Street Address: Mailing Address:

Lazarus Gov. CenterTELE: (614) 644-3020 FAX: (614) 644-2329

Lazarus Gov. 

Center

State of Ohio Environmental Protection Agency

RE: FINAL PERMIT TO INSTALL MODIFICATION CERTIFIED MAIL

SUMMIT COUNTY

Application No: 16-02110

DATE: 5/23/2002

Norton Energy Storage

Dennis Hockenbury

20445 State Hwy 249 Suite 230 

Houston, TX 770702616

Enclosed Please find a modification to the Ohio EPA Permit To Install referenced above which will modify the terms and

conditions.

You are hereby notified that this action by the Director is final and may be appealed to the Ohio Environmental Review

Appeals Commission pursuant to Chapter 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth

the action complained of and the grounds upon which the appeal is based. It must be filed within thirty (30) days after the

notice of the Directors action. A copy of the appeal must be served on the Director of the Ohio Environmental Protection

Agency within three (3) days of filing with the Commission. An appeal may be filed with the Environmental Review

Appeals Commission at the following address:

Environmental Review Appeals Commission

236 East Town Street, Room 300

Columbus, Ohio 43215

Very truly yours,

Thomas G. Rigo

Field Operations and Permit Section

Division of Air Pollution Control

cc: USEPA ARAQMD
 STATE OF OHIO ENVIRONMENTAL PROTECTION AGENCY

Permit To Install Issue Date: 5/23/2002

Terms and Conditions Effective Date: 5/23/2002

FINAL ADMINISTRATIVE MODIFICATION OF PERMIT TO INSTALL 16-02110

Application Number: 16-02110

APS Premise Number: 1677100033

Permit Fee: $0

Name of Facility: Norton Energy Storage

Person to Contact: Dennis Hockenbury

Address: 20445 State Hwy 249 Suite 230 

Houston, TX 770702616

Location of proposed air contaminant source(s) [emissions unit(s)]:

3700 Limestone Dr

Norton, Ohio

Description of proposed emissions unit(s):

Modification of terms and conditions of PTI 16-02110 issued final on 8/28/01.

The above named entity is hereby granted a modification to the permit to install described above pursuant to Chapter 3745-

31 of the Ohio Administrative Code. Issuance of this modification does not constitute expressed or implied approval or 

agreement that, if constructed or modified in accordance with the plans included in the application, the above described 

source(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and 

does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans included in 

the application, the above described source(s) of pollutants will be granted the necessary operating permits.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Director
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Part I - GENERAL TERMS AND CONDITIONS

A. State and Federally Enforceable Permit To Install General Terms and Conditions

1. Monitoring and Related Recordkeeping and Reporting Requirements

a. Except as may otherwise be provided in the terms and conditions for a specific emissions

unit, the permittee shall maintain records that include the following, where applicable, for

any required monitoring under this permit:

i. The date, place (as defined in the permit), and time of sampling or measurements.

ii. The date(s) analyses were performed.

iii. The company or entity that performed the analyses.

iv. The analytical techniques or methods used.

v. The results of such analyses.

vi. The operating conditions existing at the time of sampling or measurement.

b. Each record of any monitoring data, testing data, and support information required

pursuant to this permit shall be retained for a period of five years from the date the record

was created. Support information shall include, but not be limited to, all calibration and

maintenance records and all original strip-chart recordings for continuous monitoring

instrumentation, and copies of all reports required by this permit. Such records may be

maintained in computerized form.

c. Except as may otherwise be provided in the terms and conditions for a specific emissions

unit, the permittee shall submit required reports in the following manner:

i. Reports of any required monitoring and/or recordkeeping of federally enforceable

information shall be submitted to the appropriate Ohio EPA District Office or local

air agency.

ii. Quarterly written reports of (i) any deviations from federally enforceable emission

limitations, operational restrictions, and control device operating parameter

limitations, excluding deviations resulting from malfunctions reported in

accordance with OAC rule 3745-15-06, that have been detected by the testing,

monitoring and recordkeeping requirements specified in this permit, (ii) the

probable cause of such deviations, and (iii) any corrective actions or preventive

measures taken, shall be made to the appropriate Ohio EPA District Office or

local air agency. The written reports shall be submitted quarterly, i.e., by January

31, April 30, July 31, and October 31 of each year and shall cover the previous
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

calendar quarters. See B.10 below if no deviations occurred during the quarter.

iii. Written reports, which identify any deviations from the federally enforceable

monitoring, recordkeeping, and reporting requirements contained in this permit

shall be submitted to the appropriate Ohio EPA District Office or local air agency

every six months, i.e., by January 31 and July 31 of each year for the previous six

calendar months. If no deviations occurred during a six-month period, the

permittee shall submit a semi-annual report, which states that no deviations

occurred during that period.

iv. Each written report shall be signed by a responsible official certifying that, based

on information and belief formed after reasonable inquiry, the statements and

information in the report are true, accurate, and complete.

2. Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance

with paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units

or any associated air pollution control system(s) shall be reported to the appropriate Ohio EPA

District Office or local air agency in accordance with paragraph (B) of OAC rule 3745-15-06.

(The definition of an upset condition shall be the same as that used in OAC rule 3745-15-06(B)(1)

for a malfunction.) The verbal and written reports shall be submitted pursuant to OAC rule

3745-15-06.

Except as provided in that rule, any scheduled maintenance or malfunction necessitating the

shutdown or bypassing of any air pollution control system(s) shall be accompanied by the

shutdown of the emission unit(s) that is (are) served by such control system(s).

3. Risk Management Plans

If the permittee is required to develop and register a risk management plan pursuant to section

112(r) of the Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall

comply with the requirement to register such a plan.

4. Title IV Provisions

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the

permittee shall ensure that any affected 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.

5. Severability Clause

A determination that any term or condition of this permit is invalid shall not invalidate the force or

effect of any other term or condition thereof, except to the extent that any other term or condition

depends in whole or in part for its operation or implementation upon the term or condition
5

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

declared invalid.

6. General Requirements

a. The permittee must comply with all terms and conditions of this permit. Any

noncompliance with the federally enforceable terms and conditions of this permit

constitutes a violation of the Act, and is grounds for enforcement action or for permit

revocation, revocation and reissuance, or modification, or for denial of a permit renewal

application.

b. It shall not be a defense for the permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

federally enforceable terms and conditions of this permit.

c. This permit may be modified, reopened, revoked, or revoked and reissued, for cause. The

filing of a request by the permittee for a permit modification, revocation and reissuance, or

revocation, or of a notification of planned changes or anticipated noncompliance does not

stay any term and condition of this permit.

d. This permit does not convey any property rights of any sort, or any exclusive privilege.

e. The permittee shall furnish to the Director of the Ohio EPA, or an authorized

representative of the Director, upon receipt of a written request and within a reasonable

time, any information that may be requested to determine whether cause exists for

modifying, reopening or revoking this permit or to determine compliance with this permit.

Upon request, the permittee shall also furnish to the Director or an authorized

representative of the Director, copies of records required to be kept by this permit. For

information claimed to be confidential in the submittal to the Director, if the Administrator

of the U.S. EPA requests such information, the permittee may furnish such records

directly to the Administrator along with a claim of confidentiality.

7. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section

3745.11 and OAC Chapter 3745-78. The permittee shall pay all applicable Permit To Install fees

within 30 days after the issuance of this Permit To Install.

8. Federal and State Enforceability

Only those terms and conditions designated in this permit as federally enforceable, that are
6

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

required under the Act, or any of its applicable requirements, including relevant provisions

designed to limit the potential to emit of a source, are enforceable by the Administrator of the

U.S. EPA, the State, and citizens under the Act. All other terms and conditions of this permit

shall not be federally enforceable and shall be enforceable under State law only.

9. Compliance Requirements

a. Any document (including reports) required to be submitted and required by a federally

applicable requirement in this permit shall include a certification by a responsible official

that, based on information and belief formed after reasonable inquiry, the statements in the

document are true, accurate, and complete.

b. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow the Director of the Ohio EPA or an authorized representative of the

Director to:

i. At reasonable times, enter upon the permittee's premises where a source is located

or the emissions-related activity is conducted, or where records must be kept

under the conditions of this permit.

ii. Have access to and copy, at reasonable times, any records that must be kept under

the conditions of this permit, subject to the protection from disclosure to the public

of confidential information consistent with ORC section 3704.08.

iii. Inspect at reasonable times any facilities, equipment (including monitoring and air

pollution control equipment), practices, or operations regulated or required under

this permit.

iv. As authorized by the Act, sample or monitor at reasonable times substances or

parameters for the purpose of assuring compliance with the permit and applicable

requirements.

c. The permittee shall submit progress reports to the appropriate Ohio EPA District Office or

local air agency concerning any schedule of compliance for meeting an applicable

requirement. Progress reports shall be submitted semiannually, or more frequently if

specified in the applicable requirement or by the Director of the Ohio EPA. Progress

reports shall contain the following:

i. Dates for achieving the activities, milestones, or compliance required in any

schedule of compliance, and dates when such activities, milestones, or compliance

were achieved.

ii. An explanation of why any dates in any schedule of compliance were not or will

not be met, and any preventive or corrective measures adopted.
7

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

10. Permit To Operate Application

a. If the permittee is required to apply for a Title V permit pursuant to OAC Chapter

3745-77, the permittee shall submit a complete Title V permit application or a complete

Title V permit modification application within twelve (12) months after commencing

operation of the emissions units covered by this permit. However, if the proposed new or

modified source(s) would be prohibited by the terms and conditions of an existing Title V

permit, a Title V permit modification must be obtained before the operation of such new

or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule

3745-77-08(C)(3)(d).

b. If the permittee is required to apply for permit(s) pursuant to OAC Chapter 3745-35, the

source(s) identified in this Permit To Install is (are) permitted to operate for a period of up

to one year from the date the source(s) commenced operation. Permission to operate is

granted only if the facility complies with all requirements contained in this permit and all

applicable air pollution laws, regulations, and policies. Pursuant to OAC Chapter 3745-35,

the permittee shall submit a complete operating permit application within thirty (30) days

after commencing operation of the source(s) covered by this permit.

11. Best Available Technology

As specified in OAC Rule 3745-31-05, all new sources must employ Best Available Technology

(BAT). Compliance with the terms and conditions of this permit will fulfill this requirement.

12. Air Pollution Nuisance

The air contaminants emitted by the emissions units covered by this permit shall not cause a public

nuisance, in violation of OAC rule 3745-15-07.
8

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

B. State Only Enforceable Permit To Install General Terms and Conditions

1. Compliance Requirements

The emissions unit(s) identified in this Permit to Install shall remain in full compliance with all

applicable State laws and regulations and the terms and conditions of this permit.

2. Reporting Requirements Related to Monitoring and Recordkeeping Requirements

The permittee shall submit required reports in the following manner:

a. Reports of any required monitoring and/or recordkeeping of state-only enforceable

information shall be submitted to the appropriate Ohio EPA District Office or local air

agency.

b. Except as otherwise may be provided in the terms and conditions for a specific emissions

unit, quarterly written reports of (a) any deviations (excursions) from state-only required

emission limitations, operational restrictions, and control device operating parameter

limitations that have been detected by the testing, monitoring, and recordkeeping

requirements specified in this permit, (b) the probable cause of such deviations, and (c)

any corrective actions or preventive measures which have been or will be taken, shall be

submitted to the appropriate Ohio EPA District Office or local air agency. If no

deviations occurred during a calendar quarter, the permittee shall submit a quarterly

report, which states that no deviations occurred during that quarter. The reports shall be

submitted quarterly, i.e., by January 31, April 30, July 31, and October 31 of each year

and shall cover the previous calendar quarters. (These quarterly reports shall exclude

deviations resulting from malfunctions reported in accordance with OAC rule

3745-15-06.)

3. Permit Transfers

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The

appropriate Ohio EPA District Office or local air agency must be notified in writing of any

transfer of this permit.

4. Termination of Permit To Install

This permit to install shall terminate within eighteen months of the effective date of the permit to

install if the owner or operator has not undertaken a continuing program of installation or

modification or has not entered into a binding contractual obligation to undertake and complete
9

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

within a reasonable time a continuing program of installation or modification. This deadline may 

be extended by up to 12 months if application is made to the Director within a reasonable time 

before the termination date and the party shows good cause for any such extension.

5. Construction of New Sources(s)

The proposed emissions unit(s) shall be constructed in strict accordance with the plans and 

application submitted for this permit to the Director of the Ohio Environmental Protection 

Agency. There may be no deviation from the approved plans without the express, written 

approval of the Agency. Any deviations from the approved plans or the above conditions may 

lead to such sanctions and penalties as provided under Ohio law. Approval of these plans does 

not constitute an assurance that the proposed facilities will operate in compliance with all Ohio 

laws and regulations. Additional facilities shall be installed upon orders of the Ohio 

Environmental Protection Agency if the proposed sources cannot meet the requirements of this 

permit or cannot meet applicable standards.

If the construction of the proposed emissions unit(s) has already begun or has been completed 

prior to the date the Director of the Environmental Protection Agency approves the permit 

application and plans, the approval does not constitute expressed or implied assurance that the 

proposed facility has been constructed in accordance with the approved plans. The action of 

beginning and/or completing construction prior to obtaining the Director's approval constitutes a 

violation of OAC rule 3745-31-02. Furthermore, issuance of the Permit to Install does not 

constitute an assurance that the proposed source will operate in compliance with all Ohio laws 

and regulations. Approval of the plans in any case is not to be construed as an approval of the 

facility as constructed and/or completed. Moreover, issuance of the Permit to Install is not to be 

construed as a waiver of any rights that the Ohio Environmental Protection Agency (or other 

persons) may have against the applicant for starting construction prior to the effective date of the 

permit. Additional facilities shall be installed upon orders of the Ohio Environmental Protection 

Agency if the proposed facilities cannot meet the requirements of this permit or cannot meet 

applicable standards.

6. Public Disclosure

The facility is hereby notified that this permit, and all agency records concerning the operation of 

this permitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03.

7. Applicability
10

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

This Permit to Install is applicable only to the emissions unit(s) identified in the Permit To Install. 

Separate application must be made to the Director for the installation or modification of any other 

emissions unit(s).

8. Construction Compliance Certification

The applicant shall provide Ohio EPA with a written certification (see enclosed form) that the 

facility has been constructed in accordance with the Permit To Install application and the terms 

and conditions of the Permit to Install. The certification shall be provided to Ohio EPA upon 

completion of construction but prior to startup of the source.

9. Additional Reporting Requirements When There Are No Deviations of Federally

Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating

Parameter Limitations (See Section A of This Permit)

If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report,

which states that no deviations occurred during that quarter. The reports shall be submitted

quarterly, i.e., by January 31, April 30, July 31, and October 31 of each year and shall cover the

previous calendar quarters.

C. Permit To Install Summary of Allowable Emissions

The following information summarizes the total allowable emissions, by pollutant, based on the individual

allowable emissions of each air contaminant source identified in this permit.

SUMMARY (for informational purposes only)

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS

Pollutant Tons Per Year

NOx 360

SO2

CO

VOC

PM

NH3

formaldehyde

sulfuric acid mist

48.1

1767.4

147.9

318.5

374.4

9.86

4.77
11

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002
12

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

Part II - FACILITY SPECIFIC TERMS AND CONDITIONS

A. State and Federally Enforceable Permit To Install Facility Specific Terms and Conditions

The emissions of Hazardous Air Pollutants (HAPs), as defined in Section 112(b) of the Clean Air Act,

from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2 emergency generators, and diesel

fuel pump) located at this facility combined, shall not exceed 9.86 tons per year for an individual

HAP(formaldehyde) and 25 tons per year for any combination of HAPs*, per rolling 12 month period.

Since the restricted potential to emit for all HAPs is less than 25 tons, no monitoring, record keeping, or

reporting requirements are necessary to meet this limit.

B. State Only Enforceable Permit To Install Facility Specific Terms and Conditions

None
13

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #1 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B001 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B001, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
16

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD
17

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
20

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
21

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
22

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:
23

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average
24

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
25

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #1 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
26

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B001
27

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #2 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
28

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
29

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B002 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B002, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
30

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD
31

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
32

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
33

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year
34

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
35

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.84 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
36

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
37

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:
38

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average
39

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
40

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #2 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
41

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B002
42

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #3 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
43

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
44

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B003 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B003, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and 

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions
45

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States
46

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
47

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
48

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year
49

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
50

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
51

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003
52

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a
53

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
54

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #3 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
55

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B003
56

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #4 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
57

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per

year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
58

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B004 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B004, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
59

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.
60

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
61

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
62

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year
63

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
64

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
65

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
66

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:
67

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average
68

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
69

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #4 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
70

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B004
71

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #5 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
72

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
73

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B005 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B005, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
74

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.
75

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.
76

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2

emissions. The Administrator will examine the description of the control device

and will determine whether the technology qualifies as an emerging technology. In

making this determination, the Administrator may require the owner or operator of

the affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
77

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
78

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
79

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
80

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a
81

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
82

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #5 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
83

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B005
84

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #6 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
85

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
86

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B006 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B006, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
87

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.
88

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is
89

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
90

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006
91

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year
92

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
93

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
94

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
95

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average
96

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
97

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #6 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
98

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B006
99

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #7 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
100

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
101

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B007 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B007, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and 

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions
102

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.
103

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is
104

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
105

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.
106

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
107

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr
108

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:
109

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
110

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #7 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
111

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B007
112

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #8 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
113

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
114

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B008 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B008, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and 

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions
115

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.
116

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.
117

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

Appeals will be addressed to:
118

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year

Applicable Compliance Method:

lb/MMBtu
119

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor 

for natural gas combustion of 94 lb/106 scf. 

(94 lb / 106 scf)*(scf / 1000 Btu)*(106 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu 

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
120

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
121

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year
122

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
123

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

VI. Miscellaneous Requirements

None
124

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #8 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
125

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B008
126

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #9 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60, subpart Dc
127

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

Subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.076 lb/hr, and 2.24 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.021 lb/hr, and 0.04 ton per

year

carbon monoxide (CO)

emissions shall not exceed

0.084 lb/MMBtu actual heat

input

0.96 lb/hr, and 2.0 tons per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.063 lb/hr, and 0.13 ton per

year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

See A.IV.6 below.
128

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual cumulative fuel heat input of emissions unit B009 shall not exceed 47,630 

MMBtu, based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly fuel heat input restrictions specified in 

the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 8,245

1 - 2 16,487

1 - 3 24,310

1 - 4 32,974

1 - 5 41,220

1 - 6 47,630

1 - 7 47,630

1 - 8 47,630

1 - 9 47,630

1 - 10 47,630

1 - 11 47,630

1 - 12 47,630

After the first 12 calendar months following the startup of emissions unit B009, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in
129

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. fuel quantity, in cubic feet;

b. heating value of fuel, in MMBtu; and

c.beginning after the first 12 calendar months of operation following issuance of

this permit, the rolling, 12-month summation of the cumulative heat input.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative heat input for each calendar month.
130

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic feet. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month heat input limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative heat input. These reports are due by the date

described in Part 1 - General Terms and Conditions of this permit under section (A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency
131

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.076 lb/hr, and 2.24 ton per year
132

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 1.076 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.076

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.021 lb/hr, and 0.04 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (11.45 MMBtu/hr). The resulting value is 0.021 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.021

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
133

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.084 lb/MMBtu actual heat input

0.96 lb/hr, and 2.0 tons per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.458 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.458

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.063 lb/hr, and 0.13 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu
134

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

input rate (11.45 MMBtu/hr). The resulting value is 0.063 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.063

lb/hr) by actual hours/year and dividing by 2000 lb/ton.
135

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.087 lb/hr, and 0.18 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008

lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (11.45 MMBtu/hr). The resulting value is 0.087 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.087

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 2.24

SO2 - 0.04

PM - 0.18

CO - 2.0

VOC - 0.13

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a
136

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
137

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B009

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Fuel Supply Heater #9 -

11.45 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
138

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #1 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
139

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
140

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B010 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B010, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
141

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
142

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
143

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:
144

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094

lb/MMBtu
145

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input
146

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

0.514 lb/hr, and 0.03 ton per year
147

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
148

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
149

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements
150

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

None
151

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #1 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
152

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B010
153

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #2 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
154

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
155

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B011 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B011, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and 

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions 

unit:
156

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
157

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
158

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
159

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

lb/MMBtu
160

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input
161

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

0.514 lb/hr, and 0.03 ton per year
162

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
163

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
164

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
165

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

VI. Miscellaneous Requirements

None
166

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #2 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
167

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B011
168

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #3 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
169

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton

per year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
170

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B012 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B012, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
171

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
172

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
173

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
174

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

lb/MMBtu
175

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu 

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input

0.514 lb/hr, and 0.03 ton per year
176

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

Applicable Compliance Method:
177

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input
178

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

0.098 lb/hr, and 0.005 ton per year
179

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
180

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

VI. Miscellaneous Requirements

None
181

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #3 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
182

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B012
183

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #4 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton

per year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
185

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B013 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B013, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
186

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
187

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460
188

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
189

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

lb/MMBtu
190

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input

0.514 lb/hr, and 0.03 ton per year
191

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

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Emissions Unit ID: B013
192

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
193

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
194

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
195

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

VI. Miscellaneous Requirements

None
196

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #4 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
197

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B013
198

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #5 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
199

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
200

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B014 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B014, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
201

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
202

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460
203

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
204

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

lb/MMBtu
205

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input
206

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

0.514 lb/hr, and 0.03 ton per year
207

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
208

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
209

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
210

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

VI. Miscellaneous Requirements

None
211

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #5 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
212

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B014
213

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #6 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
214

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
215

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B015 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B015, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
216

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions

unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
217

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
218

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:
219

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094

lb/MMBtu
220

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input

0.514 lb/hr, and 0.03 ton per year
221

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015
222

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
223

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
224

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.
225

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).

VI. Miscellaneous Requirements

None
226

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #6 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
227

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B015
228

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #7 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
229

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton per year

particulate matter (PM) emissions

shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
230

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B016 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B016, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and 

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions unit:
231

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
232

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
233

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
234

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

lb/MMBtu
235

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input

0.514 lb/hr, and 0.03 ton per year
236

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

Applicable Compliance Method:
237

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor 

for natural gas combustion of 40 lb/106 scf. 

(40 lb / 106 scf)*(scf / 1000 Btu)*(106 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu 

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed
238

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
239

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
240

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

VI. Miscellaneous Requirements

None
241

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #7 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
242

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B016
243

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #8 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
244

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton

per year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
245

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B017 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B017, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
246

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
247

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:
248

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
249

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

lb/MMBtu
250

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu 

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207 

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input

0.514 lb/hr, and 0.03 ton per year
251

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

Applicable Compliance Method:
252

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input
253

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

0.098 lb/hr, and 0.005 ton per year
254

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

g. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
255

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

VI. Miscellaneous Requirements

None
256

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #8 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
257

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B017
258

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #9 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(A)

OAC rule 3745-17-10(B)(1)

OAC rule 3745-18-06(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

40 CFR 60 subpart Dc
259

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-10(B)(1), OAC

rule 3745-18-06(A), OAC

3745-31- (13) thru (20), 40

CFR 52.21, and 40 CFR 60

subpart Dc.

nitrogen oxide (NOx)

emissions shall not exceed

0.094 lb/MMBtu actual heat

input

1.207 lb/hr, and 0.06 ton per

year

sulfur dioxide (SO2)

emissions shall not exceed

0.002 lb/MMBtu actual heat

input

0.023 lb/hr, and 0.0012 ton

per year

carbon monoxide (CO)

emissions shall not exceed

0.040 lb/MMBtu actual heat

input

0.514 lb/hr, and 0.03 ton per

year

volatile organic compounds

(VOC) emissions shall not

exceed

0.006 lb/MMBtu actual heat

input

0.071 lb/hr, and 0.004 ton

per year

particulate matter (PM)

emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year

visible particulate emissions from any

stack shall not exceed 10 percent

opacity as a six-minute average

Operational restriction, see A.II.1

below.

The emission limitations specified by

these rules are less stringent than

those established above

The tons per rolling 12-month period

shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

See A.IV.6 below.
260

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

1. The permittee shall burn only natural gas in this emission unit. The maximum sulfur content of the 

natural gas shall not exceed 0.6 grains per 100 standard cubic feet.

2. The maximum annual hours of operation of emissions unit B018 shall not exceed 100 hours, 

based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit the permittee shall not exceed the monthly hours of operation restrictions specified 

in the following table:

Month Cumulative hours of Operation 

1 20

1 - 2 40

1 - 3 60

1 - 4 80

1 - 5 100

1 - 6 100

1 - 7 100

1 - 8 100

1 - 9 100

1 - 10 100

1 - 11 100

1 - 12 100

After the first 12 calendar months following the startup of emissions unit B018, compliance with 

the annual hours of operation restriction shall be based on a rolling, 12-month summation.

III. Monitoring and/or Recordkeeping Requirements

1. For each day during which the permittee burns a fuel other than natural gas, the permittee shall 

maintain a record of the type and quantity of fuel burned in this emissions unit

2. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in 

the emission unit. Fuel sampling and analysis shall be conducted according to the procedures and
261

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

at the frequency specified by 40 CFR Part 75, Appendix D.

3. The permittee shall maintain monthly records of the following information for each emissions unit:

a. hours of operation of the boiler; and

b. beginning after the first 12 calendar months of operation following issuance of this permit,

the rolling, 12-month summation of the hours of operation.

Also, during the first 12 calendar months of operation following issuance of this permit, the

permittee shall record the cumulative hours of operation for each calendar month.

4.The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
262

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurs.

2. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per standard cubic foot. These reports

are due by the date described in Part I - General Terms and Conditions of this permit under

section (A)(2).

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month operating hours limitation and, for the first 12 calendar months of operation, all

exceedances of the maximum allowable cumulative operating hours levels. These reports are due

by the date described in Part 1 - General Terms and Conditions of this permit under section

(A)(2).

4. The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

5. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460
263

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

6.The permittee shall submit notification of the date of construction or reconstruction, anticipated

startup, and actual startup, as provided by 40 CFR 60.70. This notification shall include:

a. the design heat input capacity of the affected facility and identification of fuels to

be combusted in the affected facility;

b. if applicable, a copy of any Federally enforceable requirement that limits the

annual capacity factor for any fuel or mixture of fuels under Sec. 60.42c, or Sec.

60.43c;

c. the annual capacity factor at which the permittee anticipates operating the

affected facility based on all fuels fired and based on each individual fuel fired; and

d.notification if an emerging technology will be used for controlling SO2 emissions.

The Administrator will examine the description of the control device and will

determine whether the technology qualifies as an emerging technology. In making

this determination, the Administrator may require the owner or operator of the

affected facility to submit additional information concerning the control device.

The affected facility is subject to the provisions of Sec. 60.42c(a) or (b)(1), unless

and until this determination is made by the Administrator.

V. Testing Requirements

1. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation:

nitrogen oxide (NOx) emissions shall not exceed

0.094 lb/MMBtu actual heat input

1.207 lb/hr, and 0.06 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 94 lb/10

6

scf.

(94 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.094
264

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

lb/MMBtu
265

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

lb/hr

Multiply the converted AP-42 emission factor of 0.094 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 1.207 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly NOx emission rate (1.207

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

b. Emission Limitation:

sulfur dioxide (SO2) emissions shall not exceed

0.002 lb/MMBtu actual heat input

0.023 lb/hr, and 0.0012 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated based on the record keeping requirements of section

A.III.2 and the following methodology:

(0.6 grains S / 100 scf)*( 1 lb S / 7,000 grains S)*(64 lb SO2 / 32 lb

S)

= 1.71x10

-6

lb SO2 / scf

(1.71x10

-6

lb SO2 / scf)*( scf / 1000 Btu)*(10

6

/ MMBtu) = 0.002

lb SO2 / MMBtu

lb/hr

Multiply the converted worst case emission factor of 0.002 lb/MMBtu by the maximum

Btu input rate (12.84 MMBtu/hr). The resulting value is 0.023 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly SO2 emission rate (0.023

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

c. Emission Limitation:

carbon monoxide (CO) emissions shall not exceed

0.040 lb/MMBtu actual heat input
266

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

0.514 lb/hr, and 0.03 ton per year
267

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-1] emission factor

for natural gas combustion of 40 lb/10

6

scf.

(40 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.040 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.040 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.514 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly CO emission rate (0.514

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

d. Emission Limitation:

volatile organic compounds (VOC) emissions shall not exceed

0.006 lb/MMBtu actual heat input

0.071 lb/hr, and 0.004 ton per year

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 5.5 lb/10

6

scf.

(5.5 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.006 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.006 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.071 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly VOC emission rate (0.071

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

e. Emission Limitation:
268

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

particulate matter (PM) emissions shall not exceed

0.008 lb/MMBtu actual heat input

0.098 lb/hr, and 0.005 ton per year
269

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

Applicable Compliance Method:

lb/MMBtu

Compliance shall be demonstrated using the AP-42 [(7/98) Table 1.4-2] emission factor

for natural gas combustion of 7.6 lb/10

6

scf.

(7.6 lb / 10

6

scf)*(scf / 1000 Btu)*(10

6 Btu / MMBtu) = 0.008 lb/MMBtu

lb/hr

Multiply the converted AP-42 emission factor of 0.008 lb/MMBtu by the maximum Btu

input rate (12.84 MMBtu/hr). The resulting value is 0.098 lbs/hr.

tons per year

Compliance shall be demonstrated by multiplying the hourly PM emission rate (0.098

lb/hr) by actual hours/year and dividing by 2000 lb/ton.

f. Emission Limitation:

The tons per rolling 12-month period shall not exceed :

NOx - 0.06

SO2 - 0.0012

PM - 0.005

CO - 0.03

VOC - 0.004

Applicable Compliance Method:

Compliance with the above limitations shall be demonstrated based upon the record

keeping requirements of section A.III.3.

7. Emission Limitation:

visible particulate emissions from any stack shall not exceed 10 percent opacity as a

six-minute average

Applicable Compliance Method:

Compliance shall be demonstrated by the method specified in OAC rule 3745-17-

03(B)(1).
270

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

VI. Miscellaneous Requirements

None
271

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Recuperator Pre-heater #9 -

12.84 MMBtu/hr natural

gas-fired boiler

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
272

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: B018
273

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #1 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(B)

OAC rule 3745-17-08(B)

OAC 3745-31- (13) thru (20), and

40 CFR 52.21.

Applicable Emissions Limitations/Control

Measures

The requirements of this rule also include

compliance with the requirements of OAC

rule 3745-17-07(B), OAC rule

3745-17-08(B), OAC 3745-31- (13) thru

(20), and 40 CFR 52.21.

particulate matter (PM) emissions shall

not exceed 5.62 lb/hr and 24.6 tons per

year

10% opacity as a 3-minute average

(fugitive emissions)

The emission limitation specified by this

rule is less stringent than that established

above.

See section A.II.1 below.

The tons per rolling 12-month period shall

not exceed :

PM - 24.6 tons per year

2. Additional Terms and Conditions
274

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

2.a The 5.62 lbs/hr limitation was established for PTI purposes to reflect the potential to emit

for this emissions unit. Therefore, it is not necessary to develop record keeping and/or

reporting requirements to ensure compliance with this limit.
275

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

II. Operational Restrictions

1.The permittee shall employ mist eliminators to minimize drift from the cooling tower.

III. Monitoring and/or Recordkeeping Requirements

1.PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports which identify all exceedances of the 5.62

lb/hr PM limitation.

2. The permittee shall submit deviation reports as specified in Part I - General Terms and Conditions

of this permit under section (A)(2).

V. Testing Requirements
276

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

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

determined in accordance with the following method(s):
277

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

a.Emission Limitation:

particulate matter (PM) emissions shall not exceed 5.62 lb/hr and 24.6 tons per year

Applicable Compliance Method:

Compliance shall be demonstrated in accordance with the

procedures from AP-42, Section 13.4 (1/95).

PM emissions (lb/hr) = WCR * Drift * TDS * [ (3.78L/gal)*(2.20E-06 lb/mg)*(60min/hr)

]

Where:

WCR = maximum water circulation rate, 749,342 gpm (based on compression phase for

turbines)

Drift = 0.0005%

TDS = total dissolved solids, 3,000mg/L

Compliance with the annual limitation shall be demonstrated by

multiplying the hourly PM emissions rate by actual hours/year and

dividing by 2,000 lb/ton.

b.Emission Limitation:

10% opacity as a 3-minute average (fugitive emissions)

Applicable Compliance Method:

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

VI. Miscellaneous Requirements

None
278

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #1 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
279

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F001
280

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #2 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(B)

OAC rule 3745-17-08(B)

OAC 3745-31- (13) thru (20), and 40

CFR 52.21..

Applicable Emissions Limitations/Control

Measures

The requirements of this rule also include

compliance with the requirements of OAC

rule 3745-17-07(B), OAC rule

3745-17-08(B), OAC 3745-31- (13) thru

(20), and 40 CFR 52.21.

particulate matter (PM) emissions shall

not exceed 5.62 lb/hr and 24.6 tons per

year

10% opacity as a 3-minute average

(fugitive emissions)

The emission limitation specified by this

rule is less stringent than that established

above.

See section A.II.1 below.

The tons per rolling 12-month period shall

not exceed :

24.6 tons per year

2. Additional Terms and Conditions
281

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002

2.a The 5.62 lbs/hr limitation was established for PTI purposes to reflect the potential to emit 

for this emissions unit. Therefore, it is not necessary to develop record keeping and/or 

reporting requirements to ensure compliance with this limit.

II. Operational Restrictions

1.The permittee shall employ mist eliminators to minimize drift from the cooling tower.

III. Monitoring and/or Recordkeeping Requirements

1.PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports which identify all exceedances of the 5.62

lb/hr PM limitation.

2. The permittee shall submit deviation reports as specified in Part I - General Terms and Conditions
282

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002

of this permit under section (A)(2).

V. Testing Requirements

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

determined in accordance with the following method(s):
283

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002

a.Emission Limitation:

particulate matter (PM) emissions shall not exceed 5.62 lb/hr and 24.6 tons per year

Applicable Compliance Method:

Compliance shall be demonstrated in accordance with the

procedures from AP-42, Section 13.4 (1/95).

PM emissions (lb/hr) = WCR * Drift * TDS * [ (3.78L/gal)*(2.20E-06 lb/mg)*(60min/hr)

]

Where:

WCR = maximum water circulation rate, 749,342 gpm (based on compression phase for

turbines)

Drift = 0.0005%

TDS = total dissolved solids, 3,000mg/L

Compliance with the annual limitation shall be demonstrated by

multiplying the hourly PM emissions rate by actual hours/year and

dividing by 2,000 lb/ton.

b.Emission Limitation:

10% opacity as a 3-minute average (fugitive emissions)

Applicable Compliance Method:

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

VI. Miscellaneous Requirements

None
284

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #2 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
285

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F002
286

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #3 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

OAC rule 3745-17-07(B)

OAC rule 3745-17-08(B)

OAC 3745-31- (13) thru (20), 40

CFR 52.21, OAC 3745-31-05(D)

Applicable Emissions Limitations/Control

Measures

The requirements of this rule also include

compliance with the requirements of OAC

rule 3745-17-07(B), OAC rule

3745-17-08(B), OAC 3745-31- (13) thru

(20), and 40 CFR 52.21.

particulate matter (PM) emissions shall

not exceed 5.62 lb/hr and 24.6 tons per

year

10% opacity as a 3-minute average

(fugitive emissions)

The emission limitation specified by this

rule is less stringent than that established

above.

See section A.II.1 below.

The tons per rolling 12-month period shall

not exceed :

PM - 24.6 tons per year

2. Additional Terms and Conditions
287

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

2.a The 5.62 lbs/hr limitation was established for PTI purposes to reflect the potential to emit

for this emissions unit. Therefore, it is not necessary to develop record keeping and/or

reporting requirements to ensure compliance with this limit.
288

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

II. Operational Restrictions

1.The permittee shall employ mist eliminators to minimize drift from the cooling tower.

III. Monitoring and/or Recordkeeping Requirements

1.PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports which identify all exceedances of the 5.62

lb/hr PM limitation.

2. The permittee shall submit deviation reports as specified in Part I - General Terms and Conditions

of this permit under section (A)(2).

V. Testing Requirements
289

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

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

determined in accordance with the following method(s):
290

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

a.Emission Limitation:

particulate matter (PM) emissions shall not exceed 5.62 lb/hr and 24.6 tons per year

Applicable Compliance Method:

Compliance shall be demonstrated in accordance with the

procedures from AP-42, Section 13.4 (1/95).

PM emissions (lb/hr) = WCR * Drift * TDS * [ (3.78L/gal)*(2.20E-06 lb/mg)*(60min/hr)

]

Where:

WCR = maximum water circulation rate, 749,342 gpm (based on compression phase for

turbines)

Drift = 0.0005%

TDS = total dissolved solids, 3,000mg/L

Compliance with the annual limitation shall be demonstrated by

multiplying the hourly PM emissions rate by actual hours/year and

dividing by 2,000 lb/ton.

b.Emission Limitation:

10% opacity as a 3-minute average (fugitive emissions)

Applicable Compliance Method:

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

VI. Miscellaneous Requirements

None
291

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Cooling Tower #3 - induced

draft mechanical wet cooling

tower

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None
292

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: F003
293

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #1 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
294

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31- 05(D)

40 CFR Part 75

OAC rule 3745-103
295

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
296

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
297

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P001) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
298

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
299

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P001 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions 

specified in the following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000

1 - 6 5,948,800
300

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P001

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P001, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
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9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. The plan shall follow the requirements of

40CFR 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within
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30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.
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III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.
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The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the
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United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the
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emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by
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January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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:
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Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.

e. 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
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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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire
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clock-hour of the averaging period.

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year
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Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.
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d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the

unit operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation
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ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation
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Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P001 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 & maintenance manual, as provided by the manufacturer.
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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #1 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
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Emissions Unit ID: P001

None
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Emissions Unit ID: P001

VI. Miscellaneous Requirements

None
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Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #2 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
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OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

40 CFR part 60, Subpart Db

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
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Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20),

OAC 3745-31-05(D), 40

CFR 52.21, 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
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carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
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2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P002) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
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MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
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If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P002 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
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1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P002, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
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9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test
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results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the
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applicable standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

. b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or
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CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the
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Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD
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regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).
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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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.
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If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Kb 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);
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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:
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PTI Application: 16-02110

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Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.
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e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

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Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.
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Norton Energy Storage Facility ID: 1677100033

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b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by
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multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the

unit operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

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Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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Norton Energy Storage Facility ID: 1677100033

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g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.
342

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P002

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P002

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P002 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 & maintenance manual, as provided by the manufacturer.
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Norton Energy Storage Facility ID: 1677100033

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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #2 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
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Norton Energy Storage Facility ID: 1677100033

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None
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

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Emissions Unit ID: P002

VI. Miscellaneous Requirements

None
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P003

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #3 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

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OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P003

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
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carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
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2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P003) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
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Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P003

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
353

Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P003

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P003 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
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Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P003

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P003, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
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9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test
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results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,
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emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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.
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9. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each
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calendar quarter to the appropriate Ohio EPA District Office or local air agency documenting the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, and ORC sections 3704.03(I) and 3704.031, the permittee

shall submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The

summary shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, and ORC sections 3704.03(I) and 3704.031 and 40 CFR

Parts 60.7 and 60.13(h), 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 the date, commencement and completion times, duration, magnitude, reason (if

known), and corrective actions taken (if any) of all instances of CO values in excess of any

applicable limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s)

specified in the terms and conditions of this permit, in units of the standard. These reports shall

also contain the total CO emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to
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the appropriate Ohio EPA District Office or local air agency documenting any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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.
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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:
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Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or
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approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the
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CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.
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b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by
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multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 pmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.
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Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.
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Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P003 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 & maintenance manual, as provided by the manufacturer.
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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #3 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
372

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P003

None
373

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P003

VI. Miscellaneous Requirements

None
374

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #4 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
375

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
376

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20),

OAC 3745-31-05(D), 40

CFR 52.21, 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
377

Norton Energy Storage Facility ID: 1677100033

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Modification Issued: 5/23/2002

Emissions Unit ID: P004

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
378

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P004) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
379

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.

If the change(s) is (are) defined as a modification under other provisions of the modification
380

Norton Energy Storage Facility ID: 1677100033

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Modification Issued: 5/23/2002

Emissions Unit ID: P004

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P004 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000

1 - 6 5,948,800
381

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P004, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
382

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within
383

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to
384

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

ensure continuous valid and representative readings of O2 or CO2 emissions in units of the

applicable standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.
385

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS
386

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx
387

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement
388

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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,
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PTI Application: 16-02110

Modification Issued: 5/23/2002

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

Reports are to be sent to:
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.
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e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the

unit operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P004 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 & maintenance manual, as provided by the manufacturer.
398

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #4 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
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Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P004

None
400

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P004

VI. Miscellaneous Requirements

None
401

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #5 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

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OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
403

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P005) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
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Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P005

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8
407

Norton Energy Storage Facility ID: 1677100033

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Emissions Unit ID: P005

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.

If the change(s) is (are) defined as a modification under other provisions of the modification

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P005 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

After the first 12 calendar months following the startup of emissions unit P005, compliance with

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the

Ohio EPA, Central Office.

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 start-up of such emissions unit, the permittee

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

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

Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous NOx monitoring system designed to ensure

continuous valid and representative readings of NOx emissions in units of the applicable standard.

The plan shall follow the requirements of the appropriate sections 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.

9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by
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the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.
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12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span
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calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.
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11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).
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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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the
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emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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);
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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

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.
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d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

Initial compliance with the allowable outlet concentration, and the lbs/hr emission
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limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns
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Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.
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e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee
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shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.
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Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
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i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P005 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 & maintenance manual, as provided by the manufacturer.
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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #5 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
425

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

None
426

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P005

VI. Miscellaneous Requirements

None
427

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #6 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
428

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05 (A)(3) 40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
429

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
430

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
431

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P006) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
432

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
433

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P006 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
434

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P006, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
435

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test
436

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,
437

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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.
438

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

9. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each
439

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

calendar quarter to the appropriate Ohio EPA District Office or local air agency documenting the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to
440

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

the appropriate Ohio EPA District Office or local air agency documenting any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Dbof 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.
441

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

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:
442

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or
443

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the
444

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.
445

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by
446

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.
447

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
448

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.
449

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.
450

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P006 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 & maintenance manual, as provided by the manufacturer.
451

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #6 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
452

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

None
453

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P006

VI. Miscellaneous Requirements

None
454

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #7 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
455

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
456

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20),

OAC 3745-31-05(D), 40

CFR 52.21, 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
457

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
458

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P007) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
459

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
460

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P007 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
461

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P007

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P007, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
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9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall
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conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and
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recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

8. The permittee shall maintain records of the following information for each emissions unit:
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a. Number of startups, and the duration of each startup.

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

9. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports
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are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable
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limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.
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10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

b. The emission testing shall be conducted to demonstrate compliance with the NOx and CO
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outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:
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a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping
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required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.
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Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:
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Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P007 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
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of the operation & maintenance manual, as provided by the manufacturer.
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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #7 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
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None
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VI. Miscellaneous Requirements

None
479

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #8 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
480

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05

(A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
481

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Db.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
482

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
483

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P008) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
484

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
485

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P008 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
486

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P008, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
487

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008
488

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall
489

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and
490

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,

emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

8. The permittee shall maintain records of the following information for each emissions unit:
491

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

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

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

9. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports
492

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable
493

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

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 any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.
494

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

b. The emission testing shall be conducted to demonstrate compliance with the NOx and CO
495

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or

approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:
496

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the

CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping
497

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.
498

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation

ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:
499

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation

Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P008 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
500

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

of the operation & maintenance manual, as provided by the manufacturer.
501

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #8 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
502

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P008

None

VI. Miscellaneous Requirements

None
503

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. State and Federally Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #9 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)

OAC Rule 3745-31-05 (A)(3)
504

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

OAC Rule 3745-31-05

(A)(3)

OAC Rule 3745-31-05 (A)(3)

40 CFR part 60, Subpart GG

OAC rule 3745-18-06(F)

OAC Rule 3745-17-11 (B)(4)

OAC Rule 3745-17-07(A)

40 CFR part 60, Subpart Db

40 CFR 52.21

OAC rule 3745-31- (13) thru (20)

OAC rule 3745-31-05(D)

40 CFR Part 75

OAC rule 3745-103
505

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

Applicable Emissions

Limitations/Control

Measures

The requirements of this rule

also include compliance with

the requirements of OAC

rule 3745-17-07(A),

3745-17-11(B)(4), OAC rule

3745-18-06(F), OAC

3745-31- (13) thru (20), 40

CFR 52.21, OAC

3745-31-05(D), 40 CFR 60

Subpart GG and Kb.

EMISSION LIMITS

WITHOUT DUCT

BURNER FIRING

nitrogen oxides (NOx)

emissions shall not exceed

3.5 ppmvd at 15% Oxygen

and 14.5 lbs /hr

PM emissions shall not

exceed

12.0 lbs/hr

sulfur dioxide (SO2) shall not

exceed

1.98 lbs/hr

carbon monoxide (CO)

emissions shall not exceed

11.0 ppmvd at 15% Oxygen

and 23 lbs/hr

volatile organic compounds

(VOC) emissions shall not

exceed

4.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not

exceed

0.4512 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.198 lbs/hr

EMISSION LIMITS WITH DUCT

BURNER FIRING (limited to 4,160

hours per year)

nitrogen oxides (NOx) emissions shall

not exceed 3.5 ppmvd at 15%

Oxygen

and 16.0 lbs /hr

PM emissions shall not exceed

13.0 lbs/hr

sulfur dioxide (SO2) shall not exceed

2.55 lbs/hr

carbon monoxide (CO) emissions

shall not exceed 17.0 ppmvd at 15%

Oxygen

and 38.0 lbs/hr

volatile organic compounds (VOC)

emissions shall not exceed

7.0 lbs/hr

ammonia (NH3) emissions shall not

exceed

20.0 lbs/hr

formaldehyde emissions shall not exceed

0.472 lbs/hr

sulfuric acid mist emissions shall not

exceed

0.255 lbs/hr

STARTUP AND SHUTDOWN

EMISSIONS (also see A.II.3.)

nitrogen oxides (NOx) emissions shall not

exceed 4.42 tons per year

carbon monoxide (CO) emissions shall not

exceed 116.4 tons per year

volatile organic compounds (VOC)

emissions shall not exceed 1.76 tons per

year

formaldehyde emissions shall not exceed

0.1132 tons per year

TOTAL TONS PER YEAR

(including 4,160 hours per year with duct

burners, and 260 cycles

startups/shutdowns)

nitrogen oxides (NOx) emissions shall not

exceed

37.7 tons per year

PM emissions shall not exceed

27.0 tons per year

sulfur dioxide (SO2) shall not exceed

5.30 tons per year
506

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

carbon monoxide (CO)

emissions shall not exceed

195.4 tons per year

volatile organic compounds

(VOC) emissions shall not

exceed

16.3 tons per year

ammonia (NH3) emissions

shall not exceed

41.6 tons per year

formaldehyde emissions shall

not exceed

1.096 tons per year

sulfuric acid mist emissions

shall not exceed

0.53 tons per year

Visible particulate emissions

from any stack shall not

exceed 10 percent opacity as

a six-minute average

operational restriction, see

II. 1.

See section A.2.b below.

See section A.2.a below.

See section A.2.a below.

See section A.2.a below.

The tons per rolling

12-month period shall not

exceed :

NOx - 37.7

SO2 - 5.30

PM - 27.0

CO - 195.4

VOC - 16.3

The tons per rolling 12-month period

shall not exceed :

formaldehyde - 1.096

See section A.I.2.c below.

See section A.I.2.c below.
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Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

2. Additional Terms and Conditions

2.a The emissions limit based on this applicable rule is equivalent to or less stringent than the

limit established pursuant to OAC rule 3745-31-05.

2.b The emissions limits based on this applicable rule are equivalent to or less stringent than

the limits established pursuant to OAC rule 3745-31-05. Except as provided for in the

terms and conditions in this permit, the permittee is not exempt from meeting any

additional requirements of 40 CFR Part 60, Subpart GG.

2.c 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.

II. 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 0.6 grains per 100 standard cubic feet.

2. The permit to install for this emissions unit (P009) was evaluated based actual materials (typical

coatings and clean up materials) and the design parameters of the emissions unit's exhaust system,

as specified by the permittee in the air permit to install application. The Ohio EPA's "Review of

New Sources of Air Toxic Emissions" policy (Air Toxic Policy") was applied for each pollutant

emitted by this emissions unit using data from the permit to install application and the SCREEN

3.0 model ( or other Ohio EPA approved model). The predicted 1-hour maximum ground-level

concentration to the Maximum Acceptable Ground-Level Concentration (MAGLC). The

following summarizes the results of the modeling:

Pollutant: Formaldehyde

TLV (mg/m3): 273 (Converted from the STEL)

Maximum Hourly Emission Rate (lbs/hr): 4.45*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.74

MAGLC (ug/m3): 6.49

Pollutant: Toluene

TLV (mg/m3): 188

Maximum Hourly Emission Rate (lbs/hr): 1.36*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.23

MAGLC (ug/m3): 4,477

Pollutant: Xylene

TLV (mg/m3): 434

Maximum Hourly Emission Rate (lbs/hr): 0.67*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.11
508

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

MAGLC (ug/m3): 10,333

Pollutant: Sulfuric Acid Mist

TLV (mg/m3): 1

Maximum Hourly Emission Rate (lbs/hr): 2.30*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 0.38

MAGLC (ug/m3): 23.8

Pollutant: Ammonia

TLV (mg/m3): 17

Maximum Hourly Emission Rate (lbs/hr): 180*

Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 29.92

MAGLC (ug/m3): 404.8

* This was modeled for emissions units P001 through P009 combined.

Physical changes to or changes in the method of operation of the emissions unit after its

installation or modification could affect the parameters used to determine whether or not the "Air

Toxic Policy" is satisfied. Consequently, prior to making a change that could impact such

parameters, the permittee shall conduct an evaluation to determine that the "Air Toxic Policy" will

still be still satisfied. If, upon evaluation, the permittee determines that the "Air Toxic Policy" will

not be satisfied, the permittee will not make the change. Changes that can affect the parameters

used in applying the "Air Toxic Policy" include 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 compound with a lower Threshold Limit Value (TLV), as

indicated in the most recent version of the handbook entitled "American Conference of

Governmental Industrial Hygienists (ACGIH)," than the lowest TLV value specified in the

above table;

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

an increase in emissions of any pollutant with a listed TLV that was proposed in the

application and modeled; and

c. physical changes to the emissions unit or its exhaust parameters (e.g., increased/ decreased

exhaust flow, changes in stack height, changes in stack diameter, etc.).

3. If the permittee determines that the "Air Toxic Policy" 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(VV)(1)(a)(ii), and a modification of the existing permit to install will not be required.
509

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

If the change(s) is (are) defined as a modification under other provisions of the modification 

definition (other than (VV)(1)(a)(ii)), then the permittee shall obtain a final permit to install prior 

to the change.

4. The permittee shall collect, record, and retain the following information when it conducts 

evaluations to determine that the changed emissions unit will still satisfy the "Air Toxic Policy:"

a. a description of the parameters changed (composition of materials, new pollutants emitted, 

change in stack/exhaust parameters, etc.);

b. documentation of its evaluation and determination that the changed emissions unit still 

satisfies the "Air Toxic Policy"; and

c. where computer modeling is performed, a copy of the resulting computer model runs that 

show the results of the application of the "Air Toxic Policy" for the change.

5. Startup and Shut down shall be defined as when the unit is running at less than 70% of electric 

load, but under no circumstances shall startups exceed 30 minutes in duration and shutdowns shall 

not exceed 30 minutes in duration. Startup and shutdowns shall be limited to 260 cycles(one 

startup and one shutdown) per year. Each start up shall be a Hot Start, and any necessary 

heaters shall be utilized to ensure that only Hot Starts occur. Each start up and shutdown shall be 

limited to the following:

Pollutant total lbs/startup and one shutdown

NOx 34

CO 895

VOC 14 

Formaldehyde 0.87

6. The maximum cumulative fuel heat input for emissions unit P009 shall not exceed 5,948,800 

MMBtu based upon a rolling, 12-month summation.

To ensure enforceability during the first 12 calendar months following the startup of this 

emissions unit, the permittee shall not exceed the monthly heat input restrictions specified in the 

following table:

Month Cumulative Fuel Heat Input

(MMBtu) 

1 1,029,600

1 - 2 2,059,200

1 - 3 3,088,800

1 - 4 4,118,000

1 - 5 5,148,000
510

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

1 - 6 5,948,800

1 - 7 5,948,800

1 - 8 5,948,800

1 - 9 5,948,800

1 - 10 5,948,800

1 - 11 5,948,800

1 - 12 5,948,800

After the first 12 calendar months following the startup of emissions unit P009, compliance with 

the annual heat input restriction shall be based on a rolling, 12-month summation.

7. Continuous NOx Monitoring - Certified Systems

Statement of Certification

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 for approval by the 

Ohio EPA, Central Office. 

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 start-up of such emissions unit, the permittee 

shall conduct certification tests of such equipment pursuant to the appropriate sections of ORC 

section 3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 

75. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test 

results shall be submitted to the appropriate Ohio EPA District Office or local air agency within 

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio 

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the 

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

Office that the system meets all requirements of the appropriate sections of ORC section 

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 2, and 40 CFR Part 75.

8. Within 180 days prior to initial startup, the permittee shall develop a written quality 

assurance/quality control plan for the continuous NOx monitoring system designed to ensure 

continuous valid and representative readings of NOx emissions in units of the applicable standard. 

The plan shall follow the requirements of the appropriate sections 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.
511

Norton Energy Storage Facility ID: 1677100033

PTI Application: 16-02110

Modification Issued: 5/23/2002

Emissions Unit ID: P009

9. Continuous CO Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous 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 and 6 for approval by

the Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of the continuous CO monitoring system pursuant to ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 4 and 6. Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test results shall be

submitted to the appropriate Ohio EPA District Office or local air agency within 30 days after the

test is completed. Copies of the test results shall be sent to the appropriate Ohio EPA District

Office or local air agency and the Ohio EPA, Central Office. Certification of the continuous CO

monitoring system shall be granted upon determination by the Ohio EPA Central Office that the

system meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B,

Performance Specification 4 and 6.

10. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous CO monitoring system designed to ensure

continuous valid and representative readings of CO. 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.

11. Continuous O2 or CO2 Monitoring - Certified Systems

Statement of Certification

Prior to the installation of the continuous O2 or CO2 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 3 for approval by the

Ohio EPA, Central Office.

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 such emissions unit, the permittee shall

conduct certification tests of such equipment pursuant to the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

Personnel from 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. In accordance with OAC rule 3745-15-04, all copies of the test
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results shall be submitted to the appropriate Ohio EPA District Office or local air agency within

30 days after the test is completed. Copies of the test results shall be sent to the appropriate Ohio

EPA District Office or local air agency and the Ohio EPA, Central Office. Certification of the

continuous O2 or CO2 monitoring system shall be granted upon determination by the Ohio EPA,

Central Office that the system meets all requirements of the appropriate sections of ORC section

3704.03(I), 40 CFR Part 60, Appendix B, Performance Specification 3, and 40 CFR Part 75.

12. Within 180 days prior to initial startup, the permittee shall develop a written quality

assurance/quality control plan for the continuous O2 or CO2 monitoring system designed to ensure

continuous valid and representative readings of O2 or CO2 emissions in units of the applicable

standard. The plan shall follow the requirements of the appropriate sections 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 O2 or CO2 monitoring system must be kept on site and

available for inspection during regular office hours.

III. Monitoring and/or Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information for this emissions unit:

a. the natural gas usage rate for the month, in standard cubic feet;

b. monthly fuel heat input to the turbine, in MMBtu;

c. monthly fuel heat input to the duct burner, in MMBtu;

d. the total number hours the duct burner was being fired;

e. during the first 12 calendar months of operation, the permittee shall record the cumulative

fuel heat input to each combustion turbine and duct burner for each calendar month; and

f. beginning after the first 12 calendar months of operation, the rolling, 12-month summation

of the cumulative fuel heat input to each combustion turbine and duct burner.

2. The permittee shall operate and maintain existing equipment to continuously monitor and record

NOx from this emissions unit in units of the applicable standard. Such continuous monitoring and

recording equipment shall comply with the requirements of the appropriate sections specified in

40 CFR Part 60.13 and 40 CFR Part 75.

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

system including, but not limited to, parts per million NOx on an instantaneous (one-minute) basis,
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emissions of NOx in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span calibration

checks, and magnitude of manual calibration adjustments.

3. The permittee shall operate and maintain equipment to continuously monitor and record CO from

this emissions unit in units of the applicable standard. Such continuous monitoring and recording

equipment shall comply with the requirements specified in 40 CFR Part 60.13 .

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

including, but not limited to, parts per million CO on an instantaneous (one minute) basis,

emissions of CO in units of the applicable standard in the appropriate averaging period (e.g.,

hourly, hourly rolling, 3-hour, daily, 30-day rolling, annual, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

4. The permittee shall operate and maintain equipment to continuously monitor and record O2 or

CO2 from this emissions unit in percent O2 or CO2. Such continuous monitoring and recording

equipment shall comply with the requirements in the appropriate sections specified in 40 CFR Part

60.13 and 40 CFR Part 75.

The permittee shall maintain records of all data obtained by the continuous O2 or CO2 monitoring

system including, but not limited to, percent O2 or CO2 on an instantaneous (one-minute) basis,

emissions of O2 or CO2 in units of the applicable standard in the appropriate averaging period

(e.g., hourly, hourly rolling, 3-hour, daily, 30-day rolling, etc.), results of daily zero/span

calibration checks, and magnitude of manual calibration adjustments.

5. The permittee shall install, calibrate, operate, and maintain continuous monitoring systems to

monitor and record the average hourly fuel consumption of the combustion turbine and duct

burner. The fuel flow monitoring systems comply with the requirements of 40 CFR Part 75,

Appendix D.

6. The permittee shall monitor the sulfur content and gross calorific value of the fuel being fired in

the combustion turbine and duct burner. Fuel sampling and analysis shall be conducted according

to the procedures and at the frequency specified by 40 CFR Part 75, Appendix D.

7. The permittee shall determine the hourly heat input rate to the combustion turbine and duct burner

from the fuel flow rate as determined in term A.III.5 and fuel gross calorific value as determined

in term A.III.6. The heat input rate shall be calculated in accordance with the procedures in

Section 5 of 40 CFR Part 75, Appendix F.

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.
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9. The permittee shall maintain hourly records in lb(s)/hr of the emissions rate for NOx and CO

based upon an hourly averaging period as allowed in the appropriate sections of 40 CFR Part 60.

10. The permittee shall calculate and record, on an annual basis, the total facility mass emissions of

formaldehyde, in tons, from all emissions units (B001 - B018, F001 - F003, P001 - P009, 2

emergency generators, and diesel fuel pump) located at this facility.

11. PSD REQUIREMENTS

The source described in this Permit to Install is subject to the applicable provisions of the

Prevention of Significant Deterioration (PSD) regulations as promulgated by the United States

Environmental Protection Agency 40 CFR 52.21. The authority to apply and enforce the PSD

regulations has been delegated to the Ohio Environmental Protection Agency. The terms and

conditions of this permit and the requirements of the PSD regulations are also enforceable by the

United States Environmental Protection Agency.

In accordance with 40 CFR 124.15, 124.19 and 124.20, the following shall apply: (1) the effective

date of this permit shall be 30 days after the service of notice to any public commentors of the

final decision to issue, modify, or revoke and re-issue the permit, unless the service of notice is by

mail, in which case the effective date of the permit shall be 33 days after the service of notice; and

(2) if an appeal is made to the Environmental Appeals Board of the United States Environmental

Protection Agency, the effective date of the permit is suspended until such time as the appeal is

resolved or denied.

Appeals will be addressed to:

United States Environmental Protection Agency

Environmental Appeals Board

401 M Street, SW (MC-113do)

Washington, DC 20460

IV. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify each day when a fuel other

than natural gas was burned in this emissions unit. Each report shall be submitted within 30 days

after the deviation occurred.

2. The permittee shall submit deviation (excursion) reports which identify all exceedances of the

rolling, 12-month cumulative fuel heat input limitation and, for the first 12 calendar months of

operation, all exceedances of the maximum allowable cumulative heat input levels. These reports

are due by the date described in Part 1 - General Terms and Conditions of this permit under

section (A)(2).

3. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each
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calendar quarter to the appropriate Ohio EPA District Office or local air agency documenting the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any), of all instances of NOx values in excess of the applicable limits

specified in 40 CFR Part 76 and any limitations specified in the terms and conditions of this permit

or variance. These reports shall also contain the total NOx emissions for the calendar quarter (in

tons).

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 any continuous NOx

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line also shall be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

4. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031, the permittee shall

submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary

shall be submitted to the appropriate Ohio EPA District Office or local air agency within 30 days

following the end of each calendar quarter in a manner prescribed by the Director.

5. Pursuant to OAC rule 3745-15-04, ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts

60.7 and 60.13(h), 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 the

date, commencement and completion times, duration, magnitude, reason (if known), and

corrective actions taken (if any) of all instances of CO values in excess of any applicable

limitation(s) specified in OAC Chapter 3745-21, 40 CFR Part 60, or any limitation(s) specified in

the terms and conditions of this permit, in units of the standard. These reports shall also contain

the total CO emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to
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the appropriate Ohio EPA District Office or local air agency documenting any continuous CO

monitoring system downtime while the emissions unit was on line (date, time, duration and

reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit

operating time during the reporting period and the date, time, reason and corrective action(s)

taken for each time period of emissions unit and control equipment malfunctions. The total

operating time of the emissions unit and the total operating time of the analyzer while the

emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement

to that effect along with the emissions unit operating time during the reporting period and the

date, time, reason, and corrective action(s) taken for each time period of emissions unit, control

equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit

and the total operating time of the analyzer while the emissions unit was on line shall also be

included in the quarterly report. These quarterly excess emission reports shall be submitted by

January 30, April 30, July 30, and October 30 of each year and shall address the data obtained

during the previous calendar quarter.

6. Pursuant to 40 CFR Parts 60.7 and 60.13(h), 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 continuous O2 or CO2 monitoring system downtime while the

emissions unit was on line (date, time, duration and reason) along with any corrective action(s)

taken. The permittee shall provide the emissions unit operating time during the reporting period

and the date, time, reason and corrective action(s) taken for each time period of emissions unit

malfunctions. The total operating time of the emissions unit and the total operating time of the

analyzer while the emissions unit was on line shall be included in the quarterly report. These

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

and shall address the data obtained during the previous calendar quarter.

7. The permittee shall submit deviation (excursion) reports that identify any record which shows that

the sulfur content of the natural gas exceeded 0.6 grains per 100 standard cubic foot. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

8. The permittee shall submit deviation (excursion) reports that identify each time when this

emissions unit was not in compliance with the requirements of condition A.II.3. above. These

reports are due by the date described in Part I - General Terms and Conditions of this permit

under section (A)(2).

9. In lieu of the excess emissions reports required under 40 CFR Part 60.334, the permittee shall

submit excess emissions reports for emissions unit P001 in accordance with this permit.

10. This emissions unit is subject to the applicable provisions of Subparts GG and Db 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.
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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:
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Ohio Environmental Protection Agency

DAPC - Permit Management Unit

P. O. Box 163669

Columbus, Ohio 43216-3669

and

Akron RAQMD

Room 904

146 S. High Street

Akron, OH 44308

11.The permittee shall submit annual reports that specify the total facility mass emissions of

formaldehyde, in tons. These reports shall include the emission calculations, shall be submitted by

April 30, and shall contain information for the previous calendar year.

V. Testing Requirements

1. 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 such emissions unit.

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

outlet concentration, and the mass emissions limitations for NOx,* CO, Formaldehyde,

VOC PM, and visible emission limitation.

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

emissions limitations: for NOx, Method 20 of 40 CFR Part 60, Appendix A; for PM,

Method 5 of 40 CFR Part 60, Appendix A; for visible emission limitations, Method 9, 40

CFR Part 60 Appendix A; for Formaldehyde, SW-846 Method 0011; for VOC Method

25 of 40 CFR Part 60, Appendix A; and for CO Method 10 of 40 CFR Part 60, Appendix

A. Alternative U.S. EPA approved test methods may be used with prior approval from the

Ohio EPA.

d. The testing shall be conducted while the emissions unit is operating at or near its

maximum capacity with and without duct burner firing, unless otherwise specified or
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approved by Ohio EPA or local air agency.

e. 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 appropriate Ohio

EPA District Office or local air agency refusal to accept the results of the emission test(s).

f. 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.

g. 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.

* Using the test methods and procedures required under 40 CFR Part 60.335.

2. Compliance with the allowable emission limitations in this permit shall be determined according to

the following methods:

a. Emission Limitation

NOx emissions shall not exceed 3.5 ppmvd at 15% Oxygen

14.5 lbs/hr without duct burner firing

16.0 lbs/hr with duct burner firing

37.7 tons per year, which includes 4.42 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition V.1

and continual compliance with those limitations shall be demonstrated by the use of the
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CEM in condition A.III.2. based upon an hourly averaging period as allowed in 40 CFR

Part 60. Compliance with the annual emission limitation shall be determined by the record

keeping required in condition A.III.2 and A.III.9. The annual emissions associated with

start-up and shut-down shall be demonstrated by the record keeping required in condition

A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3. Compliance with

the 3.5 ppmvd limit is required only when the unit operates above 70% load for the entire

clock-hour of the averaging period.

b. Emission Limitation

PM emissions shall not exceed

12.0 lbs/hr without duct burner firing

13.0 lbs/hr with duct burner firing

27.0 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

c. Emission Limitation

SO2 emissions shall not exceed

1.98 lbs/hr without duct burner firing

2.55 lbs/hr with duct burner firing

5.30 tons per year

Applicable Compliance Method

Compliance with the hourly emission limitation shall be determined by the record keeping

required in conditions A.III.1 and 6. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.
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d. Emission Limitation

VOC emissions shall not exceed

4.0 lbs/hr without duct burner firing

7.0 lbs/hr with duct burner firing

16.3 tons per year, which includes 1.76 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr limitations shall be demonstrated by the performance testing in

condition A.V.1. Compliance with the annual emission limitation shall be determined by

multiplying the hourly emission rate by the actual annual hours of operation and dividing

by 2000 lbs/ton. The annual emissions associated with start-up and shut-down shall be

determined by the record keeping required in condition A.III.8. using the lbs/ start-up and

shut-down values in condition II.3.

e. Emission Limitation

CO emissions shall not exceed

11 ppmvd at 15% Oxygen without duct burner firing

17 ppmvd at 15% Oxygen with duct burner firing

23.0 lbs/hr without duct burner firing

38.0 lbs/hr with duct burner firing

195.4 tons per year, which includes 116.4 tons for startups and shutdowns

Applicable Compliance Method

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

limitations shall be demonstrated by the performance testing as described in condition

A.V.1 and continual compliance with those limitations shall be demonstrated by the use of

the CEM in condition A.III.3. based upon an hourly averaging period as allowed in 40

CFR Part 60. Compliance with the annual emission limitation shall be determined by the

record keeping required in condition A.III.3 and A.III.9. The annual emissions associated

with start-up and shut-down shall be determined by the record keeping required in

condition A.III.8. using the lbs/ start-up and shut-down values in condition A.II.3.

Compliance with the 11 ppmvd limit and the 17 ppmvd limit is required only when the unit

operates above 70% load for the entire clock-hour of the averaging period.

f. Emission Limitation
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ammonia (NH3) emissions shall not exceed

20.0 lbs/hr without duct burner firing

20.0 lbs/hr with duct burner firing

41.6 tons per year

Applicable Compliance Method

Compliance with the lbs/hr emission limitation shall be demonstrated by multiplying the

emission factor of 0.0173 pound of ammonia/MMBtu heat input (emission factor supplied

by the permittee) by the maximum Btu rating. If required, the permittee shall demonstrate

compliance by emission testing in accordance with approved US EPA test methods.

Compliance with the annual emission limitation shall be determined by multiplying the

hourly emission rate by the actual annual hours of operation and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

g. Emission Limitation

Formaldehyde emissions shall not exceed

0.4512 lbs/hr without duct burner firing

0.472 lbs/hr with duct burner firing

1.096 tons per year, which includes 0.1132 tons for startups and shutdowns

Applicable Compliance Method

Compliance with the lbs/hr emission limitations shall be demonstrated by the performance

testing in condition A.V.1. Compliance with the annual emission limitation shall be

determined in the following manner:

Annual Emissions (tpy) = (Hours * EF + ∑ StartEF ) / 2000

Where:

Hours = actual annual hours of operation

EF = lb/hr formaldehyde emission rate based on stack test result

StartEF =pounds of emissions allocated to each start-up/shutdown cycle

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

h. Emission Limitation
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Sulfuric acid mist (H2SO4) emissions shall not exceed

0.198 lbs/hr without duct burner firing

0.255 lbs/hr with duct burner firing

0.53 tons per year

Applicable Compliance Method

Compliance with the lb/hr emission limitation shall be demonstrated by multiplying the

SO2 hourly emission rate by 10% (emission factor supplied by the permittee). If required,

the permittee shall demonstrate compliance by emission testing in accordance with

approved US EPA test methods. Compliance with the annual emission limitation shall be

determined by multiplying the hourly emission rate by the actual annual hours of operation

and dividing by 2000 lbs/ton.

Should more accurate emission factors be developed, the permittee

shall use them, provided the new emission factors are mutually

agreeable to the Ohio EPA, the Akron RAQMD and Norton

Energy Storage.

i. Emission Limitation

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

six-minute average.

Applicable Compliance Method

Compliance with the visible emissions limitation established by this permit shall be

determined by Method 9, 40 CFR Part 60 Appendix A.

VI. Miscellaneous Requirements

1. In accordance with good engineering practices, the SCR unit on emissions unit P009 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 & maintenance manual, as provided by the manufacturer.
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B. State Only Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are

listed in the following table along with the applicable rules and/or requirements and with the

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

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

following the table.

Operations, Property,

and/or Equipment

Combustion Turbine #9 -

300 MW Alstom ET-11NM

natural gas-fired dry low

NOx (DLN) combustion

turbine with 283 MMBtu/hr

duct burner operating in

combined cycle mode

controlled by Selective

Catalytic Reduction (SCR)

Applicable Rules/Requirements

OAC rule 3745-31-05

Applicable Emissions Limitations/Control

Measures

None

2. Additional Terms and Conditions

2.a None

II. Operational Restrictions

None

III. Monitoring and/or Recordkeeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements
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None
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VI. Miscellaneous Requirements

None