Specifications include, but are not limited to: Task 1: Information Collection and Review. The consultant will request relevant information from Bluegrass Station (BGS) necessary to develop a complete permit renewal application. Such information will include, but not be limited to, the current emission inventory spreadsheet used by BGS, recent Ky Emission Inventory Surveys (EIS), the previous operating permit renewal application submitted to the Ky Div for Air Quality (KDAQ), applications for minor revisions submitted during the current permit term, and any notifications submitted during the current permit term for administrative permit amendments, Section 502(b)(10) changes, and off permit changes. Site visits may be necessary to fully evaluate the emission points at BGS. Task 2: Emission Calculations. Using BGS's current emission inventory spreadsheet as a starting point, the consultant will assemble a complete set of emission calculations for BGS. This inventory will include changes addressed by recent minor revisions and requested adjustments to the emission factors currently used in the EIS. The consultant will revise or provide new spreadsheets for use by BGS employees. Task 3: Regulatory Review. The consultant will prepare a cursory regulatory review to verify that the current operating permit addresses all applicable regulations and to identify necessary supplements or changes. This review will account for changes in regulatory applicability associated with projects undertaken during the current permit term, including those characterized by Section 501(b)(10) and off-permit change notifications. TASK 4: Application Forms. KDAQ requires that the DEP7007 AI to DD-forms be submitted for a renewal application only to the extent that each has changed since the previous submittal. However, additional application forms may be included to convey information related to corrections or updates relative to the most recent source-wide permit application. As such, BGS wishes to take this opportunity to either correct or reaffirm the information previously provided in applicable DEP forms. Recent experience with KDAQ suggests that the agency may require a complete set of DEP7007 N-forms as part of a renewal application. BGS requests that the proposed scope of work include a comprehensive set of N-forms, which address requested changes to the EIS emission factors. BGS assumes that it will be acceptable for the DEP7007 CC-form to reference the most recent annual compliance certification and that the scope of the DEP7007 V-forms can be limited to addressing changes to existing regulations and newly applicable regulations. Task 5: Requested Permit Changes and/or Red-Lined Permit. To address requested changes to the current operating permit language, BGS asks that the consultant develop a red-lined version of the permit and/or a list identifying requested changes and the corresponding rationale for each change. BGS will provide a permit mark-up to identify its specific requested changes; however, BGS assumes that the consultant will also review the existing permit language to identify opportunities for streamlining and improved clarity. These requested changes should accommodate the application for revision and notifications submitted during the permit term. (The current operating permit already accounts for the most recent minor revision application submitted to KDAQ). Task 6: Complete Permit Application. The consultant will assemble the deliverables from Tasks 2 through 5 into a comprehensive operating permit renewal application. A draft of this application will be reviewed by BGS, and BGS will provide comments, edits and other feedback. The consultant will then update the application to accommodate this feedback prior to submittal. The consultant shall be available for assistance during the KDAQ review and public notice periods.
