State of Ohio Environmental Protection Agency

STREET ADDRESS: MAILING ADDRESS:

Lazarus Government Center

50 W. Town St., Suite 700

Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644-3184

www.epa.state.oh.us

P.O. Box 1049

Columbus, OH 43216-1049

Ted Strickland, Governor

Lee Fisher, Lieutenant Governor

Chris Korleski, Director

v Printed on Recycled Paper Ohio EPA is an Equal Opportunity Employer Printed in-house

11/24/2008

Mr. Raj Shah

Norton Energy Storage L.L.C.

2603 Augusta Boulevard, Suite 900

Houston, TX 77057

RE: FINAL AIR POLLUTION PERMIT-TO-INSTALL AND OPERATE

Facility ID: 1677105001

Permit Number: P0103955

Permit Type: Administrative Modification

County: Summit

Dear Permit Holder:

Enclosed please find a final Air Pollution Permit-to-Install and Operate ("PTIO") which will allow you to install, modify,

and/or operate the described emissions unit(s) in the manner indicated in the permit. Because this permit contains 

conditions and restrictions, please read it very carefully.

Ohio EPA maintains a document entitled "Frequently Asked Questions about the PTIO". The document can be 

downloaded from the DAPC Web page, www.epa.state.oh.us/dapc, from the "Permits" link. This document contains 

additional information related to your permit, such as what activities are covered under the PTIO, who has enforcement 

authority over the permit and Ohio EPA’s authorization to inspect your facility and records. Please contact the Office of 

Compliance Assistance and Pollution Prevention at (614) 644-3469 if you need assistance.

The issuance of this PTIO is a final action of the Director and may be appealed to the Environmental Review Appeals 

Commission ("ERAC") under Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and describe the 

action complained of and the grounds for the appeal. The appeal must be filed with the ERAC within thirty (30) days after 

notice of the Director's action. A filing fee of $70.00 must be submitted to the ERAC with the appeal, although the ERAC, 

has discretion to reduce the amount of the filing fee if you can demonstrate (by affidavit) that payment of the full amount of 

the fee would cause extreme hardship. If you file an appeal of this action, you must notify Ohio EPA of the filing of the 

appeal (by providing a copy to the Director) within three (3) days of filing your appeal with the ERAC. Ohio EPA requests 

that a copy of the appeal also be provided to the Ohio Attorney General's Office, Environmental Enforcement Section. An 

appeal may be filed with the ERAC at the following address:

Environmental Review Appeals Commission

309 South Fourth Street, Room 222

Columbus, OH 43215

If you have any questions regarding this permit, please contact the Akron Regional Air Quality Management District. This 

permit has been posted to the Division of Air Pollution Control (DAPC) Web page www.epa.state.oh.us/dapc. 

Sincerely,

Michael W. Ahern, Manager

Permit Issuance and Data Management Section, DAPC

Cc: ARAQMD

Certified Mail

No TOXIC REVIEW

No PSD

No SYNTHETIC MINOR

No CEMS

No MACT

No NSPS

No NESHAPS

No NETTING

No MAJOR NON-ATTAINMENT

No MODELING SUBMITTED

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

FINAL

Air Pollution Permit-to-Install and Operate

for

Norton Energy Storage L.L.C.

Facility ID: 1677105001

Permit Number: P0103955

Permit Type: Administrative Modification

Issued: 11/24/2008

Effective: 11/24/2008

Expiration: 9/25/2013

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Air Pollution Permit-to-Install and Operate

for

Norton Energy Storage L.L.C.

Table of Contents

Authorization.......................................................................................................................................................... 1

A. Standard Terms and Conditions....................................................................................................................... 3

1. What does this permit-to-install and operate ("PTIO") allow me to do?....................................................... 4

2. Who is responsible for complying with this permit?..................................................................................... 4

3. What records must I keep under this permit? ............................................................................................. 4

4. What are my permit fees and when do I pay them?.................................................................................... 4

5. When does my PTIO expire, and when do I need to submit my renewal application? ................................ 4

6. What happens to this permit if my project is delayed or I do not install or modify my source?..................... 5

7. What reports must I submit under this permit? ........................................................................................... 5

8. If I am required to obtain a Title V operating permit in the future, what happens to the operating provisions 

and PER obligations under this permit?...................................................................................................... 5

9. What are my obligations when I perform scheduled maintenance on air pollution control equipment? ....... 5

10. Do I have to report malfunctions of emissions units or air pollution control equipment? If so, how must I 

report?........................................................................................................................................................ 6

11. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are located?.......... 6

12. What happens if one or more emissions units operated under this permit is/are shut down permanently? . 6

13. Can I transfer this permit to a new owner or operator? ............................................................................... 6

14. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution 

nuisance"? ................................................................................................................................................. 7

15. What happens if a portion of this permit is determined to be invalid?.......................................................... 7

B. Facility-Wide Terms and Conditions................................................................................................................. 8

C. Emissions Unit Terms and Conditions............................................................................................................ 10

1. F001, Cooling Tower............................................................................................................................... 11

2. Emissions Unit Group - Combustion Trains: P001, P002, P003, P004, P005, P006................................ 13

Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 1 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Authorization

Facility ID: 1677105001

Application Number(s): M0000281

Permit Number: P0103955

Permit Description: Admin mod of P0103620 to clarify compliance method language

Permit Type: Administrative Modification

Permit Fee: $0.00

Issue Date: 11/24/2008

Effective Date: 11/24/2008

Expiration Date: 9/25/2013

Permit Evaluation Report (PER) Annual Date: Jan 1 - Dec 31, Due Feb 15

This document constitutes issuance to:

Norton Energy Storage L.L.C.

3700 Limestone Drive

Norton, OH 44203

of a Permit-to-Install and Operate for the emissions unit(s) identified on the following page. 

Ohio EPA District Office or local air agency responsible for processing and administering your permit:

Akron Regional Air Quality Management District

146 South High Street, Room 904

Akron, OH 44308

(330)375-2480

The above named entity is hereby granted this Permit-to-Install and Operate for the air contaminant source(s) 

(emissions unit(s)) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. 

Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or 

modified in accordance with the plans included in the application, the described emissions unit(s) will operate 

in compliance with applicable State and federal laws and regulations.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Chris Korleski

Director 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 2 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Authorization (continued)

Permit Number: P0103955

Permit Description: Admin mod of P0103620 to clarify compliance method language

Permits for the following emissions unit(s) or groups of emissions units are in this document as indicated 

below:

Emissions Unit ID: F001

Company Equipment ID: Cooling Tower

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P001

Company Equipment ID: Combustion Train #1

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P002

Company Equipment ID: Combustion Train #2

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P003

Company Equipment ID: Combustion Train #3

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P004

Company Equipment ID: Combustion Train #4

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P005

Company Equipment ID: Combustion Train #5

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P006

Company Equipment ID: Combustion Train #6

Superseded Permit Number:

General Permit Category and Type: Not Applicable
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 3 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

A. Standard Terms and Conditions
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 4 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

1. What does this permit-to-install and operate ("PTIO") allow me to do?

This permit allows you to install and operate the emissions unit(s) identified in this PTIO. You must 

install and operate the unit(s) in accordance with the application you submitted and all the terms and 

conditions contained in this PTIO, including emission limits and those terms that ensure compliance 

with the emission limits (for example, operating, recordkeeping and monitoring requirements). 

2. Who is responsible for complying with this permit?

The person identified on the "Authorization" page, above, is responsible for complying with this permit 

until the permit is revoked, terminated, or transferred. "Person" means a person, firm, corporation, 

association, or partnership. The words "you," "your," or "permittee" refer to the "person" identified on 

the "Authorization" page above.

The permit applies only to the emissions unit(s) identified in the permit. If you install or modify any other 

equipment that requires an air permit, you must apply for an additional PTIO(s) for these sources. 

3. What records must I keep under this permit?

You must keep all records required by this permit, including monitoring data, test results, strip-chart 

recordings, calibration data, maintenance records, and any other record required by this permit for five 

years from the date the record was created. You can keep these records electronically, provided they 

can be made available to Ohio EPA during an inspection at the facility. Failure to make requested 

records available to Ohio EPA upon request is a violation of this permit requirement. 

4. What are my permit fees and when do I pay them?

There are two fees associated with permitted air contaminant sources in Ohio:

 PTIO fee. This one-time fee is based on a fee schedule in accordance with Ohio Revised Code 

(ORC) section 3745.11, or based on a time and materials charge for permit application review 

and permit processing if required by the Director. 

You will be sent an invoice for this fee after you receive this PTIO and payment is due within 30 

days of the invoice date. You are required to pay the fee for this PTIO even if you do not install 

or modify your operations as authorized by this permit. 

 Annual emissions fee. Ohio EPA will assess a separate fee based on the total annual emissions 

from your facility. You self-report your emissions in accordance with Ohio Administrative Code 

(OAC) Chapter 3745-78. This fee assessed is based on a fee schedule in ORC section 3745.11 

and funds Ohio EPA’s permit compliance oversight activities. For facilities that are permitted as 

synthetic minor sources, the fee schedule is adjusted annually for inflation. Ohio EPA will notify 

you when it is time to report your emissions and to pay your annual emission fees.

5. When does my PTIO expire, and when do I need to submit my renewal application? 

This permit expires on the date identified at the beginning of this permit document (see "Authorization" 

page above) and you must submit a renewal application to renew the permit. Ohio EPA will send a 

renewal notice to you approximately six months prior to the expiration date of this permit. However, it is 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 5 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

very important that you submit a complete renewal permit application (postmarked prior to expiration of 

this permit) even if you do not receive the renewal notice.

If a complete renewal application is submitted before the expiration date, Ohio EPA considers this a 

timely application for purposes of ORC section 119.06, and you are authorized to continue operating 

the emissions unit(s) covered by this permit beyond the expiration date of this permit until final action is 

taken by Ohio EPA on the renewal application.

6. What happens to this permit if my project is delayed or I do not install or modify my source?

This PTIO expires 18 months after the issue date identified on the "Authorization" page above unless 

otherwise specified if you have not (1) started constructing the new or modified emission sources 

identified in this permit, or (2) entered into a binding contract to undertake such construction. This 

deadline can be extended by up to 12 months, provided you apply to Ohio EPA for this extension within 

a reasonable time before the 18-month period has ended and you can show good cause for any such 

extension.

7. What reports must I submit under this permit? 

An annual permit evaluation report (PER) is required in addition to any malfunction reporting required 

by OAC rule 3745-15-06 or other specific rule-based reporting requirement identified in this permit. 

Your PER due date is identified in the Authorization section of this permit. 

8. If I am required to obtain a Title V operating permit in the future, what happens to the operating 

provisions and PER obligations under this permit?

If you are required to obtain a Title V permit under OAC Chapter 3745-77 in the future, the permit-tooperate portion of this permit will be superseded by the issued Title V permit. From the effective date of 

the Title V permit forward, this PTIO will effectively become a PTI (permit-to-install) in accordance with 

OAC rule 3745-31-02(B). The following terms and conditions will no longer be applicable after issuance 

of the Title V permit: Section B, Term 1.b) and Section C, for each emissions unit, Term a)(2).

The PER requirements in this permit remain effective until the date the Title V permit is issued and is 

effective, and cease to apply after the effective date of the Title V permit. The final PER obligation will 

cover operations up to the effective date of the Title V permit and must be submitted on or before the 

submission deadline identified in this permit on the last day prior to the effective date of the Title V 

permit.

9. What are my obligations when I perform scheduled maintenance on air pollution control 

equipment?

You must perform scheduled maintenance of air pollution control equipment in accordance with OAC 

rule 3745-15-06(A). If scheduled maintenance requires shutting down or bypassing any air pollution 

control equipment, you must also shut down the emissions unit(s) served by the air pollution control 

equipment during maintenance, unless the conditions of OAC rule 3745-15-06(A)(3) are met. Any 

emissions that exceed permitted amount(s) under this permit (unless specifically exempted by rule) 

must be reported as deviations in the annual permit evaluation report (PER), including nonexempt 

excess emissions that occur during approved scheduled maintenance.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 6 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

10. Do I have to report malfunctions of emissions units or air pollution control equipment? If so, 

how must I report? 

If you have a reportable malfunction of any emissions unit(s) or any associated air pollution control 

system, you must report this to the Akron Regional Air Quality Management District in accordance with 

OAC rule 3745-15-06(B). Malfunctions that must be reported are those that result in emissions that 

exceed permitted emission levels. It is your responsibility to evaluate control equipment breakdowns 

and operational upsets to determine if a reportable malfunction has occurred. 

If you have a malfunction, but determine that it is not a reportable malfunction under OAC rule 3745-15-

06(B), it is recommended that you maintain records associated with control equipment breakdown or 

process upsets. Although it is not a requirement of this permit, Ohio EPA recommends that you 

maintain records for non-reportable malfunctions.

11. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are 

located?

Yes. Under Ohio law, the Director or his authorized representative may inspect the facility, conduct 

tests, examine records or reports to determine compliance with air pollution laws and regulations and 

the terms and conditions of this permit. You must provide, within a reasonable time, any information 

Ohio EPA requests either verbally or in writing. 

12. What happens if one or more emissions units operated under this permit is/are shut down 

permanently?

Ohio EPA can terminate the permit terms associated with any permanently shut down emissions unit. 

"Shut down" means the emissions unit has been physically removed from service or has been altered 

in such a way that it can no longer operate without a subsequent "modification" or "installation" as 

defined in OAC Chapter 3745-31.

You should notify Ohio EPA of any emissions unit that is permanently shut down by submitting a 

certification that identifies the date on which the emissions unit was permanently shut down. The 

certification must be submitted by an authorized official from the facility. You cannot continue to operate 

an emission unit once the certification has been submitted to Ohio EPA by the authorized official.

You must comply with all recordkeeping and reporting for any permanently shut down emissions unit in 

accordance with the provisions of the permit, regulations or laws that were enforceable during the 

period of operation, such as the requirement to submit a PER, air fee emission report, or malfunction 

report. You must also keep all records relating to any permanently shutdown emissions unit, generated 

while the emissions unit was in operation, for at least five years from the date the record was 

generated.

Again, you cannot resume operation of any emissions unit certified by the authorized official as being 

permanently shut down without first applying for and obtaining a permit pursuant to OAC Chapter 3745-

31.

13. Can I transfer this permit to a new owner or operator? 

You can transfer this permit to a new owner or operator. If you transfer the permit, you must follow the 

procedures in OAC Chapter 3745-31, including notifying Ohio EPA or the local air agency of the 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 7 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

change in ownership or operator. Any transferee of this permit must assume the responsibilities of the 

transferor permit holder.

14. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution 

nuisance"?

This permit and OAC rule 3745-15-07 prohibit operation of the air contaminant source(s) regulated 

under this permit in a manner that causes a nuisance. Ohio EPA can require additional controls or 

modification of the requirements of this permit through enforcement orders or judicial enforcement 

action if, upon investigation, Ohio EPA determines existing operations are causing a nuisance.

15. What happens if a portion of this permit is determined to be invalid? 

If a portion of this permit is determined to be invalid, the remainder of the terms and conditions remain 

valid and enforceable. The exception is where the enforceability of terms and conditions are dependent 

on the term or condition that was declared invalid.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 8 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

B. Facility-Wide Terms and Conditions
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 9 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

1. This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a 

permit-to-operate issued in accordance with ORC 3704.03(G).

a) For the purpose of a permit-to-install document, the facility-wide terms and conditions identified 

below are federally enforceable with the exception of those listed below which are enforceable 

under state law only.

(1) None.

b) For the purpose of a permit-to-operate document, the facility-wide terms and conditions 

identified below are enforceable under state law only with the exception of those listed below 

which are federally enforceable.

(1) None.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 10 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

C. Emissions Unit Terms and Conditions
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 11 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

1. F001, Cooling Tower

Operations, Property and/or Equipment Description: 

Cooling Tower – Induced draft mechanical wet cooling tower

a) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) 

and a permit-to-operate issued in accordance with ORC 3704.03(G).

(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions 

identified below are federally enforceable with the exception of those listed below which 

are enforceable under state law only.

a. None.

(2) For the purpose of a permit-to-operate document, the emissions unit terms and 

conditions identified below are enforceable under state law only with the exception of 

those listed below which are federally enforceable.

a. None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions 

unit along with the applicable rules and/or requirements and with the applicable 

emissions limitations and/or control measures. Emissions from each unit shall not 

exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

a. ORC 3704.03(T)(4) See b.2.a below.

b. OAC rule 3745-17-07(B) 20% opacity as a 3-minute average, 

except as provided by rule (fugitive 

emissions)

c. OAC rule 3745-17-08(B) See c.1 below.

(2) Additional Terms and Conditions

a. The Best Available Technology (BAT) requirements under OAC rule 3745-31-

05(A)(3) do not apply to the particulate emissions (PE) from this air contaminant 

source since the uncontrolled potential to emit for PE is less than ten tons per 

year.

c) Operational Restrictions

(1) The permittee shall employ mist eliminators designed for 0.001% drift from the cooling 

tower.

d) Monitoring and/or Recordkeeping Requirements

(1) None.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 12 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

e) Reporting Requirements

(1) Annual Permit Evaluation Report (PER) forms will be mailed to the permittee at the end 

of the reporting period specified in the Authorization section of this permit. The permittee 

shall submit the PER in the form and manner provided by the director by the due date 

identified in the Authorization section of this permit. The permit evaluation report shall 

cover a reporting period of no more than twelve-months for each air contaminant source 

identified in this permit.

f) Testing Requirements

(1) Compliance with the emission limitation(s) in Section b.I. of these terms and conditions 

shall be determined in accordance with the following method(s):

Emission Limitation

20% opacity as a 3-minute average, except as provided by rule (fugitive emissions)

Applicable Compliance Method

OAC rule 3745-17-03(B)(3)

g) Miscellaneous Requirements

(1) None.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 13 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

2. Emissions Unit Group - Combustion Trains: P001, P002, P003, P004, P005, P006

EU ID Operations, Property and/or Equipment Description

P001 Combustion Train #1 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

P002 Combustion Train #2 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

P003 Combustion Train #3 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

P004 Combustion Train #4 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

P005 Combustion Train #5 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

P006 Combustion Train #6 – 589MMBtu/hr Dresser Rand natural gas fired combustion turbine 

(134 MW) operating in simple cycle mode with recuperator controlled by catalytic oxidation, 

water injection, and selective catalytic reduction

a) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) 

and a permit-to-operate issued in accordance with ORC 3704.03(G).

(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions 

identified below are federally enforceable with the exception of those listed below which 

are enforceable under state law only.

a. Sections d.1 – d.4, and e.1

(2) For the purpose of a permit-to-operate document, the emissions unit terms and 

conditions identified below are enforceable under state law only with the exception of 

those listed below which are federally enforceable.

a. Sections b,c,d.5 – d.14, e.2 – e.9, f, and g

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions 

unit along with the applicable rules and/or requirements and with the applicable 

emissions limitations and/or control measures. Emissions from each unit shall not 

exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

a. OAC rule 3745-31-05(A)(3) The requirements of this rule also include 

compliance with the requirements or OAC 

rule 3745-103, 3745-31-05(D), 40 CFR 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 14 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

Part 60, Subpart KKKK, and 40 CFR Part 

75.

Nitrogen oxides (NOx) emissions shall 

not exceed 3.0 ppmvd at 15% oxygen 

and 7.18 lbs/hr.

Particulate emissions (PE) shall not 

exceed 0.0066 lb/MMbtu and 3.89 lbs/hr.

Sulfur dioxide (SO2) emissions shall not 

exceed 0.006 lb/MMbtu and 3.53 lbs/hr.

Carbon monoxide (CO) emissions shall 

not exceed 5.0 ppmvd at 15% oxygen 

and 7.28 lbs/hr.

Volatile organic compounds (VOC) 

emissions shall not exceed 2.2 lbs/hr.

Visible particulate emissions from any 

stack shall not exceed 10 percent opacity 

as a six-minute average.

Permittee shall employ catalytic oxidation 

(CO), water injection, and selective 

catalytic reduction (SCR).

b. OAC rule 3745-17-07(A) See section b.2.a below.

c. OAC rule 3745-17-11(B)(4) See section b.2.a below.

d. OAC rule 3745-18-06(F) See section b.2.a below.

e. OAC rule 3745-21-08(B) See section b.2.d below.

f. 40 CFR Part 60, Subpart KKKK NOx emissions shall not exceed 25ppm 

at 15%oxygen or 150 ng/J of useful 

output (1.2 lb/MWh) – See b.2.a below.

SO2 emissions shall not exceed 110 

nanograms ng/J (0.90 lb/MWh) gross 

output, or 

26 ng/J (0.060 lb/MMBtu) heat input

See sections b.2.e – b.2.l below.

g. 40 CFR Part 75 See section b.2.b below.

h. OAC rule 3745-103 See section b.2.b below.

i. OAC rule 3745-31-05(D) Maximum output of emissions units P001 

– P006 combined shall not exceed 

14.14E06 MMBtu per rolling 12-month 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 15 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

summation.

The tons per rolling 12-month period for

emissions units P001 – P006 combined 

(including startups/shutdowns) shall not 

exceed:

NOx – 93.67

CO – 90.36

VOC – 26.40

PE – 46.65

SO2 – 42.41 

(2) Additional Terms and Conditions

a. The emissions limitation specified by this rule is less stringent than the emission 

limitation established pursuant to OAC rule 3745-31-05(A)(3).

b. If the permittee is subject to the requirements of 40 CFR Part 75 concerning acid 

rain, the permittee shall ensure that any effected emissions unit complies with 

those requirements. Emissions exceeding any allowances that are lawfully held 

under Title IV of the Act, or any regulations adopted thereunder, are prohibited.

c. The maximum annual output for this emissions units P001 – P006 combined

shall not exceed 14.14E06 MMBtu, based upon a rolling, 12-month summation of 

the outputs.

To ensure enforceability during the first 12 calendar months of operation or the 

first 12 calendar months following the issuance of this permit, the permittee shall 

not exceed the output levels specified in the following table:

Maximum Allowable

Month(s) Cumulative Output

 1 2.36E06

 1-2 2.36E06

 1-3 4.72E06

 1-4 4.72E06

 1-5 7.08E06

 1-6 7.08E06

 1-7 9.44E06

 1-8 9.44E06

 1-9 11.80E06

 1-10 11.80E06

 1-11 14.14E06

1-12 14.14E06

After the first 12 calendar months of operation or the first 12 calendar months 

following the issuance of this permit, compliance with the annual combined 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 16 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

output limitation shall be based upon a rolling, 12-month summation of the 

combined outputs.

d. The permitee has satisfied the "best available control techniques and operating 

practices" required pursuant to OAC rule 3745- 21-08(B) by committing to comply 

with the best available technology (BAT) requirements established pursuant to 

OAC rule 3745-31-05(A)(3) in this permit to install. The design of the emissions 

unit and the technology associated with the current operating practices satisfy 

the BAT requirements.

On November 5, 2002, OAC rule 3745-21-08 was revised to delete paragraph 

(B); therefore, paragraph (B) is no longer part of the State regulations. This rule 

revision was submitted to the U.S. EPA as a revision to Ohio's State 

Implementation Plant (SIP). Until the U.S. EPA approves the revision to OAC 

rule 3745-21-08, the requirement to satisfy the "best available control techniques 

and operating practices" still exists as part of the federally-approved SIP for Ohio. 

e. § 60.4340 How do I demonstrate continuous compliance for NOX if I do not use 

water or steam injection?

Permitte will use continuous emission monitoring, as follows:

i. Install, certify, maintain, and operate a continuous emission monitoring 

system (CEMS) consisting of a NOX monitor and a diluent gas (oxygen 

(O2) or carbon dioxide (CO2)) monitor, to determine the hourly NOX

emission rate in parts per million (ppm) or pounds per million British 

thermal units (lb/MMBtu); and

ii. Install, calibrate, maintain, and operate a fuel flow meter to continuously 

measure the heat input to the affected unit;.

f. § 60.4345 What are the requirements for the continuous emission monitoring 

system equipment, if I choose to use this option?

For the NOXCEMS :

i. Installed and certified according to appendix A of part 75 of this chapter. 

The relative accuracy test audit (RATA) of the CEMS shall be performed 

on a lb/MMBtu basis.

ii. As specified in §60.13(e)(2), during each full unit operating hour, both the 

NOX monitor and the diluent monitor must complete a minimum of one 

cycle of operation (sampling, analyzing, and data recording) for each 15-

minute quadrant of the hour, to validate the hour. For partial unit 

operating hours, at least one valid data point must be obtained with each 

monitor for each quadrant of the hour in which the unit operates. For unit 

operating hours in which required quality assurance and maintenance 

activities are performed on the CEMS, a minimum of two valid data points 

(one in each of two quadrants) are required for each monitor to validate 

the NOX emission rate for the hour.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 17 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

iii. Fuel flow meters that meet the installation, certification, and quality 

assurance requirements of appendix D to part 75 of this chapter are 

acceptable for use under this subpart.

iv. The owner or operator shall implement the QA program and plan 

described in section 1 of appendix B to part 75 of this chapter.

g. § 60.4350 How do I use data from the continuous emission monitoring 

equipment to identify excess emissions?

For purposes of identifying excess emissions:

i. All CEMS data must be reduced to hourly averages as specified in 

§60.13(h).

ii. For each unit operating hour in which a valid hourly average, as 

described in §60.4345(b), is obtained for both NOX and diluent monitors, 

the data acquisition and handling system must calculate and record the 

hourly NOX emission rate in units of ppm or lb/MMBtu, using the 

appropriate equation from method 19 in appendix A of this part. For any 

hour in which the hourly average O2concentration exceeds 19.0 percent 

O2(or the hourly average CO2concentration is less than 1.0 percent CO2), 

a diluent cap value of 19.0 percent O2or 1.0 percent CO2(as applicable) 

may be used in the emission calculations.

iii. Quality assured data per Part 75 from the CEMS shall be used to identify 

excess emissions under this subpart. Periods where the missing data 

substitution procedures in subpart D of part 75 are applied are to be 

reported as monitor downtime in the excess emissions and monitoring 

performance report required under §60.7(c).

iv. Required fuel flow rate must be reduced to hourly averages.

v. Calculate the hourly average NOX emission rates, in units of the emission 

standards under §60.4320, using ppm 

vi. Calculated hourly average emission rates from paragraph (f) of this 

section to assess excess emissions on a 4-hour rolling average basis, as 

described in §60.4380(b)(1).

h. § 60.4365 How can I be exempted from monitoring the total sulfur content of the 

fuel?

Monitor the total sulfur content of the fuel combusted in the turbine by a current, 

valid purchase contract, tariff sheet or transportation contract for the fuel, 

specifying that the maximum total sulfur content for natural gas use in continental 

areas is 20 grains of sulfur or less per 100 standard cubic feet .

i. § 60.4375 What reports must I submit?

i. For each affected unit required to continuously monitor parameters or 

emissions, or to periodically determine the fuel sulfur content under this 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 18 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

subpart, you must submit reports of excess emissions and monitor 

downtime, in accordance with §60.7(c). Excess emissions must be 

reported for all periods of unit operation, including start-up, shutdown, and 

malfunction.

ii. For each affected unit that performs annual performance tests in 

accordance with §60.4340(a), you must submit a written report of the 

results of each performance test before the close of business on the 60th 

day following the completion of the performance test.

j. § 60.4380 How are excess emissions and monitor downtime defined for NOX?

For the purpose of reports required under §60.7(c), periods of excess emissions 

and monitor downtime that must be reported are defined as follows:

For turbines using continuous emission monitoring, as described in §§60.4335(b) 

and 60.4345:

i. An excess emissions is any unit operating period in which the 4-hour or 

30-day rolling average NOX emission rate exceeds the applicable 

emission limit in §60.4320. For the purposes of this subpart, a “4-hour 

rolling average NOX emission rate” is the arithmetic average of the 

average NOX emission rate in ppm measured by the continuous emission 

monitoring equipment for a given hour and the three unit operating hour 

average NOX emission rates immediately preceding that unit operating 

hour. Calculate the rolling average if a valid NOX emission rate is obtained 

for at least 3 of the 4 hours. For the purposes of this subpart, a “30-day 

rolling average NOX emission rate” is the arithmetic average of all hourly 

NOX emission data in ppm measured by the continuous emission 

monitoring equipment for a given day and the twenty-nine unit operating 

days immediately preceding that unit operating day. A new 30-day 

average is calculated each unit operating day as the average of all hourly 

NOX emissions rates for the preceding 30 unit operating days if a valid 

NOX emission rate is obtained for at least 75 percent of all operating 

hours.

ii. A period of monitor downtime is any unit operating hour in which the data 

for any of the following parameters are either missing or invalid: NOX

concentration, CO2 or O2concentration, fuel flow rate, steam flow rate, 

steam temperature, steam pressure, or megawatts. The steam flow rate, 

steam temperature, and steam pressure are only required if you will use 

this information for compliance purposes.

k. § 60.4395 When must I submit my reports?

All reports required under §60.7(c) must be postmarked by the 30th day following 

the end of each 6-month period.

l. § 60.4405 How do I perform the initial performance test if I have chosen to 

install a NOX-diluent CEMS?
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 19 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Then the initial performance test required under §60.8 may be performed in the 

following alternative manner:

i. Perform a minimum of nine RATA reference method runs, with a 

minimum time per run of 21 minutes, at a single load level, within plus or 

minus 25 percent of 100 percent of peak load. The ambient temperature 

must be greater than 0 °F during the RATA runs.

ii. For each RATA run, concurrently measure the heat input to the unit using 

a fuel flow meter (or flow meters) and measure the electrical and thermal 

output from the unit.

iii. Use the test data both to demonstrate compliance with the applicable 

NOX emission limit under §60.4320 and to provide the required reference 

method data for the RATA of the CEMS described under §60.4335.

iv. Compliance with the applicable emission limit in §60.4320 is achieved if 

the arithmetic average of all of the NOX emission rates for the RATA runs, 

expressed in units of ppm or lb/MWh, does not exceed the emission limit.

m. Each continuous NOx monitoring system shall be certified to meet the 

requirements of 40 CFR Part 60, Appendix B, Performance Specifications 2 and 

6. At least 45 days before commencing certification testing of the continuous 

NOx monitoring system(s), the permittee shall develop and maintain a written 

quality assurance/quality control plan designed to ensure continuous valid and 

representative readings of NOx emissions from the continuous monitor(s), in 

units of the applicable standard(s). The fuel flow monitor/meter shall be 

maintained as required in Part 75, Appendix D. Except as allowed below, the 

plan shall follow the requirements of 40 CFR Part 60, Appendix F and 40 CFR 

Part 75, Appendix B. The quality assurance/quality control plan and a logbook 

dedicated to the continuous NOx monitoring system must be kept on site and 

available for inspection during regular office hours.

The plan shall include the requirement to conduct relative accuracy test audits for 

the continuous NOx monitoring system in accordance with the frequencies 

required pursuant to 40 CFR Part 60 and 40 CFR Part 75; or may follow relative 

accuracy test audit frequency requirements for monitoring systems subject to 40 

CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either 

case, results shall be recorded and reported in units of the applicable standard(s) 

in accordance with 40 CFR Part 60.

The plan shall include the requirement to conduct quarterly cylinder gas audits or 

relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks 

pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 

CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or 

relative accuracy audits required per 40 CFR Part 60.

n. The continuous emission monitoring system consists of all the equipment used to 

acquire data to provide a record of emissions and includes the sample extraction 

and transport hardware, sample conditioning hardware, analyzers, and data 

recording/processing hardware and software.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 20 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

o. Each continuous carbon monoxide (CO) monitoring system shall be certified to 

meet the requirements of 40 CFR Part 60, Appendix B, Performance 

Specifications 4 or 4a and 6. At least 45 days before commencing certification 

testing of the continuous CO monitoring system(s), the permittee shall develop 

and maintain a written quality assurance/quality control plan designed to ensure 

continuous valid and representative readings of CO emissions from the 

continuous monitor(s), in units of the applicable standard(s). The fuel flow 

monitor/meter shall be maintained as required in Part 75, Appendix D. Except as 

allowed below, the plan shall follow the requirements of 40 CFR Part 60, 

Appendix F. The quality assurance/quality control plan and a logbook dedicated 

to the continuous CO monitoring system must be kept on site and available for 

inspection during regular office hours.

The plan shall include the requirement to conduct relative accuracy test audits for 

the continuous CO monitoring system in accordance with the frequencies 

required for monitoring systems subject to 40 CFR 60, or may follow relative 

accuracy test audit frequency requirements for monitoring systems subject to 40 

CFR 75, Appendix B. In either case, results shall be recorded and reported in 

units of the applicable standard(s) in accordance with 40 CFR Part 60.

The plan shall include the requirement to conduct quarterly cylinder gas audits or 

relative accuracy audits as required in 40 CFR Part 60; however, the quarterly 

cylinder gas audit and relative accuracy audit frequency requirements may be 

adjusted to coincide with linearity checks completed for continuous emissions 

monitoring systems subject to 40 CFR Part 75, Appendix B requirements.

p. The continuous emission monitoring system consists of all the equipment used to 

acquire data to provide a record of emissions and includes the sample extraction 

and transport hardware, sample conditioning hardware, analyzers, and data 

recording/processing hardware and software.

c) Operational Restrictions

(1) The permittee shall burn only natural gas in this emissions unit. The maximum sulfur 

content of the natural gas shall not exceed 2.0 grains per 100 standard cubic feet.

d) Monitoring and/or Recordkeeping Requirements

(1) The federally enforceable permit-to-install and operate (FEPTIO) application for 

this/these emissions unit(s) P001 – P006, and F001 was evaluated based on the 

actual materials and the design parameters of the emissions unit's(s’) exhaust 

system, as specified by the permittee. The AToxic Air Contaminant Statute@, ORC 

3704.03(F), was applied to this/these emissions unit(s) for each toxic air contaminant 

listed in OAC rule 3745-114-01, using data from the permit application; and modeling 

was performed for each toxic air contaminant(s) emitted at over one ton per year using 

an air dispersion model such as SCREEN3, AERMOD, or ISCST3, or other Ohio EPA 

approved model. The predicted 1-hour maximum ground-level concentration result(s) 

from the approved air dispersion model, was compared to the Maximum Acceptable 

Ground-Level Concentration (MAGLC), calculated as described in the Ohio EPA 

guidance document entitled AReview of New Sources of Air Toxic Emissions, Option A@, 

as follows:
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 21 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

a. the exposure limit, expressed as a time-weighted average concentration for a 

conventional 8-hour workday and a 40-hour workweek, for each toxic 

compound(s) emitted from the emissions unit(s), (as determined from the raw 

materials processed and/or coatings or other materials applied) has been 

documented from one of the following sources and in the following order of 

preference (TLV was and shall be used, if the chemical is listed):

i. threshold limit value (TLV) from the American Conference of 

Governmental Industrial Hygienists= (ACGIH) AThreshold Limit Values for 

Chemical Substances and Physical Agents Biological Exposure Indices@; 

or 

ii. STEL (short term exposure limit) or the ceiling value from the American 

Conference of Governmental Industrial Hygienists= (ACGIH) AThreshold 

Limit Values for Chemical Substances and Physical Agents Biological 

Exposure Indices@; the STEL or ceiling value is multiplied by 0.737 to 

convert the 15-minute exposure limit to an equivalent 8-hour TLV.

b. The TLV is divided by ten to adjust the standard from the working population to 

the general public (TLV/10).

c. This standard is/was then adjusted to account for the duration of the exposure or 

the operating hours of the emissions unit(s), i.e., AX@ hours per day and AY@

days per week, from that of 8 hours per day and 5 days per week. The resulting 

calculation was (and shall be) used to determine the Maximum Acceptable 

Ground-Level Concentration (MAGLC):

TLV/10 x 8/X x 5/Y = 4 TLV/XY = MAGLC

d. The following summarizes the results of dispersion modeling for the significant 

toxic contaminants (emitted at 1 or more tons/year) or Aworst case@ toxic 

contaminant(s):

Toxic Contaminant: formaldehyde

TLV (mg/m3): Maximum Hourly Emission Rate (lbs/hr): 2.51

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 4.8

MAGLC (ug/m3): 6.5

Toxic Contaminant: sulfuric acid mist

TLV (mg/m3): 1000

Maximum Hourly Emission Rate (lbs/hr): 2.12

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 4.1

MAGLC (ug/m3): 23.8
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 22 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Toxic Contaminant: ammonia 

TLV (mg/m3): 17,413

Maximum Hourly Emission Rate (lbs/hr): 60.0

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 115.8

MAGLC (ug/m3): 408

The permittee, has demonstrated that emissions of formaldehyde, sulfuric acid mist, and 

ammonia, from emissions unit(s) P001 – P006, is calculated to be less than eighty per 

cent of the maximum acceptable ground level concentration (MAGLC); any new raw 

material or processing agent shall not be applied without evaluating each component 

toxic air contaminant in accordance with the AToxic Air Contaminant Statute@, ORC 

3704.03(F).

(2) Prior to making any physical changes to or changes in the method of operation of the 

emissions unit(s), that could impact the parameters or values that were used in the 

predicted 1-hour maximum ground-level concentration@, the permittee shall re-model the 

change(s) to demonstrate that the MAGLC has not been exceeded. Changes that can 

affect the parameters/values used in determining the 1-hour maximum ground-level 

concentration include, but are not limited to, the following:

a. changes in the composition of the materials used or the use of new materials, 

that would result in the emission of a new toxic air contaminant with a lower 

Threshold Limit Value (TLV) than the lowest TLV previously modeled;

b. changes in the composition of the materials, or use of new materials, that would 

result in an increase in emissions of any toxic air contaminant listed in OAC rule 

3745-114-01, that was modeled from the initial (or last) application; and

c. physical changes to the emissions unit(s) or its/their exhaust parameters (e.g., 

increased/ decreased exhaust flow, changes in stack height, changes in stack 

diameter, etc.).

If the permittee determines that the AToxic Air Contaminant Statute@ will be satisfied for 

the above changes, the Ohio EPA will not consider the change(s) to be a "modification" 

under OAC rule 3745-31-01 solely due to a non-restrictive change to a parameter or 

process operation, where compliance with the AToxic Air Contaminant Statute@, ORC 

3704.03(F), has been documented. If the change(s) meet(s) the definition of a 

“modification”, the permittee shall apply for and obtain a final PTI, PTIO, or 

FEPTIO (as applicable) prior to the change. The Director may consider any 

significant departure from the operations of the emissions unit, described in the permit

application, as a modification that results in greater emissions than the emissions rate 

modeled to determine the ground level concentration; and he/she may require the 

permittee to submit a permit application for the increased emissions.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 23 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

(3) The permittee shall collect, record, and retain the following information for each toxic 

evaluation conducted to determine compliance with the AToxic Air Contaminant 

Statute@, ORC 3704.03(F):

a. a description of the parameters/values used in each compliance demonstration 

and the parameters or values changed for any re-evaluation of the toxic(s) 

modeled (the composition of materials, new toxic contaminants emitted, change 

in stack/exhaust parameters, etc.);

b. the Maximum Acceptable Ground-Level Concentration (MAGLC) for each 

significant toxic contaminant or worst-case contaminant, calculated in 

accordance with the AToxic Air Contaminant Statute@, ORC 3704.03(F);

c. a copy of the computer model run(s), that established the predicted 1-hour 

maximum ground-level concentration that demonstrated the emissions unit(s) to 

be in compliance with the AToxic Air Contaminant Statute@, ORC 3704.03(F), 

initially and for each change that requires re-evaluation of the toxic air 

contaminant emissions; and

d. the documentation of the initial evaluation of compliance with the AToxic Air 

Contaminant Statute@, ORC 3704.03(F), and documentation of any 

determination that was conducted to re-evaluate compliance due to a change 

made to the emissions unit(s) or the materials applied.

(4) The permittee shall maintain a record of any change made to a parameter or value used 

in the dispersion model, used to demonstrate compliance with the AToxic Air 

Contaminant Statute@, ORC 3704.03(F), through the predicted 1-hour maximum 

ground-level concentration. The record shall include the date and reason(s) for the 

change and if the change would increase the ground-level concentration.

(5) The permittee shall maintain daily records of the following information:

a. the operating hours for each day; and

b. beginning after the first 12 calendar months of operation or the first 12 calendar 

months following the issuance of this permit, the rolling,12-month summation of 

the combined operating hours (P001 – P006).

Also, during the first 12 calendar months of operation or the first 12 calendar months 

following the issuance of this permit, the permittee shall record the cumulative combined 

operating hours (P001 – P006) for each calendar month.

(6) The permittee shall maintain monthly records of the natural gas usage rate, in standard 

cubic feet.

(7) The permittee shall monitor the sulfur content and gross caloric value of the fuel being 

fired in the combustion turbine. Fuel sampling and analysis shall be conducted 

according to the procedures and at the frequency specified by 40 CFR Part 75, 

Appendix F.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 24 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

(8) The permittee shall maintain records of the following information for each emissions unit:

a. Number of startups, and the duration of each startup.

b. Number of shutdowns, and the duration of each shutdown.

(9) Prior to the installation of the continuous NOx monitoring system, the permittee shall 

submit information detailing the proposed location of the sampling site in accordance 

with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 

2. The Ohio EPA, Central Office shall approve the proposed sampling site and certify 

that the continuous NOx monitoring system meets the requirements of Performance 

Specification 2 and the accuracy requirements of Performance Specification 6.

Following installation, the permittee shall document that the fuel flow monitor/meter 

meets 40 CFR 75 certification requirements prior to the performance specification test, 

and shall demonstrate how the pound per hour emissions of NOx is being calculated 

stoichiometrically. The U.S. EPA shall certify that the continuous NOx monitoring system 

meets the requirements under 40 CFR Part 75, which may be approved through the 

recommendation for certification by Ohio EPA to U.S. EPA. Once received, the 

letter(s)/document(s) of certification under Part 60 and certification or recommendation 

for certification under Part 75 shall be maintain on-site and made available to the 

Director (the appropriate Ohio EPA District Office or local air agency) upon request.

Each continuous monitoring system consists of all the equipment used to acquire and 

record data in units of all applicable standard(s), and includes the sample extraction and 

transport hardware, sample conditioning hardware, analyzers, and data processing 

hardware and software.

(10) The permittee shall install, operate, and maintain equipment to continuously monitor and 

record NOx emissions from this emissions unit in units of the applicable standard(s). 

The continuous monitoring and recording equipment shall comply with the requirements 

specified in 40 CFR Part 60 and 40 CFR Part 75.

The permittee shall maintain records of data obtained by the continuous NOx monitoring 

system including, but not limited to:

a. emissions of NOx in parts per million on an instantaneous (one-minute) basis;

b. emissions of NOx in pounds per 3-hour average and in all units of the applicable 

standard(s) in the appropriate averaging period;

c. results of quarterly cylinder gas audits or linearity checks;

d. results of daily zero/span calibration checks and the magnitude of manual 

calibration adjustments;

e. results of required relative accuracy test audit(s), including results in units of the 

applicable standard(s);

f. hours of operation of the emissions unit, continuous NOx monitoring system, and 

control equipment;
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 25 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

g. the date, time, and hours of operation of the emissions unit without the control 

equipment and/or the continuous NOx monitoring system;

h. h. malfunction of the control equipment and/or the continuous NOx

monitoring system; as well as,

i. the reason (if known) and the corrective actions taken (if any) for each such 

event in (g) and (h).

(11) The permittee may operate and maintain equipment to continuously monitor and record 

the fuel flow rate in order to stoichiometrically calculate emissions of NOx, in pounds per 

hour, as an alternative to conducting Specification 6. Fuel heat content values for each 

fuel burned, as applied in the stoichiometric calculations, shall also be recorded. The 

permittee shall maintain records of data obtained by the fuel flow monitor/meter, 

including the dates and results of each calibration check and the magnitude of 

calibration adjustments; periods of downtime and malfunction of the fuel flow 

monitor/meter; as well as, the reason (if known) and the corrective actions taken (if any) 

for each such event.

(12) Prior to the installation of the continuous carbon monoxide (CO) monitoring system, the 

permittee shall submit information detailing the proposed location of the sampling site in 

accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance 

Specification 4 or 4a (as appropriate). The Ohio EPA, Central Office shall approve the 

proposed sampling site and certify that the continuous CO monitoring system meets the 

requirements of Performance Specification 4 or 4a and the accuracy requirements of 

Performance Specification 6.

Following installation, the permittee shall document that the fuel flow monitor/meter 

meets 40 CFR 75 certification requirements prior to the performance specification test, 

and shall demonstrate how the pound per hour emissions of CO is being calculated 

stoichiometrically. Once received, the letter(s)/document(s) of certification shall be 

maintained on-site and shall be made available to the Director (the appropriate Ohio 

EPA District Office or local air agency) upon request.

Each continuous monitoring system consists of all the equipment used to acquire and 

record data in units of all applicable standard(s), and includes the sample extraction and 

transport hardware, sample conditioning hardware, analyzers, and data processing 

hardware and software.

(13) The permittee shall operate and maintain equipment to continuously monitor and record 

CO emissions from this emissions unit in units of the applicable standard(s). The 

continuous monitoring and recording equipment shall comply with the requirements 

specified in 40 CFR Parts 60.

The permittee shall maintain records of data obtained by the continuous CO monitoring 

system including, but not limited to:

a. emissions of CO in parts per million on an instantaneous (one-minute) basis;

b. emissions of CO in pounds per 3-hour average and in all units of the applicable 

standard(s) in the appropriate averaging period;
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 26 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

c. results of quarterly cylinder gas audits;

d. results of daily zero/span calibration checks and the magnitude of manual 

calibration adjustments;

e. results of required relative accuracy test audit(s), including results in units of the 

applicable standard(s);

f. hours of operation of the emissions unit, continuous CO monitoring system, and 

control equipment;

g. the date, time, and hours of operation of the emissions unit without the control 

equipment and/or the continuous CO monitoring system;

h. the date, time, and hours of operation of the emissions unit during any 

malfunction of the control equipment and/or the continuous CO monitoring 

system; as well as,

i. the reason (if known) and the corrective actions taken (if any) for each such 

event in (g) and (h).

(14) The permittee may operate and maintain equipment to continuously monitor and record 

the fuel flow rate in order to stoichiometrically calculate emissions of CO in pounds per 

hour, as an alternative to conducting Specification 6. Fuel heat content values for each 

fuel burned, as applied in the stoichiometric calculations, shall also be recorded. The 

permittee shall maintain records of data obtained by the fuel flow monitor/meter, 

including the dates and results of each calibration check and the magnitude of 

calibration adjustments; periods of downtime and malfunction of the fuel flow 

monitor/meter; as well as, the reason (if known) and the corrective actions taken (if any) 

for each such event.

e) Reporting Requirements

The permittee shall submit annual reports to the appropriate Ohio EPA District Office or 

local air agency, documenting any changes made to a parameter or value used in the 

dispersion model, that was used to demonstrate compliance with the AToxic Air 

Contaminant Statute@, ORC 3704.03(F), through the predicted 1-hour maximum 

ground-level concentration. If no changes to the emissions unit(s) or the exhaust stack 

have been made, then the report shall include a statement to this effect. This report 

shall be postmarked or delivered no later than January 31 following the end of each 

calendar year.

(1) The permittee shall submit quarterly deviation (excursion) reports that identify:

a. all deviations (excursions) of the following emission limitations, operational 

restrictions and/or control device operating parameter limitations that restrict the 

Potential to Emit (PTE) of any regulated air pollutant and have been detected by 

the monitoring, record keeping and/or testing requirements in this permit:

all exceedances of the rolling, 12-month limitation on the combined hours of 

operation (P001 – P006); and for the first 12 calendar months of operation or the 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 27 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

first 12 calendar months following the issuance of this permit, all exceedances of 

the maximum allowable cumulative combined hours of operation (P001 – P006). 

b. the probable cause of each deviation (excursion);

c. any corrective actions that were taken to remedy the deviations (excursions) or 

prevent future deviations (excursions); and

d. the magnitude and duration of each deviation (excursion).

If no deviations (excursions) occurred during a calendar quarter, the permittee shall 

submit a report that states that no deviations (excursions) occurred during the quarter.

The quarterly reports shall be submitted (postmarked) each year by the thirty-first of 

January (covering October to December), the thirtieth of April (covering January to 

March), the thirty-first of July (covering April to June), and the thirty-first of October 

(covering July to September), unless an alternative schedule has been established and 

approved by the director (the appropriate district office or local air agency).

(2) Annual Permit Evaluation Report (PER) forms will be mailed to the permittee at the end 

of the reporting period specified in the Authorization section of this permit. The permittee 

shall submit the PER in the form and manner provided by the director by the due date 

identified in the Authorization section of this permit. The permit evaluation report shall 

cover a reporting period of no more than twelve-months for each air contaminant source 

identified in this permit.

(3) This emissions unit is subject to the applicable provisions of Subpart KKKK of the New 

Source Performance Standards (NSPS) as promulgated by the United States 

Environmental Protection Agency, 40 CFR Part 60. The application and enforcement of 

these standards are delegated to the Ohio EPA. The requirements of 40 CFR Part 60 

are also federally enforceable.

Pursuant to 40 CFR Part 60.7, the permittee is hereby advised of the requirement to 

report the following at the appropriate times:

a. construction date (no later than 30 days after such date);

 b. anticipated start-up date (not more than 60 days or less than 30 days prior to 

such date);

c. actual start-up date (within 15 days after such date); and,

d. date of performance testing (if required, at least 30 days prior to testing).

Reports are to be sent to:

Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 28 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

(4) The permittee shall comply with the following quarterly reporting requirements for the 

emissions unit and its continuous NOx monitoring system:

a. Pursuant to the monitoring, record keeping, and reporting requirements for

continuous monitoring systems contained in 40 CFR 60.7 and 60.13(h) and the 

requirements established in this permit, the permittee shall submit reports within 

30 days following the end of each calendar quarter to the appropriate Ohio EPA 

District Office or local air agency, documenting all instances of NOx emissions in 

excess of any applicable limit specified in this permit, 40 CFR Part 60, 40 CFR 

Parts 75 and 76, OAC Chapters 3745-14 and 3745-23, and any other applicable 

rules or regulations. The report shall document the date, commencement and 

completion times, duration, and magnitude of each exceedance, as well as the 

reason (if known) and the corrective actions taken (if any) for each exceedance. 

Excess emissions shall be reported in units of the applicable standard(s).

b. These quarterly reports shall be submitted by January 30, April 30, July 30, and 

October 30 of each year and shall include the following:

i. the facility name and address;

ii. the manufacturer and model number of the continuous NOx and other 

associated monitors;

iii. a description of any change in the equipment that comprises the 

continuous emission monitoring system (CEMS), including any change to 

the hardware, changes to the software that may affect CEMS readings, 

and/or changes in the location of the CEMS sample probe;

iv. the excess emissions report (EER)*, i.e., a summary of any exceedances 

during the calendar quarter, as specified above;

v. the total NOx emissions for the calendar quarter (tons);

vi. the total operating time (hours) of the emissions unit;

vii. the total operating time of the continuous NOx monitoring system while 

the emissions unit was in operation;

viii. results and date of quarterly cylinder gas audits or linearity checks;

ix. unless previously submitted, results and date of the relative accuracy test 

audit(s), including results in units of the applicable standard(s), (during 

appropriate quarter(s));
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 29 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

x. unless previously submitted, the results of any relative accuracy test audit 

showing the continuous NOx monitor out-of-control and the compliant 

results following any corrective actions;

xi. the date, time, and duration of any/each malfunction** of the continuous

NOx monitoring system, emissions unit, and/or control equipment;

xii. the date, time, and duration of any downtime** of the continuous NOx

monitoring system and/or control equipment while the emissions unit was 

in operation; and

xiii. the reason (if known) and the corrective actions taken (if any) for each 

event in (b)(xi) and (xii).

Each report shall address the operations conducted and data obtained during the 

previous calendar quarter. Data substitution procedures from 40 CFR 75 are not to be 

used for showing compliance with the short term OAC 3745-31-05(A)(3) rule-based or 

NSPS-based limitation(s) in this permit.

* where no excess emissions have occurred or the continuous monitoring system(s) 

has/have not been inoperative, repaired, or adjusted during the calendar quarter, such 

information shall be documented in the EER quarterly report

** each downtime and malfunction event shall be reported regardless if there is an 

exceedance of any applicable limit

(5) If using the fuel flow rate to stoichiometrically calculate the pound per hour emissions of 

NOx, in place of Specification 6 requirements, the permittee shall submit quarterly 

reports, to the appropriate Ohio EPA District Office or local air agency, that document 

the date, time, and duration of each malfunction and/or period of downtime of the 

continuous fuel flow monitoring system, while the emissions unit was in operation, and 

the reason (if known) and the corrective actions taken (if any) for each such event. If 

there was no downtime or malfunction of the continuous fuel flow monitoring system 

during any calendar quarter, the report shall be submitted so stating it. These quarterly 

reports shall be submitted by January 30, April 30, July 30, and October 30 of each year.

(6) The permittee shall collect, record, and maintain measurements, data, records, and 

reports required per 40 CFR Part 75; and shall submit certification, recertification, 

notifications, applications, monitoring plans, petitions for alternative monitoring systems, 

electronic quarterly reports, and any other pertinent record and/or report to the 

Administrator (U.S. EPA), as required by this Part.

(7) The permittee shall comply with the following quarterly reporting requirements for the 

emissions unit and its continuous CO monitoring system:

a. Pursuant to the monitoring, record keeping, and reporting requirements for

continuous monitoring systems contained in 40 CFR 60.7 and 60.13(h) and the 

requirements established in this permit, the permittee shall submit reports within 

30 days following the end of each calendar quarter to the appropriate Ohio EPA 

District Office or local air agency, documenting all instances of CO emissions in 

excess of any applicable limit specified in this permit, 40 CFR Part 60, OAC 

Chapter 3745-21, and any other applicable rules or regulations. The report shall 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 30 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

document the date, commencement and completion times, duration, and 

magnitude of each exceedance, as well as, the reason (if known) and the 

corrective actions taken (if any) for each exceedance. Excess emissions shall be 

reported in units of the applicable standard(s).

b. These quarterly reports shall be submitted by January 30, April 30, July 30, and 

October 30 of each year and shall include the following:

i. the facility name and address;

ii. the manufacturer and model number of the continuous CO and other 

associated monitors;

iii. a description of any change in the equipment that comprises the 

continuous emission monitoring system (CEMS), including any change to 

the hardware, changes to the software that may affect CEMS readings, 

and/or changes in the location of the CEMS sample probe;

iv. the excess emissions report (EER)*, i.e., a summary of any exceedances 

during the calendar quarter, as specified above;

v. the total CO emissions for the calendar quarter (tons);

vi. the total operating time (hours) of the emissions unit;

vii. the total operating time of the continuous CO monitoring system while the 

emissions unit was in operation;

viii. results and dates of quarterly cylinder gas audits;

ix. unless previously submitted, results and dates of the relative accuracy 

test audit(s), including results in units of the applicable standard(s), 

(during appropriate quarter(s));

x. unless previously submitted, the results of any relative accuracy test audit 

showing the continuous CO monitor out-of-control and the compliant 

results following any corrective actions;

xi. the date, time, and duration of any/each malfunction** of the continuous 

CO monitoring system, emissions unit, and/or control equipment;

xii. the date, time, and duration of any downtime** of the continuous CO 

monitoring system and/or control equipment while the emissions unit was 

in operation; and

xiii. the reason (if known) and the corrective actions taken (if any) for each 

event in (b)(xi) and (xii).

Each report shall address the operations conducted and data obtained during the 

previous calendar quarter. Data substitution procedures from 40 CFR 75 are not to be 

used for showing compliance with the short term OAC 3745-31-05(A)(3) rule-based or 

NSPS-based limitation(s) in this permit.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 31 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

* where no excess emissions have occurred or the continuous monitoring system(s) 

has/have not been inoperative, repaired, or adjusted during the calendar quarter, such 

information shall be documented in the EER quarterly report

** each downtime and malfunction event shall be reported regardless if there is an 

exceedance of any applicable limit

(8) If using the fuel flow rate to stoichiometrically calculate the pound per hour emissions of 

CO, in place of Specification 6 requirements, the permittee shall submit quarterly 

reports, to the appropriate Ohio EPA District Office or local air agency, that document 

the date, time, and duration of each malfunction and/or period of downtime of the 

continuous fuel flow monitoring system, while the emissions unit was in operation, and 

the reason (if known) and the corrective actions taken (if any) for each such event. If 

there was no downtime or malfunction of the continuous fuel flow monitoring system 

during any calendar quarter, the report shall be submitted so stating it. These quarterly 

reports shall be submitted by January 30, April 30, July 30, and October 30 of each year.

f) Testing Requirements

(1) Compliance with the emission limitation(s) in Section b.I. of these terms and conditions 

shall be determined in accordance with the following method(s):

a. Emission Limitation

Nitrogen oxides (NOx) emissions shall not exceed 3.0 ppmvd at 15% oxygen and 

7.18 lbs/hr.

Applicable Compliance Method

Initial compliance with the allowable outlet concentration, and the lbs/hr emission 

limitations shall be demonstrated through emission testing performed in 

accordance with Methods 1-4 and Method 20 of 40 CFR Part 60, Appendix A. 

Compliance with the 3.0 ppmvd and 7.18 lbs/hr limits are required only when the 

unit operates above 25% load for the entire clock-hour of the averaging period. 

Testing shall be conducted per 40 CFR 60.4405.

Compliance with the above limitation will ensure compliance with the mass 

emission limitation listed in 40 CFR 60 Subpart KKKK.

Continuous compliance shall be based on the use of the CEM system with the 

data averaged over a 4-hour period.

b. Emission Limitation

Particulate emissions (PE) shall not exceed 0.0066 lb/MMbtu and 3.89 lbs/hr.

Applicable Compliance Method

Initial compliance with the allowable outlet concentration, and the lbs/hr emission 

limitations shall be demonstrated through emission testing performed in 

accordance with Methods 1-5 of 40 CFR Part 60, Appendix A. 
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 32 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

c. Emission Limitation

Sulfur dioxide (SO2) emissions shall not exceed 0.006 lb/MMbtu and 3.53 lbs/hr.

Applicable Compliance Method

Initial compliance with the allowable outlet concentration, and the lbs/hr emission 

limitations shall be demonstrated through the sulfer content of the natural gas 

data obtained from the natural gas supplier. 

d. Emission Limitation

Carbon monoxide (CO) emissions shall not exceed 5.0 ppmvd at 15% oxygen 

and 7.28 lbs/hr.

Applicable Compliance Method

Initial compliance with the allowable outlet concentration, and the lbs/hr emission 

limitations shall be demonstrated through emission testing performed in 

accordance with Methods 1-4 and Method 10 of 40 CFR Part 60, Appendix A. 

Compliance with the 5.0 ppmvd and 7.28 lbs/hr limits are required only when the 

unit operates above 25% load for the entire clock-hour of the averaging period.

Continuous compliance shall be based on the use of the CEM system with the 

data averaged over a 4-hour period. 

e. Emission Limitation

Volatile organic compounds (VOC) emissions shall not exceed 2.2 lbs/hr.

Applicable Compliance Method

If required, the permittee shall demonstrate compliance with this emission 

limitation through emission testing performed in accordance with Methods 1-4 

and Method 25 of 40 CFR Part 60, Appendix A.

f. Emission Limitation

Visible particulate emissions from any stack shall not exceed 10 percent opacity 

as a six-minute average.

Applicable Compliance Method

If required, compliance shall be determined through visible emissions 

observations performed in accordance with 40 CFR Part 60, Appendix A, Method 

9, and the procedures specified in OAC rule 3745-17-03(B)(1).

g. Emission Limitation

SO2 emissions shall not exceed 110 nanograms ng/J (0.90 lb/MWh) gross 

output, or 

26 ng/J (0.060 lb/MMBtu) heat input
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 33 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Applicable Compliance Method

Compliance with the emission limitation shall be demonstrated by the methods 

outlined in sections b.2.e – b.2.p.

h. Emission Limitation

The tons per rolling 12-month period for emissions units P001 – P006 combined 

(including startups/shutdowns) shall not exceed:

NOx – 93.67

CO – 90.36

VOC – 26.40

PE – 46.65

SO2 – 42.41

Applicable Compliance Method

To demonstrate compliance with the annual emission limitations for NOx and 

CO, the permittee will utilize the mass emission data from the required CEM 

system for these two pollutants. The CEM system will be utilized to continually 

measure emissions during all periods of turbine operation (including periods of 

startup and shutdown).

To demonstrate compliance with the annual emission limits for SO2, the 

permittee will calculate SO2 mass emissions from fuel usage and analysis data. 

Fuel usage will be measured (including periods of startup and shutdown) and the 

SO2 emissions will be calculated based on the sulfur concentrations obtained as 

required in Condition 2(h). These calculations will include fuel used during 

startup and shutdown.

To demonstrate compliance with the annual emission limits for PE and VOC the 

permittee will use the lb/hr limitation or most recent compliance stack test lb/hr 

emission factor multiplied by the total operating hours, including hours during 

startup and shutdown.

(2) The permittee shall conduct, or have conducted, emission testing for this emissions unit 

in accordance with the following requirements:

a. The emission testing shall be conducted within 60 days after achieving the 

maximum production rate at which the emissions unit will be operated, but not 

later than 180 days after initial startup of the emissions unit.

b. The emission testing shall be conducted to demonstrate compliance with the 

mass emissions limitations for NOx, PE, and CO.

c. The following test method(s) shall be employed to demonstrate compliance with 

the allowable mass emission rate(s):

NOx – Method 20 of 40 CFR Part 60, Appendix A;
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 34 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

PE - Method 5 of 40 CFR Part 60, Appendix A; and

CO- Method 10 of 40 CFR Part 60, Appendix A.

d. Alternative U.S. EPA approved test methods may be used with prior approval 

from the Ohio EPA.

e. The test(s) shall be conducted while the emissions unit is operating at or near its 

maximum capacity, unless otherwise specified or approved by the appropriate 

Ohio EPA District Office or local air agency.

f. Not later than 30 days prior to the proposed test date(s), the permittee shall 

submit an "Intent to Test" notification to the appropriate Ohio EPA District Office 

or local air agency. The "Intent to Test" notification shall describe in detail the 

proposed test methods and procedures, the emissions unit operating 

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be 

conducting the test(s). Failure to submit such notification for review and approval 

prior to the test(s) may result in the Ohio EPA District Office's or local air 

agency's refusal to accept the results of the emission test(s).

g. Personnel from the appropriate Ohio EPA District Office or local air agency shall 

be permitted to witness the test(s), examine the testing equipment, and acquire 

data and information necessary to ensure that the operation of the emissions unit 

and the testing procedures provide a valid characterization of the emissions from 

the emissions unit and/or the performance of the control equipment.

h. A comprehensive written report on the results of the emissions test(s) shall be 

signed by the person or persons responsible for the tests and submitted to the 

appropriate Ohio EPA District Office or local air agency within 30 days following 

completion of the test(s). The permittee may request additional time for the 

submittal of the written report, where warranted, with prior approval from the 

appropriate Ohio EPA District Office or local air agency.

(3) Within 60 days of the effective date of this permit, the permittee shall conduct 

certification tests of the continuous NOx monitoring system, in units of the applicable 

standard(s), to demonstrate compliance with 40 CFR Part 60, Appendix B, Performance 

Specification 2; Performance Specification 6 relative accuracy requirements; ORC 

section 3704.03(I); and 40 CFR Part 75.

The permittee shall certify that the fuel flow monitor/meter meets 40 CFR 75 certification 

requirements prior to the performance specification test and shall demonstrate how the 

pound per hour emissions of NOx will be calculated stoichiometrically from the fuel flow 

rate.

Personnel from the Ohio EPA Central Office and the appropriate Ohio EPA District 

Office or local air agency shall be notified 45 days prior to initiation of the applicable 

tests and shall be permitted to examine equipment and witness the certification tests. 

Two copies of the test results shall be submitted to Ohio EPA, one copy to the 

appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA 

Central Office, and pursuant to OAC rule 3745-15-04, within 30 days after the test is 

completed.
Final Permit-to-Install and Operate

Permit Number: P0103620

Facility ID: 1677105001

Effective Date: 11/24/2008

Page 35 of 35

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

Certification, or recommendation for certification by Ohio EPA to U.S. EPA, of the 

continuous NOx monitoring system shall be granted upon determination by the Ohio 

EPA, Central Office that the system meets the requirements of 40 CFR Part 60, 

Appendix B, Performance Specification 2; Performance Specification 6 relative accuracy 

requirements; ORC section 3704.03(I); and 40 CFR Part 75.

Ongoing compliance with the NOx emissions limitations contained in this permit, 40 CFR 

Parts 60 and 75, and any other applicable standard(s) shall be demonstrated through 

the data collected as required in the Monitoring and Record keeping Section of this 

permit; and through demonstration of compliance with the quality assurance/quality 

control plan, which shall meet the testing and recertification requirements of 40 CFR Part 

60 and 40 CFR Part 75.

(4) Within 60 days of the effective date of this permit, the permittee shall conduct 

certification tests of the continuous CO monitoring system in units of the applicable 

standard(s), to demonstrate compliance with 40 CFR Part 60, Appendix B, Performance 

Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy 

requirements; and ORC section 3704.03(I).

The permittee shall certify that the fuel flow monitor/meter is calibrated prior to the 

performance specification test and shall demonstrate how the pound per hour emissions 

of CO will be calculated stoichiometrically from the fuel flow rate.

Personnel from the Ohio EPA Central Office and the appropriate Ohio EPA District 

Office or local air agency shall be notified 30 days prior to initiation of the applicable 

tests and shall be permitted to examine equipment and witness the certification tests. 

Two copies of the test results shall be submitted to Ohio EPA, one copy to the 

appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA 

Central Office, and pursuant to OAC rule 3745-15-04, within 30 days after the test is 

completed.

Certification of the continuous CO monitoring system shall be granted upon 

determination by the Ohio EPA Central Office that the system meets the requirements of 

40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); 

Performance Specification 6 relative accuracy requirements; and ORC section 

3704.03(I).

Ongoing compliance with the CO emission limitations contained in this permit, 40 CFR 

Part 60, and any other applicable standard(s) shall be demonstrated through the data 

collected as required in the Monitoring and Record keeping Section of this permit; and 

through demonstration of compliance with the quality assurance/quality control plan, 

which shall meet the requirements of 40 CFR Part 60.

g) Miscellaneous Requirements

(1) In accordance with good engineering practices, the SCR unit on this emissions unit shall 

be installed, operated, and maintained in accordance with the manufacturer’s 

recommendations, with any modifications deemed necessary by the permittee. The 

permittee shall maintain on site a copy of the operation and maintenance manual, as 

provided by the manufacturer.