For Startup ,Shutdown and Malfunction

Date TBD

EMISSION MINIMIZATION PLAN

FOR STARTUP

,SHUTDOWN AND

MALFUNCTION

HILLMAN POWER COMPANY LL.C.

750 PROGRESS STREET

HILLMAN, MICHIGAN I. OPERATING PHILOSOPHY...... 3 2...... REPORTING ...... 3 3. CONTINUOUS EMISSION MONITORING SYSTEM (CEM)...... 4 3.1...... Description ...... 4 3.2...... Operation ...... 4 3.3...... Critical Criteria ...... 5 3.4...... Inspections ...... 7 3.5...... Maintenance ...... 8 3.6...... Spare Pmts ...... 8 3.7. Abnormal conditions or malfunction:...... 8 3.8...... Abatement Measures ...... 9 3.9. Time Frame for Abatement Measures...... 9 4. ELECTROSTATIC PRECIPATOR ...... !0 4.1. Description ...... I 0 4.2. ESP Interior Pmts ...... IO 4.3. ESP External Pmts ...... !! 4.4. Operation ...... II 4.5. Theory ofOperation ...... ll 4.6. ESP Operation ...... l2 4.7. Critical Criteria ...... 12 4.8. Inspection ...... 13 4.9. Maintenance ...... 14 4.10. Spare Parts ...... 14 4.11. Abnormal conditions or malfunctions ...... 14 4.12. Abatement Measures ...... 15 5. SELECTIVE NON-CALAL YTIC REDUCTION SYSTEM (SNCR) ...... 16 5.1. Description ...... 16 5.2. Operation ...... l6 5.3. Critical Criteria ...... 17 5.4. Inspections ...... 18 5.5. Maintenance ...... 19 5.6. Spare Parts...... l9 5.7. Abnormal conditions or malfunctions ...... 19 5.8. Abatement Measures...... 19 5.9. Time Frame for Abatement Measures ...... 20 6. MECHANICAL DUST COLLECTOR ...... 21 6.1. Description ...... 21 6.2. Operation ...... 21 6.3. Critical Criteria ...... 21 6.4. Inspections ...... 22 6.5. Maintenance ...... 22 6.6. Spare parts ...... 22 6.7. Abnormal conditions and malfunctions ...... 22 6.8. Abatement measures ...... 23 6.9. Time Frame for Abatement Measures ...... 23 7. BOILER ...... 24 7.1. Description ...... 24 7.2. Operation...... 25 7.3. Critical Criteria...... 25 7.4. Inspections ...... 26 7.5. Maintenance ...... 27 7.6. Spare Patts...... 27 7.7. Abnormal conditions, malfunctions, and startup and shutdown ...... 27 7.8...... Abate ment measures...... 28 7.9. Time Frame for Abatement Measures ...... 29 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

8. Startup and Shutdown...... 29 8.1. Description ...... 30 8.2. Operation ...... 30 8.3. Critical Criteria ...... 30 8.4. Inspections...... 31 8.5. Maintenance ...... 3 I 8.6. Abatement Measures ...... 3 I Attachments I. Opacity Monitor 2. Nox Analyzer 3. CO Analyzer 4. 0 Analyzer 2 5. CEM system Drift Forms 6. CEM spare patts list 7. Boiler startup and natural gas light off 8. Boiler startup wood light off 9. Nox reduction system startup procedures I 0. Spare patts for Nox system (SNCR) II. Spare parts for Mechanical Dust Collector 12. Proximate and ultimate analysis on fuels burned 13. Operators rounds sheet 14. Spare parts list for boiler and auxiliaries 15. Spare parts list for Electrostatic Precipator system 16. Emergency and Special Instructions 17. Plant Shutdown Procedures 2 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

Hillman Power Company L.L.C. Emission Minimization Plan for Startup, Shutdown, and Malfunction Abatement February 26, 2002

1. OPERATING PHILOSOPHY

The operating philosophy implemented at the Hillman Power Company is to operate the plant within the emission levels required by the Air Use Permit. To achieve these goals, the boiler will be operated in the most efficient manner possible, which in turn, will conserve fuel and provide for complete combustion. Hillman Power Company recognizes that exceedances of limits may occur which are unavoidable under certain malfunction situations, as well as startup and shutdown of the boiler and control equipment. The equipment will be operated and maintained in such a manner to minimize the duration and magnitude of these incidents. The operation of the plant will be performed utilizing properly trained and experienced operators.

In addition to proper operation, it is equally important to establish inspection and maintenance procedures that will allow the plant to continue running in an optimum operating condition. These procedures will include regular scheduled inspections. Properly trained and experienced plant operators and maintenance personnel will perform the inspections. To ensure that maintenance will be performed in a timely manner, it is intended to have an inventory of appropriate spare parts available at the plant for normal scheduled maintenance. The quantity and type of spare parts selected for inventory will be based on plant operating experience.

2. REPORTING

Operating reports consisting of the Hillman Power Company emission levels and plant operating data will be submitted quarterly by written report to the Michigan DEQ-AQD district supervisor within 30 days following the end of the calendar quarter. The quatterly report will include a detailed analysis of all recording, reporting, and record keeping requirements in compliance with 40 CFR, part 60 and the current Air Use Permit. The quarterly repmts will be in a format exceptible to the depmtment and contain the required information.

In addition to the qumterly repmts, notifications will be provided to the DEQ-AQD district supervisor of any abnormal conditions or malfunctions of process or control equipment that results in emissions in violation of the Air Use Permit or Rule 912. This notice will be provided not later than two business days after the startup, shutdown, or discovery of the abnormal condition or malfunction. Also, within I 0 days, a written detailed report including probable causes, duration of violation, remedial action taken, and the steps which are being taken to prevent a reoccurrence will be submitted to the DEQ-AQD district supervisor.

All monitoring data for the Hillman Power Company will be kept on file at the plant for a period of fire years and made available to the DEQ-AQD district supervisor upon request.

3 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

3. CONTINUOUS EMISSION MONITORING SYSTEM (CEM)

3.1. Description

A continuous emissions monitoring (CEM) system is used to monitor and record the emissions from Hillman Power Company as required by the current Air Use Permit. The system is a complete emissions monitoring and data gathering system used to demonstrate compliance with state and federal air emissions regulations.

Gas emissions and opacity monitoring systems including monitoring, data collection, data storage and rep01ting are in accordance with the requirements of the Environmental Protection Agency (EPA) as stated in 40 CFR Part 60, "Standards of Performance for New Stationary Sources".

The CEM System monitors opacity, 0 , CO, and NO, in the stack at an approved location. 2 Provisions are made to accept inputs for steam flow and fuel feed rates into the data collection system.

The monitoring equipment provided comprises a complete system designed to function as a unit. The CEM system is a direct extractive monitoring system and includes the following items: a. Probes, transducers, and duct mounted instruments b. Sample conditioning and extraction equipment c. Analyzers and monitors d. Sample tubing and special cable e. Signal conversion equipment f. Calibration gases and interconnecting equipment g. Data collection and storage software

3.2. Operation

The CEM System is operated at all times when the boiler is firing on wood, tire derived fuel (TDF), other alternative fuels, and natural gas by properly trained experienced operators. The equipment is operated in accordance with the manufacturer's recommendations and plant operating procedures. Monitoring of the CEM system is through the main plant computer (DCS) Data Control System located in the plants control room. The DCS system is provided with software to receive and process signals from the analyzers, signal conversions, calculate variables from the database, signal alarms, and store and retrieve data. The DCS system provides fault monitoring to detect equipment malfunction. Outputs are provided to alarm system malfunctions as sensed by the fault monitors supplied as patt of the analyzers and the DCS system. The DCS system alarms and logs the following:

• CO emissions high and low • Opacity emissions high and low 4 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

• 0 concentration high and low 2 • NOx emissions high and low • so2 emissions high and low

The DCS system is a redundant system, failure of one component will not result in the loss of any previously stored data within 24 hours. The DCS system is designed to sustain memory in the event of a power supply failure and is supplied with an internal clock to maintain correct time and date during power failure.

Hourly and daily reports can be generated at the operator's request. The dates and times are included in the reports when the repmt is requested. The repmt uses the most up-to-date information from the data base of emissions data stored in the computer.

Reports display hourly emissions averages, rolling averages, daily averages, status logs, steam flow, fuel feed rate, 6 minute averages for opacity, and values of emission products as ppmd, #/lu, and other data as required by the specified regulatory agencies.

Operator generated logs compiled from DCS trend logs are also kept on file. These logs demonstrated compliance or noncompliance, give reason codes for noncompliance, and contain a comment section for operation action taken.

3.3. Critical Criteria

The CEM System is operated in a manner that will provide accurate monitoring, recording, and reporting of Hillman Power Company's emissions limitation as specified in the plants current Air Usc Permit. The CEM System is operated to monitor the following critical criteria:

Opacity a. The Opacity monitor is designed to accurately monitor and record the flue gas opacity. Visible emissions fi·om the boiler are not to exceed the specified limits set in the air use permit. b. The opacity monitor optical head and retro reflector alignment will be properly aligned when the angle of projection from the optical head is within two degrees and the angle of view fi·om the retro reflector is within two degrees. Completed as needed. c. The allowable angle of alignment drift will be within ± 0.5 degrees. d. The optical head light source is a super wide band diode. e. A blower is provided for the optical head and retro reflector tor gas purging of the assemblies. The blowers are designed to provide 60 inches water column of static pressure and are fitted with an inlet filter and pmticulate bowl. f. A copy of the calibration procedures are add as attachment# I. g. A calibration check instrument is at the facility and is used whenever necessary to verify accuracy, and calibrate the instrument. The calibration check instrument is also

used for the Relative Accuracy Test Audit by the vendor contracted to perform the testing. h. The opacity monitor is automatically calibrated daily and a RATA is performed annually.

a. The NOx analyzer is designed to accurately monitor and record the NOx emission levels from the boiler. The NOx emission rate from the boiler will not exceed the limits of the current air use permit. b. The NOx calibration gas cylinder will contain gas of at least 80% to I 00 % of the instrument range. c. The NOx analyzer sensitivity will be a 0.5-ppb. d. The NOx analyzer range will be 0 - 500 ppm. e. The NOx analyzer accuracy will be ± 2% of full scale. f. The NOx analyzer calibration drift will be± I% in 24 hours. g. The purge air supply for the NOx sample will be at 120 psi and at a flow rate of 6 liters per minute. h. The calibration gas supply for the NOx sample will be at a flow rate of 8 liters per minute. 1. A copy of the calibration procedures is supplied as attachment #2. J. The NOx analyzer is run through, a daily calibration of the zero and span, a quarterly Cylinder Gas Audit, and an annual RATA test.

a. The S02 analyzer is designed to accurately monitor and record the S02 emission levels from the boiler. The S02 emission rate from the boiler will not exceed the limits of the current air use permit. b. The S02 calibration gas cylinder will contain gas of at least 80% to I 00 % of the instrument range. c. The So2 analyzer sensitivity will be a 0.5-ppb. d. The S02 analyzer range wi II be 0 - 500 ppm. e. The S02 analyzer accuracy will be ± 2% of full scale. f. The S02 analyzer calibration drift will be± I% in 24 hours. g. The purge air supply for the S02 sample will be at 120 psi and at a flow rate of6 liters per minute. h. The calibration gas supply for the S02 sample will be at a flow rate of 8 liters per minute. i. A copy of the calibration procedures is supplied as attachment #2. j. The S02 analyzer is run through, a daily calibration of the zero and span, a quarterly Cylinder Gas Audit, and an annual RATA test.

6 Emission Minimization Plan for Startup, Shutdown, and rvtalfunction Hillman Power Company

Carbon Monoxide

a. The CO analyzer is designed to accurately monitor and record the CO emission levels from the boiler. The CO emission rate from the boiler is not to exceed the plants current air use permit based on a 24-hour daily average. b. The calibration gas cylinder will contain CO gas at 80% to 100% of instrument range. c. The CO analyzer sensitivity is 0.1 ppm. d. The CO analyzer range is 0 to 1000 ppm. e. The CO accuracy will be± 2 % offull scale. f. The CO analyzer calibration drift will be ± 3% in 24 hours. g. The purge air supply for the CO sample will be 120 psi at 8 liters per minute. h. The CO calibration gas supply for the CO sample will be at a flow rate of3.5 liters per minute. 1. A copy of the calibration procedures is added as attachment #3. J. The CO analyzer is run through a daily calibration of the zero and span, a quarterly Cylinder Gas Audit, and an annual RATA test.

The 0 analyzer is designed to accurately monitor and record the levels of 0 at a. 2 2 the stack gas sample point. The predicted levels of 0 are in the range of 5% to 6%. 2 The 0 calibration gas cylinders will contain 0 gas at 2% and 18% by volume. b. 2 2 c. The 0 analyzer sensitivity will be 0.1%. 2 d. The 0 analyzer range will be 0 - 25 %. 2 e. The 0 analyzer accuracy will be± 0.1% of full scale. 2 The 0 analyzer calibration drift will be± 2.5% in 24 hour. f. 2 The reference air supply for the 0 sample is 2 SCFH. g. 2 The 0 analyzer calibration gas supply for the 0 sample is at a flow rate of l0 liters h. 2 2 per minute. 1. A copy of the calibration procedure is added as attachment #4.

3.4. Inspections

a. Daily inspections are performed on the CEM equipment to ensure that the equipment is operating properly. Inspection form # 1 is used see attachment# 5 b. Quarterly cleaning is done on the equipment ifthere is enough monitor equipment down time left for the quatter. Work orders (log# 5) are used for the cleaning and inspection forms see attachment #5

c. Annual cleaning and inspection is done on our annual outage for maintenance and 7 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

repair. Work orders (log# 5) are used for the cleaning and inspection forms see attachment # 5

Daily, quarterly, and annual inspections are performed on the CEM equipment to ensure that the equipment is operating properly and to observe various changes that may indicate a potential malfunction. If the CEM system fails to pass any inspection immediate action is taken to correct the malfunction or abnormal condition. Copies of the inspection forms are added as attachment #5

3.5. Maintenance

Maintenance on the CEM equipment is performed in accordance with the manufacturer's recommendations. Normal maintenance is performed during the daily and quarterly inspections with the replacement of worn patts that do not meet the manufacturer's specification tolerances. Other maintenance is performed to either replace or rebuild various pieces of equipment when a malfunction occurs.

3.6. Spare Parts

Spare pmts are purchased and stored in inventory based on plant operating experience. A copy of the spare parts inventory is included as attachment #6.

3.7. Abnormal conditions or malfunction:

Abnormal conditions or malfunctions of the equipment include, but are not limited to, the following equipment status which result in emissions or operations outside the permit requirements:

a. CO analyzer failure b. NOx analyzer failure c. Opacity analyzer failure d. 0 analyzer failure 2 e. Failure of extractive system f. failure of cabinet heater or air conditioner g. Failure of electronic transmission system between analyzer's and DCS system h. Failure of DCS printer 1. Failure of purge air system

8 Emission Minimization Plan for Startup, Shutdown, and ivfalfunction Hillman Power Company

3.8. Abatement Measures

In the event that a malfunction should occur to the CEM equipment that affects monitoring, recording, or repmting of the plant emissions, specific action will be taken to correct the equipment malfunction. Whenever needed the use of overtime, off-shift labor, outside consultants or contractors, where reasonable to minimize the duration of the malfunction or excess emissions will be used. This action in cooperation with the DEQ-AQD district supervisor will be taken and one or more of the following steps:

a. Based on stable operation of the boiler and being in compliance with the required emission levels at the time of the malfunction, continue to run the boiler at a stable rate of operation and repair the CEM equipment as soon as possible. b. Should it be determined that equipment replacement is required in lieu of repairs, continue to nm the boiler at a stable rate of operation and replace the equipment as soon as possible. c. Should it be determined that replacement of equipment is going to take an excessive length of time, continue to run the boiler at a stable rate of operation and arrange for rental of CEM equipment in the interim period. d. Should it be determined that rental of CEM equipment is not possible, continue to run the boiler in a manner where extensive operating experience has demonstrated that the plant always complied with the permit emission levels. e. Plant shutdown.

3.9. Time Frame for Abatement Measures

The time frame for repair of each of the malfunctions listed in the table below are estimates tl·om prior plant experience. All components of the plant systems are not identical and time frames for repair will vary somewhat due to location in the plant, accessibility for repairs, and time when malfunction occurs. Each time frame should be completed from time of initial malfunction or abnormal condition.

3.8 Abatement measures times in hours 3.7 Abnormal conditions or maltlmctions

a. b. c. d. e. 240 720 I. CO analyzer failure 48 72 96 2. NOx analyzer failure 48 72 96 240 720 3. Opacity analyzer failure 48 72 96 240 720 4. 0 analyzer failure 2 48 72 96 240 720 5. Failure of dilution extractive system 48 72 96 240 720 6. Failure of cabinet heater or air conditioner 48 72 96 240 720 7. Failure of electronic transmission system 9 Emission Minimization Plan for Startup, Shutdown, and rvtalfunction Hillman Power Company

between analyzer's and DCS system 48 72 96 240 720 8. Fmlure of DCS pnnter 48 72 96 240 720 9. Failure of purge air system 24 72 96 240 720

4. ELECTROSTATIC PRECIPITATOR

4.1. Description

The flue gas environmental control system is a Environmental Elements Corporation multi-field electrostatic precipitator (ESP) designed to remove patticulate from the flue gas flow and maintain an emission rate as specified in the current Air Use Permit. The ESP is located down stream from the induced draft fan to prevent air in leakage and possibility of fires. The ESP is enclosed and insulated around the bottom for equipment protection from the weather and to improve the ability of maintaining the equipment.

The main controls for the ESP are located in the equipment room adjacent to the main plant control room for ease in stattup and monitoring of performance.

The precipitator is comprised of one (I) chamber of three (3) mechanical I electrical fields, and consists of a 3/16 mild steel casing containing the collecting panels and the high voltage discharge electrodes, and associated suspension and alignment hardware.

The precipitator has one longitudinal trough hopper, which collects the ash from the collecting plates and the high voltage electrodes, dislodged when the electromagnetic rappers are activated. The rapping equipment is located at the roof level and the rapper control panel is located in the boiler building.

The precipitator is equipped with inlet nozzles containing gas distribution plates and an outlet nozzle. The roof of the precipitator has a complete checkerplate-walking surface for ease of maintenance. Access is provided to the roof of the precipitator by a stairtower.

4.2. ESP Interior Parts

The interior patts of the ESP field consist of a system of grounded collecting surfaces and independently hung high voltage elements.

Collecting surfaces are assemblies of panels, each panel being fabricated of light gauge steel plate, stiffened by rolled edges and align bars. Collecting surfaces are held in vertical alignment and parallel to one another to allow for uniform gas flow.

High voltage discharge electrodes are a rigid mast type of rolled construction, hung from a framework of channels and angles braced and tied to prevent horizontal movement. Each mast is bolted in place at the upper end and lower end.

The masts are shrouded at the top and lower end to prevent electrical sparking. An alignment frame at the lower end of the elements is designed to maintain the elements in proper vertical and horizontal alignment.

The spaces between parallel collecting surfaces are called gas passages, and the high voltage discharge electrodes are positioned in these spaces symmetrical with collecting surfaces.

The high voltage frame in each field is supported at four (4) points by insulators mounted on the precipitator casing cover and housed in steel compartments. These suppott insulators provide electrical insulation between the high voltage frame and the grounded structure.

4.3. ESP External Parts

The high voltage for the discharge systems is supplied by transformer-rectifier sets located on the ESP roof. These units are connected to the high voltage elements through high voltage lines. The high voltage lines and high voltage support insulators are enclosed in bus ducts above the ESP roof level. Extremely accurate power regulation to each high voltage system is provided by automatic control. All ESP operating control and indicator panels, power distribution and automatic voltage control units are located in the equipment room adjacent to the plants main control room.

The ESP also has a series of ash augers, rotary valve, and mixer system to handle the ash to the ash bay for storage until it is removed from the site.

The ESP ash system is equipped with motion detection devices that will alarm the Operator Tech in the plants main control room of any interruption in the system. The mixer system also uses water for temperature and dust control.

4.4. Operation

Properly trained opet·ators who operate the equipment in accordance with the manufacturer's recommendations and plant operating procedures operate the ESP.

4.5. Theory of Operation

Operation of the ESP depends upon creation of an electrostatic field to electrically charge dust patticles in the gas stream as it passes through the ESP.

II Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

The electrostatic field is established by stepping up low voltage alternating current with a transformer, and changing the resulting high voltage alternating current with a rectifier to high voltage direct current. The rectified current is then delivered to a system of mast electrodes uniformly spaced between collecting surfaces. The mast electrodes create the electrostatic field within spaces between the collecting surfaces.

The dust patticles in the gas stream are charged as they pass through the electrostatic field. Most particles are charged negatively, or opposite in polarity to that of the collecting surfaces, and therefore are attracted to these surfaces and adhere to them until removed. The remaining patticles are attracted to the mast electrodes. This collected material is periodically removed by a system of rappers which strike the surfaces a sharp blow, breaking loose the collected material, which then falls by gravity into the precipitator hoppers.

The polarity of the transformer-rectifier high voltage output is always negative at the voltage necessary for highest ESP operating efficiency.

The precipitator may be operated either on automatic or manual voltage control. On automatic control, the controller varies the voltage to the ESP as required to maintain optimum removal efficiency under varying inlet gas and dust conditions. On manual control, proper ESP operating voltage is obtained by adjusting voltage until only occasional sparking or shmting between high tension electrodes and the collecting surfaces is reflected by the spark-rate meter.

4.6. ESP Operation

The main controls for the ESP are located in the plant equipment room and control room, they will perform the following specific functions:

a. Automatic voltage regulation to each of the transformer/rectifiers associated with the three (3) fields. b. Control the operation of the Insulator Compmtment Pressurization System, which provides a positive pressure to prevent dust from entering the compartment. c. Control the operation of the rappers system on the collecting surfaces, discharge electrodes, and the ESP inlet distribution plates. d. Monitor high ash level in the ESP ash hoppers. e. Control power supply to the ESP through the key interlock system on the ESP access doors. f. Control ESP ash auger and mixing system. g. Ash auger motion detection system. h. Monitor the ESP ash hopper electric heating system.

The operational parameters for the critical criteria are not requirements of the air use permit but are requirements for safe operating conditions. The operation of the ESP controls the final 12 Emission Minimization Plan for Startup, Shutdown, and rv1alfunction Hillman Power Company

particulate emissions from the plant. The ESP operates in a manner to satisfy the following critical criteria:

Patticulate a. Inlet dust loading to the ESP not to exceed 1.7 gr./DSCF. As design specifications. b. Flue gas temperature entering the ESP not to exceed 360 degrees F. As design specifications. c. Flue gas moisture content entering the ESP not to be greater than 29%. As design specifications. d. Particulate emissions from the ESP outlet shall not exceed the Air Use Permit limits. Monitored and recorded by the CEM e. Visible emissions from the ESP not to exceed the limitations of the Air Use Permit. Monitored and recorded by the CEM

A copy of the plant startup procedures is added as attachment #8 which includes the startup procedures for the ESP.

4.8. Inspection

Daily inspections are performed on the ESP in accordance with the manufacturer's recommendations and plant operating experience to ensure that the equipment is operating properly and to observe various changes that may indicate potential malfunction. The inspections performed each day are as follows: See attached plant log sheets section 13

a. Spark rate on each of the three fields average from 0 to 240 sparks per min. Log# 2 b. Voltage on each of the three fields maximum is 55 KV Log# 2 c. Amperage on each of the three fields. Log# 2 d. Transformer oil temperature on each field maximum is 55° C. Log# 3 e. Transformer oil Pressure on each field. Log# 3 f. Rappers operating properly. Monitored by the DCS and operators g. Ash removal system operating properly. Log# 4

Weekly inspection items:

a. Remove dust and foreign matter from electrical equipment. Log #7 b. Check signal lights for proper operation. Log #7 c. Check rapper alignment. Log #7 d. Check rapper boots for cracks and wear. Log #7 e. Check tightness of belts on penthouse fan. Log #7 f. Grease penthouse blower fan and motor. Log #7 g. Check precipator rotary valve and lubricate. Log #7 h. Inspect and lubricate precipitator ash system bearings. Log #7 i. Check precipator auger gear boxes for unusual sounds, vibrations, and grease. Log #7

Annual inspections items:

a. Clean insulators in the high voltage insulator compmtment, as well as all other insulators. b. Thoroughly inspect the interior of the ESP and make necessary adjustments or repairs. Give particular attention to the high voltage electrodes, each of which should be centered between the collecting surfaces. Misalignment of even a single unit reduces the electrical clearances between high voltage electrodes and collecting surfaces, resulting in a marked reduction of collecting efficiency. Misaligned electrodes should be removed or replaced as required. c. Disassemble electric rappers and inspect the high voltage system rapper shaft ceramic material for deterioration or cracking. d. Test the insulating fluid in each transformer for dielectric strength according to the appropriate American Society of Testing Materials Code. See plant work orders Log #5 section 13.

See plant work orders.

4.9. Maintenance

Maintenance on the ESP is performed in accordance with the manufacturer's recommendations and previous plant experience. Normal maintenance is performed during the annual inspection with the replacement of worn pmts that do not meet the manufacturer's specification tolerances. Other maintenance is performed to either replace of rebuild various pieces of equipment should a malfunction occur or force the shut down of the boiler.

4.10. Spare Parts

Spare pmts will be purchased and stored in inventory based on the manufacturer's recommendations and plant operating experience. The expected spare parts list for the ESP is added as attachment 15#.

4.11. Abnormal conditions or malfunctions

a. ESP ash and mixer system b. Penthouse pressurization system c. Transformers/rectifier system 14 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

d. ESP high voltage insulators e. ESP rapper system f. Startup and shutdown of plant g. Rigitrode/plate collection system

In the event that a malfunction should occur to the ESP equipment that affects or controls the plant emissions and causes the plant to exceed the permitted levels, specific action will be taken to bring the plant back into compliance. Whenever needed the use of overtime, off-shift labor, outside consultants or contractors, where reasonable to minimize the duration of the malfunction or excess emissions will be used. This action, in cooperation with the DEQ-AQD district supervisor will be taken and either one or more of the following steps:

a. Continue to run the malfunctioned ESP equipment at lower loads or fewer electrical fields as long as the plant emissions are in compliance. This may or may not require the boiler to run at reduced loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. It may be possible to run the ESP and boiler at reduced loads and be in compliance with emissions when the malfunctioned equipment is out of service for repairs.

c. Continue to nm the boiler and repair the equipment, if the estimated repair would create less total emission than a normal shutdown and startup. Emissions may exceed the permit limits for certain periods of time during boiler startup and shutdown. This situation may be unavoidable and is addressed in the emission minimization plan during statiup and shutdown (see Section 7).

d. Correct the malfunctioned equipment by shutting down the ESP and repair the equipment. Shutting down the ESP will also require shutting down the boiler, which in turn will cease all plant emissions.

Time Frame for Abatement Measures

The time frame for repair of each of the malfunctions listed in the table below are estimates from prior plant experience. All components of the plant systems are not identical and time frames for repair will vary somewhat due to location in the plant, accessibility for repairs, and time when malfunction occurs. Each time frame should be completed from time of initial malfunction or abnormal condition.

4.11Abnormal conditions or malfunctions 4.12 Abatement measures times in hours

a b c d.

I.ESP ash and mixer system - - - 24 2. Penthouse pressurization system - - - 24 3. Transformers/rectifier system - - - 12 4. ESP !ugh voltage msulators 24 - - 720 5. ESP rapper system - - - 24 6. Startup or shutdown of plant - - 48- 7.Rtgttrode/plate collection system I. - - - 720

5. SELECTIVE NON-CALAL YTIC REDUCTION SYSTEM (SNCR)

5.1. Description

A selective non-catalytic reduction (SNCR) urea based system is provided to control the NO, emissions as required by the current Air Use Permit. This system includes a recirculating and heater skid, a metering I mixing skid, and associated valves, fittings, and injectors. The urea control fluid is mixed with water and it jected into the boiler through water wall injectors. Compressed air is utilized for atomization and proper distribution into the boiler's flue gas path. NALCO Fueltech furnishes the SNCR system.

5.2. Operation

The SNCR system is operated at all times when the boiler is firing on wood fuel, or a combination of wood fuel and tire derived fuel by properly trained operators. The equipment is operated in accordance with the manufacturer's recommendations and plant operating procedures. A copy of the plant operating and startup procedures for the SNCR system are attachment #9. Control of the SNCR System is directed by a single loop controller. The alarm system is directed by the main DCS system. The Operator Tech on shift monitors all plant systems and makes all necessary adjustments to maintain a safe operation, and be in compliance with state and federal regulations. Specific functions of the SNCR controls are as follows:

a. Control urea chemical temperature in the chemical storage tank. The tank is supplied with insulation to minimize heat loss. The method for heating the urea is by a heating element and a recirculating pump. The recirculation skid serves the SNCR Process in a dual role. It has one purpose of keeping the urea reagent at a temperature above 85 degrees F. and its second purpose is to supply the urea to the Metering/Mixing Skid.

The skid consists of dual redundant centrifugal pumps, one electric in-line heater, one self-contained control panel, and all associated stainless steel piping and valving.

b. The metering mixing skid is used to supply urea to the (3) injector wands mounted on the upper boiler walls. The unit includes two sets of full flow duplex metering pumps and gear pumps for water/chemical mixing and pressure boost, respectively. The skid contains a pressure control loop consisting of a pneumatic valve and a pressure transmitter system wired into the single loop controller for discharge pressure control. In addition the module contains all necessary motor operated ball valves, manual ball valves, check valves, pressure switches, flow switches, and stainless steel piping to make it a self-contained pumping system.

c. The SNCR also contains an air pressure regulator system which is used to control the atomizing air pressure at the il ectors.

d. The injectors consist of an atomizing chamber in which the air and urea first meet. Air is required for atomizing the urea and cooling when the il*ctors are off-line and not retracted from the boiler.

The SNCR System is operated in a manner that will control the plant's NO, emissions in compliance with the current Air Use Permit. The SNCR System is operated to maintain the following critical criteria

a. The SNCR System provides the proper urea and water mixture to the injectors to maintain plant NOx emissions at the current air use permit limits. This level of NO, emissions represents a reduction of approximately 20 percent of the NO, level received from the boiler.

b. In order to achieve the above reduction in NO, emissions the urea is ii*cted and atomized through injectors installed in the boiler walls in a location where the furnace temperature averages 1800 degrees F.

c. Proper flow and mixing of the urea chemical is best controlied when the chemical temperature is maintained at greater than 70 degrees F. log #4 section 13

d. Compressed air at a pressure of 80 psig is provided for atomization of the urea chemical into the boiler. Log #3 section 13

e. Service water for urea dilution is provided at a pressure of 60 psig to the metering mixing skid. Log #3 section 13

f. The NO, emissions are monitored by the CEM equipment and recorded by the plants DCS system as required by the current Air Use Permit. co

a. The SNCR System by injecting urea chemical for NO, reduction will contribute to the level of CO emissions. However the SNCR System is designed to be in compliance with the Air Use Permit.

5.4. Inspections

Inspections are performed on the SNCR system every four hours to insure that the equipment is operating properly and to observe any changes that may indicate potential malfunction of the equipment. The inspections performed are as follows: see log sheets section 13

a. Observe the level in the urea-mixing tank, operating range is from 200 to 750 gallons. Log#3 b. Observe the recirculation skid, heater, pump, and discharge pressure. The discharge pressure during normal operation averages 20 psi g. Log #4

c. Observe the metering/mixing skid, pumps, and pressure control system. Log #3

d. Observe the air pressure to the injectors for proper atomization and cooling. Atomization air pressure during normal operations averages 35 psig. Log #3

e. Observe the service water supply to the metering/mixing skid for proper water pressure. City water pressure averages 60 psig. Log #3

Through the process of normal operation other operating parameters arc continuously observed in the control room including NO, emission levels. Maintaining the plant emissions at proper levels provides an additional means of inspection that assures the plant operators that the SNCR system is operating properly.

Annual inspections are performed on the SNCR equipment to ensure that the equipment is in proper operating condition. This inspection includes the shutting down of the equipment during a scheduled plant shutdown and removal of various parts for close inspections. Annual inspections and tear down may include the following equipment: See plant work orders Log #5 section 13.

a. Piping Injectors b. Pumps

c. Heater system d. Check valves

5.5. Maintenance

Maintenance on the SNCR System is performed in accordance with the manufacturer's recommendations and previous plant experience. Normal maintenance is performed during the annual inspection with the replacement of worn patts that do not meet the manufacturer's specification tolerances. Other maintenance is performed to either replace or rebuild various pieces of equipment should a malfunction occur and force the shutdown of individual pieces of equipment. Due to the redundancy of many pieces of equipment, a malfunction of rotating equipment will not shut the SNCR System down.

5.6. Spare Parts

Spare parts are purchased and stored in inventory based on manufacturer's recommendations and plant operating experience. The spare parts for the SNCR equipment is added as attachment# I 0.

5.7. Abnormal conditions or malfunctions

a. Heater system failure b. Pressure control system failure c. Single loop controller failure d. Injector failure e. Failure of air supply for atomization and cooling f. Loss of dilution water supply g. System temperature control of solubility of solution h. Flue gas temperature control i. Nitrogen content in alternative fuels j. Failure of motor operated control valves k. Failure of pumps, piping, or check valves

In the event that a malfunction should occur to the SNCR equipment that affects or controls the plant emissions, specific action will be taken to correct the equipment malfunction. Whenever needed the use of overtime, off-shift labor, outside consultants or contractors, where reasonable to minimize the duration of the malfunction or excess emissions will be used. This action in cooperation with the DEQ-AQD district supervisor will be taken, and one or more of the following steps: 19 Emission J'vfinimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

a. Continue to nm the malfunctioned equipment as long as the plant emissions are in compliance. This may or may not require the boiler to run at reduced loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. In some cases, it will be possible to run the boiler at either full load or reduced load and be in compliance with emissions when the malfunctioned SNCR equipment is out or service for repairs.

c. Continue to run the boiler and repair the equipment, if the repair takes less time than the time required for a normal boiler shutdown and startup. Emissions may exceed the permit limits for certain periods of time during boiler stattup and shutdown. This situation may be unavoidable and is addressed in the emission minimization plan during startup and shutdown (see Section 7)

d. Correct the malfunctioned equipment by shutting down the SNCR system and boiler to repair the equipment. Shutting down the boiler will cease all plant emissions.

The time frame for repair of each of the malfunctions listed in the table below are estimates from prior plant experience. All components of the plant systems are not identical and time frames for repair will vary somewhat due to location in the plant, accessibility for repairs, and time when malfunction occurs. Each time frame should be completed from time of initial malfunction or abnormal condition.

5.7Abnonnal conditions or malfunctions 5.8 Abatement measures times in hours

, fnilm·e a. b c d HeMer - - 1?0 ?1 P•·e«m·e nntrnl - foilu•·e - - - 1?0 ,,.. ;11, ·foilmP - - - 1 SinaiP lnnn 120 4. lniector fHilure - - - 1?0 'i I'Hilure nf oi•· en content in alternative fuels - - - 240

6. MECHANICAL DUST COLLECTOR

6.1. Description

A Joy Manufacturing multi-clone mechanical dust collector is provided in the flue gas ductwork exiting the boiler. The multi-clone mechanical dust collector will remove the heavier patticles of fly ash from the flue gas steam prior to the flue gas passing through the induced draft fan and to the electrostatic precipitator. The mechanical dust collector is furnished by Joy Manufacturing Corporation.

The mechanical dust collector does not have moving parts and is fitted with the following fixed devices for removal of dust particles, char, and sand.

A series of collector tubes consisting of inlet and outlet tubes.

The collector tubes are contained within a dust collector housing where the flue gas enters and exits the mechanical dust collector. Two ash hoppers are attached to the housing to collect the ash removed from the gas stream by the collector tubes.

6.2. Operation

The mechanical dust collector is operated at all times when the boiler is operating. In as much as the mechanical dust collector has no moving parts, it relies on centrifugal force created by the collector tubes for removal of dust particles, char and sand from the flue gas stream. This material is then collected in the ash hoppers below the collector tube housing and removed by means of the ash handling system.

Controls for the mechanical dust collector operate rotary valves and an ash removal system on the outlets of the ash hoppers. This equipment handles the material removed by the multi-clone collector tubes.

The operation of the mechanical dust collector assist in controlling the plant's particulate emissions. The mechanical dust collector is operated in a manner to satisfy the following critical criteria.

Patticulate

Inlet dust loading to the collectors per cubic feet of flue gas flow. Flue gas temperature of approximately 350 degrees F. at collectors.

6.4. Inspections

Daily inspections are performed on the mechanical dust collector to ensure that the equipment is operating properly and to observe various changes that may indicate potential malfunction. The inspections to be performed each day are as follows: see log sheets section 13

a. Observe the operation of the system. Log #4 b. Observe that the ash removal system is operating properly. Log #4 c. Operator Tech from the DCS system monitor the drafts and temperature on the system continuously. Under normal conditions the dust collector draft averages -9 inches of water and operates at an average temperature of 340° F.

Annual inspections are performed on the mechanical dust collector to ensure that the equipment is in proper operating condition. This inspection includes the shutting down of the boiler and internal inspection of the multi-clone collector tubes. Log #5

Due to the abrasive nature of the sand and unburned char being collected in the mechanical dust collector, the multi-clone collector tubes will erode away and need to be replaced periodically. The rotary air lock valves and external ash removal system are to be inspected during the annual outage.

6.5. Maintenance

Maintenance on the mechanical dust collector is performed in accordance with the manufacture's recommendations and plant operating experience. Normal maintenance is performed during the annual inspection with the replacement of worn parts that do not meet the manufacturer's specification tolerances. Other maintenance will be performed to either replace or rebuild various pieces of equipment should a malfunction occur and force the shut down of the boiler.

6.6. Spare parts

Spare patts are purchased and stored in inventory based on manufacturer's recommendations and plant operating experience. The spare parts list for the mechanical dust collector is included as attachment #I I .

6.7. Abnormal conditions and malfunctions

a. Rotary air lock valve failure b. Ash removal system failure c. Ash reinjection system failure d. Centrifugal turning vanes or separator tube failure. e. Tube sheet failure.

6.8. Abatement measures

In the event that a malfunction should occur to mechanical dust collector equipment that affects the control of the plant emissions and causes the plant to exceed the permitted levels, specific action will be taken to bring the plant back into compliance. Whenever needed the use of ovettime, off-shift labor, outside consultants or contractors, where reasonable to minimize the duration of the malfunction or excess emissions will be used. This action in cooperation with the DEQ-AQD district supervisor will be taken and either one or more of the following steps:

a. Continue to run the malfunctioned equipment at lower loads as long as the plant emissions are in compliance. This may or may not require the boiler to run at reduced loads.

b. Continue to run the boiler and repair the equipment, if the estimated repair would create less total emission than a normal shutdown and stattup. Emissions may exceed the permit limits for certain periods of time during boiler stattup and shutdown. This situation may be unavoidable and is addressed in the emission minimization plan during startup and shutdown (see Section 7).

c. Correct the malfunctioned equipment by shutting down the boiler and repair the equipment. Shutting down the boiler will cease all plant operations.

The time frame for repair of each of the malfunctions listed in the table below are estimates fi·om prior plant experience. All components of the plant systems are not identical and time frames for repair will vary somewhat due to location in the plant, accessibility for repairs, and time when malfunction occurs. Each time frame should be completed from time of initial malfunction or abnormal condition.

Abnormal conditions or malfunctions 6.8 Abatement measures times in hours

I. Rotarx air lock valve failure 24 48 120 2. Ash removal system failure 24 48 120 3. Ash reinjection S:istem failure 24 48 120 4. Centrifugal turning vanes or separator tube failure. 720 5. lube sheet failure. 720

7. BOILER

7.1. Description

Hillman Power Company uses wood fuel, tire derived fuel, and natural gas to fire a cross flow boiler with a double-pass superheater to generate steam at 850 psig and 900 degrees F. This boiler is of the latest design technology utilizing water panels open to the combustion space walls and floor to gain maximum heat transfer. A natural gas system is used for boiler startup and also for flame stabilization of the wood and TDF fuel supply.

The method of combustion is by the use of a shaker grate system. The fuel is uniformly distributed over the stoker grate by means of air swept spout feeders. Combustion air is provided to the stokers grate system by forced draft and overfire air fans and flue gas drawn from the combustor by an induced draft fan. The steam generator pmtion consists of both radiant and convection pass tubes and superheater above the shaker grate system.

An ash reinjection system is included to collect unburned carbon from the ductwork hoppers and the multi-clone mechanical dust collectors. The unburned carbon is reii*cted into the boiler. The ash reinjection system will reduce the ash that would normally be collected in the ash handling system and enhance the combustion efficiency.

The boiler ash system consist of a series of augers conveying ash from the ESP, air heater ash system, mechanical dust collector, and bottom ash to the ash storage area. From the storage area the ash is transpmted by truck to the local landfill. Fuel system consist of a reclaimer, disc screen, three feeders, and a series of belt conveyors that size and convey the wood and tire derived fuel to the boiler grate area.

24 7.2. Operation

The boiler is operated by properly trained boiler operators who will operate the equipment in accordance with the manufacturer's recommendations and plant operating procedures. Combustion control of the boiler, monitoring of boiler parameters and alarms for the boiler are directed by the main plant Distributed Control System (DCS) located in the main control room. Specific functions of the boiler controls are as follows:

a. Control steam flow, pressure, and temperature from the superheater to the steam turbine generator. b. Control fuel feed rate to the boiler for proper heat input to satisfy the required steam generation rate. c. Control fuel air ratio through the forced draft, overfire air, and induced draft fans. d. Control grate shaker sequence for proper and complete combustion for the fuel. e. Control steam drum water level and pressure to ensure proper boiler circulation and steam flow. f. Monitor and record boiler operating parameters and auxiliary equipment. g. Monitor all motion detection devices.

Above items are monitored 24 hours a day by the plant operator and DCS system.

Proper control and efficient operation of the boiler also ensures that complete combustion is achieved and emissions minimized. In order for the overall plant emissions to be in compliance with the current Air Use Permit, the boiler is operated to maintain the following critical criteria:

Patticulate

a. Wood and tire derived fuel consisting of chips sized at minus 2.5" x 2.5", saw dust and planer mill fines are burned in the boiler. The specification for the wood fuel and tire derived fuel is as described in the Fuel Analysis added as attachment #12.

b. Efficient operation of the boiler will also ensure that complete combustion is taking place and that the amount of particulate consisting of fly ash is minimized. The predicted efficiency of the boiler is 68 %. The efficiency of the boiler is directly related to maintaining the fuel to air ratio, which will provide an excess air leaving the furnace a approximately 5 % 0 while burning approximately 28 ton per hour of fuel. 2

a. Efficient operation of the boiler also influences the generation of NO, . The boiler is designed to maintain proper combustion temperatures to minimize the generation of NO, through control of the fuel air ratio. The predicted NOx levels before reduction by the SNCR system is approximately 0.30 #/mbtu heat Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

input. Again this is demonstrated by maintaining the excess air leaving the furnace at 5% oxygen. The excess air is being monitored and recorded by the CEM equipment as required by the Air Use Permit.

b. Efficient operation of the boiler also controls the flue gas temperature in the furnace in the region where the urea chemical is to be injected from the SNCR system. In this area of the furnace the flue gas temperature will range from 1700 to 2000 degrees. co

a. Efficient operation of the boiler also influences the generation or CO. In as much as the generation of CO is somewhat related to the level of NO,, as long as the NO, is being maintained at 0.30 #/mbtu heat input before reduction, CO should also be controlled. One distinct exception is the moisture content in the fuel.

Opacity

a. Wood fuel and tire derived fuel consisting of chips sized at minus 2.5" x 2.5", sawdust and planer mill fines are burned in the boiler. The specification for the fuels in the Fuel Analysis is included in the attachments.

b. Efficient operation of the boiler will also ensure that complete combustion is taking place and that the opacity will be minimized. voc

a. Efficient operation of the boiler influences the generation ofVOC emissions.

7.4. Inspections

Inspections are performed every four hours on the boiler to ensure that the equipment is operating properly and to observe various changes that may indicate potential malfunction. The complete plant is monitored continuously by the plant DCS System which alarms the Operator Tech as to any function that varies from the average operation by a few percentage points. The inspections to be performed each round arc as follows: sec logs in section 13

a. Observe the stoker distribution and grate area. Log #4 b. Observe the grate shakers are working properly. Log #4 c. Record bearing temperature and condition of forced draft fan. Log #4 d. Record bearing temperature and condition of overfire air fan. Log #4 e. Record bearing temperature and condition of induced draft fan. Log #4 f. Observe the complete ash system. Log #4 26 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

g. Observe the complete fuel system. Log #6

Through the process of normal operation other operating parameter are continuously observed in the control room including boiler pressures, temperature, functions of controls, and performance of the systems. A copy of the daily inspection round logs are added as attachment #13.

Annual inspections will be performed on the boiler to ensure that the equipment is in proper operating condition. The annual inspection also will include a boiler inspection by the insurance carrier. Annual inspections will include the following equipment: see work orders log #5 section 13. See also boiler license in control room.

a. All pumps pertaining to boilerwater, feedwater, and condensate. b. All boiler air fans. c. Internal inspection of the stoker grate, boiler water walls, superheater, economizer, air heater, refractory, sidewalls and seals. d. Fuel system e. Ash system

7.5. Maintenance

Maintenance on the boiler is performed in accordance with the manufacturer's recommendations and plant operating experience. Normal maintenance is performed during the annual inspection with the replacement of worn parts that do not meet the manufacturer's specification tolerances. Other maintenance will be performed to either replace or rebuild various pieces of equipment should a malfunction occur and force the shut down of the boiler.

7.6. Spare Parts

Spare patts are purchased and stored in inventory based on plant operating experience. The expected spare parts list is added as attachment # 13.

7. 7. Abnormal conditions, malfunctions, and startup and shutdown a. Loss of fuel feeders b. Rotary air damper failure c. Hydrograte failure d. Bottom ash conveyor failure e. Boiler air fan system and controls f. High moisture content in incoming fuel g. High flue gas temp h. Loss of incoming fuel i. Ash system failure j. Loss of boiler refractmy k. Plant air supply system failure 27 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

l. Nitrogen content in alternative fuels m. Clinkers and stagging on the Hydrograte system n. Incoming line voltage surges o. Safety valve failure p. Scheduled maintenance q. Distributed Control system failure (DCS) r. Turbine/generator system failure s. Transfer trip failure (Consumers Power emergency trip system) t. Condenser tube failure u. Loss offeedwater control v. Electrical equipment and or control failure w. Substation equipment and or control failure x. Cooling water system failure y. Boiler tube failure z. Act of God (For example Electrical storm hit by lightning)

7.8. Abatement measures

In the event that a malfunction should occur to the boiler or related equipment that affects the control of the plants emissions and causes the plant to exceed the permitted levels, specific action will b taken to bring the plant back into compliance.

Whenever needed the use of ove1time, off-shift labor, outside consultants or contractors, where reasonable to minimize the duration of the malfunction or excess emissions will be used. This action in cooperation with the DEQ-AQD district supervisor will be taken and either one or more of the following steps:

a. Continue to run the malfunctioned equipment at lower loads as long as the plant emissions are in compliance .. This may or may not require the boiler to run at reduced loads.

b. Correct the malfunctioned equipment by taking it out of service for repairs. It may be necessary to run the boiler at reduced loads to be in compliance with emissions when the malfunctioned equipment is out of service for repairs.

c. Continue to run the boiler and repair the equipment, if the repair takes less time than the time required for a normal boiler shutdown and startup. Emissions may exceed the permit limits for certain periods of time during boiler startup and shutdown. This situation may be unavoidable and is addressed in the emission minimization plan during startup and shutdown (see Section 7).

d. Correct the malfunctioned equipment by shutting down the boiler and repa1r the equipment. Shutting down the boiler will cease all plant emissions.

The time frame for repair of each of the malfunctions listed in the table below are estimates from prior plant experience. All components of the plant systems are not identical and time frames for repair will vary somewhat due to location in the plant, accessibility for repairs, and time when malfunction occurs. Each time fi·ame should be completed from time of initial malfunction or abnormal condition. 7.7 Abnormal conditions or malfunctions 7.8 Abatement measures times in hours

a b c d a. _Loss ot tuel teeders 24 4 n - b. Hydrograte tailure - - - 24 c. Bottom ash convevor failure - - - 24 d. Boiler air fan system and controls - - - 24 e. High moisture content in incoming fuel - - - 120 f. High flue gas temp - - - 120 g. Loss of incoming fuel - - - 120 h. Ash failure 24 - 4R 120 i. Loss of boiler refractory - - - 720 j. Plant air supply system failure - - - 24 k. Nitrogen content in alternative fuels - - - 240 l. Clinkers and stagging on the Hydrograte system - - - 24 m. Incoming line voltage surges - - 24 n. Safety valve failure - - - 48 o. UJstrmutect Lonu·o• system .aimre uLe> J - - - L't p. Turbme/generator system taJiure - - - 24 q. Transter tnp tailure - - - 24 (Consumers Power emergency trip system) r. Condenser tube failure - - - 48 s. Loss of feedwater control - - - 24 t. Electrical equipment and or control failure - - - 24 u. Substation equipment and or control failure - - - 24 v. Cooling water system failure - - - 24 w. Boiler tube failure - - - x. Act of God (Fo1 example Electllcal sto11n Jut by hghtnmg) 48 48

Startup and Shutdown

29 Emission Minimization Plan for Startup, Shutdown, and lvfalfunction Hillman Power Company

8.1 Description

Plant startup will begin when fuel is introduced to the boiler at 20.9 percent oxygen and will end when the one hour average for oxygen in the boiler reaches 5 percent. Plant shutdown will begin when the one hour average for oxygen in the boiler exceeds 5 percent until fuel stops entering the boiler and combustion ceases a 20.9 percent oxygen.

8.2 Operation

During plant startup and shutdown the plant is operated by properly trained personnel who will operate the facility in accordance with the manufacturers recommendations and plant operating procedures. During a normal plant stmiup two operating crews are generally on duty to provide constant monitoring of plant equipment and to complete the startup procedures of the individual pieces of equipment required to operate the facility. A copy of the startup procedure is added as attaclunent # 7 & 8

8.3 Critical Criteria

Proper control and efficient operation of the plant during stmiup and shutdown provides for personnel safety, minimizes wear or damage to the equipment, and minimizes the amount of and duration of emissions emitted by the facility. Plant emissions may exceed the permit limits for certain periods of time during boiler stmiup and shutdown. This situation may be unavoidable due to the limitations and conditions of the manufacturers recommended startup and shutdown procedures. The facility is operated to maintain the following critical criteria:

a. Proper valve arrangement for the process operation per plant stmiup or shutdown procedures. b. Boiler water drum level± 5" from normal operating level. c. Drum pressure not to exceed 950# d. Main steam pressure not to exceed 900#. e. Main steam temperature not to exceed 950° F. f. Furnace draft to operate from -0.2" to -1.5" of water. g. Furnace temperature not to exceed 750° F at secondary superheater inlet. h. Not to exceed Boiler Heating Curve attached in startup procedure #7. 1. Maintain cooling tower level 80% to 95% . j. Cooling tower water inlet temperature not to exceed 85° F. k. Condenser vacuum to maintain at least 20" of hg. I. Hotwelllevel not to exceed± I 0 inches from normal operating level. m. Turbine hood temperature not to exceed 200° F. n. DA tank level not to exceed± 10% of normal operating level. o. DA tank temperature not to exceed 240° F. 30 Emission Minimization Plan for Startup, Shutdown, and Malfunction Hillman Power Company

p. Reduce oxygen level in the boiler to below 8% as soon as operating condition allow. q. Maintain feed water pump pressure less than 1300#. r. Lube oil temperature not to be less than 90° F, or greater than 140° F. s. Maintain boiler water chemistry as per manufacturers recommendations. t. Maintain hydrogen purity in the generator above 90%. u. Transformer Rectifier spark rate not to exceed 240 sparks per minute. v. Account for all personnel on sight at all times.

8.4/nspections

Inspections are performed on a continuous basic during statiup to ensure that the equipment is operating properly and to observe various changes that may indicate potential malfunction. The inspections include all previous inspection items listed in this program as well as many others that petiain to the complete operation of the facility.

8.5Maintenance

Maintenance is performed to either replace or rebuild various pieces of equipment should a malfunction occur. Maintenance during startup and shutdown is performed as needed to ensure a successful operation, and to minimize the amount and duration of excess emissions.

8.6Abatement Measures

In the event that a malfunction or an abnormal condition should occur during startup or shutdown the abatement measures listed in the previous sections of this program will be complied with.