OPERATOR TRAINING

1. OPERATOR TRAINING Calhoun Energy Center Title V Air Permit - 40 CFR 75 April 2014

2. COURSE OUTLINE • Review Air Permit Requirements • Production Execution Requirements • Daily • On-line • Weekly • Quarterly • Maintenance • Documentation • ERTS • Appendix D - Fuel FlowRequirements

3. TITLE V - MAJOR SOURCE OPERATING PERMIT Issuance Date: April 6, 2006 Expiration Date: April 5, 2011

4. TABLE OF CONTENTS • General Provisos • Emissions Summary Page • Provisos for CTs • Acid Rain Permit (attached) • NOx Budget Permit (attached)

5. GENERAL PERMIT PROVISOS • Operational Permit • Not Transferable • Compliance Noncompliance with this permit violates federal and state law and can result in losing the permit or jail time. “Staying within the permit would have required shutdown or reduced load.”; is not a valid excuse. • Submission of Information If ADEM asks for information we must supply it.

6. GENERAL PERMIT PROVISOS • Inspection and Entry If ADEM and/or EPA show the correct credentials, they can come on the site to review and/or copy any records that are required by the permit. They can inspect the CEMS and air pollution control equipment and sample or monitor the stacks. ADEM has its own trailer for stack testing. • Compliance Certification We are required to submit an annual report to ADEM and EPA that identifies each term or condition of this permit and its compliance status. Were we in continuous or intermittent compliance with each proviso in the permit?

7. GENERAL PERMIT PROVISOS • Equipment Maintenance If we plan to run out of NOx control, we are required to notify ADEM at least twenty-four (24) hours prior to the planned shutdown. No notice required if unit is off-line. • Equipment Breakdown ADEM is required to be notified within 24 hours or the next working day if an equipment breakdown causes an exceedence. Notify Production Manager immediately. We will shutdown if the problem can not be corrected in the first hour.

8. GENERAL PERMIT PROVISOS • Operation of Capture and Control Devices When we run on gas, we must run in Mode 6. On oil, the water injection must be operating. Air pollution control devices shall be maintained and operated at all times. • Obnoxious Odors Obnoxious odors arising from the plant must be addressed with countermeasures that are technically and economically feasible .

9. GENERAL PERMIT PROVISOS • Fugitive Dust We need to control the dust on the site - plant roads, grounds, ductwork, etc. We can’t have clouds of dust rolling around the site. • Additions and Revisions Any modifications to this source shall comply with ADEM regulations. Modifications can be software or equipment. Always use Change Management. TOI’s and TMODS should be reviewed for impact to the Air Permit.

10. GENERAL PERMIT PROVISOS • Recordkeeping We are required to keep records of all required monitoring data and support information for least 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records continuous monitoring instrumentation and copies of all reports required by the permit.

11. GENERAL PERMIT PROVISOS • Reporting Requirements Every 6 months we must report all of deviations from the permit. (We will report deviations as part of the quarterly report to ADEM) Deviations reports must be reported within 48 hours or 2 working days. When in doubt, record the event details and call.

12. GENERAL PERMIT PROVISOS • Emission Testing Requirements The Air Division must be notified in writing at least 10 days in advance of all emission tests to be conducted. • Payment of Emissions Fees Annual emissions fees paid. • Other Reporting and Testing Submission of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required. ADEM may require emission testing at any time.

13. GENERAL PERMIT PROVISOS • Title VI Requirements (Refrigerants) You must be certified to work on any equipment (air conditioning) equipment containing Class I or Class II ozone-depleting substances. No person shall knowingly vent or otherwise release any Class I or Class II substance into the environment during the repair, servicing,maintenance. • Display of Permit. This permit shall be kept under file or on display at all times at the site where the facility for which the permit is issued is located and will be made readily available for inspection by any or all persons who may request to see it.

14. GENERAL PERMIT PROVISOS • Visible Emissions At no time shall any source discharge a 6-minute average opacity of particulate emissions greater than 40%. Opacity will be determined by 40 CFR Part 60, Appendix A, Method 9.

15. EMISSIONS SUMMARY * NEW LIMIT

16. EMISSIONS SUMMARY * NEW LIMIT

17. EMISSIONS SUMMARY

18. PROVISOS FOR CTs • Applicability ADEM Admin Code R. 335-3-16, “Major Source Operating Permits” ADEM Admin Code R. 335-3-14, PSD 40 CFR Part 60, Subpart GG 40 CFR Part 60, Subpart GG 40 CFR Part 72, 73, and 75, Acid Rain Rules ADEM Admin Code R. 335-3-8, “NOx Budget Trading”

19. PROVISOS FOR CTs • Emissions Standards - EXEMPTIONS The emission standards apply except during startup, shutdown, load change, and fuel transfer. Startup: The period from when the combustion turbine is started until it reaches 50% load. Shutdown: The period when the combustion turbines are shutting down from 50% load to 0% load. Load Change: A rapid change in the electrical loading of a unit that is readily identifiable on the load chart recording.

20. PROVISOS FOR CTs • Emissions Standards The sulfur content of the distillate fuel oil shall not exceed 0.05% by weight. The turbines shall not be operated at a load less than that designated as 50%, except during SU/SD. 50% load = 50% of 170 MW = 85 MW

21. PROVISOS FOR CTs • Emissions Standards Each CT shall not operate more than 4000 hrs in any consecutive 12 month period. Each CT shall not burn FO more than 1000 hrs in any consecutive 12 month period. Each CT shall not operate in peak mode more than 500 hrs in any consecutive 12 month period.

22. PROVISOS FOR CTs • Emissions Monitoring The CEMS are required to monitor NOx and O2. The CEMS shall be maintained in accordance with 40 CFR Part 75, Appendix B. Daily cals, linearity, and RATA requirements. Oil sampling and analysis shall be performed in accordance with 40 CFR Part 75, App. D.

23. PROVISOS FOR CTs • Recordkeeping and Reporting Requirements An excess emissions report for each turbine stack shall be submitted to the Department within 30 days of the end of each calendar quarter. Records of the following shall be maintained in a file suitable for inspection for a period of at least five years a. The percent by weight of the sulfur in the fuel oil burned in the combustion turbines. b. Monthly and rolling 12-month total operating hours for each turbine.

24. PROVISOS FOR CTs • Recordkeeping and Reporting Requirements c. Monthly and rolling 12-month total operating hours for each turbine while firing distillate oil. d. Monthly and rolling 12-month total operating hours for each turbine during peak mode conditions. e. The loads at which the turbines operated.

25. AIR PERMIT 301-0073-x002 • For the 2.5m gallon F/O storage tank • Non-transferable • Issued for the storage of distillate fuel ONLY • New permit required for new sources, replacements, alterations or design changes that result in a decrease OR increase in emissions • Subject to 40 CFR 60, Subpart Kb

26. AIR PERMIT 301-0073-x002 • In the event of an equipment breakdown that causes increased emissions, ADEM must be notified within 24 hours or next business day. • ADEM may test at any time. • Obnoxious odors arising from the plant must be addressed with countermeasures that are technically and economically feasible

27. PRODUCTION EXECUTION REQUIREMENTS

28. PRODUCTION EXECUTION REQUIREMENTS DAILY/ON-LINE • Calibration Error • review calibration results • OOC - immediate attention - invalid data • OOC period starts at the failure of the calibration error test and ends with next valid calibration error test • plot n’ dot • address trends

29. PRODUCTION EXECUTION REQUIREMENTS DAILY • Calibration Gases • expiration date • pressure - change < 250 psi • perform calibration after • change value in DAHS • record cylinder information in the logbook

30. PRODUCTION EXECUTION REQUIREMENTS DURING OPERATION • Verify on-line calibration occurs • Verify data is being shown as “process on” • Answer episodes and alarms • Verify fuel flow data

31. PRODUCTION EXECUTION REQUIREMENTS WEEKLY • Calibration Error • initiate a weekly off-line cal when not dispatched • review calibration results • OOC - immediate attention - invalid data • plot n’ dot • address trends

32. PRODUCTION EXECUTION REQUIREMENTS QUARTERLY • Linearity Check • required at least once each QA operating quarter or 8 calendar quarters • QA operating quarter >= 168 hours • must be 30 days apart

33. PRODUCTION EXECUTION REQUIREMENTS ANNUAL • RATA • Performed by third party tester • Unit at normal load and fuel • Every 4 QA quarters or 8 calendar quarters

34. PRODUCTION EXECUTION REQUIREMENTS MAINTENANCE • Scheduled • cal before and after • PMs part of QA Manual • Corrective • cal before and after • Record all maintenance activities in log • include details of what was done

35. PRODUCTION EXECUTION REQUIREMENTS DOCUMENTATION • Log book is legal log - date, time, who • Record all maintenance with details • Record reason & corrective actions for all OOC cals • Record all cals not scheduled and why • Record QA activities

36. PRODUCTION EXECUTION REQUIREMENTS DOCUMENTING IN ERTS • All failed cals • All breakdowns and corrective actions • All excess emissions not excused by permit • All trends that require action • All off spec operations

37. APPENDIX D - FUEL FLOW • What is Appendix D? Appendix D is part of 40 CFR 75 that allows sites to use fuel flows to calculate heat input and mass emissions. Appendix D outlines the requirements for fuel flow meter calibrations, oil analysis, and frequences.

38. Portable Air Compressor • Specifies emissions standards to be met • Specified fuel allowed to be used • Requires that we follow the OEM operations and maintenance for the entire life of the engine • Requires a non-resettable hour meter • Requires we keep records of the OEM data indicating compliance with the standards • Limits operating the engine for the purpose of maintenance checks and readiness testing to 100 hrs / year • No time limit for operating in emergency situations • Must record monthly and rolling 12 month total hours of operation

39. APPENDIX D - FUEL FLOW • Calibration Frequency Test the accuracy of each fuel flowmeter at least once every 4 fuel flowmeter QA quarters No more than 20 successive calendar quarters between tests

40. APPENDIX D - FUEL FLOW • Oil Analysis Requirements % Sulfur Density Gross Caloric Value (GCV) Defaults set for natural gas

41. KEY POINTS NOx Limits GAS - 0.033 LB/MMBTU or 9 ppm PEAK - 0.055 LB/MMBTU or 15 ppm OIL - 0.163 LB/MMBTU or 42 ppm

42. KEY POINTS Notify ADEM Within 24 hours or the next working day if an equipment breakdown causes an exceedence. 24 hours prior to planned maintenance that would cause an exceedence. Permit deviations within 48 hours or 2 business days.

43. KEY POINTS Document If you touch it, log it. Open ERTS events for all reportable and off-spec Permit deviations within 48 hours or 2 business days.

44. References Air Permit / CEMS Reference Binder Part 75 Operators Guide CAMD website - www.epa.gov/airmarkets/ ADEM website - www.adem.state.al.us/ .