SPECIAL CONDITIONS
Permit Numbers 70492 and PSD-TX-1037

EMISSION STANDARDS, FUEL SPECIFICATIONS, AND OTHER LIMITATIONS

1. This permit covers only those sources of emissions listed in the attached table entitled "Emission Sources - Maximum Allowable Emission Rates," and those sources are limited to the emission limits and other conditions specified in that attached table. Compliance with the annual emission limits shall be based on throughput for a rolling 12-month year rather than thecalendar year.

2. Emission limits are based upon in the permit application representations datedNovember 2003 and subsequent submittals dated; July 2004 (Supplemental to Application), September 2004 (Air Quality Analysis), and October 2004 (Air Quality Analysis Supplement).

FEDERAL APPLICABILITY

3. These facilities shall comply with applicable requirements of the EPA regulations in 40 CFR Part 60 on Standards of Performance for New Stationary Sources promulgated for:
   1. Applicable General Conditions, Subpart A.

   2. The Spruce 2 Utility Boiler is subject to the applicable requirements of Subpart Da, Standards of Performance for Electric Utility Steam Generating Units.

   3. The coal handling facilities shall comply with all applicable requirements of Subpart Y, Standards of Performance for New Stationary Sources promulgated for coal preparation plants.

4. The Spruce 2 Utility Boiler shall comply with applicable requirements of the EPA regulations in 40 CFR Part 63, Subpart UUUUU for Electric Utility Steam Generating Units, as adopted.

   If any condition of this permit is more stringent than the regulations identified above, then for the purposes of complying with this permit, the permit shall govern and be the standard by which compliance shall be demonstrated.

UTILITY BOILER FUEL SPECIFICATIONS, OPERATING LIMITATIONS, PERFORMANCE STANDARDS, AND CONSTRUCTION SPECIFICATIONS

5. Fuel fired in the Spruce 2 Utility Boiler shall be limited to:
   1. Low sulfur subbituminous coal with a sulfur (S) content not to exceed an annual average of 0.625 lb S/MMBtu heat input and with the trace metal concentrations not to exceed the concentration limitation identified in Attachment A.

   2. Sweet natural gas as defined in Title 30 Texas Administrative Code Chapter 101 (30 TAC Chapter 101).

      Use of any other fuel will require prior approval from the permitting authority. Upon request by the Executive Director of the Texas Commission on Environmental Quality (TCEQ) or any air pollution control program having jurisdiction, the holder of this permit shall provide a sample and/or an analysis of the fuel fired in the utility boiler or shall allow air pollution control agency representatives to obtain a sample for analysis.

6. The Spruce 2 Utility Boiler shall be limited to a maximum heat input of 8,000million British thermal units per hour (MMBtu/hr), averaged over a 30 day period, based on the higher heating value (HHV) of thefuel fired.

7. Opacity of emission from the utility boiler must not exceed 10 percent as determined by EPA Reference Method 9 or by COMS as required by Special Condition No. 11 averaged over a six-minute period, except for those periods as described by 30TAC§111.111(a)(1)(e), 30 TAC §§ 101.201 and 101.211, 40 CFR Part 60, § 60.11(c), or as otherwise allowed by law.

8. Emissions from the Spruce 2 Utility Boiler exhausting through EPN U-6 shall not exceed the heat input-based performance standards identified in the table below. The heat input shall be based upon the higher heating value of the fuel. The performance standards of this permit condition shall apply at all times except during periods of start-up, shutdown, maintenance or malfunctions. Initial compliance with the performance standards of this special condition shall be demonstrated in the initial determination of compliance stack sampling utilizing EPA Reference Method testing and shall be determined based upon the average of three stack sampling test runs. Continuous compliance thereafter shall be either via CEMS or COMS for the pollutants monitored by CEMS or COMS or via stack sampling described by Special Condition No. 26. The averaging periods identified in the table shall be the basis for continuous compliance.

Pollutant	Performance Standard	Averaging Period	Compliance Method
Nitrogen Oxides (NOx)	0.069 lb/MMBtu	30-day roll	CEMS1
NOx	0.05 lb/MMBtu	12-month roll	CEMS1
Sulfur Dioxide (SO2)	0.10 lb/MMBtu	30-day roll	CEMS1
SO2	0.06 lb/MMBtu	12-month roll	CEMS1
Carbon Monoxide (CO)	0.15 lb/MMBtu	12-month roll	CEMS1
Opacity	10%	six minutes	COMS2
Ammonia (NH3)	0.0063 lb/MMBtu	hourly	Stack sample3
Particulate Matter, PM10 (Front and Back Half)	0.022 lb/MMBtu	annual	Stack sample3
Lead (Pb)	8.4E-06 lb/MMBtu	annual	Stack sample3
Hydrogen Fluoride (HF)	0.0008 lb/MMBtu	annual	Stack sample3
Sulfuric Acid Mist (H2SO4)	0.0037 lb/MMBtu	annual	Stack sample3
Mercury (Hg)	2E-05 lb/MWh	annual	Stack sample3
Hydrogen Chloride (HCl)	0.0019 lb/MMBtu	annual	Stack sample3
Volatile Organic Compounds (VOC)	0.0025 lb/MMBtu	annual	Stack sample3

Notes:
¹CEMS - Continuous Emission Monitoring System. CEMS are subject to the requirements of Special Condition No. 22.
²COMS - Continuous Opacity Monitoring System. COMS are subject to the requirements of Special Condition No. 23.
³Stack sampling is the average of three stack sampling runs to be conducted as prescribed by Special Conditions No. 21.

9. In the event that the Continuous Emissions Monitoring Systems (CEMS) for NO_x or SO₂ are not operating (except when the CEMS are down for planned QA/QC procedures), the permit holder shall operate at the minimum ammonia feed rate to the selective catalytic reduction system and the minimum sorbent feed rate to the flue gas desulfurization system, or at the pH levels, that were established during a successful initial performance test (adjusted for load) or at the feed rates that were measured prior to the loss of the CEMS, which ever feed rates are higher.

10. The Spruce 2 Utility Boiler Stack, EPN U-6, will be approximately 600 feet tall and 29 feet in diameter. Stack sampling ports and platform(s) shall be constructed on the stack as specified in the attachment entitled "Chapter 2, Stack Sampling Facilities," or an alternate design may be required at a later date if determined necessary by the TCEQ Regional Director or the Manager of the TCEQ AustinEnforcement Division, Compliance Support Team.

11. Emergency Generators, EPN EMGEN-1 and EMGEN-2, shall be limited to a maximum of 60 non-emergency hours per year and these generators shall be limited to firing distillate fuel oil containing no more than 0.1 percent sulfur by weight.

    AMMONIA (NH₃) STORAGE

12. The service of NH₃ storage tanks represented in this permit is limited to the storage of aqueous NH₃ only.

13. Audio, olfactory, and visual checks for NH₃ shall be made once per day within the operating area.
    1. .No later than one hour following detection of a leak, plant personnel shall take the following actions:

       (1) Locate and isolate the leak.

       (2) Use a leak collection/containment system to control the leak until repair or replacement can be made.

    2. Within 24 hours of detection of a leak, plant personnel shall commence repair or replacement of the leaking component as appropriate.

MATERIAL HANDLING OPERATING LIMITATIONS AND STANDARDS

14. Annual throughput of coal received at the Calvaeras Lake site shall not exceed 15 million tons per year. Coal may be delivered at either of the two rotary car dumper buildings which shall be partially enclosed as described in the application.

15. .Fugitive emissions from the transfer points on belt conveyors, any material handling, or the stockpile activities shall not create an off- property nuisance condition. A trained observer with delegation from the Executive Director of the Texas Commission on Environmental Quality (TCEQ) may determine by EPA Reference Method 22 or equivalent compliance with this special condition. Continuous demonstration of compliance with this special condition is not required. If this condition is violated, additional controls or process changes may be required to limit visible PM emissions.

16. As determined by a certified opacity observer with delegation from the Executive Director of the TCEQ and according to EPA Reference Method No. 9 or equivalent, opacity of emissions from any single fabric filter baghouse stack listed in Special Conditions No. 20 shall not exceed 5 percent averaged over a six-minute period. Continuous demonstration of compliance with this special condition is not required.

17. All conveyors shall be covered or enclosed to minimize fugitive particulate matter (PM) emissions except the stacker/reclaim conveyor. If visibility problems occur, additional controls may be required. Covering and enclosures are considered abatement equipment, and should be kept in good repair.

18. A watering truck and/or the coal yard watering system shall be used to minimize dust emissions from the coal storage pile area.

19. The combined active and inactive stockpiles of coal, sludge/ash landfill, and limestone stockpiles shall be limited to 55 acres, 26 acres, and 1 acre, respectively. If spontaneous combustion occurs in the coal stockpile, plant personnel will begin efforts as a soon as possible to extinguish the fires, except when extinguishing stockpile fires may unduly jeopardize the safety of plant personnel and equipment or may cause the fire to spread, in which case these stockpile firesmay be permitted to burn themselves out.

20. Baghouses, properly installed and in good working order, shall control PM emissions from the following emission point numbers (EPNs):

Emission Point No.	Source
FAS3	Fly Ash Silos for Spruce Unit 1
FAS4	Fly Ash Silos for Spruce Unit 2
EAS4	Economizer Ash Silo for Spruce Unit 2
LDC-12	Limestone Receiving Baghouse
LDC-10	Limestone Silos
PX-CO1A/B	Railcar No.1 Unloading and Transfer Baghouse
DC-15	Railcar No.2 Unloading and Transfer Baghouse
DC-1	Transfer Building 1
DC-2	South Reclaim Hopper to Conveyor 4
DC-3	Transfer Building 1a
DC-CCG016	Crusher Building
DC-4A	Silo Group A Headhouse
DC-4B	Silo Group A Unloading
DC-5	Crusher Building 2
DC-6	North Reclaim Hopper to Conveyor 23B
DC-7	Transfer Building 4
DC-9	Transfer Building 6
DC-10	Transfer Building 7
DC-11	Silo Group B Headhouse
DC-12	Silo Group B Loadout
DC-13	Transfer Building 9
DC-14	Transfer Building 1B
DC-101	Unit 1 Transfer Building 5 and Tripper Deck
DC-201	Unit 2 Transfer Building 8 and Tripper Deck

INITIAL DEMONSTRATION OF COMPLIANCE

21. The holder of this permit shall perform stack sampling and other testing as required to establishthe actual quantities of air contaminants being emitted into the atmosphere from the Spruce 2 Utility Boiler stack, EPN U-6. Newly constructed coal handling facilities shall be tested to demonstrate compliance with 40 CFR Part 60, Subpart Y.
    1. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures Manual, EPA Methods in 40 CFR Part 60, Appendix A and 40 CFR Part 51, Appendix M, and American Society for Testing and Materials (ASTM) as follows:

       (1) Methods 201A and 202, or Reference Method 5, modified to include back-half condensibles, for the concentration of particulate matter less than 10microns in diameter PM₁₀;

       (2) Reference Method8 or Reference Methods 6 or 6c for SO₂;

       (3) Reference Method 9 for opacity (consisting of 30six-minute readings as provided in 40 CFR §60.11[b]);

       (4)Reference Method10for the concentration ofCO;

       (5)Reference Method 25A, modified to exclude methane and ethane, for the concentration of volatile organic compounds (VOC) (to measure total carbon as propane);

       (6)Reference Method7E for the concentrations of NO_x and O₂ or equivalent methods;

       (7)Reference Method 8 or a modified Method 8 for H₂SO₄;

       (8)Reference Method 26 or 26A for HCl and HF;

       (9)Reference Method 29 for Total Selected Metals identified in C. of this condition; and

       (10)ASTM D6784-02, Standard Test Method for Elemental, Oxidized, Particle-Bound, and Total Mercury in Flue Gas Generated from Coal-Fired Stationary Sources (also known as the Ontario Hydro Method), or other approved EPA methods.

       Any deviations from those procedures must be approved by the Executive Director of theTCEQ prior to sampling. The TCEQ Executive Director or his designated representative shall be afforded the opportunity to observe all such sampling. The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense.

    2. The TCEQ San Antonio Regional Office shall be contacted as soon as testing is scheduled but not less than 30 days prior to sampling to schedule a pretest meeting. The notice shall include:

       (1)Date for pretest meeting.

       (2)Date sampling will occur.

       (3)Name of firm conducting sampling.

       (4)Type of sampling equipment to be used.

       (5)Method or procedure to be used in sampling.

       (6)Procedure used to determine turbine loads during and after the sampling period.

       The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for submitting the test reports. The permit holder shallpresent at the pretest meeting the manner in which stack sampling will be executed in order to demonstrate compliance with emission standards found in 40 CFR Part 60, Subparts Da, and Y. A written proposed description of any deviation from sampling procedures specified in permit conditions or TCEQ, EPA or ASTM sampling procedures shall be made available to the TCEQ prior to the pretest meeting. The TCEQ Regional Director or the TCEQ Austin Compliance Support Division shall approve or disapprove of any deviation fromspecified sampling procedures. Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Permitting, Remediation, and Registration, Air Permits Division. Test waivers and alternate or equivalent procedure proposals for New Source Performance Standards testingwhich must have the EPA approval shall be submitted to the TCEQ Austin Compliance Support Division.

    3. Air contaminants from the utility boiler stack, EPN U-6, to be sampled and analyzed include: NO_x, SO₂, CO, VOC, H₂SO₄, HCl, HF, PM₁₀, NH₃, Pb, Hg, opacity, total selected metals. Diluents to be measured include oxygen (O₂) or carbon dioxide (CO₂)_. Total selected metals means the combination of the following metallic hazardous air pollutants: arsenic, beryllium, cadmium, chromium, lead, manganese, nickel, and selenium. Newly constructed coal handling facilities subject to 40 CFR Part 60, Subpart Y shall be tested for opacity.

    4. Sampling as required by this condition shall occur within 60 days after achieving the maximum fuel firing rate at which the new Spruce 2 Utility Boiler will be operated but nolater than 180days after initial start-up.

    5. Two copies of the final sampling report shall be forwarded to the TCEQ within 60 days after sampling is completed. Sampling reports shall comply with the attached conditions of Chapter 14 of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows:

       One copy to the TCEQ San Antonio Regional Office.
       One copy to the TCEQ Austin Office of Permitting, Remediation, and Registration, Air Permits Division.

CONTINUOUS DEMONSTRATION OF COMPLIANCE

22. .The holder of this permit shall install, calibrate, maintain, and operate a continuous emission monitoring system (CEMS) to measure and record the concentrations of NO_x, CO, SO₂ from EPN U-6. Diluents to be measured include O₂ or CO_2. The continuous monitoring data shall also be used to determine compliance with the emission limitations in the attached maximum allowable emission rates table.
    1. The CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and the data analysis and reporting requirements specified in the applicable Performance Specification Nos. 1 through 9, 40 CFR Part 60, Appendix B or an acceptable alternative. If there are no applicable performance specifications in 40 CFR Part 60, Appendix B, contact the TCEQ Office ofPermitting, Remediation, and Registration, Air Permits Division in Austin for requirements to be met.

    2. The holder of this permit shall assure that the CEMS meets the applicable quality-assurance requirements specified in 40 CFR Part 60, Appendix F, Procedure 1, or an acceptable alternative. Relative accuracy exceedances, as specified in 40 CFR Part60, Appendix F, § 5.2.3 and any CEMS downtime and all cylinder gas audit exceedances of±15 percent accuracy shall be reported semi-annually to the appropriate TCEQ RegionalDirector, and necessary corrective action shall be taken. Supplemental stack concentration measurements may be required at the discretion of the appropriate TCEQ Regional Director.

    3. The monitoring data shall be reduced to hourly average concentrations at least once everyday, using a minimum of four equally-spaced data points from each one-hour period. The individual average concentrations shall be reduced to units of the permit allowable emission rate in pounds per hour at least once everyday. Pound per hour data shall besummed on a monthly basis to TPY and used to determine compliance with the annualemissions limits of this permit. If the CEMS malfunctions, then the recorded concentrations may be reduced to units of the permit allowable as soon as practicable afterthe CEMS resumes normal operation.

    4. .All required monitoring data and quality-assurance data shall be maintained by the source for a period of five years and shall be made available to the TCEQ Executive Director or his designated representative upon request.

    5. The appropriate TCEQ Regional Office shall be notified at least 30 days prior to any required relative accuracy test audits in order to provide them the opportunity to observe the testing.

    6. If applicable, each CEMS will be required to meet the design and performance specifications, pass the field tests, and meet the installation requirements and data analysisand reporting requirements specified in the applicable performance specificationsin 40CFR Part 75, Appendix A and B, as an acceptable alternative to Special Condition 23A, B, and E.

23. The owner or operator of the facility shall install, calibrate, operate, and maintain a continuousopacity monitoring system (COMS) to measure and record the opacity of emissionsfrom the Spruce 2 Utility Boiler.
    1. .The COMS may be located where no interference with opacity readings will be experienced due to water droplets from the FGD system. The COMS shall satisfy all of the Federal NSPS requirements for COMS as specified in 40 CFR Part 60, Appendix B, Performance Specification 1 (PS-1). In order to demonstrate compliance with PS-1, the COMS shallmeet the manufacturer’s design and performance specifications, and undergo performance evaluation testing as outlined in 40CFR 60, Subpart A, § 60.13. The TCEQRegional Director shall be notified 30days prior to the certification.

    2. The COMS shall be zeroed and spanned daily as specified in 40 CFR Part § 60.13. Corrective action shall be taken when the 24-hour span drift exceeds two times the amounts specified in PS-1, or as specified by the TCEQ if not specified in PS-1.

    3. If the EPA promulgates a quality assurance, quality control standard for the COMS, aQuality Assurance Plan shallbe prepared and maintained in accordance with the EPAstandard for the COMSwithin six months. At the request of the TCEQ Regional Director, the holder of this permit shall submit documentation demonstrating compliance with these standards.

    4. The data shall be reduced to six-minute opacity averages, using a minimum of 36equally-spaced data points from each six-minute period.

    5. Data including all periods of operation, all monitoring data, and quality-assurance data shall be maintained and made available on request to representatives of the TCEQ andany local air pollution program having jurisdiction, and shall be retained for at leasttwoyears following the date that the data is obtained.

    6. If the COMS exceeds greater than 5 percent downtime for the reporting quarter, the owner/operator shall develop and implement a monitor quality improvement plan. Theplan should address the downtime issues to improve availability and reliability. The plan should provide additional assurance of compliance including EPA Reference Method 9 support duringdaytime monitor downtime periods and parametric support for nighttime monitor downtime periods.

    7. For Special Condition No. 23A and B, the COMS shall meet the applicable requirements of 40 CFR Part 60, Appendix B, PS-1 upon certification and/or recertification where compliance is based on the regulation in effect at the time of initial certification of the system.

24. If any emission monitor fails to meet specified performance, it shall be repaired or replaced as soon as reasonably possible.

25. Compliance stack sampling for pollutants that are not monitored with a CEMS or COMS that are identified in Special Condition No. 8 shall occur once annually. If after two years of stack sampling, the average of the two stack sampling results per pollutant is below 70% of the performance standard identified in Special Condition No. 8, then compliance stack sampling for the specific pollutant may be conducted once every three years. Compliance testing required by 40 CFR Part 63, Subpart UUUUU may be used to satisfy the permit testing requirements for mercury.

EMISSION REDUCTION AND NETTING

26. The permit holder will net out of PSD review for NO_x and SO_2. The reduction of emissions relied upon for netting shall occur not later than the commencement of operation of the Spruce Unit 2 Utility Boiler. The permit holder will upgrade the wet limestone scrubbing system serving J.K. Spruce Unit 1 to generate SO₂ reductions. Upon completion of the upgrades to Spruce Unit 1, the combined SO₂ emissions from Spruce Unit 1 and Spruce Unit 2 shall not exceed a total of 4,319 tons per year. The permit holder will over control NO_x emissions from J.T. Deely Units 1 and 2, Spruce Unit 1, and O.W. Sommers Units 1 and 2 to generate NO_x reductions. The permit holder will over control NO_x emissions such that the combined total emissions from J.T. Deely Units 1 and 2, Spruce Unit 1 and 2, and O.W. Sommers Units 1 and 2, shall not exceed 10,454 tons per year of NO_x.

RECORDKEEPING REQUIREMENTS

27. The following records shall be kept at the plant for the life of the permit. All records required in this permit shall be made available at the request of personnel from the TCEQ, the EPA, or any air pollution control agency with jurisdiction.
    1. A copy of this permit.

    2. Permit application dated November 2003 and subsequent representations submitted to the TCEQ.

    3. .A complete copy of the testing reports and records of the initial performance testing completed pursuant to Special Condition No. 13 to demonstrate initial compliance.

    4. Required stack sampling results or other air emissions testing (other than CEMS or COMS data) that may be conducted on units authorized under this permit after the date of issuance of this permit.

28. Records shall be kept for a minimum of five (5) years after collection and shall be made immediately available upon request to representatives of the TCEQ, the EPA, or any local air pollution control program having jurisdiction. The most recent two (2) years shall be maintained on-site and shall be available for inspection. The remaining three (3) years of records may be maintained off site. Records shall be legible and maintained in an orderly manner. The following records shall be maintained:
    1. .Continuous emission monitoring data for opacity, SO₂, NO_x, CO, and diluent gases, O₂ or CO₂, from CEMS or COMS to demonstrate compliance with the emission rates listed in the maximum allowable emission rates table (MAERT) and performance standards listed in Special Condition No. 7 and 8 for pollutants that are monitored by CEMS or COMS. Records should identify the times when emissions data have been excluded from the calculation of average emission rates because of startup, shutdown, maintenance, and malfunction along with the justification for excluding data. Records should also identify factors used in calculations that are used to demonstrate compliance with emissions limits and performance standards.

    2. Raw data files of all continuous emission monitoring including calibration checks andadjustments and maintenance performed on these systems.

    3. Records of coal analysis and analysis provided by natural gas suppliers to show compliance with Special Condition No. 5A and 5B.

    4. Records of the average coal feed rate to the Spruce 2 Utility Boiler in pounds per hour and the corresponding average heat input (HHV) in MMBtu/hr, based upon an average over a 30 day period, to show compliance with Special Condition No.6.

    5. Records of ammonia feed rate, sorbent feed rate, and pH established during the initial determination of compliance stack sampling to fulfill the requirements of Special Condition No. 9.

    6. .Records of the hours of operation of the emergency generators to show compliance with Special Condition No. 11.

    7. Records of the coal received at Calaveras Lake site to show compliance with Special Condition No. 14.

    8. .Records of cleaning and maintenance performed on abatement equipment including records of replacement maintenance performed on baghouses and conveyors.

    9. Records of NO_x and SO₂ emissions from other combustion units identified in Special Condition No. 26 to show compliance with the emissions cap in the MAERT and with the emissions reductions required by Special Condition No. 26.

    10. Records required to show compliance with 40 CFR part 60, Subparts Da and Y, including records of required reporting.

REPORTING

29. .The holder of this permit shall submit to the TCEQ San Antonio Regional Office and the Air Enforcement Branch of EPA in Dallas semi-annual reports as described in 40 CFR § 60.7. Such reports are required for each emission unit which is required to be continuously monitored pursuant to this permit.

OPTIMIZATION STUDIES

30. If the permit holder is unable to demonstrate initial compliance with the Spruce 2 Utility Boiler performance standards for the control of NO_x, Hg, H₂SO₄, and PM₁₀ identified in Special Condition NO. 8 within the time allotted for in this permit, then the permit holder may request additional time for an emissions optimization study to mitigate emissions from the unit. Optimization studies may be requested by the permit holder to evaluate and implement additional efforts to mitigate the emissions of NO_x, Hg, H₂SO₄, and PM₁₀. Exceedances of any emission limit that occur during an approved optimization study is not a violation of the emission limits set forth for NO_x, Hg, H₂SO₄, and PM₁₀ in this permit as long as the owner or operator maintains and operates the equipment and control equipment at all times in a manner consistent with good practice for minimizing emissions. The following conditions shall be met for the studies:

    Prior to the initiation of optimization studies, a protocol shall be developed and approved by the Executive Director of the TCEQ. The protocol shall include at a minimum a proposed duration of the study period and an explanation of control efforts that will be evaluated. Additionally, the protocol will include a description of the specific testing that will be used to evaluate emissions during the optimization study. All stack testing done for this optimization study shall be coordinated with the TCEQ Regional Office.

    A report summarizing the results of the optimization study shall be submitted to the TCEQ within forty-five (45) days after the completion of the individual optimization study. This report shall include a summary of the effort utilized to mitigate emissions and the resulting emission rates measured during the study, as well as a listing of actions that will be undertaken by the permit holder to achieve the emission standard listed in Special Condition No. 8.

    All optimization studies shall be completed within 12 months of the initial demonstration of compliance stack testing.

    Dated________________________

Attachment A Trace Metal Concentrations
Constituent	Maximum Concentrations (ppmw)
Mercury	0.49
Beryllium	6.3
Lead	11.55
Arsenic	9.45
Cadmium	4.52
Vanadium	326
Nickel	47.3
Silver	2.64
Barium	1019
Chromium	77.7
Cobalt	42
Manganese	158
Antimony	5.25
Selenium	5.3
Zinc	231

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