SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 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. § 7470, 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

800 Long Ridge Road

Stamford, Connecticut 06927

to construct and operate Greenhouse Gas (GHG) air emissions units as a modification to the 

existing Shady Hills Generating Station located at 14240 Merchant Energy Way within the City 

of Spring Hill, in Pasco County, Florida.

This modification to the Shady Hills facility shall be constructed and operated in accordance 

with the terms and conditions set forth in this permit.

This permit becomes effective on [INSERT EFFECTIVE DATE].

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 responsibility to comply fully with all applicable provisions 

of federal and state law.

__________ ______________________

Date Signed Carol L. Kemker

Acting Director

Air, Pesticides, and Toxics

Management Division
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 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 (Shady Hills), dated September 25, 2012, November 30, 

2012, March 27, 2013, 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

800 Long Ridge Road

Stamford, Connecticut 06927

PROJECT LOCATION

Shady Hills’s project will be located at the existing Shady Hills Generating Station located at 

14240 Merchant Energy Way within 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 

combustion turbines (Model: General Electric 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 natural 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). 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 SF6 circuit breaker 

(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 turbine units can operate in 

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

oxides (NOx) combustors and water injection capability. The three units are regulated under 

Phase II of the Federal Acid Rain Program. The existing facility and the Project are located at 

14240 Merchant Energy Way within the City of Spring Hill, in Pasco County, Florida. The 

Project will be located within the existing Shady Hills boundaries. The facility has been in 

operation since 2002 and operates during peak hours of electrical use.
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 3

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

to limit emissions of GHGs, 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 2,500 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 SF6 Circuit Breakers

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; 

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.
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 4

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 practices 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 the performance of the 

facility, 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 procedures for maintaining the facility in good operating condition.

IV. MALFUNCTION REPORTING

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

Condition X: AGENCY 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: SPECIAL 

CONDITIONS of this permit.

B. In addition, pursuant to Condition X: AGENCY NOTIFICATIONS, Permittee 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 initial 

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. 
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 5

V. RIGHT OF ENTRY

The EPA Regional Administrator, and/or an authorized representative, upon the 

presentation of credentials, shall be permitted:

A. to enter the premises where the facility is located or where any records are required to 

be kept under the terms and conditions 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 OWNERSHIP

In the event of any changes in control or ownership of the facility, 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: AGENCY NOTIFICATIONS 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 APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS

A. Permittee shall construct the Project in compliance with this PSD permit, the 

application on which this permit is based, and all other applicable federal, state, and 

local air quality 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 as 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 project should cease all activities 
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 6

involving subsurface disturbance in the immediate vicinity of such discoveries. Upon 

such discovery, Permittee, or other designee, shall 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 offices (FDEP and the EPA Region 4). Project activities shall not resume 

without verbal and/or written authorization from the Division of Historical 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.

IX. SPECIAL CONDITIONS

A. Air Pollution Control Equipment and 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 Turbines (EU 005 & 006) Emission Limits

1. Except as noted below under Condition IX.C, on and after the date of initial startup, 

Permittee shall not discharge or cause the discharge of emissions from the SCCT Units

into the atmosphere in excess of the following:

Normal Operation*

Emission Limit (per CT) 

(natural gas firing)**

Emission Limit (per CT) 

(ULSD oil burning)

**

1,377 pounds (lb) of carbon

dioxide equivalent (CO2e) per

megawatt-hour (MWh) gross

output

(12-month rolling average)

1,928 lb CO2e/MWh gross

output

(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.9.

2. EU 005 and 006 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 one 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. EU 005 and 006 shall not operate firing ULSD fuel oil more than 1,000 combined hours 

per year on a 12-month rolling total. The Permittee shall monitor and record the number 
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 7

of hours each CT operates on ULSD monthly and totalled every month for the previous 

12 months.

If only one SCCT is installed, the CT may operate up to 500 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 mist reduce its capability to fire natural gas by five hours (i.e., 5:1 natural gas to 

ULSD fuel oil ratio).

C. Combustion Turbines (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 sufficient to cause temperature, 

pressure, chemical, or pollution control device imbalances, which result in excess 

emissions above the limits in Condition IX.C.3.

2. Shutdown is the cessation of the operation of an emissions unit for any purpose.

3. Permittee shall not discharge or cause the discharge of emissions from the CT Unit into 

the atmosphere in excess of the following during startup and shutdown events:

Startup and 

Shutdown

Emission Limit (per CT) 

(natural gas firing)*

Emission Limit (per CT) 

(ULSD oil burning)

*

21 tons CO2e per event

(12-month rolling average)

28 tons CO2e per event 

(12-month rolling average)

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

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 CO2e)

EU 007 Emergency Generator

2,500 kW per engine

Work Practice 

Standards

EU 008 Natural Gas Heater

10 MMBtu/hr 3,965 TPY
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 8

Unit ID (description) GHG Limit 

(as CO2e)

EU 010 Circuit Breakers

Three SF6 Circuit Breakers

Work Practice 

Standards

2. EU 007 Emergency Generator shall be properly operated and maintained in accordance to 

manufacturer’s specifications.

3. The EU 007 Emergency Generator shall be limited to operation of the engine for 

maintenance and testing purposes, except during an emergency. Annual hours of 

operation for emergency stationary reciprocating internal combustion engine (as defined 

in 40 CFR 63 Subpart ZZZZ) for maintenance and testing, shall not exceed 100 hours per 

12-month rolling total. Permittee shall monitor and record the number of hours the 

emergency generator operates monthly and totalled every month for the previous 12 

months.

4. EU 008 Natural Gas Heater shall operate exclusively on natural gas and operate on an 

efficiency of 75% or higher.

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

surge. EU 010 Circuit Breakers 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. Records of 

inspection shall be kept in accordance with Condition IX.G.

6. The on-site pipeline and natural gas supply system pressure shall be monitored and 

recorded continuously against alarm set points to be determined upon system design and 

implementation to identify any leaks. Personnel shall treat the natural gas with mercaptan 

for leak detection by odor. 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. Permittee shall install and certify monitoring systems required for quantifying CO2 

emissions from each CT in accordance with the applicable requirements of 40 CFR Part 

75. Consistent with §75.4(b), all applicable certification tests shall be completed within 

180 calendar days after the date the unit commences commercial operation (as defined in 

40 CFR 72.2).

2. Following initial certification, the CO2 continuous monitoring system shall be quality

assured in accordance with the applicable requirements of 40 CFR Part 75.
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 9

3. The CO2 continuous monitoring system shall be capable of producing hourly 

determinations of CO2 mass emissions in tons per hour (tons/hr).

4. In accordance with §75.62, an initial monitoring plan shall be submitted identifying the

methodology for which CO2 mass emissions will be continuously monitored. The initial 

monitoring plan shall be submitted no later than 21 days prior to the initial certification

tests.

5. Permittee shall provide notifications as specified in §75.61 for any event related to the

continuous measurement of CO2.

6. Permittee shall measure and record, for each CT, the following on an hourly basis:

a. Gross energy output rate (MW);

b. CO2 mass emission rate (lbs CO2

/hr);

c. Heat input rate (MMBtu/hr; HHV), in accordance with 40 CFR Part 75, Appendix 

D;

d. Unit operating time as described in §75.57(b)(2); and

e. The type (natural gas or ULSD) and amount of fuel (gals) burned.

7. Permittee shall calculate and record, for each CT, the following on a monthly basis:

a. Monthly average CO2 mass emission rate (lbs CO2/MWh) calculated as the sum 

of each hourly CO2 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 CO2 emission rate shall be calculated for 

each fuel.

b. Monthly average heat rate (Btu/kWh) calculated as the sum of each hourly heat 

input rate times the unit operating time for the hour divided by the sum of the

recorded energy output rates times the unit operating time for the hour for all 

hours of operation in each month times 1,000. If more than one fuel is utilized in a

month, a separate average heat input rate shall be calculated for each fuel.

8. Permittee shall calculate and record, for each CT, the following on an annual basis:

a. The 12-month rolling average CO2 mass emission rate (lbs CO2/MWh) (for each 

fuel combusted in the previous 12 months) shall be calculated as the sum of each 

monthly average value times the monthly energy output (MWh) divided by the

sum of the energy output (MWh) generated during the 12 month period.
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b. The 12-month rolling average heat rate (Btu/kWh) (for each fuel combusted in the

previous 12 months) shall be calculated as the sum of each monthly average heat 

rate value times the monthly energy output (kWh) divided by the sum of the

energy output (kWh) generated during the 12 month period.

9. 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 CO2e) based on the combination of measured CO2 emissions and calculated 

CO2e of other GHG pollutants (as specified in Condition J: GLOBAL WARMING 

POTENTIAL (GWP)). Permittee 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. 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 such 

event.

2. 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 CO2e) based on the combination of measured CO2 emissions and calculated 

CO2e of other GHG pollutants (as specified in Condition J: GLOBAL WARMING 

POTENTIAL (GWP)). Permittee shall keep adequate records of these GHG emission 

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

G. Monitoring and Compliance for Auxiliary Equipment

1. Permittee shall install 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 and totalled every month for the 

previous 12 months.

2. Permittee shall install and maintain an 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 efficiency of the 10.0 MMBtu/hr 

natural gas heater (EU 008) on a daily 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 week of 

startup):
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 11

a. Inspect 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 burner 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 ratio, and ensure that it is correctly 

calibrated and functioning properly

4. Permittee shall use the annual heat input and data from 40 CFR Part 98, Table C-1 to 

calculate and record CO2e emissions from the 10.0 MMBtu/hr natural gas heater (EU 

008) 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;

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 

related to the operation of the facility, including, but not limited to, the following:

a. all records or reports pertaining to adjustments and/or maintenance performed on any 

system or device at the facility; 

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.
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 12

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 report 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 necessary to accurately assess the 

compliance status of the source. The report is due on September 30th and March 31st and 

shall include the following:

a. If applicable, time intervals, data and magnitude of the excess emissions, the nature 

and cause (if known), corrective actions taken and preventive measures adopted;

b. If applicable, 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 monitoring 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 conduct any required source testing, monitoring, or other compliance 

activities; and

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

on hours of operation.

5. Excess emissions shall be defined as any period in which the facility emissions exceed 

the maximum emission limits 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 monitoring system to validate the hour for CO2.

7. Excess emissions indicated by continuous monitoring system source testing, or 

compliance monitoring 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 

facility, 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 facility

performance measures and all maintenance activities; the Permittee shall maintain such 

records for a minimum of five years following the date they are created

9. Unless otherwise specified herein, all 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 
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 13

upon request by the Agency or authorized representative during the course of an 

inspection.

I. Shakedown Periods

The combustion turbine and auxiliary equipment emission limits and requirements in 

Conditions IX.B, IX.C, and IX.D shall not apply during combustion shakedown 

periods. Shakedown is defined as the period beginning with initial startup and ending no 

later than 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 180 days. The requirements of Section 

III 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 as of the date of this permit 

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

GHG Pollutant GWP Factor

CO2 1

CH4 21

N2O 310

SF6 23,900

X. AGENCY 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
SHGS Project (PSD-EPA-R4013) - Draft PSD Permit 9/17/13 14

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. Lusky forney.kathleen@epa.gov 404-562-9130

Heather Ceron ceron.heather@epa.gov 404-562-9185