John R. Kasich , Governor Mary Taylor, Lt. Governor Craig W. Butler, Director

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216

- 1049 www.epa.ohio.gov • (614) 644

- 3020 • (614) 644

- 3184 (fax) 11/5/2014
Mr. Michael Schuster NTE Ohio, LLC 24 Cathedral Place, Suite 300 St. Augustine, FL 32084 RE: FINALAIR POLLUTION PERMIT
-TO
- INSTALL Facility ID: 1409001151 Permit Number: P0116610 Permit Type: Initial Installation County: Butler Dear Permit Holder: Enclosed please fi nd a final Ohio Environmental Protection Agency (EPA)Air Pollution Permit
-to
- Install (PTI) which will allow you to install or modify the described emissions unit(s) in a manner indicated in the permit. Because this permit contains several conditions and restrictions, we urge you to read it carefully. Because this permit contains conditions and restrictions, please read it very carefully. In this letter you will find the information on the following topics:

 How to appeal this permit  How to save money, reduce pollution and reduce energy consumption
 How to give us feedback on your permitting experience
 How to get an electronic copy of your permit How to appeal this permit The issuance of this PTI is a final action of the Director and may be appealed to the Environmental Review Appeals Commission pursuant to Section 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. The appeal must be filed with the Commission within thirty (30) days after notice of the Director's action. The appeal must be accompanied by a filing fee of $70.00, made payable to "Ohio Treasurer Josh Mandel, " which the Commission, in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would cause extreme hardship. N otice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General 's Office, Environmental Enfo rcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 77 South High Street, 17th Floor Columbus, OH 43215 Certified Mail
Yes TOXIC REVIEW Yes PSD Yes SYNTHETIC MINOR TO AVOID MAJOR NSR Yes CEMS Yes MACT/GACT Yes NSPS No NESHAPS No NETTING No MAJOR NON
-ATTAINMENT Yes MODELING SUBMITTED Yes MAJOR GHG No SYNTHETIC MINOR TO AVOID MAJOR GHGHow to save money, reduce pollution and reduce energy consumption The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. N ot only will this reduce pollution and energy consumption, but it can also save you money. If you would like to learn ways you can save money while protecting the environment, please contact our Office of Compliance Assistance and Pollution Prevention at (614) 644
-3469. Additionally, all or a portion of the capital expenditures related to installing air pollution control equipment under this permit may be eligible for financing and State tax exemptions through the Ohio Air Quality Development Authority (OAQDA) under Ohio Revised Code Section 3706. For more information, see the OAQDA website: www.ohioairquality.org/clean_air How to give us feedback on your permitting experience Please complete a survey at www.epa.ohio.gov/survey.aspx and give us feedback on your permitting experience. We value your opinion. How to get an electronic copy of your permit This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or in Adobe PDF on the Division of Air Pollution Control (DAPC) We b page, www.epa.ohio.gov/dapc by clicking the "Search for Permits" link under the Permitting topic on the Programs tab. If you have any questions, please contact Southwest Ohio Air Quality Agency at (513)946
-7777 or the Office of Compliance Assistance and Pollution Prevention at (614) 644
-3469. Sincerely, Erica R. Engel
- Ishida , Manager Permit Issuance and Data Management Section, DAPC Cc: U.S. EPA SW OAQA; Indiana; Kentucky

# FINAL

Division of Air Pollution Control Permit-to -Install for NTE Ohio, LLC

Facility ID: 1409001151 Permit Number: P0116610 Permit Type: Initial Installation Issued: 11/5/2014 Effective: 11/5/2014

### Division of Air Pollution Control Permit-to -Install for NTE Ohio, LLC Table of Contents Authorization

................................ ................................ ................................ ................................ ..................... 1 A. Standard Terms and Conditions

................................ ................................ ................................ .................. 3 1. Federally Enforceable Standard Terms and Conditions

................................ ................................ ......... 4 2. Severability Clause

................................ ................................ ................................ ................................ 4 3. General Requirements

................................ ................................ ................................ ........................... 4 4. Monitoring and Related Record Keeping and Reporting Requirements

................................ .................. 5 5. Scheduled Maintenance/Malfunction Reporting

................................ ................................ ..................... 6 6. Compliance Requirements

................................ ................................ ................................ ..................... 6 7. Best Available Technology

................................ ................................ ................................ ..................... 7 8. Air Pollution Nuisance

................................ ................................ ................................ ............................ 8 9. Reporting Requirements

................................ ................................ ................................ ........................ 8 10. Appl icability

................................ ................................ ................................ ................................ ............ 8 11. Construction of New Sources(s) and Authorization to Install

................................ ................................ .. 8 12. Permit
-To
-Operate Application

................................ ................................ ................................ ............... 9 13. Construction Compliance Certification

................................ ................................ ................................ . 10 14. Public Disclosure

................................ ................................ ................................ ................................ . 10 15. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

................... 10 16. Fees

................................ ................................ ................................ ................................ ..................... 10 17. Permit Transfers

................................ ................................ ................................ ................................ .. 10 18. Risk Management Plans

................................ ................................ ................................ ...................... 10 19. Title IV Provisions

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

................................ ................................ ................................ ........... 11 C. Emissions Unit Terms and Conditions

................................ ................................ ................................ ....... 15 1. B001, Auxiliary Boiler

................................ ................................ ................................ ........................... 16 2. P001, CT+HRSG M501JAC or M501GAC

................................ ................................ ........................... 27 3. P002, Emergency Generator

................................ ................................ ................................ ................ 57 4. P003, Emergency Fire Pump Engine

................................ ................................ ................................ ... 67 5. P004, Cooling Tower

................................ ................................ ................................ ............................ 77Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 1 of 81 

# Au thorization Facility ID: 1409001151 Facility Description: Combined
-cycle, natural gas
-fired power plant Application Number(s): A0050416, A0050480, A0051818 Permit Number: P0116610 Permit Description: Initial installation of either one (1) Mitsubishi Hitachi Power Systems Am ericas M501JAC or one (1) Mitsubishi Hitachi Power Systems Americas M501GAC single power block in a 1x1 combined
cycle multi
-shaft configuration, including a combustion turbine and heat recov ery steam generator with duct burners and a steam turbine to be known as the Middletown Energy Center. Permit Type: Initial Installation Permit Fee: $3,000.00 Issue Date: 11/5/2014 Effective Date: 11/5/2014 This document constitutes issuance to : NTE Ohio, LLC South of Oxford State Rd west of Cincinnati Dayton Rd Middletown, OH 45044
of a Permit
-to
- Install for the emissions unit(s) identified on the following page. Ohio Environmental Protection Agency ( EPA) District Office or local air agency responsible for processing and administering your permit: Southwest Ohio Air Quality Agency 250 William Howard Taft Rd. Cincinnati, OH 45219 (513)946
-7777 The abov e named entity is hereby granted a Permit
-to
- Install for the emissions unit(s) listed in this section pursuant to Chapter 3745
-31 of the Ohio Administrative Code. Issuance of this perm it does not constitute ex pressed or implied approv al or agreement that, if constructed or modified in accordance with the plans included in the application, the emissions unit(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 and specifications, the abov e described emissions unit(s) of pollutants will be granted the necessary pe rmits to operate (air) or NPDES permits as applicable. This permit is granted subject to the conditions attached hereto. Ohio Environmental Protection Agency Craig W. Butler DirectorFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 2 of 81 

# Au thorization (continued)
Permit Number: P0116610 Permit Description: Initial installation of either one (1) Mitsubishi Hitachi Power Systems Americas M501JAC

or one (1) M itsubishi Hitachi Power Systems Americas M501GAC single power block in a 1x 1 com bined
-cycle multi
-shaft configuration, including a combustion turbine and heat recovery steam generator with duct burners and a steam turbine to be known as the Middletown Energy Center. Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below: Emissions Unit ID : B001 Com pany Equipment ID : Aux Bioler Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : B002 Com pany Equipment ID : Fuel Gas Heater Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : B003 Com pany Equipment ID : Fuel Gas Heater Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : P001 Com pany Equipment ID : CT+HRSG M501JAC or M501GAC Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : P002 Com pany Equipment ID : Em ergency Generator Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : P003 Com pany Equipment ID : Em ergency Fire Pump Engine Superseded Permit Number: General Permit Category and Type : Not Applicable Emissions Unit ID : P004 Com pany Equipment ID : Cooling Tower Superseded Permit Number: General Permit Category and Type : Not ApplicableFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 3 of 81 

# A. Standard Terms and ConditionsFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 4 of 81 1. Federally Enforceable Standard Terms and Conditions a) All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only: (1) Standard Term and Condition A. 2

. a) , Severability Clause (2) Standard Term and Condition A. 3

. c) through A. 3.e)General Requirements (3) Standard Term and Condition A. 6

. c) and A. 6.d) , Compliance Requirements (4) Standard Term and Condition A. 9 ., Reporting Requirements (5) Standard Term and Condition A. 10 ., Applicability (6) Standard Term and Condition A. 11

. b) through A.11.e) , Construction of New Source(s) and Authorization to Install (7) Standard Term and Condition A. 14., Public Disclosure (8) Standard Term and Condition A. 15., Additio nal Reporting Requirements Wh en There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations (9) Standard Term and Condition A. 16., Fees (10) Standard Term and Condition A. 17., Pe rmit Transfers 2. Severability Clause a) 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 declared invalid

. b) All terms and conditions designated in parts B and C of this permit are federally enforceable as a practical matter, if

they are 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 and the State and by citizens (to the extent allowed by section 304 of the Act) under the Act. Terms and conditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if s pecifically identified in this permit as such

. 3. General Requirements a) 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 re
- issuance, or modification.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 5 of 81 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, 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 or revoking this permit or to determine compliance with this permit. U pon 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

. 4. Monitoring and Related Record Keeping and Reporting Requirements a) Except as may otherwise be provided in the terms and conditions for as pe cific emissions unit, the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit : (1) The date, place (as defined in the permit), and time of sampling or measurements. (2) The d ate(s) analyses were performed. (3) The company or entity that performed the analyses. (4) The analyti cal techniques or methods used. (5) The results of such analyses. (6) The operating conditions existing at the ti me of sampling or measurement. b) Each record of any monitoring data, testin g 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 as pecific emissions unit, the permittee shall submit required reports in the following manner: (1) Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Southwest Ohio Air Quality Agency.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 6 of 81 (2) Quarterly written reports of (i) any deviations from federally enforceable emissionlimitations , operationalrestrictions , andcontroldeviceoperatingparameterlimitations , 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 Southwest Ohio Air Quality Agency. The written reports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. See A.15. below if no deviations occurred during the quarter. (3) Written reports, which identify any deviations from the federally enforceable monitoring , recordkeeping , andreportingrequirements contained in this permit shall be submitted to the Southwest Ohio Air Quality Agency every six months, by January 31 and July 31 of each year for the previous six calendar months. If n o deviations occurred during a six
month period, the permittee shall submit a semi
-annual report, which states that no devi ations occurred during that period

. (4) This permit is for an emissions unit located at a Title V facility. 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

. d) The permittee shall report actual emissions pursuant to OAC Chapter 3745
-78 for the purpose of collecting Air Pollution Control Fees

. 5. 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 Southwest Ohio Air Quality Agencyin 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 sub mitted 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) th at is (are) served by such control system(s)

. 6. Compliance Requirements a) All applications, notifications or reports required by terms and conditions in this permit to be submitted or " reported in writing " are to be submitted to Ohio EPA through the Ohio EPA's eBusiness Center: Air Services web service ("Air Services" ). Ohio EPA will accept hard copy submittals on a n as-needed basis if the permittee cannot submit the required documents throug h the Ohio EPA eBusiness Center

. In the event of an alternative hard copy submission in lieu of the eBusiness Center, the post
- marked date or the date the document is delivered in person will be recognized as the date submitted. Electronic submission of applications, notifications or reports required to be submitted to Ohio EPA fulfills the requirement to submit the required information to the Director, the appropriate Ohio EPA District Office or contractedFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 7 of 81 local air agency, and/or any other individual or organization specifically identified as an additio nal recipient identified in this permit unless otherwise specified. Consistent with OAC rule 3745
- 15
-03, the electronic signature date shall constitute the date that the required application, notification or report is considered to be "submitted "

. Any docu ment requiring s ignature may be represented by entry of the personal identification number (PIN) by responsible official as part of the electronic submission process or by the scanned attestation document signed by the Authorized Representative that is attached to the electronically submitted written report

. 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 Di rector of the Ohio EPA or an authorized representative of the Director to : (1) 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

. (2) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit, subject to the protection fr om disclosure to the public of confidential information consistent with ORC section 3704.08

. (3) Inspe ct at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit

. (4) 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 Southwest Ohio Air Quality Agency concerning any schedule of compliance for meeting an applicable requirement. P rogress reports shall be submitted semiannually or more frequently if s pecified in the applicable requirement or by the Director of the Ohio EPA. Progress reports shall contain the following : (1) Dates for achieving the activities, milestones, or compliance r equired in any schedule of compliance, and dates when such activities, milestones, or compliance were achieved

. (2) 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. Best Available Technology As specified in OAC Rule 3745
-31
-05, new sources that must employ Best Available Technology (BAT) shall comply with the Applicable Emission Limitations/Control Measures identified as BAT for each subject emissions unit

.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 8 of 81 8. Air Pollution Nuisance The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in vi olation of OAC rule 3745
- 15
-07

. 9. Reporting 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 Southwest Ohio Air Quality Agency

. b) Except as otherwise may be provided in the terms and conditions for as pecific emissions unit, quar terly written reports of (a) any deviations (excursions) fr om state
-only required emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and recordkeeping requi rements 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 Southwest Ohio Air Quality 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, by January 31, April 30, July 31, and October 31 of each year and shall cover th e previous calendar quarters. (These quarterly reports shall exclude deviations resulting from malfunctions reported in accordance with OAC rule 3745
- 15
-06.) 10. Applicability This Permit
-to
- Install is applicable only to the emissions unit(s) identified in th e Permit
-to
- Install

. Separate application must be made to the Director for the installation or modification of any other emissions unit(s) not exempt from the requirement to obtain a Permit
-to
- Install

. 11. Construction of New Sources(s) and Authorization to In stall a) This permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. This permit does not constitute expressed or implied assurance that the proposed facility has been constructed in a ccordance with the application and terms and conditions of this permit. 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 this permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. I ssuance of this permit 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

. b) If applicable, authorization to install any new emissions unit included in this permit shall terminate within eighteen months of the effective date of the permit if the owner or operator has not undertaken a continuing program of installation or has not entered into a binding contractual obligation to undertake and complete within a reasonable time a continuing program of installation. This deadline may be extended by up to 12 months if a pplication is made to theFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 9 of 81 Director within a reasonable time before th e termination date and the permittee shows good cause for any such extension

. c) The permittee may notify Ohio EPA of any emissions unit that is permanently shut down (i.e., the emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent " modification " or " installation " as defined in OAC Chapter 3745
-31) by submitting a certification from the authorized official that identifies the date on which the emissions unit was permanently shut down. Authorization to operate the affected emissions unit shall cease upon the date certified by the authorized official that the emissions unit was permanently shut down. At a minimum, notification of permanent shut down shall be made or confirmed by marking the affected emissions unit(s) as " permanently shut down " in "Air Services" alon g with the date the emissions unit(s) was permanently removed and/or disabled. Submitting the facility profile update electronically will constitute notifying the Director of the permanent shutdown of the affected emissions unit(s)

. d) The provisions of this permit shall cease to be enforceable for each affected emissions unit after the date on which an emissions unit is permanently shut down (i.e., emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent " modification " or " installation " as defined in OAC Chapter 3745
-31). All records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with l aw. All reports required by this permit must be submitted for any period an affected emissions unit operated prior to permanent shut down. At a minimum, the permit requirements must be evaluated as part of the reporting requirements identified in this pe rmit covering the last period the emissions unit operated. Unless otherwise exempted, n o emissions unit certified by the responsible official as being permanently shut down may resume operation without first applying for and obtaining a permit pursuant to OAC Chapter 3745
-31 and OAC Chapter 3745
-77 if the restarted operation is subject to one or more applicable requirements

. e) The permittee shall comply with any residual requirements related to this permit, such as the requirement to submit a deviation report , air fee emission report, or other any reporting required by this permit for the period the operating provisions of this permit were enforceable, or as required by regulation or law. All reports shall be submitted in a form and manner prescribed by the D irector. All records relating to this permit must be maintained in accordance with law

. 12. Permit-To -Operate Application 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 operation of the proposed new or modified source(s) as authorized by this permit would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit modification of such new or modified source(s) pursuant to OAC rule 3745
-77
-04(D) and OAC rule 3745
-77
-08(C)(3)(d)must be obtained beforeoperating the source in a manner that would violate the existing Title V permit requirements

.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 10 of 81 13. Construction Compliance Certification The applicant shall identify the following dates in the "Air Services"facility profile for each new em issions unit identified in this permit

. a) Completion of initial installation date shall be enteredupon completion of construction and prior to start
-up
. b) Commence operation after installation or latest modification date shall be entered within 90 days after commencing operation of the applicable emissions unit

. 14. 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

. 15. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations 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 by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters

. 16. 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 any permit
-to
- install

. The permittee shall pay all applicable permit
-to
-operate fees within thirty days of the issuance of the invoice

. 17. Permit Transfers Any transferee of this permit shall assume the responsibilities of the prior permit holder. The new owner must update and subm it the ownership information via the "Owner/Contact Change " functionality in "Air Services" once the transfer is legally completed.The change must be submitted through "Air Services" within thirty days of the ownership transfer date

. 18. 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

. 19. 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

.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 11 of 81 

# B. Facility-Wide Terms and ConditionsFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 12 of 81 1. All the following facility
-wide terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only: a) None. 2. The permittee shall ensure that any emissions unit(s) subject to the Clean Air Interstate Rule (CAIR) complies/comply with the requirements of the Ohio Administrative Code (OAC) Chapter 3745
- 109, which includes submitting timely permit applications. 3. The following emissions unit contained in this permit is subject to 40 CFR Part 60 Subpart A and Db: B001 (150 MMBtu/hr natural gas fired boiler). The complete NSPS requirements, including the NSPS General Provisions may be accessed via the internet fr om the electronic Code of Federal Regulations (e
-CFR) website www.ecfr.gov or by contacting the appropriate Ohio EPA district or local air agency. 4. The following emissions units contained in this permit are subject to 40 CFR Part 60 Subpart A and IIII: P002 and P003 (diesel fired emergency standby generator and emergency fire pump). The complete NSPS requirements, including the NSPS General Provision s may be accessed via the internet from the electronic Code of Federal Regulations (e
-CFR) website www.ecfr.gov or by contacting the appropriate Ohio EPA district or local air agency. 5. The following emissions unit contained in this permit is subject to 40 CFR Part 60 Subpart A and KKKK: P001 (CC CTG). The complete NSPS requirements, including the NSPS General Provisions may be accessed via the internet from the electronic Code of Federal Regulations (e
-CFR) website www.ecfr.gov or by contacting the appropriate Ohio EPA district or local air agency. 6. The following emissions units contained in this permit are subject to 40 CFR Part 63 Subpart A and ZZZZ: P002 and P003 (diesel fired emergency standby generator and emergency fire pump). The complete MACT requirements, including the MACT General Provisions may be accessed via the internet from the electronic Code of Federal Regulations (e
-CFR) website www.ecfr.gov or by contacting the appropriate Ohio EPA district or local air agency. 7. The following emissions units are also part of this project:

Emission Unit Description Emission

Unit ID# BACT Emissions, tons per year (TPY) 9 MMBtu/hr. fuel gas/dew
point heater B002 The permittee shall only operate one (1) fuel gas/dew
- point heater at a time, or, if both units are operated simultaneously, each shall be operated at no more than 50% load; Each fuel gas/dew
- point heater shall employ ULN burners, good combustion practices (GCP), and the exclusive use of natural gas as a fuel to satisfy BACT. Emissions from B002 and B003, combined, shall not exceed: 0.43 TPY of NOx per rolling, 12
- month period; 3.15 TPY CO per rolling, 12
- month period; 0.197 TPY VOC per rolling, 12
- mo nth period; 0.276 TPY PE/PM10/PM2.5 per rolling, 12
- month period; 6.76E
-03 TPY H 2SO 4 per rolling, 12
- month period; 4,716 TPY of 9 MMBtu/hr. fuel gas/dew
B003Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 13 of 81 point heater CO2e per rolling, 12
- month period. All TPY figures are based on 8760 hours per year of operation, 2 units, only 1 operating at a time or, if 2 units operating, not >50% each. Natural Gas Piping Fugitives Daily audio/visual/olfactory inspection walk
-throughs for piping components in natural gas service. 73.0 TPY of CO2e per rolling, 12
- month period. Natural Gas Maintenance + SU/SD Venting Standard industry work practice and minimize startups and shutdowns to the extent that is practical. 170.0 TPY of CO2e per rolling, 12
- month period.
SF6 Circuit Breakers Equipment design specifications

– low pressure alarm and a low pressure lockout. 132.8 TPY of CO2e per rolling, 12
- month period.
8. Abbreviations used throughout the permit: CC Combined Cycle CTG Combustion Turbine Generator DB Duct Burner MW MegaWatt NG Natural Gas HRSG Heat Recovery Steam Generator MMBtu /hr Mi llion(s) of British thermal units per hour MMscf Mi llion(s) of standard cubic feet Lb/MMBtu Pound(s) per Million British thermal units Lb/MW
- hr Pound(s) per Mega Watt
- hour Lbs/hr Pound(s) per hour g/hp
- hr Grams per horsepower
- hour g/Lb Grams per pound DLN Dry Low NOx ULN Ultra Low NOxFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 14 of 81 SCR Selective Catalytic Reduction CEMS Continuous Emissions Monitoring System OAC Ohio Administrative Code ORC Ohio Revised Code BAT Best Available Technology PTE Potential to Emit PTI Permit to Install SIP State Implementation Plan NAAQS National Ambient Air Quality Standards NOx Nitrogen Oxides CO Carbon Monoxide VOC Volatile Organic Compounds SO 2 Sulfur Dioxide PE Particulate Emissions PM 10 Particulate Matter 10 microns and less in diameter PM 2.5 Particulate Matter 2.5 microns and less in diameter H 2SO 4 Sulfuric acid mist emissions CO 2 Carbon Dioxide CO 2e Carbon Dioxide equivalent GHG Green House GasesFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 15 of 81 

# C. Emissions Unit Terms and ConditionsFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 16 of 81 1. B0 01, Auxiliary Boiler Operations, Property and/or Equipment Description: A natural gas
-fired auxiliary boiler, rated at 150 MMBtu/hr will be used primarily to provide high
temperature steam when the CTG is offline in order to accommodate more rapid star tups after extended shutdowns and potentially to provide fuel gas heating. a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only. (1) None. b) Applicable Emissions Limitations and/or Control Requirements (1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table. Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. OAC rule 3745
-31
-05(A)(3), as effective 11/30/2001 The permittee shall install a burner that is designed to meet 1.4E
-03 Lb. of SO 2/MMBtu of heat input based on the source design characteristic. See b)(2)a. and b)(2)b. b. OAC rule 3745
-31
-05(A)(3)(b), as effective 12/01/2006 See b)(2)c.
c. ORC 3704.03(T) and OAC rule 3745
-31
-05(A)(3) For emissions of CO, the requirements established pursuant to this rule are equivalent to the requirements established pursuant to OAC rules 3745
- 31
- 1 1 through 20. d. OAC rule 3745
-31
-05(D) Synthetic Minor to avoid Nonattainment Area New Source Review (NAA
- NSR) for NOx and VOC The NOx emissions shall not exceed 3.30 TPY based on a rolling 12
- month summation. The VOC emissions shall not exceed 1.50 TPY based on a rolling 12
- month summation. See b)(2)k. e. OAC rules 3745
-31
- 11 through 20 CO emissions shall not exceed 0.037 Lb/MMBtu of heat input, 5.55 pounds per hour, and 11.10 tons per rolling, 12
- month period.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 17 of 81 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures NOx emissions shall not exceed 0.011 Lb/MMBtu of heat input, 1.65 pounds per hour, and 3.30 tons per rolling, 12
- month period. PM, PM 10 , and PM 2.5 emissions shall not exceed 0.007 Lb/MMBtu of heat input, 1.05 pounds per hour, and 2.10 tons per rolling, 12
- month period. H 2SO 4 emissions shall not exceed 1.7E
04 Lb/MMBtu, 0.03 pound per hour, and 0.06 ton per rolling, 12
- month period. CO 2e emissions shall not exceed 35,895 tons per rolling, 12
- month period. See b)(2)d., b)(2)e., b)(2)k., b)(2)m, and c)(1). f. OAC rule 3745
- 17
-07(A)(1) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average, except as specified by rule. g. OAC rule 3745
- 17
- 10(B)(1) See b)(2)f. h. OAC rule 3745
- 110
-03(K)(20) exemption
- see b)(2)l. i. 40 CFR Part 60, Subpart A See b)(2)g. j. 40 CFR Part 60, Subpart Db [In accordance with 40 CFR 60.40b(a), this emissions unit is a steam generating unit that commenced construction after June 19, 1984, and that has a heat input capacity of greater than 100 MMBtu/hr.] The NOx emission limitation specified by this rule is less stringent than the emission limitation established pursuant to OAC rules 3745
-31
- 11 through 20. See b)(2)h. and b)(2)i.

k. 40 CFR Part 63, Subpart JJJJJJ See b)(2)j. (2) Additional Terms and Conditions
a. Compliance with the requirements of this rule for NOx and PM/PM 10/PM 2.5 emissions includes compliance with the requirements of OAC rule 3745
-31
- 11 through 20.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 18 of 81 Compliance with the requirements of this rule for VOC is equivalent to the rolling, 12
- month emission limitation established in OAC rule 3745
-31
-05(D). b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745
-31
-05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745
-31
-05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745
-31
-05, the requirement to satisfy BAT still exists as part of the federally
-approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05, these emission limitations/control measures no longer apply.
c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05 as part of the State Implementation Plan. The Best Available Technology (BAT) requirements under OAC rule 3745
-31
- 05(A)(3) do not apply to the NOx, PE/PM 10/PM 2.5 , SO 2 , and VOC emissions from this air contaminant source since the uncontrolled potential to emit for NOx, PE/PM 10/PM 2.5 , SO 2 , and VOC is less than 10 tons per year each. d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10/PM 2.5 emission s limitations include both filterable and condensable particulate emissions.
e. The Lb/MMBtu and pound per hour, emission limitations are based on the emissions unit's potentials to emit. Therefore, no monitoring, record keeping, and reporting requirements a re necessary to ensure ongoing compliance with these emission limitations. f. The emission limitation specified by this rule is less stringent than the limitation established by OAC rule 3745
-31
- 11 through 20. g. 40 CFR Part 60 subpart A provides applicability p rovisions, definitions, and other general provisions that are pertinent to emissions units affected by 40 CFR Part 60. h. Pursuant to 40 CFR 60.42b(k)(2), this rule exempts units firing gaseous fuel (natural gas) from the SO2 emission limitation. Also, this rule does not establish a PM emission limitation for natural gas-fired units. This rule does require recordkeeping pursuant to 40 CFR 60.45b(k) and 40 CFR 60.49b(r). i. This emissions unit is subject to the applicable provisions of Subpart Db of the New Source Performance Standards (NSPS) as promulgated by the United States Environmental Protection Agency, 40 CFR Part 60. The application andFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 19 of 81 enforcement of these standards are delegated to the Ohio EPA. The requirements of 40 CFR Part 60 are also federally e nforceable. j. This emissions unit is exempt from the requirements of this rule per 40 CFR 63.11195(e) due to combusting only natural gas. k. The maximum annual fuel consumption for this emissions unit shall not exceed 600,000 MMBtu per rolling, 12
- month period. To ensure enforceability during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall not exceed the fuel consumption levels specified in the following table: Maximum Allowable Month(s) Cumulative Fuel Consumption (MMBtu) 1 108,000 1
-2 216,000 1
-3 324,000 1
-4 432,000 1
-5 540,000 1
-6 600,000 1
-7 600,000 1
-8 600,000 1
-9 600,000 1
- 10 600,000 1
- 11 600,000 1
- 12 600,000 After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual fuel consumption levels shall be based upon a rolling, 12
- month summation of the fuel consumption levels. l. The permittee is exempt fr om the requirements of OAC rule 3745
- 110
-03(A) through (G), since this emissions will be issued a PTI that is subject to BACT.
m. The permittee shall employ ULN burners in this emissions unit.
n. OAC rule 3745
- 18
-06 does not establish a sulfur dioxide emission limitation for this "fuel burning equipment" because it only employs natural gas as fuel. c) Operational Restrictions (1) The permittee shall burn only natural gas in this emissions unit. d) 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.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 20 of 81 (2) The permittee shall maintain monthly records of the following information:
a. th e fuel consumption for each month in MMBtu; b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the fuel consumption in MMBtu;
c. the CO, NOx, PE/P M 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emission rate for each month of operations ; and d. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emissions. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative fuel consumption in MMBtu for each calenda r month. (3) See 40 CFR Part 60, Subpart Db (40 CFR 60.40b
- 49b). e) 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. E ach report shall be submitted within 30 days after the deviation occurs. (2) Pursuant to the 40 CFR Part 60.7 and 60.49b(a), 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. the design heat input capacity of the affected facility and identification of fuels to be combusted in the affected facility. (3) The permittee shall submit quarterly deviation (excursion) reports that identify the following:
a. all exceedances of the rolling, 12
- month limitation on the fuel consumption for this emissions unit; and for the first 12 calenda r months of operation or the first 12 calendar months following the issuance of this permit, all exceedances of the maximum allowable cumulative fuel consumption; and b. all exceedances of the rolling, 12
- month CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 e mission rates.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 21 of 81 The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. (4) See 40 CFR Part 60, Subpart Db (40 CFR 60.40b

– 49b). (5) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: Air Services online web portal. f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
a. Emission Limitation: CO emissions shall not exceed 0.037 Lb/MMBtu of heat input, 5.55 pounds per hour, and 11.10 tons per rolling, 12
- month period. Applicable Compliance Method: The Lb/MMBtu emission limitation is based on manufacturer’s data. The hourly emission limitation was developed by multiplying the maximum heat input (150 MMBtu/hr) by the CO emission factor supplied by the manufacturer (0.037 Lb/MMBtu). The annual emission limitation was developed by multiplying the hourly emission limitation (5.55 pounds per hour) by the maximum annual operating hours (4,000 ho urs per year) and dividing by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
- month period value. Therefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown. b. Emission Limitation: NOx emissions shall not exceed 0.011 Lb/MMBtu of heat input, 1.65 pounds per hour, and 3.30 tons per rolling, 12
- month period. Applicable Compliance Method: The Lb/MMBtu emission limitation is based on manufacturer’s data. The hourly emission limitation was developed by multiplying the maximum heat input (150 MMBtu/hr) by the NOx emission factor supplied by the manufacturer (0.011 Lb/MMBtu). The annual emission limitation was developed by multiplying the hourly emi ssion limitation (1.65 pounds per hour) by the maximum annual operating hours (4,000 hours per year) and dividing by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
- month period value.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 22 of 81 Therefore, co mpliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown.
c. Emission Limitation: PE, PM 10 , and PM 2.5 shall not exceed 0.007 Lb/MMBtu of heat input, 1.05 pounds per hour, and 2.10 tons per rolling, 12
- month period. Applicable Compliance Method: The Lb/MMBtu emission limitation is based on manufacturer’s data and AP
-42 emission factors. The hourly emission limitation was developed by multiplying the maximum heat input (150 MMBtu/hr) by the PE/PM 10/PM 2.5 emissi on factor supplied by the manufacturer (0.007 Lb/MMBtu). If required, the permittee shall demonstrate compliance with the Lb/MMBtu and hourly emission limitation using Methods 1
-5, 201 or 201A, and 202 of 40 CFR Part 51, Appendix M. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (1.05 pounds per hour) by the maximum annual operating hours (4,000 hours per year) and dividing by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
- month period value. Therefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown. d. Emission Limitation: The permittee shall install a burner that is designed to meet 1.4E
-03 Lb SO 2/MMBtu of heat input based on the source design characteristic. Applicable Compliance Method: The Lb/MMBtu source design characteristic was established based on using pipeline quality natural gas having a maximum sulfur content of 0.5 grains per 100 cubic feet according to the following calculation. The source design characteristic was developed by multiplying the maximum sulfur content of natural gas (0.5 gra in S/100 scf) by the molecular weight of SO 2 (64.07 Lb SO 2/Lb
- mole) divided by the molecular weight of sulfur (32.06 Lb S/Lb
- mole) divided by (7,000 grains/Lb), divided by (1,020 Btu/scf), and multiplied by (10 6 Btu/MMBtu). If required, the permittee shall demonstrate compliance with the Lb/MMBtu source design characteristic using Methods 1 thru 4 and 6C of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 23 of 81 e. Emission Limitation: VOC em issions shall not exceed 1.50 tons per rolling, 12
- month period. Applicable Compliance Method: If required, the permittee shall demonstrate compliance with the Lb/MMBtu and hourly emission limitation Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. Use of Method 18, 25 or 25A is to be selected based on the results of pre-survey stack sampling and U.S. EPA guidance documents. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (0.75 pound per hour) by the maximum annual operating hours (4,000 hours per year) and dividing by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
- month period value. Therefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is maintained. f. Emission Limitation: Sulfuric acid mist (H 2SO 4 ) emissions shall not exceed 1.7E
-04 Lb/MMBtu, 0.03 pound per hour, and 0.06 ton per rolling, 12
- month period. Applicable Compliance Method: The Lb/MMBtu emission limitation is based on the assumption that 20% of the SO 2 emissions are converted to SO 3 on a mass basis and 100% of the SO 3 emissions are converted to H 2SO 4 when combined with water vapor by the following calculation: (1.4E
-03 Lb SO 2/MMBtu)(0.1 Lb SO 3/Lb SO 2 )(98 Lb H 2SO 4/80 Lb SO 3) = 1.7E
-04 Lb H 2SO 4/MMBtu Multiply the Lb H 2SO 4/MMBtu (1.7E
-04 Lb/MMBtu) by the maximum heat input (150 MMBtu/hr) to determine the maximum hourly H 2SO 4 emissions (0.03 pound per hour), and multiply by the the maximum annual operating hours (4,000 hours per year) and dividing by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
- month period value. Therefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is maintained. If required, the permittee shall demonstrate compliance with the Lb/MM Btu and pound per hour emissions limitations using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A.

. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 24 of 81 g. Emission Limitation: Carbon dioxide equivalent (CO 2e) emissions shall not exceed 35,895 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation was established to reflect the potential to emit for this emissions unit by calculating the product of the maximum natural gas u sage (150 MMBtu/hr) multiplied by the summation of the AP
-42 emission factors from Table 1.4
-2 dated 7/1998 [120,000 Lb CO 2/MMscf, 0.64 Lb N 2O/MMscf, and 2.3 Lb CH 4/MMscf, each multiplied by their respective global warming potentials (1, 298, and 25; Table A
- 1 to Subpart A of 40 CFR 98, 11/29/2013)], divided by 1005 MMBtu/MMscf, multiplied by the maximum annual hours of operation 4,000 hours per year and divided by 2,000 pounds per ton. The 4000 hours per year value is equivalent to the 600,000 MMBtu , per rolling, 12
-month period value:
150 h 120, 000 2 ( 1) + (0
. 64 2 ) (298)

+ 2
. 3 4 (25) 1005 4, 000 h h 2, 000

= 35 , 895 Since the CO 2e emissions are estim ated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the Lb/scf CO 2 emission rate does not exceed 120,000 Lb/MMscf. If required, the permittee shall conduct emissions testing using Methods 1, 2, 3A an d 4 of 40 CFR Part 60, Appendix A to determine the Lb/scf CO 2 emission rate. h. Emission Limitation: Visible emissions shall not exceed 20% opacity as a 6
- minute average, except as provided by rule. Applicable Compliance Method: If required, compliance with the stack visible particulate emissions limitation shall be determined through visible emissions observations performed in accordance with Method 9 of 40 CFR Part 60, Appendix A. (2) The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the following requirements:
a. The emission testing shall be conducted within 60 days after achieving the maximum production rate at which the emissions unit will be operated, but not later than 180 days after initial startup of the emissions unit.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 25 of 81 b. The emission testing shall be conducted to demonstrate compliance with the following emissions limitations: i. CO emissions in pound per hour and Lb/MMBtu; and ii. NOx emissions in pound per hour and Lb/MMBtu. The emission testing shall also be conducted to determine the CO 2 emission rate in Lb/MMBtu.
c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for CO, Methods 1 thru 4 and 10 of 40 CFR Part 60, Appendix A; forNOx Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A; and for CO 2 , Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA. d. The test(s) shall be conducted under those rep resentative conditions that challenge to the fullest extent possible a facility’s ability to meet the applicable emissions limits and/or control requirements, unless otherwise specified or approved by the appropriate Ohio EPA District Office or local air agency. Although this generally consists of operating the emissions unit at its maximum material input/production rates and results in the highest emission rate of the tested pollutant, there may be circumstances where a lower emissions loading is deemed the most challenging control scenario. Failure to test under these conditions is justification for not accepting the test results as a demonstration of compliance.
e. Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "In tent to Test" notification to the appropriate Ohio EPA District Office or local air agency. The "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA District Office's or local air agency's refusal to accept the results of the emission test(s). 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.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 26 of 81 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. g) Miscellaneous Requirements (1) None.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 27 of 81 2. P001, CT+HRSG M501JAC or M501GAC Operations, Property and/or Equipment Description: Combined
-cycle combustion turbine generator (CTG) with heat recovery steam generator (HRSG), natural gas
-fired, including duct burners (DB). a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable un der state law only. (1) d)(10) through d)(13) and e)(5). b) Applicable Emissions Limitations and/or Control Requirements (1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table. Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. ORC 3704.03(T) and OAC rule 3745
-31
-05(A)(3) The permittee shall install combustion devices in the CTG and DB that are designed to meet 1.4E
-03 Lb SO 2/MMBtu of heat input based on the source design characteristic. See b)(2)b. b. OAC rule 3745
-31
-05(D) Synthetic Minor to avoid Nonattainment Area New Source Review (NAA
- NSR) for NOx and VOC The NOx emissions shall not exceed 88.4 TPY based on a rolling 12
- month summation. The VOC emissions shall not exceed 92.3 TPY based on a rolling 12
- month summation. See b)(2)c. through e., b)(2)u. and b)(2)v. c. OAC rule 3745
-31
- 11 through 20 CO 2e emissions shall not exceed 880 Lb/MW
- hr and 375,130 Lbs/hr gross energy output, @ ISO conditions, 100% load, without duct firing. See b)(2)c, b)(2)d., b)(2)e., b)(2)g. through b)(2)i., b)(2)r. through t., and c)(1). d. OAC rule 3745
- 17
-07(A)(1) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average, except as specified by rule.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 28 of 81 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures e. OAC rule 3745
- 17
- 11(B)(4) See b)(2)j. f. OAC rule 3745
- 18
-06(A) See b)(2)l. g. OAC rule 3745
- 110
-03(K)(20) exemption
- see b)(2)n. h. OAC rule 3745
- 114 See d)(10) through d)(13) i. 40 CFR Part 60, Subpart A See b)(2)m. j. 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420) [In accordance with 40 CFR 60.4305(a), this emissions unit is a stationary combustion turbine with a heat input at peak load greater than 10 MMBtu/hr with a heat recovery steam generator/duct burners subject to the emissions limitations/control measures specified in this section.] See b)(2)k. and b)(2)o.

k. 40 CFR Part 63, Subpart YYYY See b)(2)p. l. 40 CFR Part 63, Subpart JJJJJJ See b)(2)q. (2) Additional Terms and Conditions
a. All Applicable Emission Limitations and/or Control measures specified in this Section of the permit for Emissions Unit P001 consist of the worst
-case (highest emitting) scenario considering the permittee may install either the Mitsubishi M501GAC or M501JAC as outlined in Application A0050480 for PTI P0116610. b. Compliance with the requirements of this rule for CO, NOx, PE, PM 10 , and PM 2.5 are equivalent to the requirements of OAC rule 3745
-31
- 11 through 20. Compliance with the requirements of this rule for VOC are equivalent to the rolling, 12
- month emission limitation established in OAC rule 3745
-31
-05(D).
c. To ensure enforceability of the rolling, 12
- month emissions limitations during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall not exceed the emission levels specified in the following table: Maximum Allowable Cumulative Emissions

(Tons) Month(s) CO NOx PE/PM10/PM2.5 VOC H 2SO 4 1 24.9 8.8 5.9 9.2 1.4 1
-2 49.8 17.7 11.9 18.5 2.8Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 29 of 81 Maximum Allowable Cumulative Emissions

(Tons) Month(s) CO NOx PE/PM10/PM2.5 VOC H 2SO 4 1
-3 74.7 26.5 17.8 27.7 4.2 1
-4 99.6 35.4 23.8 36.9 5.6 1
-5 124.6 44.2 29.7 46.2 7.0 1
-6 149.5 53.0 35.6 55.4 8.4 1
-7 174.4 61.9 41.6 64.6 9.8 1
-8 199.3 70.7 47.5 73.8 11.2 1
-9 224.2 79.6 53.5 83.1 12.6 1
- 10 249.1 88.4 59.4 92.3 14.0 1
- 11 249.1 88.4 59.4 92.3 14.0 1
- 12 249.1 88.4 59.4 92.3 14.0
After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual emissions limitations shall be based upon a rolling, 12
- month summation of the monthly emissions. d. The emission s fr om this emissions unit shall be vented to the SCR and catalytic oxidation units at all times during which the emissions unit is in operation.
e. The permittee shall employ lean pre
- mix or DLN burners in this emissions unit. f. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10/PM 2.5 emissions limitations include both filterable and condensable particulate emissions. g. The permittee shall comply with the following emissions limitations: Allowable Emissions Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, Lb/hrb Emission rate,

tons per rolling, 12 -month period CO CT with DB 2.0 c 16.8
-Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 30 of 81

Allowable Emissions Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, Lb/hrb Emission rate,

tons per rolling, 12 -month period CT only 2.0 c 13.2
- All operating modes, including startup periods - - 249.1 NOx CT with DB 2.0 c 27.7
-

CT only 2.0 c 21.8
- All operating modes, including startup periods 88.4 PE/PM 10/PM 2.5 CT with DB 5.70E
-03 d 20.0
-

CT only 3.80E
-03 d 10.8
- All operating modes, including startup periods - - 59.4 H 2SO 4 CT with DB 1.1E
-03 d 4.3
-

CT only 1.1E
-03 d 3.5
- All operating modes, including startup periods - - 14.0 CO 2e All operating

modes, including startup periods - - 1,626,781 a. CT = combustion turbine DB = duct burner b. Emission limitation does not apply during periods of startup and shutdown. c. Parts per million by volume dry (ppmvd) at 15% oxygen d. Pound per million Btu of heat input e. Emissions limitations are based on an hourly average. h. The permittee shall comply with the following requirements during periods of startup and shutdown:Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 31 of 81

Emissions Limitations During Startup and

Shutdown (Lbs/hr) a Cold Startup Hot

Startup b Warm

Startup Shutdown b
CO 1762.8 1108.0 1432.9 602.0 NOx 58.3 32.0 46.2 28.0 VOC 675.7 374.0 508.4 298.0

a Pound per hour emissions rates as presented are averaged over the duration of the event where the duration of a cold start is 142.5 minutes, the duration of a warm start is 103 minutes, and it has been assumed that the CTs are at their respective maximum potential emission rates (100% load) for the balance of the averaging period that they are not in start
- up or shutdown mode. The duration of a hot start is 22.8 minutes, and the duration of a shutdown is 12.5 minutes.
b Emissions Limitations in units of po unds per event. “Cold Startup” is defined as a combustion turbine startup that occurs more than 60 hours after a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 150 minutes of continuous fuel flow to the combusti on turbine after fuel flow is initiated or the period of time from combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data [see g) where data point is defined.] points in compliance with the ppmvd emission limitations for CO and NO x. “Hot Startup” is defined as a combustion turbine startup that occurs within 12 hours of a combustion turbine shutdown. T he period of hot startup is defined as the lesser of the first 30 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time from combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emission limitations for CO and NOx. “Warm Startup” is defined as a combustion turbine startup that occurs between 12 hours of and 60 hours of a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 110 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time from combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points where in compliance with the ppmvd emission limitations for CO and NOx. i. The design plant base heat rate shall not exceed 7,341 Btu/k W
- hr HHV, gross (ISO conditions without duct firing).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 32 of 81 j. The emission limitation specified by this rule is less stringent than the limitation established by OAC rule 3745
-31
- 11 through 20. k. The emission limitation specified by this rule is less stringent than the limitation established by ORC 3704.03(T) and OAC rule 3745
-31
-05(A)(3) for SO2 and OAC rule 3745
-31
- 11 through 3745
-31
-20 for NOX. l. This emissions unit is exempt from the requirements of this rule, since only natura l gas is burned.
m. 40 CFR Part 60 subpart A provides applicability provisions, definitions, and other general provisions that are pertinent to emissions units affected by 40 CFR Part 60.
n. The permittee is exempt fr om the requirements of OAC rule 3745
- 110
-03(A) through (G), since this emissions will be issued a PTI that is subject to BACT.
o. This emissions unit is subject to the applicable provisions of Subpart KKKK of the New Source Performance Standards (NSPS) as promulgated by the United States Environmental P rotection 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. p. This emissions unit is not subject to the requirements of 40 CFR Part 63, Subpart YYYY, since it is not located at a major source of HAP emissions. q. The duct burner is exempt from the requirements of this rule per 40 CFR 63.11195(e) due to combusting only natural gas.
r. The continuous NOx monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 2 and 6. At least 45 days before commencing certification testing of the continuous NOx monitoring system(s), the permittee shall develop and maintain a written quality assurance/quality control plan designed to ensure continuous valid and representative readings of NOx emissions from the continuous monitor(s), in units of the applicable standard(s). The fuel flow monitor/meter shall be maintained as required in Part 75, Appe ndix D. Except as allowed below, the plan shall follow the requirements of 40 CFR Part 60, Appendix F and 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous monitoring system must be kept on s ite and available for inspection during regular office hours. The plan shall include the requirement to conduct relative accuracy test audits for the continuous NOx monitoring system in accordance with the frequencies required pursuant to 40 CFR Part 60 an d 40 CFR Part 75; or may follow relative accuracy test audit frequency requirements for monitoring systems subject to 40 CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 33 of 81 The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or relative accuracy audits required per 40 CFR Part 60.
s. The continuous carbon monoxide (CO) monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 4 or 4a and 6. At least 45 days before commencing certification testing of the continuous CO monitoring system(s), the permittee shall develop and maintain a written quality assurance/quality control plan designed to ensure continuous valid and representative readings of CO emissions from the continuous monitor(s), in units of the applicable standard(s). The fuel flow monitor/meter shall be maintained as required in Part 75, Appendix D. Except as allowed below, the plan shall follow the requirements of 40 CFR Part 60, Appendix F. The quality assurance/quality control plan and a logbook dedicated to the continuous monitoring system must be kept on site and available for inspecti on during regular office hours. The plan shall include the requirement to conduct relative accuracy test audits for the continuous CO monitoring system in accordance with the frequencies required for monitoring systems subject to 40 CFR 60, or may follow relative accuracy test audit frequency requirements for monitoring systems subject to 40 CFR 75, Appendix B. I n either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60. The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits as required in 40 CFR Part 60; however, the quarterly cylinder gas audit and relative accuracy audit fr equency requirements may be adjusted to coincide with linearity checks completed for continuous emissions monitoring systems subject to 40 CFR Part 75, Appendix B requirements. t. The continuous emission monitoring system consists of all the equipment used to acquire data to provide a record of emissions and includes the sample extraction and transport hardware, sample conditioning hardware, analyzers, and data recording/processing hardware and software.
u. The permittee shall comply with the following emissions limitations: Allowable Emissions Pollutant Operating

Mode a Emission

Rate b,d Emission

rate, Lb/hrb Emission rate,

tons per rolling, 12 -month period VOC CT With DB 1.5c 7.2
-

CT only 1.0 c 3.8
-Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 34 of 81

Allowable Emissions Pollutant Operating

Mode a Emission

Rate b,d Emission

rate, Lb/hrb Emission rate,

tons per rolling, 12 -month period All operating modes, including startup periods - - 92.3 a. CT = combustion turbine DB = duct burner b. Emission limitation does not apply during periods of startup and shutdown. c. Parts per million by volume dry (ppmvd) at 15% oxygen d. Emissions limitations are based on an hourly average.
v. Ongoing compliance with the VOC emission limitation shall be based on the following calculation: ( = [ (# ) ( 1, 294 ( ∗) / ) + (# ) ( 304 ( ∗) / ) + ( # ) ( 304 ( ∗) / ) + (# Shut) (240 ( ∗) / h ) + (# ) (6
. 6 ( ∗) / h ) + (# ) (3
. 4 ( ∗) / h ) ] ) / (2000 / ) Wh ere: VOC = tons VOC emissions per rolling, 12
- month period #CS = number of cold startups per rolling, 12
- month period #W S = number of warm startups per rolling, 12
- month period #HS = number of hot startups per rolling, 12
- month period #Shut = number of shutdowns pe r rolling, 12
- month period #SSDB = hours operated in steady state with duct burner per rolling, 12
- month period #SSNDB = hours operated in steady state without duct burner per rolling, 12
- month period *Or the permittee shall use the most recent emissions r ate data in pounds per event and/or pounds per hour obtained via emission testing results, vendor
supplied data, etc. c) Operational Restrictions (1) The permittee shall only burn pipeline quality natural gas as fuel in this emissions unit. (2) See 40 CFR Part 60, Su bpart KKKK (40 CFR 60.4300

– 60.4420).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 35 of 81 d) 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 emission s unit. (2) The permittee shall use one of the following to demonstrate the potential sulfur emissions do not exceed 1.4E
-03 Lb. of SO2/MMBtu of heat input:
a. the fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, specifying that the maximum total sulfur content for natural gas is 0.5 grains of sulfur or less per 100 standard cubic feet, resu lting in potential sulfur emissions of 1.4E
-03 Lb SO 2/MMBtu heat input, or less; b. representative fuel sampling data which show that the sulfur content of the fuel does not exceed 1.4E
-03 Lb SO 2/MMBtu heat input. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of appendix D to part 75 of this chapter is required; or
c. one of the custom sulfur monitoring schedules outlined in 40 CFR 60.4370(c) may be used to comply with the 1.4E
-03 Lb. of SO2/MMBtu standard. (3) The permittee s hall maintain monthly records of the following information:
a. the CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emission rate for each month of operations ; and b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emissions. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emissions for each calendar month. (4) The permittee shall maintain monthly records of the following information for this emissions unit for purposes of calculating rolling, 12
- month emissions:
a. date, time, and duration of each cold, warm, hot startup and shutdown period; b. the hours of operation of the combustion turbine;
c. the hours of operation of the duct burner; d. the total duration of all cold startup periods in hours per rolling, 12
- month period;
e. the total duration of all hot startup periods in hours per rolling, 12
- month period;Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 36 of 81 f. the total duration of all warm startup periods in hours per rolling, 12
- month period; g. the total duration of all shutdown periods in hours per rolling, 12
- mo nth period; h. the total duration of steady
-state operation without duct burner firing in hours per rolling, 12
- month period; i. the total duration of steady
-state operation with duct burner firing in hours per rolling, 12
- month period; (5) 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, Per formance Specification 2. The Ohio EPA, Central Office shall approve the proposed sampling site and certify that the continuous NOx monitoring system meets the requirements of Performance Specifications 2 and 6; and the U.S. EPA shall certify that the continuous NOx monitoring system meets the requi rements under 40 CFR Part 75, which may be approved through the recommendation for certification by Ohio EPA to U.S. EPA. Once received, the letter(s)/document(s) of certification under Part 60 and certification or recommendation for certification under Part 75 shall be maintain on -site and made available to the Director (the appropriate Ohio EPA District Office or local air agency) upon request

. (6) The permittee shall install, operate, and maintain equipment to continuously monitor and record NOx emissions from this emissions unit in units of the applicable standard(s). The continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60 and 40 CFR Part 75. The permittee shall maintain records of all data obtained by the continuous NOx monitoring system including, but not limited to:
a. emissions of NOx in parts per million for each cycle time of the analyzer, with no resolution less than one data point per minute required; b. emissions of NOx in pounds per hour and in un its of the applicable standard(s) in the appropriate averaging period;
c. results of quarterly cylinder gas audits or linearity checks; d. results of daily zero/span calibration checks and the magnitude of manual calibration adjustments;
e. results of required relative accuracy test audit(s), including results in units of the applicable standard(s); f. hours of operation of the emissions unit, continuous NOx monitoring system, and control equipment; g. the date, time, and hours of operation of the emissions unit without the control equipment and/or the continuous NOx monitoring system;Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 37 of 81 h. malfunction of the control equipment and/or the continuous NOx monitoring system; as well as, i. the reason (if known) and the corrective actions taken (if any) for each such event in (g) and (h). All valid data points generated and recorded by the continuous emission monitoring and data acquisition and handling system shall be used in the calculation of the pollutant concentr ation and/or emission rate over the appropriate averaging period. (7) Prior to the installation of the continuous carbon monoxide (CO) monitoring system, the permittee shall submit information detailing the proposed location of the sampling site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate). The Ohio EPA, Central Office shall approve the proposed sampling site and certify that the continuous CO monitoring system meets the requiremen ts of Performance Specifications 4 or 4a and 6. O nce received, the letter(s)/document(s) of certification shall be maintained on -site and shall be made available to the Director (the appropriate Ohio EPA District Office or local air agency) upon request. (8) The permittee shall operate and maintain equipment to continuously monitor and record CO emissions from this emissions unit in units of the applicable standard(s). The continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Parts 60. The permittee shall maintain records of all data obtained by the continuous CO monitoring system including, but not limited to:
a. emissions of CO in parts per million for each cycle time of the analyzer, with no resolution less than o ne data point per minute required; b. emissions of CO in pounds per hour and in units of the applicable standard(s) in the appropriate averaging period;
c. results of quarterly cylinder gas audits; d. results of daily zero/span calibration checks and the magnitude of manual calibration adjustments;
e. results of required relative accuracy test audit(s), including results in units of the applicable standard(s); f. hours of operation of the emissions unit, continuous CO monitoring system, and control equipment; g. the date, ti me, and hours of operation of the emissions unit without the control equipment and/or the continuous CO monitoring system; h. the date, time, and hours of operation of the emissions unit during any malfunction of the control equipment and/or the continuous CO monitoring system; as well as,Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 38 of 81 i. the reason (if known) and the corrective actions taken (if any) for each such event in (g) and (h). All valid data points generated and recorded by the continuous emission monitoring and data acquisition and handling system shall be used in the calculation of the pollutant concentration and/or emission rate over the appropriate averaging period. (9) The permittee shall calculate and record the monthly CO 2 emissions from the continuous flow and moisture content monitors using the procedures set forth in 40 CFR Part 75, Appendix G. From this data, the permittee shall calculate the CO 2 emissions per rolling, 12
- month period. (10) The Permit to Install application for this emissions unit, P001 , was evaluated based on the actual materials and the design parameters of the emissions unit's(s’) exhaust system, as specified by the permittee. The “Toxic Air Contaminant Statute”, ORC 3704.03(F), was applied to this/these emissions unit(s) for each toxic air contaminant listed in OAC rule 3745
- 11 4
-01, using data from the permit application; and modeling was performed for each toxic air contaminant(s) emitted at over one ton per year using an air dispersion model such as SCREEN3, AERMOD, or ISCST3, or other Ohio EPA approved model. The predicted 1
- hour maximum ground
- level concentration result(s) fr om the approved air dispersion model, was compared to the Maximum Acceptable Ground
- Level Concentration (MAGLC), calculated as described in the Ohio EPA guidance document entitled “Review of N ew Sources of Air Toxic Emissions, Option A”, as follows:
a. the exposure limit, expressed as a time
-weighted average concentration for a conventional 8
- hour workday and a 40
-hour workweek, for each toxic compound(s) emitted fr om the emissions unit(s), (as determined from the raw materials processed and/or coatings or other materials applied) has been documented from one of the following sources and in the following order of preference (TLV was and shall be used, if the chemical is listed): i. threshold limit value (TLV) fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices”; or ii. STEL (short term exposure limit) or the ceiling value fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices”; the STEL or ceiling value is multiplied by 0.737 to convert the 15
- minute exposure limit to an equivalent 8
- ho ur TLV. b. The TLV is divided by ten to adjust the standard fr om the working population to the general public (TLV/10).
c. This standard is/was then adjusted to account for the duration of the exposure or the operating hours of the emissions unit(s), i.e., “X = 24” hours per day and “Y = 7” days per week, fr

om that of 8 hours per day and 5 days per week. TheFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 39 of 81 resulting calculation was (and shall be) used to determine the Maximum Acceptable Ground
- Level Concentration (MAGLC): TLV/10 x 8/X x 5/Y = 4 TLV/XY = MAGLC d. The following summarizes the results of dispersion modeling for the “worst case” toxic contaminant(s): Toxic Contaminant: ammonia TLV (mg/m3): 17.41 Maximum Hourly Emission Rate (Lbs/hr): 25.6, ammonia “slip”, M501J, Winter 100% fired Predicted 1
- Hou r Maximum Ground
- Level Concentration (ug/m3): 3.17 MAGLC (ug/m3): 414.52 Toxic Contaminant: formaldehyde TLV (mg/m3): 0.27 Maximum Hourly Emission Rate (Lbs/hr): 0.70, M501J, Winter 100% fired Predicted 1
- Hour Maximum Ground
- Level Concentration (u g/m3): 0.09 MAGLC (ug/m3): 6.5 Toxic Contaminant: n
-hexane TLV (mg/m3): 176.23 Maximum Hourly Emission Rate (Lbs/hr): 0.74, M501G, Winter 100% fired Predicted 1
- Hour Maximum Ground
- Level Concentration (ug/m3): 0.09 MAGLC (ug/m3): 4196 Toxic Contaminant: toluene TLV (mg/m3): 75.36 Maximum Hourly Emission Rate (Lbs/hr): 0.47, M501J, Winter 100% fired Predicted 1
- Hour Maximum Ground
- Level Concentration (ug/m3): 0.06 MAGLC (ug/m3): 1794 The permittee, has demonstrated that emissions of each Air Toxic from emissions unit(s) P001 are calculated to be less than eighty per cent of the maximum acceptable ground level concentration (MAGLC) each; any new raw material or processing agent shall notFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 40 of 81 be applied without evaluating each component toxic ai r contaminant in accordance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F). (11) Prior to making any physical changes to or changes in the method of operation of the emissions unit(s), that could impact the parameters or values that were used in the p redicted 1
- hour maximum ground
- level concentration, the permittee shall re- model the change(s) to demonstrate that the MAGLC has not been exceeded. Changes that can affect the parameters/values used in determining the 1
- hour maximum ground
-level concentration include, but are not limited to, the following:
a. changes in the composition of the materials used or the use of new materials, that would result in the emission of a new toxic air contaminant with a lower Threshold Limit Value (TLV) than the lowest TLV previously modeled; b. changes in the composition of the materials, or use of new materials, that would result in an increase in emissions of any toxic air contaminant listed in OAC rule 3745
- 114
-01, that was modeled from the initial (or last) application; and
c. physical changes to the emissions unit(s) or its/their exhaust parameters (e.g., increased/ decreased exhaust flow, changes in stack height, changes in stack diameter, etc.). If the permittee determines that the “Toxic Air Contaminant Statute” will be satisfied for the above changes, the Ohio EPA will not consider the change(s) to be a "modification" under OAC rule 3745
-31
-01 solely due to a non - restrictive change to a parameter or process operation, where compliance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F), has been documented. If the change(s) meet(s) the definition of a “modification”, the permittee shall apply for and obtain a fi nal PTI prior to the change. The Director may consider any significant departure from the operations of the emissions unit, described in the permit application, as a modification that results in greater emissions than the emissions rate modeled to determine the ground level concentration; and he/she may require the permittee to submit a permit application for the increased emissions. (12) The permittee shall collect, record, and retain the following information for each toxic evaluation conducted to determine compliance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F):
a. a description of the parameters/values used in each compliance demonstration and the parameters or values changed for any re-evaluation of the toxic(s) modeled (the composition of materials, new toxic contaminants emitted, change in stack/exhaust parameters, etc.); b. the Maximum Acceptable Groun d
-Level Concentration (MAGLC) for each significant toxic contaminant or worst
-case contaminant, calculated in accordance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F);
c. a copy of the computer model run(s), that established the predicted 1
- hour maximum ground
- level concentration that demonstrated the emissions unit(s) to be in compliance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F),Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 41 of 81 initially and for each change that requires re-evaluation of the toxic air contaminant emissions; and d. the documentation of the initial evaluation of compliance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F), and documentation of any determination that was conducted to re-evaluate compliance due to a change made to the emissions unit(s) or the materi als applied. (13) The permittee shall maintain a record of any change made to a parameter or value used in the dispersion model, used to demonstrate compliance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F), through the predicted 1
- hour maximum ground
-level concentration. The record shall include the date and reason(s) for the change and if the change would increase the ground
- level concentration. (14) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420). (15) The permittee shall maintain monthly records of the following information:
a. the natural gas usage rate in MMBtu for each month of operation ; and b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the natural gas usage rate in MMBtu. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative natural gas usage rate in MMBtu for each ca lendar month. e) 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. E ach report shall be submitted within 30 days after the deviation occurs. (2) The permittee shall comply with the following quarterly reporting requirements for the emissions unit and its continuous NOx monitoring system:
a. Pursuant to the monitoring, record keeping, and reporting requirements for continuous monitoring systems contained in 40 CFR 60.7 and 60.13(h) and the requirements established in this permit, the permittee shall submit reports within 30 days following the end of each calendar quarter to the appropriate Ohio EPA District Office or local air agency, documenting all instances of NOx emissions in excess of any applicable limit specified in this permit, 40 CFR Part 60, 40 CFR Parts 75 and 76, OAC Chapters 3745
- 14 and 3745
-23, and any other applicable rules or regulations. The report shall document the date, commencement and completion times, duration, and magnitude of each exceedance, as well as the reason (if known) and the corrective actions taken (if any) for each exceedance. Excess emissions shall be reported in units of the applicable standard(s).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 42 of 81 b. These quarte rly reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall include the following: i. the facility name and address; ii. the manufacturer and model number of the continuous NOx and other associated monitors; iii. a descriptio n of any change in the equipment that comprises the continuous emission monitoring system (CEMS), including any change to the hardware, changes to the software that may affect CEMS readings, and/or changes in the location of the CEMS sample probe; iv. the excess emissions report (EER)*, i.e., a summary of any exceedances during the calendar quarter, as specified above;
v. the total NOx emissions for the calendar quarter (tons); vi. the total operating time (hours) of the emissions unit; vii. the total operating time of the continuous NOx monitoring system while the emissions unit was in operation; viii. results and date of quarterly cylinder gas audits or linearity checks; ix. unless previously submitted, results and date of the relative accuracy test a udit(s), including results in units of the applicable standard(s), (during appropriate quarter(s));
x. unless previously submitted, the results of any relative accuracy test audit showing the continuous NOx monitor out
-of
-control and the compliant results fol lowing any corrective actions; xi. the date, time, and duration of any/each malfunction** of the continuous NOx monitoring system, emissions unit, and/or control equipment; xii. the date, time, and duration of any downtime** of the continuous NOx monitoring system and/or control equipment while the emissions unit was in operation; and xiii. the reason (if known) and the corrective actions taken (if any) for each event in (b)(xi) and (xii). Each report shall address the operations conducted and data obtained during the previous calendar quarter. Data substitution procedures from 40 CFR 75 are not to be used for showing compliance with the short term OAC 3745
-31
-05(A)(3) rule
- based or NSPS
- based limitation(s) in this permit. * where no excess emissions have occurred or the continuous monitoring system(s) has/have not been inoperative, repaired, or adjusted during the calendar quarter, such information shall be documented in the EER quarterly reportFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 43 of 81 ** each downtime and malfunction event shall be reported regardless if there is an exceedance of any applicable limit (3) The permittee shall comply with the following quarterly reporting requirements for the emissions unit and its continuous CO monitoring system:
a. Pursuant to the monitoring, record keeping, and reporting requirements for continuous monitoring systems contained in 40 CFR 60.7 and 60.13(h) and the requirements established in this permit, the permittee shall submit reports within 30 days following the end of each calendar quarter to the appropriate Ohio EPA District Office or local air agency, documenting all instances of CO emissions in excess of any applicable limit specified in this permit, 40 CFR Part 60, OAC Chapter 3745
-21, and any other applicable rules or regulations. The report shall document the date, commencemen t and completion times, duration, and magnitude of each exceedance, as well as, the reason (if known) and the corrective actions taken (if any) for each exceedance. Excess emissions shall be reported in units of the applicable standard(s). b. These quarterly reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall include the following: i. the facility name and address; ii. the manufacturer and model number of the continuous CO and other associated monitors; iii. a description of any change in the equipment that comprises the continuous emission monitoring system (CEMS), including any change to the hardware, changes to the software that may affect CEMS readings, and/or changes in the location of the CEMS sample probe; iv. the excess e missions report (EER)*, i.e., a summary of any exceedances during the calendar quarter, as specified above;
v. the total CO emissions for the calendar quarter (tons); vi. the total operating time (hours) of the emissions unit; vii. the total operating time of the continuous CO monitoring system while the emissions unit was in operation; viii. results and dates of quarterly cylinder gas audits; ix. unless previously submitted, results and dates of the relative accuracy test audit(s), including results in units of the applicable standard(s), (during appropriate quarter(s));
x. unless previously submitted, the results of any relative accuracy test audit showing the continuous CO monitor out
-of
-control and the compliant results following any corrective actions;Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 44 of 81 xi. the date, time, and duration of any/each malfunction** of the continuous CO monitoring system, emissions unit, and/or control equipment; xii. the date, time, and duration of any downtime** of the continuous CO monitoring system and/or control equipment while the emissions unit was in o peration; and xiii. the reason (if known) and the corrective actions taken (if any) for each event in (b)(xi) and (xii). Each report shall address the operations conducted and data obtained during the previous calendar quarter. Data substitution procedures from 40 CFR 75 are not to be used for showing compliance with the short term OAC 3745
-31
-05(A)(3) rule
- based or NSPS
- based limitation(s) in this permit. * where no excess emissions have occurred or the continuous monitoring system(s) has/have not been inoperative, repaired, or adjusted during the calendar quarter, such information shall be documented in the EER quarterly report ** each downtime and malfunction event shall be reported regardless if there is an exceedance of any applicable limit (4) The permittee sha ll collect, record, and maintain measurements, data, records, and reports required per 40 CFR Part 75; and shall submit certification, recertification, notifications, applications, monitoring plans, petitions for alternative monitoring systems, electronic quarterly reports, and any other pertinent record and/or report to the Administrator (U.S. EPA), as required by this Part. (5) The permittee shall submit annual reports that include any changes to any parameter or value used in the dispersion model used to dem onstrate compliance with the “Toxic Air Contaminate Statute”, ORC 3704.03(F), through the predicted 1 hour maximum concentration. The report should include:
a. the original model input; b. the updated model input;
c. the reason for the change(s) to the input parameter(s); d. a summary of the results of the updated modeling, including the input changes; and
e. a statement that the model results indicate that the 1
- hour maximum ground
-level concentration is less than 80% of the MAGLC. If no changes to the emissions, emiss ions unit(s), or the exhaust stack have been made during the reporting period, then the report shall include a statement to that effect. (6) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 45 of 81 (7) The permittee shall submit quarterly deviation (excursion) reports that identify all exceedances of the rolling, 12
- month CO, NOx, PE/PM 10/PM 2.5 , VOC, CO 2e and H 2SO 4 emission rates. The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
a. Emission Limitatio n: CO emissions from this emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 13.2 Lbs/hr when the duct burner is not in operation; and, 2.0 ppmvd at 15% oxygen as an hourly average and 16.8 Lbs/hr when the duct burner is in operation. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60. The permittee shall demonstrate compliance using Methods 1 thru 4 and 10 of 40 CFR Part 60, Ap pendix A. Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA. S ee f)(2) for emission testing requirement. b. Emission Limitation: CO emissions fr

om this emissions unit shall not exceed 249.1 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation is based on the following anticipated worst case emissions: 10 cold startups per year, with a minimum downtime preceding cold startup of 60 hours, a cold startup duration of 142.5 min utes, and maximum CO emissions of 3365 pounds during each cold startup event; 52 warm startups per year, with a minimum downtime preceding warm startup of 12 hours, a warm startup duration of 102.5 minutes, and maximum CO emissions of 2235 pounds during ea ch warm startup event;Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 46 of 81 208 hot startups per year, with a minimum downtime preceding hot startup of 0 hours, a hot startup duration of 22.8 minutes, and maximum CO emissions of 869 pounds during each hot startup event; 270 shutdowns per year, with a shutdown duration of 12.5 minutes, and maximum CO emissions of 393 pounds during each shutdown event; and hourly CO emissions at average ambient conditions with duct firing during 100 percent load steady state operation of 14.6 Lbs/hr based on manufacturer’s data and steady state operating hours. The allowable annual emission rate was determined by the following calculation using the above information:

, , , . 

### = 249.1 TPY CO Wh ere: CS = cold starts WS = warm starts HS = hot starts Shut = shutdown Ongoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in th e Monitoring and Record keeping Section of this permit
c. Emission Limitation: CO emissions from this emissions unit shall not exceed 1762.8 Lbs/hr during cold startup, 1108.0 Lbs/event during hot startup, 1432.9 Lbs/hr during warm startup, and 602 Lbs/event during shutdown averaged over the duration of the event. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 47 of 81 d. Emission Limitation: NOx emissions from thi s emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 21.8 Lbs/hr when the duct burner is not in operation; and, NO x emissions shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 27.7 Lbs/hr when the duct burner i s in operation. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Record kee ping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the testing and recertification requirements of 40 CFR Part 60 and 40 CFR Part 75. The permittee shall demonstrate compliance using Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A, and the procedures specified in 40 CFR 60.4400. Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA. See f)(2) for emissio n testing requirement.
e. Emission Limitation: NOx emissions shall not exceed 88.4 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation is based on the following anticipated worst case emissions: hourlyNOx emissions, at average ambient conditions with duct firing during 100 percent load steady state operation, of 25.3 Lbs/hr with DB firing and 19.3 Lbs/hr without DB firing based on manufacturer’s data and steady state operating hours. The allowable annual emission rate was determined by the following calculation using the above information: 

### [ (

. )

. (

. )

. ] 

## = 88.4 TPY NOx Ongoing compliance with the NOx emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit f. Emission Limitations: NOx emissions from this emissions unit shall not exceed:Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 48 of 81 58.3 Lbs/hr during cold startup and 46.2 Lbs/hr during warm startup, averaged over the duration of the event(s); and 32.0 Lbs/event during hot startup, and 28.0 Lbs/event during shutdown. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the testing and recertification requirements of 40 CFR Part 60 and 40 CFR Part 75. g. Emission Limitation: PE, PM 10 emissions, and PM 2.5 emissions shall not exceed 3.80E
-03 Lb/MMBtu of heat input and 10.8 Lbs/hr when the duct burner is not in operation; and PE, PM 10 emissions, and PM 2.5 emissions shall not exceed 5.70E
-03 Lb/MMBtu of heat input and 20.0 Lbs/hr when the duct burner is in operation. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. The permittee shall demonstrate compliance with these emissions l imitations using Methods 201A and 202 of 40 CFR Part 51, Appendix M. Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA. See f)(2) for emission testing requirement. h. Emission Limitation: PE, PM 10 emissions, and PM 2.5 emissions from this emissions unit shall not exceed 59.4 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation is based on the following anticipated worst case emissions: hourly PE/PM10/PM2.5 emissions, at ISO conditions during steady state operation, of 18.9 Lbs/hr with DB firing and 9.4 Lbs/hr without DB firing based on manufacturer’s data and steady state operating hours. The allowable annual emission rate was determined by the following calculation: 

### [ (

. )

. (

. )

. ] 

## = 59.4TPY PE/PM10/PM2.5Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 49 of 81 Ongoing compliance with the PE/PM10/PM2.5 emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit. i. Emission Limitation: The permittee shall install combustion devices in the CTG and DB that are designed to meet 1.4E
-03 Lb SO 2/MMBtu of heat input based on the source design characteristic. Applicable Compliance Method: The Lb/MMBtu source design characteristic was established based on using pipeline quality natural gas having a maximum sulfur content of 0.5 grains per 100 cubic feet according to the following calculation. The source design characteristic was developed by multiplying the m aximum sulfur content of natural gas (0.5 grain S/100 scf) by the molecular weight of SO 2 (64.07 Lb SO 2/Lb
- mole) divided by the molecular weight of sulfur (32.06 Lb S/Lb
- mole) divided by (7,000 grains/Lb), divided by (1,020 Btu/scf), and multiplied by (10 6 Btu/MMBtu). Compliance shall be demonstrated according to 40 CFR 60.4415. j. Emission Limitation: VOC emissions shall not exceed 1.0 ppmvd at 15% oxygen as an hourly average and 3.8 Lbs/hr when the duct burner is not in operation; and, VOC emissions shall not exceed 1.5 ppmvd at 15% oxygen as an hourly average and 7.2 Lbs/hr when the duct burner is in operation. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. The permittee shall demonstrate compliance with this emi ssion limitation through emission testing performed in accordance with Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. Use of Method 18, 25 or 25A is to be selected based on the results of pre-survey stack sampling an d U.S. EPA guidance documents. Alternative U.S. EPA approved test methods may be used with prior approval from Ohio EPA. See f)(2) for emission testing requirement. k. Emission Limitation: VOC emissions shall not exceed 92.3 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation is based on the following anticipated worst case emissions:Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 50 of 81 10 cold startups per year, with a minimum downtime preceding cold startup of 60 hours, a cold startup duration of 142.5 minutes, and maxi mum VOC emissions of 1294 pounds during each cold startup event; 52 warm startups per year, with a minimum downtime preceding warm startup of 12 hours, a warm startup duration of 22.8 minutes, and maximum VOC emissions of 304 pounds during each warm startu p event; 208 hot startups per year, with a minimum downtime preceding hot startup of 0 hours, a hot startup duration of 22.8 minutes, and maximum VOC emissions of 304 pounds during each hot startup event; 270 shutdowns per year, with a shutdown duration of 12.5 minutes, and maximum VOC emissions of 240 pounds during each shutdown event; and hourly VOC emissions at average ambient conditions with duct firing during 100 percent load steady state operation of 6.6 Lbs/hr based on manufacturer’s data and steady state operating hours. The allowable annual emission rate was determined by the following calculation using the above information:

, , . 

### = 92.3 TPY VOC Wh ere: CS = cold starts WS= warm starts HS = hot starts Shut = shutdowns Ongoing compliance with this emissions limitation shall be based on the following calculation:

= (# ) 1 , 294 ∗ + (# ) 304 ∗ + (# ) 304 ∗ + (# Shut) ( 240 ∗ ) + (# ) 6
. 6 ∗ + (# ) ( 3
. 4 ∗) 2000 Wh ere: VOC = tons VOC emissions per rolling, 12
- month period #CS = number of cold startups per rolling, 12
- month period #W S = n umber of warm startups per rolling, 12
- month periodFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 51 of 81 #HS = number of hot startups per rolling, 12
- month period #Shut = number of shutdowns per rolling, 12
- month period #SSDB = hours operated in steady state with duct burner per rolling, 12
- month period #SSN DB = hours operated in steady state without duct burner per rolling, 12
- month period *Or the permittee shall use the most recent emissions rate data in pounds per event and/or pounds per hour obtained via emission testing results, vendor
supplied data, etc

. l. Emission Limitations: VOC emissions from this emissions unit shall not exceed: 675.7 Lbs/hr during cold startup and 508.4 Lbs/hr during warm startup, averaged over the duration of the event(s); and 374.0 Lbs/event during hot startup, and 298.0 Lbs/event during shutdown. Applicable Compliance Method: These emissions limitations are based on manufacturer’s data. If required, the permittee shall demonstrate compliance with these emission limitations through emission testing performed in accordance with Meth ods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. Use of Method 18, 25 or 25A is to be selected based on the results of pre
-survey stack sampling and U.S. EPA guidance documents. Alternative U.S. EPA approved test methods may be used with prior approval from Ohio EPA.
m. Emission Limitation: H 2SO 4 emissions shall not exceed 1.1E
-03 Lb/MMBtu of heat input and 3.5 Lbs/hr when the duct burner is not in operation; and, H 2SO 4 emissions shall not exceed 1.1E
-03 Lb/MMBtu of heat inpu t and 4.3 Lbs/hr when the duct burner is in operation. These emissions limitations are based on manufacturer’s data. The permittee shall demonstrate compliance using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. See f)(2) for emission testing requirement.
n. Emission Limitation: H 2SO 4 emissions shall not exceed 14.0 tons per rolling, 12
- month period.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 52 of 81 Applicable Compliance Method: This emission limitation was developed by multiplying the short
-term allowable H 2SO 4 emission limitation (1.1E
-03 Lb/MMBtu) by the maximum steady state fuel usage (25,534,234 MMBtu/yr), and then dividing by 2,000 pounds per ton. Therefore, if compliance is shown with the short
-te rm allowable emission limitation, compliance shall also be shown with the annual emission limitation.
o. Emission Limitation: CO 2e emissions shall not exceed 880 Lb/MW
-hr and 375,130 Lbs/hr gross energy output, @ ISO conditions, 100% load, without duct firing, and 1,626,781 tons per rolling, 12
- month period. Applicable Compliance Method: The allowable hourly emission rate was determined by the following calculation: 855 Lbs CO2e/MW
-hr x CT g ross power, 439 MW = 375,130 Lbs CO2e The permittee shall conduct emissions testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the hourly CO 2 emission rate. S ee f)(2) for emission testing requirement. Since the CO2e emissions are estimated to consist of more than 99% CO2, compliance with this emission limitation will be assumed provided that the hourly CO2 emission rate does not exceed 371,833 Lbs/hr gross energy output, @ ISO conditions, 100% load, without duct firing, The al lowable annual emission rate was determined by the following calculation: CO 2 e = [ fuel 120
. 243 ( 1) + fuel 0
. 0086 (25) + fuel 2000 = 1,549,315 TPY CO 2e Wh ere: CO 2e = Equivalent CO2 emissi ons; Fuel = maximum fuel usage, natural gas, 25,534,234 MMBtu/yr; and the associated global warming potential for each pollutant (CO 2=1, CH 4=25, N 2O=298 from Table A
- 1 of 40 CFR 98, November 29, 2013). The Allowable Emissions includes a 5% margin for CT degradation in thermal efficiency: 1,549,315 TPY CO 2e + [(1,549,315 TPY CO 2e)(0.05)] = 1,626,781 TPY CO 2eFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 53 of 81 Since the CO 2e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the rolli ng, 12
- month CO 2 emissions as calculated in section d) above do not exceed 1,611,914 tons per rolling, 12
- month period. p. Emission Limitation: Visible particulate emissions from any stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. Applicable Compliance Method: If required, the permittee shall demonstrate compliance with this emissions limitation using Method 9 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be approved with prior approval from Ohio EPA. (2) The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the following requirements:
a. The emission testing shall be conducted within 60 days after achieving the maximum production rate at which the emissions unit will be operated, but not later than 180 days after initial startup of the emissions unit. b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate(s) for CO, NO x, PE, PM 10 , PM 2.5 , VOC, and H 2SO 4 , in the appropriate averaging period(s). The emission testing shall also be conducted to determine a site
-specific emission factor for CO 2 . c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): For CO, Methods 1 thru 4 and 10 of 40 CFR Part 60, Appendix A; For NOx, Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A, and the procedures specified in 40 CFR 60.4400; For PE, Method 5 of 40 CFR Part 60, Appendix A; For PM 10 and PM 2.5 , Methods 201A and 202 of 40 CFR Part 52, Appendix M; For SO 2 , 40 CFR 60.4415; For VOC, Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. U se of Method 18, 25 or 25A is to be selected based on the results of pre
-survey stack sampling and U.S. EPA guidance documents; For H 2SO 4 , Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A; and For CO 2 , Methods 1, 2, 3A, and 4 of 40 CFR Part 60, Appendix A.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 54 of 81 Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. d. The test(s) shall be conducted under those representative conditions that challenge to the fullest extent possible a facility’s ability to meet the applicable emissions limits and/or control requirements, unless otherwise specified or app roved by the appropriate Ohio EPA District Office or local air agency. Although this generally consists of operating the emissions unit at its maximum material input/production rates and results in the highest emission rate of the tested pollutant, there may be circumstances where a lower emissions loading is deemed the most challenging control scenario. Failure to test under these conditions is justification for not accepting the test results as a demonstration of compliance.
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 Ohio EPA District Office's or local air agency's 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. (3) Within 60 days of achieving the maximum production rate at which the emissions unit(s) wi ll be operated, but not later than 180 days after initial startup, the permittee shall conduct certification tests of the continuous NOx monitoring system, in units of the applicable standard(s), to demonstrate compliance with 40 CFR Part 60, Appendix B, Performance Specification 2; Performance Specification 6 relative accuracy requirements; ORC section 3704.03(I); and 40 CFR Part 75. The permittee shall certify that the fuel flow monitor/meter meets 40 CFR 75 certification requirements prior to the perform ance specification test and shall demonstrate how the pound per hour emissions of NOx will be calculated stoichiometrically from the fuel flow rate. Personnel fr

om the Ohio EPA Central Office and the appropriate Ohio EPA District Office or local air agency shall be notified 45 days prior to initiation of the applicableFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 55 of 81 tests and shall be permitted to examine equipment and witness the certification tests. Two copies of the test results shall be submitted to Ohio EPA, one copy to the appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA Central Office, and pursuant to OAC rule 3745
- 15
-04, within 30 days after the test is completed. Certification, or recommendation for certification by Ohio EPA to U.S. EPA, of the continuous NOx mon itoring system shall be granted upon determination by the Ohio EPA, Central Office that the system meets the requirements of 40 CFR Part 60, Appendix B, Performance Specification 2; Performance Specification 6 relative accuracy requirements; ORC section 37 04.03(I); and 40 CFR Part 75. Ongoing compliance with the NOx emissions limitations contained in this permit, 40 CFR Parts 60 and 75, and any other applicable standard(s) shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the testing and recertification requirements of 40 CFR Part 60 and 40 CFR Part 75. (4) Within 60 days of achieving th e maximum production rate at which the emissions unit(s) will be operated, but not later than 180 days after initial startup, the permittee shall conduct certification tests of the continuous CO monitoring system in units of the applicable standard(s), to demonstrate compliance with 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy requirements; and ORC section 3704.03(I). The permittee shall certify that the fuel flow monitor/meter is calibrated prior to the performance specification test and shall demonstrate how the pound per hour emissions of CO will be calculated stoichiometrically from the fuel flow rate. Personnel fr

om the Ohio EPA Central Office and the appropriate Ohio EPA D istrict Office or local air agency shall be notified 30 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests. Two copies of the test results shall be submitted to Ohio EPA, one co py to the appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA Central Office, and pursuant to OAC rule 3745
- 15
-04, within 30 days after the test is completed. Certification of the continuous CO monitoring system shall be granted upon determination by the Ohio EPA Central Office that the system meets the requirements of 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy requirements; and ORC section 3704. 03(I). Ongoing compliance with the CO emission limitations contained in this permit, 40 CFR Part 60, and any other applicable standard(s) shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this perm it; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 56 of 81 g) Miscellaneous Requirements (1) ISO conditions are 288 degrees Kelvin (15 degrees Celsius), 60% relative humidity a nd 101.3 kilopascals pressure. (2) One CEM data point is equivalent to one
- minute of data.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 57 of 81 3. P002, Emergency Generator Operations, Property and/or Equipment Description: Emergency diesel engine powered standby generator, rated at 1,100 kilowatts. a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only. (1) None. b) Applicable Emissions Limitations and/or Control Requirements (1) The specific operation(s), prope rty, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table. Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. OAC rule 3745
-31
-05(A)(3), as effective 11/30/2001 The permittee shall equip the combustion engine such that SO 2 emissions shall not exceed 5.50E
-03 g/hp
- hr based on the source design characteristic. see b)(2)a. and b)(2)b. b. OAC rule 3745
-31
-05(A)(3)(b), as effective 12/01/2006 see b)(2)c.
c. OAC rule 3745
-31
-05(D) Synthetic Minor to avoid Nonattainment Area New Source Review (NAA
- NSR) for NOx and VOC The NOx emissions shall not exceed 7.25 TPY based on a rolling 12
- month summation. The VOC emissions shall not exceed 0.26 TPY based on a rolling 12
- m onth summation. see b)(2)e. d. OAC rule 3745
-31
- 11 through 20 CO emissions shall not exceed 2.61 g/hp
hr, 8.49 Lbs/hr, and 2.12 tons per rolling, 12
- month period. NOx emissions shall not exceed 8.92 g/hp
- hr, 29.01 Lbs/hr, and 7.25 tons per rolling, 12
- month period. PE, PM 10 , and PM 2.5 emissions shall not exceed 0.236 g/hp
- hr, 0.77 Lb./hr, and 0.19 ton per rolling, 12
- month period.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 58 of 81 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures Sulfuric acid mist (H 2SO 4 ) emissions shall not exceed 6.74E
-04 g/hp
- hr, 2.19 E
-03 Lb/hr and 5.48E
-04 ton per rolling, 1 2
- month period. Carbon dioxide equivalent (CO 2e) emissions shall not exceed 474 tons per rolling, 12
- month period. see b)(2)d. and b)(2)e. e. OAC rule 3745
- 17
-07(A)(1) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. f. OAC rule 3745
- 17
- 11(B)(5)(a) see b)(2)f. g. OAC rule 3745
- 18
-06(G) see b)(2)j. h. OAC rule 3745
- 110
-03(K)(20) exemption

– see b)(2)g. i. 40 CFR Part 60, Subpart A (40 CFR 60.1
- 19) Table 8 to Subpart IIII of 40 CFR Part 60

– Applicability of General Provisions to Subpart IIII shows which parts of the General Provisions in 40 CFR 60.1
- 19 apply. j. 40 CFR Part 60, Subpart IIII (40 CFR 60.4200

–4219) [In accordance with 40 CFR 60.4200(a)(2), this emissio ns unit is a compression ignition emergency stationary internal combustion engine (CI ICE) for which construction commenced after July 11, 2005 subject to the emissions limitation/control measures specified in this section.] see b)(2)h. and b(2)k. Exhaust opacity shall not exceed: 20 percent during acceleration mode; 15 percent during lugging mode; and 50 percent during the peaks in either the acceleration or lugging modes. [60.4205(b) and 60.4207(b)]

k. 40 CFR Part 63, Subpart ZZZZ (40 CFR 63.6580
-63.66 75) [In accordance with 40 CFR 63.6590(c)(1), this emissions unit is a new stationary internal combustion engine (RICE) located at an area source of HAP emissions subject to the emissions limitation/control measures specified in this section.] see b)(2)i. [63.6590(c), (c)(1)]Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 59 of 81 (2) Additional Terms and Conditions
a. BAT for CO, NOx, and PE/PM 10/PM 2.5 emissions is equivalent to the BACT requirements established through OAC rules 3745
-31
- 11 through 20. BAT for VOC is equivalent to the requirements established through OAC rule 3745
-31
- 05(D). b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745
-31
-05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745
-31
-05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745
-31
-05, the requirement to satisfy BAT still exists as part of the federally
-approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05, then these emission limitations/control measures no longer apply.
c. These rule paragraphs apply once U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05 as part of the State Implementation Plan. i. The Best Available Technology (BAT) requirements under OAC rule 3745
-31
-05(A)(3) do not apply to the SO 2 emissions from this air contaminant source since the uncontrolled potential to emit for SO 2 is less than 10 TPY. ii. The Best Available Technology (BAT) requirements under OAC rule 3745
-31
-05(A)(3) do not apply to the CO, NOx, and PE/PM 10/PM 2.5 emissions from this air contaminant source since the uncontrolled potential to emit for CO, NOx, and PE/PM 10/PM 2.5 is less than 10 TPY, each, taking into account the federally enforceable emissions limitations and operating hours restriction specified by OAC rule 3745
-31
- 11 through 20. d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10/PM 2.5 emissions limitations include both filterable and condensable particulate emissions.
e. The maximum annual operating hours for this emissions unit shall not exceed 500 hours , based upon a rolling, 12
- month summation of the operating hours. To ensure enforceability during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall not exceed the operating hours levels specified in the following table:Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 60 of 81 Maximum Allowable Month(s) C umulative Operating Hours 1 500 1
-2 500 1
-3 500 1
-4 500 1
-5 500 1
-6 500 1
-7 500 1
-8 500 1
-9 500 1
- 10 500 1
- 11 500 1
- 12 500 After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual operating hours limitation shall be based upon a rolling, 12
- month summation of the operating hours. f. The emission limitation specified by this rule is less stringent than the emission limitation established by OAC rule 3745
-31
- 11 through 20. g. The permittee is exempt fr om the requirements of OAC rule 3745
- 110
-03(A) through (G) since this emissions will be issued a PTI that is subject to BACT. h. Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in §60.4202, for all pollutants, for the same model year and maximum engine power for their 2007 model year and later emergency stationary CI ICE. Stationary CI ICE manufacturers must certify their 2007 model year and later emergency stationa ry CI ICE with a maximum engine power less than 2,237 KW (3,000 HP) and a displacement of less than 10 liters per cylinder that are not fire pump engines to the emission standards for all pollutants as specified in 40 CFR 89.112 and 40 CFR 89.113, for engi nes with a maximum engine power greater than or equal to 37 KW (50 HP). 40 CFR 89.112 contains the emission standards for new and in
- use nonroad CI engines for NOx, HC, NMHC + NOx, CO, and PM. I n lieu of the NOx, NMHC + NOx, and PM standards in Table 1 of §89.112, manufacturers may elect to include engine families in the averaging, banking, and trading program and set a Family Emission Limit (FEL) not to exceed the levels contained in Table 2 of §89.112. The FEL established by the manufacturer serves as the standard for that engine family. 40 CFR 89.113 contains the opacity standards for new and in
-use nonroad CI engines.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 61 of 81 i. This emissions unit must meet the requirements of 40 CFR Part 60 Subpart IIII. No further requirements apply under this subpart. j. The em ission limitation established by this rule is less stringent than the limitation established in 40 CFR Part 60, Subpart IIII. k. The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standards: i. 15 ppm maximum sulfur content; and ii. a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. c) Operational Restrictions (1) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219). d) Monitoring and/or Recordkeeping Requirements (1) The permittee shall maintain monthly records of the following information:
a. the CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emission rate for each month of operations; and b. beginning after the first 12 calendar months of operation or the first 12 calendar months followin g the issuance of this permit, the rolling, 12
- month summation of the CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emissions. (2) The permittee shall maintain monthly records of the following information:
a. the operating hours for each month; and b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the operating hours. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative operating hours for each calendar month. (3) For each shipment of diesel fuel received for burning in this emissions unit, the permittee shall maintain records of the oil supplier's (or permittee’s) analyses for sulfur content in parts per million (40 CFR 80.510). The permittee shall perform or require the supplier to perform the analyses for sulfur content in accordance with 40 CFR 80.585. (4) The permittee shall also maintain documen tation of supplier verification that the diesel fuel as purchased has a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. (5) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 62 of 81 e) Reporting Requirements (1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:
a. each shipment of diesel fuel received for burning in this emissions unit which did not comply with the per gallon standards specified in b)(2); b. all exceedances of the rolling, 12
- month l imitation on the hours of operation for this emissions unit; and for the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, all exceedances of the maximum allowable cumulative hours of operation; an d
c. allexceedances of the rolling, 12
- month emission limitation for CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emissions. The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. (2) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219). (3) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: Air Services online web portal. f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
a. Emission Limitation: CO emissions shall not exceed 2.61 g/hp
- hr, 8.49 Lbs/hr, and 2.12 tons per rolling, 12
- month period. Applicable Compliance Method: The g/hp
-hr limitation is supplied in PTI Application A0050416 and based on the NSPS Subpart IIII requirement in §60.4202(a)(2) through §89.112 Table 1. The §89.112 requirement was converted to g/hp
-hr by dividing the emission standard (3.5 g/KW
-hr) by the unit conversion (1.34 hp
- hr/KW
-hr). The hourly emission limitation was developed by multiplying the maximum operating load (1475 HP) by the CO emission factor supplied by the manufacturer (2.61 g/hp
- hr) and dividing by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 1 thru 4 and 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.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 63 of 81 The annual emission limitation was developed by multiplying the hourly emission limitation (8.49 Lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1). b. Emission Limitation: NOx emissions shall not exceed 8.92 g/hp
-hr, 29.01 Lbs/hr, and 7.25 tons per rolling, 12
- month period. Applicable Compliance Method: The g/hp
- hr limitation is based on manufacturer’s data supplied in PTI Application A0050416. The hourly emission limitation was developed by multiplying the m aximum operating load (1475 HP) by the NOx emission factor supplied by the manufacturer (8.92 g/hp
- hr) divided by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emissi on limitation (29.01 Lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1).
c. Emission Limitation: PE, P M 10 , and PM 2.5 emissions shall not exceed 0.236 g/hp
-hr, 0.77 Lbs/hr, and 0.19 tons per rolling, 12
- month period. Applicable Compliance Method: The g/hp
- hr limitation is based on manufacturer’s data supplied in PTI Application A0050416. The hourly emissio n limitation was developed by multiplying the maximum operating load (1475 HP) by the PE/PM 10/PM 2.5 emission factor supplied by the manufacturer (0.236 g/hp
- hr) divided by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall de monstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 201 or 201A and 202 of 40 CFR Part 51, Appendix M. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (0.77 Lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 64 of 81 d. Emission Limitation: The permittee shall equip the combustion engine such that SO 2 emissions shall not exceed 5.50E
-03 g/hp
- hr based on the source design characteristic. Applicable Compliance Method: The g/hp
- hr limitation is supplied in PTI Application A0050416 as derived from the emission factor in AP
-42, Fifth Ed., Large Stationary Diesel And All Stationary Dual
-fuel Engines, Table 3.4
- 1, 10/96, using 0.0015 percent sulfur. If required, the permittee shall demonstrate co mpliance with the hourly emission limitation using Methods 1 thru 4 and 6C of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA.
e. Emission Limitation: VOC emissions shall not exceed 0.2 6 tons per rolling, 12
- month period. Applicable Compliance Method: The annual emission limitation was developed by multiplying the maximum hourly emissions (1.04 Lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1). f. Emission Limitation: Sulfuric acid mist (H 2SO 4 ) emissions shall not exceed 6.74E
-04 g/hp
- hr, 2.19 E
03 Lb/hr and 5.48E
-04 ton per rolling, 12
- month period. Applicable Compliance Method: The g/hp
- hr limitation is based on a conservative estimate of 10% conversion of SO 2 to SO 3 and 100% conversion of SO 3 to H2SO 4 . The pound per hour emissions limitation was developed by multiplying the g/hp
- hr allowable H 2SO 4 emission limitation (6.74E
-04 g/hp
-hr) by the maximum operating load (1475 HP) and divided by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with th e g/hp
- hr and Lb/hr emission limitation using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The ton per year emission limitation was developed by multi plying the hourly allowable H 2SO 4 emission limitation (2.19E
-04 Lb/hr) by the maximum annual hours of operation (500 hours), and then dividing by 2,000 pounds per ton. Therefore, if compliance is shown with the short
-term allowable emission limitation, co mpliance shall also be shown with the annual emission limitation.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 65 of 81 g. Emission Limitation: Carbon dioxide equivalent (CO 2e) emissions shall not exceed 474 tons per rolling, 12
- month period. Applicable Compliance Method: This emissions limitation was established to reflect the potential to emit for this emissions unit by calculating the sum of the maximum capacity multiplied by the emission factors for CO 2 , N 2O, and CH 4 , multiplied by the global warming potential for CO 2 , N 2O, and CH 4 (1, 298, and 25, respective ly from Table A
- 1 to Subpart A of 40 CFR 98). The CO 2 emission factor was obtained from AP
-42 Table 3.4
- 1 dated 10/96 (165 Lb/MMBtu). The N 2O emission factor was derived from AP
-42 Table 1.3
-8 dated 5/10 (0.26 Lb N 2O/10 3 gal x 10 3 gal/141.666E6 Btu x 1E6Btu/MMBtu = 0.00184 Lb N 2O/MMBtu). The CH 4 emission factor was obtained from AP
-42 Table 3.4
- 1 dated 10/96 (0.09 Lb TOC/MMBtu x 0.09 Lb CH 4/Lb TOC = 0.0081 Lb CH 4/MMBtu).
5716 ( 165 ) ( 1) + 0
. 00184 (298 )

+ (0
. 0081 (25 ) ) 2 , 000 = 474 /
Since the CO 2e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the Lb/hp
hr CO 2 emission rate does not exceed 165 Lb/MMBtu. If required, the permittee shall conduct emission testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the Lb/hp
-hr CO 2 emission rate. h. Emission Limitation: The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standard: 15 ppm maximum sulfur content Applicable Compliance Method: The records required by d)(3) shall be used to demonstrate compliance. i. Emission Limitation: The permittee shall only combust diesel fuel in this emissions unit m eeting the following per gallon standard: a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. Applicable Compliance Method: The records required by d)(4) shall serve as demonstration of compliance.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 66 of 81 j. Emission Limitation: Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. Applicable Compliance Method: If required, the permittee shall demonstrate compliance according to Method 9 of 40 CFR Part 60, Appen dix A. k. Emission Limitation: Exhaust opacity shall not exceed: 20 percent during acceleration mode; 15 percent during lugging mode; and 50 percent during the peaks in either the acceleration or lugging modes. Applicable Compliance Method: According to 40 CFR 60.4211(c), the permittee shall demonstrate compliance with these emission limitations by purchasing an engine certified to the emission standards in 40 CFR 60.4205(b) for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer’s emission
- related specifications, except as permitted in 40 CFR 60.4211(g). The permittee shall maintain documentation of certification to the emission standards in 40 CFR 60.4205. If required, the permittee shall demonstrate compliance according to Method 9 of 40 CFR Part 60, Appendix A. g) Miscellaneous Requirements (1) None.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 67 of 81 4. P003, Emergency Fire Pump Engine Operations, Property and/or Equipment Description: Emergency diesel fire pump engine is rated at a maximum 260 BHP. a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only. (1) None. b) Applicable Emissions Limitations and/or Control Requirements (1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table. Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. OAC rule 3745
-31
-05(A)(3), as effective 11/30/2001 The permittee shall equip the combustion engine such that SO 2 emissions shall not exceed 5.5E
-03 g/hp
- hr (1.21E
-05 Lb/hp
hr) based on the source design characteristic. see b)(2)a. and b)(2)b. b. OAC rule 3745
-31
-05(A)(3)(b), as effective 12/01/2006 see b)(2)c.
c. OAC rule 3745
-31
-05(D) Synthetic Minor to avoid Nonattainment Area New Source Review (NAA
- NSR) for NOx and VOC The NOx emissions shall not exceed 0.43 TPY based on a rolling 12
- month summation. The VOC emissions shall not exceed 0.017 TPY based on a rolling 12
- month summation. see b)(2)e. d. OAC rule 3745
-31
- 11 through 20 CO emissions shall not exceed 1.2 g/hp
hr, 0.69 pounds per hour (Lbs/hr), and 0.17 ton per rolling, 12
- month period. NOx emissions shall not exceed 3.0 g/hp
hr, 1.72 Lb/hr, and 0.43 ton per rolling, 12
- month period. PE, PM 10 , and PM 2.5 emissions shall not exceed 0.15 g/hp
- hr, 0.09 Lb/hr, andFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 68 of 81 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures 0.023 ton per rolling, 12
- month period. H 2SO 4 emissions shall not exceed 6.7E
04 g/hp
- hr, 3.9E
-04 Lb/hr and 9.7E
-05 ton per rolling, 12
- month period CO 2e emissions shall not exceed 75 tons per rolling, 12
- month period. see b)(2)d. and b)(2)e. e. OAC rule 3745
- 17
-07(A)(1) Visible particulate emissi ons fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. f. OAC rule 3745
- 17
- 11(B)(5)(a) see b)(2)f. g. OAC rule 3745
- 18
-06(G) The emission limitation established by this rule is less stringent than the limitation established in 40 CFR Part 60, Subpart IIII. h. OAC rule 3745
- 110
-03(K)(20) exemption

– see b)(2)g. i. 40 CFR Part 60, Subpart A (40 CFR 60.1
- 19) Table 8 to Subpart IIII of 40 CFR Part 60

– Applicability of General Provisions to Subpart IIII s hows which parts of the General Provisions in 40 CFR 60.1
- 19 apply. j. 40 CFR Part 60, Subpart IIII (40 CFR 60.4200

–4219) [In accordance with 40 CFR 60.4200(a)(2), this emissions unit is a compression ignition stationary internal combustion fire pump engine for which construction commenced after July 11, 2005 subject to the emissions limitation/control measures specified in this section.] Non
- methane hydrocarbon (NMHC) + NOx emissions shall not exceed 3.0 g/hp
hr. PM emissions shall not exceed 0.15 g/hp
hr. see b)(2)h. [60.4202(d) and 60.4205(c)]
k. 40 CFR Part 63, Subpart ZZZZ (40 CFR 63.6580
-63.6675) [In accordance with 40 CFR 63.6590(c)(1), this emissions unit is a new stationary reciprocating internal combustion engine (RICE) located at an area source of HAP emissions subject to the emission see b)(2)i [63.6590(c), (c)(1)]Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 69 of 81 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures limitation/control measures specified in this section.] (2) Additional Terms and Conditions
a. BAT for CO, NOx, and PE/PM 10/PM 2.5 emissions is equivalent to the BACT requirements established through OAC rules 3745
-31
- 11 through 20. BAT for VOC is equivalent to the requirements establis hed through OAC rule 3745
-31
- 05(D). b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745
-31
-05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, pa ragraph (A)(3) of OAC rule 3745
-31
-05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745
-31
-05, the requirement to satisfy BAT still exists as part of the federally
-approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05, then these emission limitations/control measures no longer apply.
c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05 as part of the State Implementation Plan. The Best Available Technology (BAT) requirements under OAC rule 3745
-31
- 05(A)(3) do not apply to the CO, NOx, PE/PM10/PM2.5, VOC and SO 2 emissions fr om this air contaminant source since the uncontrolled PTE for CO, NOx, PE/PM10/PM2.5, VOC and SO 2 is less than 10 TPY each. d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10/PM 2.5 emission limitations include both filterable and condensable particulate emissions.
e. The maximum annual operating hours for this emissions unit shall not exceed 500 hours , based upon a rolling, 12
- month summation of the operating hours. To ensure enforceability during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall not exceed the operating hours levels specified in the following table:Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 70 of 81 Maximum Allowable Month(s) Cumulative Operating Hours 1 500 1
-2 500 1
-3 500 1
-4 500 1
-5 500 1
-6 500 1
-7 500 1
-8 500 1
-9 500 1
- 10 500 1
- 11 500 1
- 12 500 After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual operating hours limitation shall be based upon a rolling, 12
- month summation of the operating hours. f. The emiss ion limitation specified by this rule is less stringent than the emission limitation established by OAC rule 3745
-31
- 11 through 20. g. The permittee is exempt fr om the requirements of OAC rule 3745
- 110
-03(A) through (G) since this emissions will be issued a PTI that is subject to BACT. h. The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standards: 15 ppm maximum sulfur content; and
a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. i. This emissions unit must meet the requirements of 40 CFR Part 60 Subpart IIII. No further requirements apply under this subpart. c) Operational Restrictions (1) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219). d) Monitoring and/or Recordkeeping Requirements (1) The permittee shall maintain monthly records of the following information:
a. the CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emission rate for each month of operations; andFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 71 of 81 b. beginning after the first 12 calendar months of operation or the first 12 calendar m onths following the issuance of this permit, the rolling, 12
- month summation of the CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emissions. (2) The permittee shall maintain monthly records of the following information:
a. the operating hours for each month ; and b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12
- month summation of the operating hours. Also, during the first 12 calendar months of operation or the first 12 ca lendar months following the issuance of this permit, the permittee shall record the cumulative operating hours for each calendar month. (3) For each shipment of diesel fuel received for burning in this emissions unit, the permittee shall maintain records of th e oil supplier's (or permittee’s) analyses for sulfur content in parts per million (40 CFR 80.510). The permittee shall perform or require the supplier to perform the analyses for sulfur content in accordance with 40 CFR 80.585. (4) The permittee shall also ma intain documentation of supplier verification that the diesel fuel as purchased has a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. (5) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219). e) Reporting Requirements (1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:
a. each shipment of diesel fuel received for burning in this emissions unit which did not comply with the per gallon standards specified in b)(2); b. all exceedances of the rolling, 12
- month limitation on the hours of operation for this emissions unit; and for the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, all exceedances of the maximum allowable cumulative hours of operation; and
c. allexceedances of the rolling, 12
- month emission limitation for CO, NOx, PE/PM10/PM2.5, VOC, CO 2e and H2SO4 emissions. The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. (2) See 40 CFR Part 60, Subpart IIII (40 CFR 60.4200
-4219). (3) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: Air Services online web portal.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 72 of 81 f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:
a. Emission Limitations: CO emissions shall not exceed 1.2 g/hp
- hr, 0.69 pounds per hour (Lbs/hr), and 0.17 ton per rolling, 12
- month period. Applicable Compliance Method: The g/hp
- hr limitation is based on the engine manufacturer’s specification for CO emissions, multiplied by a factor of 3. The hourly emission limitation was developed by multiplying the maximum operating load (260 hp) by the g/hp
- hr CO emission limitation (1.2 g/hp
- hr) divided by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 1 thru 4 and 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. The annual emission limitation was developed by multiplying the hourly emission limitation (0.69 Lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demon strated by the recordkeeping in d)(1). b. Emission Limitation: NOx emissions shall not exceed 3.0 g/hp
- hr, 1.72 Lbs/hr, and 0.43 ton per rolling, 12
- month period. Applicable Compliance Method: The g/hp
-hr limitation is based on the engine manufacturer’s specification for NOx emissions. The hourly emission limitation was developed by multiplying the maximum operating load (260 hp) by the g/hp
-hrNOx emission limitation (3.0 g/hp
- hr) divided by (453.59 g/Lb) to determine the hourly emissions. If required, the pe rmittee shall demonstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (1.72 Lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 73 of 81 c. Emission Limitation: PE, PM 10 , and PM 2.5 emissions shall not exceed 0.15 g/hp
- hr, 0.09 Lb/hr, and 0.023 ton per rolling, 12
- month period. Applicable Compliance Method: The g/hp
-hr limitation is based on the emission standard for PM from 40 CFR Part 60, Subpart IIII, Table 4. The hourly emission limitation was developed by multiplying the maximum operating load (260 hp) by the PM emission factor based on the Federal standard (0.15 g/hp
- hr) divided by (453.59 g/Lb) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with the g/hp
- hr limitation and hourly emission limitation using Methods 201 or 201A and 202 of 40 CFR Part 51, Appendix M. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (0.09 Lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1). d. Emission Limitation: The permittee shall equip the combustion engine such that SO 2 emissions shall not exceed 5.5E
-03 g/hp
- hr (1.21E
-05 Lb/hp
-hr) based on the source design characteristic. Applicable Compliance Method: The g/hp
- hr limitation is derived fr om the method supplied by the permittee in Application A0050416 for calculating SO2 emissions taking into account the fuel sulfur content. If required, the permittee shall demonstrate compliance with the g/hp
- hr limitation using Methods 1 thru 4 and 6C of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio E PA.
e. Emission Limitation: The VOC emissions shall not exceed 0.017 TPY based on a rolling 12
- month summation. Applicable Compliance Method: The annual emission limitation was developed by multiplying the maximum operating load (260 hp) by the engine manufacturer’s specification for VOC emissions (0.12 g/hp
- hr) divided by (453.59 g/Lb), and multiplied by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds perFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 74 of 81 ton. Compliance with the rolling, 12
- month emission limitation shall be dem onstrated by the recordkeeping in d)(1). f. Emission Limitation: H 2SO 4 emissions shall not exceed 6.7E
-04 g/hp
-hr, 3.9E
-04 Lb/hr and 9.7E
-05 ton per rolling, 12
- month period Applicable Compliance Method: The g/hp
- hr limitation is based on a conservative estimate of 10% conversion of SO 2 to SO 3 and 100% conversion of SO 3 to H2SO 4 . The pound per hour emissions limitation was developed by multiplying the g/hp
- hr allowable H 2SO 4 emission limitation (6.7E
-04 g/hp
- hr) by the maximum operating load (260 hp) and divided by 453.59 grams per pound to determine the hourly emissions (3.9E
04 Lb/hr). If required, the permittee shall demonstrate compliance with the g/hp
- hr and Lb/hr emission limitation using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. The ton per year emission limitation was developed by multiplying the hourly allowable H 2SO 4 emission limitation (3.9E
-04 Lb/hr) by the maximum annual hours of operation (500 hours), and then dividing by 2,000 pounds per ton. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1). g. Emission Limitation: CO 2e emissions shall not exceed 75 tons per rolling, 12
- month period. Applicable Compliance Method: This emission limitation was established to reflect the potential to emit for this emissions unit by calculating the sum of the maximum capacity multiplied by the emission factors for CO 2 , N 2O, and CH 4 , multiplied by the global warming potential for CO 2 , N 2O, and CH 4 (1, 298, and 25, respectively from Table A
- 1 to Subpart A of 40 CFR 98). The CO 2 emission factor was obtained from AP
-42 Table 3.3
- 1 dated 10/96 (164 Lb/MMBtu). The N 2O emission factor was derived from AP
-42 Table 1.3
-8 dated 5/10 (0.26 Lb N 2O/10 3 gal x 10 3 gal/141.666E6 Btu x 1E6Btu/MMBtu = 0.00184 Lb N 2O/MMBtu). The CH 4 emission factor was obtained from AP
-42 Table 3.4
- 1 dated 10/96 (0.09 Lb TOC/MMBtu x 0.09 Lb CH 4/L b TOC = 0.0081 Lb CH 4/MMBtu).Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 75 of 81 900 ( 165 ) ( 1) + 0
. 00184 (298)

+ (0
. 0081 (25 ) ) 2, 000 = 75 /
If required, the permittee shall conduct emission testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the Lb/hp
-hr CO 2 emission rate. Compliance with the rolling, 12
- month emission limitation shall be demonstrated by the recordkeeping in d)(1). h. Emission Limitation: The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standard: 15 ppm maximum sulfur content Applicable Compliance Method: The records required by d)(3) shall be used to demonstrate compliance. i. Emission Limitation: The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standard: a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. Applicable Compliance Method: The records required by d)(4) shall ser ve as demonstration of compliance. j. Emission Limitation: Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. Applicable Compliance Method: If required, the permittee shall demon strate compliance with this emission limitation according to Method 9 of 40 CFR Part 60, Appendix A. k. Emission Limitation: NMHC + NOx emissions shall not exceed 3.0 g/hp
- hr; and PM emissions shall not exceed 0.15 g/hp
- hr Applicable Compliance Method: Accord ing to 40 CFR 60.4211(c), the permittee shall demonstrate compliance with these emission limitations by purchasing an engine certified to the emission standards in 40 CFR 60.4205(c) for the same model year and maximum engineFinal Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 76 of 81 power. The engine must be installed and configured according to the manufacturer’s emission
- related specifications, except as permitted in 40 CFR 60.4211(g). g) Miscellaneous Requirements (1) None.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 77 of 81 5. P004, Cooling Tower Operations, Property and/or Equipment Description: 8
-cell mechanical draft wet cooling tower for steam turbine steam condensation. a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only. (1) None. b) Applicable Emiss ions Limitations and/or Control Requirements (1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table. Applicable Rules/Requirements Applicable Emissions Limitations/Control Meas ures a. OAC rule 3745
-31
-05(A)(3), as effective 11/30/2001 see b)(2)a. and b. b. OAC rule 3745
-31
-05(A)(3)(b), as effective 12/01/2006 see b)(2)c.
c. OAC rules 3745
-31
- 11 through 20 (Prevention of Significant Deterioration of Air Quality) Particulate emissions (PE) shall not exceed 2.685 Lbs/hr and 11.76 TPY. PM 10 emissions shall not exceed 1.70 Lbs/hr and 7.47 TPY. PM 2.5 emissions shall not exceed 0.006 Lbs/hr and 0.025 TPY. The permittee shall install a drift eliminator with a maximum drift rate of 0.0005% on this emissions unit. see c)(1). d. OAC rule 3745
- 17
-07(A)(1) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6
- minute average. e. OAC rule 3745
- 17
- 11(B) see b)(2)d. f. OAC rule 3745
-31
-05(A)(3) ORC 3704.03 Applicable to PE. See b)(2)a.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 78 of 81 (2) Additional Terms and Conditions
a. The requirements of this rule are equivalent to the requirements of OAC rules 3745
-31
- 11 through 20. b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745
-31
-05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745
-31
-05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. However, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745
-31
-05, the requirement to satisfy BAT still exists as part of the federally
-approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05, then these emission limitations/control measures no longer apply.
c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745
-31
-05 as part of the State Implementation Plan. The Best Available Technology (BAT) requirements under OAC rule 3745
-31
- 05(A)(3) do not apply to the PM 10 and PM 2.5 emissions from this air contaminant source si nce the calculated annual emission rate for PM 10 and PM 2.5 is less than 10 tons per year taking into account the federally enforceable limitation of 0.0005% drift and a maximum TDS concentration of 5800 ppm under OAC rules 3745
-31
- 11 through 20. d. The emiss ion limitation specified by this rule is less stringent than the emission limitation established by OAC rules 3745
-31
- 11 through 20. c) Operational Restrictions (1) The permittee shall maintain the total dissolved solids (TDS) concentration of the cooling water less than or equal to 5800 ppm. d) Monitoring and/or Recordkeeping Requirements (1) The permittee shall properly install, operate, and maintain a conductivity meter or other equipment to continuously monitor and record the TDS concentration of the cooling tower water. The monitoring devices shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manuals. (2) Since the TDS data measured by TDS monitors is based on a correlation between conductivity and TDS, an exceedance measured by the TDS monitor is not a violation of the TDS operational restriction, but rather serves as an indicator to initiate corrective action by the permittee to reduce the TDS concentration.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 79 of 81 (3) The permittee shall mai ntain a record of all TDS exceedances and any corrective actions taken in effort to correct the exceedance(s). e) Reporting Requirements (1) The permittee shall submit quarterly deviation (excursion) reports that identify all TDS readings in excess of 5800 ppm. The reports shall identify corrective action taken to reduce the TDS concentration. The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit (2) Prior to startup, the permittee shall submit written documentation provided by the vendor/manufacturer, of the maximum drift rate of 0.0005% for the drift eliminator and the premise, basis, and justification for the drift rate. (3) Unless other arrangements have been app roved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: Air Services online web portal. f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in sectio n b) of these terms and conditions shall be determined in accordance with the following methods:
a. Emission Limitation: PE shall not exceed 2.685 Lbs/hr and 11.76 TPY. Applicable Compliance Method: The Lbs/hr PE emission limitation is based on multiplying the maximum recirculating water flow rate (185,000 gal/min) by the density of water (8.34 Lbs/gal) m ultiplied by the decimal fr action drift rate (0.000005) multiplied by the maximum TDS concentration (5800 ppm) multiplied by 60 min/hr. The annual emission limitation is based on multiplying the hourly emission limitation (2.685 Lbs/hr) by the maximum annual hours of operation (8,760 hrs/yr) and dividing by (2,000 Lbs/ton). Compliance with the hourly and annu al emissions limitation will be assumed provided that the TDS concentration recorded in d) remains below 5800 ppm. b. Emission Limitation: PM10 emissions shall not exceed 1.70 Lbs/hr and 7.47 tons per year.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 80 of 81 Applicable Compliance Method: The Lbs/hr PM10 emission limitation is based on multiplying the maximum recirculating water flow rate (185,000 gal/min) by the density of water (8.34 Lbs/gal) m ultiplied by the decimal fr action drift rate (0.000005) multiplied by the maximum TDS concentration (5800 ppm) multiplied by 60 min/hr then multiplied by 63.4% (percentage of PM which is PM10). The annual emission limitation is based on multiplying the hourly emission limitation (1.70 Lbs/hr) by the maximum annual hours of operation (8,760 hrs/yr) and dividing by (2, 000 Lbs/ton). Compliance with the hourly and annual emission limitation will be assumed provided that the TDS concentration recorded in d) remains below 5800 ppm.
c. Emission Limitation: PM 2.5 emissions shall not exceed 0.006 Lbs/hr and 0.025 ton per year. Applicable Compliance Method: The Lbs/hr PM2.5 emission limitation is based on multiplying the maximum recirculating water flow rate (185,000 gal/min) by the density of water (8.34 Lbs/gal) m ultiplied by the decimal fr action drift rate (0.000005) multipli ed by the maximum TDS concentration (5800 ppm) multiplied by 60 min/hr then multiplied by 0.22% (percentage of PM which is PM2.5). The annual emission limitation is based on multiplying the hourly emission limitation (0.006 Lbs/hr) by the maximum annual ho urs of operation (8,760 hrs/yr) and dividing by (2,000 Lbs/ton). Compliance with the hourly and annual emission limitation will be assumed provided that the TDS concentration recorded in d) remains below 5800 ppm d. Emission Limitation: The maximum drift rate shall not exceed 0.0005%. Applicable Compliance Method: Manufacturer's emission data shall be used to demonstrate compliance with this limitation. Within 90 days of startup, the permittee shall submit to the Southwest Ohio Air Quality Agency written documentation provided by the vendor/manufacturer, of the maximum drift rate of 0.0005% for the drift eliminator and the premise, basis, and justification for the drift rate.Final Permit-to -Install NTE Ohio, LLC Permit Number: P0116610 Facility ID: 1409001151 Effective Date : 11/5/2014

Page 81 of 81 e. Emission Limitation: The permittee shall maintain the TDS concentration of the cooling water less than or equal to 5800 ppm. Applicable Compliance Method: The monitoring and recordkeeping requirements under d)(1) and d)(2) shall serve as demonstration of compliance. If required, compliance shall be demonstrated using test procedures that conform to regulation 40 CFR 136, "Test Procedures For The Analysis of Pollutants". Alternative U.S. EPA approved test methods may be used with prior written approval from the Ohio EPA. f. E mission Limitation: Visible particulate emissions shall not exceed 20% opacity as a 6
- minute average. Applicable Compliance Method: If required, compliance with the stack visible particulate emission limitation shall be determined through visible emission observations performed in accordance with Method 9 of 40 CFR Part 60, Appendix A. g) Miscellaneous Requirements (1) None.