SHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

1 

## ***PUBLIC NOTICE COPY***

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia

Prevention of Significant Deterioration Permit

For Greenhouse Gas Emissions

Permit PSD

- EPA

- R4013

In accordance with the provisions of the Clean Air Act (CAA), Subchapter I, Part C

, 42 U.S.C. § 7 4 7 0

, and the implementing Prevention of Significant Deterioration (PSD) of Air Quality Regulations at the Code of Federal Regulations (CFR) Title 40 , Section 52.21 (40 CFR § 52.21 ) , and the Federal Implementation Plan at 40 CFR § 52.37 (effective December 30, 2010 and published at 75 FR 82246 (Dec. 30, 2010)) the U

. S

. Environmental Protection Agency Region 4 hereby authorizes :

Shady Hills Power Company, LLC EFS Shady Hills LLC 800 Long Ridge Road Stamford, Connecticut 06927

to construct and operate Greenhouse Gas (GHG) air emissions units as a modification to the existing Sha dy Hills Generating Station located at 14240 Merchant Energy Way within near the City of Spring Hill , in Pasco County, Florida.

T his modification to the Shady Hills facility shall be constructed and operated in accordance with the terms and conditions set forth in this permit.

This p ermit becomes effective on [ INSERT EFFECTIVE DATE] February 15, 2014

.

This permit addresses greenhouse gas

- related PSD requirements, only. For this Project, the State of Florida, through the Florida Department of Environmental Protection, retains jurisdiction over PSD permitting for regulated pollutants other than greenhouse gases. This permit shall not relieve the owner or operator of the responsi bility to comply fully with all applicable provisions

of federal and state law.

__________ ______________________ Date Signed Carol L. KemkerJeaneanne Gettle Acting Direct or Air, Pesticides, and Toxics Management DivisionSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

2 AUTHORITY

The EPA issues this permit pursuant to Subchapter I, Part C, of the Clean Air Act (CAA), 42 U.S.C. § 7470, and the implementing PSD Regulations at 40 CFR § 52.21

, and the Federal Implementation Plan at 40 CFR § 52.37 (effective December 30, 2010 and published at 75 FR 82246 (Dec. 30, 2010)) . This permit is based upon application materials submitted to the EPA by Shady Hills Power Company, LLC EFS Shady Hills LLC ( Shady Hills ), dated September 2 5

, 2012, November 30 , 2012, March 27 , 201 3

, and July 26, 2013, supplemental submittals in the administrative record for this permit action, and upon the technical analysis performed by the

EPA.

APPLICANT

Shady Hills Power Company, LLC EFS Shady Hills LLC 800 Long Ridge Road Stamford, Connecticut 06927

PROJECT LOCATION

The existing Shady Hills ’s facility and the project will be are located at the existing Sha dy Hills Generating Station located at 14240 Merchant Energy Way within near the City of Spring Hill

, in Pasco County, Florida.

PROJECT DESCRIPTION

Shady Hills has applied for a GHG PSD air permit pursuant to the CAA from the EPA Region 4

for the proposed Project. Shady Hills is proposing to build two additional simple cycle

com bustion turbine s (Model: G eneral E lectric 7FA.05) at their existing facility . The GE7FA.05 output is 218 megawatts ( MW ) (gross) when firing natural gas and 223 MW (gross) when firing

ultra

- low sulfur distillate (ULSD) fuel oil. The primary fuel will be nat ural gas with ULSD fuel

oil

, with sulfur content of is 0.015 percent

, as backup fuel. The heat input per turbine would be 2,135 million British thermal units per hour ( MMBtu/hour ) , high heating value (HHV) at 59 deg. F, 60 percent relative humidity (ISO co nditions)

. Ancillary equipment consists of a 2.5 MW emergency generator (EU 007), a natural gas fuel heater (EU 008), a 2.8 million gallon (Mgal)

ULSD fuel oil storage tank (EU 009), an SF 6 circuit breaker s (EU 010), and new on

- site natural

gas pipeline.

Shady Hills ’s existing facility consists of three, dual

- fuel, 170 MW (nominal) GE PG7241FA simple cycle combustion turbine (SCCT)

- electrical generators, three 75 feet high exhaust stacks

, and one 2.8 million gallon fuel oil storage tank. The combustion tur bine units can operate in simple

- cycle mode and intermittent duty mode. The units are equipped with dry low

- nitrogen oxides ( NO

x ) combustors and water injection capability. The three units are regulated underSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

3 Phase II of the Federal Acid Rain Program. The existing facility and the Project are located at 14240 Merchant Energy Way within near the City of Spring Hill, in Pasco County, Florida. The Project will be located within the existing Shady Hills boundaries. The existing facility has been in operation si nce 2002 and operates usually during peak hours of electrical use

.

Th is PSD permit for the Project requires the use of Best Available Control Technology (BACT)

to limit emissions of GHG s , to the greatest extent feasible

.

EQUIPMENT LIST

The following devices and activities are subject to this PSD permit:

Unit ID Description

EU 005 223 MW GE 7FA.05 simple cycle combustion turbine

- electrical generator

EU 006 223 MW GE 7FA.05 simple cycle combustion turbine

- electrical generator

EU 007 2,5 00 kilowatt (kW) emergency generator firing ULSD fuel oil

EU 008 10 MMBtu/hr Natural Gas Heater

EU 009 2.8 Mgal Distillate Fuel Oil Storage Tank

EU 010 Three SF 6 Circuit Breaker s Fugitives On

- site pipeline and natural gas supply

PERMIT CONDITIONS

I. PERMIT EXPIRATION

As provided in 40 CFR § 52.21(r), this PSD Permit shall become invalid if construction:

A. is not commenced (as defined in 40 CFR § 52.21(b)(9)) within 18 months after the approval takes effect; or

B. is discontinued for a period of 18 months or more; or

C. is not completed within a reasonable time

.

II. PERMIT NOTIFICATION REQUIREMENTS

Pursuant to Condition IX : SPECIAL CONDITIONS

, Permittee shall notify the EPA Region 4 by letter or electronic mail of the:

A. date construction is commenced, postmarked within 30 days of such date;SHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

4 B. actual date of initial setting in operation for any purpose, postmarked within 15 days

of such date; and

C. date upon which initial certification tests will commence, in accordance with the provisions of Condition IX.E , postmarked not less than 21 days prior to such date. Notification may be provided with the submittal of the certification test protocol required pursuant to Condition IX.E

.

III. FACILITY OPERATION

A. At all times, including periods of startup, shutdown, shakedown, and malfunction, Permittee shall, to the extent practicable, maintain and operate the facility

, including associated air pollution control equipment

, in a manner consistent with good air pollution control practice s for minimizing emissions

. Determination of whether acceptable operating and maintenance procedures are being used will be based on

information available to the EPA, which may include, but is not limited to, monitoring results, opacity observations, review of operating maintenance procedures and inspection of the facility

.

B. The Permittee shall operate and maintain the CTs and associated components in a manner consistent with good engineering practices for its full utilization.

C. As soon as practicable following initial startup of the CTs (as defined in 40 CFR § 60.2) but prior to commencement of commercial operation (as defined in 40 CFR § 72.2), and thereafter, the Permittee shall develop and implement an operation and maintenance plan for the facility , consistent with Condition III.B above

. At a minimum, the plan shall identify measures for assessing th e performance of the

f acility , the acceptable range of the plant performance measures for achieving the design electrical output, the methods for monitoring the plant performance measures, and the routine pr ocedures for maintaining the f acility in good operating condition.

IV. MALFUNCTION REPORTIN G

A. Permittee shall notify the EPA Region 4 via the contact information provided in

Condition X : A GENCY NOTIFICATIONS within two (2) calendar days following the discovery of any failure of air pollution control equipment or process equipment

,

or failure of a process to operate in a normal manner, which results in an increase in

emissions above the allowable emission limits stated in Condition IX : S PECIAL

CONDITIONS of this permit.

B. In addition, pursuant to Condition X : A GENCY NOTIFICATIONS

, Permit tee shall provide written notification to the EPA within fifteen (15) calendar days of any such

failure described under Condition IV.A

. This notification shall include a description of the malfunctioning equipment or abnormal operation, the date of the initia lSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

5 malfunction, the period of time over which emissions were increased due to the

failure, the cause of the failure, the estimated resultant emissions in excess of those

allowed in Condition IX : SPECIAL CONDITIONS , and the methods utilized to mitigate emissions and restore normal operations

.

C. Compliance with this malfunction notification provision shall not excuse or otherwise constitute a defense to any violation of this permit or any law or regulation such malfunction may cause.

V. RIGHT OF ENTR Y

The EPA Regional Administrator, and/or an authorized representative, upon the presentation of credentials, shall be permitted:

A. t o enter the premises where the f acility is located or where any records are required to be kept under the terms and condi tions of this PSD Permit;

B. during normal business hours, to have access to and to copy any records required to be kept under the terms and conditions of this PSD Permit;

C. to inspect any equipment, operation, or method subject to requirements in this PSD Permit; and

D. to sample materials and emissions from the source(s).

VI. TRANSFER OF OWNERSHI P

In the event of any changes in control or ownership of the f acility, this PSD Permit shall be binding on all subsequent owners and operators

. Within 14 days of any such change in control or ownership, Permittee shall notify the succeeding owner and operator of the existence of this PSD Permit and its conditions by letter

. Permittee shall send a copy of

this letter pursuant to Condition X : A GENCY NOTIF ICATIONS to the EPA Region 4 within thirty (30) days of its issuance

.

VII. SEVERABILITY

The provisions of this PSD Permit are severable, and, if any provision of the PSD Permit is held invalid, the remainder of this PSD Permit shall not be affected.

VIII. ADHERENCE TO APPLICA TION AND COMPLIANCE WITH OTHER

ENVIRONMENTAL LAWSSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

6 A. Permittee shall construct th e P roject in compliance with this PSD permit, the

application on which this permit is based

, and all other applicable federal, state, and local air qua lity regulations. This PSD permit does not release the Permittee from any liability for compliance with other applicable federal, state and local environmental laws and regulations, including the Clean Air Act.

B. If prehistoric or historic artifacts, such a s pottery or ceramics, stone tools or metal implements, or any other physical remains that could be associated with Native American cultures, or early colonial or America settlement are encountered at any time within the project site area, the permitted pr oject should cease all activities involving subsurface disturbance in the immediate vicinity o f such discoveries. Upon such discovery, P ermittee, or other designee, sh all immediately contact the Florida Department of State, Division of Historical Resources , Review and Compliance Section at 850.245.6333 or 800.847.7278, as well as the appropriate permitting agency office s (FDEP and the EPA Region 4) . Project activities sh all not resume
wit hout verbal and/or written auth o r ization from the Division of Historic al Resource. In the event that unmarked human remains are encountered during permitted activities, all work shall stop immediately and the proper authorities notified in accordance with Section 872.05, Florida Statutes.

B.



### I X. SPECIAL CONDITIONS

A. Air Pollution Control Equipment and Equipment Operation

Permittee shall perform any necessary operations to minimize emissions so that emissions are at or below the emission limits specified in this permit

.

B. Combustion Turbine s (EU 005 & 006) Emission Limits

1. Except as noted below under Condition IX.C

. and Condition IX.I. , on and after the date of initial startup and completion of the shakedown period , Permittee shall not discharge

or cause the disc harge of emissions from the SC CT Unit s into the atmosphere in excess of the following:

Normal Operation * GHG Emission Limit per CT on gross output basis

and corrected to ISO

conditions * Emission Limit (per CT)

(n N atural gas firing ) * * Emission Limit (per CT ) ( ULSD oil burning ) * *

1,377 pounds ( lb ) of carbon dioxide equivalent ( CO 2 e ) per

megawatt

- hour ( MWh ) gross output (12

- month rolling average ) 1, 928 lb CO 2 e /MWh gross

o utput (12

- month rolling average )

* Normal operation is achieved when a CT reaches 50% load or greater.

* * Compliance with the above limits shall be demonstrated in accordance with Condition IX.E. 8 9

. Formatted: Normal, No bullets or numberingSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

7 2. If both, EU 005 and 006 are constructed, they shall not operate an average of more than 3,390 hours per year per CT on a 12

- month rolling total basis

. No single unit shall operate more than 5,000 hours per year on a 12

- month rolling total basis , when firing natural gas

.

If only on e combustion turbines is installed, it shall operate no more than 3,390 hours per

year on a 12

- month rolling total basis , when firing natural gas

.

Permittee shall monitor and record the number of hours each CT operates monthly and totalled every month for the previous 12 months.

3. If both, EU 005 and 006 are constructed, they shall not operate firing fire ULSD fuel oil

more than 1,0 0 0 combined hours per year on a 12

- month rolling total . The Permittee shall monitor and record the number of hours each CT operates on ULSD monthly and totalled every month for the previous 12 months

.

If only one SC CT is installed

, the CT may operate up to 5 00 hours firing ULSD oil per

year on a 12

- month rolling total

. The single combustion turbine may fire additional 250 hours of ULSD oil, provided that for every hour of ULSD oil fired beyond the 500 hours,

the CT m u i st reduce its capability to fire natural gas by five hours ( i.e., 5:1 natural gas to ULSD fuel oil ratio). { Example: I

f the single combustion turbine operates on ULSD fuel oil for 750 hours per

year on a 12

- month rolling total , then it may only operate for only 1,640 hours on natural gas during t

he same period [( 3,390

- 500)

- 5(750

- 500)]}

C. Combustion Turbine s (EU 005 & 006) Startup and Shutdown Emission Limits

1. Startup is defined as the commencement of operation of any emissions unit which has shut down or ceased operation for a period of time to begin on the minute when fuel is first ignited in the CT and terminates on the minute when the CT reaches 50% load. sufficient to cause temperature, pressure, chemical, or pollution control device

imbalances

, which result in excess emissions above the limi ts in Condition IX. C

. 3

.

2. Shutdown occurs on the minute when the CT load is less than 50% load until the minute that fuel flow to the CT stops is the cessation of the operation of an emissions unit for any

purpose

.

2. 3. T otal t ime ( in hours) during startup and shutdown shall be included in the limit on tot al hours of operation in Condition IX.B.2. When ULSD oil is used during startup or shutdown, the total time (in hours) of such use shall be included in the limit on hou r s of operation firing ULSD oil in Conditi on IX.B.3.

3. 4. Permittee shall not discharge or cause the disc harge of emissions from the CT Unit into the atmosphere in excess of the following during startup and shutdown events :SHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

8 GHG Emission

Limit per event and

corrected to ISO

conditions Startup

and Shutdown Emission Limit (per CT)

N (n atural gas firing ) * Emission Limit (per CT ) ( ULSD oil burning ) *

21 tons CO 2 e per event

(12

- month rolling average ) 28 tons CO 2 e per event (12

- month rolling average )

* Compliance with the above limits shall be demonstrated in accordance with Condition IX.E. 9 8

.

D. Auxiliary Equipment Emission and Operational Limits and Work Practices

1. At all times, the Permittee shall not discharge or cause the discharge of emissions from each unit into the atmosphere in excess of the following , and shall otherwise comply with the following specifications on a 12

- month rolling total :

Unit ID (description) GHG Limit ( as CO 2 e)

EU 007 Emergency Generator 2,5 00 kW per engine Work Practice

Standards

EU 008 Natural Gas Heater

10 MMBtu/hr 3,96 5 6 TPY

EU 010 Circuit Breaker s Three SF 6 Circuit Breakers Work Practice

Standards

2. EU 007 E mergency G enerator shall be properly operated and maintained in accordance to manufacturer’s specifications.

3. The EU 007 Emergency Generator may be operated for emer gency and non

- emergency situations

. Combined, the The EU 007 Emergency Generator shall be limited to operation of the engine for mainten to tal a a nce and testing purposes, except during an emergency

. A nnual hours of operation of for emergency stationary reciprocating internal combustion engine EU 007 Emergency Generator (as defined in 40 CFR 63 Subpart ZZZZ) for maintenance and testing , emergency demand response

, voltage deviation, and non

emergency situations

, shall not exceed 100 hours per 12

- month rolling total , as defined by 40 CFR 63.6640(f)(2) and (4)

.

EU 007 may be operated for up to 50 hours per 12

- month rolling total in non

- emergency situations, which will be included in the maximum total annual hours of operation of 100 hours per 12

- month rolling total.SHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

9 Permittee shall monitor and record the number of hours the emergency generator operates as well as the purpose of the operation . Permittee shall calculate the total hours of operation other than for emergency situations monthly and totalled every month for the previous 12 months.

3. 4. EU 008 Natural Gas Heater shall operate exclusively on natura l gas and in accordance

to with manufacturer’s specifications

, and operate in order to maintain on a minimum n thermal efficiency of 75% or higher

.

4. 5. EU 010 Circuit B reakers shall be used as electrical interrupters in the event of a power

surge

. EU 010 Circuit Breaker s shall be totally enclosed . Permittee shall install and maintain a leak detection system on the circuit breakers that signals an alarm in the facility’s control room in the event that any circuit breaker looses pressure

. Any detected

leaks must be repaired immediately. Records of inspection shall be kept in accordance

with Condition IX.G

.

5. 6. The on

- site pipeline and natural gas supply system pressure shall be monitored and

record ed continuously against alarm set points to be determined upon sy stem design and implementation to identify any leaks . Per mitte sonnel shall treat the use natural gas treated with mercaptan for leak detection by odor. Any detected leaks must be repaired immediately. Records of inspection, detected leaks, and repairs (including action taken and duration) shall be kept in accordance with Condition IX.G

.

E. Monitoring and Compliance with GHG Emission Limits for CTs ( EU005 and 006 ) During Normal Operation

1. P er mitt e e sh a ll inst a ll

, cer ti f y
, operate, and maintain fuel flow a nd cer ti f y monito r i n g

s y st e ms re qui re d f

o r qu a nt i f y i n g C O 2 e missions fr om on each C T in acc o r d a n ce with the

a p pli ca ble re qui r e m e nts of 40 C F R P ar t 75 , Appendix D , which shall constitute the “compliance monitoring system” for this permit

. C onsist e nt with §75

. 4 ( b )

, a ll a ppli ca b l e

c e r ti f i ca tion t e sts sh a ll be c o m pl e t e d within 180 ca l e nd a r d a y s a f t er t he d a te the unit

c omm e n ces c omm e r c i a l op e r a tion (a s d ef in e d in 40 C F R 72.2 )

.

2. F ollowing initi a l c e r ti f i ca tion, the C O 2 c ontinuous fuel flow c ontinuous monitoring

s y st e m s h a ll be qu a li t y a ssu r e d in a c c o r d a n c e with the a ppli ca ble re qui re m e nts of 40 C F R

P ar t 75.

3. Data from T t he fuel flow C O 2 c ontinuous monitoring s y st e m and the procedure provided

in 40 CFR 7 5 .10(a)(3)(ii) along with the Global Warming Potential (GWP) factors provided in Condition J below sh a ll be ca p a ble of p r od u c i n g used to produce hou r l y d e t er min a tions of C O 2 m a ss CO 2 e e missions in tons p e r hour ( tons/h r)

. The permitte shall

calculat e CO 2 emissions using the Equation G

- 4 from 40 CFR 75 Appendix G and the

CH 4 and N 2 O emissions using Equation C

- 8 from 40 CFR 98 Subpart C

.

4. I n acc o r d a n c e with § 7 5.62, a n initi a l monito r i n g pl a n s h a ll be submitt e d id e nti f y i n g theSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

10 m e thodolo g y f

or whi c h fuel flow C O 2 m a ss e missions wi l l be c ontinuous l y monito r e d.

The initi a l monito r ing pl a n sh a ll be submitt e d no l a t e r th a n 21 d a y s p r ior to the initi a l

cer ti f i c a tion t e sts.

5. P er mitt e e sh a ll p r ovide noti f i ca tions a s sp ec i f

i e d in §75.61 f

or a n y e v e nt re l a t e d to the

c ontinuous m ea su re m e nt of the fuel flow C O 2

.

6. P er mitt e e sh a ll m ea su r e a nd r e c o r d, f o r e ac h C T , the f

ollowing on a n ho u r l y b a sis:

a. Gross e n e rg y output ra t e ( M W ) ;

b. C O 2 m a ss e mission ra t e ( lbs C O 2 /h r) ;

c. b. H ea t i nput ra te ( MM B t u/h r ; HHV )

, in a cc o r d a n c e with 40 C F R P ar t 75 , Appendix

D ;

d. c. Unit o p era

ti n g t ime a s d e s cr ib e d in §75.57 ( b ) ( 2) ; and

d. The t y

pe ( n a tu r a l g a s or U L S D) and amount of f u e l ( scf or gals) b u r n e d

.

e. Ambient conditions (temperature, humidity, and pressure).

7. P er mitt ee sh a ll ca l c u l a te a nd r ec o r d, f or e ac h C T, the f

ollowing on a m onth l y b a sis:

a. Monthly average CO 2 mass emission rate (lbs CO 2 /MWh) calculated as the sum of each hourly CO 2 mass emission rate times the unit operating time for the hour divided by the sum of the recorded energy output rates times the unit operation

time for the hour for all hours of operation in each month. If more than one fuel is utilized in a month, a separate average CO 2 emission rate shall be calculated for

each fuel.

b. Month l y a v e r a g e h ea t ra te ( B tu/k W h) ca l c ul a t e d a s the sum of e a c h hou r l y h e a t input ra te tim e s the unit op era t i ng time f or t h e hour divid e d b y t h e sum of the

r ec o r d e d e n e rg y output ra t e s tim e s the unit op era ting time f or the h our f

or a ll

hou r s of o p e r a tion in eac h month tim e s 1,000. I f m o r e th a n one f u el is utili z e d in a month, a s e p a r a te a v er a g e h eat input ra te sh a ll be c a l c ul a t ed f or e ach f u e l.

8. 7. P er mitt e e sh a ll ca l c u l a te a nd r ec o r d, f or e ac h C T, the f

ollowing on a n a nnu a l 12

- month rolling average b a sis , in each case corrected to ISO conditions :

a. The 12

- month r olling a v er a ge C O 2 mass e e mission ra te ( lbs C O 2 /M e / M W h 12

- month rolling total ) (f

or e a c h f u e l c ombust e d in the p re vio u s 12 months) sh a ll be

ca l c ul a t e d a s the sum of ea c h month l y a v er a ge v a lue tim e s the month l y e n e rg y output ( M W h) divid e d b y the s u m of the e n e rg y output ( M W h) g e n e ra t e d du r ingSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

11 the 12 month p e r iod based on the total fuel fired during the prior 12 calendar

months

, at all times other than startup and shutdown

, using the global warming potential (GWP) factors in Condition J : GLOBAL WARMING POTENTIAL (GWP )

.

. b. The 12

- month r olling a v er a ge h e a t ra te gross output ( B tu/ M k W h) (f or e a c h f u e l

c ombust e d in the p re vious 12 months) sh a ll be ca l c ul a t e d based on the total fuel fired, at all times other than startup and shutdown , during the prior 12 calendar

months using the global warming potential (GWP) factors in Condition J

. a s the

s u m of eac h month l y a v e r a g e h ea t r a te v a lue tim e s the month l y e n e rg y output ( k W h) divid e d b y the sum of t h e e n e rg y output ( k W h) g e n era t ed du r i n g t he 12 month p er iod

.

c. The 12

- month rolling total CO 2 e emission rate shall be divided by the 12

- month rolling gross output rate to determine the lb/MWh rolling average

.

a.

8. For demonstrating compliance with the limits specified in Condition IX.B.1 , Permittee shall use the procedures set forth in 40 CFR parts 75 and 98 to determine resulting GHG emissions (as CO 2 e) based on the combination of measured CO 2 emissions and calculated

CO 2 e of other GHG pollutants ( using the GWP as specified in Condition J : GLOBAL

W ARMING POTENTIAL (GWP ) )

. Permitte e shall keep adequate records of these GHG

emission calculations according to requirements in Condition IX.H.1.

F. Monitoring and Compliance with GHG Emission Limits for CTs (EU005 and 006) During Startup and Shutdown

1. For each fuel, a new startup and shutdown CO 2 e 12

- month rolling average (tons

CO 2 e/event) is calculated each calendar month based on the summation of fuel consumption during all startup and shutdown events during the prior 12 consecutive

calendar months divided by the number of startup and shutdown events in the 12

- month period.

1. 2. Permittee shall monitor and record the time, date, fuel type, and duration of each startup and shutdown event. These records must be kept for five years following the date of suc h

event s

.

2. 3. For demonstrating compliance with the limits specified in Condition IX.C.3 , Permittee shall use the procedures set forth in 40 CFR parts 75 and 98 to determine resulting GHG emissions (as CO 2 e) based on the combination of measured CO 2 emissions and calculated

CO 2 e of other GHG pollutants (as specified in Condition J : GLOBAL WARMING POTENTIAL (GWP ) ). Permittee shall keep adequate records o f these GHG emission

calculations according to requirements in Condition IX.H.1.

G. Monitoring and Compliance for Auxiliary EquipmentSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

12 1. Permittee shall install

, operate, and maintain an operational non

- resettable totalizing mass

or volumetric flow meter in each fuel line to measure fuel use for the 10.0 MMBtu/hr natural gas heater (EU 008) to be recorded monthly an d totalled every month for the previous 12 months

.

2. Permittee shall install , operate, and maintain a n operational non

- resettable elapsed time

meter for 2,500 kW emergency use engine ( EU 007) and 10.0 MMBtu/hr Natural gas heater (EU 008) to be recorded monthly and totalled every month for the previous 12

months

.

3. Permittee shall calculate and record the operating thermal efficiency of the 10.0 MMBtu/hr natural gas heater (EU 008) on a daily monthly basis.

To maintain the EU 008 operating at a high efficiency, the Permittee shall perform annual

tune

- ups and meet the associated requirements as follows (if the unit is not operating on the required date for a tune

- up, the tune

- up must be conducted within one we ek of startup) in accordance with manufacturer’s specifications :

a. I nspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, but you must inspect each bur ner at least once every 18 months).

b. Inspect the flame pattern, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications.

c. Inspect the system controlling the air

- to

- fuel r atio, and ensure that it is correctly calibrated and functioning properly

4. On a monthly basis, Permittee shall use the annual heat input as calculated using the data obtained from monitoring required by Conditions G.1 and G.2, and data from 40 CFR
Part 98, Table C

- 1 to calculate and record CO 2 e emissions from the 10.0 MMBtu/hr natural gas heater (EU 008) on a 12

- month rolling average using the Global Warming

Potential factors as established in Condition J.

5. Permittee shall:

a. Continuously monitor and record circuit breakers pressure;

b. Visually inspect, in accordance with manufacturer’s standards, circuit breakers and components on a daily basis;

c. Provide periodic maintenance to the circuit breaks and its components; Formatted: Not Superscript/ SubscriptSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

13 d. Repair any leaks and replace equipment as needed;

H. Recordkeeping and Reporting

1. Permittee shall maintain a file of all records, data, measurements, reports, and documents

r elated to the operation of the f acility, including, but not limited to, the following:

a. all records or reports pe rtaining to adjustments and/or maintenance performed on any system or device at the f

acility that are part of the emission units and activities regulated by this permit ;

b. all records relating to performance tests and monitoring of auxiliary combustion equipment ; and

c. all other information that this permit requires Permittee to obtain, maintain, or develop, recorded in a permanent form suitable for inspection.

2. Permittee shall maintain continuous monitoring system records that include the following: the occurrence and duration of any startup, shutdown, shakedown, or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is inoperative, and corresponding emission measurements

.

3. Permittee shall maintain records of all source tests and monitoring and compliance information required by this permit

.

4. Permittee shall maintain records and submit a written repo rt of all deviations from permit requirements to the EPA semi

- annually, except when: more frequent reporting is specifically required by an applicable subpart; or the Administrator, on a case

- by

- case basis, determines that more frequent reporting is necess ary to accurately assess the compliance status of the source

. The report is due on September 30 th and March 31 st and shall include the following:

a. If applicable, t ime intervals, data and magnitude of the excess emissions, the nature and cause (if known), corrective actions taken and preventive measures adopted ;

b. If a pplicable , the time and date of each period during which the continuous monitoring system was inoperative (monitor down

- time), except for zero and span checks, and the nature of continuous moni toring system repairs or adjustments;

c. A statement in the report of a negative declaration; that is, a statement when no

excess emissions occurred or when the continuous monitoring system has not been inoperative, repaired, or adjusted; ;

d. Any failure to co nduct any required source testing, monitoring, or other complianceSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

14 activities; and

e. Any violation of limitations on operation, including but not limited to restrictions on hours of operation.

5. Excess emissions shall be defi ned as any period in which the f acility emissions exceed

the maximum emission limits based on the applicable averaging period as set forth in this permit.

6. A period of monitor down

- time shall be any unit operating clock hour in which sufficient

data are not obtained by the continuous mon itoring system to validate the hour for CO 2

.

7. Excess emissions indicated by continuous monitoring system source testing, or compliance monitoring Section IX.E. Monitoring and Compliance with GHG Emission Limits for CTs (EU005 and 006) and Section IX.F Monitoring and Compliance with GHG Emission Limits for CTs (EU005 and 006) During Startup and Shutdown shall be considered violations of the applicable emission limit for the purpose of this permit.

8. Permittee shall maintain a copy of the current operation and maintenance plan for the

f acility , and shall keep a copy of all prior versions of the plan for a minimum of five

years

. The Permittee shall also keep records of the monitoring data for each of the f acility performance measures and all maintenance acti vities; the Permittee shall maintain such records for a minimum of five years following the date they are created

9. Unless otherwise specified herein , a ll records required by this PSD Permit shall be retained for not less than five years following the date of such measurements, maintenance, reports , and/or records. These records shall be made available for review upon request by the Agency or authorized representative during the course of an inspection.

I. Shakedown Periods

The combustion turbine and auxiliar y equipment emission limits and requirements in

Conditions I X. B

, I X. C , and I X. D shall not apply during combustion shakedown periods. Shakedown is defined as the period beginning with initial startup and ending no

later than the successful completion of initial performance testing, during which the Permittee conducts operational and contractual testing and tuning to ensure the safe, efficient and reliable operation of the plant

. The shakedown period shall not exceed 18 0 days. The requirements of Section I II of this permit shall apply at all times.

J. Global Warming Potential (GWP)

For the purposes of showing compliance with any GHG emission limit in this permit, the GWP factors listed in 40 CFR Part 98 Subpart A, Table A

- 1 amended on November 29,

2013 [78 FR 71948 ] and effective on January, 1 ,2014 as of the date of this permit shallSHGS EFS Shady Hills LLC Project (PSD

- EPA

- R401 3 )

- Final Draft PSD Permit 1 / 1 3 /1 3 4

15 be used. The current GWP factors are listed below:

GHG Pollutant GWP Factor

CO 2 1

CH 4 2 5 1

N 2 O 298 310

SF 6 2 3 2

, 8 9 00

X. A GENCY NOTIFICATIONS

All notifications, reporting or other communications relating to this permit shall be

submitted to:

Chief

Air & EPCRA Enforcement Branch Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

In addition, electronic copies of the above

- referenced notifications and communications shall be submitted to the following individuals at their corresponding email address:

Name Email Phone

Jason Dressler dressler.jason@epa.gov 404

- 562

- 9208 Katy R. Lus k y forney.kathleen@epa.gov 404

- 562

- 9 130

Heather Ceron ceron.heather@epa.gov 404

- 562

- 9185