations at the facility fall within SIC Code 4911. The facility was issued a Prevention of Significant Deterioration (PSD) Permit to Construct on August 17, 2010, for two combustion turbines, two heat recovery generators with supplemental duct firing, and two natural gas fired heaters.  Part of this project included the conversion of two of the existing boilers (formerly permitted as AA-001 and AA-002) into heat recovery steam generators that would eventually be added to the combustion turbines which would allow them to operate as either simple or combined cycle turbines. Primary emission sources operated at the site include a boiler, four simple cycle combustion turbines (two that can be operated in combined cycle mode) and various other small fuel burning sources (i.e., heaters, generators). A complete list of the permitted emission sources is included in the table below. The purpose of this permitting action is to renew the facility’s Title V Operating Permit and Phase II Acid Rain Permit that were previously issued December 17, 2009.  

Emission Point	Description	
AA-003	868.6 MMBtu/hr Natural Gas/#2 Fuel Oil Fired Boiler (Unit No. 3 Boiler)	
AA-004	1.6 MMBtu/hr (173.5 HP/469.4 kW) Diesel Fired Emergency Fire Pump Engine (CAT C6.6 ACERTTM)	
AA-005	1,547 MMBtu/hr Natural Gas/#2 Fuel Oil Fired Simple Cycle Combustion Turbine (SCCT) equipped with Dry Low NOx Burners and Water-Steam Injection (Unit 4 SCCT)	
AA-006	1,143 MMBtu/hr Natural Gas Fired Simple Cycle Combustion Turbine equipped with Dry Low NOx Burners and inlet combustion air evaporative cooling (Unit 5 SCCT)	
AA-007	3.6 MMBtu/hr Natural Gas Fired Heater	
AA-008	1,260 MMBtu/hr (103 MW) Natural Gas Fired Simple Cycle Combustion Turbine equipped with Dry Low NOx Burners (Unit 6 SCCT)	
AA-009	1,260 MMBtu/hr (103 MW) Natural Gas Fired Simple Cycle Combustion Turbine equipped with Dry Low NOx Burners (Unit 7 SCCT)	
AA-010	Natural Gas Fired Combined Cycle Combustion Turbine (AA-008 Turbine) equipped with a Heat Recovery Steam Generator (HRSG), Dry Low NOx Burners, and Selective Catalytic Reduction (SCR).  The HRSG is equipped with a 267 MMBtu/hr Duct Burner.  Total Heat Input 1,527 MMBtu/hr. (Unit 6 CCCT)	
AA-011	Natural Gas Fired Combined Cycle Combustion Turbine (AA-009 Turbine) equipped with a Heat Recovery Steam Generator (HRSG), Dry Low NOx Burners, and Selective Catalytic Reduction (SCR).  The HRSG is equipped with a 267 MMBtu/hr Duct Burner.  Total Heat Input 1,527 MMBtu/hr. (Unit 7 CCCT)	
AA-012	9.8 MMBtu/hr Natural Gas Fired Pre-heater	
AA-013	9.8 MMBtu/hr Natural Gas Fired Pre-heater	
AA-014	0.88 MMBTU/hr (82kW) Diesel Fired Emergency Generator (Detroit Diesel - Mfr. Date 1969) 	
AA-015	9.45 MMBTU/hr (1,474 HP/1,000 kW) Diesel Fired Emergency Generator (CAT C32)	

PERMIT CHANGES
The proposed permit incorporates the following changes:
•	Requirements established in the August 2010 PSD Permit to Construct;
•	Newly applicable federal requirements for some sources (i.e., engines);
•	The Cross-State Air Pollution Rule (CSAPR) found in 40 CFR Part 97, Subpart BBBBB, NOx Ozone Season Group 1 Trading Program); 
•	Revisions to previous requirements to clarify and streamline the existing standards; and
•	Replacement and/or addition of small emergency engines not previously identified in the permit.  

The PM and PM10 limits established in applicable standards and permits issued prior to January 1, 2011, were reevaluated to determine if they were based upon the filterable portion only or both the filterable and condensable portion. The limits were determined to be based on the filterable portion of the PM because the monitoring previously established did not require a demonstration of compliance using both a filterable and a condensable test method. As allowed under 40 CFR 52.21(b)(50)(vi), limits established prior to January 1, 2011, need not include condensable PM.  
All PM/PM10 limits in the permit now indicate the portion of PM to which the limit applies.

Mississippi’s state standards for PM found in 11 Miss. Admin. Code Pt. 2, Ch.1 were developed based upon filterable PM to ensure ambient air quality met the Total Suspended Particulate (TSP) NAAQS and were also established prior to the regulation of condensable PM.  Therefore, they are considered “filterable only” PM standards and are now indicated as such in the permit.
  
TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential-to-emit exceeds the Title V threshold limits of 100 tons/year (TPY) of each of the following criteria air pollutants: Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Particulate Matter (10 microns or less).  The facility’s potential-to-emit of a single hazardous air pollutant (HAP) is less than 10 TPY and less than 25 TPY for total HAPs; therefore, the facility is considered an area source of HAPs.

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS
The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1. and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6. or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

CAM APPLICABILITY
40 CFR Part 64 contains the requirements for Compliance Assurance Monitoring (CAM).  Per 64.2(b)(i) and (iii), Part 64 does not apply to emission units subject to limits or standards proposed after November 15, 1990, pursuant to Section 111 and 112 of the Clean Air Act (post -1990 NSPS or NESHAP) or units subject to the requirements of the Acid Rain Program.  All potentially affected units are either subject to an NSPS (Subpart GG) or the Acid Rain Program; therefore, the CAM provisions do not apply.

NESHAP APPLICABILITY
•	40 CFR 63, Subpart YYYY, NESHAP for Stationary Combustion Turbines – This subpart only applies to turbines located at major sources of HAP emissions.

•	40 CFR 63, Subpart UUUUU, NESHAP for Coal and Oil-Fired Electric Utility Steam Generating Units – The potentially subject sources at the facility are either stationary combustion turbines located at an area source of HAP or is a unit that is not considered a coal or oil-fired unit as defined by the subpart since they estimate fuel oil will not be burned for more than ten (10) percent of the average annual heat input during the three (3) calendar years after the compliance date or for more than fifteen (15) percent of the annual heat input during any of those calendar years (will meet definition of natural gas-fired EGU).  As such, §63.9983(a) and (b), exempts these sources from being subject to this subpart. 

•	40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines – The facility operates three emergency generators that are subject to this subpart.  Two of the generators are considered new sources under this rule since they were constructed after June 12, 2006, and will comply by meeting the requirements for new compression ignition internal combustion engines under 40 CFR 60, Subpart IIII. The other engine is considered an existing source and must meet the requirements pertaining to emergency engines under this subpart.

NSPS APPLICABILITY
•	40 CFR 60, Subpart GG, Standards of Performance for Stationary Gas Turbines – This subpart is applicable to stationary gas turbines with a heat input at peak load in excess of 10 MMBTU/hr that were constructed after October 3, 1977.  Emission Points AA-005 and AA-006 are subject to the requirements of this subpart since they both have a rated heat input in excess of 10 MMBTU/hr and were constructed after October 3, 1977.

•	40 CFR 60, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines – This subpart applies to stationary combustion turbines with a heat input at peak load in excess of 10 MMBTU/hr and commenced construction after February 18, 2005.  Emission Points AA-008, AA-009, AA-010, and AA-011 are subject to the requirements of this subpart since they have a rated heat input in excess of 10 MMBTU/hr and were constructed after February 18, 2005.

•	40 CFR 60, Subpart IIII, Standards of Performance for Compression Ignition (CI) Internal Combustion Engines – This subpart applies to owners of stationary CI engines that commenced construction after July 11, 2005, and the engine was manufactured after April 1, 2006.  Emission Points AA-004 and AA-015 are new engines subject to the requirements of this subpart.

•	40 CFR 60, Subpart TTTT, Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units – This subpart applies to stationary combustion turbines that are constructed after January 8, 2014.  None of the turbines at the facility are subject to the requirements of this subpart since they were all constructed prior to this date.

ACID RAIN PROGRAM
Emission Points AA-003, AA-005, AA-006, AA-008 (includes AA-010) and AA-009 (includes AA-011) are subject to the requirements of the Acid Rain Program.  The facility’s Acid Rain permit is being reissued concurrently with the Title V Operating Permit and will be incorporated into an appendix of the Title V Operating Permit.

CROSS-STATE AIR POLLUTION RULE
Emission Points AA-003, AA-005, AA-006, AA-008 (includes AA-010) and AA-009 (includes AA-011) are subject to the requirements of the Cross-State Air Pollution Rule NOx Ozone Season Group 1 Trading Program as set forth in 40 CFR 97, Subpart BBBBB, 

SPECIFIC APPLICABLE REQUIREMENTS
Emission Point AA-003 is subject to the state regulations for PM and SO2 and must also meet the fuel sulfur content restriction established in the PSD Construction Permit issued April 9, 1996.  The facility will demonstrate compliance with these requirements by keeping detailed records of the fuels burned in the unit.

Emission Points AA-004, AA-014, and AA-015 are subject to the state regulation for PM and the requirements of 40 CFR 63, Subpart ZZZZ.  Emission Point AA-014 is considered an existing unit and will comply with the applicable requirements of Subpart ZZZZ; however, Emission Points AA-004 and AA-015 are considered new engines under Subpart ZZZZ and will comply with the requirements of Subpart ZZZZ by complying with the applicable requirements of 40 CFR 60, Subpart IIII.  

Emission Point AA-005 is subject to emission and operating limits established in the PSD Construction Permit issued April 9, 1996, and 40 CFR 60, Subpart GG.  The facility will demonstrate compliance with the VOC, PM, and CO limits by stack testing once within the life of this permit and will demonstrate compliance with the NOx limits using a continuous emission monitoring system (CEMS).  The facility will also keep records concerning the hours of operation and fuel fired during operation to demonstrate compliance with the operating limits.

Emission Point AA-006 is subject to emission and operating limits established in the PSD Construction Permit issued December 10, 2004, and modified December 17, 2009, and 40 CFR 60, Subpart GG.  The facility will demonstrate compliance with the emission limits for NOx and CO using a CEMS (NOx) and biennial stack tests and hours of operation (CO).  The facility will keep operational and fuel usage records to demonstrate compliance with the SO2, PM/PM10, and operating limits.  

Emission Point AA-007 is subject to the state regulations for PM and SO2 and must also meet the fuel restriction established in the PSD Construction Permit issued December 10, 2004, and modified December 17, 2009.  The facility will demonstrate compliance with these requirements by keeping records of the fuel burned in the unit.

Emission Points AA-008, AA-009, AA-010, and AA-011 are subject to the emission and operating limits established in the PSD Construction Permit issued August 17, 2010, and 40 CFR 60, Subpart KKKK.  The facility will demonstrate compliance with the emission limits by stack testing (CO – biennially, PM/PM10/PM2.5 – once per permit term) and CEMS (NOx), and will keep records documenting operating scenarios, fuel usage, and fuel analysis (operating limits, SO2).

Emission Points AA-012 and AA-013 are subject to the state regulations for PM and SO2 and must also meet the operating restrictions established in the PSD Construction Permit issued August 17, 2010.  The facility will demonstrate compliance with these requirements by keeping records of the fuels burned in each unit. 

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-003	PM 
(filterable only)	E = 0.8808*(I)-0.1667	Monitor fuels fired in the unit	
	SO2	4.8 lb/MMBtu		
	Fuel Restriction	Sulfur content ≤0.15% by weight		
AA-014 	PM 
(filterable only)	0.6 lb/MMBTU	Monitoring not proposed since diesel fuel is expected to provide a large margin of compliance	
	HAP	Operating and maintenance requirements	Documentation that maintenance activities performed as required	
		General requirements	Documentation of malfunctions and any corrective actions	
		Install hour meters, minimize emissions during startup, maintenance plan	Record operating hours, minimize engine idle time, and keep documents detailing manufacturer’s emission-related instructions or other maintenance plan	
		Operating Restriction	Monitor the purpose for operation of the engine	
AA-004
AA-015	PM 
(filterable only)	0.6 lb/MMBTU	Monitoring not proposed since diesel fuel is expected to provide a large margin of compliance	
	AA-004
NMHC + NOx
CO
PM

AA-015
NMHC + NOx
CO
PM	
< 4.0 g/kW-hr
< 3.5 g/kW-hr
< 0.20 g/kW-hr

< 4.0 g/kW-hr
< 3.5 g/kW-hr
< 0.20 g/kW-hr
	Keep manufacturer’s certification indicating engines meet standards	
	Fuel Restriction	Sulfur content ≤ 15 ppm and either cetane index of 40 or aromatic content of 35 volume percent	No documentation of diesel fuel is required in the subpart since suppliers are required to provide diesel meeting these standards	
	HAP	Operating and maintenance requirements	Documentation of maintenance activities performed as required	
		General requirements	Documentation of malfunctions and any corrective actions	
		Install hour meters, minimize emissions during startup, maintenance plan	Record operating hours, minimize engine idle time, and keep documents detailing manufacturer’s emission-related instructions or other maintenance plan	
		Operating Restriction	Monitor the purpose for operation of the engine	
AA-005
AA-006	NOx	STD = 0.0075(14.4/Y) + F	Continuous emission monitoring system	
	SO2	Fuel sulfur content ≤0.8 percent by weight	Fuel monitoring	
AA-005 (while firing natural gas)	PM 
(filterable only)	8.1 lb/hr not to exceed 16.5 TPY		
	PM10 
(filterable only)	8.1 lb/hr not to exceed 16.5 TPY	Stack testing once per permit term	
	SO2	1.0 ppmdv at 15% O2 at 100 percent load; not to exceed 0.98 TPY	Fuel monitoring	
	NOx	15.0 ppmdv at 15% O2 at 100 percent load; not to exceed 199.5 TPY	Continuous emission monitoring system	
		25.0 ppmdv at 15% O2 during periods of power augmentation		
	CO	25.0 ppmdv at 15% O2 at 100 percent load; not to exceed 1,587.0 TPY	Stack testing once per permit term	
	VOC	4.0 ppmdv at 15% O2 at 100 percent load; not to exceed 12.0 TPY	Stack testing once per permit term	
	Operating restriction	≤ 3,000 hours (rolling 365-day)	Records documenting hours of operation	
	Fuel Restriction	Sulfur content ≤0.15% by weight	Fuel monitoring	
AA-005 (while firing fuel oil)	PM
(filterable only)	195.4 lb/hr at 100 percent load; not to exceed 47.0 TPY	Stack testing once per permit term	
	PM10
(filterable only)	195.4 lb/hr at 100 percent load; not to exceed 47.0 TPY	Stack testing once per permit term	
	SO2	64.0 ppmdv at 15% O2 at 100 percent load; not to exceed 39.8 TPY	Fuel monitoring	
	NOx	42.0 ppmdv at 15% O2 at 100 percent load; not exceed 181.1 TPY	Continuous emission monitoring system	
	CO	90.0 ppmdv at 15% O2 at 100 percent load; not to exceed 365.8 TPY	Stack testing once per permit term	
	VOC	30.0 ppmdv at 15% O2 at 100 percent load; not to exceed 42.3 TPY	Stack testing once per permit term	
	Operating restriction	≤ 450 hours (rolling 365-day)	Records documenting hours of operation	
	Fuel Restriction	Sulfur content ≤0.15% by weight	Fuel monitoring	
AA-006	CO	20 ppmdv at 15% O2; not to exceed 54.0 lb/hr, 3-hour average; not to exceed 148.1 TPY	Biennial stack testing	
	NOx	9 ppmdv at 15% O2; not to exceed 36.0 lb/hr, 3-hour average; not to exceed 99.0 TPY	Continuous emission monitoring system	
	PM/PM10
(filterable only)	10.0 lb/hr, not to exceed 27.5 TPY	No monitoring proposed. Limited to natural gas only which is expected to provide a large margin of compliance	
	Opacity	≤ 10%		
	Startup/ Shutdown	Not to exceed 60 minutes for either	Records documenting details of each startup and shutdown	
	Fuel Restriction	Limited to natural gas only with sulfur content ≤ 2 grains per 100 dry SCF.	Fuel monitoring	
	Operating Restriction	Limited to ≤ 5,500 hours per year (365-day rolling total)	Records documenting hours of operation	
AA-007	Fuel Restriction	Limited to natural gas only	Fuel monitoring	
	SO2	4.8 lb/MMBtu	Monitoring not proposed since natural gas is expected to provide a large margin of compliance	
	PM (filterable only)	0.6 lb/MMBTU		
AA-008 AA-009 AA-010 AA-011	NOx	15 ppmdv at 15% O2	Continuous emission monitoring system	
	SO2	Fuel sulfur emissions ≤ 0.060 lb SO2/MMBtu heat input	Fuel Monitoring	
	Startup/ shutdown	Duration of each	Records detailing time spent in startup and shutdown during each instance and time spent operating controls once conditions allowing such exist	
		Minimize emissions		
AA-008 AA-009 (simple cycle)	PM
PM10
PM2.5
(filterable only)	10 lb/hr (3-hr average); not to exceed 10.9 TPY (12-month rolling total including startup and shutdown)	Stack testing once per permit term	
	NOx	9 ppmdv at 15% O2 at 60 percent and greater load, not to exceed 36.0 lb/hr (1-hour average) and 43 TPY (12-month rolling total including startup and shutdown)	Continuous emission monitoring system	
	CO	20.0 ppmdv at 15% O2 at 80-100 percent load not to exceed 49.0 lb/hr (3-hour average);
85 ppmdv at 15% O2 at 60-79 percent load not to exceed 117.0 lb/hr (3-hour average);
136.5 TPY (12-month rolling total including emissions at all loads and during startup/shutdown)	Biennial stack tests	
	Opacity	≤ 10%	No monitoring proposed. Limited to natural gas only which is expected to provide a large margin of compliance	
	Operating Restriction	Each turbine limited to 2,000 hours of operation per year (12-month rolling total)	Records documenting hours of operation	
	Fuel Restriction	Limited to pipeline natural gas only.	Fuel monitoring	
AA-010 AA-011 (combined cycle)	With Duct Firing - Case 1	
	PM
PM10
PM2.5
(filterable only)	16.8 lb/hr (3-hour average)	Stack testing once per permit term	
	NOx	2 ppmdv at 15% O2 not to exceed 11.4 lb/hr (1-hour average)	Continuous emission monitoring system	
	CO	28.2 ppmdv at 15% O2 not to exceed 67.0 lb/hr (3-hour average)	Biennial stack tests	
	Opacity	≤10%	No monitoring proposed. Limited to natural gas only which is expected to provide a large margin of compliance	
	Operating Restriction	Duct burners shall only be fired during periods of the maximum capable combustion turbine output.	Records documenting hours of operation for the duct burners	
	Operating Restriction	Each turbine/HRSG with duct firing shall be limited to a heat input of 1,538.8 MMBtu/hr (HHV)	Fuel records	
	No Duct Firing - Case 2	
	PM
PM10
PM2.5
(filterable only)	16.8 lb/hr (3-hour average) 	Stack testing once per permit term	
	NOx	2 ppmdv at 15% O2 at 60 percent and greater load not to exceed 11.4 lb/hr (1-hour average)	Continuous emission monitoring system	
	CO	17.5 ppmdv at 15% O2 at 100 percent load not to exceed 48.0 lb/hr (3-hour average);
44 ppmdv at 15% O2 at 80-99 percent load not to exceed 88.0 lb/hr (3-hour average);
106 ppmdv at 15% O2 at 60-79 percent load not to exceed 180.0 lb/hr (3-hour average)	Biennial stack tests	
	Opacity	≤ 10%	No monitoring proposed. Limited to natural gas only which is expected to provide a large margin of compliance	
	Operating Restriction	Each turbine shall be limited to heat input of 1,260.0 MMBtu/hr (HHV)	Records documenting hours of operation for the duct burners	
	Limits Applicable to Both Operating Cases	
	PM
PM10
PM2.5
(filterable only)	74.4 TPY including operation at all loads, while duct firing, and startup and shutdown	Stack testing once per permit term	
	NOx	75.7 TPY including operation at all loads, while duct firing, and startup and shutdown	Continuous emission monitoring system	
	CO	831.5 TPY including operation at all loads, while duct firing, and startup and shutdown	Biennial stack tests	
	Fuel Restriction	Natural gas only	Fuel monitoring	
AA-012 AA-013	Operating/Fuel/ Opacity Restriction	Heat Input limit; low-NOx burners, fuel restriction, and opacity ≤ 10%	Fuel monitoring	
	PM (filterable only)	0.6 lb/MMBTU	No monitoring proposed. Limited to natural gas only which is expected to provide a large margin of compliance	
	SO2	4.8 lb/MMBtu