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 find 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. Notice 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 Enforcement 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 GHG
How to save money, reduce pollution and reduce energy consumption

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not 

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) Web 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

SWOAQA; 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. Applicability............................................................................................................................................ 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............................................................................................................................ 77

Final Permit-to-Install

NTE Ohio, LLC

Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

Page 1 of 81

Authorization

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 Americas M501JAC or one 

(1) Mitsubishi Hitachi Power Systems Americas M501GAC single power block in a 1x1 combinedcycle 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.

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 above 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 permit does not constitute expressed or implied 

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

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 above described emissions unit(s) of pollutants will be granted the necessary permits 

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

Director 
Final Permit-to-Install

NTE Ohio, LLC

Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

Page 2 of 81

Authorization (continued)

Permit Number: P0116610

Permit Description: Initial installation of either one (1) Mitsubishi Hitachi Power Systems Americas 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 

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

Company Equipment ID: Aux Bioler

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: B002

Company Equipment ID: Fuel Gas Heater

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: B003

Company Equipment ID: Fuel Gas Heater

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P001

Company Equipment ID: CT+HRSG M501JAC or M501GAC

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P002

Company Equipment ID: Emergency Generator

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P003

Company Equipment ID: Emergency Fire Pump Engine

Superseded Permit Number:

General Permit Category and Type: Not Applicable

Emissions Unit ID: P004

Company Equipment ID: Cooling Tower

Superseded Permit Number:

General Permit Category and Type: Not Applicable
Final 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 Conditions
Final 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., Additional Reporting Requirements When 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., Permit 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 specifically 

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. Upon request, the permittee shall also furnish to the 

Director or an authorized representative of the Director, copies of records required to be kept by 

this permit. For information claimed to be confidential in the submittal to the Director, if the 

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

records directly to the Administrator along with a claim of confidentiality.

4. Monitoring and Related Record Keeping and Reporting Requirements

a) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, 

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

required monitoring under this permit:

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

(2) The date(s) analyses were performed.

(3) The company or entity that performed the analyses.

(4) The analytical techniques or methods used.

(5) The results of such analyses.

(6) The operating conditions existing at the time of sampling or measurement. 

b) Each record of any monitoring data, testing data, and support information required pursuant to 

this permit shall be retained for a period of five years from the date the record was created. 

Support information shall include, but not be limited to all calibration and maintenance records 

and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by this permit. Such records may be maintained in computerized form.

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

the permittee shall submit required reports in the following manner:

(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 no deviations occurred during a sixmonth period, the permittee shall submit a semi-annual report, which states that no 

deviations 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 theSouthwest 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 submitted pursuant to OAC rule 3745-15-06.

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

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

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

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 an as-needed basis if the permittee cannot submit the required documents 

through 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 contracted 
Final 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 

additional 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 document requiring signature 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 Director 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 from disclosure to the public of 

confidential information consistent with ORC section 3704.08.

(3) Inspect 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. Progress 

reports shall be submitted semiannually or more frequently if specified in the applicable 

requirement or by the Director of the Ohio EPA. Progress reports shall contain the following:

(1) Dates for achieving the activities, milestones, or compliance required 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 violation 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 a specific emissions unit, 

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

limitations, operational restrictions, and control device operating parameter limitations that have 

been detected by the testing, monitoring, and recordkeeping requirements specified in this 

permit, (b) the probable cause of such deviations, and (c) any corrective actions or preventive 

measures which have been or will be taken, shall be submitted to the 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 the 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 the 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 Install

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 accordance 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. Issuance 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 application is made to the 
Final 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 the 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" along 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 law. 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 permit covering the last period the emissions unit operated.

Unless otherwise exempted,no 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 Director. 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 

emissions 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 submit 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 Conditions
Final Permit-to-Install

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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 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.

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 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.

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/dewpoint 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-month period; 

0.276 TPY 

PE/PM10/PM2.5 per rolling, 

12-month period; 6.76E-03 

TPY H2SO4 per rolling, 12-

month period; 4,716 TPY of 

9 MMBtu/hr. 

fuel 

gas/dewB003
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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 Million(s) of British thermal units per hour

MMscf Million(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 NOx
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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

SO2 Sulfur Dioxide

PE Particulate Emissions

PM10 Particulate Matter 10 microns and less in diameter

PM2.5 Particulate Matter 2.5 microns and less in diameter

H2SO4 Sulfuric acid mist emissions

CO2 Carbon Dioxide

CO2e Carbon Dioxide equivalent

GHG Green House Gases
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Permit Number: P0116610

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Page 15 of 81

C. Emissions Unit Terms and Conditions
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1. B001, 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 hightemperature steam when the CTG is offline in order to accommodate more rapid startups 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 

SO2/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-

31-11 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.
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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, PM10, and PM2.5 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.

H2SO4 emissions shall not exceed 1.7E04 Lb/MMBtu, 0.03 pound per hour, and 

0.06 ton per rolling, 12-month period.

CO2e 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 from 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/PM10/PM2.5

emissions includes compliance with the requirements of OAC rule 3745-31-11 

through 20.
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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. On 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. Once 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/PM10/PM2.5, SO2, and VOC emissions from 

this air contaminant source since the uncontrolled potential to emit for NOx, 

PE/PM10/PM2.5, SO2, 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 PM10/PM2.5 emissions 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 are 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 provisions, 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 and 
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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 enforceable.

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 from 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.
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Permit Number: P0116610

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Effective Date:11/5/2014

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(2) The permittee shall maintain monthly records of the following information:

a. the 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/PM10/PM2.5, VOC, CO2e and H2SO4 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/PM10/PM2.5, VOC, CO2e and H2SO4 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 calendar 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. Each 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 calendar 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/PM10/PM2.5, VOC, CO2e 

and H2SO4 emission rates.
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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 

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.

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 emission 

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. 
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Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

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Therefore, compliance with the annual limitation shall be demonstrated if 

compliance with the hourly limitation is shown.

c. Emission Limitation:

PE, PM10, and PM2.5 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/PM10/PM2.5 emission 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 

SO2/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 grain S/100 scf) by the molecular weight of SO2 (64.07 Lb 

SO2/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 (106

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.
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Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

Page 23 of 81

e. Emission Limitation:

VOC emissions 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 (H2SO4) 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 

SO2 emissions are converted to SO3 on a mass basis and 100% of the SO3

emissions are converted to H2SO4 when combined with water vapor by the 

following calculation:

(1.4E-03 Lb SO2/MMBtu)(0.1 Lb SO3/Lb SO2)(98 Lb H2SO4/80 Lb SO3) = 1.7E-04 

Lb H2SO4/MMBtu

Multiply the Lb H2SO4/MMBtu (1.7E-04 Lb/MMBtu) by the maximum heat input 

(150 MMBtu/hr) to determine the maximum hourly H2SO4 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/MMBtu 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.
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Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

Page 24 of 81

g. Emission Limitation:

Carbon dioxide equivalent (CO2e) 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 usage (150 

MMBtu/hr) multiplied by the summation of the AP-42 emission factors from Table 

1.4-2 dated 7/1998 [120,000 Lb CO2/MMscf, 0.64 Lb N2O/MMscf, and 2.3 Lb 

CH4/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 CO2e emissions are estimated to consist of more than 99% CO2, 

compliance with this emission limitation will be assumed provided that the Lb/scf 

CO2 emission rate does not exceed 120,000 Lb/MMscf.

If required, the permittee shall conduct emissions testing using Methods 1, 2, 3A 

and 4 of 40 CFR Part 60, Appendix A to determine the Lb/scf CO2 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.
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Permit Number: P0116610

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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 CO2 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 CO2, 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 

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 

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 "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.
Final Permit-to-Install

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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.
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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 under 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 SO2/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 CO2e 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 from the 

stack serving this emissions unit shall not 

exceed 20 percent opacity as a 6-minute 

average, except as specified by rule.
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Facility ID: 1409001151

Effective Date:11/5/2014

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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, PM10, and PM2.5

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 H2SO4

1 24.9 8.8 5.9 9.2 1.4

1-2 49.8 17.7 11.9 18.5 2.8
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Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

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Maximum Allowable Cumulative Emissions

(Tons)

Month(s) CO NOx PE/PM10/PM2.5 VOC H2SO4

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 emissions from 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 PM10/PM2.5 emissions limitations include both filterable and condensable 

particulate emissions.

g. The permittee shall comply with the following emissions limitations:

Allowable Emissions

Pollutant Operating 

Modea

Emission 

Rateb,e

Emission 

rate, 

Lb/hrb

Emission rate, 

tons per rolling, 

12-month 

period

CO CT with DB 2.0c16.8 -
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Facility ID: 1409001151

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Allowable Emissions

Pollutant Operating 

Modea

Emission 

Rateb,e

Emission 

rate, 

Lb/hrb

Emission rate, 

tons per rolling, 

12-month 

period

CT only 2.0c13.2 -

All operating 

modes, 

including 

startup periods

- - 249.1

NOx CT with DB 2.0c27.7 -

CT only 2.0c21.8 -

All operating 

modes, 

including 

startup periods

88.4

PE/PM10/PM2.5 CT with DB 5.70E-03d20.0 -

CT only 3.80E-03d10.8 -

All operating 

modes, 

including 

startup periods

- - 59.4

H2SO4 CT with DB 1.1E-03d4.3 -

CT only 1.1E-03d3.5 -

All operating 

modes, 

including 

startup periods

- - 14.0

CO2e 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:
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Emissions Limitations During Startup and 

Shutdown (Lbs/hr)a

Cold Startup Hot 

Startupb

Warm 

Startup

Shutdownb

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 pounds per event.

“Cold Startup” is defined as a combustion turbine startup that occurs more than 

60 hours after a combustion turbine shutdown. The period of startup is defined 

as the lesser of the first 150 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 [see g) where data point is defined.] points in compliance with the ppmvd 

emission limitations for CO and NOx.

 “Hot Startup” is defined as a combustion turbine startup that occurs within 12 

hours of a combustion turbine shutdown. The 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. The 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/kW-hr HHV, gross 

(ISO conditions without duct firing).
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Effective Date:11/5/2014

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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 

natural 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 from 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 Protection Agency, 40 CFR Part 60. The application and 

enforcement of these standards are delegated to the Ohio EPA. The 

requirements of 40 CFR Part 60 are also federally enforceable.

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, Appendix D. Except as allowed below, the 

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

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

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

available for inspection during regular office hours.

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

the continuous NOx monitoring system in accordance with the frequencies 

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

accuracy test audit frequency requirements for monitoring systems subject to 40 

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

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

in accordance with 40 CFR Part 60.
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Facility ID: 1409001151

Effective Date:11/5/2014

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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 

inspection during regular office hours.

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

the continuous CO monitoring system in accordance with the frequencies 

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

accuracy test audit frequency requirements for monitoring systems subject to 40 

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

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

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

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

cylinder gas audit and relative accuracy audit frequency requirements may be 

adjusted to coincide with linearity checks completed for continuous emissions 

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

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 

Modea

Emission 

Rateb,d

Emission 

rate, 

Lb/hrb

Emission rate, 

tons per rolling, 

12-month period

VOC CT With DB 1.5c7.2 -

CT only 1.0c3.8 -
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Allowable Emissions

Pollutant Operating 

Modea

Emission 

Rateb,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 /)

Where:

VOC = tons VOC emissions per rolling, 12-month period

#CS = number of cold startups per rolling, 12-month period

#WS = number of warm startups per rolling, 12-month period

#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

#SSNDB = 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, vendorsupplied 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, Subpart KKKK (40 CFR 60.4300 – 60.4420).
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Permit Number: P0116610

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d) Monitoring and/or Recordkeeping Requirements

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

thepermittee shall maintain a record of the type and quantity of fuel burned in this 

emissions 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, 

resulting in potential sulfur emissions of 1.4E-03 Lb SO2/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 SO2/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 shall maintain monthly records of the following information:

a. the CO, NOx, PE/PM10/PM2.5, VOC, CO2e 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 following the issuance of this permit, the rolling, 12-month summation of 

the CO, NOx, PE/PM10/PM2.5, VOC, CO2e and H2SO4 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/PM10/PM2.5, VOC, CO2e and H2SO4 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;
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Effective Date:11/5/2014

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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-month 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, Performance Specification 

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

that the continuous NOx monitoring system meets the requirements of Performance 

Specifications 2 and 6; and the U.S. EPA shall certify that the continuous NOx 

monitoring system meets the requirements under 40 CFR Part 75, which may be 

approved through the recommendation for certification by Ohio EPA to U.S. EPA. Once 

received, the letter(s)/document(s) of certification under Part 60 and certification or 

recommendation for certification under Part 75 shall be maintain on-site and made 

available to the Director (the appropriate Ohio EPA District Office or local air agency) 

upon request.

(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 units of the applicable standard(s) in 

the appropriate averaging period;

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

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

calibration adjustments;

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

applicable standard(s);

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

control equipment;

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

equipment and/or the continuous NOx monitoring system;
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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 

concentration 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 

requirements of Performance Specifications 4 or 4a and 6. Once received, the 

letter(s)/document(s) of certification shall be maintained on-site and shall be made 

available to the Director (the appropriate Ohio EPA District Office or local air agency) 

upon request.

(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 one 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, time, and hours of operation of the emissions unit without the control 

equipment and/or the continuous CO monitoring system;

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

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

system; as well as,
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Effective Date:11/5/2014

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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 CO2 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 CO2 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 3745-114-01, using data from the permit application; and modeling 

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

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

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

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

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

guidance document entitled “Review of New 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 from the emissions unit(s), (as determined from the raw 

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

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

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

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

Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for

Chemical Substances and Physical Agents Biological Exposure Indices”; 

or 

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

Conference of Governmental Industrial Hygienists (ACGIH) “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-hour TLV.

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

the general public (TLV/10).

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

the operating hours of the emissions unit(s), i.e., “X = 24” hours per day and “Y = 

7” days per week, from that of 8 hours per day and 5 days per week. The 
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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-Hour 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 (ug/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 not 
Final 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 air 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 

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

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

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

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

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

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

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

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

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

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

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

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

diameter, etc.).

If the permittee determines that the “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 final 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 Ground-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 materials 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 calendar 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. Each 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 quarterly reports shall be submitted by January 30, April 30, July 30, and 

October 30 of each year and shall include the following:

i. the facility name and address;

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

associated monitors;

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

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

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

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

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

during the calendar quarter, as specified above;

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

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

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

the emissions unit was in operation;

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

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

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

appropriate quarter(s));

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

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

results following any corrective actions;

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

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

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

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

in operation; and

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

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

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

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

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

NSPS-based limitation(s) in this permit.

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

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

information shall be documented in the EER quarterly report
Final 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, commencement and completion times, duration, and 

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

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

reported in units of the applicable standard(s).

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

October 30 of each year and shall include the following:

i. the facility name and address;

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

associated monitors;

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

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

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

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

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

during the calendar quarter, as specified above;

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

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

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

emissions unit was in operation;

viii. results and dates of quarterly cylinder gas audits;

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

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

(during appropriate quarter(s));

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

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

results following any corrective actions;
Final Permit-to-Install

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Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

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

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

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

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

in operation; and

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

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

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

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

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

NSPS-based limitation(s) in this permit.

* 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 shall collect, record, and maintain measurements, data, records, and 

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

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

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

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

(5) The permittee shall submit annual reports that include any changes to any parameter or 

value used in the dispersion model used to demonstrate 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, emissions 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/PM10/PM2.5, VOC, CO2e and H2SO4

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 Limitation:

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. Ongoing 

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, 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.

b. Emission Limitation:

CO emissions from 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 minutes, 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 each 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 

Where:

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 the 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. Ongoing 

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 this 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, NOx emissions shall not exceed 2.0 ppmvd at 15% oxygen as an 

hourly average and 27.7 Lbs/hr when the duct burner is in operation.

Applicable Compliance Method:

These emissions limitations are based on manufacturer’s data. Ongoing 

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.

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 

from the Ohio EPA. See f)(2) for emission 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. Ongoing 

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, PM10 emissions, and PM2.5 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, 

PM10 emissions, and PM2.5 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 limitations 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 from the Ohio EPA. See f)(2) for 

emission testing requirement.

h. Emission Limitation:

PE, PM10 emissions, and PM2.5 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/PM2.5
Final 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 SO2/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 grain S/100 scf) by the molecular weight of SO2 (64.07 Lb 

SO2/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 (106

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 emission 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 and 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 maximum 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 startup 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

Where:

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 



Where:

VOC = tons VOC emissions per rolling, 12-month period

#CS = number of cold startups per rolling, 12-month period

#WS = number of warm startups per rolling, 12-month period
Final Permit-to-Install

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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

#SSNDB = 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, vendorsupplied 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 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 Ohio EPA.

m. Emission Limitation:

H2SO4 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, H2SO4 emissions shall not 

exceed 1.1E-03 Lb/MMBtu of heat input 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:

H2SO4 emissions shall not exceed 14.0 tons per rolling, 12-month period.
Final Permit-to-Install

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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 

H2SO4 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-term allowable emission 

limitation, compliance shall also be shown with the annual emission limitation.

o. Emission Limitation:

CO2e 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 gross 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 CO2 emission rate. See 

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 allowable annual emission rate was determined by the following calculation:

CO2e = [fuel 

  120.243   (1) + fuel   0.0086   (25) + fuel 

2000 



= 1,549,315 TPY CO2e

Where:

CO2e = Equivalent CO2 emissions;

Fuel = maximum fuel usage, natural gas, 25,534,234 MMBtu/yr; and

the associated global warming potential for each pollutant (CO2=1, CH4=25, 

N2O=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 CO2e + [(1,549,315 TPY CO2e)(0.05)] = 1,626,781 TPY CO2e
Final Permit-to-Install

NTE Ohio, LLC

Permit Number: P0116610

Facility ID: 1409001151

Effective Date:11/5/2014

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Since the CO2e emissions are estimated to consist of more than 99% CO2, 

compliance with this emission limitation will be assumed provided that the rolling, 

12-month CO2 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, NOx, PE, PM10, PM2.5, VOC, and H2SO4, 

in the appropriate averaging period(s).

The emission testing shall also be conducted to determine a site-specific 

emission factor for CO2.

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 PM10 and PM2.5, Methods 201A and 202 of 40 CFR Part 52, Appendix M;

For SO2, 40 CFR 60.4415;

For VOC, 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;

For H2SO4, Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A; and

For CO2, Methods 1, 2, 3A, and 4 of 40 CFR Part 60, Appendix A.
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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 

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 "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) 

will 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 performance specification test and shall demonstrate how the 

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

rate.

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

Office or local air agency shall be notified 45 days prior to initiation of the applicable 
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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 monitoring system shall be granted upon determination by the Ohio 

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

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

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

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

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

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

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

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

60 and 40 CFR Part 75.

(4) Within 60 days of achieving the 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 from the Ohio EPA Central Office and the appropriate Ohio EPA District 

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

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

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

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

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

completed.

Certification of the continuous CO monitoring system shall be granted upon 

determination by the Ohio EPA Central Office that the system meets the requirements of 

40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); 

Performance Specification 6 relative accuracy requirements; and ORC section 

3704.03(I).

Ongoing compliance with the CO emission limitations contained in this permit, 40 CFR 

Part 60, and any other applicable standard(s) shall be demonstrated through the data 

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

through demonstration of compliance with the quality assurance/quality control plan, 

which shall meet the requirements of 40 CFR Part 60.
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g) Miscellaneous Requirements

(1) ISO conditions are 288 degrees Kelvin (15 degrees Celsius), 60% relative humidity and 

101.3 kilopascals pressure.

(2) One CEM data point is equivalent to one-minute of data.
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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), 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 SO2 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-month 

summation. 

see b)(2)e.

d. OAC rule 3745-31-11 through 20 CO emissions shall not exceed 2.61 g/hphr, 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, PM10, and PM2.5 emissions shall not 

exceed 0.236 g/hp-hr, 0.77 Lb./hr, and 

0.19 ton per rolling, 12-month period.
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Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

Sulfuric acid mist (H2SO4) 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.

Carbon dioxide equivalent (CO2e) 

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 from 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 emissions 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 63.6580-63.6675)

[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)]
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(2) Additional Terms and Conditions

a. BAT for CO, NOx, and PE/PM10/PM2.5 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. On 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. Once 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 SO2 emissions from this air 

contaminant source since the uncontrolled potential to emit for SO2 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/PM10/PM2.5

emissions from this air contaminant source since the uncontrolled 

potential to emit for CO, NOx, and PE/PM10/PM2.5 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 PM10/PM2.5 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:
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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 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 from 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 stationary 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 engines 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. In 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.
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i. This emissions unit must meet the requirements of 40 CFR Part 60 Subpart IIII. 

No further requirements apply under this subpart.

j. The emission 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, CO2e 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 following the issuance of this permit, the rolling, 12-month summation of 

the CO, NOx, PE/PM10/PM2.5, VOC, CO2e 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 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).
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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, CO2e 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.
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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 

maximum 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 emission 

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, PM10, and PM2.5 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 emission limitation was developed by multiplying the 

maximum operating load (1475 HP) by the PE/PM10/PM2.5 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 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 (0.77 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).
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d. Emission Limitation:

The permittee shall equip the combustion engine such that SO2 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 compliance 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 

from the Ohio EPA.

e. Emission Limitation:

VOC emissions shall not exceed 0.26 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 (H2SO4) emissions shall not exceed 6.74E-04 g/hp-hr, 2.19 E03 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 

SO2 to SO3 and 100% conversion of SO3 to H2SO4. The pound per hour 

emissions limitation was developed by multiplying the g/hp-hr allowable H2SO4

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 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 H2SO4 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, compliance shall also be shown with the annual emission limitation.
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g. Emission Limitation:

Carbon dioxide equivalent (CO2e) 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 CO2, N2O, and CH4, multiplied by the global warming 

potential for CO2, N2O, and CH4 (1, 298, and 25, respectively from Table A-1 to 

Subpart A of 40 CFR 98).

The CO2 emission factor was obtained from AP-42 Table 3.4-1 dated 10/96 (165 

Lb/MMBtu). The N2O emission factor was derived from AP-42 Table 1.3-8 dated 

5/10 (0.26 Lb N2O/103gal x 103gal/141.666E6 Btu x 1E6Btu/MMBtu = 0.00184 

Lb N2O/MMBtu). The CH4 emission factor was obtained from AP-42 Table 3.4-1 

dated 10/96 (0.09 Lb TOC/MMBtu x 0.09 Lb CH4/Lb TOC = 0.0081 Lb 

CH4/MMBtu).

5716



   (165



)(1) + 0.00184



 (298)

+ (0.0081



 (25))  



2,000 = 474 /

Since the CO2e emissions are estimated to consist of more than 99% CO2, 

compliance with this emission limitation will be assumed provided that the Lb/hphr CO2 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 CO2 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 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 serve as demonstration of compliance.
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j. Emission Limitation:

Visible particulate emissions from 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, Appendix 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.
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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 SO2 emissions shall not 

exceed 5.5E-03 g/hp-hr (1.21E-05 Lb/hphr) 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/hphr, 0.69 pounds per hour (Lbs/hr), and 

0.17 ton per rolling, 12-month period.

NOx emissions shall not exceed 3.0 g/hphr, 1.72 Lb/hr, and 0.43 ton per rolling, 

12-month period.

PE, PM10, and PM2.5 emissions shall not 

exceed 0.15 g/hp-hr, 0.09 Lb/hr, and 
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Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures

0.023 ton per rolling, 12-month period.

H2SO4 emissions shall not exceed 6.7E04 g/hp-hr, 3.9E-04 Lb/hr and 9.7E-05 ton 

per rolling, 12-month period

CO2e 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 emissions from 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 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 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/hphr.

PM emissions shall not exceed 0.15 g/hphr.

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)]
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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/PM10/PM2.5 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. On 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. Once 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 SO2 emissions 

from this air contaminant source since the uncontrolled PTE for CO, NOx, 

PE/PM10/PM2.5, VOC and SO2 is less than 10 TPY each.

d. All particulate emissions are assumed to be less than 2.5 microns in diameter. 

The PM10/PM2.5 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:
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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 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 from 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, CO2e and H2SO4 emission rate for each 

month of operations; and
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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/PM10/PM2.5, VOC, CO2e 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 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, CO2e 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.
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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 demonstrated 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 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 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).
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c. Emission Limitation:

PE, PM10, and PM2.5 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 SO2 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 from 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 EPA.

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 per 
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ton. Compliance with the rolling, 12-month emission limitation shall be 

demonstrated by the recordkeeping in d)(1).

f. Emission Limitation:

H2SO4 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 

SO2 to SO3 and 100% conversion of SO3 to H2SO4. The pound per hour 

emissions limitation was developed by multiplying the g/hp-hr allowable H2SO4

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 (3.9E04 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 H2SO4 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:

CO2e 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 CO2, N2O, and CH4, multiplied by the global warming 

potential for CO2, N2O, and CH4 (1, 298, and 25, respectively from Table A-1 to 

Subpart A of 40 CFR 98).

The CO2 emission factor was obtained from AP-42 Table 3.3-1 dated 10/96 (164 

Lb/MMBtu). The N2O emission factor was derived from AP-42 Table 1.3-8 dated 

5/10 (0.26 Lb N2O/103gal x 103gal/141.666E6 Btu x 1E6Btu/MMBtu = 0.00184 

Lb N2O/MMBtu). The CH4 emission factor was obtained from AP-42 Table 3.4-1 

dated 10/96 (0.09 Lb TOC/MMBtu x 0.09 Lb CH4/Lb TOC = 0.0081 Lb 

CH4/MMBtu).
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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 CO2 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 serve as demonstration of compliance.

j. Emission Limitation:

Visible particulate emissions from 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 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:

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(c) for the same model year and maximum engine 
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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.
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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 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

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.

PM10 emissions shall not exceed 1.70 

Lbs/hr and 7.47 TPY.

PM2.5 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 from 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.
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(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. On 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. Once 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 PM10 and PM2.5 emissions from this air contaminant 

source since the calculated annual emission rate for PM10 and PM2.5 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 emission 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.
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(3) The permittee shall maintain 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 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:

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) multiplied by the decimal fraction 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 annual 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) multiplied by the decimal fraction 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:

PM2.5 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) multiplied by the decimal fraction drift rate (0.000005) multiplied 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 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 

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. Emission 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.