John R. Kasich , Governor

Mary Taylor , Lt. Governor Scott J. Nally , 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) 6/18/2013
William Martin Oregon Clean Energy Center 20 Park Plaza, Suite 456 Boston, MA 02216
RE: FINAL AIR POLLUTION PERMIT

- TO

- INSTALL Facility ID: 0448020102 Permit Number: P0110840 Permit Type: Initial Installation County: Lucas
Dear Permit Holder:
Enclosed please fi nd a final Ohio Environmental Protection Agency (EPA) Air Pollution Permit

- to

- Install (PTI) which will allow you to install or modify the described emissions unit(s) in a manner indicated in the permit. Because this permit contains several conditions and restrictions, we urge you to read it carefully. Becaus e this permit contains conditions and restrictions, please read it very carefully. In this letter you will find the information on the following topics:

 Ho w to appeal this permit

 Ho w to save money, reduce pollution and reduce energy consumption

 Ho w to give us feedback on your permitting experience

 Ho w to get an electronic copy of your permit
Ho w 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 t o 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. T he appeal must be filed with the Commission within thirty (30) days after notice of the Direc tor's action. T he 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 b y affidavit you demonstrate that payment of the full amount of the fee would caus e ex treme hardship. N otice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General’s Office, Environmental Enfo rcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 77 South High Street, 17th Floor Columbus, OH 43215 Certified Mail

Yes TOXIC REVIEW Yes PSD Yes SYNTHETIC MINOR TO AVOID MAJOR NSR Yes CEMS Yes MACT /GACT Yes NSPS No NESHAPS No NETTING No MAJOR NON

- ATTAINMENT Yes MODELING SUBMITTED Yes M AJOR GHG No SYNTHETIC MINOR TO AVOID MAJOR GHGHo w to save money, reduce pollution and red uce energy consumption
The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. N ot only will this reduce pollution and energy consumption, but it can also save you money. I f 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 u nder 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
Ho w to give us feedback on your permitting experience
Please complete a survey at www.epa.ohio.gov/dapc/per mitsurvey.aspx and give us feedback on your permitting experience. We value your opinion.
Ho w to get an electronic copy of your permit
This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or in Adobe PDF on the Division of Air Pollution Control (DAPC) We b page, www.epa.ohio.gov/dapc by clickin g the "Search for Permits" link under the Permitting topic on the Programs tab.
If you have any questions, please contact Toledo Department of Environmental Services at (419)936

- 3015 or the Office of Compliance Assistance and Pollution Prevention at (61 4) 644

- 3469. Sincerely,
Michael W. Ahern, Manager Permit Issuance and Data Management Section , DAPC
Cc: U.S. EPA TDES; Michigan; Indiana; Canada

# FINA L

Division of A ir Pollution Control Permit - to - Install f or Oregon Clean Energy Center

Facility ID: 0448020102 Permit Number: P0110840 Permit Type: Initial Installation Issued: 6/18/2013 Effective: 6/18/2013

### Division of Air Pollution Control Permit - to - Install for Oregon Clean Energy Center
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

................................ ................................ ................................ ............................ 7 9. Reporting Requirements

................................ ................................ ................................ ........................ 7 10. Appl icability

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

................................ ................................ .. 8 12. Permit

- To

- Operate Application

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

................................ ................................ ................................ ... 9 14. Public Disclosure

................................ ................................ ................................ ................................ ... 9 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. Facil ity

- Wide Terms and Conditions

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

................................ ................................ ................................ ....... 13 1. B001, Auxiliary Boiler

................................ ................................ ................................ ........................... 14 2. P003, Emergency Generator

................................ ................................ ................................ ................ 24 3. P 004, Emergency Fire Pump

................................ ................................ ................................ ............... 34 4. P005, Wet Cooling Tower

................................ ................................ ................................ .................... 44 5. Emissions Unit Group

- P001 and P002: CTG #1 and CTG #2

................................ ............................ 48Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 1 of 86 

# Au thorization
Facility ID: 0448020102 Facility Description: 800 M W combined cycle gas turbine (CCGT) facility Application Number(s): A0045417, A0046584, A0047327 Permit Number: P0110840 Permit Description: Installation of a natural gas

- fired combined cycle combustion turbine power plant. Permit Type: Initial Installation Permit Fee: $6,050.00 Iss ue Date: 6/18/2013 Effective Date: 6/18/2013
This document constitutes issuance to : Oregon Clean Energy Center 816 Lallendorf Rd Oregon, OH 43616

o f 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: Toledo Department of Environmental Services 348 South Erie Street Toledo, OH 43604 (419)936

- 3015
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 c onstructed 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

Scott J. Nally DirectorFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 2 of 86 

# Au thorization (continued)

Permit Number: P0110840 Permit Description: Installation of a natural gas

- fired combined cycle combustion turbine power plant.
Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below :
Emissions Unit ID : B001 Com pany Equipment ID : Auxiliary Boiler Superseded Permit Number : General Permit Category and Type : Not Applicable Emissions Unit ID : P003 Com pany Equipment ID : Em ergency Generator Superseded Permit Number : General Permit Category and Type : Not Applicable Emissions Unit ID : P004 Com pany Equipment ID : Em ergency Fire Pump Superseded Permit Number : General Permit Category and Type : Not Applicable Emissions Unit ID : P005 Com pany Equipment ID : We t Cooling Tower Superseded Permit Number : General Permit Category and Type : Not Applicable Group Name: P001 and P002 Emissions Unit ID: P001 Com pany Equipment ID: CTG #1 Superseded Permit Number: General Permit Category and Type: Not Applicable Emissions Unit ID: P002 Com pany Equipment ID: CTG #2 Superseded Permit Number: General Permit Category and Type: Not ApplicableFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 3 of 86 

# A. Standard Terms and ConditionsFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 4 of 86 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 Co ndition 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 Requ irements Wh en There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations (9) Standard Term and Condition A. 16., Fees (10) Standard Term and Condition A. 17., 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

t hey are required under the Act, or any of its applicable r equirements, 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 c onditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if s pecifically identified in this permit as such

. 3. General Requirements a) The permittee must comply with all terms and conditions of this permit. Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and re - issuance, or modification.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 5 of 86 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 m odified, revoked, or revoked and reissued, for cause. T he filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit. d) This permit does not convey any property rights of any sort, or any exclusive privilege. e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit. U pon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. F or information claimed to be confidential in the submittal to the Director, if t he Administrator of the U.S. EPA requests such inf ormation, the permit tee 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 s pecific emissions unit , the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit: (1) The date, place (as defined in the permit), and time of sampling or measurements. (2) The d ate(s) analyses were performed. (3) The c ompany or enti ty that performed the analyses. (4) The analyti cal techniques or methods used. (5) The results of such analyses. (6) The operating conditions existing at the ti me of sampling or measurement. b) Each record of any monitoring data, testing data, and support inf ormation 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 r ecordings 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 s pecific emissions unit, the permittee shall submit required reports in the following manner: (1) Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Toledo Department of Environmental Services.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 6 of 86 (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 Toledo Department of Environmental Services. 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) Wri tten reports, which identify any deviations from the federally enforceable monitoring , recordkeeping , andreportingrequirements contained in this permit shall be submitted (i.e., postmarked) to the Toledo Department of Environmental Services every six month s, by January 31 and July 31 of each year for the previous six calendar months. If no deviations occurred during a six

- month period, the permittee shall submit a semi

annual report, which states that no deviations occurred during that period. (4) T his 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 eq uipment shall be performed in accordance with paragraph (A) of OAC rule 3745

- 15

- 06. T he malfunction, i.e., upset, of any emissions units or any associated air pollution control system(s) shall be reported to the Toledo Department of Environmental Services in accordance with paragraph (B) of OAC rule 3745

- 15

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

- 15

- 06(B)(1) for a malfunction.) T he ver bal 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) The emissions unit(s) identified in this Permit shall remain in full compliance with all applicable State laws and regulations and the terms and conditions of this permit. b) Any document (including reports) required to be s ubmitted 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.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 7 of 86 c) 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 w here 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, sub ject to the protection fr om 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. d) The permittee shall submit progress repor ts to the Toledo Department of Environmental Services concerning any schedule of compliance for meeting an applicable requirement. Progress reports shall be submitted semiannually or more frequently if s pecified in the applicable requirement or by the Dir ector of the Ohio EPA. P rogress 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 explanat ion 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) s hall comply with the Applicable Emission Limitations/Control Measures identified as BAT for each subject emissions unit. 8. Air Pollution Nuisance
The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in vi olation of OAC rule 3745

- 15

- 07. 9. Reporting Requirements The permittee shall submit required r eports in the following manner: a) Reports of any required monitoring and/or recordkeeping of state

- only enforceable information shall be submitted to the Toledo Department of Environmental Services

. b) Except as otherwise may be provided in the terms and conditions for a s pecific emissions unit, quarterly written reports of (a) any deviations (excursions) fr om state

- only required emissionFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 8 of 86 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 preve ntive measures which have been or will be taken, shall be submitted to the Toledo Department of Environmental Services. If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occ urred during that quarter. T he 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. ( These quarterly reports shall exclude deviations result ing 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 install ation or modification of any other emissions unit(s).
11. Construction of New Sources(s) and A uthorization to Install a) This permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. T his pe rmit 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. T he action of beginning and/or completing construction prior to obtaining t he Director's approval constitutes a violation of OAC rule 3745

- 31

- 02. Furthermore, issuance of this permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. I ssuance of this permit i s 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. A dditional facilities shall be installed u pon orders of the Ohio Environmental Protection Agency if

t he 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 tim e a continuing program of installation. T his deadline may be extended by up to 12 months if a pplication is made to the Director within a reasonable time before the termination date and the party shows good cause for any such extension. c) The permittee may n otify 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 d efined 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 certifi ed 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 Ohio EPA’s “Air Services” along with the date the emissions unit(s) was permanentlyFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 9 of 86 removed and/or disabled. Submitting the facility profile update will constitute notifying of the permanent shutdown of the affected emissions unit(s). d) The provisions of this permit shall cease to b e 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 subse quent "modification" or "installation" as defined in OAC Chapter 3745

- 31). A ll records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with law. A ll reports requir ed 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.
No emissions unit certified by the authorized official as being permanently shut down may resume operation without first applying for and obtaining a permit pursuant to OAC Chapter 3745

- 31. e) The permittee shall comply wit h 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 a s 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 A pplication
The permittee is required to appl y for a Title V permit pursuant to OAC Chapter 3745

- 77. T he 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 cove red by this permit. However, if t he proposed new or modified source(s) would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit modification must be obtained before the operation of such new or modified source(s) purs uant to OAC rule 3745

- 77

- 04(D) and OAC rule 3745

- 77

- 08(C)(3)(d). 13. Construction Compliance Certification The applicant shall identify the following dates in the online 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.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 10 of 86 15. Additional Reporting Requirements When Th ere Ar e 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 state s that no deviations occurred during that quarter. T he reports shall be submitted quarterly (i.e., postmarked), 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. T he 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 applica ble 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 t he “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 devel op 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 Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 11 of 86 

# B. Facility - Wide Terms and ConditionsFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 12 of 86 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 follow ing emissions unit contained in this permit is subject to 40 CFR Part 60 Subpart A and Dc: B001. T he 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 unit contained in this permit is subject to 40 CFR Part 60 Subpart A and IIII: P003 and P004. T he compl ete 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 and P002. T he complete NSPS requirements, including the NSPS General Provisions may be accessed via the internet from the elec tronic 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 unit contained in this permit is subject to 40 CFR Part 63 Sub part A and ZZZZ: P003 and P004. T he 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 con tacting the appropriate Ohio EPA district or local air agency.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 13 of 86 

# C. Emissions Unit Terms and ConditionsFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 14 of 86 1. B001, A uxiliary Boiler Operations, Property and/or Equipment Description: 99 mmBtu/hr natural gas fired boiler with low

- NOx burners and flue gas re - circulation 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 no t 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 Sulfur dioxide (SO 2 ) emissions shall not exceed 1.4E

- 03 pound per million Btu (lb/mmBtu) of heat input and 0.14 ton per year. see b)(2)a. and b)(2)b. b. OAC rule 3745

- 31

- 05(A)(3)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rule 3745

- 31

- 10 through 20 Carbon monoxide (CO) emissions shall not exceed 0.055 pound per million Btu (lb/mmBtu) of heat input, 5.45 pounds per hour (lbs/hr), and 5.45 tons per rolling, 12

- month period. Nitrogen Oxides (NO x ) emissions shall not exceed 0.020 l b/mmBtu of heat input, 1.98 lbs/hr, and 1.98 tons per rolling, 12

- month period.
Particulate matter emissions less than 10 microns in diameter (PM 10 ) and particulate matter less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 0.008 lb/mmBtu of heat i nput, 0.79 lb/hr, and 0.79 ton per rolling, 12

- month period.

Volatile organic compound (VOC) emissions shall not exceed 0.006Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 15 of 86 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures lb/mmBtu of heat input, 0.59 lb/hr and 0.59 ton per rolling, 12

- month period. Sulfuric acid mist (H 2 SO 4 ) emissions shall not ex ceed 1.1E

- 04 lb/mmBtu, 0.011 lb/hr, and 0.011 ton per rolling, 12

- month period.
Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 11,671 tons per rolling, 12

- month period.
Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. see b)(2)d., b)(2)e., and b)(2)k. d. OAC rule 3745

- 17

- 07(A) see b)(2)f. e. OAC rule 3745

- 17

- 10(B)(1) see b)(2)f. f. OAC rule 3745

- 110

- 03(J)(16) exemption

- see b)(2)l. g. 40 CFR Part 60, Subpart A see b)(2)g. h. 40 CFR Part 60, Subpart Dc see b)(2)h. and b)(2)i. i. 40 CFR Part 63, Subpart JJJJJJ see b)(2)j.

(2) Additional Terms and Conditions

a. Compliance with the requirements of this rule for CO, NOx, PM 10 /PM 2.5 , and VOC emissions includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.
b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745

- 31

- 05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745

- 31

- 05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Am bient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. H owever, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745

- 31

- 05, the requirement to satisfy BAT still exists as part of the federally

- approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05, then these emission limitations/con trol measures no longer apply.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 16 of 86 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, NO x , PM 10 /PM 2.5 , SO 2 , and VOC emissions from this air contaminant source since the uncontrolled potential to emit for CO, NO x , PM 10 /PM 2.5 , SO 2 , and VOC is less than 10 tons per year .
d. All particulate emissions are assumed to be les s than 2.5 microns in diameter. The PM 10 /PM 2.5 emissions limitations include both filterable and condensable particulate emissions.

e. The lb/mmBtu and lb/hr, emission limitations are based on the emissions unit's potentials to emit. T herefore, 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

- 10 throu gh 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. This rule does not establish emission limitations for natural gas - fired boilers, but does require recordkeeping of gas usage per 40 CFR 60.48c(g).
i. This emissions unit is subject to the applicable provisions of Subpart Dc of the New Source Performance Standards (NSPS) as promulgated by the United States Environmental Protection Agency, 40 CFR Part 60. T he application and enforcement of these standards are delegated to the Ohio EPA. T he 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 operating hours for this emissions unit shall not exceed 2,000 hours per rolling, 12

- month period.
To ensure enforceability during the first 12 calendar months of operation or the first 12 calendar mon ths following the issuance of this permit, the permittee shall not exceed the operating hours levels specified in the following table:
Maximum Allowable Month(s) Cumulative Operating Hours 1 720 1

- 2 1,440 1

- 3 2,000 1

- 4 2,000 1

- 5 2,000Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 17 of 86 1

- 6 2,000 1

- 7 2,000 1

- 8 2,000 1

- 9 2,000 1

- 10 2,000 1

- 11 2,000 1

- 12 2,000
After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual operating hours limitation shall be based upon a rolling, 12

- month summation of the operating hours.
l. The permittee is exempt fr om the requirements of OAC rule 3745

- 110

- 03(A) through (F), since this permit restricts NOx emissions from this emissions unit to less than 25 tons per year

. 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. (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 calend ar 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 recor d the cumulative operating hours for each calendar month. (3) See 40 CFR Part 60, Subpart Dc (40 CFR 60.4200

- 4219). e) Reporting Requirements (1) The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas was b urned in this emissions unit. E ach report shall be submitted within 30 days after the deviation occurs. (2) Pursuant to the 40 CFR Part 60.7 and 60.48c(a), the permittee is hereby advised of the requirement to report the following at the appropriate times:

a. co nstruction date (no later than 30 days after such date);Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 18 of 86 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 fa cility and identification of fuels to be combusted in the affected facility. (3) The permittee shall submit quarterly deviation (excursion) reports that identify the following:
all exceedances of the rolling, 12

- month limitation on the hours of operation for t his 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;
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 Dc (40 CFR 60.4200

- 4219). (5) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center: A ir 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 0.055 lb/mmBtu of heat input, 5.45 lbs/hr, and 5.45 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu emission limitation is based on manufacturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the CO emission factor supplied by the manufacturer (0.055 lb/mmBtu) to determine the hourly emissions.
The annual emission limitation was developed by multiplying the hourly emission limitation (5.45 lbs/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compl iance with the hourly limitation is shown.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 19 of 86 b. Emission Limitation: NO x emissions shall not exceed 0.020 lb/mmBtu of heat input, 1.98 lbs/hr, and 1.98 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is based on manufa cturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the NO x emission factor supplied by the manufacturer (0.020 lb/mmBtu) to determine the hourly emissions.
The annual emission limitation was developed by multiplying the hourly emission limitation (1.98 lbs/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown.

c. Emission Limitation:
PM 10 and PM 2.5 shall not exceed 0.008 lb/mmBtu of heat input, 0.79 lb/hr, and 0.79 ton per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is based on manufacturer’s data. T h e hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the PM 10 /PM 2.5 emission factor supplied by the manufacturer (0.008 lb/mmBtu) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the lb/mmBtu 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 (0.79 lb/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the h ourly limitation is shown.
d. Emission Limitation: SO 2 emissions shall not exceed 1.4E

- 03 lb/mmBtu of heat input and 0.14 ton/yr. Applicable Compliance Method:
The lb/mmBtu limitation was established based on using pipeline quality natural gas having a maximu m sulfur content of 0.5 grains per 100 cubic feet according to the following calculation. M ultiply the maximum sulfur content of natural gas (0.5 grain S/100 scf) by the molecular weight of SO 2 (64.07 lb SO 2 /lb

- mole) divide by the molecular weight of sulf ur (32.06 lb S/lb

- mole) divide by (7,000 grains/lb), divide by (1,020 Btu/scf), and multiply by (10 6 Btu/mmBtu).Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 20 of 86 If required, the permittee shall demonstrate compliance with the lb/mmBtu and hourly emission limitation using Methods 1 thru 4 and 6C of 40 CF R 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 lb/mmBtu emission limitation (1.4E

- 03 lb/mmBtu) by the maximum heat input (99 mmBtu/hr), multiplied by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown.

e. Emission Limitat ion: VOC emissions shall not exceed 0.006 lb/mmBtu of heat input, 0.59 lb/hr, and 0.59 ton per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is based on manufacturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the VOC emission factor supplied by the manufacturer (0.006 lb/mmBtu) to determine the hourly emissions. If required, the permittee shall demonstrate compliance with the lb/mmBtu and hourly emission limi tation Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. Use of M ethod 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 te st methods may be used with prior approval from the Ohio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (0.59 lb/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. Therefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation is maintained.
f. Emission Limitation: Sulfuric acid mist (H 2 SO 4 ) emissions shall not exceed 1.1E

- 04 lb/mmBtu, 0.011 lb/hr, and 0.011 ton per rolling, 12

- month period. Applicable Compliance Method: The lb/mmBtu emission limitation is based on the assumption that 5% of the SO 2 emissions are converted to SO 3 and then converted to H 2 SO 4 when combined with water vapor by the following calculation.
1 .4E

- 03 lb SO 2 /mmBtu(0.05)(98 lb H 2 SO 4 /lb

- mole)(lb

- mole/64 lb SO 2 ) = 1.1E

- 04 lb H 2 SO 4 /mmBtuFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 21 of 86 Multiply the lb H 2 SO 4 /mmBtu (0.11 lb/mmBtu) by the maximum heat input (99 mmBtu/hr) to determine the maximum hourly H 2 SO 4 emissions (0.11 lb/hr), and multiply by the maximum annual hours of operation (2,000 hrs/yr) divided by 2,000 lbs/ton to determine the annual H 2 SO 4 emissions (0.11 ton/yr).
If required, the permittee shall demonstrate compliance with the lb/mmBtu and lb/h r emissions limitations using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A.
g. Emission Limitation: Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 11,671 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limi tation was established to ref lect the potential to emit for this emissions unit by calculating the sum of the product of the maximum natural gas usage (0.104 mmscf/hr) multiplied by the AP

- 42 emission factor for CO 2 , N 2 O, and CH 4 from Table 1.4

- 2 dated 7/9 8 (120,000 lb/mmscf, 0.64 lb/mmscf, and 2.3 lb/mmscf, respectively), multiplied by the global warming potential for CO 2 , N 2 O, and CH 4 (1, 310, and 21, respectively from Table A

- 1 to Subpart A of 40 CFR 98). M ultiply the calculated sum by the natural gas h eating value used in the application for this emissions unit (950 Btu/scf), divide by the average heating value used for AP

- 42 emission factors in Table 1.

- 42 dated 7/98 (1,020 Btu/scf), multiply by the maximum annual hours of operation (2,000 hrs/yr) and divide by 2,000 pounds per ton.

99 h 120 , 000 ( 1 ) + ( 0

. 64 ) ( 310 )

+ 2

. 3 ( 21 ) 1020 2 , 000 h h 2 , 000

= 11 , 671

Since the CO 2 e emissions are estimated to consist of m ore than 99% CO 2 , compliance with this emission limitation will be assumed provided that the lb/scf CO 2 emission rate does not exceed 120,000 lb/mmscf.
If required, the permittee shall conduct emissions testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the lb/scf CO 2 emission rate.
h. Emission Limitation: Visible emissions shall not exceed 10% opacity as a 6

- minute average, except as provided by rule.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 22 of 86 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 ac cordance 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 un it.
b. The emission testing shall be conducted to demonstrate compliance with the following emissions limitations:
i. CO emissions in lb/hr and lb/mmBtu; and
ii. NO x emissions in lb/hr and lb/mmBtu. The emission testing shall also be conducted to determine the CO 2 emission rate in lb/hr and 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 of 40 CFR Part 60, Appendix A; and
for NO x 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 fr om 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 mater ial 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. F ailure to test under these conditions is justificatio n for not accepting the test results as a demonstration of compliance.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 23 of 86 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 a gency 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). T he permittee may request additional time for the submittal of the written report, where warranted, with prior approval from the appropriate Ohio EPA District Office or local air agency. g) Miscellaneous Requirements (1) None.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 24 of 86 2. P003, Emergency Generator Operations, Property and/or Equipment Description: 2,250 kW emergency diesel fired generator 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 applicab le 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 Sulfur dioxide (SO 2 ) emissions shall not exceed 0.03 pound per hour (lb/hr) and 0.008 ton per year. see b)(2)a. and b)(2)b. b. OAC rule 3745

- 31

- 05(A)(3)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rule 3745

- 31

- 10 through 20 Carbon monoxide (CO) emissions shall not exceed 3.5 g/kW

- hr, 17.35 pounds per hour (lbs/hr), and 4.34 tons per rolling, 12

- month period. Nitrogen oxides (NO x ) emissions shall not exceed 5.61 g/k

W

- hr, 27.8 lbs/hr, and 6.95 tons per rolling, 12

- month period.
Particulate matter emissions less than 10 microns in diameter (PM 10 ) and particulate matter less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 0.20 g/k W

- hr, 0.99 lb/hr, and 0.25 tons per rolling, 12

- month period.
Volatile organic compound (VOC) emissions shall not exceed 0.79 g/k W

- hr, 3.93 lbs/hr, and 0.98 ton per rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 25 of 86 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures Sulfuric acid mist (H 2 SO 4 ) emissions shall not exceed 1.32E

- 04 g/k W

- hr, 6.5 E

- 04 lb/hr and 1.6E

- 04 ton per rolling, 12

- month period.
Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 878 tons per rolling, 12

- month period. see b)(2)d. and b)(2)e. d. OAC rule 3745

- 17

- 07(A) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6

- minute average. e. OAC rule 3745

- 17

- 11(B)(5)(a) see b)(2)f. f. OAC rule 3745

- 110

- 03(J)(16), and (J)(19) exemptions

– see b)(2)g.
g. 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 Gene ral Provisions in 40 CFR 60.1

- 19 apply. h. 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.] Non

- methane hydrocarbon (NMHC) + NOx emissions shall not exceed 6.4 g/k W

- hr.
CO emissions shall not exceed 3.5 g/kW

hr.
PM emissio ns shall not exceed 0.20 g/k W

- hr. 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. see b)(2)h. [60.4205(b) and 60.4207(b)] i. 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 see b)(2)i. [63.6590(c), (c)(1)]Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 26 of 86 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures engine (RICE) located at an area source of HAP emissions subject to the emissions limitation/control measures specified in this section.]

(2) Additional Terms and Conditions

a. Compliance with the requirements of this rule for CO, NOx, PM 10 , PM 2.5 , and VOC emissions includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.
b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745

- 31

- 05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, par agraph (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 (NAAQ S) pollutant(s) less than ten tons per year. H owever, 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 OA C rule 3745

- 31

- 05, the requirement to satisfy BAT still exists as part of the federally

- approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05, then these emission limitations/control measures no longer apply.

c. Th is 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, NO x , PM 10 /PM 2.5 , SO 2 , and VOC emissions from this air contaminant source since the uncontrolled potential to emit for CO, NO x , PM 10 /PM 2.5 , SO 2 , and VOC is less than 10 tons per year taking into account the federally enforceable emissions limitations and operating hours restriction specified by OAC rule 3745

- 31

- 10 through 20.
d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10 /PM 2.5 emissions limitations include both filterable and condensable particulate emissions.

e. The maximum annual operating hours for this emissions unit shall not exceed 500 hours , based upon a rolling, 12

- month summation of the operating hours.
To ensure enforceability during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall not exceed the operating hours levels specified in the following table:Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 27 of 86 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 50 0 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

- 10 through 20.
g. The requirements of this rule do not apply, since:
i. NOx emissions are re stricted to less than 25 tons per year; and
ii. the emissions unit is subject to a BACT limitation for NOx.
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 min imum 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, Subpa rt 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 operating hours for each month ; andFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 28 of 86 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 permit tee shall record the cumulative operating hours for each calendar month. (2) 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 i n 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. (3) 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. (4) 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 id entify 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); and
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.
The quarterly deviation (excursion) reports sh all 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: A ir 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 d etermined in accordance with the following methods:

a. Emission Limitation: CO emissions shall not exceed 3.5 g/kW

- hr, 17.35 lbs/hr, and 4.34 tons per rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 29 of 86 Applicable Compliance Method: The g/k W

- hr limitation is based on the Tier 2 emissi on standards under 40 CFR 89.112(a), Subpart B, Table 1. T he hourly emission limitation was developed by multiplying the maximum operating load (2,250 kW ) by the CO emission factor supplied by the manufacturer (3.5 g/k W

- hr) and dividing by (454 g/lb) to d etermine the hourly emissions. If required, the permittee shall demonstrate compliance with the g/k W

- 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 (17.35 lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, co mpliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating hours restriction is shown.
b. Emission Limitation: NOx emissions shall not exceed 5.61 g/kW

- hr, 27.8 lbs/hr, and 6.95 tons per rolling, 12

- month period. Applicable Compliance Method:
The g/kW

- hr limitation is based on the combined NOx + NMHC emission limitation specified by the Tier 2 standard in 40 CFR 89.112(a) Table 1 (6.4 g/k W

- hr) multiplied by the Tier 1 emission limitation for NOx in Table 1 (9.2 g/kW

hr) divided by the sum of the Tier 1 emission limitations for NOx and HC in Table 1 (9.2 g/k

W

- hr + 1.3 g/k

W

- hr). T he hourly emission limitation was developed by multiplying the maximum operating load (2,250 kW ) by the NOx g/k W

- hr emission limita tion (5.61 g/k W

- hr) divided by (454 g/lb) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the g/k W

- hr limitation and hourly emission limitation using Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A. A lternative 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 (27.8 lbs/hr) by the maximum annual operating hours (500 hrs/yr) and div iding by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating hours restriction is shown.

c. Emission Limitation:
PM 10 /PM 2.5 emissions shall not exceed 0.20 g/k W

- hr, 0.99 lb/hr, and 0.25 ton per rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 30 of 86 Applicable Compliance Method:
The g/k W

- hr limitation is based on manufacturer’s emissions data. T he hourly emission limitation was developed by multiplying th e maximum operating load (2,250 k W) by the PM 10 /PM 2.5 emission factor supplied by the manufacturer (0.20 g/k W

- hr) divided by (454 g/lb) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the g/k W

- 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 h ourly emission limitation (0.99 lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating h ours restriction is shown.
d. Emission Limitation: SO 2 emissions shall not exceed 0.03 lb/hr and 0.008 ton/yr. Applicable Compliance Method:
The hourly emission limitation is based dividing the AP

- 42 emission factor for SO 2 from AP

- 42 Table 3.4

- 1 dated 10/96 when burning diesel fuel with a maximum sulfur content of 15 ppmw (0.0015 lb/mmBtu) by (10 6 Btu/mmBtu) multiplied by (7,000 Btu/hp

- hr) and multiplied by the maximum power rating (3,016.6 hp).
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 fr om the Ohio EPA. The annual emission limitation was developed by multiplying the hourly e mission limitation (0.03 lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating hours re striction is shown.

e. Emission Limitation: VOC emissions shall not exceed 0.79 g/k W

- hr, 3.93 lbs/hr, and 0.98 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/kW

- hr limitation is based on the combined NOx + NMHC emission limitation speci fied by the Tier 2 standard in 40 CFR 89.112(a) Table 1 (6.4 g/k W

- hr) multiplied by the Tier 1 emission limitation for NMHC in Table 1 (1.3Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 31 of 86 g/k W

- hr) divided by the sum of the Tier 1 emission limitations for NOx and HC in Table 1 (9.2 g/kW

- hr + 1.3 g/kW

- hr)

. T he hourly emission limitation was developed by multiplying the maximum operating load (2250 kW ) by the VOC emission factor supplied by the manufacturer (0.79 g/kW

- hr) to determine the hourly emissions.
If required, the permittee shall demonstrate compl iance with the g/k W

- hr limitation and hourly emission limitation using Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. U se of Method 18, 25 or 25A is to be selected based on the results of pre

- survey stack sampling a nd 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 (3.93 lbs/hr) by the maximum annual op erating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating hours restriction is shown.
f. Emission Limitation:
H 2 SO 4 emissions shall not exceed 1.32E

- 04 g/k W

- hr, 6.5 E

- 04 l b/hr and 1.6E

- 04 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/kW

- hr emission is based on the sulfuric acid mist emission factor from page 276 of Toxic Air Pollution Emission Factors, EP A 450/2

- 90

- 011 (8.9 ng/J x %sulfur in fuel = 8.9(0.0015) = 0.01335 ng/J). T he H 2 SO 4 emission factor (0.01335 ng/J) was converted to g/k W

- hr by multiplying by (1055.1 J/Btu), multiplying by (7000 Btu/hp

- hr), multiplying by (g/10 9 ng), and multiplying by ( 1.341 hp/kW) = 1.32E

- 04 g/kW

- hr.
The pound per hour emissions limitation was developed by multiplying the g/kW

hr allowable H 2 SO 4 emission limitation (1.32E

- 04 g/kW

- hr) by the maximum operating load (2,250 k W) and divided by 454 grams per pound to determin e the hourly emissions (6.5E

- 04 lb/hr).
If required, the permittee shall demonstrate compliance with the g/kW

- hr and lb/hr emission limitation using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
The ton per year emission limitation was developed by multiplying the hourly allowable H 2 SO 4 emission limitation (6.5E

- 04 lb/hr) by the maximum annual hours of operation (500 hours), and then dividing by 2,000 po unds per ton. Therefore, if compliance is shown with the short

- term allowable emission limitation, compliance shall also be shown with the annual emission limitation.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 32 of 86 g. Emission Limitation: Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 877 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation was established to ref lect the potential to emit for this emissions unit by calculating the sum of the maximum capacity (3016.6 hp) by the emission factor for CO 2 , N 2 O, and CH 4 , multiplied by the global warming potential for CO 2 , N 2 O, and CH 4 (1, 310, and 21, respectively from Table A

- 1 to Subpart A of 40 CFR 98). M ultiply the sum by the maximum annual hours of operation (500 hrs/yr) and divide by 2,000 pounds per to n. T he CO 2 emission factor was obtained fr om AP

- 42 Table 3.4

- 1 dated 10/96 (1.16 lb/hp

- hr). T he N 2 O emission factor was obtained from 40 Table C

- 2 to Subpart C of 40 CFR 98 (0.6 g/mmBtu). T he CH 4 emission factor was obtained from AP

- 42 Table 3.4

- 1 dat ed 10/96 (7.05E

- 04 lb TOC/hp

- hr x 0.09 lb CH 4 /lb TOC = 6.34E

- 05 lb CH 4 /hp

hr).
( 3016

. 6 h ) 1

. 16 h

− h ( 1 )

+ 0

. 6 7000 h

− h 1 06 ( 454 ) ( 310 )

+ 6

. 34

− 05 ( h

− h ) ( 21 ) 500 h h 2 , 000

= 878 / Sin ce the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the lb/hp

hr CO 2 emission rate does not exceed 1.16 lb/hp

- hr. I f required, the permittee shall conduct emissions te sting using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the lb/hp

- hr CO 2 emission rate.
h. Emission Limitation:
The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standard: 15 ppm maximum sulfur content Applicable Compliance Method: The records required by d)(2) 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 mini mum cetane index of 40 or a maximum aromatic content of 35 volume percent.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 33 of 86 Applicable Compliance Method:
The records required by d)(2) and d)(3) shall serve as demonstration of compliance. j. Emission Limitation:
Visible particulate emissions fr om the stack s erving 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: NMHC + NOx emissions shall not exceed 6.4 g/kW

- hr; CO emissions shall not exceed 3.5 g/kW

- hr; PM emissions shall not exceed 0.20 g/kW

- hr; 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 emissions 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. T he engine must be installed and configured according to the manufacturer’s emission

- related specifications, except as permitted in 40 CFR 60.4211(g). T he permittee shall maintain documenta tion of certification to the emission standards in 40 CFR 60.4205. g) Miscellaneous Requirements (1) None.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 34 of 86 3. P004, Emergency Fire Pump Operations, Property and/or Equipment Description: 300 hp (223.8 kW) emergency diesel

- fired fire pump engine a) The following e missions 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 Sulfur dioxide (SO 2 ) emissions shall not exceed 0.003 lb/hr and 8.0 E

- 04 ton/yr. see b)(2)a. and b)(2)b. b. OAC rule 3745

- 31

- 05(A)(3)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rule 3745

- 31

- 10 through 20 Carbon monoxide (CO) emissions shall not exceed 3.5 g/k

W

- hr, 1.7 pounds per hour (lbs/hr), and 0.43 ton per rolling, 12

- month period. Nitrogen Oxides (NO x ) emissions shall not exceed 3.5 g/k

W

- hr, 1.7 lb/hr, and 0.43 ton per rolling, 12

- month period.
Particulate matter emissions less than 10 microns in diameter (PM 10 ) and particulate matter less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 0.20 g/k W

- hr, 0.10 lb/hr, and 0.025 ton per rolling, 12

- month period.
Volatile organic compound (VOC) emissions shall not exceed 0.50 g/k W

- hr, 0.25 lb/hr, and 0.06 ton p er rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 35 of 86 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures H 2 SO 4 emissions shall not exceed 1.32 E

- 04 g/k W

- hr, 6.5E

- 05 lb/hr and 1.6E

- 05 ton per rolling, 12

- month period
Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 87 tons per rolling, 12

- month period. see b)(2)d. and b)(2)e. d. OAC rule 3745

- 17

- 07(A) Visible particulate emissions fr om the stack serving this emissions unit shall not exceed 20 percent opacity as a 6

- minute average. e. OAC rule 3745

- 17

- 11(B)(5)(a) see b)(2)f. f. OAC rule 3745

- 18

- 06(G) less stringent than 40 CFR Part 63, Subpart IIII g. OAC rule 3745

- 110

- 03(J)(16), (19) exemption

– see b)(2)g. h. 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 w hich parts of the General Provisions in 40 CFR 60.1

- 19 apply. i. 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 4.0 g/k W

- hr.
CO emissions shall not exceed 3.5 g/kW

hr.
PM emissions shall not exceed 0.20 g/k W

- hr. see b)(2)h. [60.4205(c) and 60.4207(b)] j. 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 combu stion engine (RICE) located at an area source of HAP emissions subject to the emissions limitation/control measures specified in this section.] see b)(2)i [63.6590(c), (c)(1)]Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 36 of 86 (2) Additional Terms and Conditions

a. Compliance with the requirements of this rule for CO, NOx, PM 10 , PM 2.5 , and VOC emissions includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.
b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745

- 31

- 05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745

- 31

- 05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. H owever, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Therefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745

- 31

- 05, the requirement to satisfy BAT still exists as part of the federally

- approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05, then these emission limitations/control measures no longer apply.

c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05 as part of the State Implementation Plan.
The Best Available Technolo gy (BAT) requirements under OAC rule 3745

- 31

- 05(A)(3) do not apply to the CO, NO x , PM 10 /PM 2.5 , SO 2 , and VOC emissions from this air contaminant source since the uncontrolled potential to emit for CO, NO x , PM 10 /PM 2.5 , SO 2 , and VOC is less than 10 tons per y ear taking into consideration the federally enforceable emissions limitations and operating hours restriction specified by OAC rule 3745

- 31

- 10 through 20.
d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10 /PM 2.5 emissi ons 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:
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 500Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 37 of 86 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 37 45

- 31

- 10 through 20.
g. The requirements of this rule do not apply, since:
i. NOx emissions are restricted to less than 25 tons per year; and
ii. the emissions unit is subject to a BACT limitation for NOx.
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. N o 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 op erating 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 mo nths 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. (2) For each shipment of diesel fuel received for burning in this emissions unit, the pe rmittee shall maintain records of the oil supplier's (or permittee’s) analyses for sulfur content inFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 38 of 86 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. (3) 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. (4) 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); and
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 t he maximum allowable cumulative hours of operation.
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: A ir Services online web portal. f) Testing Requirements (1) Compliance with the Emissions Limit ations 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 3.5 g/k W

- hr, 1.7 lbs/hr, and 0.43 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/k W

- hr limitation is based on the standard specified in Table 4 to 40 CFR Part 60, Subpart IIII. The hourly emission limitation was developed by multiplying the maximum operating load (223.8 kW ) by the g/k W

- hr CO emission limitation (3.5 g/k W

- hr) divided by (454 g/lb) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the g/k W

- hr limitation and hourly emission limitation using Methods 1 thru 4 and 10 of 40 CFRFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 39 of 86 Pa rt 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 (1.7 lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating hours restriction is shown.
b. Emission Limitation: NOx emissions shall not excee d 3.5 g/k W

- hr, 1.7 lbs/hr, and 0.43 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/kW

- hr limitation is based on the combined NOx + NMHC emission limitation specified by the Table 2 to 40 CFR Part 60, Subpart IIII (4.0 g/k W

- hr) multip lied by the Tier 1 emission limitation for NOx in Table 1 to 40 CFR 89.112(a) (9.2 g/k

W

- hr) divided by the sum of the Tier 1 emission limitations for NOx and HC in Table 1 to 40 CFR 89.112(a) (9.2 g/k W

- hr + 1.3 g/kW

- hr). T he hourly emission limitation was developed by multiplying the maximum operating load (223.8 kW ) by the g/kW

- hr NOx emission limitation (3.5 g/k W

- hr) divided by (454 g/lb) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the g/k W

- hr limitati on 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 ho urly emission limitation (1.7 lbs/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation and operating ho urs restriction is shown.

c. Emission Limitation:
PM 10 /PM 2.5 emissions shall not exceed 0.20 g/kW

- hr, 0.10 lb/hr, and 0.025 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/k W

- hr limitation is based on manufacturer’s emissions data. T he hourly emission limitation was developed by multiplying the maximum operating load (223.8 k W) by the PM 10 /PM 2.5 emission factor supplied by the manufacturer (0.20 g/k W

- hr) divided by (454 g/lb) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the g/k W

- hr limitation and hourly emission limitation using Methods 201 or 201A and 202 ofFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 40 of 86 40 CFR Part 51, Appendix M. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
The ann ual emission limitation was developed by multiplying the hourly emission limitation (0.10 lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrate d if compliance with the hourly limitation is shown.
d. Emission Limitation: SO 2 emissions shall not exceed 0.003 lb/hr and 8.0E

- 04 ton/yr. Applicable Compliance Method:
The hourly emission limitation is based dividing the AP

- 42 emission factor for SO 2 from AP

- 42 Table 3.4

- 1 dated 10/96 when burning diesel fuel with a maximum sulfur content of 15 ppmw (0.0015 lb/mmBtu) by (10 6 Btu/mmBtu) multiplied by (7,000 Btu/hp

- hr) and multiplied by the maximum power rating (300 hp).
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 fr om the Ohio EPA.
The annual emission limitation was devel oped by multiplying the hourly emission limitation (0.003 lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown.

e. Emission Limitation: VOC emissions shall not exceed 0.50 g/k W

- hr, 0.25 lb/hr, and 0.06 ton/yr as a rolling, 12

- month summation of the monthly emissions. Applicable Compliance Method:
The g/kW

- hr limitation is based on the combined NOx + NMHC emission limitation specified by the Table 2 to 40 CFR Part 60, Subpart IIII (4.0 g/k W

- hr) multiplied by the Tier 1 emission limitation for NMHC in Table 1 to 40 CFR 89112(a) (1.3 g/k

W

- hr) divided by the sum of the Tier 1 emission limitations for NO x and HC in Table 1 to 40 CFR 89.112(a) (9.2 g/kW

- hr + 1.3 g/k W

- hr). T he hourly emission limitation was developed by multiplying the maximum operating load (223.8 kW ) by the g/k W

- hr VOC emission limitation (0.50 g/k W

- hr) divided by (454 g/lb) to determin e the hourly emissions. If required, the permittee shall demonstrate compliance with the g/k W

- hr limitation and hourly emission limitation using Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. U se of Method 18, 25 or 25A is to be selected based on the results of pre

- survey stack sampling and U.S.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 41 of 86 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 multipl ying the hourly emission limitation (0.24 lb/hr) by the maximum annual operating hours (500 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is sh own. f. Emission Limitation:
H 2 SO 4 emissions shall not exceed 1.32E

- 04 g/k W

- hr, 6.5 E

- 05 l b/hr and 1.6E

- 05 ton per rolling, 12

- month period. Applicable Compliance Method:
The g/kW

- hr emission is based on the sulfuric acid mist emission factor from page 276 of Toxic Air Pollution Emission Factors, EPA 450/2

- 90

- 011 (8.9 ng/J x %sulfur in fuel = 8.9(0.0015) = 0.01335 ng/J). T he H 2 SO 4 emission factor (0.01335 ng/J) was converted to g/k W

- hr by multiplying by (1055.1 J/Btu), multiplying by (7000 Btu/hp

- hr), multipl ying by (g/10 9 ng), and multiplying by (1.341 hp/kW) = 1.32E

- 04 g/kW

- hr.
The pound per hour emissions limitation was developed by multiplying the g/kW

hr allowable H 2 SO 4 emission limitation (1.32E

- 04 g/kW

- hr) by the maximum operating load (223.8 k W) and d ivided by 454 grams per pound to determine the hourly emissions (6.5E

- 05 lb/hr).
If required, the permittee shall demonstrate compliance with the g/kW

- hr and lb/hr emission limitation using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A. A lternati ve U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
The ton per year emission limitation was developed by multiplying the hourly allowable H 2 SO 4 emission limitation (6.5E

- 05 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.
g. Emission Limitation: Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 87 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation was established to ref lect the potential to emit for this emissions unit by calculating the sum of the maximum capacity (300 hp) by the emission factor for CO 2 , N 2 O, and CH 4 , multiplied by the global warming potential for CO 2 , N 2 O, and CH 4 (1, 310, and 21, respectively from Table A

- 1 to Subpart of 40 CFR 98). M ultiply the sum by the maximum annual hours of operation (500Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 42 of 86 hrs/yr) and divide by 2,000 pounds per ton. T he CO 2 emission factor was obtained from AP

- 42 Table 3.3

- 1 dated 10/96 (1.15 lb/hp

- hr). The N 2 O emission factor was obtained from Table C

- 2 to Subpart C of 40 CFR 98 (0.6 g/mmBtu). The CH 4 emission factor was obtained from AP

- 42 Table 3.3

- 1 dated 10/96 (2.47E

- 03 lb TOC/hp

- hr (0.09 lb CH 4 /lb TOC)= 2.223E

- 04 lb CH 4 /hp

- hr, this table did not include an estimate of how much methane comprises t he TOC emission factor, so the value of 9% from AP

- 42 Table 3.4

- 1 dated 10/96 was used).
( 300 h ) 1

. 15 h

− h ( 1 )

+ 0

. 6 7000 h

− h 1 06 ( 454 ) ( 310 )

+ 2

. 223

− 04 ( h

− h ) ( 21 ) 500 h h 2 , 000

= 87 / Since the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the lb/hp

hr CO 2 emission rate does not exceed 1.15 lb/hp

- hr. I f required, the permittee shall conduct emissio ns testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the lb/hp

- hr CO 2 emission rate.
h. Emission Limitation:
The permittee shall only combust diesel fuel in this emissions unit meeting the following per gallon standard: 15 ppm ma ximum sulfur content Applicable Compliance Method: The records required by d)(2) 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)(2) and d)(3) shall serve as demonstration of compliance. j. Emission Limitation:
Visible particulate emissions fr om the st ack serving this emissions unit shall not exceed 20 percent opacity as a 6

- minute average.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 43 of 86 Applicable Compliance Method:
If required, the permittee shall demonstrate compliance with this emissions limitation according to Method 9 of 40 CFR Part 60, Appen dix A.
k. Emission Limitation: NMHC + NOx emissions shall not exceed 4.0 g/kW

- hr (3.0 g/hp

- hr); CO emissions shall not exceed 3.5 g/kW

- hr (2.6 g/hp

- hr); and PM emissions shall not exceed 0.20 g/kW

- hr (0.15 g/hp

- hr) Applicable Compliance Method: According to 4 0 CFR 60.4211(c), the permittee shall demonstrate compliance with these emissions limitations by purchasing an engine certified to the emission standards in 40 CFR 60.4205(c) for the same model year and maximum engine power. T he engine must be installed a nd configured according to the manufacturer’s emission

- related specifications, except as permitted in 40 CFR 60.4211(g). g) Miscellaneous Requirements (1) None.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 44 of 86 4. P005, Wet Cooling Tower Operations, Property and/or Equipment Description:
16 cell mechanical dra ft wet cooling tower with high efficiency drift eliminator 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)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rules 3745

- 10 through 20 (Prevention of Significant Deterioration of Air Quality) Particulate matter emissions less than 10 microns in diameter (PM 10 ) shall not exceed 1.03 pounds per hour and 4.5 tons per rolling, 12

- month period.
Particulate matter emissions less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 3.4E

- 03 pound per hour and 0. 015 ton per rolling, 12

- month period.
The permittee shall install a drift eliminator with a maximum drift rate of 0.0005% on this emissions unit.
Visible particulate emissions shall not exceed 10% opacity as a 6

- minute average. The presence of condensed water vapor shall not be deemed a violation for failure of stack emissions meeting this visible emission limitation. see c)(1) d. OAC rule 3745

- 17

- 07(A)(1) see b)(2)d. e. OAC rule 3745

- 17

- 11(B) see b)(2)d.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 45 of 86 (2) Additional Terms and Conditions

a. The requirements of this rule include compliance with the requirements of OAC rule 3745

- 10 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 effect ive November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745

- 31

- 05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no longer required by St ate regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. H owever, 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 S IP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745

- 31

- 05, the requirement to satisfy BAT still exists as part of the federally

- approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05, then these emission limitations/control measures no longer apply.

c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05 as part of the State Implementation Plan.
The Best Available Technology (BAT) requirements under OAC rule 3745

- 31

- 05(A)(3) do not apply to the PM 10 and PM 2.5 emissions from this air contaminant source since the calculated annual emission rate for PM 10 and PM 2.5 is less than 10 tons per year taking into account the federally enforceable rule lim it of 0.0005% drift and a maximum TDS concentration of 2,030.5 mg/l under OAC rule 3745

- 31

- 10 through 20.
d. The emission limitation specified by this rule is less stringent than the emission limitation established by OAC rule 3745

- 31

- 10 through 20. c) Operation al Restrictions (1) The permittee shall maintain the total dissolved solids (TDS) concentration of the cooling water less than or equal to 2,030.5 milligrams per liter. 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. T he monitoring devices shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’ s recommendations, instructions, and operating manuals. (2) Since the TDS data measured by TDS monitors is based on a correlation between conductivity and TDS, an exceedance measured by the TDS monitor is not a violation of the TDS operational restriction, but rather serves as an indicator to initiate corrective action by the permittee to reduce the TDS concentration..Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 46 of 86 e) Reporting Requirements (1) The permittee shall submit quarterly deviation (excursion) reports that identify all TDS readings in excess of 2030.5 mg/ l. T he 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 t o 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: A ir Services online web portal. f) Testing Requirements (1) Compliance with the Emissions Limitations and/or Control Requirements specified in se ction b) of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:
PM 10 emissions shall not exceed 1.03 lbs/hr and 4.5 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/hr PM 10 emission limitation is based on multiplying the maximum re circulating water flow rate (322,000 gal/min) by the maximum TDS concentration (2030.5/1E06) multiplied by the decimal fraction drift rate (0.000005) multiplied by the density of water (8.34 lbs/g al) multiplied by (60 min/hr) and multiplied by the decimal fraction of PM 10 contained in the TDS (0.63). T he permittee calculated the PM 10 fraction using AW MA Abstract No. 216, Session No. AM

- 1b, Orlando, 2001.
The annual emission limitation is based on multiplying the hourly emission limitation (1.03 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 2030.5 mg/l.
b. Emission Limitation:
PM 2.5 emissions shall not exceed 3.4E

- 03 lb/hr and 0.015 ton/yr
The lb/hr PM 2.5 emission limitation is based on multiplying the maximum re circulating water flow rate (322,000 gal/min) by the maximum TDS concentrationFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 47 of 86 (2030.5/1E06) multiplied by the decimal fraction drift rate (0.000005) multiplied by the density of water (8.34 lbs/gal) multiplied by (60 min/hr) and multiplied by the decimal fraction of PM 2.5 contained in the TDS (0.0021). T h e permittee calculated the PM 2.5 fraction using AW MA Abstract No. 216, Session No. AM

- 1b, Orlando, 2001.
The annual emission limitation is based on multiplying the hourly emission limitation (3.4E

- 03 lb/hr) by the maximum annual hours of operation (8,760 h rs/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 2030.5 mg/l.

c. Emission Limitation: The maximum drift rate shall not exceed 0. 0005%. Applicable Compliance Method: Manufacturer's emissions data shall be used to demonstrate compliance with this limitation.
Wi thin 90 days of startup, the permittee shall submit to the Toledo Division of Environmental Services written documentation pr ovided 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.
d. Emission Limitation:
The permittee shall maintain the TDS concentration of the cooling water less than or equal to 2,030.5 milligrams per liter. 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 procedure s 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. g) Miscellaneous Requirements (1) None.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 48 of 86 5. Emissions Unit Group - P001 and P002: CTG #1 and CTG #2
EU ID Operations, Property and/or Equipment Description P001 Mitsubishi M501GAC or Siemens SCC6

- 8000H combined cycle combustion turbine (2,932

mmBtu/hr heat input turbine and 300 mmBtu/hr heat input duct burner) with dry low NOx combustors, selective catalytic reduction (SCR), and catalytic oxidizer. P002 Mitsubishi M501GAC or Siemens SCC6

- 8000H combined cycle combustion turbine (2,932

mmBtu/hr heat input turbine and 300 mmBtu/hr heat input duct burner) with dry low NOx combustors, selective catalytic reduction (SCR), and catalytic oxidizer.

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)(12) through d)(15 ) and e)(6). 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 limita tions 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) Sulfur dioxide (SO 2 ) emissions shall not exceed 1.4E

- 03 lb/mmBtu of heat input. see b)(2)b. b. OAC rule 3745

- 31

- 05(D) The combined SO 2 emissions from P001 and P002 shall not exceed 34.2 tons per rolling 12

- month period if Mitsubishi turbines are installed and 36.8 tons per rolling, 12

- month period if S iemens turbines are installed. see b)(2)e. and f. c. OAC rule 3745

- 31

- 10 through 20 V isible particulate emissions fr om the stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. Carbon dioxide equivalent (CO 2 e) emissions fr

om the Mitsubishi turbine shall not exceed 840 lb/M W

- hr gross energy output and 318,404 lbs/hr.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 49 of 86 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures Carbon dioxide equivalent (CO 2 e) emissions fr

om the Siemens turbine shall not exceed 833 lb/M W

- hr gross energy output and 327,819 lbs/hr.

see b)(2)c., b)(2)d., b)(2)g. through b)(2)n., and b)(2)v. through x. d. OAC rule 3745

- 17

- 07(A) see b)(2)o. e OAC rule 3745

- 17

- 11(B)(4) see b)(2)o. f. OAC rule 3745

- 18

- 06(A) see b)(2)q. g. OAC rule 3745

- 110

- 03(J)(19) Exemption h. OAC rule 3745

- 114 see d)(12) through d)(15) i. 40 CFR Part 60, Subpart A see b)(2)r. 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 li mitations/control measures specified in this section.] see b)(2)p. and b)(2)s.

k. 40 CFR Part 63, Subpart YYYY see b)(2)t. l. 40 CFR Part 63, Subpart JJJJJJ see b)(2)u.

(2) Additional Terms and Conditions

a. All requirements specified for in this Section of the permit for Emissions Unit Group P001 and P002 apply to each combined cycle combustion turbine (P001 and P002) unless a combined requirement is otherwise specified.
b. Compliance with the requirements of this rule for CO, NO x , PM 10 , PM 2.5 , and VOC includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.

c. 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.
d. All particulate emissions ar e assumed to be less than 2.5 microns in diameter. The PM 10 /PM 2.5 emissions limitations include both filterable and condensable particulate emissions.

e. The sulfur content of natural gas burned in this emissions unit shall not exceed 0.5 grains per 100 stan dard cubic feet.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 50 of 86 f. The combined natural gas usage by emissions units P001 and P002 shall not exceed 47,917 mmscf per rolling, 12

- month period if M itsubishi turbines are installed and 51,560 mmscf per rolling, 12

- month period if Siemens turbines are installe d. T o 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 natural gas usage levels specified in the following table:
Maximum Allo wable Cumulative Natural Gas Usage by P001 and P002 combined (Million Standard Cubic Feet) Month(s) mmscf, if Mitsubishi turbines are installed mmscf, if S iemens turbines are installed
1 7,986 8,593
1

- 2 15,972 17,187
1

- 3 23,959 25,780
1

- 4 31,945 34,373
1

- 5 39,931 42,967
1

- 6 47,917 51,560
1

- 7 47,917 51,560
1

- 8 47,917 51,560
1

- 9 47,917 51,560
1

- 10 47,917 51,560
1

- 11 47,917 51,560
1

- 12 47,917 51,560

After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual natural gas usage limitation shall be based upon a rolling, 12

- month summation of the monthly natural gas usag e.
g. The permittee shall comply with the following emissions limitations if a Mitsubishi turbine is installed:Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 51 of 86 Allowable Emissions if Mitsubishi Turbine is Installed
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period
CO CT with DB 2.0 c 12.7

-

CT only 2.0 c 13.7

- All operating modes, including startup periods
- - 183.9
NOx CT with DB 2.0 c 20.8

-

CT only 2.0 c 22.6

- All operating modes, including startup periods 94.8
PM 10 /PM 2.5 CT with DB 3.73E

- 03 d 10.1

-

CT only 3.84E

- 03 d 11.3

- All operating modes, including startup periods
- - 44.2
VOC CT With DB 2.0 c 7.3

-

CT only 2.0 c 7.9

- All operating modes, including startup periods
- - 56.0
H 2 SO 4 CT only 4.1E

- 04 d 1.2

-

CT with DB 4.4E

- 04 d 1.2

- All operating modes, including startup periods
- - 5.26
CO 2 e All operating

modes, including startup periods
- - 1,394,611Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 52 of 86 Allowable Emissions if Mitsubishi Turbine is Installed
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period
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. 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 if a Mitsubishi turbine is installed

(Tons) Month(s) CO NOx PM10/PM2.5 VOC H 2 SO 4 1 30.7 15.8 7.4 9.3 0.88
1

- 2 61.3 31.6 14 18.7 1.75
1

- 3 92.0 47.4 22.1 28.0 2.63
1

- 4 122.6 63.2 29.5 37.3 3.51
1

- 5 153.3 79.0 36.8 46.7 4.38
1

- 6 183.9 94.8 44.2 56.0 5.26
1

- 7 183.9 94.8 44.2 56.0 5.26
1

- 8 183.9 94.8 44.2 56.0 5.26
1

- 9 183.9 94.8 44.2 56.0 5.26
1

- 10 183.9 94.8 44.2 56.0 5.26
1

- 11 183.9 94.8 44.2 56.0 5.26
1

- 12 183.9 94.8 44.2 56.0 5.26Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 53 of 86 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.
i. The permitte e shall comply with the following requirements during periods of startup and shutdown if a Mitsubishi turbine is installed. Emissions Limitations During Startup (lbs/hr) a
Cold Startup Hot

Startup Warm

Startup Shutdown

CO 1106.72 578.5 973.42 263
NOx 43.56 46.93 42.27 35 VOC 339.4 109.34 314.07 111

a Pound per hour emissions rates as presented are averaged over the duration of the event where the duration of a cold start is 150 minutes, the duration of a warm start is 110 minutes, the duration of a hot start is 67 minutes, and the duration of a shutdo wn is less than 1 hour.

“Cold Startup” is defined as a combustion turbine startup that occurs more than 60 hours after a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 150 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x .

“ Hot Startup” is defined as a combustion turbine startup that occurs within 8 hours of a combustion turbine shutdown. T he period of hot startup is defined as the lesser of the first 67 minutes of continuous fuel flow to the combustion turbine after fuel fl ow is initiated or the period of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . “W arm Startup” is defined as a combustion turbine startup that occurs between 8 hours of and 60 hours of a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 110 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time from combustion turbine fuel fl ow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x .Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 54 of 86 j. The design net plant base heat rate with the Mitsub ishi turbine shall not exceed 7,280 Btu/k

W

- hr HHV (ISO conditions without duct firing).
k. The permittee shall comply with the following emissions limitations if a Siemens turbine is installed:

Allowable Emissions if Siemens Turbine is Installed
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period
CO CT with DB 2.0 c 13.0

-

CT only 2.0 c 13.0

- All operating modes, including startup periods
- - 72.2
NOx CT with DB 2.0 c 21.0

-

CT only 2.0 c 22.0

- All operating modes, including startup periods 92.0
PM 10 /PM 2.5 CT with DB 5.5E

- 03 d 14.0

-

CT only 4.7E

- 03 d 13.3

- All operating modes, including startup periods
- - 61.3
VOC CT With DB 1.9 c 5.9

-

CT only 1.0 c 3.9

- All operating modes, including startup periods
- - 28.6
H 2 SO 4 CT with DB 7.0E

- 04 d 1.5

-

CT only 6.0E

- 04 d 1.6

- All operating modes, includingFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 55 of 86 Allowable Emissions if Siemens Turbine is Installed
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period startup periods

- - 6.57
CO 2 e All operating

modes, including startup periods
- - 1,435,847
a. CT = combustion turbine DB = duct burner b. 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.

l. 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 if a Siemens turbine is installed

(Tons) Month(s) CO NOx PM10/PM2.5 VOC H 2 SO 4 1 12.0 15.3 10.2 4.8 1.10
1

- 2 24.1 30.7 20.4 9.5 2.19
1

- 3 36.1 46.0 30.7 14.3 3.29
1

- 4 48.1 61.3 40.9 19.1 4.3
1

- 5 60.2 76.7 51.1 23.8 5.48
1

- 6 72.2 92.0 61.3 28.6 6.57
1

- 7 72.2 92.0 61.3 28.6 6.57
1

- 8 72.2 92.0 61.3 28.6 6.57
1

- 9 72.2 92.0 61.3 28.6 6.57Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 56 of 86 Maximum Allowable Cumulative Emissions if a Siemens turbine is installed

(Tons) Month(s) CO NOx PM10/PM2.5 VOC H 2 SO 4 1

- 10 72.2 92.0 61.3 28.6 6.57
1

- 11 72.2 92.0 61.3 28.6 6.57
1

- 12 72.2 92.0 61.3 28.6 6.57

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.

m. The permitte e shall comply with the following requirements during periods of startup and shutdown if a Siemens turbine is installed. Emissions Limitations During Startup and Shutdown (lbs/hr) a
Cold Startup Hot

Startup Warm

Startup Shutdown

CO 182.0 211.46 214.90 113
NOx 62.67 76.83 78.98 46 VOC 56.0 83.41 84.49 44

a Pound per hour emissions rates as presented are averaged over the duration of the event where the duration of a cold start is 180 minutes, the duration of a warm start is 98 minutes, the duration of a hot start is 82 minutes, and the duration of a shutdow n is less than 1 hour.

“Cold Startup” is defined as a combustion turbine startup that occurs more than 64 hours after a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 180 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . “H ot Startup” is defined as a combustion turbine startup that occurs within 16 hours of a combustion turbine shutdown. T he period of hot startup is defined asFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 57 of 86 the lesser of the first 82 minutes of continuous fuel flow to the combustion turbine after fuel fl ow is initiated or the period of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . “W arm Startup” is defined as a combu stion turbine startup that occurs between 16 hours of and 64 hours of a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 98 minutes of continuous fuel fl ow to the combustion turbine after fuel fl ow is initiated or t he period of time fr om combustion turbine fuel fl ow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x .
n. The design net plant base heat rate with the Siemens tur bine shall not exceed 7,227 Btu/k

W

- hr HHV (ISO conditions without duct firing).

o. The emission limitation specified by this rule is less stringent than the limitation established by OAC rule 3745

- 31

- 10 through 20.
p. The emission limitation specified by this ru le is less stringent than the limitation established by ORC 3704.03(T).
q. This emissions unit is exempt from the requirements of this rule, since only natural gas is burned.

r. 40 CFR Part 60 subpart A provides applicability provisions, definitions, and other g eneral provisions that are pertinent to emissions units affected by 40 CFR Part 60.

s. 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. T he application and enforcement of these standards are delegated to the Ohio EPA. T he requirements of 40 CFR Part 60 are also federally enforceable.
t. This emissions unit is not subject to the requirements of 40 CFR Par t 63, Subpart YYYY, since it is not located at a major source of HAP emissions.

u. The duct burner is exempt from the requirements of this rule per 40 CFR 63.11195(e) due to combusting only natural gas.

v. Each continuous NOx monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 2 and 6. A t least 45 days before commencing certification testing of the continuous NOx monitoring system(s), the permittee shall develop and maintain a written quality as surance/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). E xcept as allowed below, the plan shall follow the requirements of 40 CFR Part 60, Appendix F and 40 CFR Part 75, Appendix B. T he quality assurance/quality control plan and a l ogbook dedicatedFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 58 of 86 to the continuous monitoring system must be kept on site and available for inspection during regular office hours. The plan shall inclu de 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 requirement s for monitoring systems subject to 40 CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60. The plan shall i nclude 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 subs tituted for the quarterly cylinder gas or relative accuracy audits required per 40 CFR Part 60.

w. Each continuous carbon monoxide (CO) monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 4 or 4a and 6. A t 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 representati ve readings of CO emissions from the continuous monitor(s), in units of the applicable standard(s). T he 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. T he 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 conduc t 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 subjec t to 40 CFR 75, Appendix B. I n either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60. The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accura cy audits as required in 40 CFR Part 60; however, the quarterly cylinder gas audit and relative accuracy audit fr equency requirements may be adjusted to coincide with linearity checks completed for continuous emissions monitoring systems subject to 40 CFR Part 75, Appendix B requirements.

x. 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, analyze rs, and data recording/processing hardware and software.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 59 of 86 c) Operational Restrictions (1) The permittee shall only burn pipeline quality natural gas as fuel in this emissions unit. (2) To ensure compliance with the PSD modeling, the permittee shall not operate more than one combustion turbine in startup mode at a time. (3) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420) 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. (2) For purposes of demonstrating compliance with the natural gas sulfur concentration restriction of 0.5 grain/dscf, the permittee shall sample and analyze the natural gas burn ed in this emissions unit monthly to determine the sulfur content using the appropriate ASTM or Gas Processors Association standards. Fuel supplier data may be used to comply with this requirement, provided that it is demonstrated to be representative of the fuel received for burning at this emissions unit. (3) The permittee may elect not to monitor the total sulfur content of the fuel combusted in the turbine as specified in d)(2), if the fuel is demonstrated not to exceed potential sulfur emissions of 1.4E

- 0 3 lb SO 2 /mmBtu. T he permittee shall use one of the following sources of information to make the required demonstration:

a. the fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, specifyin g that the maximum total sulfur content for natural gas is 0.5 grains of sulfur or less per 100 standard cubic feet, has potential sulfur emissions of l ess than less than 1.4E

- 03 l b SO 2 /mmBtu heat input;
b. representative fuel sampling data which show that th e sulfur content of the fuel does not exceed 1.4E

- 03 lb SO 2 /mmBtu heat input. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of appendix D to part 75 of this chapter is required; or

c. one of the custom sulfur monitorin g schedules outlined in 40 CFR 60.4370(c) may be used to comply with the 1.4E

- 03 lb SO 2 /mmBtu standard. (4) The permittee shall maintain monthly records of the following information:

a. the natural gas usage by P001 and P002 for each month;
b. the combined natural g as usage by P001 and P002 for each month ; and

c. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12

- month summation of the combined natural gas usage by P001 and P00 2.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 60 of 86 Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative combined natural gas usage by P001 and P002 for each calendar month. (5) The permittee sh all maintain monthly records of the following information:

a. the CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emission rate for each month of operations ; and
b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12

- month summation of the CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emissions. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emissions for each calendar month. (6) The permittee shall maintain monthly records of the follow ing 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;
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; (7) 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 requirem ents in 40 CFR Part 60, Appendix B, Per formance Specification 2. T he 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. OnceFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 61 of 86 received, the letter(s)/document(s) of ce rtification 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. (8) The permittee shall inst all, 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 calibrati on 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 co ntrol equipment;
g. the date, time, and hours of operation of the emissions unit without the control equipment and/or the continuous NOx monitoring system;
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. (9) Prior to the installation of the continuous carbon monoxide (CO) monitoring system, the permittee shall submit information detailing the proposed location of the sampli ng site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate). T he Ohio EPA, Central Office shall approve the proposed sampling site and certify that the continuous CO monitoring syste m meets theFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 62 of 86 requirements of Performance Specifications 4 or 4a and 6. O nce received, the letter(s)/document(s) of certification shall be maintained on - site and shall be made available to the Director (the appropriate Ohio EPA District Office or local ai r agency) upon request. (10) 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). T he 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 n o 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 c hecks and the magnitude of manual calibration adjustments;

e. results of required relative accuracy test audit(s), including results in units of the applicable standard(s);
f. hours of operation of the emissions unit, continuous CO monitoring system, and control equipment;
g. the date, time, and hours of operation of the emissions unit without the control equipment and/or the continuous CO monitoring system;
h. the date, time, and hours of operation of the emissions unit during any malfunction of the control equipment and/or the continuous CO monitoring system; as well as,
i. the reason (if known) and the corrective actions taken (if any) for each such event in (g) and (h).
All valid data points generated and recorded by the continuous emission monitoring and data acquisit ion and handling system shall be used in the calculation of the pollutant concentration and/or emission rate over the appropriate averaging period. (11) The permittee shall calculate and record the monthly CO 2 emissions from P001 and P002 using data fr

om the co ntinuous fl ow and moisture content monitors using the procedures set forth in 40 CFR Part 75, Appendix G. From this data, the permittee shall calculate the CO 2 emissions from P001 and P002 per rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 63 of 86 (12) The Permit to Install application for these emissions units, P001 and P002 , was evaluated based on the actual materials and the design parameters of the emissions unit's(s’) exhaust system, as specified by the permittee. T he “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. T he 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), calc ulated 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 work week, for each toxic compound(s) emitted fr om the emissions unit(s), (as determined from the raw materials processed and/or coatings or other materials applied) has been documented from one of the following sources and in the following order of preference (TLV was and shall be used, if the chemical is listed):
i. threshold limit value (TLV) fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices”; or ii. STEL (short term exposure limit) or the ceiling value fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices”; the STEL or ceiling valu e 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 fr om the working population to the general public (TLV/10).

c. This standard is/was then adjusted to account for the duration of the exposure or the operating hours of the emissions unit(s), i.e., “ X = 24” hours per day and “ Y = 7” days per week, fr

om that of 8 hours per day and 5 days per week. T he 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) if Mitsubishi turbines are installed: Toxic Contaminant: H 2 SO 4 TLV (mg/m3): 0.2 mg/m 3 Maximum Hourly Emission Rate (lbs/hr): 1.2Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 64 of 86 Predicted 1

- Hour Maximum Ground

- Level Concentration (μg/m3): 0.329 MAGLC (μg/m3): 4.76

e. The following summarizes the results of dispersion modeling for the “worst case” toxic contaminant(s) if Siemens turbines are installed: Toxic Contaminant: H 2 SO 4 TLV (mg/m3): 0.2 Maximum Hourly Emission Rate (lbs/hr): 0.7
Predicted 1

- Hour Maximum Ground

- Level Concentration (μg/m3): 0.169 MAGLC (μg/m3): 4.76 The permittee, has demonstrated that emissi ons of H 2 SO 4 , from emissions unit(s) P001 and P002 , is calculated to be less than eighty per cent of the maximum acceptable ground level concentration (MAGLC); any new raw material or processing agent shall not be applied without evaluating each component toxic air contaminant in accordance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F). (13) 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. C hanges that can affect the parameters/values used in determining the 1

- hour maximum ground

- level c oncentration 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 lo west 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) applic ation; and

c. physical changes to the emissions unit(s) or its/their exhaust parameters (e.g., increased/ decreased exhaust fl ow, changes in stack height, changes in stack diameter, etc.).
If the permittee determines that the “Toxic Air Contaminant Statute” w ill 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 Contamina nt Statute”, ORC 3704.03(F), has been documented. I f the change(s) meet(s) the definition of a “modification”, the permittee shall apply for and obtain a fi nal PTI prior to the change. The Director may consider any significant departure from the operatio ns of theFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 65 of 86 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 appli cation for the increased emissions. (14) 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 pr edicted 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), initially and for each change that requires re - evaluation of the toxic air contaminant e missions; 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. (15) 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. T he record shall include the date and reason(s) for the change and if the change would increase the ground

- level concentration. (16) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420) e) Reporting Requirements (1) T he permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas was burned in this emissions unit. E ach report shall be submitted within 30 days after the deviation occurs. (2) The permittee shall submit quart erly deviation (excursion) reports that identify the following:

a. Any monthly record showing an exceedance of the allowable sulfur content of natural gas, 0.5 grain per 100 standard cubic feet; andFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 66 of 86 b. all exceedances of the rolling, 12

- month combined natural ga s usage limitation; 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 combined natural gas usage levels.
The quarterly deviation (exc ursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. (3) The permittee shall comply with the following quarterly reporting requirements for the emissions unit and its continuous N Ox 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 7 6, OAC Chapters 3745

- 14 and 3745

- 23, and any other applicable rules or regulations. T he 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 acti ons 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. th e 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 ha rdware, 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 em issions 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 o r linearity checks;
ix. unless previously submitted, results and date of the relative accuracy test audit(s), including results in units of the applicable standard(s), (during appropriate quarter(s));Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 67 of 86 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. D ata 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 comply with the following quarterly reporting requirements for the emissions unit and its contin uous 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 wi thin 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 exce edance. 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;Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 68 of 86 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 t hat 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, resul ts 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 o ut

- of

- control and the compliant results following any corrective actions;
xi. the date, time, and duration of any/each malfunction** of the continuous CO monitoring system, emissions unit, and/or control equipment;
xii. the date, time, and duration of any downtime* * of the continuous CO monitoring system and/or control equipment while the emissions unit was in operation; and
xiii. the reason (if known) and the corrective actions taken (if any) for each event in (b)(xi) and (xii).
Each report shall address the operations c onducted and data obtained during the previous calendar quarter. D ata 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 eve nt shall be reported regardless if there is an exceedance of any applicable limit (5) The permittee shall collect, record, and maintain measurements, data, records, and reports required per 40 CFR Part 75; and shall submit certification, recertification, notif ications, applications, monitoring plans, petitions for alternative monitoring systems,Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 69 of 86 electronic quarterly reports, and any other pertinent record and/or report to the Administrator (U.S. EPA), as required by this Part. (6) 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); and
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 m aximum 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. (7) See 40 CFR Part 6 0, Subpart KKKK (40 CFR 60.4300

– 60.4420) 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. Emissi on Limitation: If a Mitsubishi turbine is installed, CO emissions from this emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 13.7 lbs/hr when the duct burner is not in operation; and, 2.0 ppmvd at 15% oxygen as an hourly ave rage and 12.7 lbs/hr when the duct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60. If required, the permittee shall demonstrate compliance using Methods 1 thru 4 and 10 of 40 CFR Part 60, Appendix A. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 70 of 86 b. Emission Limitation: If a Mitsubishi turbine is installed, CO emissions from this emis sions unit shall not exceed 183.9 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 50 cold startups per year, with a minimum downtime preceding cold start up of 60 hours and a cold startup duration of 150 minutes, maximum CO emissions of 2,766.8 pounds during each cold startup period; 250 hot startups per year with a of duration of 67 minutes each and maximum CO emissions of 646 pounds during each hot startu p period; hourly CO emissions at ISO conditions during steady state operation of 12.7 lbs/hr based on manufacturer’s data and steady state operating hours was determined by the following equation.

8 , 760 h

− 50 60 h + + 250 = 5,355.8 hours

The allowable annual emission rate was determined by the following calculation using the above information.

, . , . . 

## = 183.9 tons

Wh ere: C S = cold starts HS = hot starts Ongoing compliance with this emissions limitation shall be based on the pounds per hour emission data fr om the CO CEMS and the actual hours of operation of this emissions unit.

c. Emission Limitation: If a Mitsubishi turbine i s installed, CO emissions from this emissions unit shall not exceed 1106.72 lbs/hr during cold startup, 578.5 lbs/hr during hot startup, 973.42 lbs/hr during warm startup, and 263 lbs/hr during shutdown averaged over the duration of the event.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 71 of 86 Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60.
d. Emission Limitation: If a Mitsubishi turbine is installed, NO x emissions from this emissions unit shall not excee d 2.0 ppmvd at 15% oxygen as an hourly average and 22.6 lbs/hr when the duct burner is not in operation; and, NO x emissions shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 20.8 lbs/hr when the duct burner is in operation. Applicable Compl iance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the testing and recertification requirements of 40 CFR Part 60 and 40 CFR Part 75.
If required, 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. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

e. Emission Limitation:
If a Mitsubishi turbine is installed, NO x emi ssions shall not exceed 94.8 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 250 hot startups per year with a duration of 67 minutes each and maximum NOx emissions of 52.4 pounds during each hot startup period; hourly NOx emissions at ISO conditions during steady state operation of 20.8 lbs/hr based on manufacturer’s data and steady state operating hours as calculated by the following equation.

8 , 760 h

− 250 67

60 = 8 , 480

. 83 hFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 72 of 86 The allowable annual emission rate was determined by the following calculation using the above information.



### . . . 

## = 94.8 tons NOx

Wh ere: HS = hot starts

Ongoing compliance with this emissions limitation shall be determined using the pounds per hour emission data from the NOx CEMS and the actual hours of operation of this emissions unit.
f. Emission Limitation: If a Mitsubishi turbine is installed, NOx emissions from this emissions unit shall not exceed 43.56 lbs/hr during cold startup, 46.93 lbs/hr during hot startup, 42.27 lbs/hr during warm startup, and 35 lbs/hr during shutdown averaged over the duration of the event. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Rec ord 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:
If a Mitsu bishi turbine is installed, PM 10 emissions and PM 2.5 emissions shall not exceed 3.84E

- 03 lb/mmBtu of heat input and 11.3 lbs/hr when the duct burner is not in operation; and, PM 10 and PM 2.5 shall not exceed 3.73E

- 03 lb/mmBtu of heat input and 10.1 lbs/hr w hen the duct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. I f required, the permittee shall demonstrate compliance with these emissions limitations using Methods 201A and 202 of 40 CFR Part 51, Appendix M. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 73 of 86 h. Emission Limitation: If a M itsubishi turbine is installed, PM 10 and PM 2.5 emissions from this emissions unit shall not exceed 44.2 tons pe r rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the short

- term allowable PM 10 /PM 2.5 emission limitation (10.1 lbs/hr) by the maximum annual hours of operation (8,760 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.
i. Emission Limitation: The sulfur content of natural gas burned shall not excee d 0.5 gr ain per standard cubic feet. Applicable Compliance Method: Compliance with the lb/mmBtu limitation will be determined by the monitoring and recordkeeping specified in 40 CFR 60.4365 or 40 CFR 60.4370.
If required, the permittee shall demonstrate co mpliance using the procedures specified in 40 CFR 60.4415(a)(1). Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA. j. Emission Limitation: SO 2 emissions shall not exceed 1.4E

- 03 lb/mmBtu of heat input. Applicable C ompliance Method:
The lb/mmBtu limitation 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. M ultiply the maximum sulfur content of natural g as (0.5 grain S/100 scf) by the molecular weight of SO 2 (64.07 lb SO 2 /lb

- mole) divide by the molecular weight of sulfur (32.06 lb S/lb

- mole) divide by (7,000 grains/lb), divide by (1,020 Btu/scf), and multiply by (10 6 Btu/mmBtu). If required, compliance sh all be demonstrated according to 40 CFR 60.4415.
k. Emission Limitation:
The combined SO 2 emissions fr om P001 and P002 shall not exceed 34.2 tons per rolling 12

- month period if Mitsubishi turbines are installed. Applicable Compliance Method: Compliance with this emissions limitation shall be determined by the following calculation based on the records required by d). M ultiply the maximum sulfurFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 74 of 86 content of natural gas (0.5 gr S/100 scf) by the molecular weight of SO 2 (64.07 lb/lb

- mole), divide by the molecular weight of sulfur (32.06 lb/lb

- mole), divide by (7,000 gr/lb), multiply by the monthly natural gas usage (scf), and divide by (2,000 lbs/ton) to determine the monthly SO 2 emissions (tons). A dd the SO 2 emissions calculated for the current month to the total SO 2 emissions calculated for the previous 11 months to determine the tons SO 2 emissions per rolling, 12

- month period.
l. Emission Limitation: If a M itsubishi turbine is installed, VOC emissions shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 7.9 lbs/hr when the duct burner is not in operation; and, VOC emissions shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 7.3 lbs/hr when the duct burner is in operation. Applicable Compliance Method:
These emissions lim itations are based on manufacturer’s data. I f required, 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.

m. Emission Limitation: If a M itsubishi turbine is installed, VOC emissions shall not exceed 56.0 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 50 cold startups per year, with a minimum downtime preceding cold startup of 60 minutes and a cold startup duration of 150 minutes, maximum VOC emissions of 848.5 pounds during each cold startup period; 250 hot startups per year with a of duration of 67 minutes each and maximum VOC emis sions of 122.1 pounds during each hot startup period; hourly VOC emissions at ISO conditions during steady state operation of 7.3 lbs/hr based on manufacturer’s data and steady state operating hours was determined by the following equation.

8 , 760 h

− 50 6 0 h + + 250 = 5,355.8 hours

The allowable annual emission rate was determined by the following calculation using the above information.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 75 of 86 . . , . . 

## = 56.0 tons

Wh ere: CS = cold starts HS = hot starts

Ongoing compliance with this emissions limitation shall be based on the following calculation.

= ( # ) 339

. 5 h + ( # ) 109

. 88 + ( # ) 314

. 07 h + ( # ) 7

. 3 h + ( # ) ( 7

. 0 h )
2000
Wh ere: VOC = tons VOC emissions per rolling, 12

- month period #CS = hours operated in cold startup per rolling, 12

- month period #HS = hours operated in hot startup per rolling, 12

- month period #W S = hours op erated in warm startup 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

n. Emission Limitation: If a Mitsubishi turbine is installed, VOC emissions fr om this emissions unit shall not exceed 339.4 lbs/hr during cold startup, 109.34 lbs/hr during hot startup, 314.07 lbs/hr during warm startup, and 111 lbs/hr during shutdown averaged over the duration of th e event. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. I f required, the permittee shall demonstrate compliance with this emission limitation through emission testing performed in accordance with Methods 1 thro ugh 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. Use of Method 18, 25 orFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 76 of 86 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 us ed with prior approval from Ohio EPA.

o. Emission Limitation:
If a Mitsubishi turbine is installed, H 2 SO 4 emissions shall not exceed 4.1E

- 04 lb/mmBtu of heat input and 1.2 lbs/hr when the duct burner is not in operation; and, H 2 SO 4 emissions shall not exceed 4.4E

- 04 lb/mmBtu of heat input and 1.2 lbs/hr when the duct burner is in operation.
These emissions limitations are based on manufacturer’s data. I f required, the permittee shall demonstrate compliance using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appen dix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
p. Emission Limitation:
If a Mitsubishi turbine is installed, H 2 SO 4 emissions shall not exceed 5.26 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the short

- term allowable H 2 SO 4 emission limitation (1.2 lbs/hr) by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefore, if compliance is sh own with the short

- term allowable emission limitation, compliance shall also be shown with the annual emission limitation.
q. Emission Limitation: If a Mitsubishi turbine is installed, CO 2 e emissions shall not exceed 318,404 lbs/hr and 1,394,611 tons per roll ing, 12

- month period. Applicable Compliance Method:
The hourly emission limitation is based on the sum of following manufacturer’s data (317,920.46 lbs/hr CO 2 , 6.007 lbs/hr CH 4 , and 1.154 lbs/hr N 2 O) multiplied by the associated global warming potential fo r each pollutant (CO 2 =1, CH 4 =21, N 2 O=310 from Table A

- 1 of 40 CFR 98).

317 , 920

. 46 h ( 1 ) + 6

. 007 h ( 21 ) + 1

. 154 h ( 310 ) = 318 , 404 / h
Since the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the hourly CO 2 emission rate does not exceed 317,920.46 lbs/hr. 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 hourly CO 2 emis sion rate.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 77 of 86 The annual emission limitation is based on the sum of following manufacturer’s data (317,920.46 lbs/hr CO 2 , 6.01 lbs/hr CH 4 , and 1.15 lbs/hr N 2 O) multiplied by the associated global warming potential for each pollutant (CO 2 =1, CH 4 =21, N 2 O=310 fr om Table A

- 1 of 40 CFR 98), multiplied by the maximum annual hours of operation (8,760 hrs/yr) and divided by (2,000 lbs/ton).

317 , 920

. 46 h ( 1 ) + 6

. 007 h ( 21 )

+ 1

. 154 h ( 310 ) 8 , 760 h 2000 = 1 , 394 , 611 /

Since the CO 2 e emis sions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the rolling, 12

- month CO 2 emissions as calculated in section d) above do not exceed 1,392,492 tons per rolling, 12

- month period (317 ,920.46 lbs/hr x 8760 hrs/yr x ton/2000 lb = 1,392,492 tons/yr).

r. Emission Limitation:
Visible particulate emissions from any stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. Applicable Compliance Method:
If requi red, 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.

s. Emission Limitation: If a Si emens turbine is installed, CO emissions from this emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 13.0 lbs/hr when the duct burner is not in operation; and, 2.0 ppmvd at 15% oxygen as an hourly average and 13.0 lbs/hr when the d uct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60.
If required, the permittee shall demonstrate compliance using Methods 1 thr u 4 and 10 of 40 CFR Part 60, Appendix A. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
t. Emission Limitation:Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 78 of 86 If a Si emens turbine is installed, CO emissions from this emissions unit shall not exceed 182.0 lb s/hr during cold startup, 211.46 lbs/hr during hot startup, 214.90 lbs/hr during warm startup, and 113 lbs/hr during shutdown averaged over the duration of the event. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s dat a. O ngoing compliance with the CO emission limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality con trol plan, which shall meet the requirements of 40 CFR Part 60.

u. Emission Limitation: If a Si emens turbine is installed, CO emissions from this emissions unit shall not exceed 72.2 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissi ons limitation is based on the following anticipated worst case emissions: 250 warm startups per year, with a minimum downtime preceding warm startup of 16 hours and a warm startup duration of 98 minutes, maximum CO emissions of 351 pounds during each warm startup period; hourly CO emissions at ISO conditions during steady state operation of 13.0 lbs/hr based on manufacturer’s data and steady state operating hours was determined by the following equation.

8 , 760 h

− 250 16 h + = 4,351 .7 hours

The allowable annual emission rate was determined by the following calculation using the above information.

, . . 

## = 72.2 tons

Wh ere: WS = warm starts

Ongoing compliance with this em issions limitation shall be based on the pounds per hour emission data fr om the CO CEMS and the actual hours of operation of this emissions unit.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 79 of 86 v. Emission Limitation: If a Siemens turbine is installed, NO x emissions from this emissions unit shall not exc eed 2.0 ppmvd at 15% oxygen as an hourly average and 22.0 lbs/hr when the duct burner is not in operation; and, NO x emissions shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 21.0 lbs/hr when the duct burner is in operation. Applicable Com pliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; a nd 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.
If required, the permittee shall demonstrate compliance using Method s 1 thru 4 and 7E of 40 CFR Part 60, Appendix A, and the procedures specified in 40 CFR 60.4400. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

w. Emission Limitation:
If a Siemens turbine is installed, NO x emissions shall not exceed 92.0 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the short

- term allowable NOx emission limitation (21.0 lbs/hr) by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefore, if compliance is shown with the short

- term allowable emission limitation, compliance shall also be shown with the annual emission limitation. Ongoing compliance with this emissions limit ation shall be determined using the pounds per hour emission data from the NOx CEMS and the actual hours of operation of this emissions unit.

x. Emission Limitation: If a Siemens turbine is installed, NOx emissions from this emissions unit shall not exceed 62 .67 lbs/hr during cold startup, 76.83 lbs/hr during hot startup, 78.98 lbs/hr during warm startup, and 46 lbs/hr during shutdown averaged over the duration of the event. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. O ngoing compliance with the NOx emissions limitations shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of thisFinal Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 80 of 86 permit; and through demonstration of compliance with the quality assurance/qualit y control plan, which shall meet the testing and recertification requirements of 40 CFR Part 60 and 40 CFR Part 75.
y. Emission Limitation:
If a Siemens turbine is installed, PM 10 emissions and PM 2.5 emissions shall not exceed 4.7E

- 03 lb/mmBtu of heat input a nd 13.3 lbs/hr when the duct burner is not in operation; and, PM 10 and PM 2.5 shall not exceed 5.5E

- 03 lb/mmBtu of heat input and 14.0 lbs/hr when the duct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufa cturer’s data. I f required, the permittee shall demonstrate compliance with these emissions limitations using Methods 201A and 202 of 40 CFR Part 51, Appendix M. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA

.
z. Emission Limitation: If a Siemens turbine is installed, PM 10 and PM 2.5 emissions from this emissions unit shall not exceed 61.3 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the sho rt

- term allowable PM 10 /PM 2.5 emission limitation (14.0 lbs/hr) by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. Therefore, if compliance is shown with the short

- term allowable emission limitation, complian ce shall also be shown with the annual emission limitation.

aa. Emission Limitation:
The combined SO 2 emissions fr om P001 and P002 shall not exceed 36.8 tons per rolling, 12

- month period if Siemens turbines are installed. Applicable Compliance Method: Complian ce with this emissions limitation shall be determined by the following calculation based on the records required by d). M ultiply the maximum sulfur content of natural gas (0.5 gr S/100 scf) by the molecular weight of SO 2 (64.07 lb/lb

- mole), divide by the molecular weight of sulfur (32.06 lb/lb

- mole), divide by (7,000 gr/lb), multiply by the monthly natural gas usage (scf), and divide by (2,000 lbs/ton) to determine the monthly SO 2 emissions (tons). A dd the SO 2 emissions calculated for the current month to the total SO 2 emissions calculated for the previous 11 months to determine the tons SO 2 emissions per rolling, 12

- month period.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 81 of 86 bb. Emission Limitation:
If a Siemens turbine is installed, VOC emissions shall not exceed 1.0 ppmvd at 15% oxygen as an hourly a verage and 3.9 lbs/hr when the duct burner is not in operation; and, VOC emissions shall not exceed 1.9 ppmvd at 15% oxygen as an hourly average and 5.9 lbs/hr when the duct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. I f required, 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, Appendi x 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.

cc. Emission Limitation: If a Siemens turbine is installed, VOC emissions shall not exceed 28.6 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 250 warm startups per year, with a mini mum downtime preceding warm startup of 16 hours and a warm startup duration of 98 minutes, maximum VOC emissions of 138 pounds during each warm startup period; hourly VOC emissions at ISO conditions during steady state operation of 5.2 lbs/hr based on manu facturer’s data and steady state operating hours was determined by the following equation.

8 , 760 h

− 250 16 h + = 4,351.7 hours

The allowable annual emission rate was determined by the following calculation using the above information.

, . . 

## = 28.6 tons

Wh ere: WS = warm starts

Ongoing compliance with this emissions limitation shall be based on the following calculation.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 82 of 86 ( # )

. ( # )

. ( # )

. ( # )

. ( # )

. = VOC

Wh ere: VOC = tons VOC emissions per rolling, 12

- month period #CS = hours operated in cold startup per rolling, 12

- month period #HS = hours operated in hot startup per rolling, 12

- month period #W S = hours operated in warm startup 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

- mont h period

dd. Emission Limitation:
If a Siemens turbine is installed, VOC emissions from this emissions unit shall not exceed 56.0 lbs/hr during cold startup, 83.41 lbs/hr during hot startup, 84.49 lbs/hr during warm startup, and 44 lbs/hr during shutdown ave raged over the duration of the event. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. I f required, the permittee shall demonstrate compliance with this emission limitation through emission testing performed in a ccordance 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 app roved test methods may be used with prior approval from Ohio EPA.

ee. Emission Limitation: If a Siemens turbine is installed, H 2 SO 4 emissions shall not exceed 6.0E

- 04 lb/mmBtu of heat input and 1.6 lbs/hr when the duct burner is not in operation; and, H 2 SO 4 em issions shall not exceed 7.0E

- 04 lb/mmBtu of heat input and 1.5 lbs/hr when the duct burner is in operation.
These emissions limitations are based on manufacturer’s data. I f required, 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.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 83 of 86 ff. Emission Limitation: If a Siemens turbine is installed, H 2 SO 4 emissions shall not exceed 6.57 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the short

- term allowable H 2 SO 4 emission limitation (1.5 lbs/hr) by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefor e, if compliance is shown with the short

- term allowable emission limitation, compliance shall also be shown with the annual emission limitation.
gg. Emission Limitation: If a Siemens turbine is installed, CO 2 e emissions shall not exceed 327,819 lbs/hr and 1,43 5,847 tons per rolling, 12

- month period. Applicable Compliance Method:
The hourly emission limitation is based on the sum of following manufacturer’s data (327,380 lbs/hr CO 2 , 6.14 lbs/hr CH 4 , and 1.00 lbs/hr N 2 O) multiplied by the associated global warmin g potential for each pollutant (CO 2 =1, CH 4 =21, N 2 O=310 from Table A

- 1 of 40 CFR 98).

327 , 380 h ( 1 ) + 6

. 14 h ( 21 ) + 1

. 00 h ( 310 ) = 327 , 819 / h

Since the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the hourly CO 2 emission rate does not exceed 327,380 lbs/hr. I f required, the permittee shall conduct emissions testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the hourly CO 2 emissi on rate.
This emission limitation is based on the sum of following manufacturer’s data (327,380 lbs/hr CO 2 , 6.14 lbs/hr CH 4 , and 1.00 lbs/hr N 2 O) multiplied by the associated global warming potential for each pollutant (CO 2 =1, CH 4 =21, N 2 O=310 from Table A

- 1 of 40 CFR 98), multiplied by the maximum annual hours of operation (8,760 hrs/yr) and divided by (2,000 lbs/ton).

327 , 380 h ( 1 ) + 6

. 14 h ( 21 ) + 1

. 00 h ( 310 ) 8 , 760 h 2000

= 1 , 435 , 847 / Since the CO 2 e emissions are esti mated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the rolling, 12

- month CO 2 emissions as calculated in section d) above do not exceed 1,433,924 tons per rolling, 12

- month period (327,380 lbs/hr x 8760 hrs/yr x ton/2000 lb = 1,433,924 tons/yr).Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 84 of 86 (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 t he maximum production rate at which the emissions unit will be operated, but not later than 180 days after initial startup of the emissions unit.
b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate(s) for CO, NO x , PM 10 , PM 2.5 , VOC, and H 2 SO 4 , in the appropriate averaging period(s).
The emission testing shall also be conducted to determine a site

- specific emission factor for CO 2 .
c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): For CO, Methods 1 thru 4 and 10 of 40 CFR Part 60, Appendix A;
For NOx, Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A, and the procedures specified in 40 CFR 60.4400;
For PM 10 and PM 2.5 , Methods 201A and 202 of 40 CFR Part 52, Appendix M;
For SO 2 , 40 CFR 60.4415;
For VOC, Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A. 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 H 2 SO 4 , Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A; and
For CO 2 , Methods 1, 2, 3A, and 4 of 40 CFR Part 60, Appendix A.
Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA.
d. The test(s) shall be conducted under those 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 appr opriate 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 circumstan ces where a lower emissions loading is deemed the most challenging control scenario. F ailure to test under these conditions is justification for not accepting the test results as a demonstration of compliance.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 85 of 86 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. T he "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 nece ssary 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). T he 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) Wi thin 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 Speci fication 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 fr

om the Ohio EPA Central Office and the appropriate Ohio EPA District Office or local air agency shal l be notified 45 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests. Two copies of the test results shall be submitted to Ohio EPA, one copy to the appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA Central Office, and pursuant to OAC rule 3745

- 15

- 04, within 30 days after the test is completed. Certification, or recommendation for certification by Ohio EPA to U.S. EPA, of the continuous NOx monitori ng 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.Final Permit - to - Install Oregon Clean Energy Center Permit Number : P0110840 Facility ID: 0448020102 Effective Date : 6/18/2013

Page 86 of 86 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 Recor d 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) Wi thin 60 days of achieving the m aximum 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 dem onstrate compliance with 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy requirements; and ORC section 3704.03(I).
The permittee shall certify that the fuel flow monitor/meter is calibrated prior to the performance specification test and shall demonstrate how the pound per hour emissions of CO will be calculated stoichiometrically from the fuel flow rate.
Personnel fr

om the Ohio EPA Central Office and the appropriate Ohio EPA Dist rict Office or local air agency shall be notified 30 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests. Two copies of the test results shall be submitted to Ohio EPA, one copy to the appropriate Ohio EPA District Office or local air agency and one copy to Ohio EPA Central Office, and pursuant to OAC rule 3745

- 15

- 04, within 30 days after the test is completed. Certification of the continuous CO monitoring system shall be granted upon determination by the Ohio EPA Central Office that the system meets the requirements of 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy requirements; and ORC section 3704.03( I). Ongoing compliance with the CO emission limitations contained in this permit, 40 CFR Part 60, and any other applicable standard(s) shall be demonstrated through the data collected as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60. g) Miscellaneous Requirements (1) None.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) 9/30/2014

William Martin Oregon Clean Energy Center 20 Park Plaza, Suite 456 Boston, MA 02216
RE: FINAL AIR POLLUTION PERMIT

- TO

- INSTALL Facility ID: 0448020102 Permit Number: P0117413 Permit Type: Administrative Modification County: Lucas
Dear Permit Holder:
Enclosed please fi nd a final Ohio Environmental Protection Agency (EPA) Air Pollution Permit

- to

- Install (PTI) which will allow you to install or modify the described emissions unit(s) in a manner indicated in the permit. Because this permit contains several conditions and restrictions, we urge you to read it carefully. Becaus e this permit contains conditions and restrictions, please read it very carefully. In this letter you will find the information on the following topics:

 Ho w to appeal this permit

 Ho w to save money, reduce pollution and reduce energy consumption

 Ho w to give us feedback on your permitting experience

 Ho w to get an electronic copy of your permit
Ho w 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 t o 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. T he appeal must be filed with the Commission within thirty (30) days after notice of the Direc tor ' s action. T he 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 b y affidavit you demonstrate that payment of the full amount of the fee would caus e ex treme hardship. N otice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General ' s Office, Environmental Enfo rcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 77 South High Street, 17th Floor Columbus, OH 43215 Certified Mail

Yes TOXIC REVIEW Yes PSD Yes SYNTHETIC MINOR TO AVOID MAJOR NSR Yes CEMS No MACT /GACT Yes NSPS No NESHAPS No NETTING No MAJOR NON

- ATTAINMENT Yes MODELING SUBMITTED Yes M AJOR GHG No SYNTHETIC MINOR TO AVOID MAJOR GHGHo w to save money, reduce pollution and red uce energy consumption
The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. N ot only will this reduce pollution and energy consumption, but it can also save you money. I f 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 u nder 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
Ho w 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.
Ho w to get an electronic copy of your permit
This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or in Adobe PDF on the Division of Air Pollution Control (DAPC) We b page, www.epa.ohio.gov/dapc by clickin g the " Search for Permits " link under the Permitting topic on the Programs tab.
If you have any questions, please contact Toledo Department of Environmental Services at (419)936

- 3015 or the Office of Compliance Assistance and Pollution Prevention at (61 4) 644

- 3469. Sincerely,

Erica R. Engel

- Ishida , Interim Manager Permit Issuance and Data Management Section , DAPC
Cc: U.S. EPA TDES; Michigan; Indiana; CanadaResponse to Comments Oregon Clean Energy Center Permit Number: P0117413 Facility ID: 0448020102 

# Response to Comments
Facility ID: 0448020102 Facility Name: Oregon Clean Energy Center Facility Description: Electric power generating plant Facility Address: 816 Lallendorf Rd Oregon, OH 43616 Lucas County Permit: P0117413, Permit

- To

- Install

- Administrative Modification A public notice for the draft permit issuance was published in the Ohio EPA We ekly Review and appeared in the Toledo Blade on 08/27/2014. The comment period ended on 09/26/2014. Hearing date (if held) Hearing Public Notice Date (if different from draft public notice)

The following comments were received during the comment period specified. O hio EPA reviewed and considered all comments received during the public comment period. By law, Ohio EPA has authority to consider specific issues related to protection of the environment and public health. Often, public concerns fall o utside the scope of that authority. For example, concerns about zoning issues are addressed at the local level. Ohio EPA may respond to those concerns in this document by identifying another government agency with more direct authority over the issue.
In an effort to help you review this document, the questions are grouped by topic and organized in a consistent format. PDF copies of the original comments in the format submitted are available upon request.
1. Topic: There were no comments received.

a. Comment: None
b. Response: None

# FINA L

Division of A ir Pollution Control Permit - to - Install f or Oregon Clean Energy Center

Facility ID: 0448020102 Permit Number: P0117413 Permit Type: Adm inistrative Modification Issued: 9/30/2014 Effective: 9/30/2014

### Division of Air Pollution Control Permit - to - Install for Oregon Clean Energy Center
Table of Contents
Authorization

................................ ................................ ................................ ................................ ..................... 1 A. Standard Terms an d 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. Bes t 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 Op erating Parameter Limitations

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

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

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

................................ ................................ ................................ ...................... 10 19. Ti tle IV Provisions

................................ ................................ ................................ ................................ 10 B. Facility

- Wide Terms and Conditions

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

................................ ................................ ................................ ....... 13 1. B001, Auxiliary Boiler

................................ ................................ ................................ ........................... 14 2. P005, Wet Cooling Tower

................................ ................................ ................................ .................... 24 3. Emissions Unit Group

- P001, P002: P001,P002,

................................ ................................ ................ 28Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 1 of 55 

# Au thorization
Facility ID: 0448020102 Facility Description: Electric power generating plant Application Number(s): M0002922 Permit Number: P0117413 Permit Description: Administrative modification to revise emissions limitations based on updated information fr

om the turbine manufacturer and to revise the projected operating scenario for a natural gas

- fired combined cycle combustion turbine power plant. Permit Type: Administrative Modification Permit Fee: $2,300.00 Issue Date: 9/30/2014 Effective Date: 9/30 /2014
This document constitutes issuance to : Oregon Clean Energy Center 816 Lallendorf Rd Oregon, OH 43616

o f 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: Toledo Department of Environmental Services 348 South Erie Street Toledo, OH 43604 (419)936

- 3015
The above named entity is hereby granted a Permit

- to

- Install f or 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 plan s 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 c onstructed or modified in ac cordance 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 DirectorFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 2 of 55 

# Au thorization (continued)

Permit Number: P0117413 Permit Description: Administrative modification to revise emissions limitations based on updated information

fr om the turbine manufacturer and to revise the projected operating scenario for a natural gas

- fired combined cycle combustion turbine power plant.
Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below :
Emissions Unit ID : B001 Com pany Equipment ID : Auxiliary Boiler Superseded Permit Number : P0110840 General Permit Category and Type : Not Applicable Emissions Unit ID : P005 Com pany Equipment ID : We t Cooling Tower Superseded Permit Number : P0110840 General Permit Category and Type : Not Applicable Group Name: P001, P002 Emissions Unit ID: P001 Com pany Equipment ID: CTG #1 Superseded Permit Number: P0110840 General Permit Category and Type: Not Applicable Emissions Unit ID: P002 Com pany Equipment ID: CTG #2 Superseded Permit Number: P0110840 General Permit Category and Type: Not ApplicableFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 3 of 55 

# A. Standard Terms and ConditionsFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 4 of 55 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 Authoriza tion to Install (7) Standard Term and Condition A. 14., Public Disclosure (8) Standard Term and Condition A. 15., Additional Reporting Requirements Wh en There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Devic e 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

t hey 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 Administrat or 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 i f 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.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 5 of 55 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. T he filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned ch anges or anticipated noncompliance does not stay any term and condition of this permit. d) This permit does not convey any property rights of any sort, or any exclusive privilege. e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit. U pon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. F or information claimed to be confidential in the submittal to the Director, if t he Administr

ator of the U.S. EPA requests such inf ormation, 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 s pecific 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 o r measurements. (2) The d ate(s) analyses were performed. (3) The company or enti ty that performed the analyses. (4) The analyti cal techniques or methods used. (5) The results of such analyses. (6) The operating conditions existing at the ti me of sampling or measurement. b) Each record of any monitoring data, testing data, and support inf ormation 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 calibrat ion 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 t he terms and conditions for a s pecific emissions unit, the permittee shall submit required reports in the following manner : (1) Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Toledo Depart ment of Environmental Services.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 6 of 55 (2) Quarterly written reports of (i) any deviations from federally enforceable emissionlimitations , operationalrestrictions , andcontroldeviceoperatingparameterlimitations , excluding deviations resulting from malfunctions reporte d 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 Toledo Department of Environmental Services. 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 Toledo Department of Environmental Services every six months, by January 31 and July 31 of each year for the previous six calendar months. I f no deviations occurred during a six

- month period, the permittee shall submit a s emi

- annual report, which states that no deviations occurred during that period

. (4) T his 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 inqu iry, 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 Repo rting Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745

- 15

- 06. T he malfunction, i.e., upset, of any emissions units or any associated air pollution control system(s) shall be reported to the Toledo Department of Environmental Services in accordance with paragraph (B) of OAC rule 3745

- 15

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

- 15

- 06(B)(1) for a malfunction.) T he ver bal and writte n 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 t he 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 a n as - needed basis if t he permittee cannot submit the required documents throug h the Ohio EPA eBusiness Center

. In the event o f 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 t o be submitted to Ohio EPA fulfills the requirement to submit the required information to the Director, the appropriate Ohio EPA District Office or contractedFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 7 of 55 local air agency, and/or any other individual or organization specifically identified as an addit ional 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 do cument requiring s ignature may be represented by entry of the personal identification number (PIN) by responsible official as part of the electronic submission process or by the scanned attestation document signed by the Authorized Representative that is a ttached 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 R esponsible O fficial 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 conditio ns of this permit

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

. (3) Ins pect 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 p arameters for the purpose of assuring compliance with the permit and applicable requirements

. c) The permittee shall submit progress reports to the Toledo Department of Environmental Services concerning any schedule of compliance for meeting an applicable req uirement. Progress reports shall be submitted semiannually or more frequently if s pecified in the applicable requirement or by the Director of the Ohio EPA. P rogress 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

.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 8 of 55 8. Air Pollution Nuisance
The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in vi olation of OAC rule 3745

- 15

- 07

. 9. Reporting Requirements The permittee shall submit required r eports in the following ma nner: a) Reports of any required monitoring and/or recordkeeping of state

- only enforceable information shall be submitted to the Toledo Department of Environmental Services

. b) Except as otherwise may be provided in the terms and conditions for a s pecific emissions unit, quarterly written reports of (a) any deviations (excursions) fr om state

- only required emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and recordkeeping 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 Toledo Department of Environmental Services. If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. T he reports shall be submitted quarterly, by January 31, April 30, July 31, and October 31 o f eac h 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 emis sions 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 Sour ces(s) and A uthorization to Install a) This permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. T his permit does not constitute expressed or implied assurance that the proposed faci lity has been constructed in accordance with the application and terms and conditions of this permit. T he action of beginning and/or completing construction prior to obtaining the Director ' s approval constitutes a violation of OAC rule 3745

- 31

- 02. Furthe rmore, issuance of this permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. I ssuance of this permit is not to be construed as a waiver of any rights that the Ohio Environmental Pr otection Agency (or other persons) may have against the applicant for starting construction prior to the effective date of the permit. A dditional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if

t he proposed facilit ies 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 ow ner 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. T his deadline may be extended by up t o 12 months if a pplication is made to theFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 9 of 55 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 ce rtified 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 p ermit 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 o perate without a subsequent " modification " or " installation " as defined in OAC Chapter 3745

- 31). A ll records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with la w. A ll 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 per mit covering the last period the emissions unit operated.
Unless otherwise exempted, n o emissions unit certified by the responsible official as being permanently shut down may resume operation without first applying for and obtaining a permit pursuant to OAC Chapter 3745

- 31 and OAC Chapter 3745

- 77 if t he restarted operation is subject to one or more applicable requirements

. e) The permit tee 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 we re 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 A pplication
The permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745

- 77. T he 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 before operating the source in a manner that would violate the existing Title V permit requirements

.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 10 of 55 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) Com mence 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 concernin g 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 Ar e No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Co ntrol 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. T he reports shall be submitted quarterly by Janu ary 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. T he permittee shall pa y 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 pe rmit 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 am ended, 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

.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 11 of 55 

# B. Facility - Wide Terms and ConditionsFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 12 of 55 1. All t he following facility

- wide terms and conditions are federally enfo rceable with the exception of t hose 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 Dc: B001. T he 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 unit contained in this permit is subject to 40 CFR Part 6 0 Subpart A and KKKK : P001 and P002

. The complete NSPS requirements, including the NSPS General Provis ions 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.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 13 of 55 

# C

. Emissions Unit Terms and ConditionsFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 14 of 55 1. B001 , Au xiliary Boiler Operations, Property and/or Equipment Description: 99 mmBtu/hr natural gas fired boiler with low

- NOx burners and flue gas re

- circulation a) The following emissions unit terms and conditions are federally enfor ceable 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 w ith 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 i n 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 Sulfur dioxide (SO 2 ) emissions shall not exceed 1.5E

- 03 pound per million Btu (lb/ mmBtu) of heat input. see b)(2)a. and b)(2)b. b. OAC rule 3745

- 31

- 05(A)(3)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rule 3745

- 31

- 10 through 20 Carbon monoxide (CO) emissions shall not exceed 0.055 pound per million Btu (lb/mmBtu) of heat input, 5.45 pounds per hour (lbs/hr), and 5.45 tons per rolling, 12

- month period. Nitrogen Oxides (NO x ) emissions shall not exceed 0.020 lb/mmBtu of heat input, 1.98 lbs/hr, and 1.98 tons per rolling, 12

- month period.
Particulate matter emissions less th an 10 microns in diameter (PM 10 ) and particulate matter less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 0.008 lb/mmBtu of heat input, 0.79 lb/hr, and 0.79 ton per rolling, 12

- month period. Volatile organic compound (VOC) emissions shall not exceed 0.006 lb/mmBtu of heat input, 0.59 lb/hr and 0.59 ton per rolling, 12

- month period.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 15 of 55 Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures Sulfuric acid mist (H 2 SO 4 ) emissions shall not exceed 1.1E

- 04 lb/mmBtu, 0.011 lb/hr, and 0.011 ton per rolling, 12

- month period. Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 11,671 tons per rolling, 12

- month period. Visible particulate emissions from the stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. see b)(2)d., b)(2)e. d. OAC rule 3745

- 31

- 05(D) SO 2 emissions shall not exceed 0.15 ton per rolling, 12

- month period. see b)(2)k. e. OAC rule 3745

- 17

- 07(A) see b)(2)f. f. OAC rule 3745

- 17

- 10(B)(1) see b)(2)f. g. OAC rule 3745

- 110

- 03(J)(16) exemption

- see b)(2)l. h. 40 CFR Part 60, Subpart A (40 CFR 60.1

– 40 CFR 60.19) see b)(2)g.
i. 40 CFR Part 60, Subpart Dc (40 CFR 60.40c

– 40 CFR 60.48c) see b)(2)h. and b)(2)i. j. 40 CFR Part 63, Subpart JJJJJJ (40 CFR 63.11193

– 63.11236) see b)(2)j.

(2) Additional Terms and Conditions

a. Compliance with the requirements of this rule for CO, NOx, PM 10 /PM 2.5 , and VOC emissions includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.
b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745

- 31

- 05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745

- 31

- 05 was revised to conform to the Ohio Revised Code (ORC) ch anges 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. H owever, that rule revision has not yet been ap proved 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 satisfyFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 16 of 55 BAT still exists as part of the federally

- appro ved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05, then these emission limitations/control measures no longer apply

.
c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 374 5

- 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, NO x , PM 10 /PM 2.5 , SO 2 , and VOC emissions from this air contaminant source since the uncontrolled potential to emit for CO, NO x , PM 10 /PM 2.5 , SO 2 , and VOC is less than 10 tons per year .
d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10 /PM 2 .5 emissions limitations include both filterable and condensable particulate emissions.

e. The lb/mmBtu and lb/hr, emission limitations are based on the emissions unit's potentials to emit. T herefore, 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

- 10 through 20.
g. 4 0 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. This rule does not establish emission limitations for natural gas - fired boilers, but does require recordkeeping of gas usage per 40 CFR 60.48c(g).
i. This emissions unit is subject to the applicable provisions of Subpart Dc of the New Source Performance Standards (NSPS) as promulgated by the United States Environmental Protection A gency, 40 CFR Part 60. The application and enforcement of th ese standards are delegated to the Ohio EPA. T he 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 tocombusting only natural gas

. k. The maximum annual o perating hours for this emissions unit shall not exceed 2,000 hours per rolling, 12

- monthperiod

. 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:Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 17 of 55 Maximum Allowable Month(s) Cumulative Operating Hours 1 720 1

- 2 1,440 1

- 3 2,000 1

- 4 2,000 1

- 5 2,000 1

- 6 2,000 1

- 7 2,000 1

- 8 2,000 1

- 9 2,000 1

- 10 2,000 1

- 11 2,000 1

- 12 2,000
After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual operating hours limitation shall be based upon a rolling, 12

- month summation of the operating hours.
l. The permittee is exempt fr om the requirements of OAC rule 3745

- 110

- 03(A) through (F), since this permit restricts NOx emissions from this emissions unit to less than 25 tons per year. c) Operational Restrictions (1) The permitte e 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. (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 thi s 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 ea ch calendar month. (3) See 40 CFR Part 60, Subpart Dc (40 CFR 60.40c

- 48c).Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 18 of 55 e) Reporting Requirements (1) The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas was burned in this emissions unit. E ach report shall be submitted within 30 days after the deviation occurs. (2) Pursuant to the 40 CFR Part 60.7 and 60.48c(a) , the permittee is hereby advised of the requirement to report the following at the appropriate times:

a. c onstruction date (no later than 30 da ys after such date);
b. a nticipated start

- up date (not more than 60 days or less than 30 days prior to such date);

c. a ctual start

- up date (within 15 days after such date); and
d. the design heat input capacity of the affected facility and identification of fuels t o be combusted in the affected facility. (3) The permittee shall submit quarterly deviation (excursion) reports that identify the following:
all exceedances of the rolling, 12

- month limitation on the hours of operation for this emissions unit ; and for the firs t 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 ; The quarterly deviation (excursion) report s shall be submitted in accordance wi th the reporting requirements of the Standard Terms and Conditions of this permit. (4) See 40 CFR Part 60, Subpart Dc (40 CFR 60.40c

- 48c). (5) Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through th e 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 follo wing methods:

a. Emission Limitation: CO emissions shall not exceed 0.055 lb/mmBtu of heat input, 5.45 lbs/hr, and 5.45 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu emission limitation is based on manufacturer’s data. T he hou rly emission limitation was developed by multiplying the maximum heat input (99Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 19 of 55 mmBtu/hr) by the CO emission factor supplied by the manufacturer (0.055 lb/mmBtu) to determine the hourly emissions. The annual emission limitation was developed by multiplying the hourly emission limitation (5.45 lbs/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is sho wn. b. Emission Limitation: NO x emissions shall not exceed 0.020 lb/mmBtu of heat input, 1.98 lbs/hr, and 1.98 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is based on manufacturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the NO x emission factor supplied by the manufacturer (0.020 lb/mmBtu) to determine the hourly emissions.
The a nnual emission limitation was developed by multiplying the hourly emission limitation (1.98 lbs/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demons trated if compliance with the hourly limitation is shown.

c. Emission Limitation:
PM 10 and PM 2.5 shall not exceed 0.008 lb/mmBtu of heat input, 0.79 lb/hr, and 0.79 ton per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is bas ed on manufacturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the PM 10 /PM 2.5 emission factor supplied by the manufacturer (0.008 lb/mmBtu) to determine the hourly emissions.
If required, the permittee shall demonstrate compliance with the lb/mmBtu 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 O hio EPA. The annual emission limitation was developed by multiplying the hourly emission limitation (0.79 lb/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation sh all be demonstrated if compliance with the hourly limitation is shown.
d. Emission Limitation: SO 2 emissions shall not exceed 1.5E

- 03 lb/mmBtu of heat input and 0.15 ton per rolling, 12

- month period.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 20 of 55 Applicable Compliance Method:
The lb/mmBtu limitation was e stablished 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. M ultiply the maximum sulfur content of natural gas (0.5 grain S/100 scf) by the molecular weigh t of SO 2 (64.07 lb SO 2 /lb

- mole) divide by the molecular weight of sulfur (32.06 lb S/lb

- mole) divide by (7,000 grains/lb), divide by manufacturer’s gas specification (983 Btu/scf), and multiply by (10 6 Btu/mmBtu).
If required, the permittee shall demonstra te compliance with the lb/mmBtu and 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.
The annual emission limitation was de veloped by multiplying the lb/mmBtu emission limitation (1.5E

- 03 lb/mmBtu) by the maximum heat input (99 mmBtu/hr), multiplied by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if compliance with the hourly limitation is shown.

e. Emission Limitation: VOC emissions shall not exceed 0.006 lb/mmBtu of heat input, 0.59 lb/hr, and 0.59 ton per rolling, 12

- month period. Applicable Compliance Method:
The lb/mmBtu limitation is based on manufacturer’s data. T he hourly emission limitation was developed by multiplying the maximum heat input (99 mmBtu/hr) by the VOC emission factor supplied by the manufacturer (0.006 lb/mmBtu) to determine the hourly emission s. 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 res ults 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. 59 lb/hr) by the maximum annual operating hours (2,000 hrs/yr) and dividing by 2,000 pounds per ton. T herefore, compliance with the annual limitation shall be demonstrated if c ompliance with the hourly limitation is maintained.
f. Emission Limitation: Sulfur ic acid mist (H 2 SO 4 ) emissions shall not exceed 1.1E

- 04 lb/mmBtu, 0.011 lb/hr, and 0.011 ton per rolling, 12

- month period.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 21 of 55 Applicable Compliance Method: The lb/mmBtu emission limitation is based on the assumption that 5% of the SO 2 emissions are converted to SO 3 and then converted to H 2 SO 4 when combined with water vapor by the following calculation.
1.5E

- 03 lb SO 2 /mmBtu(0.05)(98 lb H 2 SO 4 /lb

- mole)(lb

- mole/64 lb SO 2 ) = 1.1E

- 04 lb H 2 SO 4 /mmBtu Multiply the lb H 2 SO 4 /mmBtu (1.1E

- 04 lb/mmBtu) by the maximum heat i nput (99 mmBtu/hr) to determine the maximum hourly H 2 SO 4 emissions (0.011 lb/hr), and multiply by the maximum annual hours of operation (2,000 hrs/yr) divided by 2,000 lbs/ton to determine the annual H 2 SO 4 emissions (0.011 ton/yr).
If required, the permitt ee shall demonstrate compliance with the lb/mmBtu and lb/hr emissions limitations using Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A.
g. Emission Limitation: Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 11,671 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation was established to ref lect the potential to emit for this emissions unit by calculating the sum of the product of the maximum natural gas usage (0.104 mmscf/hr) multiplied by the AP

- 42 emissi on factor for CO 2 , N 2 O, and CH 4 from Table 1.4

- 2 dated 7/98 (120,000 lb/mmscf, 0.64 lb/mmscf, and 2.3 lb/mmscf, respectively), multiplied by the global warming potential for CO 2 , N 2 O, and CH 4 (1, 298, and 25, respectively from Table A

- 1 to Subpart A of 40 CFR 98). M ultiply the calculated sum by the natural gas heating value used in the application for this emissions unit (950 Btu/scf), divide by the average heating value used for AP

- 42 emission factors in Table 1.

- 42 dated 7/98 (1,020 Btu/scf), multiply by the maximum annual hours of operation (2,000 hrs/yr) and divide by 2,000 pounds per ton.

99 h 120 , 000 ( 1 ) + ( 0

. 64 ) ( 298 )

+ 2

. 3 ( 25 ) 1020 2 , 000 h h 2 , 000

= 11 , 671

Since the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the lb/scf CO 2 emission rate does not exceed 120,000 lb/mmscf.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 22 of 55 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 CO 2 emission rate.
h. Emission Limitation: Visible emissions shall not exceed 10% opacity as a 6

- minute average, exce pt as provided by rule. Applicable Compliance Method: If required, c ompliance 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, Append ix 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 em issions 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 following emissions limitations:
i. CO emissions in lb/hr and lb/mmBtu; and
ii. NO x emissions in lb/hr and lb/mmBtu. The emission testing shall also be conducted to determine the CO 2 emission rate in lb/hr and lb/mmBtu.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for C O, Methods 1 thru 4 of 40 CFR Part 60, Appendix A; and
forNO x , 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 fr om 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 appro priate 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 circumstanc es where a lower emissions loading is deemed the most challenging control scenario. F ailure to test under theseFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 23 of 55 conditions is justification for not accepting the test results as a demonstration of compliance.

e. Not later than 30 days prior to the proposed t est date(s), the permittee shall submit an "Intent to Test" notification to the appropriate Ohio EPA District Office or local air agency. T he "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the emissions un it 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 a ir 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 necess ary 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 th e 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). T he permittee may request additional t ime 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.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 24 of 55 2. P005 , Wet Cooling Tower Operations, Property and/or Equipment Descripti on: 11 cell mechanical draft wet cooling tower with high efficiency drift eliminator 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) Ap plicable 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 co ntrol 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)(a)(ii), as effective 12/01/2006 see b)(2)c.

c. OAC rules 3745

- 10 through 20 (Prevention of Significant Deterioration of Air Quality) Particulate matter emissions less than 10 microns in diameter (PM 10 ) shall not exceed 1.03 pounds per hour and 4.5 tons per rolling, 12

- month period.
Particulate matter emissions less than 2.5 microns in diameter (PM 2.5 ) shall not exceed 3.4E

- 03 pound per hour and 0.015 ton per rolling, 12

- month period. The permittee shall install a drift eliminator with a maximum drift rate of 0.0005% on this emissions unit. Visible particulate emissions shall not exceed 10% opacity as a 6

- minute averag e. The presence of condensed water vapor shall not be deemed a violation for failure of stack emissions meeting this visible emission limitation. see c)(1) d. OAC rule 3745

- 17

- 07(A)(1) see b)(2)d. e. OAC rule 3745

- 17

- 11(B) see b)(2)d.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 25 of 55 (2) Additional Terms and Conditions

a. The requirements of this rule include compliance with the requirements of OAC rule 3745

- 10 through 20.
b. The permittee has satisfied the Best Available Technology (BAT) requirements pursuant to Ohio Administrative Code (OAC) paragraph 3745

- 31

- 05(A)(3), as effective November 30, 2001, in this permit. O n December 1, 2006, paragraph (A)(3) of OAC rule 3745

- 31

- 05 was revised to conform to the Ohio Revised Code (ORC) changes effective August 3, 2006 (Senate Bill 265 changes), such that BAT is no l onger required by State regulations for National Ambient Air Quality Standards (NAAQS) pollutant(s) less than ten tons per year. H owever, that rule revision has not yet been approved by U.S. EPA as a revision to Ohio’s State Implementation Plan (SIP). Th erefore, until the SIP revision occurs and the U.S. EPA approves the revisions to OAC rule 3745

- 31

- 05, the requirement to satisfy BAT still exists as part of the federally

- approved SIP for Ohio. O nce U.S. EPA approves the December 1, 2006 version of OAC r ule 3745

- 31

- 05, then these emission limitations/control measures no longer apply

.
c. This rule paragraph applies once U.S. EPA approves the December 1, 2006 version of OAC rule 3745

- 31

- 05 as part of the State Implementation Plan.
The Best Available Technology (BAT) requirements under OAC rule 3745

- 31

- 05(A)(3) do not apply to the PM 10 and PM 2.5 emissions from this air contaminant source since the calculated annual emission rate for PM 10 and PM 2.5 is less than 10 tons per year taking into account the federally e nforceable rule limit of 0.0005% drift and a maximum TDS concentration of 2,030.5 mg/l under OAC rule 3745

- 31

- 10 through 20.
d. The emission limitation specified by this rule is less stringent than the emission limitation established by OAC rule 3745

- 31

- 10 th rough 20. c) Operational Restrictions (1) The permittee shall maintain the total dissolved solids (TDS) concentration of the cooling water less than or equal to 2, 030.5 milligrams per liter. d) Monitoring and/or Recordkeeping Requirements (1) The permittee shall properl y install, operate, and maintain a conductivity meter or other equipment to continuously monitor and record the TDS concentration of the cooling tower water. T he monitoring devices shall be installed, calibrated, operated, and maintained in accordance wit h the manufacturer’s recommendations, instructions, and operating manuals. (2) Since the TDS data measured by the conductivity meter or other equipment is based on a correlation between conductivity and TDS, an exceedance measured by the conductivity meter or equivalent 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.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 26 of 55 e) Reporting Requirements (1) The permittee shall submit quarterly deviation (excur sion) reports that identify all hourly TDS readings in excess of 2030.5 mg/l. The reports shall identify corrective action taken to reduce the TDS concentration.
The quarterly deviation (excursion) report s shall be submitted in accordance with the reporti ng 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:
PM 10 emissions shall not exceed 1.03 lbs/hr and 4.5 tons per rolling, 12

- month period. Applicable Compliance Method:
The lb/hr PM 10 emission limitation is based on multiplying the maximum re circulating water flow rate (322,000 gal/min) by the maximum TDS concentration (2030.5/1E06) multiplied by the decimal fracti on drift rate (0.000005) multiplied by the density of water (8.34 lbs/gal) multiplied by (60 min/hr) and multiplied by the decimal fraction of PM 10 contained in the TDS (0.63). T he permittee calculated the PM 10 fraction using AW MA Abstract No. 216, Sessio n No. AM

- 1b, Orlando, 2001.
The annual emission limitation is based on multiplying the hourly emission limitation (1.03 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 e missions limitation will be assumed provided that the TDS concentration recorded in d) remains below 2030.5 mg/l.
b. Emission Limitation:
PM 2.5 emissions shall not exceed 3.4E

- 03 lb/hr and 0.015 ton/yr
The lb/hrPM 2.5 emission limitation is based on multiplyi ng the maximum re circulating water flow rate (322,000 gal/min) by the maximum TDS concentrationFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 27 of 55 (2030.5/1E06) multiplied by the decimal fraction drift rate (0.000005) multiplied by the density of water (8.34 lbs/gal) multiplied by (60 min/hr) and multipli ed by the decimal fraction of PM 2

. 5 contained in the TDS (0.0021). T he permittee calculated the PM 2.5 fraction using AW MA Abstract No. 216, Session No. AM

- 1b, Orlando, 2001.
The annual emission limitation is based on multiplying the hourly emission limita tion (3.4E

- 03 lb/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 2030.5 mg/l.

c. Emission Limitation: The maximum drift rate shall not exceed 0.0005%. Applicable Compliance Method: Manufacturer's emissions data shall be used to demonstrate compliance with this limitation.
Wi thin 90 days of startup, the permittee shall submit to the Toledo Division of Environmental Services 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.
d. Emission Limitation:
The pe rmittee shall maintain the TDS concentration of the cooling water less than or equal to 2,030.5 milligrams per liter. Applicable Compliance Method: The monitoring and recordkeeping requirements under d)(1) and d)(2) shall serve as demonstration of complian ce. 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 Oh io EPA. g) Miscellaneous Requirements (1) None.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 28 of 55 3. Emissions Unit Group - P001, P002 : P001 , P002 , EU ID Operations, Property and/or Equipment Description P001 Siemens SCC6

- 8000H combined cycle combustion turbine (2,936 mmBtu/hr heat input

turbine and 300 mmBtu/hr heat input duct burner) with dry low NOx combustors, selective catalytic reduction (SCR), and catalytic oxidizer. P002 Siemens SCC6

- 8000H combined cycle combustion turbine (2,936 mmBtu/hr heat input

turbine and 300 mmBtu/hr heat input duct burner) with d ry low NOx combustors, selective catalytic reduction (SCR), and catalytic oxidizer.

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)(12) through d)(15) and e)(6). 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 emi ssions 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 App licable Emissions Limitations/Control Measures a. ORC 3704.03(T) Sulfur dioxide (SO 2 ) emissions shall not exceed 1.5E

- 03 lb/mmBtu of heat input. see b)(2)b. b. OAC rule 3745

- 31

- 05(D) The combined SO 2 emissions from P001 and P002 shall not exceed 37.6 tons per rolling, 12

- month period. see b)(2)e. and f. c. OAC rule 3745

- 31

- 10 through 20 Visible particulate emissions from the stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. Carbon dioxide equivalent (CO 2 e) emissions shall not exceed 833 lb/M W

- hr gross energy output and 371,029 lbs/hr. see b)(2)c., b)(2)d., b)(2)g. through b)(2)j., and b)(2)r. through t. d. OAC rule 3745

- 17

- 07(A) see b)(2)k. e OAC rule 3745

- 17

- 11(B)(4) see b)(2)k. f. OAC rule 3745

- 18

- 06(A) see b)(2)m.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 29 of 55 Applicable Rules/Requirements App licable Emissions Limitations/Control Measures g. OAC rule 3745

- 110

- 03(J)(19) Exemption from NOx RACT requirements h. OAC rule 3745

- 114 see d)(12) through d)(15) i. 40 CFR Part 60, Subpart A (40 CFR 60.1

– 40 CFR 60.19) see b)(2)n. 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 bur ners subject to the emissions limitations/control measures specified in this section.] see b)(2)l. and b)(2)o.

k. 40 CFR Part 63, Subpart YYYY (40 CFR 63.6080

– 63.6175) see b)(2)p.
l. 40 CFR Part 63, Subpart JJJJJJ (40 CFR 63.11193

– 63.11236) see b)(2)q.

(2) Additional Terms and Conditions

a. All requirements specified for in this Section of the permit for Emissions Unit Group P001 and P002 apply to each combined cycle combustion turbine (P001 and P002) unless a combined requirement is otherwise specified.
b. Compliance with the requirements of this rule for CO, NO x , PM 10 , PM 2.5 , and VOC includes compliance with the requirements of OAC rule 3745

- 31

- 10 through 20.

c. The emissions from this emissions unit shall be vented to the SCR and catalytic oxidati on units at all times during which the emissions unit is in operation.
d. All particulate emissions are assumed to be less than 2.5 microns in diameter. The PM 10 /PM 2.5 emissions limitations include both filterable and condensable particulate emissions.

e. The s ulfur content of natural gas burned in this emissions unit shall not exceed 0.5 grains per 100 standard cubic feet.
f. The combined natural gas usage by emissions units P001 and P002 shall not exceed 48,484 mmscf per rolling, 12

- month period. To ensure enfo rceability 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 natural gas usage levels specified in the following table:Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 30 of 55 Maximum Allowable Cumulative N atural Gas Usage by P001 and P002 combined (Million Standard Cubic Feet) Month(s) mmscf
1 8,081
1

- 2 16,161
1

- 3 24,242
1

- 4 32,323
1

- 5 40,403
1

- 6 48,484
1

- 7 48,484
1

- 8 48,484
1

- 9 48,484
1

- 10 48,484
1

- 11 48,484
1

- 12 48,484

After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual natural gas usage limitation shall be based upon a rolling, 12

- month summation of the monthly natural gas usag e

. g. The permittee shall comply with the following emissions limitations:
Allowable Emissions
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period
CO CT with DB 2.0 c 14.4

-

CT only 2.0 c 13.0

-Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 31 of 55

Allowable Emissions
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period All operating modes, including startup periods
- - 91.3
NOx CT with DB 2.0 c 23.6

-

CT only 2.0 c 22.0

- All operating modes, including startup periods 92.0
PM 10 /PM 2.5 CT with DB 5.5E

- 03 d 15.1

-

CT only 5.4E

- 03 d 13.3

- All operating modes, including startup periods
- - 61.3
VOC CT With DB 1.9 c 5.9

-

CT only 1.0 c 3.9

- All operating modes, including startup periods
- - 38.5
H 2 SO 4 CT with DB 7.0E

- 04 d 1.5

-

CT only 6.0E

- 04 d 1.6

- All operating modes, including startup periods
- - 6.6
CO 2 e All operating

modes, including startup periods
- - 1,477,071

a. CT = combustion turbine DB = duct burner b. Limitation does not apply during periods of startup and shutdown. c. Parts per million by volume dry (ppmvd) at 15% oxygenFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 32 of 55

Allowable Emissions
Pollutant Operating

Mode a Emission

Rate b,e Emission

rate, lb/hr b Emission rate,

tons per rolling, 12 - month period d. Pound per million Btu of heat input e. Emissions limitations are based on an hourly average.

h. 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 PM10/PM2.5 VOC H 2 SO 4 1 15.2 15.3 10.2 6.4 1.10
1

- 2 30.4 30.7 20.4 12.8 2.19
1

- 3 45.6 46.0 30.7 19.2 3.29
1

- 4 60.8 61.3 40.9 25.7 4.3
1

- 5 76.1 76.7 51.1 32.1 5.48
1

- 6 91.3 92.0 61.3 38.5 6.57
1

- 7 91.3 92.0 61.3 38.5 6.57
1

- 8 91.3 92.0 61.3 38.5 6.57
1

- 9 91.3 92.0 61.3 38.5 6.57
1

- 10 91.3 92.0 61.3 38.5 6.57
1

- 11 91.3 92.0 61.3 38.5 6.57
1

- 12 91.3 92.0 61.3 38.5 6.57

After the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, compliance with the annual emission s limitation s shall be based upon a rolling, 12

- month summation of the monthly emissions.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 33 of 55 i. The permittee shall comply with the following requirements during periods of startup and shutdown.
Em issions LimitationsDuring Startupand Shutdown ( lbs/hr ) a
Cold Startup Hot

Startup Warm

Startup Shutdown

CO 546 289 351 113
NOx 188 105 129 46 VOC 168 114 138 45

a Pound per hour emissions rates as presented are the maximum rates during any hour during the event from each unit.

“Cold Startup” is defined as a combustion turbine startup that occurs more than 64 hours after a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 180 minutes of continuous fuel flow to the combustion turbine after fuel flow is initiated or the period of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . “Hot Startup” is defined as a combustion turbine startup that occurs within 16 hours of a combustion turbine shutdown. T he period of hot startup is defined as the lesser of the first 82 minutes of continuous fuel flow to the combustion turbine after fuel fl ow is initiated or the pe riod of time fr om combustion turbine fuel flow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . “W arm Startup” is defined as a combustion turbine startup tha t occurs between 16 hours of and 64 hours of a combustion turbine shutdown. T he period of startup is defined as the lesser of the first 98 minutes of continuous fuel fl ow to the combustion turbine after fuel fl ow is initiated or the period of time fr om co mbustion turbine fuel fl ow initiation until the combustion turbine achieves ten consecutive CEM data points in compliance with the ppmvd emissions limitations for CO and NO x . j. The design net plant base heat rate shall not exceed 7,227 Btu/k W

- hr HHV (ISO con ditions without duct firing).
k. The emission limitation specified by this rule is less stringent than the limitation established by OAC rule 3745

- 31

- 10 through 20.
l. The emission limitation specified by this rule is less stringent than the limitation establish ed by ORC 3704.03(T).Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 34 of 55 m. This emissions unit is exempt from the requirements of this rule, since only natural gas is burned.

n. 4 0 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.

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 A gency, 40 CFR Part 60. The applicati on and enforcement of these standards are delegated to the Ohio EPA. T he 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 ma jor source of HAP emissions.
q. The duct burner is exempt from the requirements of this rule per 40 CFR 63.11195(e) due tocombusting only natural gas

.
r. Each continuous NOx monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendi x B, Performance Specifications 2 and 6. A t 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 cont inuous valid and representative readings of NOx emissions from the continuous monitor(s), in units of the applicable standard(s). E xcept 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 l ogbook 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 NO x 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, Appen dix B, in lieu of frequencies required in 40 CFR Part 60. In either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60. The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or relative a ccuracy audits required per 40 CFR Part 60.

s. Each continuous carbon monoxide (CO) monitoring system shall be certified to meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 4 or 4a and 6. A t least 45 days before commencing cert if ication testing of the continuous CO monitoring system(s), the permittee shall develop and maintain a written quality assurance/quality control plan designed to ensureFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 35 of 55 continuous valid and representative readings of CO emissions from the continuous monit or(s), in units of the applicable standard(s). T he 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. T he quality assurance/quali ty 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. I n either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60. The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits as required in 40 CFR Part 60; however, the quarterly cylinder gas audit and relative accuracy audit fr equency requirements may be adjusted to coincide with linearity checks completed for continuous emissions monitoring systems subject to 40 CFR Part 75, Appendix B requirements.
t. The continuous emis sion 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 softwa re

. 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). 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. (2) For purposes of demonstrating compliance with the natural gas sulfur concentration restriction of 0.5 grain /scf, the permittee shall sample and analyze the natural gas burned in this emissions unit monthly to determine the sulfur content using the appropriate ASTM or Gas Processors Association standards. Fuel supplier data may be used to comply with this requi rement, provided that it is demonstrated to be representative of the fuel received for burning at this emissions unit. (3) The permittee may elect not to monitor the total sulfur content of the fuel combusted in the turbine as specified in d)(2) , if the fuel i s demonstrated not to exceed potential sulfur emissions of 1.5E

- 03 lb SO 2 /mm Btu

. T he permittee shall use one of the following sources of information to make the required demonstration:Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 36 of 55 a. t he 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, has potential sulfur emissions of l ess than less than 1.5E

- 03 lb SO 2 / mm Btu heat input ; b. r epresentative fuel sampling data which show that the sulfur content of the fuel does not exceed 1.5E

- 03 lb SO 2 / mm Btu 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 1.5E

- 03 lb SO 2 /mmBtu standard. (4) The permittee shall maintain monthl y records of the following information:

a. the natural g as usage by P001 and P002 for each month;
b. the combined natural gas usage by P001 and P002 for each month ; and

c. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12

- m onth summation of the combined natural gas usage by P001 and P002

. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative combined natural gas usage by P001 and P002 for each calendar month. (5) The permittee shall maintain monthly records of the following information:

a. the CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emission rate for each month of operations ; and
b. beginning after the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the rolling, 12

- month summation of the CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emissions

. Also, during the first 12 calendar months of operation or the first 12 calendar months following the issuance of this permit, the permittee shall record the cumulative CO, NOx, PM 10 /PM 2.5 , VOC, and H 2 SO 4 emissions for each calendar month. (6) 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;Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 37 of 55 e. the total duration of all hot startup periods in hours per rolling, 12

- month period;
f. the total dura tion 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; (7) Prior to the installation of the continuous NO x monitoring system, the permittee shall submit information detailing the proposed location o f the sampling site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Per formance Specification 2. T he Ohio EPA, Central Office shall approve the proposed sampling site and certify that the continuous NO x monitoring system meets th e requirements of Performance Specifications 2 and 6; and the U.S. EPA shall certify that the continuous NO x 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 l ocal air agency) upon request. (8) The permittee shall install, operate, and maintain equipment to continuously monitor and record NO x 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 NO x monitoring system including, but not limited to:

a. emissions of NO x in parts per million for e ach cycle time of the analyzer, with no resolution less than one data point per minute required ; b. emissions of NO x 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 e missions unit, continuous NO x monitoring system, and control equipment;Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 38 of 55 g. the date, time, and hours of operation of the emissions unit without the control equipment and/or the continuous NO x monitoring system;
h. malfunction of the control equipment and/or the continuous NO x 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 ha ndling system shall be used in the calculation of the pollutant concentration and/or emission rate over the appropriate averaging period. (9) 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). T he 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. O nce received, the letter(s)/document(s) of certification shall be maintained on - site and shall be made available to the Directo r (the appropriate Ohio EPA District Office or local air agency) upon request. (10) 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). T he continuo us 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 cylind er 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 emiss ions 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;Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 39 of 55 h. the date, time, and hours of operation of the emission s unit during any malfunction of the control equipment and/or the continuous CO monitoring system; as well as,
i. the reason (if known) and the corrective actions taken (if any) for each such event in (g) and (h).
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. (11) The permittee shall calculate and record the monthly CO 2 emissions from P001 and P002 using data from the continuous fl ow monitor using the procedures set forth in 40 CFR Part 75, Appendix G. F rom this data, the permittee shall calculate the CO 2 emissions from P001 and P002 per rolling, 12

- month period. (12) The Permit to Install application for these emissions units , P001 and P002 , was evaluated based on the actual materials and the design parameters of the emissions unit's(s’) exhaust system, as specified by the permittee. T he “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. T he predicted 1

- hour maximum ground

- level concentration result(s) from the approved air dispersion model, was compared to the Maximum Acceptable Ground

- Le vel 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 fr om the emissions unit(s), (as determined from the raw materials processed and/or coatings or other materials applied) has been documented from one of the following sources and in the following order of preference (TLV was and shall be used, if the chemical is listed):
i. threshold limit value (TLV) fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agent s Biological Exposure Indices”; or ii. STEL (short term exposure limit) or the ceiling value fr om the American Conference of Governmental Industrial Hygienists (ACGIH) “Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Ind ices”; 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 fr om the working population to the general public (TLV/10).Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 40 of 55 c. This standard is/was t hen adjusted to account for the duration of the exposure or the operating hours of the emissions unit(s), i.e., “ X = 24 ” hours per day and “ Y = 7 ” days per week, fr

om that of 8 hours per day and 5 days per week. T he 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: Formaldehyde TLV (mg/m3): 0.272 Maximum Hourly Emission Rate (lbs/hr): 1.6 (Siemens Case #3)
Predicted 1

- Hour Maximum Ground

- Level Concentration ( μ g/m3): 0.151 MAGLC ( μ g/m3): 6.5 The permittee, has demonstrated that emissions of formaldehyde , from emissions unit(s) P001 and P002 , is calculated to be less than eighty per cent of the maximum acceptable ground level concentration (MAGLC); any new raw material or processing agent shall not be applied without evaluating each component toxic air co ntaminant in accordance with the “Toxic Air Contaminant Statute”, ORC 3704.03(F). (13) 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 predi cted 1

- hour maximum ground

- level concentration, the permittee shall re - model the change(s) to demonstrate that the MAGLC has not been exceeded. C hanges 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 pre viously 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. p hysical changes to the emissions unit(s) or its/their exhaust parameters (e.g., increased/ decreased exhaust fl ow, changes in stack height, changes in stack diameter, etc.).
If the permittee determines that the “Toxic Air Contaminant Statute” will be satis fi ed 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. I f the change(s) meet(s) the definition of aFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 41 of 55 “modification”, the permittee shall apply for and obtain a fi nal PTI prior to the change. The Director may consider any significant departure from the operations of the em issions 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. (14) 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

- Lev el 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), initially and for each change that requires re - evaluation of the toxic air contaminant emissions; and
d. the docu mentation 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 a pplied. (15) 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

- leve l concentration. T he record shall include the date and reason(s) for the change and if the change would increase the ground

- level concentration. (16) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420). e) Reporting Requirements (1) The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas was burned in this emissions unit. E ach report shall be submitted within 30 days after the deviation occurs. (2) The permittee shall submit quarterly deviation (excursion ) reports that identify the following:

a. Any monthly record showing an exceedance of the allowable sulfur content of natural gas,0.5 grain per 100 standard cubic feet; andFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 42 of 55 b. all exceedances of the rolling, 12

- month combined natural gas usage limitation; 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 cu mulative combined natural gas usage levels.
The quarterly deviation (excursion) report s shall be su bmitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit. (3) The permittee shall comply with the following quarterly reporting requirements for the emissions unit and its continuous NO x 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 NO x emissions in excess of any applicable limit specified in this permit, 40 CFR Part 60, 40 CFR Parts 75 and 76, OAC Chapters 3745

- 1 4 and 3745

- 23, and any other applicable rules or regulations. T he 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 ad dress;
ii. the manufacturer and model number of the continuous NO x 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 NO x emissions for the calend ar quarter (tons);
vi. the total operating time (hours) of the emissions unit;
vii. the total operating time of the continuous NO x monitoring system while the emissions unit was in operation;
viii. results and date of quarterly cylinder gas audits or linearity checks;
ix. un less 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));Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 43 of 55 x. unless previously submitted, the results of any relative accuracy test audit show ing the continuous NO x 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 NO x monitoring system, emissions unit, and/or control equipment;
xii. the date, ti me, and duration of any downtime** of the continuous NO x 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 rep ort shall address the operations conducted and data obtained during the previous calendar quarter. D ata 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 limi tation(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 comply with the following quarterly reporting requirements for the emissions unit and its continuous CO monitoring syste m:

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 t he 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 applic able 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 emission s 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;Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 44 of 55 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 read ings, 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 t he relative accuracy test audit(s), including results in units of the applicable standard(s), (during appropriate quarter(s));

x. unless previously submitted, the results of any relative accuracy test audit showing the continuous CO monitor out

- of

- control and the compliant results following any corrective actions;
xi. the date, time, and duration of any/each malfunction** of the continuous CO monitoring system, emissions unit, and/or control equipment;
xii. the date, time, and duration of any downtime** of the continuo us 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. D ata 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 emissio ns 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 repor ted regardless if there is an exceedance of any applicable limit (5) 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 sys tems,Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 45 of 55 electronic quarterly reports, and any other pertinent record and/or report to the Administrator (U.S. EPA), as required by this Part. (6) 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) t o the input parameter(s); and
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. (7) See 40 CFR Part 60, Subpart KKKK (40 CFR 60.4300

– 60.4420). f) Testing Requirements (1) Compliance with t he 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: The sulfur content of natural gas burned shall not exceed 0.5 grain per standard cubic feet. Applicable Compliance Method: Compliance with the lb/mmBtu limitation will be determined by the monitoring and recordkeeping specified in 40 CFR 60.4365 or 40 CFR 60.4370.
If required, the permittee shall demonstrate complian ce using the procedures specified in 40 CFR 60.4415(a)(1). Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
b. Emission Limitation: SO 2 emissions shall not exceed 1.5E

- 03 lb/mmBtu of heat input.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 46 of 55 Applicable Compli ance Method:
The lb/mmBtu limitation 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. M ultiply the maximum sulfur content of natural gas (0 .5 grain S/100 scf) by the molecular weight of SO 2 (64.07 lb SO 2 /lb

- mole) divide by the molecular weight of sulfur (32.06 lb S/lb

- mole) divide by (7,000 grains/lb), divide by the manufacturer’s gas specification ( 983 Btu/scf) , and multiply by (10 6 Btu/mmBt u). If required, compliance shall be demonstrated according to 40 CFR 60.4415.

c. Emission Limitation:
Visible particulate emissions from any stack serving this emissions unit shall not exceed 10 percent opacity as a 6

- minute average. Applicable Compliance Me thod: 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.
d. Emission Limitation: C O emissions from this emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 13.0 lbs/hr when the duct burner is not in operation; and, 2.0 ppmvd at 15% oxygen as an hourly average and 14.4 lbs/hr when the duct burner is in operat ion. 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. If required, the permittee shall demonstrate compliance using Methods 1 thru 4 and 10 of 40 CFR Pa rt 60, Appendix A. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

e. Emission Limitation: CO emissions fr

om this emissions unit shall not exceed 546 lbs/hr during cold startup, 289 lbs/hr during hot startup, 351 lbs/hr during warm startup, and 113 lbs/hr during shutdown.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 47 of 55 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.
f. Emission Limitation: CO emissions from th is emissions unit shall not exceed 91.3 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 250 hot startups per year, with an annual average downtime preceding hot startup of 8 hours, and a hot startup duration of 98 minutes; shutdown duration of 26 minutes; ma ximum combined CO emissions of 351 pounds during each hot startup period and 113 pounds during each shutdown period; hourly CO emissions during steady state operation (Siemens Case #31 of PSD Dispersion Modeling) of 13.0 lbs/hr based on manufacturer’s data ; and steady state operating hours was determined by the following equation.

8 , 760 h

− 250 8 h + ( ) = 6,310 hours

The allowable annual emission rate was determined by the following calculation using the above information.

, . 

## = 91.3 tons /yr

Wh ere: HS = hot starts Ongoing compliance with this emissions limitation shall be based on the pounds per hour emission data fr om the CO CEMS and the actual hours of operation of this emissions unit.
g. Emission Limitation: NO x emissions from this emissions unit shall not exceed 2.0 ppmvd at 15% oxygen as an hourly average and 22.0 lbs/hr when the duct burner is not in operation; and, NO x emissions shall not exceed 2.0 p pmvd at 15% oxygen as an hourly average and 23.6 lbs/hr when the duct burner is in operation.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 48 of 55 Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. Ongoing compliance with the NO x emissions limitations shall be demons trated 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 requirement s of 40 CFR Part 60 and 40 CFR Part 75.
If required, 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. A lternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.
h. Emission Limitation: NO x emissions shall not exceed 92.0 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the NOx emissions during steady stat e operation (Siemens Case #31 of PSD Dispersion Modeling) of 21.0 lbs/hr by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefore, if compliance is shown with the short

- term allowable emission limitation , compliance shall also be shown with the annual emission limitation. Ongoing compliance with this emissions limitation shall be determined using the pounds per hour emission data from the NOx CEMS and the actual hours of operation of this emissions unit.
i. Emission Limitation: NOx emissions from this emissions unit shall not exceed 188 lbs/hr during cold startup, 105 lbs/hr during hot startup, 129 lbs/hr during warm startup, and 46 lbs/hr during shutdown. Applicable Compliance Method:
These emissions limita tions are based on manufacturer’s data. Ongoing compliance with the NO x 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. j. Emission Limitation:
PM 10 emissions and PM 2.5 emissions shall not exceed 5.4E

- 03 lb/mmBtu of heat input and 13.3 lbs/hr when the duct burner is not in operation; and, PM 10 andFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 49 of 55 PM 2.5 shall not exceed 5.5E

- 03 lb/mmBtu of heat input and 15.1 lbs/hr when the duct burner is in operation. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. I f required, the permittee shall demonstrate compliance with these emissions limitations using Methods 201A and 202 of 40 CFR Part 51, Appendix M. A lternative U.S. EPA approved test methods may be used with prior approval f rom the Ohio EPA.
k. Emission Limitation:
PM 10 and PM 2.5 emissions from this emissions unit shall not exceed 61.3 tons per rolling, 12

- month period. Applicable Compliance Method:
This emission limitation was developed by multiplying the PM 10 /PM 2.5 emissions d uring steady state operation (Siemens Case #3 of PSD Dispersion Modeling) of 15.1 lbs/hr by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefore, if compliance is shown with the short

- term allowable emi ssion limitation, compliance shall also be shown with the annual emission limitation.
l. Emission Limitation:
The combined SO 2 emissions fr om P001 and P002 shall not exceed 37.6 tons per rolling, 12

- month period. Applicable Compliance Method: Compliance with this emissions limitation shall be determined by the following calculation based on the records required by d). M ultiply the maximum sulfur content of natural gas (0.5 gr S/100 scf) by the molecular weight of SO 2 (64.07 lb/lb

- mole), divide by the molecula r weight of sulfur (32.06 lb/lb

- mole), divide by (7,000 gr/lb), multiply by the monthly natural gas usage (scf), and divide by (2,000 lbs/ton) to determine the monthly SO 2 emissions (tons). A dd the SO 2 emissions calculated for the current month to the tot al SO 2 emissions calculated for the previous 11 months to determine the tons SO 2 emissions per rolling, 12

- month period.

m. Emission Limitation: VOC emissions shall not exceed 1.0 ppmvd at 15% oxygen as an hourly average and 3.9 lbs/hr when the duct burner is not in operation; and, VOC emissions shall not exceed 1.9 ppmvd at 15% oxygen as an hourly average and 5.9 lbs/hr when the duct burner is in operation.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 50 of 55 Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. If r equi red, 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 s elected 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.

n. Emission Limitation: VOC emissions shall not exceed 38.5 tons per rolling, 12

- month period. Applicable Compliance Method:
This emissions limitation is based on the following anticipated worst case emissions: 250 hot startups per year, with an annual average downtime preceding hot startup of 8 hours, and a hot startup duration of 98 minutes; shutdown duration of 26 minutes; maximum VOC emissions of 114 pounds during each hot startup period and 45 pounds during each shutdown period; hourly VOC emissions during steady state operation (Siemens Case #31 of PSD Dispersion Modeling) of 5.9 lbs/hr based on manufacturer’s data; and steady state operating hours was determined by the following equation.

8 , 760 h

− 250 8 h + ( ) = 6,310 hours

The allowable annual emission rate was determined by the following calculatio n using the above information.

, . 

## = 38.5 tons /yr

Wh ere: HS = hot starts Ongoing compliance with this emissions limitation shall be based on the following calculation.
( # ) ( # ) ( # ) ( # ) ( # )

. ( # )

.

= VOCFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 51 of 55 Wh ere: VOC = tons VOC emissions per rolling, 12

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

- month perio d #HS = number of hot startups per rolling, 12

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

- month period #SD = number of shutdowns per rolling, 12

- month period #SSDB = hours operated in steady state with duct burner per rolling, 12

- month peri od #SSNDB = hours operated in steady state without duct burner per rolling, 12

- month period

o. Emission Limitation: VOC emissions from this emissions unit shall not exceed 168 lbs/hr during cold startup, 114 lbs/hr during hot startup, 138 lbs/hr during warm startup, and 45 lbs/hr during shutdown. Applicable Compliance Method:
These emissions limitations are based on manufacturer’s data. If r equired, the permittee shall demonstrate compliance with this emission limitation through emission testing performed i n 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 a pproved test methods may be used with prior approval from Ohio EPA.
p. Emission Limitation:
H 2 SO 4 emissions shall not exceed 6.0E

- 04 lb/mmBtu of heat input and 1.6 lbs/hr when the duct burner is not in operation; and, H 2 SO 4 emissions shall not exceed 7.0E

- 04 lb/mmBtu of heat input and 1.5 lbs/hr when the duct burner is in operation.
These emissions limitations are based on manufacturer’s data. I f required, 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.
q. Emission Limitation:
H 2 SO 4 emissions shall not exceed 6.6 tons per rolling, 12

- month period.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 52 of 55 Applicable Compliance Method:
This emission limitation was developed by multiplying the short

- term allowable H 2 SO 4 emission limitation (1.5 lbs/hr) by the maximum annual hours of operation (8,760 hours), and then dividing by 2,000 pounds per ton. T herefore, if compliance is shown with the short

- term allowable emission lim itation, compliance shall also be shown with the annual emission limitation.

r. Emission Limitation: CO 2 e emissions shall not exceed 371,029 lbs/hr and 1,477,071 tons per rolling, 12

- month period. Applicable Compliance Method:
The hourly emission limitation i s based on the sum of following manufacturer’s data Siemens Case #3 (370,652 lbs/hr CO 2 , 6.876 lbs/hr CH 4 , and 0.688 lbs/hr N 2 O) multiplied by the associated global warming potential for each pollutant (CO 2 =1, CH 4 =25, N 2 O=298 from Table A

- 1 of 40 CFR 98).

370 , 652 h ( 1 ) + 6

. 876 + h ( 25 ) + 0

. 688 h ( 298 ) = 371 , 029 / h

Since the CO 2 e emissions are estimated to consist of more than 99% CO 2 , compliance with this emission limitation will be assumed provided that the hourly CO 2 emission rate does not exceed 370,652 lbs/hr. I f required, the permittee shall conduct emissions testing using Methods 1, 2, 3A and 4 of 40 CFR Part 60, Appendix A to determine the hourly CO 2 emission rate.
The annual emission limitation is based on the sum of following manufacturer’s data modeling Siemens Case #3 (336,888.4 lbs/hr CO 2 , 6.25 lbs/hr CH 4 , and 0.625 lbs/hr N 2 O) multiplied by the associated global warming potential for each pollutant (CO 2 =1, CH 4 =25, N 2 O=298 from Table A

- 1 of 40 CFR 98) by the maximum annual hours of operation (8,760 hrs/yr) and dividing by (2,000 lbs/ton).

336 , 888

. 4 h ( 1 ) + 6

. 25 h ( 25 ) + 0

. 625 h ( 298 ) 8 , 760 h 2000

= 1 , 477 , 071 / Since the CO 2 e emissions are estimated to consist of more than 99 % CO 2 , compliance with this emission limitation will be assumed provided that the rolling, 12

- month CO 2 emissions as calculated in section d) above do not exceed 1,475,570 tons per rolling, 12

- month period (336,888 lbs/hr x 8760 hrs/yr x ton/2000 lb = 1,47 5,570 tons/yr). (2) The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the following requirements:Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 53 of 55 a. The emission testing shall be conducted within 60 days after achieving the maximum production rate at wh ich the emissions unit will be operated, but not later than 180 days after initial startup of the emissions unit

. b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate(s) for CO, NO x , PM 10 , PM 2.5 , VOC, and H 2 SO 4 , in the appropriate averaging period(s ).
The emission testing shall also be conducted to determine a site

- specific emission factor for CO 2 .
c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate (s): For CO, Methods 1 thru 4 and 10 of 40 CFR Part 60, Appendix A;
For NOx, Methods 1 thru 4 and 7E of 40 CFR Part 60, Appendix A, and the procedures specified in 40 CFR 60.4400;
For PM 10 and PM 2.5 , Methods 201A and 202 of 40 CFR Part 52, Appendix M;
For SO 2 , 40 CFR 60.4415;
For VOC, Methods 1 through 4 and 18, 25 or 25A, as appropriate, of 40 CFR Part 60, Appendix A.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 H 2 SO 4 , Methods 1 thru 4 and 8 of 40 CFR Part 60, Appendix A; and
For CO 2 , Methods 1, 2, 3A, and 4 of 40 CFR Part 60, Appendix A.
Alternative U.S. EPA approved test methods may be used with prior approval fr om the Ohio EPA.
d. The test(s) shall be conducted under those 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 appro priate Ohio EPA District Office or local air agency. Although this generally consists of operating the emissions uni t at its maximum material input/ production rates and results in the highest emission rate of the tested pollutant, there may be circumstance s 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 tes t date(s), the permittee shall submit an "Intent to Test" notification to the appropriate Ohio EPA District Office or local air agency. T he "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 beFi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 54 of 55 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 necessar y 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). T he permittee may request additional tim e for the submittal of the written report, where warranted, with prior approval from the appropriate Ohio EPA District Office or local air agency. (3) Wi thin 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 NO x monitoring system, in units of the applicable standard(s), to demonstrate compliance with 40 CFR Part 60, Appendix B, Performance Specifica tion 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 t est and shall demonstrate how the pound per hour emissions of NO x will be calculated stoichiometrically from the fuel flow rate. Personnel fr

om the Ohio EPA Central Office and the appropriate Ohio EPA District Office or local air agency shall be notified 4 5 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 loca l 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 NO x 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 NO x 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.Fi nal Permit - to - Install Oregon Clean Energy Center Permit Number : P0117413 Facility ID: 0448020102 Effective Date : 9/30/2014

Page 55 of 55 (4) Wi thin 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 complian ce with 40 CFR Part 60, Appendix B, Performance Specification 4 or 4a (as appropriate); Performance Specification 6 relative accuracy requirements; and ORC section 3704.03(I).
The permittee shall certify that the fuel flow monitor/meter is calibrated prior to the performance specification test and shall demonstrate how the pound per hour emissions of CO will be calculated stoichiometrically from the fuel flow rate.
Personnel fr

om the Ohio EPA Central Office and the appropriate Ohio EPA 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 test s. 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 compl eted. 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); Performa nce 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 collec ted as required in the Monitoring and Record keeping Section of this permit; and through demonstration of compliance with the quality assurance/quality control plan, which shall meet the requirements of 40 CFR Part 60. g) Miscellaneous Requirements (1) None.

# Oregon Clean Energy Center Lucas County, Oregon, Ohio



# Application for Prevention of Significant Deterioration Preconstruction Permit

Submitted by:
Oregon Clean Energy, LLC 20 Park Plaza, Suite #471 Boston, MA 02116



### Prepared by:

One Executive Drive Suite 303 Chelmsford, MA 01824



## August 2012Table of Contents Page i Oregon Clean Energy Center Lucas County, OH PSD Permit Application

1. Introduction 1-1
1.1 Project Overview 1-1
1.2 Regulatory Overview 1-2
1.3 Application Overview 1-2
1.3.1 Application Organization 1-2
1.3.2 Application Contacts 1-3
2. Project Description 2-1
2.1 Overview 2-1
2.2 Site Location 2-1
2.3 Combined Cycle Combustion Turbines 2-2
2.3.1 Combustion Turbine Generators 2-2
2.3.2 Heat Recovery Steam Generators and Duct Burners 2-3
2.3.3 Steam Turbine Generator 2-3
2.3.4 Cooling Tower 2-3
2.4 Air Pollution Control Equipment 2-3
2.4.1 Selective Catalytic Reduction 2-4
2.4.2 Oxidation Catalyst 2-4
2.5 Ancillary Equipment 2-4
2.5.1 Auxiliary Boiler 2-5
2.5.2 Emergency Diesel Generator 2-5
2.5.3 Emergency Diesel Fire Pump 2-5
2.5.4 Aqueous NH 3 Storage Tank 2-5
2.6 Emissions Estimates 2-5
2.6.1 Combined Cycle Combustion Turbine Emissions – Steady State Operation 2-7
2.6.2 Combined Cycle Combustion Turbine Emissions – Start-up and Shutdown Operations 2-8
2.6.3 Ancillary Equipment 2-10Table of Contents Page ii Oregon Clean Energy Center Lucas County, OH PSD Permit Application

2.6.4 Potential Annual Emissions 2-11 3. Regulatory Applicability Evaluation 3-1
3.1 PSD New Source Review 3-1
3.1.1 Best Available Control Technology 3-2
3.1.2 Air Quality Impact Analysis 3-2
3.1.3 PSD Class I Area Im pact Analysis 3-3
3.1.4 Additional Impact Analyses 3-4
3.2 New Source Performance Standards 3-5
3.2.1 40 CFR 60 – Subpart A – General Provisions 3-5
3.2.2 40 CFR 60 – Subpart KKKK – Stationary Combustion Turbines 3-5
3.2.3 40 CFR 60 – Subpart Dc – Small Industrial-CommercialInstitutional Steam Generating Units 3-6
3.2.4 40 CFR 60 – Subpart IIII – Stationary Compression Ignition Internal Combustion Engines 3-6
3.3 State of Ohio Best Available Technology 3-7
3.4 Operating Permit 3-8
3.5 National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63) 3-9
3.6 Acid Rain Program 3-10
3.7 Cross-State Air Pollution Rule 3-10
3.8 State Regulations 3-11
4. Control Technology Evaluation – BACT/BAT 4-1
4.1 Regulatory Applicability of Control Requirements 4-1
4.1.1 PSD Pollutants Subject to BACT/BAT 4-1
4.1.2 Emission Units Subject to BACT Analyses 4-2
4.2 BACT Analysis Approach 4-2
4.2.1 Best Available Control Technology 4-2
4.2.1.1 Identification of Technically Feasible Control Options 4-2
4.2.1.2 Economic (Cost-Effectiveness) Analysis 4-3Table of Contents Page iii Oregon Clean Energy Center Lucas County, OH PSD Permit Application

4.2.1.3 Energy Impact Analysis 4-3
4.2.1.4 Environmental Impact Analysis 4-4
4.3 BACT Analysis for NO x 4-4
4.3.1 Identification of Control Options 4-5
4.3.2 Search of RBLC Determinations 4-6
4.3.2.1 Combustion Turbine Generators and Duct Burners 4-6
4.3.2.2 Auxiliary Boiler 4-6
4.3.3 BACT Determinations 4-7
4.3.3.1 Combustion Turbine Generators and Duct Burners 4-7
4.3.3.2 Auxiliary Boiler 4-7
4.4 BACT Analysis for VOC 4-7
4.4.1 Identification of Control Options 4-8
4.4.2 Search of RBLC Determinations 4-8
4.4.2.1 Combustion Turbine Generators and Duct Burners 4-8
4.4.2.2 Auxiliary Boiler 4-9
4.4.3 BACT Determinations 4-9
4.4.3.1 Combustion Turbine Generators and Duct Burners 4-9
4.4.3.2 Auxiliary Boiler 4-9
4.5 BACT Analysis for CO 4-9
4.5.1 Identification of Control Options 4-10
4.5.2 Search of RBLC Determinations 4-10
4.5.2.1 Combustion Turbine Generators and Duct Burners 4-10
4.5.2.2 Auxiliary Boiler 4-11
4.5.3 BACT Determinations 4-12
4.5.3.1 Combustion Turbine Generators and Duct Burners 4-12
4.5.3.2 Auxiliary Boiler 4-12
4.6 BACT Analysis for Particulate Matter (PM 10 /PM 2.5 ) 4-12Table of Contents Page iv Oregon Clean Energy Center Lucas County, OH PSD Permit Application

4.6.1 Search of RBLC Determinations 4-13
4.6.1.1 Combustion Turbine Generators and Duct Burners 4-13
4.6.1.2 Auxiliary Boiler 4-13
4.6.1.3 Wet Cooling Tower 4-13
4.6.2 BACT Determinations 4-14
4.6.2.1 Combustion Turbine Generators and Duct Burners 4-14
4.6.2.2 Auxiliary Boiler 4-14
4.6.2.3 Wet Cooling Tower 4-14
4.7 BACT Analysis for Sulfur Dioxide and Sulfuric Acid 4-14
4.7.1 Search of RBLC Determinations 4-15
4.7.1.1 Combustion Turbine Generators and Duct Burners 4-15
4.7.1.2 Auxiliary Boiler 4-15
4.7.2 BACT Determinations 4-16
4.7.2.1 Combustion Turbine Generators and Duct Burners 4-16
4.7.2.2 Auxiliary Boiler 4-16
4.8 BACT Analysis for Greenhouse Gases 4-16
4.8.1.1 Search of RBLC Determinations 4-19
4.9 Emission Limit and Control Technology Summaries 4-20 5. References 5-1Table of Contents Page v Oregon Clean Energy Center Lucas County, OH PSD Permit Application

List of Tables

T ABLE 1

‐ 1: S UMMARY OF P ROPOSED P OTENTIAL E MISSIONS AND A PPLICABLE R EGULATORY T HRESHOLDS

.... 1

‐ 2 T ABLE 2

‐ 1: S UMMARY OF P ROPOSED E MISSION L IMITS FOR C OMBINED C YCLE C OMBUSTION T URBINES (S TEADY S TATE F ULL L OAD O PERATION )

.................................................................................................... 2

‐ 6 T ABLE 2

‐ 2: S UMMARY OF S HORT T ERM E MISSION R ATES FOR A S INGLE C OMBUSTION T URBINE

.................... 2

‐ 8 T ABLE 2

‐ 3: E MISSIONS AND D OWNTIMES A SSOCIATED WITH S TART
‐ UP AND S HUTDOWN E VENTS

................. 2

‐ 9 T ABLE 2

‐ 4: A VERAGE H OURLY E MISSIONS FOR S TART
‐ UP AND S HUTDOWN E VENTS ( INCLUDING DOWNTIME )

. 2

‐ 9 T ABLE 2

‐ 5: S HORT
‐ T ERM P OTENTIAL E MISSIONS FROM A NCILLARY E QUIPMENT .......................................2

‐ 11 T ABLE 2

‐ 6: P OTENTIAL A NNUAL E MISSIONS FROM A NCILLARY E QUIPMENT ..............................................2

‐ 11 T ABLE 2

‐ 7: S UMMARY OF A NNUAL P OTENTIAL E MISSIONS ....................................................................2

‐ 12 T ABLE 3

‐ 1: “Q/ D ” S CREENING A NALYSIS FOR OCE FOR C LASS I A REAS

..................................................... 3

‐ 4 T ABLE 3

‐ 2: O HIO EPA A PPLICABLE R EGULATIONS ................................................................................3

‐ 11 T ABLE 4

‐ 1: S UMMARY OF P ROPOSED BACT/BAT E MISSION L IMITS AND A SSOCIATED C ONTROL T ECHNOLOGIES FOR THE C OMBUSTION T URBINES ...............................................................................................4

‐ 21 T ABLE 4

‐ 2: S UMMARY OF P ROPOSED BACT/BAT E MISSION L IMITS AND A SSOCIATED C ONTROL T ECHNOLOGIES FOR THE A UXILIARY B OILER ........................................................................................................4

‐ 22
List of Figures (provided following text)

F IGURE 1: S ITE L OCATION
Appendices

A PPENDIX A: P RINTOUT OF O HIO EPA P ERMIT F ORMS A PPENDIX B: S UPPORTING C ALCULATIONS A PPENDIX C: RBLC T ABLESTable of Contents Page vi Oregon Clean Energy Center Lucas County, OH PSD Permit Application

List of Acronyms and Abbreviations

°F degrees Fahrenheit % percent AQRV Air Quality Related Values BAAMD Bay Area Air Quality Management District BACT Best Available Control Technology BAT Best Available Technology BP British Petroleum Btu British thermal units Btu/kW-hr British thermal unit per kilowatt-hour CAA Clean Air Act CAIR Clean Air Interstate Rule CARB California Air Resource Board CATEF California Air Toxics Emission Factor CCGT combined cycle gas turbine CCS carbon capture and sequestration CEMS continuous emissions monitoring systems CFR Code of Federal Regulations CH 4 methane CI compression ignition CO carbon monoxide CO 2 carbon dioxide the Court U.S. Court of A ppeals for the D.C. Circuit CSAPR Cross-State Air Pollution Rule CTG combustion turbine generator DB duct burner DLN dry low NO x FGD flue gas desulfurization FLM Federal Land Manager GHG greenhouse gasTable of Contents Page vii Oregon Clean Energy Center Lucas County, OH PSD Permit Application

g/hp-hr grams per horsepower-hour g/kW-hr grams per kilowatt-hour HAP hazardous air pollutant HHV higher heating value H 2 O water hp horsepower HRSG heat recovery steam generator H 2 SO 4 sulfuric acid mist ISO International Organization for Standards km kilometer kV kilovolts kW kilowatts LAER Lowest Achievable Emission Rate lb pounds lb/hr pounds per hour lb/MMBtu pounds per million British thermal units lb/MW-hr pounds per megawatt-hour MACT Maximum Achievable Control Technology MAGLC Maximum Acceptable Ground-Level Concentration mg/l milligrams per liter MMBtu million British thermal units MMBtu/hr million British thermal units per hour MW megawatts N 2 nitrogen gas n/a not applicable NESHAP National Emission Standards for Hazardous Air Pollutants ng/J nanograms per Joule NH 3 ammonia NO nitrogen oxide NO 2 nitrogen dioxideTable of Contents Page viii Oregon Clean Energy Center Lucas County, OH PSD Permit Application

N 2 O nitrous oxide NO x nitrogen oxides NSPS New Source Performance Standards O 2 oxygen OAC Ohio Administrative Code OCE Oregon Clean Energy, LLC Ohio EPA Ohio Environmental Protection Agency Pb lead PM 10 particulate matter with a diameter equal to or less than 10 microns PM 2.5 particulate matter with a diameter equal to or less than 2.5 microns ppm parts per million ppm v parts per million by volume ppm w parts per million by weight the Project Oregon Clean Energy Center PSD Prevention of Significant Deterioration psia pound per square inch absolute PTI Permit to Install RACT Reasonably Available Control Technology RBLC RACT/BACT/LAER Clearinghouse scf standard cubic feet SCR selective catalytic reduction SIL Significant Impact Level SIP State Implementation Plan SO 2 sulfur dioxide SO 3 sulfur trioxide SO 4 sulfate STG steam turbine generator TES Toledo Environmental Services TLV threshold limit value tpy tons per yearTable of Contents Page ix Oregon Clean Energy Center Lucas County, OH PSD Permit Application

TSP total suspended particulates ULSD ultra low sulfur diesel USEPA United States Environmental Protection Agency VCAPCD Ventura County Air Pollution Control District VOC volatile organic compoundsIntroduction Page 1-1 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

1. I NTRODUCTION
1.1 Project Overview
Oregon Clean Energy, LLC (OCE) is proposi ng to construct the Oregon Clean Energy Center, a nominal 800-megawatt (MW) combined cycle gas turbine (CCGT) facility (the Project). The Project will utilize combined cycl e combustion turbine technology in a 2 x 2 x 1 configuration. Accordingly, the major equipment will include two combustion turbine generators (CTGs), two supplementary-fired heat recovery steam generators (HRSGs), one steam turbine generator (STG), a mechanica l draft wet cooling tower, and associated auxiliary and balance of plant equipment and syst ems. The Project is anticipated to be fired with natural gas; no oil backup is proposed. Where necessary, ancillary equipment utilizing fuel oil will utilize ultra-low sulfur (0.0015%) diesel (ULSD) fuel. The Project is intended to operate as a base load facility and is proposing to be available to operate up to 8,760 hours per year, incorporating a range of load conditions. The Project seeks the flexibility to operate with frequent starts in order to meet energy demand (anticipating potential operation for 16 hours per day, five days per week).
OCE proposes to construct the Project within an approximately 30-acre parcel of land located entirely within Lucas County in the ci ty of Oregon, Ohio. The site is industrially zoned within the Cedar Point Development Park, a designated Foreign Trade Zone. Its setting is within a mixed industrial, commercial and agricultural area that is located east of Lallendorf Road, west of farmland located at 4632 Cedar Point Road, north of the Norfolk Southern Railroad, and south of the John Gradel and Sons’ Farms. Access to the Site is via Lallendorf Road. The western edge of the site is transected by Johlin Ditch, while a tributary of Driftmeyer Ditch tr ansects the eastern portion of the site. Bothditches flow north to Lake Erie, located less than 2 miles north of the site. FirstEnergyowned transmission lines extend in an east-west direction just to the north of the site.
Air emissions from the proposed Project primari ly consist of products of combustion from the combustion turbines, HRSG duct burners, and ancillary equipment. Pollutants that are regulated under federal and Ohio programs, such as Prevention of Significant Deterioration (PSD), include carbon monoxide (CO), nitrogen dioxide (NO 2 ), sulfur dioxide (SO 2 ), total suspended particulates (TSP), particulate matter with a diameter equal to or less than 10 microns (PM 10 ), particulate matter with a diameter equal to or less than 2.5 microns (PM 2.5 ), volatile organic compounds (VOC), greenhouse gases (GHGs), lead (Pb), sulfuric acid mist (H 2 SO 4 ), and air toxics. Potential emissions from the proposed Project, on a tons per year (tpy) basis, are presented in Table 1-1.Introduction Page 1-2 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 1-1: Summary of Proposed Potential Emissions and Applicable Regulatory Thresholds

Pollutant Annual Emissions (tpy) PSD Major Source Threshold (tpy) PSD Significant Emission Rate (tpy) PSD Applies? (Yes/No)

NO x 210.4 100 40 a Yes VOC 120.7 100 40 Yes CO 178.2 100 100 Yes
PM 10 173.0 100 15 Yes PM 2.5 173.0 100 10 Yes SO 2 40.6 100 40 Yes H 2 SO 4 21.6 100 7 Yes GHGs b 3,287,836 100,000 75,000 Yes Pb 0.00005 10 0.6 No
a. PSD significant emission rate for NO 2 . b. GHGs are expressed as CO 2 . 1.2 Regulatory Overview
The Project will include emissions control technology that will reflect Best Available Control Technology (BACT) and Best Available Technology (BAT), as applicable. In addition to the use of clean-burning natural gas, emissions of nitrogen oxides (NO x ) will be controlled with selective catalytic reduction (SCR). E missions of CO and VOC will be controlled with oxidation catalyst systems.
1.3 Application Overview
1.3.1 Application Organization
This permit application is divided into five sections. Section 2 provides a detailed description of the proposed Project, including a facility description and estimated emissions. Section 3 provides a review of r egulations applicable to the proposed Project. Section 4 provides the BACT/BAT control tec hnology evaluations. Section 5 provides aIntroduction Page 1-3 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

list of references. The air quality modeling anal ysis for the Project will be provided in a separate report.
A printout of the information submitted to t he Toledo Environmental Services (TES) via the Ohio Environmental Protection Agency (Ohio EPA) Air Services eBusiness Center is included as Appendix A. Emission calcul ation spreadsheets providing supporting calculations for the application are pr ovided in Appendix B. Appendix C presents summary tables supporting the BACT/BAT analysis.
1.3.2 Application Contacts
To facilitate agency review of this application, individuals fa miliar with the Project and this application are identified below.

William J. Martin Oregon Clean Energy, LLC 20 Park Plaza, Suite #471 Boston, MA 02116 Phone: 617-945-2165 Email: wmartin@cme-energy.com Lynn Gresock ARCADIS One Executive Drive, Suite 303 Chelmsford, MA 01824 Phone: 978-322-4520 e-mail: lynn.gresock@arcadis-us.comProject Description Page 2-1 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

2. P ROJECT D ESCRIPTION

2.1 Overview
OCE proposes development of a nominal 800- MW electric generating facility at an industrially zoned site in the city of Oregon, Ohio. Figure 1 presents the proposed Project location on a topographic map. The facility will include the following major and ancillary equipment:

 Two CTGs;

 Two HRSGs with supplemental duct firing;

 One STG;

 One mechanical draft wet cooling tower;

 One 1,500-kilowatt (kW) emergency diesel generator;

 One natural gas-fired, 90-million Britis h thermal units (MMBtu) steam production auxiliary boiler; and

 One 250-horsepower (hp) fire pump. The Project will be fueled by clean-burning natural gas to be provided by a new natural gas pipeline lateral connection from the nearby natural gas networks of NiSource/Columbia Gas or ANR Pipeline/Trans Canada. Electrical interconnection will be to the 345-kilovolt (kV) FirstEnergy transmission line, located just north of the site.
Steam condenser cooling will utilize a 12-cell mechanical draft wet cooling tower system with average consumptive water use of 6 - 7 million gallons per day. A combination of treated effluent and/or raw water from the ci ty of Oregon is being considered for process use. Discharge of wastewater is anticipated to be to the Oregon sanitary sewer system for treatment at the wastewater treatment plant , located within 1 mile of the site.

2.2 Site Location
The proposed site consists of an irregularly shaped parcel of land, totaling approximately 30 acres, located entirely within Lucas County in the city of Oregon, Ohio. The site is industrially zoned within the Cedar Point Development Park, a designated Foreign Trade Zone. Its setting is within a mixed industrial , commercial and agricultural area that is located east of Lallendorf Road, west of farmland located at 4632 Cedar Point Road, north of the Norfolk Southern Railroad, and south of the John Gradel and Sons’ Farms.Project Description Page 2-2 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Access to the site is via Lallendorf Road. The western edge of the site is transected by Johlin Ditch, while a tributary of Driftmeyer Di tch transects the eastern portion of the site. Both ditches flow north to Lake Erie, located less than 2 miles north of the site. FirstEnergy-owned transmission lines extend in an east-west direction just to the north of the site.
The site consists of farmland with associated structures, including two single-family dwellings, a garage and a barn. T he majority of the parcel is in active agricultural use. Site topography is relatively flat, at an el evation of approximately 590 feet above mean sea level. The Maumee River, which flows sout hwest to northeast to its confluence with Lake Erie, is situated approximatel y 2 miles northwest of the site.
The Project is located approximately 2 miles south of First Energy’s existing Bay Shore coal-fired power plant on Lake Erie. Br itish Petroleum’s (BP’s) expansive Toledo Refinery is located less than 0.5 mile to the north, beyond the electric transmission corridor. Land uses east and southeast of the site are primarily agricultural, with some residences along the roads which divide the land in a grid-like fashion. A cluster of commercial/industrial uses border the site to the south-southwest, including several manufacturing and warehouse facilities, among them, Fresenius Medical Care (a manufacturer of dialysis machines) and Caraustar (a manufacturer of gypsum facing paper and spiral-wound paper tubes). More densely developed residential areas are located about a mile southwest of the site.
Pearson Park is located approximately 1.5 m iles south of the site, Collins Park is 1.5 miles west-southwest of the site, and Maumee Bay State Park is approximately 2 miles east-northeast of the site. Further east-northeast, along the shore of Lake Erie, are Mallard Club Wilderness Area and Cedar Point National Wildlife Refuge.
2.3 Combined Cycle Combustion Turbines
The Project’s major equipment will include two CTGs, two supplementary-fired HRSGs, one STG, and a 12-cell mechanical draft wet cooling tower. This equipment is described in more detail below. The information provided in this application are based upon a Siemens “F” class CTG, or equivalent.

2.3.1 Combustion Turbine Generators
Thermal energy will be produced in the two CT Gs through the combustion of natural gas as the sole fuel. Each CTG is capable of running independently of the other. The thermalProject Description Page 2-3 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

energy is converted to mechanical energy in the CTG turbine that drives the CTG compressor and electric generator. The maximum heat input rate of each CTG for 100 percent load at International Organization for Standards (ISO) temperature (59 degrees Fahrenheit [°F]), relative humidity of 71 per cent and a site pressure of 14.5 pounds per square inch absolute (psia) is 2,266 MMBtu per hour (MMBtu/hr) at the higher heating value (HHV) for natural gas.
2.3.2 Heat Recovery Steam Generators and Duct Burners
In the combined cycle configuration, each CTG will exhaust through a dedicated HRSG to generate steam from the waste heat energy in the exhaust gas. Each HRSG will be equipped with supplemental fuel firing via a duct burner. The duct burners provide additional energy to the HRSG, to provide more steam to the STG during periods of high demand. The duct burners will be natural gas fired and each will have a maximum input capacity of 841 MMBtu/hr (HHV), although t he duct burners will not always operate at maximum capacity. The use of the duct burner will vary based upon different temperature and operating conditions.

2.3.3 Steam Turbine Generator
Steam generated in the HRSGs will be expanded through a STG multi-stage, reheat, condensing turbine and associated electric generat or to generate additional electricity.
2.3.4 Cooling Tower
The steam condenser cooling will utilize a 12-cell mechanical draft wet cooling tower system. In the cooling tower, circulating wate r is distributed among multiple cells of the cooling tower, where it cascades downward through each cell and then collects in the cooling tower basin. The mechanical draft c ooling tower employs electric motor-driven fans to move air through each cooling tower cell. The cascading circulating water is partially evaporated and the evaporated water is dispersed to the atmosphere as part of the moist air leaving each cooling tower cell. The circulating water is cooled primarily through its partial evaporation. The cooli ng tower will be equipped with a high-efficiency drift eliminator with an efficiency of 0.0005 percent.
2.4 Air Pollution Control Equipment
The emission control technologies propos ed for the combustion turbine and duct burner exhaust gases include dry low-NO x (DLN) combustors which are integrated within theProject Description Page 2-4 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

combustion turbines, and SCR systems and oxidat ion catalysts which are located within each HRSG to control NO x , CO and VOC emissions. The DLN combustion controls NO x formation by pre-mixing fuel and air immediately prior to combustion. Pre-mixing inhibits NO x formation by minimizing both the flame te mperature and the concentration of oxygen at the flame front. The S CR systems further control NO x emissions, while the oxidation catalysts control emissions of CO and VOC. Emissions of SO 2 , PM 10 /PM 2.5 , and H 2 SO 4 will be minimized through the exclusive use of pipeline quality natural gas in the combustion turbines. The SCR and oxidation cata lyst are discussed further in the sections below.
2.4.1 Selective Catalytic Reduction
SCR, a post-combustion chemical process, will be installed in the HRSGs to treat exhaust gases downstream of the CTGs. The SCR process will use 19 percent aqueous ammonia (NH 3 ) as a reagent. Aqueous NH 3 will be injected into the flue gas stream, upstream of the SCR catalyst, where it will mix with NO x . The catalyst bed will be located in a temperature zone of the HRSG where the catalyst is most effective. The mixture will pass over the catalyst and the NO x will be reduced to nitrogen gas (N 2 ) and water (H 2 O). The SCR system will reduce NO x concentrations to 2.0 parts per million by volume (ppm v ) at 15 percent oxygen (O 2 ) with or without duct firing at all load conditions and ambient temperatures. A small amount of NH 3 will remain un-reacted through the catalyst, which is called the “ammonia slip.” The NH 3 slip will be limited to 5.0 ppm v at all load conditions and ambient temperatures.
2.4.2 Oxidation Catalyst
An oxidation catalyst system will be located within each HRSG to control emissions of CO and VOC. Exhaust gases from the turbines will be passed over a catalyst bed where excess air will oxidize the CO and VOC to form carbon dioxide (CO 2 ) and H 2 O. The oxidation catalyst system will reduce CO concentrations to 2.0 ppm v (at 15% O 2 ) in the exhaust gas under all load conditions and ambient temperatures. The oxidation catalyst will also reduce VOC emissions, to between 1.0 ppm to 3.5 ppm, depending on the amount of supplemental duct firing.
2.5 Ancillary Equipment
The proposed Project will utilize a variety of ancillary equipment to support the facility including an auxiliary boiler, an emergenc y generator, an emergency fire pump, and storage tanks. This equipment is discu ssed further in the sections below.Project Description Page 2-5 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

2.5.1 Auxiliary Boiler
An auxiliary boiler will operate as needed to keep the HRSG warm during periods of turbine shutdown and provide sealing steam to the steam turbine during warm and hot starts. The auxiliary boiler will have a maximum input capacity of 90 MMBtu/hr.
2.5.2 Emergency Diesel Generator
The Project will have a 1,500-kW emergenc y diesel generator to provide on-site emergency power capabilities independent of t he utility grid. The emergency generator will fire ULSD fuel and will typically only operate for testing and to maintain operational readiness in the event of an emergency. Rout ine operation of the generator will be limited to a maximum of 500 operating hours per year.
2.5.3 Emergency Diesel Fire Pump
The Project will have an emergency fire pump to provide on-site fire fighting capabilities independent of the utility grid. The emergency fire pump will fire ULSD fuel and will typically only operate for testing and to mainta in operational readiness in the event of an emergency. Similar to the emergency generator , it will be limited to a maximum of 500 operating hours per year.

2.5.4 Aqueous NH 3 Storage Tank
The proposed facility will have tanks that will store 19 percent aqueous NH 3 for use in the SCR system. The tanks will be equipped with secondary containment sized to accommodate the entire volume of one tank and sufficient freeboard for precipitation. The tanks will be located outdoors within an im permeable containment area, surrounded by a wall. The floor of the containment area will be covered with plastic balls designed to float on the liquid surface in the event of a spill, thereby reducing the exposed surface area, and minimizing potential emissions.

2.6 Emissions Estimates
The combined cycle units will typically operate at or near full load capacity to respond to electricity demands as needed. However, depending upon the demand, each unit can operate at loads ranging from approximat ely 50 percent turbine load without supplemental duct firing to 100 percent load with supplemental duct firing (full capacity). The emissions provided in this applicatio n are based upon 100 percent load steady stateProject Description Page 2-6 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

operation of a Siemens “F” Class turbine, or equivalent. Combustion turbine performance and emissions are affected by ambient conditions: humidity, pressure and temperature; with turbine fuel consumption, power output and emissions increasing at lower ambient temperatures. Supplemental duct firing performance and emissions are affected indirectly by ambient conditions , with fuel consumption, heat output and emissions increasing at higher ambient te mperatures. As the combustion turbine decreases heat output to the HRSG at higher ambient temperatures, the supplemental duct firing increases to make up the loss of heat output to maintain maximum steam production to the steam turbine.
Table 2-1 presents a summary of the pr oposed limits for pollutants emitted from combined cycle combustion turbines at steady state full load operation. The limits incorporate BACT/BAT as applicable (Section 4.0). Table 2-1: Summary of Proposed Emission Limits for Combined Cycle Combustion Turbines (Steady State Full Load Operation) a

Pollutant Case Emission Rate (lb/MMBtu) b Emission Rate (ppm v ) c NO x CT Only CT with DB d 0.0076 0.0077 2.0 2.0 VOC CT Only CT with DB 0.0013 0.0048 1.0 3.5 CO CT Only CT with DB 0.0048 0.0048 2.0 2.0 PM 10 /PM 2.5 CT Only CT with DB 0.0049 0.0065 n/a n/a SO 2 CT Only CT with DB 0.0015 0.0015 n/a n/a H 2 SO4 CT Only CT with DB 0.0008 0.0008 n/a n/a a. Facility may exceed these lim its during defined periods of startup an d shutdown. b. Emission rates are based on HHV of natural gas. c. Concentrations are ppm v at 15% O 2 . d. Duct burner.

Because of the different emission rates an d exhaust characteristics, a matrix of operation modes, including partial load oper ation, will be evaluated in the OCE Dispersion Modeling Report.Project Description Page 2-7 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Combined cycle start-up and shutdown scenario s are also addressed in this air permit application. Emissions during start-up and shutdown may, for some pollutants, result in an increase in short term (pounds per hour [lb/hr]) emission rates. There is a minimum turbine downtime and maximum duration associat ed with each type of start-up. There is also a maximum duration associated with each shutdown. Potential annual emissions estimates for the proposed Project include emissions from start-up and shutdown.
The following sections provide estimated e missions from the combined cycle combustion turbines and from the facility’s ancillary equipm ent. Emissions of air contaminants from this equipment have been estimated based upon vendor emission guarantees, United States Environmental Protection Agency (USEPA) emission factors, mass balance calculations and engineering estimates.
2.6.1 Combined Cycle Combustion Turbine Emissions – Steady State Operation
Table 2-2 presents short term (lb/hr) em issions estimates from each combined cycle turbine under ISO conditions at 100 percent load conditions including duct burner operations. These emissions were deve loped from vendor estimates. The PM 10 /PM 2.5 emissions estimates include filterable and condensable particulate matter and an allowance for sulfate and/or ammonia salt format ion due to the reaction of sulfur trioxide (SO 3 ) with H 2 O and/or excess NH 3 in the SCR and oxidation ca talyst systems. Emission rates for all base load operating condi tions are provided in Appendix B.
Potential non-criteria pollutant emissions from the operation of the combustion turbines and ancillary equipment were estimated usi ng AP-42 emission factors (USEPA, 2000) with the following exceptions. Emissions of formaldehyde from the combustion turbine generators were estimated using an emission fact or from a California Air Resource Board (CARB) database. The California Air Toxics Emission Factor (CATEF) database contains air toxics emission factors calculated from s ource test data collected for California’s Air Toxics Hot Spots Program (CARB, 1996). Em issions of hexane from the duct burner and the auxiliary boiler were estimated using an emission factor from the Ventura County Air Pollution Control District (VCAPCD, 2001). In both cases, the AP-42 emission factors had a very low emission factor rating and were not considered representative of the proposed equipment. The CARB and VCAPCD emission fa ctors are considered more appropriate for the advanced technology of the combustion turbines. Potential emissions of Hazardous Air Pollutants (HAPs) and Ohio EPA air toxics from operation of the combustion turbines and duct burners are also provided in Appendix B.Project Description Page 2-8 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 2-2: Summary of Short Term Emission Rates for a Single Combustion Turbine a

Pollutant 100% Load with Duct Burning (lb/hr) 100% Load without Duct Burning (lb/hr) NO x 23.0 17.0 VOC 13.0 3.0 CO 14.0 10.0
PM 10 /PM 2.5 19.0 11.0 SO 2 4.6 3.4 H 2 SO 4 2.5 1.8 NH 3 21.0 16.0a. Emissions presented in table are for ISO conditions. These may not represent worstcase conditions for air quality dispersion modeling. Appropriate worst-case conditions will be used for these analyses in the Dispersion Modeling Report.

2.6.2 Combined Cycle Combustion Turbine Emissions – Start-up and Shutdown Operations

Potential emissions associated with start- up and shutdown of the combustion turbines were developed using vendor supplied information. Table 2-3 presents the emissions and downtimes (minimum number of hours the tu rbines would be off before a re-start) associated with startup and shutdown events for the combined cycle turbines. In most cases, emissions from these events are “sel f correcting” on an annual basis. In other words, the average hourly emissions for each startup event (including downtime) are less than the corresponding steady st ate emission rate for the minimum downtime that would precede a start. Table 2-3 identifies the pollutant s that are self-correcting for each event. Permitted annual emission limits for the facility incorporates those conditions that are not considered self-correcting. Table 2-4 pr esents the average hourly emission rates associated with each start-up/shutdown event. These emission rates incorporate the minimum downtime that would precede each event. These average hourly rates were used to determine if the event was consider ed self-correcting com pared to steady state emission rates. Emissions of SO 2 will always be self-correcting because SO 2 emissions are dependent upon the amount of fuel burned, and steady state is always worst-case.Project Description Page 2-9 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 2-3: Emissions and Downtimes Associated with Start-up and Shutdown Events
Cold Startup Hot Startup Warm Start-up Shutdown
Number of Events per Year 50 250 a 0 300 Minimum Downtime Preceding Event (hrs) b 64 2 16 1 Duration of Event (min) c 178 80 88 42 Emissions Per Event (lb) d
PM 10 /PM 2.5 24 12 14 6 NO x 76 64 67 32 CO 253 130 130 80 VOC 63 51 52 31 Self-Correcting
PM 10 /PM 2.5 Yes Yes Yes Yes NO x Yes Yes Yes Yes CO Yes No Yes No VOC Yes No Yes No
a. Total hot start and warm start emissions are 250 starts. b. hours c. minutes d. pounds
Table 2-4: Average Hourly Emissions for Start-up and Shutdown Events (including downtime)

Pollutant Cold Startup (lb/hr) Hot Startup (lb/hr) Warm Start-up (lb/hr) Shutdown (lb/hr)
PM 10 /PM 2.5 0.36 3.60 0.80 3.65 NO x 1.13 19.20 3.84 18.82 CO 3.78 39.00 7.44 47.06 VOC 0.94 15.30 2.98 18.24Project Description Page 2-10 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

2.6.3 Ancillary Equipment
This section presents estimated criteria pollu tant emissions from the ancillary equipment at the facility. The proposed ancillary equi pment includes one auxiliary boiler, one emergency generator, one emergency fire pump, and the cooling tower. The following assumptions were used in evaluating emissions from this equipment:

 The natural gas-fired auxiliary boiler w ill have a maximum input capacity of 90.0 MMBtu/hr with unlimited hours of operation per year.

 The diesel-fired emergency fire pump will have a maximum heat input of 1.3 MMBtu/hr (9.3 gallons per hour) and will be limited to 500 hours of operation per year.

 The diesel-fired emergency generator w ill have a maximum heat input of 14.1 MMBtu/hr (101 gallons per hour) and will be limited to 500 hours of operation per year.

 The cooling tower is expected to have a recirculating flow rate of 133,700 gallons per minute and 3,000 milligrams per liter (mg/l) of TDS.
Criteria pollutant emissions from the an cillary equipment were estimated based on vendor supplied information except for SO 2 emissions from the emergency equipment, which are based on a mass balance assuming ULSD. PM 10 /PM 2.5 emissions from the cooling tower are based upon design values and conservatively assume five cycles of concentration. The cooling tower will utilize a high efficiency drift eliminator.

Tables 2-5 and 2-6 summarize estimated sh ort-term (lb/hr) and annual emissions of criteria pollutants from the ancillary equipment. Supporting calculations are located in Appendix B.Project Description Page 2-11 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 2-5: Short-Term Potential Emissions from Ancillary Equipment

Pollutant Auxiliary Boiler (lb/hr) Emergency Fire Pump (lb/hr) Emergency Generator

(lb/hr) Cooling Tower (lb/hr)

PM 10 0.45 0.08 0.66 1.00 PM 2.5 0.45 0.08 0.66 1.00 SO 2 0.06 0.003 0.021 

### -- NO x 0.90 1.44 18.53 

### -- CO 3.33 1.44 11.56 -- VOC 0.36 0.20 2.62 --

Pb 0.00 0.00002 0.0002 --

Table 2-6: Potential Annual Emis sions from Ancillary Equipment

Pollutant Auxiliary Boiler (tpy) Emergency Fire Pump (tpy) Emergency Generator (tpy) Cooling Tower

(tpy) Total (tpy) PM 10 1.97 0.021 0.17 4.4 6.56 PM 2.5 1.97 0.021 0.17 4.4 6.56 SO 2 0.28 0.0007 0.005 -- 0.29 NO x 3.94 0.36 4.63 -- 8.93 CO 14.59 0.36 2.89 -- 17.84 VOC 1.58 0.05 0.65 -- 2.28

Pb 0.00 0.000006 0.00005 -- 0.00006

HAP emissions will be less than major source thresholds, less than 10 tpy for any individual HAP and 25 tpy for total HAPs.

2.6.4 Potential Annual Emissions

Potential annual emissions fr om the proposed facility were estimated using the following worst-case assumptions:Project Description Page 2-12 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

 Full load operation of the combustion turbines (at 59°F ambient temperature);

 Duct burning for 8,760 hours per year during steady state operation of each combustion turbine;

 Incorporation of start-up/shutdown even ts as described in Section 2.6.2; for start-up/shutdown events t hat are not self correcting, a total of 300 combined start-up events per year and 300 shutdown events per year were assumed (see Table 2-3); and

 Incorporation of emissions from ancillary equipment as discussed in Section 2.6.3 (see Table 2-6).
Potential annual emissions for the proposed Project are summarized in Table 2-7.

Table 2-7: Summary of Annual Potential Emissions

Pollutant Combustion Turbines (tpy) Ancillary Equipment (tpy) Total (tpy)
PM 10 166.4 6.6 173.0 PM 2.5 166.4 6.6 173.0 SO 2 40.3 0.3 40.6 NO x 201.5 8.9 210.4 CO 160.3 17.8 178.2 VOC 118.5 2.3 120.7 H 2 SO 4 21.6 0.02 21.6

NH 3 184.0 0.0 184.0 Pb 0.0 0.00006 0.00006

.Regulatory Applicability Evaluation Page 3-1 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

3. R EGULATORY A PPLICABILITY E VALUATION
OCE is requesting approval to construct a nominal 800-MW combined cycle electric generating facility in the city of Oregon, Lucas County, Ohio. The Project is considered a new major stationary combustion source under PSD regulations because the potential annual emissions from the facility exceed major source thresholds as illustrated in Table 1-1.
This section contains an analysis of the applicability of federal and state air quality regulations to the proposed Project. The specific regulations and programs that are included in this review include:

 PSD New Source Review;

 Federal New Source Performance Standards (NSPS);

 Federal National Emission Standards for Hazardous Air Pollutants (NESHAP);

 Federal Acid Rain Program;

 Other Ohio EPA requirements; and

 Accidental Release requirements.

3.1 PSD New Source Review
Combined cycle power plants with potential e missions greater than 100 tpy of one or more criteria pollutants are considered new major stationary sources under the PSD program. As shown in Table 1-1, the potential emissions of at least one regulated criteria pollutant will exceed this threshold. As such, the pr oposed facility is subject to PSD New Source Review. Under the PSD regulations, once a major source threshold is triggered, PSD review must be completed for all pollut ants whose potential emissions exceed their Significant Emission Rate increase.
On April 2, 2007, the U.S. Suprem e Court found that GHGs, including CO 2 , are air pollutants covered by the Clean Air Act (CAA) . On May 13, 2010, the USEPA issued a final rule (called the “Tailoring Rule”) that establishes an approach to GHG emissions from stationary sources under the CAA. This final rule “tailors” the requirements of the CAA permitting program to limit which facilities will be required to obtain PSD permits. The CAA permitting program emissions thresholds for criteria pollutants are 100 tpy or 250 tpy, depending on the source category. While these thresholds are appropriate for criteriaRegulatory Applicability Evaluation Page 3-2 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

pollutants, they are not feasible for GHG emi ssions as they are emitted in much greater quantities. USEPA will phase in the CA A permitting requirements in two phases:

 Only sources already subject to the PS D program (i.e., new major sources such as the OCE Project) are subject to permitting requirements for their GHG emissions under PSD. For these projects, those with GHG emission increases of 75,000 tpy or greater are required to determine BACT for their GHG emissions. This phase began on January 2, 2011.

 In the second phase, PSD permitting r equirements will cover new construction projects that exceed 100,000 tpy of GHG emissions, even if they do not exceed any other permitting thresholds. This began on July 1, 2011.
As presented in Table 1-1, the Project has tri ggered major source thresholds for GHGs. In addition, PSD review is required for NO x , CO, VOC, SO 2 , H 2 SO 4 and PM 10/ PM 2.5 emissions.
PSD review requirements include application of BACT, an ambient air quality modeling analysis demonstrating compliance with N AAQS and PSD increments, and an additional impacts analysis. Ohio EPA has been delegated PSD review authority by USEPA. For an air contaminant subject to BACT, complianc e with BACT requirements also represents Ohio EPA BAT.
3.1.1 Best Available Control Technology
Pollutants subject to PSD review are required to apply BACT for control of emissions of PSD pollutants. BACT is defined as an e mission limitation based on the maximum degree of reduction, on a case-by-case basis, taki ng into account energy, environmental and economic considerations. In establishing the final BACT limit, USEPA may consider any new information, including recent permit decis ions, subsequent to submittal of a complete application. The BACT analyses for NO x , CO, VOC, SO 2 , H 2 SO 4 and PM 10/ PM 2.5 are presented in Section 4.0.
3.1.2 Air Quality Impact Analysis
An ambient air quality analysis must be performed to demonstrate compliance with NAAQS and PSD increments. Proposed new s ources subject to PSD review may not cause or significantly contribute to a violation of the NAAQS. As part of this demonstration, the USEPA has es tablished Significant Impact Levels (SILs) for all of the criteria pollutants. SILs r epresent concentrations of pollutants that are considered to beRegulatory Applicability Evaluation Page 3-3 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

insignificant with respect to demonstration of NAAQS compliance. By definition, proposed new sources whose air quality impacts are le ss than SILs neither cause nor significantly contribute to NAAQS violations. Proposed new sources whose air quality impacts exceed the SILs must complete a cumulative ana lysis taking into consideration existing background air quality levels and cont ributions from other sources.
The air quality impact analysis for the Proj ect will be included in the OCE Dispersion Modeling Report.

3.1.3 PSD Class I Area Impact Analysis PSD regulations require that proposed major s ources within 100 kilometers (km) of a PSD Class I area perform an assessment of potential impacts in the PSD Class I area. PSD Class I areas are specifically designated areas of special national or regional value from a natural, scenic, recreational or historic pers pective. These areas are administered by the National Park Service, U.S. Fish and Wildlife Se rvice, or the U.S. Forest Service. These Federal Land Managers (FLMs) are responsible for evaluating proposed projects’ air quality impacts in the Class I areas and ma y make recommendations to the permitting agency to approve or deny permit applications.
PSD Class I area impact analyses consist of:

 An air quality impact analysis;

 A visibility impairment analysis; and

 An analysis of impacts on other air q uality related values (AQRVs) such as impacts to flora and fauna, water, and cultural resources.

There are no PSD Class I areas within 100 km of the proposed Project site. The nearest PSD Class I Areas are the Otter Creek and Dolly Sods Wilderness Areas in West Virginia, and the Mammoth Cave National Park in Kentu cky. These PSD Class I areas are located over 250 miles fr om the Project.
Ohio EPA recommends that a screening formula be used to determine if a Class I Area is close enough to warrant analysis. The screening formula, which is found in The Federal Land Managers AQRV Workgroup (FLAG) Phase I Report – Revised (FLAG 2010) is provided below:Regulatory Applicability Evaluation Page 3-4 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

A PSD Class I area analysis is not required if Q (tpy)/d (km) < 10,

where:
Q = the combined emissions increase from a source of SO 2 , NO x , PM 10 , and H 2 SO 4 in tpy based on 24-hour maximum allowable emissions (which are annualized); and d = the nearest distance (km) to a Class I area from the source.
Table 3-1: “Q/d” Screening Analysis for OCE for Class I Areas

Class I

Area d, Distance to Class I Area (km) SO 2 Emissions (tpy) NO x Emissions (tpy) PM 10 Emissions (tpy) H 2 SO 4 Emissions (tpy) Q, Total Emissions (tpy) Q/d (tpy/km)

Otter Creek 439.0 40.6 210.4 173.0 21.6 445.6 1.0 Dolly Sods 457.0 40.6 210.4 173.0 21.6 445.6 1.0 Mammoth Cave 548.0 40.6 210.4 173.0 21.6 445.6 0.8

Table 3-1 presents results of the screening ca lculation performed in accordance with the screening formula. The calculations show that “Q/d” is below 10 for the nearest Class I areas to the proposed source. Accordingly, based on the level of proposed emissions from the Project, the distances to the nearest PSD Class I areas, and the screening calculation above, a PSD Class I impact analysis is not required for the Project.
3.1.4 Additional Impact Analyses
Additional impact analys es are also required as part of PSD review and Ohio EPA regulations. These additional analyses in clude an assessment of impacts on community growth resulting from the Project, an assessment of visibility impairment and an assessment of impacts to soils and vegeta tion. These impact analyses will be presented in the OCE Dispersion Modeling Report.
Federal actions, such as the issuance of PSD permits (in this case, delegated to the state), require review and consideration of the potent ial implications of a proposed project to endangered or threatened species and their habitats, as well as cultural resources. OCE will consult with applicable agencies to deter mine whether such resources will requireRegulatory Applicability Evaluation Page 3-5 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

specific consideration, and records of these communications will be provided in the OCE Dispersion Modeling Report.

3.2 New Source Performance Standards
NSPS are technology-based standards applicable to new and modified stationary sources. NSPS have been established for approximately 70 source categories. Based upon a review of these standards, several subparts are applicable to the proposed Project. The Project’s compliance with each of these st andards is presented in the sections below.
3.2.1 40 CFR 60 – Subpart A – General Provisions
Any source subject to an applicable standard under 40 Code of Federal Regulations (CFR) 60 is also subject to the general provis ions under Subpart A. Because the Project is subject to other Subparts of the regulation, the requirements of Subpart A will also apply. OCE will comply with the applicable notifications, performance testing, recordkeeping and reporting outlined in Subpart A.
3.2.2 40 CFR 60 – Subpart KKKK – Stationary Combustion Turbines
Subpart KKKK places emission limits on NO x and SO 2 from new combustion turbines. The proposed combustion turbines and duct burners would be subject to this standard. For new combustion turbines firing natural gas with a rated heat input greater than 850 MMBtu/hr, NO x emissions are limited to:

 15 ppm v at 15 percent O 2 ; or

 54 nanograms per Joule (ng/J) of useful output (0.43 pounds per megawatt-hour [lb/MW-hr]).
Additionally, SO 2 emissions must meet one of the following:

 Emissions limited to 110 ng/J (0.90 lb/MW-hr) gross output; or

 Emissions limited to 26 ng/J (0.060 lb/MMBtu).
As described in Section 2.0, the proposed Pr oject will use an SCR system to reduce NO x emissions to 2 ppm v at 15 percent O 2 and pipeline natural gas to limit SO 2 emissions to 0.0015 lb/MMBtu. As such, the Project will m eet the emission limits under Subpart KKKK.Regulatory Applicability Evaluation Page 3-6 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Additionally, the provisi ons of this Subpart require continuous monitoring of water-to-fuel ratio, but allow for the use of either a 40 CFR Part 60 or Part 75 certified NO x continuous emissions monitoring system (CEMS) in lieu of this requirement. OCE is proposing to use a 40 CFR Part 75 certified NO x CEMS, which will satisfy this requirement.
3.2.3 40 CFR 60 – Subpart Dc – Small Industrial-Commercial-Institutional Steam Generating Units
Subpart Dc is applicable to steam generating un its with a maximum i nput capacity greater than 10 MMBtu/hr and less than 100 MMBtu/hr. The proposed auxiliary boiler has a maximum input capacity of 90 MMBtu/hr, and is, therefore, subject to the standard. For units combusting natural gas, the standard requi res initial notifications at the start of construction and at startup. In addition, re cords must be maintained regarding the amount of fuel burned on a monthly basis; however, sinc e natural gas is the only fuel burned in the proposed boiler, there are no specific repor ting requirements to the USEPA under Subpart Dc.
3.2.4 40 CFR 60 – Subpart IIII – Stationary Compre ssion Ignition Internal Combustion Engines
Subpart IIII is applicable to owners and operator s of stationary compression ignition (CI) internal combustion engines that commence operat ion after July 11, 2005. Relevant to the proposed project, this rule applies to the em ergency generator and emergency fire pump.
For model year 2009 and later fire pump engines with a displacement less than 30 liters per cylinder and an energy rating between 300 and 600 hp, Subpart IIII provides the following emission limits:

 4.0 grams per kilowatt-hour (g/kW-hr) (3.0 grams per horsepower-hour [g/hp-hr]) of VOC + NO x

 3.5 g/kW-hr (2.6 g/hp-hr) of CO

 0.2 g/kW-hr (0.15 g/hp-hr) of particulate matter
The Project will install a fire pump meeting these emission standards.
To comply with Subpart IIII, the emergency generator must meet the emission standards for new non-road CI engines (Tier 2 or 3). Engi nes with a model year 2006 or later with a power rating of 560 kW (750 hp) or gr eater must meet the following limits:Regulatory Applicability Evaluation Page 3-7 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

 6.4 g/kW-hr (4.8 g/hp-hr) of VOC + NO x

 3.5 g/kW-hr (2.6 g/hp-hr) of CO

 0.2 g/kW-hr (0.15 g/hp-hr) of particulate matter
The emergency generator associated with the pr oposed Project will be certified to meet non-road emission standards.
3.3 State of Ohio Best Available Technology
“Best available technology," or BAT, means any combination of work practices, raw material specifications, throughput limitat ions, source design characteristics, an evaluation of the annualized cost per ton of air pollutant removed, and air pollution control devices that have been pr eviously demonstrated to t he director of environmental protection to operate satisfactorily in this stat e or other states with similar air quality on substantially similar air pollution sources (Ohio Administrative Code [OAC] Rule 3745- 31-01 (T)).
Ohio EPA has published several memoranda (inter-office communications) and engineering guides that explain the implementation of the BAT program. Under the BAT program, sources with pollutants meeting ce rtain other standards al so meet BAT. For pollutants subject to BACT requirements, BAC T is presumed to meet BAT requirements. For pollutants subject to NSPS, compliance with NSPS represents BAT. If there is a Reasonably Available Control Technology (RAC T) minimum limit anywhere in the state, BAT is determined to be at a minimum, equivalent to most stringent pollutant emission rate limit no matter where in the state the RACT limit applies. Where the above prescriptive approach is not applicable to a criteria pollutant, a case-by-case BAT determination may be conducted using a “top down” approach, simila r to a BACT analysis. BAT for criteria pollutants is described in Section 4.0.
For HAPs subject to Maximum Available C ontrol Technology (MACT), compliance with MACT represents BAT. In addition, BAT is appli ed to any air toxic (non-criteria pollutant) for which there is no federal or state standard using Ohio EPA’s Air Toxics policy. Ohio EPA’s Air Toxic policy is contained in the gui dance document titled “Option A – Review of New Sources of Air Toxics.” The guidelines are:

 Determine if a threshold limit value (TLV) exists for the specific compound, which is emitted from the source.Regulatory Applicability Evaluation Page 3-8 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

 Divide the TLV by ten to adjust the st andard from the working population to the general public (TLV/10).

 Adjust the standard to account for the dur ation of the exposure (operating hours of source) of “X” hours per day and “Y” days per week from 8 hours per day and 5 days per week. This formula is used to ob tain the Maximum Acceptable Ground-Level Concentration (MAGLC) or Acceptable Incremental Impact:

MAGLC XY TLV X TLV Y 5 x x   4 8 10

 Compare the one-hour averaging time ambient pollutant emissions, predicted by an appropriate air dispersion model, with the corresponding MAGLC for compliance with the air toxic’s policy.
A comprehensive list of air toxics to which the policy applies is contained in Appendix B of OAC Rule 3745-114. For these air toxics, Ohio EPA requires only those emitted above one ton per year to be subject to review. Fo r the Project, the following air toxics will be subject to “Option A” review or require a BAT determination: ammonia; formaldehyde; toluene; xylene; and sulfuric acid.
3.4 Operating Permit
OAC Rule 3745-77 specifies that a facility with an annual potential to emit equal to or exceeding any of the following thresholds is required to obtain an Operating Permit from Ohio EPA:

 CO – 100 tpy;

 PM 10 – 100 tpy;

 TSP – 100 tpy;

 SO 2 – 100 tpy;

 NO x – 100 tpy;

 VOC – 100 tpy;

 Pb – 10 tpy;

 Any other contaminant, except CO 2 – 100 tpy;

 Any single HAP – 10 tpy; andRegulatory Applicability Evaluation Page 3-9 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

 Combination of HAPs – 25 tpy.

Potential NO x , CO, VOC, and PM 10 emissions for the Project exceed the Title V Operating Permit applicability threshold, triggering t he need to apply for the Operating Permit. The Project is also required to obtain an Operat ing Permit due to the combustion turbines being subject to New Source Perf ormance Standards Subpart KKKK.
An Operating Permit application is a compr ehensive document that includes: potential to emit data for all sources across the facility; supporting information and calculations; control equipment data; a review of state and federal regulations; a description of proposed monitoring methods; fuel data; stack and vent information; a proposed compliance plan; proposed operating hours; and descriptions of normal source operation and startup and shutdown conditions for each source at the facility along with emissions data for those operating modes. Permit applications are sub mitted using the Ohio EPA Air Services system.
Pursuant to OAC rule 3745-77-04, a timely and complete Title V operating permit is required to be submitted within 12 months a fter commencing operations. As per OAC rule 3745-77-08, the state shall take final acti on on the application within 18 months of receiving a complete application. The draft permit shall be issued no later than 45 days before the aforementioned deadline for final action on the permit.
3.5 National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63)
There are no 40 CFR Part 61 standards applicabl e to the proposed facility operations. Current USEPA AP-42 emission factors, other emission factors and vendor information were reviewed in determining if the propos ed project was subject to a standard under 40 CFR Part 63. Based on potential emission calc ulations, the potential emissions of a single HAP will not exceed the major source threshold of 10 tpy. In addition, potential emissions of combined HAPs will be less than the major sour ce threshold of 25 tpy. Therefore, the major source NESHAP standards under 40 CFR Pa rt 63 are not applicable to this Project.
The USEPA has also promulgated a variety of standards applicable to area sources, those sources that are not considered major source s of HAPs. USEPA recently promulgated an area source standard for industrial, commercia l and institutional boilers. This standard does not have requirements for boilers that ar e natural gas fired. As such, the boiler associated with the proposed Project does not have any requirements under this standard.Regulatory Applicability Evaluation Page 3-10 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

3.6 Acid Rain Program

Title IV of the Clean Air Act Amendments r equired USEPA to establish a program to reduce emissions of acid rain forming pollu tants, called the Acid Rain Program. The overall goal of this program is to achiev e significant environmental benefits through reduction in SO 2 and NO x emissions. To achieve this goal, the program employs both traditional and market-based approaches for c ontrolling air pollution. Under the marketbased aspect of the program, affected units are allocated SO 2 allowances by the USEPA, which may be used to offset emissions, or traded under the market allowance program. In addition, in order to ensure that facilities do not exceed their allowances, affected units are required to monitor and report their emissi ons using a CEMS system, as approved under 40 CFR Part 75.
The Project is subject to the Acid Rain Program based on the provisions of 40 CFR 72.6(a)(3) because the turbines are consider ed utility units under the program definition and they do not meet the exemptions listed under paragraph (b) of this Section. The Project will be required to submit an acid rain permit application at l east 24 months prior to the date on which the affected unit commences op eration. OCE will submit an acid rain permit application in compliance with thes e requirements prior to this deadline.

3.7 Cross-State Air Pollution Rule
On March 10, 2005, USEPA issued the Clean Air Interstate Rule (CAIR) which requires reductions in emissions of NO x and SO 2 from large fossil fueled electric generating units using a cap and trade system. The rule provides both annual emissions budgets and an ozone season emission budget for each state. On July 11, 2008, the U.S. Court of Appeals for the D.C. Circuit (the Court) issued an opinion vacating and remanding these rules. However, on December 23, 2008, t he Court granted rehearing only to the extent that it remanded the rules to USEPA wit hout vacating them. The December 23, 2008 ruling leaves CAIR in place until the USEPA issues a new rule to replace CAIR in accordance with the July 11, 2008 provisions . On July 6, 2011, the USEPA issued the Cross-State Air Pollution Rule (CSAPR) wh ich replaced CAIR. Ohio power generation sources of 25 MW or greater would be subject to this rule. CSAPR was to go into effect January 1, 2012 and would have imposed new ca p-and-trade programs for ozone season NO x , annual NO x , and annual SO 2 emissions. However, a ruling issued by the Court on December 30, 2011 stayed CSAPR until further resolution of petitions filed by several entities. On August 21, 2012, the Court vaca ted CSPAR and ruled that the former CAIR remain in effect until a viable replacement to CSAPR is made. U nder CSAPR, electricRegulatory Applicability Evaluation Page 3-11 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

generating facilities in Ohio would have been required to obtain allowances for ozone season NO x , annual NO x , and annual SO 2 emissions.
Under CAIR, assets holding excess allowances will be able to sell or trade allowances to those without sufficient allowances. The Proj ect will comply with the rules currently in effect at the time of operational start.
3.8 State Regulations
In addition to regulations already discussed in preceding sections, state regulations that pertain to this facility are listed in Table 3-2. Titles shown in capital letters in the table are permits, notifications, and/or reports that w ill be needed for construction and operation of this facility. Table 3-2: Ohio EPA Applicable Regulations
RULE DESCRIPTION

OAC 3745-17-07 Control of visible particulate emissions from stationary sources

OAC 3745-17-10 Restrictions on particulate emissions from fuel burning equipment

OAC 3745-18-06 General emission limit pr ovisions for sulfur dioxide

OAC 3745-21-07 Control of emissions of organic materials from stationary sources

OAC 3745-21-09 Control of emissions of volatile organic compounds from stationary sources

OAC 3745-23-06 Control of nitrogen oxides emissions from stationary sources OAC 3745-25-03 Emission control action programs

OAC 3745-31 PERMIT TO INSTALL NEW SOURCES OF POLLUTION

OAC 3745-71-02 Emissions test methods and procedures for new and existing sourcesRegulatory Applicability Evaluation Page 3-12 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

RULE DESCRIPTION
OAC 3745-77 TITLE V PERMITS
OAC 3745-100 TOXIC CHEMICAL RELEASE REPORTING
OAC 3745-103 ACID RAIN PERMITS AND COMPLIANCE

OAC 3745-104 ACCIDENTAL RELEASES PREVENTION PROGRAM

Federal authority is delegated to the State of Ohio, and all permit applications will be submitted to Ohio EPA through the delegated local permitting agency. In Lucas County, the TES in Toledo, Ohio will handle these permit applications. The Permit to Install (PTI) will serve as the air construction permit and in itial operating permit for emission testing purposes. As explained in preceding sections, the following list of air permits is applicable to the proposed facility:
1) OEPA PTI: OAC Chapter 3745-31 – Pe rmit to Install New Source of Pollution. The PTI will serve as the submission vehicle for the preconstruction permit.
2) Title V Permit: OAC Chapter 3745-77 – Title V Permits
3) Acid Rain Permit: OAC Chapter 3745- 103 – Title IV Acid Rain Permits and ComplianceControl Technology Evaluation Page 4-1 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4. C ONTROL T ECHNOLOGY E VALUATION – BACT/BAT
Control technology evaluations for new major stationary sources involve an evaluation of BACT for pollutants subject to PSD pre-cons truction review and State of Ohio BAT for other pollutants not subject to PSD. A c ontrol technology analysis has been performed for the proposed facility based upon the USEP A guidance document New Source Review Workshop Manual (USEPA, 1990). The PSD and St ate of Ohio BAT requirements for each pollutant were defined in Section 3.0 of this application, and are briefly summarized in the sections below.
4.1 Regulatory Applicability of Control Requirements
This section provides a brief summary of the control technology requirements under the PSD and state of Ohio permitting programs for each pollutant. Control technology requirements are generally based on the potentia l emissions from the new or modified source and the attainment status of the area in which the source is located. A detailed determination of applicable regulatory requi rements under PSD rules are provided in Section 3.0. The following sections di scuss the applicability of BACT and BAT requirements for emissions from the equi pment associated with the project.
4.1.1 PSD Pollutants Subject to BACT/BAT
Pollutants subject to PSD review are subjec t to a BACT analysis. The proposed Project is considered a major source for PSD purposes since potential emissions exceed major source thresholds. Therefore, individual po llutants are subject to BACT requirements if their potential emissions exc eed the Significant Emission Rates presented in Table 1-1. As shown in this table, the Pr oject is subject to PSD review for the criteria pollutants: NO 2 , CO, VOC, SO 2 , H 2 SO 4 , CO 2 and PM 10 /PM 2.5 and is therefore required to implement BACT for these pollutants. Criteria pollutants fo r which BACT is not required to be implemented are subject to BAT.
As described in Section 3.3 of this report, s ources with pollutants meeting certain other standards also meet BAT. For pollutants subj ect to BACT requirements, compliance with BACT meets BAT requirements. For HAPs s ubject to MACT, compliance with MACT meets BAT requirements. For pollutants s ubject to NSPS, compliance with NSPS represents BAT. Sources subject to BAT may comply with the levels achieved by similar sources or may conduct a case-by-case BAT determination using a “top down” approach, similar to a BACT analysis. BAT for non-criteria or air toxic pollutants are addressed by anControl Technology Evaluation Page 4-2 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

“Option A” evaluation described in Section 3.3. The evaluation will be included in the Air Dispersion Report submi tted for the Project.
4.1.2 Emission Units Subject to BACT Analyses
For a facility subject to a BACT analysis, each pollutant emi tted in amounts greater than the regulatory thresholds are subject to a pre scribed level of control technology review for each emission unit that emits that pollutant. For the proposed Project, the source responsible for the majority of the Proj ect’s emissions will be the combined cycle combustion turbines with supplemental duct burni ng. Therefore, the primary focus of the BACT analyses presented in the following sect ions is on the combined cycle combustion turbines. Evaluation of the ancillary equi pment is conducted consistent with proposed small annual emission levels and with limited hours of operation.
4.2 BACT Analysis Approach
The sections below outline the approach used to conduct the BACT/BAT analyses presented in this application.
4.2.1 Best Available Control Technology
BACT is defined as the optimum level of cont rol applied to a pollutant emissions based upon consideration of energy, economic and envir onmental factors. In a BACT analysis, the energy, environmental, and economic factor s associated with each alternate control technology are evaluated, as necessary, in addition to the benefit of reduced emissions that each technology would provide. The BACT analyses presented in the following sections consist of up to four steps as outlined below.
4.2.1.1 Identification of Technically Feasible Control Options
The first step in a BACT analysis is the identif ication of technically feasible and available control technology options, including consider ation of transferable and innovative control measures that may not have been previously applied to the source type under analysis. The minimum requirement for a BACT proposal is an option that meets federal NSPS limits or other minimum state or local requirements, such as RACT or Ohio EPA emission standards. After elimination of technically infeasible control technologies, the remaining options are ranked by control effectiveness.Control Technology Evaluation Page 4-3 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

If there is only a single feasible option, or if the most stringent alternative is proposed, then no further analysis is required. Technical c onsiderations and site-spec ific sensitive issues will often play a role in BACT determinations. Generally, if the most stringent technology is rejected as BACT, the next most stringent technology is evaluated and so on.
In order to identify options for each cla ss of equipment, a search of the USEPA’s RACT/BACT/LAER Clearinghouse (RBLC) databas e was performed. Individual searches were performed for each pollutant emitted from each emission unit. The most recently issued permits from Ohio and other permits lis ted on the RBLC were also analyzed if available. Information was found for several hundred large combined cycle power plant projects permitted in the past decade. Appendi x C provides a summary of recent similar energy projects from around the country. Less recent projects were also included due to regional proximity and/or very stringent emission limits. Using these criteria, lists for each pollutant for each equipment source were compiled and are presented in Appendix C.
If two or more technically feasible options ar e identified, the next three steps (as presented below) are applied to identify and compar e the economic, energy and environmental impacts of the options.
4.2.1.2 Economic (Cost-E ffectiveness) Analysis
This analysis consists of an estimation of cost and calculation of the cost-effectiveness of each control technology, on a dollar per ton of pollution removed basis. Annual emissions with a control option are subtracted from base ca se emissions to calculate tons of pollutant controlled per year. The base case may be uncontrolled emissions or the maximum emission rate allowed with BACT considerati ons (such as an NSPS or RACT limit). Annual costs are calculated by adding annual operation and maintenance costs to the annualized capital cost of a control option. Cost -effectiveness (dollars per ton) of a control option is the annual cost (dollars per yea r) divided by the annual reduction in emissions (tpy). If either the most effe ctive control option is proposed, or if there are no technically feasible control options, an economic analysis is not required.
4.2.1.3 Energy Impact Analysis Two types of energy impacts are normally considered quantifiable. First, when the installation of a particular option would resu lt in a reduction in either the power output capacity or reliability of a unit, this reduc tion is a quantifiable energy impact. Second, the consumption of energy by the control option it self is a quantifiable energy impact. TheseControl Technology Evaluation Page 4-4 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

impacts can be quantified by either an incr ease in fuel consumption due to reduced efficiency or fuel consumption to power the equipment.
4.2.1.4 Environmental Impact Analysis The primary focus of the environmental impac t analysis is the reduction in ambient concentrations of the pollutant being emitted. Increases or decreases in emissions of other criteria or non-criteria pollutants may occur with some technologies and should be identified. Non-air related impacts such as solid waste generation, increased water consumption or waste water generation may al so be an issue associated with a control option. These additional impacts should be identified and qualitatively or quantitatively evaluated.
4.3 BACT Analysis for NO x
NO x is formed during the combustion of fuel and is generally classified as either thermal NO x or fuel-related NO x . Thermal NO x results when atmospheric nitrogen is oxidized at high temperatures to produce nitrogen oxide (NO), NO 2 , and other oxides of nitrogen. The major factors influencing the formation of thermal NO x are temperature, concentrations of oxygen in the inlet air and residence time within the combustion zone. Fuel-related NO x is formed from the oxidation of chemically bound nitrogen in the fuel. Fuel-related NO x is generally minimal for natural gas combustion. As such, NO x formation from combustion of natural gas is due mostly to thermal NO x formation.

Reduction in NO x formation can be achieved using combustion controls and/or flue gas treatment. Available combustion controls include water or steam injection and low emission combustors. Typical gas turbines are designed to operate at a nearly stoichiometric ratio of fuel in the co mbustion zone, with additional air introduced downstream. Fuel-to-air ratios below stoichiome tric are referred to as fuel-lean mixtures. This type of fuel mixture limits the formation of NO x because there is lower flame temperature with a lean fuel mixture. Usi ng this concept, lean combustors are designed to operate below the stoichiometric rati o, thereby reducing the thermal NO x formation within the combustion chamber.
The turbines proposed for the Project utilize a lean fuel technology. In addition, exhaust gases from the turbine (and duct burner) will exhaust through an SCR system (discussed below) to further reduce NO x emissions to 2.0 ppm v at 15 percent O 2 , with and without duct burning.Control Technology Evaluation Page 4-5 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

The Project will also utilize an auxiliary boiler. The auxiliary boiler will utilize flue gas recirculation and low-NO x burner technology, two combusti on optimization techniques that also reduce the formation of NO x . Using these enhanced combustion techniques, emissions from the auxiliary boiler will be limited to 0.01 lb/MMBtu.
The following discussion will demonstrate that the proposed NO x emission rates for the combined cycle turbines and auxiliary boiler are considered BACT.
4.3.1 Identification of Control Options

SCR is an add-on NO x control technology that is placed in the exhaust stream following the gas turbine/duct burner. SCR involves the injection of ammonia into the exhaust gas upstream of a catalyst bed. On the catalyst surface, NH 3 reacts with the NO x contained within the flue gas to form nitrogen gas and water in accordance with the following chemical reactions:

4NH 3 + 4NO + O 2 → 4N 2 + 6H 2 O

8NH 3 + 6NO 2 → 7N 2 + 12H 2 O
The catalyst’s active surface is usually a nobl e metal (platinum), base metal (titanium or vanadium) or a zeolite-based material. Me tal-based catalysts are usually applied as a coating over a metal or ceramic substrate. Zeolite catalysts are typically a homogeneous material that forms both the acti ve surface and the substrate. NH 3 is fed and mixed into the combustion gas upstream of the catalyst bed in greater than stoichiometric amounts to achieve maximum conversion of NO x . Excess NH 3 which is not reacted in the catalyst bed is subsequently emitted through the sta ck; this is called “ammonia slip.”
An important factor that affects the pe rformance of an SCR syst em is the operating temperature. The optimal temperature range for standard base metal catalysts is between 400°F and 800°F. Because the optimal temperature is below the CTG exhaust temperature but above the stack exhaust tem perature, the catalyst needs to be located within the HRSG.

An undesirable side effect of the use of S CR systems is the potential for formation of ammonium bisulfate and ammonium sulfate, re ferred to as ammonium salts. These salts are reaction products of SO 3 and NH 3 . Ammonium salts are corrosive and can stick to the heat exchanger surfaces, duct work or the stack at low temperatures. In addition, ammonia salts are considered PM 10 /PM 2.5 , and, therefore, increase the emissions of theseControl Technology Evaluation Page 4-6 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

criteria pollutants. Use of low sulfur fuels such as natural gas minimizes the formation of SO 3 and the subsequent formation of these ammonium salts.

4.3.2 Search of RBLC Determinations

4.3.2.1 Combustion Turbine Generators and Duct Burners

The search of the RBLC and other available permits identified several natural gas fired combined cycle combustion turbine projects. As described previously, representative projects were selected based upon recent decis ions, local proximity, or stringent limits. Details for representative facilities are presented in Appendix C. The lowest permitted NO x limit for a natural gas fired combined cycle turbine with duct burning was 2.0 ppm v at 15 percent O 2 . All of these projects use SCR syst ems in combination with combustion optimization technology such as low-NO x burners. It is our understanding that several of these projects have demonstrat ed compliance with the 2.0 ppm v emission limits under primary operating modes. Some of these projects have permit limits above 2.0 ppm v to accommodate alternative operating modes such as duct burning.
In general, BACT determinations have focused on the level that can be achieved in the primary operating mode (typically gas-fired 100 percent load), with NO x levels being set for alternative modes (duct burning, partial load, etc.) at the levels that result from application of the same degree of control used to achieve BACT in the primary mode.
4.3.2.2 Auxiliary Boiler
The RBLC and recent air permit search fo r natural gas-fired boilers between 10 and 100 MMBtu/hr in size identified close to 100 installations. NO x emission limits for these boilers widely range from approximately 0.009 lb/MMBtu to 0.08 lb/MMBtu. Details on approximately 40 of the installations that were determined to be most representative for the proposed boiler are provided in Appendix C. The projects with emission limits less than 0.011 lb/MMBtu are generally industri al/commercial boilers less than 30 MMBtu/hr that are operated continuously to support indus trial processes or other operations; these were not considered relevant to the projec t. Beyond these projects , other determinations generally proposed NO x emission limits greater than 0.03 lb/MMBtu. The most recent determination for an auxiliary boiler in Ohio proposed a NO x emission limit of 0.037 lb/MMBtu.Control Technology Evaluation Page 4-7 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4.3.3 BACT Determinations

4.3.3.1 Combustion Turbine Generators and Duct Burners
OCE is proposing a NO x emission limit of 2.0 ppm v at 15 percent O 2 (with and without duct burning) as BACT for the proposed Project. This level of emissions will be achieved through the application of DLN burners in combi nation with SCR. This emission level is consistent with the most stringent level of control found during the RBLC search and has been demonstrated in practice.
4.3.3.2 Auxiliary Boiler OCE is proposing a NO x emission limit of 0.01 lb/MMBtu. The auxiliary boiler will use flue gas recirculation in combination with low-NO x burners. These technologies, used in combination, are capable of reducing NO x emissions by 60 to 90 percent. This limit is consistent with the results from the RBLC database search.
4.4 BACT Analysis for VOC
Combustion turbines have inherently low VOC e mission rates. Emissions of VOC from a combustion turbine occur as a result of incomplete combustion of organic compounds within the fuel. In an ideal combustion pr ocess, all carbon and hydrogen contained within the fuel are oxidized to form CO 2 and water. VOC emissions can be minimized by the use of good combustion controls and add-on controls as described below.
The turbines proposed for the project will utilize good combustion controls and exhaust through an oxidation catalyst to further reduc e VOC emissions. Emissions of VOC from the exhaust stack will be limited to 1.0 ppm v at 15 percent O 2 without duct burning and 3.5 ppm v with duct burning.
The Project will also utilize an auxiliary boiler. The auxiliary boiler will utilize combustion optimization technologies to minimize incomp lete combustion and subsequent emissions of VOC. Using good combustion controls, emissions from the auxiliary boiler will be limited to 0.004 lb/MMBtu.Control Technology Evaluation Page 4-8 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4.4.1 Identification of Control Options
There are only two practical methods for controlling VOC emissions from combustion processes: efficient combustion and add-on contro l equipment. The most stringent level of control is through the use of add-on control equipment. The only post-combustion control that can be practically implemented is cataly tic oxidation. Oxidat ion catalyst systems consist of a passive reactor comprised of a grid of metal panels with a platinum catalyst. The optimal location for VOC control, in t he 900°F to 1,100°F temperature range, would be upstream of the HRSG or in the front-end sect ion of the HRSG. However, at the high temperatures necessary to make the oxidat ion catalyst optimized for VOC reduction, there is the undesirable result of causing substantially more conversion of SO 2 to SO 3 . As described previously, SO 3 may react with water and/or NH 3 to form H 2 SO 4 and/or ammonium salt (PM 10 /PM 2.5 ). Therefore, the placement of the oxidation catalyst in the “cooler” section of the HRSG, which is necessa ry for CO control, is the optimal design.
VOC emissions from the auxiliary boiler will also occur due to incomplete combustion. As such, VOC emissions are minimized by co mbustion practices that promote high combustion temperatures, long residence t imes, and turbulent mixing of fuel and combustion air. In practice, post-com bustion control methods are not routinely implemented for the reduction of VOC emissions from auxiliary boilers, as supported by the search of the RBLC determinations presented below.

4.4.2 Search of RBLC Determinations

4.4.2.1 Combustion Turbine Generators and Duct Burners

The search of the RBLC and other available permits identified many natural gas-fired combined cycle combustion turbine projects. Details for approximately 30 of these facilities have been included in Appendix C. Based on this search, use of an oxidation catalyst appears to be the most stringent leve l of VOC control for natural gas fired combined cycle turbines. VOC limits range from 0.7 ppm v to 6 ppm v . The variation in VOC concentrations between different projects is not unexpected due to differences in turbine and HRSG manufacturers and overall engineering design. Based on the review of the RBLC, BAT for VOC is utilization of an oxidati on catalyst system to achieve an outlet VOC concentration in the 1 to 3.5 ppm v range.Control Technology Evaluation Page 4-9 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4.4.2.2 Auxiliary Boiler
The RBLC and recent air permit search for natural gas fired boilers between 10 and 100 MMBtu/hr in size identified close to 100 in stallations. VOC emission limits for these installations range from approximately 0.002 lb/MMBtu to 0.08 lb/MMBtu. Details on approximately 30 of the installations that we re determined to be most applicable to the proposed boiler are provided in Appendix C.

The most recent determination in the databas e is for a commercial boiler with a VOC BACT limit of 0.0054 lb/MMBtu. Most of the boilers that operate in a similar manner to the proposed boiler also have operational restri ctions on hours. There are several determinations for auxiliary boilers at energy generating facilities in the database. The majority of the installations have emission limit s of 0.005 lb/MMBtu or greater. Based on the review of the RBLC, BAT for VOC is good combustion practices to achieve a VOC emission limit in the 0.004 to 0.005 lb/MMBtu range.

4.4.3 BACT Determinations

4.4.3.1 Combustion Turbine Generators and Duct Burners
OCE is proposing a VOC emission limit of 1.0 ppm v at 15 percent O 2 without duct burning and 3.5 ppm v at 15 percent O 2 while duct burning as BACT for the proposed Project. This level of emissions will be achieved via good co mbustion control and an oxidation catalyst.
4.4.3.2 Auxiliary Boiler OCE is proposing a VOC emission limit of 0.004 lb/MMBtu from the aux iliary boiler using good combustion practices.
4.5 BACT Analysis for CO

Emissions of CO from combustion occur as a re sult of incomplete combustion of fuel. CO emissions are minimized by the use of proper combustor design, good combustion practices and add-on controls. The combined cycl e turbines and the auxiliary boiler will be sources of CO emissions. Since the potent ial emissions from the project exceed PSD significance thresholds, BACT is required fo r CO emissions. As indicated previously, pollutants that comply with BACT meet BAT requirements.Control Technology Evaluation Page 4-10 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

The turbines proposed for the Project will utilize good combustion controls and exhaust through an oxidation catalyst to reduce CO em issions. Emissions of CO from the exhaust stack will be limited to 2.0 ppm v at 15 percent O 2 with and without duct burning.
The auxiliary boiler will utilize good combustion practices to minimize incomplete combustion and subsequent emissions of CO. Using good combustion controls, emissions from the auxiliary boiler will be limited to 0.037 lb/MMBtu.
The following discussion demonstrates that the proposed CO emission rates for the combined cycle turbines and auxiliary boiler are considered BACT.
4.5.1 Identification of Control Options
There are only two practical methods for co ntrolling CO emissions from combustion processes: efficient combustion and add-on contro l equipment. The most stringent level of control is the use of add-on equipment. The only post-combustion control that can be practically implemented is cataly tic oxidation. Oxidation ca talyst systems consist of a passive reactor comprised of a grid of metal panels with a platinum catalyst. CO reduction efficiencies in the range of 80 to 90 percent can be expected, although CO reduction may at times be less than these values due to the low inlet concentrations expected from the turbines.
CO emissions from the auxiliary boiler will also occur due to incomplete combustion. As such, combustion design that promotes high combustion temperatures, long residence times, and turbulent mixing of fuel and co mbustion air is the common practice used to minimize CO emissions. Although it is technol ogically feasible to control CO emissions from a boiler in the 10 to 100 MMBtu/hr size range using an oxidation catalyst, current combustion technology results in very low emi ssions of CO such that add-on control would not be considered cost-effective.

4.5.2 Search of RBLC Determinations

4.5.2.1 Combustion Turbine Generators and Duct Burners
The search of the RBLC available permits i dentified almost 300 natural gas fired combined cycle combustion turbine projects. Based on this search, use of an oxidation catalyst appears to be the most stringent level of control for natural gas fired combined cycle turbines.Control Technology Evaluation Page 4-11 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

CO emission limits from recently permitt ed projects generally ranged from 0.9 ppm v to 15 ppm v (or greater). The lowest CO limit found in a permit for a natural gas fired combined cycle turbine was 0.9 ppm v without duct burning and 1.8 ppm v with duct burning, issued to Kleen Energy Systems in Connecticut. While t he duct burning limit is consistent with other determinations, the 0.9 ppm v limit is an outlier. It is impor tant to note that Kleen Energy has a VOC BACT limit of 5.0 ppm v , which is significantly higher than the proposed VOC limit for the Project. This is indicative of the fa ct that it is difficult to design a system that provides a very high level of control for CO while simultaneously providing a very high level of control for VOC. As such, systems are more commonly designed to provide substantial control for both CO and VOC simultaneously. Th is is illustrated by two recent BACT/LAER determinations for proposed combined-cycle pow er plants in New Jersey. Draft permits for the Woodbridge Energy Center and the Newa rk Energy Center were issued in June 2012. Both facilities proposed CO BACT limits of 2.0 ppm v and VOC LAER limits of 1.0 ppm v (without duct burning) For these facilities, the turbine train was designed to optimize control of both CO and VOC. There are many fa cilities in the RBLC with recently permitted BACT CO emission limits of 2.0 ppm v (or greater). For exampl e, the Empire Generating and Caithness Long Island Energy projects in New York State have permit limits of 2.0 ppm v for CO, which is considered representativ e of BACT. It is our understanding that several of these facilities are operating in compliance with their 2.0 ppm v limit.
4.5.2.2 Auxiliary Boiler
The RBLC and recent air permit search fo r natural gas-fired boilers between 10 and 100 MMBtu/hr in size identified close to 100 installations. CO emission limits for these installations range from approximately 0.0073 lb /MMBtu to 0.08 lb/MMBtu. Details on approximately 30 of the installations that we re determined to be most applicable to the proposed boiler are provided in Appendix C.
The most stringent limit for an auxiliary boile r at an energy generating facility is 0.0164 lb/MMBtu at Emery Generating Station in Iowa, which was permitted in 2002. This installation is operational and it utilizes a catalytic oxidizer with an estimated control efficiency of 80 percent to achieve this emissi on rate. Since this installation, there have been many projects permitted without add-on controls that utilize good combustion practices to achieve CO control. The most re cent auxiliary boiler installation listed in the RBLC has a CO limit of 0.15 lb/MMBtu. Ther e are several other recent determinations with CO limits between 0.02 and 0.04 lb/MMBtu. These installations also utilize good combustion practices to control CO emissions.Control Technology Evaluation Page 4-12 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4.5.3 BACT Determinations

4.5.3.1 Combustion Turbine Generators and Duct Burners
OCE is proposing a CO emission limit of 2.0 ppm v at 15 percent O 2 with and without duct burning as BACT for the proposed project. This level of emissions will be achieved via good combustion control and an oxidation catalyst . This proposal is consistent with the limits and control technologies found in the RBLC and with recent BACT determinations in Ohio and in other states.
4.5.3.2 Auxiliary Boiler OCE is proposing a CO emission limit of 0.037 lb/MMBtu from the auxiliary boiler using good combustion practices. This is consistent with BACT determinations for this type of equipment.
4.6 BACT Analysis for Particulate Matter (PM 10 /PM 2.5 )
Emissions of particulate matter from combustion occur as a result of inert solids contained in the fuel, unburned fuel hydrocarbons which agglomerate to form particles, and mineral matter in water that may be injected for NO x control during diesel firing. Particulate emissions can also result from the formati on of ammonium sulfates due to the conversion of SO 2 to SO 3 , which is then available to react with ammonia to form ammonium sulfate. All of the particulate matter emitted from the turbines is conservatively assumed to be less than 2.5 microns in diameter. Therefore, PM 10 and PM 2.5 emission rates are assumed to be the same.
The combustion of clean burning fuels is t he most effective means for controlling particulate emissions from combustion equipment . The project is proposing to use natural gas as the only fuel for the turbines. Natura l gas is a very clean burning fuel with very low associated particulate emissions. OCE is not aware of any combustion turbine projects in existence that have add-on particulate control.
The turbines proposed for the project will util ize natural gas as their only fuel to minimize particulate emissions. Emissions of PM 10 /PM 2.5 from the exhaust stack will be limited to 0.0049 lb/MMBtu without duct burning and 0.0065 lb/MMBtu with duct burning.
The Project will also utilize an auxiliary boiler. The auxiliary boiler will combust only natural gas, resulting in a PM 10 /PM 2.5 emission limit of 0.005 lb/MMBtu. The cooling tower willControl Technology Evaluation Page 4-13 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

also be a source of PM 10 /PM 2.5 emissions. The Project is proposing use of a high efficiency drift eliminator (0.0005%).
The following discussion will demonstrate that the proposed PM 10 /PM 2.5 emission rates for the combined cycle turbines and auxiliary boiler are considered BACT.

4.6.1 Search of RBLC Determinations

4.6.1.1 Combustion Turbine Generators and Duct Burners

The search of the RBLC and other available permits identified over 300 natural gas fired combined cycle combustion turbine projects. Based on this search, use of clean burning fuels is the primary control for particulate e missions. Particulate matter emission limits in the RBLC database generally ranged from approx imately 0.003 lb/MMBtu to 0.3 lb/MMBtu (or greater). The lowest PM 10 /PM 2.5 limit found in a permit for an F-series natural gas fired combined cycle turbine was 0.0051 lb/MMBtu, wh ich was issued to Kleen Energy Systems in Connecticut. Similarly, Caithness Long Island Energy has a limit of 0.0055 lb/MMBtu. Beyond these examples, there are many faci lities in the RBLC with permitted BACT PM 10 /PM 2.5 emission limits in the range of 0.006 lb/MMBtu to 0.01 lb/MMBtu. Generally, all of these projects utilize cl ean burning fuel as their primary control technology and their emission limits are based upon th e overall quality of their commercial natural gas source.
4.6.1.2 Auxiliary Boiler A review of the RBLC indicates that go od combustion practices and clean burning fuels have typically been determined to be BACT for boilers. PM 10 /PM 2.5 emission limits for natural gas fired boilers vary widely, rangi ng from 0.002 lb/MMBtu through 0.6 lb/MMBtu. PM 10 /PM 2.5 emission limits for gas-fired auxiliary boilers of similar size are as low as 0.003 lb/MMBtu. The most recent listing in the RBLC for an auxiliary boiler proposed a PM 10 /PM 2.5 limit of 0.005 lb/MMBtu.
4.6.1.3 Cooling Tower
A review of the RBLC provides very few entri es for cooling towers, the most recent being in 2005. In the RBLC listings, BACT for PM 10 and PM 2.5 was determined to be utilization of a high efficiency drift eliminator with a remo val efficiency of 0.0005 percent. A removal efficiency of 0.0005 is the most effective drift eliminator commercially available.Control Technology Evaluation Page 4-14 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

4.6.2 BACT Determinations

4.6.2.1 Combustion Turbine Generators and Duct Burners
OCE is proposing a PM 10 /PM 2.5 emission limit of 0.0049 lb/ MMBtu lb/MMBtu without duct burning and 0.0065 lb/MMBtu with duct burning as BACT for the proposed project. This level of emissions will be achieved by combusting only commercially available, pipeline quality natural gas in the turbines. This emi ssion level is consistent with the limits and control technologies found in the RBLC for recent BACT determinations in Ohio and in other states.
4.6.2.2 Auxiliary Boiler OCE is proposing the exclusive use of cl ean-burning pipeline quality natural gas in conjunction with good combustion practices as BAC T for the auxiliary boiler. The Project proposes a PM 10 /PM 2.5 emission limit of 0.005 lb/MMBtu boiler using natural gas as the only fuel. This is consistent with other BACT determinations for this type of equipment.
4.6.2.3 Wet Cooling Tower
OCE is proposing use of a 0.0005 percent high ef ficiency drift eliminator as BACT and for PM 10 and PM 2.5 . This equates to hourly emission rate of 1.0 lb/hr for PM 10 and PM 2.5 . Use of high efficiency drift eliminators is consis tent with recent BACT determinations in Ohio and in other states.
4.7 BACT Analysis for Sulfur Dioxide and Su lfuric Acid

Emissions of SO 2 are formed from the oxidation of sulfur in the fuel. Normally, all sulfur compounds contained in the fuel will oxidize, and virtually all will oxidize to form SO 2 . A small percentage will oxidize to sulfur trioxide (SO 3 ) and sulfate (SO 4 ), dependent on a number of factors including: combustor design; temperature; pressure; oxygen level; and moisture level in the combustion zone and downstream in the combined-cycle system, exhaust stack, and ambient air proximate to the stack. After being formed, the SO 3 and SO 4 will react to form H 2 SO 4 and sulfate particulate. SO 2 and H 2 SO 4 emissions can be controlled using pre- and post-combustion cont rols. Pre-combustion controls involve the use of low sulfur fuels such as natural gas or ULSD. Post-combustion controls involve the use of add-on control technology such as wet and dry flue gas desulfurization (FGD) processes. Installation of such systems is an established technology principally on coalfired and high sulfur oil-fired steam electric generation stations. However, FGD systemsControl Technology Evaluation Page 4-15 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

are not practical for combustion turbines due to several factors including the large exhaust flow (and corresponding pressure drop) and the low inlet concentration in the flue gas. The use of natural gas and ULSD are t he most common methods for controlling SO 2 /H 2 SO 4 emissions from combustion turbines.
The turbines proposed for the Project will utilize natural gas as their only fuel to minimize SO 2 and H 2 SO 4 emissions. Emissions of SO 2 and H 2 SO 4 from the exhaust stack will be limited to 0.0015 lb/MMBtu and 0.0008 lb/MMBtu with and without duct burning, respectively.
The project will also utilize an auxiliary boiler. The auxiliary boiler will combust only natural gas, resulting in SO 2 and H 2 SO 4 emission limits of 0.0007 lb/MMBtu and 0.00005 lb/MMBtu, respectively.
The following discussion will demonstrate that the proposed SO 2 and H 2 SO 4 emission rates for the combined cycle turbines and auxiliary boiler are considered BACT.

4.7.1 Search of RBLC Determinations

4.7.1.1 Combustion Turbine Generators and Duct Burners

The search of the RBLC and other availabl e permits identified more than 300 natural gas fired combined cycle projects. Based on this s earch, use of low sulfur fuels is the primary control for SO 2 emissions, with emission limits being dependent upon the sulfur content of the fuel and engine design. SO 2 emission limits in the RBLC generally ranged from 0.0003 lb/MMBtu to 0.01 lb/MMBtu (or greate r). Most projects proposed limits in the range of 0.002 to 0.005 lb/MMBtu and utilized commerc ially available pipeline quality natural gas.
Similarly, a search of permits for natural gas-fired combined cycle units indicated H 2 SO 4 emissions ranging from 0.0001 lb/MMBtu to 0. 002 lb/MMBtu (or greater). Similar to SO 2 , BACT for these sources was the use of low sulfur fuels and emission limits are dependent upon the sulfur content of the fuel and engine design.
4.7.1.2 Auxiliary Boiler

A review of the RBLC indicates that com bustion of clean burning low-sulfur fuels has typically been determined to be BACT for SO 2 and H 2 SO 4 . The most stringent SO 2 emission limit for an auxiliary boiler found the RBLC was 0.0006 lb/MMBtu. The mostControl Technology Evaluation Page 4-16 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

recent project listed in the RBLC proposes an SO 2 emission limit of 0.0009 lb/MMBtu. This limit is based upon the sulfur content of the natural gas supply.

A search of the RBLC for H 2 SO 4 emissions only identified two boilers of similar size to the proposed auxiliary boiler. Of these listings, only one was for an auxiliary boiler at an energy facility. This project, CPV Saint Charles, proposed an H 2 SO 4 limit of 0.0001 lb/MMBtu.

4.7.2 BACT Determinations

4.7.2.1 Combustion Turbine Generators and Duct Burners
OCE is proposing a SO 2 emission limit of 0.0015 lb/MMBtu (with and without duct burning) as BACT for the proposed project. This level of emissions will be achieved by combusting commercially available, pipeline quality natural gas with a maximum sulfur content of 0.5 grains per 100 standard cubic foot (scf) by weight in the combustion turbines. This emission level is consistent with the limi ts and control technologies found in the RBLC.
4.7.2.2 Auxiliary Boiler OCE is proposing a SO 2 emission limit of 0.0007 lb/MMBtu as BACT for the proposed project. This is consistent with other BACT determinations for this type of equipment.
4.8 BACT Analysis for Greenhouse Gases
The principal GHGs associated with the project are CO 2 , methane (CH 4 ), and nitrous oxide (N 2 O). Because these gases differ in t heir ability to trap heat, one ton of CO 2 in the atmosphere has a different effect on warming than one ton of CH 4 or one ton of N 2 O. For example, CH 4 and N 2 O have 21 times and 298 times the global warming potential of CO 2 , respectively. GHG emissions from the pr oposed Project are primarily attributable to combustion of fuels. The Project will not have any other industrial processes releasing GHGs. By far the greatest proportion of potential GHGs emissions are from CO 2 . Trace amounts of CH 4 and N 2 O, would be emitted in varying quantities depending on operating conditions. However, emissions of CH 4 and N 2 O are negligible when compared to total CO 2 emissions, and would not be considered significant to climate change issues. In addition, as presented previously, the project is proposing to implement BACT for both VOC (expressed as CH 4 ) and NO x , such that these pollutants are being effectively controlled. As such, the remainder of this section will focus on BACT for CO 2 .Control Technology Evaluation Page 4-17 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

CO 2 is a product of combusting any carbon contai ning fuel, including natural gas. All fossil fuel contains significant amount s of carbon. During complete combustion, the fuel carbon is oxidized into CO 2 via the following reaction:

C + O 2 → CO 2
Full oxidation of carbon in fuel is desirable because CO, a product of partial combustion, has long been a regulated pollutant and because full combustion results in more useful energy. In fact, emission control technologi es required for CO emissions (oxidation catalysts) increase CO 2 emission by oxidizing CO to CO 2 . There are limited alternatives available for controlling CO 2 . The USEPA has indicated in the document, PSD and Title V Permitting Guidance for Greenhouse Gases, that carbon capture and sequestration (CCS) should be consi dered in BACT analyses as a technically feasible add-on control option for CO 2 . Currently, there are no combined cycle power plants utilizing CCS, and although theoretical ly feasible, this technology is not commercially available.
CCS requires three distinct processes:

1. Isolation of CO 2 from the waste gas stream; 2. Transportation of the captured CO 2 to a suitable storage location; and 3. Safe and secure storage of the captured and delivered CO 2 . The first step in the CCS process is capture of the CO 2 from the process in a form that is suitable for transport. There are several methods that may be used for capturing CO 2 from gas streams including chemical and physica l absorption, cryogenic separation, and membrane separation. Only physical and chemical absorption would be considered technically implementable for a high volume , low concentration gas stream. Currently, there are no combined cycle power plants utilizing CO 2 absorption systems. As such, this technology, while theoretically feasible, has not been demonstrated in practice for combined cycle facilities. Even if it were commercially available, the cost for designing, installing and operating this type of capture syst em would be prohibitive. In addition, the costs of compressing the captured CO 2 to pressures needed for transportation would result in a large parasitic load to the facilit y, reducing its efficienc y and increasing overall emissions of CO 2 and all other regulated pollutants on a per megawatt-hour basis.Control Technology Evaluation Page 4-18 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

The next step in the CCS process is transportation of the captured CO 2 to a suitable storage location. Currently CO 2 storage is available at only a very limited number of sites. Geologic conditions at the proposed project site are not suitable for carbon sequestration. OCE does not own or control any other sites that would be appropriate for CO 2 sequestration. The closest commercially available CO 2 sequestration site is in Saskatchewan Canada, over 1,700 miles from the pr oject site. Accordingly, to remain a viable control technology, captured CO 2 would have to be transported to the storage site in order to achieve any environmental benefit. Pipelines are the most common method for transporting large quantities of CO 2 over long distances. There are currently approximately 3,600 miles of existing pipeline located in the United States. However, there is no existing pipeline located near the project site. As such, a CO 2 transportation pipeline would need to be constructed to tie into the existing pipeline structure. The cost for permitting and constructing this pressurized pipeline would be economically prohibitive.
Based upon the large costs associated with the capture, transportation and storage of CO 2 , in addition to the large parasitic load, CCS is considered cost prohibitive and economically infeasible for the project.
Apart from CCS, the only other technology wi th the potential to reduce GHG from the proposed facility is pollution prevention or t he use of inherently lower-emitting processes, practices and designs. Because emissions of CO 2 are directly related to the amount of fuel combusted, an effective means of reduci ng GHG emissions is through highly efficient combustion technologies. By utilizing more e fficient technology, less fuel is required to produce the same amount of output electricity.
The Project is designed for baseload electricit y generation and will utilize state-of-the-art combustion turbine technology in combi ned cycle mode. Comb ined cycle generation takes advantage of the waste heat from the com bustion turbines, capturing that heat in the HRSG and generating steam which then powers a conventional steam turbine. Use of waste heat in this manner makes combined cycle projects considerably more efficient than conventional boiler technology.
The Project is proposing to use combustion turbines which utilize highly efficient combustion technology. In addition, the combus tion turbines will combust natural gas as their only fuel source. Other foss il fuels generate a greater amount of CO 2 per megawatthour of power produced or MMBtu of fuel cons umed. As such, using natural gas as the only fuel source effectively minimizes the production of CO 2 from combustion. The proposed project has a “Design Base Heat Ra te” of approximately 6,687 British thermalControl Technology Evaluation Page 4-19 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

units per kilowatt-hour (Btu/kW-hr), HHV at ISO conditions (59°F, 71 percent relative humidity) with no duct firing.

4.8.1.1 Search of RBLC Determinations
OCE is aware of several projects that have been issued draft or final permits incorporating GHG requirements. These projects include:

 Russell City Energy Center (final permit)

 Cricket Valley Energy Center (draft permit)

 Lower Colorado River Authority (final permit)

 Woodbridge Energy Center (draft permit)

 Newark Energy Center (draft permit)
The GHG emissions limits in these permits are based upon engine efficiency expressed as heat rate and range from 7,522 to 7,730 Btu/ kW-hr (operating at 100 percent load, ISO conditions without duct firing). Several of t hese permits also incorporate emission limits for CO 2 in lb CO 2 /MW-hr. These limits range from 887 lb CO 2 /MW-hr gross to 918 lb CO 2 /MW-hr net, while combusting natural gas.
The heat rate limits for the above referenced pr ojects incorporate a margin over the design heat rate to account for degradation over t he life of the equipment. Documentation associated with Russell City Energy Center provides a methodology for determining a reasonable estimate of degradation. The Bay Area Air Quality Management District (BAAQMD) in California issued a permit in February 2010 for the Russell City Energy Center that included a BACT limit. Russell Ci ty is a proposed combined-cycle generating facility with a nominal c apacity of 600 MW utilizing two Siemens F-class combustion turbines. In its analysis, the BAAQMD evaluated factors that could be reasonably expected to degrade the theoretical design effi ciency of the turbines and increase the heat rate. They considered a number of factors including:

 A design margin to reflect that the equipment as constructed and installed may not fully achieve the assumptions that went into the design calculations;

 A reasonable performance degradation margin to reflect normal wear and tear; and

 A reasonable degradation margin based on normal wear and tear caused by variability in the operation of the auxiliary plant equipment.Control Technology Evaluation Page 4-20 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Based on their analysis, BAAMD concluded that 12.8 percent was a reasonable compliance margin to add to the design base heat rate to develop a numerical BACT limit. BACT Determination
The turbines operating in combined-cycle mode proposed for the Project have a design base heat rate of approximately 6,687 Btu/kW-hr at ISO HHV conditions with no duct firing. This value is superior to the efficiency pr oposed in the Russell City Energy Center BACT analysis and Cricket Valley Energy design bas e heat rate. Based upon this design, and adding a reasonable margin of compliance c onsistent with the BAAQMD analysis for Russell City Energy Center, OCE is pr oposing the following limits as BACT:

 7,409 Btu/kW-hr HHV (ISO condi tions without duct firing);and

 896 lb CO 2 /MW-hr gross (ISO conditions while firing natural gas).
These limits are consistent with recently permitted projects and can reasonably be assured under all operating scenarios. This level of emissions will be achieved through utilization of high efficiency, state-of-the-art, com bustion turbine technology and combusting only commercially available, pipeline quali ty natural gas in the turbines.
4.9 Emission Limit and Control Technology Summaries
Tables 4-1 and 4-2 summarize the propos ed emission limits and associated control technology for the Project.Control Technology Evaluation Page 4-21 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 4-1: Summary of Proposed BACT/ BAT Emission Limits and Associated Control Technologies for the Combustion Turbines

Pollutant Emission Rate (lb/MMBtu) Emission Rate (ppm v )

at 15% O 2 Control Technology Represents NO x CT only CT w/ DB 0.0076 0.0077 2.0 2.0 DLN and SCR BACT/BAT

VOC CT only CT w/ DB 0.0013 0.0048 1.0 3.5 Good combustion controls and oxidation catalyst BACT/BAT

CO CT only CT w/ DB 0.0048 0.0048 2.0 2.0 Good combustion controls and oxidation catalyst BACT/BAT

PM 10 /PM 2.5

CT only CT w/ DB 0.0049 0.0065 n/a n/a Low sulfur fuel BACT/BAT

SO 2 CT only CT w/ DB 0.00015 0.00015 n/a n/a Low sulfur fuel BACT/BAT

H 2 SO 4 CT only CT w/ DB 0.0008 0.0008 n/a n/a Low sulfur fuel BACT/BATControl Technology Evaluation Page 4-22 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

Table 4-2: Summary of Proposed BACT/ BAT Emission Limits and Associated Control Technologies for the Auxiliary Boiler

Pollutant Emission Rate (lb/MMBtu) Control Technology Represents NO x 0.01 LNG and FGR BACT/BAT

VOC 0.004 Good combustion controls BACT/BAT

CO 0.037 Good combustion controls BACT/BAT

PM 10 /PM 2.5 0.005 Low sulfur fuel BACT/BAT

SO 2 0.0007 Low sulfur fuel BACT/BATReferences Page 5-1 PSD Permit Application Oregon Clean Energy Center Lucas County, OH

5. R EFERENCES
CARB, 1996. California Air Toxics Emi ssion Factor Database (CATEF) 1996. USEPA, 1990. New Source Review Workshop Manual (Draft) . October 1990. USEPA, 1993. Alternative Control Techniques Document – NOx Emissions from Stationary Reciprocating Internal Combustion Engines. Office of Air and Radiation. EPA-453/R-93-032. July 1993. USEPA, 2000. Compilation of Air Pollutant Emission Factors AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources

. USEPS, 2010. “ PSD and Title V Permitting Guidance for Greenhouse Gases ”, Office of Air Quality Planning and Standards, November 2010 VCAPCD, 2001. AB2588 Combustion Emission Factors 2001.

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# ICity: Chicago Author: MNesta Path: G:\Aproject\GIS\OCE\MXD\OCE_ProjectLocation.mxd Legend Property Boundary Project Facilities PROJECT LOCATION

FIGURE 1 OREGON CLEAN

ENERGY, LLC

Lucas County, Ohio PROJECT LOCATION LUCAS COUNTY, OHIO

Date: 08/17/2012 Topographic Base Image Source: ArcGIS Online Services, Access date: 08/17/2012, via ArcGIS v. 10. This image is not for re-sale or distribution outside of the use of this PDF. PROPERTY

## Appendix A: Printout of Ohio EPA Permit Forms

### PTI/PTIO Application A0045417 Oregon Clean Energy Center

0448020102 August 23, 2012

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 

### Division of Air Pollution Control Aug 23 2012, 15:04:46 Application for Permit-to-Install or Permit-to-Install and Operate This section should be filled out for each permit to install (PTI) or Permit to Install and Operate (PTIO) application. A PTI is required for all air contaminant sources (emissions units) installed or modified after January 1, 1974 that are subject to OAC Chapter 3745-77. A PTIO is required for all air contaminant sources (emissions units) that are not subject to OAC Chapter 3745-77 (Title V). See the application instructions for additional information.

For OEPA use only: x Installation x Request Federally enforceable restrictions Modification General Permit Renewal Other Please summarize the reason for this permit application. This text will be in the public notice that will appear in the newspaper of the county where the facility is located.
A permit-to-install (PTI) application is being submitted for the construction of the Oregon Clean Energy Center - a nominal 800 megawatt (MW) combined cycle gas turbine (CCGT) facility to be located in the City of Oregon, Lucas County, Ohio. Is the purpose of this application to transition from OAC Chapter 3745-77 (Title V) to OAC Chapter 3745-31 (PTIO)?
No Establish PER Due Date - Select an annual Permit Evaluation Report (PER) due date for this facility (does not apply to facilities subject to Title V, OAC Chapter 3745-77). If the PER has previously been established and a change is now desired, a PER Change Request form must be filed instead of selecting a date here. 

### PER not applicable (Title V) or due date already established Federal Rules Applicability
New Source Performance Standards (NSPS) New Source Performance Standards are listed under 40 CFR 60 - Standards of Performance for New Stationary Sources. Subject to subpart:
Dc - Small Industrial Steam Generating Units IIII - Stationary Compression Ignition Internal Combustion Engines KKKK - Stationary Combustion Turbines

National Emission Standards for Hazardous Air Pollutants (NESHAP) National Emissions Standards for Hazardous Air Pollutants are listed under 40 CFR 61. (These include asbestos, benzene, beryllium, mercury, and vinyl chloride). Not affected

Maximum Achievable Control Technology (MACT) The Maximum Achievable Control Technology standards are listed under 40 CFR 63 and OAC rule 3745-31-28. Not affected

Prevention of Significant Deterioration (PSD) These rules are found under OAC rule 3745-31-10 through OAC rule 3745-31-20. Subject to Regulation

Non-Attainment New Source Review These rules are found under OAC rule 3745-31-21 through OAC rule 3745-31-27. Not affected

112 (r) - Risk Management Plan These rules are found under 40 CFR 68. Not affected
Title IV (Acid Rain Requirements) These rules are found under 40 CFR 72 and 40 CFR 73. Subject to Regulation
Express PTI/PTIO - Do you qualify for express PTI or PTIO processing?
No Air Contaminant Sources in this Application - Identify the air contaminant source(s) for which you are applying below. Attach additional pages if necessary. Section II of this application and an EAC form should be completed for each air

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 contaminant source.

Emissions Unit ID Company Equipment ID (company's name for air contaminant source) Equipment Description (List all equipment that are a part of this air contaminant source) TMP173331 CTG #1 TMP173332 CTG #2 TMP173333 Auxiliary Boiler TMP173334 Emergency Generator TMP173335 Emergency Fire Pump TMP173336 Wet Cooling Tower
The Emissions Unit ID would have been created when a previous air permit was issued. If no previous permits have been issued for this air contaminant source, leave this field blank. If this air contaminant source was previously identified in STARShip applications as a Z source (e.g., Z001), please provide that identification and a new ID will be assigned when the PTI/PTIO is issued. Trade Secret Information - Is any information included in this application being claimed as a trade secret per Ohio Revised Code (ORC) 3704.08?
No Permit Application Contact - Person to contact for questions about this application:

Lynn Gresock ARCADIS, US Inc. Name Title One Executive Drive, Suite 303 Chelmsford, MA 01824
Street Address City/Township, State Zip Code 9783224520 lynn.gresock@ARCADISUS.COM Phone Fax E-mail

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173331 Company Equipment ID: CTG #1 One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 19 19 83.2 19 83.2

PM # 10 microns in diameter (PE/PM10) 19 19 83.2 19 83.2
PM # 2.5 microns in diameter (PE/PM2.5) 19 19 83.2 19 83.2
Sulfur dioxide (SO2) 4.6 4.6 20.1 4.6 20.1 Nitrogen oxides (NOx) 460 23 100.7 23 100.7 Carbon monoxide (CO) 140 14 80.2 14 80.2 Organic compounds (OC) 130 13 59.3 13 59.3 Volatile organic compounds (VOC) 130 13 59.3 13 59.3

Lead (Pb) 0 0 0 0 0 Total Hazardous Air Pollutants (HAPs) 10.3 1.03 4.50 1.03 4.50

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 Highest single HAP 3 0.3 1.34 0.3 1.34 

### Hazardous Air Pollutants (HAPs):

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Toluene 3 0.3 1.3 0.3 1.3 Formaldehyde 3 0.3 1.34 0.3 1.34 Sulfuric Acid 2.47 2.47 10.8 2.47 10.8 Ammonia 21 21 92 21 92 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:
See Section 4 - BACT/BAT analysis of the permit application document Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
No Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public DocumentOregon Clean Energy Center - 0448020102 Page 3 PTI/PTIO Application - A0045417 Id CTG #1 EAC 3862 Stationary Internal Combustion Engine (2003) 628322

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173332 Company Equipment ID: CTG #2 One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 19 19 83.2 19 83.2

PM # 10 microns in diameter (PE/PM10) 19 19 83.2 19 83.2
PM # 2.5 microns in diameter (PE/PM2.5) 19 19 83.2 19 83.2
Sulfur dioxide (SO2) 4.6 4.6 20.1 4.6 20.1 Nitrogen oxides (NOx) 460 23 100.7 23 100.7 Carbon monoxide (CO) 140 14 80.2 14 80.2 Organic compounds (OC) 130 13 59.3 13 59.3 Volatile organic compounds (VOC) 130 13 59.3 13 59.3

Lead (Pb) 0 0 0 0 0 Total Hazardous Air Pollutants (HAPs) 10.3 1.03 4.5 1.03 4.5

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 Highest single HAP 3 0.3 1.34 0.3 1.34 

### Hazardous Air Pollutants (HAPs):

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Toluene 3 0.3 1.3 0.3 1.3 Formaldehyde 3 0.3 1.34 0.3 1.34 Sulfuric Acid 2.47 2.47 10.8 2.47 10.8 Ammonia 21 21 92 21 92 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:
See Section 4 - BACT/BAT analysis of the permit application document Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
No Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public DocumentOregon Clean Energy Center - 0448020102 Page 3 PTI/PTIO Application - A0045417 Id CTG #2 EAC 3862 Stationary Internal Combustion Engine (2003) 628323

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173333 Company Equipment ID: Auxiliary Boiler One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 0.45 0.45 1.97 0.45 1.97

PM # 10 microns in diameter (PE/PM10) 0.45 0.45 1.97 0.45 1.97
PM # 2.5 microns in diameter (PE/PM2.5) 0.45 0.45 1.97 0.45 1.97
Sulfur dioxide (SO2) 0.06 0.06 0.28 0.06 0.28 Nitrogen oxides (NOx) 0.9 0.9 3.94 0.9 3.94 Carbon monoxide (CO) 3.33 3.33 14.59 3.33 14.59 Organic compounds (OC) 0.36 0.36 1.58 0.36 1.58 Volatile organic compounds (VOC) 0.36 0.36 1.58 0.36 1.58

Lead (Pb) 0 0 0 0 0 Total Hazardous Air Pollutants (HAPs) 0.008 0.008 0.04 0.008 0.04

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 Highest single HAP 0.007 0.007 0.029 0.007 0.029 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:
See Section 4 - BACT/BAT analysis of the permit application document Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
No Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Aux. Boiler EAC EAC 3101 Fuel burning operation (2003) 627123

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173334 Company Equipment ID: Emergency Generator One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 0.66 0.66 0.17 0.66 0.17

PM # 10 microns in diameter (PE/PM10) 0.66 0.66 0.17 0.66 0.17
PM # 2.5 microns in diameter (PE/PM2.5) 0.66 0.66 0.17 0.66 0.17
Sulfur dioxide (SO2) 0.02 0.02 0.01 0.02 0.01 Nitrogen oxides (NOx) 18.53 18.53 4.63 18.53 4.63 Carbon monoxide (CO) 11.56 11.56 2.89 11.56 2.89 Organic compounds (OC) 2.62 2.62 0.65 2.62 0.65 Volatile organic compounds (VOC) 2.62 2.62 0.65 2.62 0.65

Lead (Pb) 1.97E-04 1.97E-04 4.93E-05 1.97E-04 4.93E-05 Total Hazardous Air Pollutants (HAPs) 0.008 0.008 0.002 0.008 0.002

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 Highest single HAP 0.002 0.002 0.0006 0.002 0.0006 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:

N/A Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
Yes If yes, why are you requesting federally enforceable limits? Avoid another requirement Describe:
Restricted to 500 hrs/year of operation to comply with Ohio EPA requirements for emergency operation Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Emergency Generator EAC EAC 3862 Stationary Internal Combustion Engine (2003) 628324

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Oregon Clean Energy Center - 0448020102 Page 3 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173335 Company Equipment ID: Emergency Fire Pump One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 0.07 0.07 0.02 0.07 0.02

PM # 10 microns in diameter (PE/PM10) 0.08 0.08 0.02 0.08 0.02
PM # 2.5 microns in diameter (PE/PM2.5) 0.08 0.08 0.02 0.08 0.02
Sulfur dioxide (SO2) 0.00 0.00 0.00 0.00 0.00 Nitrogen oxides (NOx) 1.44 1.44 0.36 1.44 0.36 Carbon monoxide (CO) 1.44 1.44 0.36 1.44 0.36 Organic compounds (OC) 0.2 0.2 0.05 0.2 0.05 Volatile organic compounds (VOC) 0.2 0.2 0.05 0.2 0.05

Lead (Pb) 2.45E-05 2.45E-05 6.13E-06 2.45E-05 6.13E-06 Total Hazardous Air Pollutants (HAPs) 0.008 0.008 0.002 0.008 0.002

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Highest single HAP 0.002 0.002 0.0006 0.002 0.0006 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:

N/A Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
Yes If yes, why are you requesting federally enforceable limits? Avoid another requirement Describe:
500 hour/year operational restriction to satisfy Ohio EPA requirement for emergency operation Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Emergency Fire Pump EAC EAC 3862 Stationary Internal Combustion Engine (2003) 628325

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Oregon Clean Energy Center - 0448020102 Page 2 PTI/PTIO Application - A0045417 Section II - Specific Air Contaminant Source Information Facility ID: 0448020102 Emissions Unit ID: TMP173336 Company Equipment ID: Wet Cooling Tower One copy of this section should be filled out for each air contaminant source (emissions unit) covered by this PTI/PTIO application identified in Section I, Question 5. See the application instructions for additional information. Air Contaminant Source Installation or Modification Schedule Check all that apply (must be completed regardless of date of installation or modification): New installation (for which construction has not yet begun, in accordance with OAC rule 3745-31-33). When will you begin to install the air contaminant source? after installation permit has been issued SCC Codes - List all Source Classification Code(s) (SCC) that describe the process(es) performed by this air contaminant source (e.g., 1-02-002-04). See Facility Profile Emissions Information - The following table requests information needed to determine the applicable requirements and the compliance status of this air contaminant source with those requirements. Suggestions for how to estimate emissions may be found in the instructions to the Emissions Activity Category (EAC) forms required with this application. If you need further assistance, contact your District Office/Local Air Agency representative. If total potential emissions of HAPs or any Toxic Air Contaminant (as identified in OAC rule 3745-114-01) are greater than 1 ton/yr, fill in the table for that (those) pollutant(s). For all other pollutants, if Emissions before controls (max), lb/hr multiplied by 24 hours/day is greater than 10 lbs/day, fill in the table for that pollutant. Actual emissions are calculated including add-on control equipment. If you have no add-on control equipment, Emissions before controls will be the same as Actual emissions. Actual emissions and Requested Allowable should be based on operating 8760 hr/yr unless you are requesting federally enforceable operating restrictions to limit emissions. If so, calculate emissions based on requested operating restrictions and describe in your calculations. If you use units other than lbs/hr or ton/yr, specify the units used (e.g., gr/dscf, lb/ton charged, lb/MMBtu, tons/12- months). Requested Allowable (ton/yr) is often equivalent to Potential to Emit (PTE) as defined in OAC rule 3745-31-01 and OAC rule 3745-77-01.

Pollutant Emissions before controls (max)* (lb/hr) Actual

emissions (lb/hr) Actual

emissions (ton/year) Requested

Allowable (lb/hr) Requested

Allowable (ton/year) Particulate emissions (PE/PM) (formerly particulate matter, PM) 1.00 1.00 4.39 1.00 4.39

PM # 10 microns in diameter (PE/PM10) 1.00 1.00 4.39 1.00 4.39
PM # 2.5 microns in diameter (PE/PM2.5) 1.00 1.00 4.39 1.00 4.39
Sulfur dioxide (SO2) 0 0 0 0 0 Nitrogen oxides (NOx) 0 0 0 0 0 Carbon monoxide (CO) 0 0 0 0 0 Organic compounds (OC) 0 0 0 0 0 Volatile organic compounds (VOC) 0 0 0 0 0

Lead (Pb) 0 0 0 0 0 Total Hazardous Air Pollutants (HAPs) 0 0 0 0 0

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Oregon Clean Energy Center - 0448020102 Page 1 PTI/PTIO Application - A0045417 Highest single HAP 0 0 0 0 0 Best Available Technology (BAT) - For each pollutant for which the Requested Allowable in the above table exceeds 10 tons per year, BAT, as defined in OAC 3745-31-01, is required. Describe what has been selected as BAT and the basis for the selection:

Drift Eliminators Control Equipment - Does this air contaminant source employ emissions control equipment? See Facility Profile Process Flow Diagram - Attach a Process Flow Diagram to this application for this air contaminant source. See the application instructions for additional information. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Process Flow Diagram_Rev Process flow diagram 628569
Modeling information: (Note: items in bold in Tables 7-A and/or 7-B, as applicable, are required even if the tables do not otherwise need to be completed. If applicable, all information is required An air quality modeling analysis is required for PTIs and PTIOs for new installations or modifications, as defined in OAC rule 3745-31-01, where either the increase of toxic air contaminants from any air contaminant source or the increase of any other pollutant for all air contaminant sources combined exceed a threshold listed below. This analysis is to assure that the impact from the requested project will not exceed Ohios Acceptable Incremental Impacts for criteria pollutants and/or Maximum Allowable Ground Level Concentrations (MAGLC) for toxic air contaminants. (See Ohio EPA, DAPCs Engineering Guide #69 for more information.) Permit requests that would have unacceptable impacts cannot be approved as proposed. See the line-by-line PTI/PTIO instructions for additional information. See Facility Profile Request for Federally Enforceable Limits - As part of this permit application, do you wish to propose voluntary restrictions to limit emissions in order to avoid specific requirements listed below, (i.e., are you requesting federally enforceable limits to obtain synthetic minor status)?
No Continuous Emissions Monitoring Does this air contaminant source utilize any continuous emissions monitoring (CEM) equipment for indicating or demonstrating compliance? This does not include continuous parametric monitoring systems. See Facility Profile EAC Forms The appropriate Emissions Activity Category (EAC) form(s) must be completed and attached for each air contaminant source. At least one complete EAC form must be submitted for each air contaminant source for the application to be considered complete. Refer to the list attached to the application instructions. Please indicate which EAC form corresponds to this air contaminant source. Process Flow Diagrams:

Description Type EAC Form Type Public Document Id Cooling Tower Process Operation EAC 3100 Process operation (2003) 627128

### Facility Profile Report Facility Name: Oregon Clean Energy Center

ID: 0448020102

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Page 1 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Facility : 0448020102 Aug 23 2012, 15:04:46 Facility Information

Facility ID: 0448020102 FacilityName: Oregon Clean Energy Center Facility Description: 800 MW combined cycle gas turbine (CCGT) facility

Address1: 816 Lallendorf Rd Address2: City: Oregon State: Ohio Zip Code: 43616

Portable: Operating Status: Not Installed Permitting Classification: NONE PER Due Date: None Transitional Status: None Title V Permit Status: None Title V Certification Report Due Date:
Anticipated Emissions Reporting

Category for 2012: NONE

Core Place ID: 313477

Latitude: 41.667587 Longtitude: -83.44293 Yearly Emissions Reporting Category

Year Category Enabled Status SIC Codes

NAICS Codes

221112 Fossil Fuel Electric Power Generation Contacts
Contact Type Contact Person Phone Number Email Start Date End Date Federal Rules Applicability

Subject to MACT: Subject to PSD: Subject to NESHAPS: Subject to non-attainment NSR: Subject to NSPS: Subject to 112(r): Subject to Title IV:

### -

-

Page 2 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173331 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173331 DAPC Description: Company Equipment ID: CTG #1 Company Description: One combustion turbine generator exhausting through a dedicated Heat Recovery Steam Generator (HRSG). The HRSG will generate steam from the waste heat energy in the exhaust gas. Each HRSG will be equipped with supplemental fuel firing via a duct burner. The duct burner provides additional energy to the HRSG, which produces more steam that can be fed to the steam turbine generator (STG). Steam generated in the HRSG will be expanded through a STG multi-stage, reheat, condensing turbine and associated electric generator to generate additional electricity Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Non-insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Turbine ORIS Boiler ID:

Processes

### -

-

Page 3 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173332 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173332 DAPC Description: Company Equipment ID: CTG #2 Company Description: One combustion turbine generator exhausting through a dedicated Heat Recovery Steam Generator (HRSG). The HRSG will generate steam from the waste heat energy in the exhaust gas. Each HRSG will be equipped with supplemental fuel firing via a duct burner. The duct burner provides additional energy to the HRSG, which produces more steam that can be fed to the steam turbine generator (STG). Steam generated in the HRSG will be expanded through a STG multi-stage, reheat, condensing turbine and associated electric generator to generate additional electricity Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Non-insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Turbine ORIS Boiler ID:

Processes

### -

-

Page 4 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173333 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173333 DAPC Description: Company Equipment ID: Auxiliary Boiler Company Description: 90 MMBtu/hr auxiliary boiler operated as needed to keep the HRSG warm during periods of turbine shutdown and provide sealing steam to the steam turbine during warm and hot starts. Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Non-insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Boiler/Heater ORIS Boiler ID:

Processes

### -

-

Page 5 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173334 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173334 DAPC Description: Company Equipment ID: Emergency Generator Company Description: 1,500 kW emergency diesel-fired generator to provide on-site emergency power capabiities independent of the utility grid Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Not Applicable Design Capacity Units:

ORIS Boiler ID: Processes

### -

-

Page 6 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173335 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173335 DAPC Description: Company Equipment ID: Emergency Fire Pump Company Description: 250 hp emergency diesel-fired firepump to provide on-site fire fighting capabilities independent of the utility grid Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Not Applicable Design Capacity Units:

ORIS Boiler ID: Processes

### -

-

Page 7 Facility Profile Report (0448020102): Oregon Clean Energy Center 

### Emission Unit : TMP173336 Aug 23 2012, 15:04:46 Emission Unit Information

DAPC Emissions Unit ID: TMP173336 DAPC Description: Company Equipment ID: Wet Cooling Tower Company Description: 12- Cell Wet Cooling Tower equipped with a high efficiency drift eliminator Operating Status: Not Installed Completion of Initial Installation Date: 04/30/2016 Begin Installation/Modification Date: 10/01/2013
Commence Operation After Installation or Latest Modification Date:

Title V EU Classification: Non-insignificant Exemption Status: NA Boiler/Turbine/Generator Design Capacity: Not Applicable Design Capacity Units:

ORIS Boiler ID: ProcessesCity:ChicagoAuthor:MNestaPath:G:\Aproject\GIS\OCE\MXD\OCE_ProcessFlow.mxd

O R E G O N C L E A N E N E R G Y , L L C

L u c a s C o u n t y , O h i o P R O C E S S F L O W D I A G R A M

D a t e : 0 8 / 1 7 / 2 0 1 2EPA FORM 3101

– REV2005 Page 1 FOR OHIO EPA USE FACILITY ID: ___________________________ EU ID: _______________ PTI #:__________________ 

## EMISSIONS ACTIVITY CATEGORY FORM FUEL BURNING OPERATION This form is to be completed for each fuel burning operation. State/Federal regulations which may apply to fuel burning operations are listed in the instructions. Note tha t there may be other regulations which apply to this emissions unit which are not included in this list

1. Reason this form is being submitted (check one)
New Permit Renewal or Modification of Air Permit Number(s) (e.g. B001)

________ 2. Maximum Operating Schedule:

__ 24

______ hours per day;

_ 365

___ days per year If the schedule is less than 24 hours/day or 365 days/year, what limits the schedule to less than maximum? See instructions for examples.

______________________________ 3. Input Capacity (million Btu/hr):

Rated (Indicate units if other than mmBtu/hr) 

### Maximum (Indicate units if other than mmBtu/hr) 

### Normal (Indicate units if other than mmBtu/hr) 

### 90 90 90

4. Output Capacity:

Rated (lb steam/hr) 

### Maximum (lb steam/hr) 

### Normal (lb steam/hr)



### Not applicable

- operation does not produce steam.
5. Percent of Operating Time Used for:
Process:

____ 100

___ % Space Heat:

_______ %
6. Type of Draft (c heck one):
Natural Induced Forced
7. Type of combustion monitoring (check one):
Fuel/Air Ratio Oxygen None Other (descri be)

______________________________EPA FORM 3101

– REV2005 Page 2 

### 8. Type of Fuel Fired (complete all that apply): Fuel* Fired as... Min. Heat Content (Btu/unit) Max. % Ash Max. % Sulfur Max. Annual Fuel Use Average Hourly Fuel Use Maximum Hourly Fuel Use

Coal Primary Backup tons lbs lbs No. 2 Fuel Oil Primary Backu p gal gal gal No. 6 Fuel Oil Primary Backup gal gal gal Other** Oil Primary Backup gal gal gal Natural Gas Primary Backup 1050 Btu/scf 751 MM ft 3 0.09 MM ft 3 0.09 MM ft 3
Wood Primary Backup tons lbs lbs LPG Primary Backup gal gal gal Other** Primary Backup Other** Primary Backup


### * Please i dentify all combinations of fuels that are co

- fired:

_______________________________ ** Identify other fuel(s):

_______________________________ Coal
- Fired Units 9. Type of Coal Firing (check one):
Pulver ized

- Wet Bottom Hand

- Fired Chain Grate Traveling Grate Pulverized

- Dry Bottom Cyclones Spreader Stoker Fluidized Bed Underfeed Stoker Other (describe)

_________________________________ 10. Flyash Reinjection:
Yes No
11. Overfire Air:
Yes No
Oil
- Fired Uni ts 12. Oil Preheater:
Yes

- Indicate Temperature

_______ deg. F NoEPA FORM 3100

– REV2005 1 of 2 FOR OHIO EPA USE FACILITY ID:_____________________________________
EU ID: PTI #: 

## EMISSIONS ACTIVITY CATEGORY FORM GENERAL PROCESS OPERATION This form is to be completed for each process operation when there is no specific emissions activity category (EAC) form applicable. If there is more than one end product for this process, copy and complete this form for each additional product (see instructions). Several State/Federal regulations which may apply to process operations are listed in the instructions. Note that there may be other regulations which apply to this emissions unit which are not included in this list.

1. Reason this form is being submitted (Check one)
New Permit Renewal or Modificatio n of Air Permit Number(s) (e.g. P001)

______ _________ 2. Maximum Operating Schedule: 24 hours per day ; 365 days per year If the schedule is less than 24 hours/day or 365 days/year, what limits the schedule to less than maximum? See instructions for examples.

___ ____________________________ 3. End product of this process: Cooling water
4. Hourly production rates (indicate appropriate units). Please see the instructions for clarification of “Maximum” and “Average” for new versus existing operations:

Minute Rate Units (e.g., widgets) Average production 133,700 Gallon Maximum production

5. Annual production rates (indicate appropriate units) Please see the instructions for clarification of “Maximum” and “Actual” for new versus existing operations:

Annual Rate Units (e.g., widgets) Actual production Maximum productionEPA FORM 3100

– REV2005 2 of 2 

### 6. Type of operation (please check one):
Continuous Batch (please complete items below) Minimum cycle* time (minutes):

_________ Minimum time between cycles (minutes):

_________ Maximum number of cycles per daily 24 hour period:

_________ (Note: include cycle time and set up/clean up time.)

* ”Cycle” refers to the time the equipm ent is in operation



### . 7. Materials u sed in process at maximum production rate (add rows/pages as needed):

Material Physical State at Standard Conditions Principle Use Amount**



### Water Liquid Cooling 133,700 gpm

** Please indicate the amount and rate (e.g., lbs/hr, gallons/hr, lbs/cycle, etc.)



### . 8. Please provide a narr ative description of the process below (e.g., coating of metal parts using high VOC content coatings for the manufacture of widgets; emissions controlled by thermal oxidizer...):

_________________________________________________________ __________________

___ See Section 2.3.4 of PTI Application Package

_________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________ ________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

__________________ ______________________________________________________________EPA FORM 3862

- REV2005 Page 1 

## EMISSIONS ACTIVITY CATEGORY FORM STATIONARY INTERNAL COMBUSTION ENGINE This form is to be completed for each stationary reciprocating or gas turbine engine. State/Federal regulations which may apply to stationary internal combustion engines are lis ted in the instructions. Note that there may be other regulations which apply to this emissions unit which are not included in this list. 1. Reason this form is being submitted (Check one)
New Permit Renew al or Modification of Air Permit Number (e.g. P001)

__________ 2. Maximum Operating Schedule:

__ 8,760

_____ hours per day;

_ 365

____ days per year If the schedule is less than 24 hours/day or 365 days/year, what limits the schedule to less than maximum? See instructions for examples.

_____________________________________________

3. Engine type: Gas turbine Reciprocating
4. Purpose of engine: Driving pump or compressor Driving electrical generator
5. Normal use of engine: Emergency only Non

- emergency
6. Engine Manufacturer:

___ TBD

_________________ Model No:

___ TBD

_________________ 7. Engine exhaust configuration: simple cycle (no heat recovery) (for turbines only) 

### regenerative cycle (hea t recovery to preheat combustion air) cogeneration cycle (heat recovered to produce steam) combined cycle (heat recovered to produce steam which drives generator)
8. Input capacities (million BTU/hr): Rated

________ Maximum

__ 2 , 277

______ Normal

_______ Supplemental burner (duct burner) input capacity, if equipped (million BTU/hr):
Rated:

_________ Maximum

___ 841

__ Normal

___________

9. Output capacities (Horsepower): Rated:

_________ Maximum

___________ Normal

___________ (Kilowatts): Rated:

_ 800,000

_ Maximum

_ 846,300

_ Normal

_________ __ (lbs steam/hr)*: Rated:

__ 75,000

____ Maximum

__ 75,000

__ Normal

___________ FOR OHIO EPA USE FACILITY ID: _________________ EU ID: _______ PTI#:__________EPA FORM 3862

- REV2005 Page 2 

### * required for cogeneration or combined cycle units only


### 10. Type of ignition: non - spark (diesel) spark
11. Type of fuel fired (check all that apply): single fuel No. 2 oil, low

- sulfur natural gas landfill gas dual fuel No. 2 oil, high

- sulfur diesel digester gas gasoline propane other, explain

______________________________________________

12. Complete the following table for all fuels identified in question 11 that are used for the engine and any supplemental (duct) burners, if equipped:

wt.% wt.% Fuel Usage
Fuel Heat Content (BTU/unit) Ash Sulfur Estimated Maximum Per Year Normal Per Hour Max. Per Ho ur
Nat. gas 1,050 BTU/cu ft 0. 005 gr/scf 25,283 MM cu ft cu ft 2.9 MM cu ft No. 2 oil BTU/gal gal gal gal Gasoline BTU/gal gal gal gal

Diesel BTU/gal gal gal gal Landfill/d igester gas BTU/cu ft ppm cu ft cu ft cu ft Other (show units) List supplemental (duct) burner fuel and information below (show units):



### 13. Type of combustion cycle (check all that apply):
2

- stroke 4

- stroke rich

- burn lean

- burn carbureted fuel injected other, explain

________________________________________________ 14. Emissions control techniques (check all that apply): prestratified charge nonselective catalytic reduction (NSCR) catalytic oxidation (CO) selective catalytic reduction (SCR) air/fuel ratio injection timing retard (ITR) 2

- stage rich/lean combustion 2

- stage lean/lean combustion water/steam injection preignition chamber combustion (PCC) other, explain

_____________________________________________ ___ For each emissions control technique checked above, explain what pollutants are controlled by each technique:EPA FORM 3862

- REV2005 Page 3 

### Catalytic oxidation will control VOCs and CO. Selective Catalytic Reduction (SCR) will control NOxEPA FORM 3862

- REV2005 Page 1 

## EMISSIONS ACTIVITY CATEGORY FORM STATIONARY INTERNAL COMBUSTION ENGINE This form is to be completed for each stationary reciprocating or gas turbine engine. State/Federal regulations which may apply to stationary internal combustion engines are lis ted in the instructions. Note that there may be other regulations which apply to this emissions unit which are not included in this list. 1. Reason this form is being submitted (Check one)
New Permit Renew al or Modification of Air Permit Number (e.g. P001)

__________ 2. Maximum Operating Schedule:

__ 8,760

_____ hours per day;

_ 365

____ days per year If the schedule is less than 24 hours/day or 365 days/year, what limits the schedule to less than maximum? See instructions for examples.

_____________________________________________

3. Engine type: Gas turbine Reciprocating
4. Purpose of engine: Driving pump or compressor Driving electrical generator
5. Normal use of engine: Emergency only Non

- emergency
6. Engine Manufacturer:

___ TBD

_________________ Model No:

___ TBD

_________________ 7. Engine exhaust configuration: simple cycle (no heat recovery) (for turbines only) 

### regenerative cycle (hea t recovery to preheat combustion air) cogeneration cycle (heat recovered to produce steam) combined cycle (heat recovered to produce steam which drives generator)
8. Input capacities (million BTU/hr): Rated

________ Maximum

__ 2 , 277

______ Normal

_______ Supplemental burner (duct burner) input capacity, if equipped (million BTU/hr):
Rated:

_________ Maximum

___ 841

__ Normal

___________

9. Output capacities (Horsepower): Rated:

_________ Maximum

___________ Normal

___________ (Kilowatts): Rated:

_ 800,000

_ Maximum

_ 846,300

_ Normal

_________ __ (lbs steam/hr)*: Rated:

__ 75,000

__ Maximum

__ 75,000

____ Normal

___________ FOR OHIO EPA USE FACILITY ID: _________________ EU ID: _______ PTI#:__________EPA FORM 3862

- REV2005 Page 2 

### * required for cogeneration or combined cycle units only


### 10. Type of ignition: non - spark (diesel) spark
11. Type of fuel fired (check all that apply): single fuel No. 2 oil, low

- sulfur natural gas landfill gas dual fuel No. 2 oil, high

- sulfur diesel digester gas gasoline propane other, explain

______________________________________________

12. Complete the following table for all fuels identified in question 11 that are used for the engine and any supplemental (duct) burners, if equipped:

wt.% wt.% Fuel Usage
Fuel Heat Content (BTU/unit) Ash Sulfur Estimated Maximum Per Year Normal Per Hour Max. Per Ho ur
Nat. gas 1,050 BTU/cu ft 0. 005 gr/scf 25,283 MM cu ft cu ft 2.9 MM cu ft No. 2 oil BTU/gal gal gal gal Gasoline BTU/gal gal gal gal

Diesel BTU/gal gal gal gal Landfill/d igester gas BTU/cu ft ppm cu ft cu ft cu ft Other (show units) List supplemental (duct) burner fuel and information below (show units):



### 13. Type of combustion cycle (check all that apply):
2

- stroke 4

- stroke rich

- burn lean

- burn carbureted fuel injected other, explain

________________________________________________ 14. Emissions control techniques (check all that apply): prestratified charge nonselective catalytic reduction (NSCR) catalytic oxidation (CO) selective catalytic reduction (SCR) air/fuel ratio injection timing retard (ITR) 2

- stage rich/lean combustion 2

- stage lean/lean combustion water/steam injection preignition chamber combustion (PCC) other, explain

_____________________________________________ ___ For each emissions control technique checked above, explain what pollutants are controlled by each technique:EPA FORM 3862

- REV2005 Page 3 

### Catalytic oxidation will control VOCs and CO. Selective Catalytic Reduction (SCR) will control NOxEPA FORM 3862

- REV2005 Page 1 

## EMISSIONS ACTIVITY CATEGORY FORM STATIONARY INTERNAL COMBUSTION ENGINE This form is to be completed for each stationary reciprocating or gas turbine engine. State/Federal regulations which may apply to stationary internal combustion engines are lis ted in the instructions. Note that there may be other regulations which apply to this emissions unit which are not included in this list. 1. Reason this form is being submitted (Check one)
New Permit Renew al or Modification of Air Permit Number (e.g. P001)

__________ 2. Maximum Operating Schedule:

__ 24

____ hours per day;

_ varies

____ days per year If the schedule is less than 24 hours/day or 365 days/year, what l imits the schedule to less than maximum? See instructions for examples.

_ Limited to 500 hours/year for emergency operations

_______________________

3. Engine type: Gas turbine Reciprocating
4. Purpose of engine: Driving pump or compressor Driving electrical generator
5. Normal use of engine: Emergency only Non

- emergency
6. Engine Manufacturer:

___ TBD

_________________ Model No:

___ TBD

_________________ 7. Engine exhaust configuration: simple cycle (no heat recovery) (for turbines only) 

### regenerative cycle (heat recovery to preheat combustion air) cogeneration cycle (heat recovered to produce steam) combined cycle (heat recovered to produce steam which drives generator)
8. Input capacities (milli on BTU/hr): Rated

___ 14.1

_____ Maximum

__ 14.1

______ Normal

_ 14.1

______ Supplemental burner (duct burner) input capacity, if equipped (million BTU/hr):
Rated:

_________ Maximum

_____ Normal

___________

9. Output capacities (Horsepower): Rated:

_________ Maximum

___________ Normal

___________ (Kilowatts): Rated: 1,500

_ Maximum

_ 1,500

_ Normal

__ 1,500

_________ FOR OHIO EPA USE FACILITY ID: _________________ EU ID: _______ PTI#:__________EPA FORM 3862

- REV2005 Page 2 

### (lbs steam/hr)*: Rated:

______ Maximum

_______ Normal

___________

* required for cogeneration or combined cycle units only


### 10. Type of ignition: non - spark (diesel) spark
11. Type of fuel fired (check all that apply): single fuel No. 2 oil, low

- sulfur natural gas landfill gas dual fuel No. 2 oil, high

- sulfur diesel digester gas gasoline propane other, explain

______________________________________________

12. Com plete the following table for all fuels identified in question 11 that are used for the engine and any supplemental (duct) burners, if equipped:

wt.% wt.% Fuel Usage
Fuel Heat Content (BTU/unit) Ash Sulfur Estimated Maximum Per Year No rmal Per Hour Max. Per Hour
Nat. gas BTU/cu ft gr/scf MM cu ft cu ft MM cu ft No. 2 oil BTU/gal gal gal gal Gasoline BTU/gal gal gal gal

Diesel 137,000 BTU/gal 0.0015 50,500 gal 101 gal 101 gal Landfill/digester gas BTU/cu ft ppm cu ft cu ft cu ft Other (show units) List supplemental (duct) burner fuel and information below (show units):



### 13. Type of combustion cycle (check all that apply):
2

- stroke 4

- stroke rich

- burn lean

- burn carbureted fuel injected other, explain

________________________________________________ 14. Emissions control techn iques (check all that apply): prestratified charge nonselective catalytic reduction (NSCR) catalytic oxidation (CO) selective catalytic reduction (SCR) air/fuel r atio injection timing retard (ITR) 2

- stage rich/lean combustion 2

- stage lean/lean combustion water/steam injection preignition chamber combustion (PCC) other, explain

__ Use of low sulfur fuel

_______________________________________EPA FORM 3862

- REV2005 Page 3 

### For each emissions control technique checked above, explain what pollutants are controlled by each technique:
The use of ultra low sulfur fu el will minimize SO2 emissionsEPA FORM 3862

- REV2005 Page 1 

## EMISSIONS ACTIVITY CATEGORY FORM STATIONARY INTERNAL COMBUSTION ENGINE This form is to be completed for each stationary reciprocating or gas turbine engine. State/Federal regulations which may apply to stationary internal combustion engines are listed in the instructions. Note that there may be other regulations which apply to this emissions unit which are not included in this list.
1. Reason this form is being submitted (Check one)
New Permit Renewal or Modification of Air Permit Number (e.g. P001)

__________ 2. Maximum Operating Schedule:

__ 24

____ hours per day;

_ varies

____ days per year If the schedule is less than 24 hours/day or 365 days/year, wha t limits the schedule to less than maximum? See instructions for examples.

_ Limited to 500 hours/year for emergency operations

_______________________

3. Engine type: Gas turbine Reciprocating
4. Purpose of engine: Driving pump or compressor Driving electrical generator
5. Normal use of engine: Emergency only Non

- emergency
6. Engine Manufacturer:

___ TBD

_________________ Model No:

___ TBD

_________________ 7. Engine exhaust configuration: simple cycle (no heat recovery) (for turbines only) 

### regenerative cycle (heat recovery to preheat combustion air) cogeneration cycle (heat recovered to produce steam) combined cycle (heat recovered to produce steam which drives generator)
8. Input capacities (million BTU/hr): Rated

___ 1 .3

_____ Maximum

__ 1 .3

______ Normal

_ 1 .3

______ Supplemental burner (duct burner) input capacity, if equipped (million BTU/hr):
Rated:

_________ Maximum

_____ Normal

___________

9. Output capacities (Horsepower): Rated:

_ 250

___ Maximum

__ 250

____ Norma l

_ 250

_______ (Kilowatts): Rated:

_ Maximum

__ Normal

___________ FOR OHIO EPA USE FACILITY ID: _________________ EU ID: _______ PTI#:__________EPA FORM 3862

- REV2005 Page 2 

### (lbs steam/hr)*: Rated:

______ Maximum

_______ Normal

________ ___

* required for cogeneration or combined cycle units only


### 10. Type of ignition: non - spark (diesel) spark
11. Type of fuel fired (check all that apply): single fuel No. 2 oil, low

- sulfur natural gas landfill gas dual fuel No. 2 oil, high

- sulfur diesel digester gas gasoline propane other, explain

______________________________________________

12. Complete the following table for all fuels identified in question 11 that are used for the engine and any supplemental (duct) burners, if equipped:

wt.% wt.% Fuel Usage
Fuel Heat Content (BTU/unit) Ash Sulfur Estimated Maximum Per Year Normal Per Hour Max. Per Hour
Nat. gas BTU/cu ft gr/scf MM cu ft cu ft MM cu ft No. 2 oil BTU/gal gal gal gal Gasoline BTU/gal gal gal gal

Diesel 137,000 BTU/gal 0.0015 4,650 gal 9.3 gal 9.3 gal Landfill/digester gas BTU/cu ft ppm cu ft cu ft cu ft Other (show units) List supplemental (duct) burner fuel and information below (show units):



### 13. Type of combustion cycle (check all that apply):
2

- stroke 4

- stroke rich

- burn lean

- burn carbureted fuel injected other, explain

________________________________________________ 14. Emissions control techniques (check all that apply): prestrati fied charge nonselective catalytic reduction (NSCR) catalytic oxidation (CO) selective catalytic reduction (SCR) air/fuel ratio injection timing retard (ITR) 2

- stage rich/lean combustion 2

- stage lean/lean combustion water/steam injection preignition chamber combustion (PCC) other, explain

__ Use of low sulfur fuel

_______________________________________ For each emissions control technique checked above, explain what pollutants are controlled by eachEPA FORM 3862

- REV2005 Page 3 

### technique:
The use of ultra low sulfur fuel will minimize SO2 emissions

## Appendix B : Supporting CalculationsSummary of Annual Emissions8/23/2012Oregon Clean EnergyMax Annual Emissions - facility wide (including startup and shutdown)number of CTs 2NOx CO VOC SO2 PM10/PM2.5 NH3 H2SO4 Pb CO2combustion turbines tpy 201.5 160.3 118.5 40.3 166.4 184.0 21.6 0 3,240,850ancillary equipment tpy 8.9 17.8 2.3 0.282 2.2 0.0000 2.13E-02 5.54E-05 47,029cooling tower tpy 0.0 0.0 0.0 0.0 4.4 0 0 0 0TOTAL TPY 210.4 178.2 120.7 40.6 172.99 184.0 21.6 0.0 3287878.9Max Annual Emissions - per unit (including startup and shutdown)lb/hr 17 23 10 14 3 13 3.4 4.6 11.0 19.0PotentialAnnual Hourstons hours tpyhours tpyhours tpyhours tpyhours0.0 steady state - no DB 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.08760.0 steady state - with DB 100.7 8760.0 51.9 7416.7 48.2 7416.7 20.1 8760.0 83.2 8760.03348.3 cold start 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0833.3 hot start 0.0 0.0 16.3 833.3 6.4 833.3 0.0 0.0 0.0 0.00.0 warm start 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0510.0 shutdown 0.0 0.0 12.0 510.0 4.7 510.0 0.0 0.0 0.0 0.0TOTAL TPY 100.7 8760.0 80.2 8760.0 59.2 8760.0 20.1 8760.0 83.2 8760.0steady state emissions are assumed for events that are self correctingSUMMARY OF SU/SD INFORMATIONSelf Correcting?NOx CO VOC SO2 PM10/PM2.5cold start emissions yes yes yes yes yeshot start emissions yesno noyes yeswarm start emissions yes yes yes yes yesshutdown emissions yesno noyes yesred value indicates not self-correctingPM10/PM2.5steady state emissions[ [no DB] / [DB] ]NOx CO VOC SO2Summary of Annual EmissionsOCE_summary of potential emissions_8_23_12.xlsxSummary of Annual Emissions8/23/2012Oregon Clean EnergyOverall Assumptionsnumber of CTs 2duct burning hours 8760 hrs/yrsteady state hours per unit8760Steady State Emissions DataEmissions data from Siemens Dated 8-10-12Emissions at ISO conditions (100% load 59 F) with and without DBEmissions Case 7 (no DB) and Case 5 (w/DB)NOx emissions assume SCRCO and VOC assume oxidation catalystSO2 emissions assume no conversion to SO3 and 0.5 grains/100 SCFH2SO4 emissions assume 35% conversion to SO3 and no conversion to ammonium sulfateEach TurbineNOxCOVOC SO2 PM10/PM2.5NH3 H2SO4CO2Emissions - (Case 7) - No DB lb/hr17 10 3 3.40 11.0 16 1.822 273289Emissions - (Case 5) - w/DB lb/hr23 14 13 4.60 19.0 21 2.465 369960Emissions from DB lb/hr6 4 10 1.2 8 5 0.64312596671Facility operating hours hr/yr 8760 8760 8760 8760 8760 8760 8760 8760operating hours no DB hrs/yr 0 0 0 0 0 0 0 0operating hours with DB hrs/yr 8760 8760 8760 8760 8760 8760 8760 8760steady state emissions per turbine tpy100.74 61.32 56.94 20.148 83.22 91.98 10.80 1620425Both Turbinesnumber of turbines 2 2 2 2 2 2 2 2total plant emissions emissions - steady state tpy201.48 122.64 113.88 40.30 166.44 183.96 21.60 3240849.60Plant gross output (case 7) MW 688.137 688.137 688.137 688.137 688.137 688.137 688.137 688.137Plant net output (case 7) MW 677.3 677.3 677.3 677.3 677.3 677.3 677.3 677.3lbs CO2 per MW-hr gross (case 7) lb/MW hr794lbs CO2 per MW-hr gross (case 7) + 12.8% marginlb/MW hr896.0ISO ConditionsOCE_summary of potential emissions_8_23_12.xlsxSummary of Annual Emissions8/23/2012Oregon Clean EnergyOverall AssumptionsSU/SD information from Siemens Technical Package Dated 8-10-12cold starts/unit 50 number/yr 2.97 hours/event 64minimum hours downtime with event178 minutes per eventhot starts/unit 250 number/yr 1.33 hours/event 2minimum hours downtime with event80 minutes per eventwarm starts/unit 0 number/yr 1.47 hours/event 16minimum hours downtime with event88 minutes per eventshutdowns/unit 300 number/yr 0.70 hours/event 1minimum hours downtime with event42 minutes per eventEmissionsNOx COVOC SO2 PM10/PM2.5Emissions per cold start lbs76 253 63 7.75 24Emissions per hot start lbs64 130 51 3.75 12Emissions per warm start lbs67 130 52 4.25 14Emissions per shutdown lbs32 80 31 1.75 6.2cold start - duration of event (include downtime) hrs 66.97 66.97 66.97 66.97 66.97hot start - duration of event (include downtime) hrs 3.33 3.33 3.33 3.33 3.33warm start - duration of event (include downtime) hrs 17.47 17.47 17.47 17.47 17.47shutdown - duration of event (include downtime) hrs 1.70 1.70 1.70 1.70 1.70cold start - avg hourly emissions (including downtime) lb/hr 1.13 3.78 0.94 0.12 0.358hot start - avg hourly emissions (including downtime) lb/hr 19.20 39.00 15.30 1.1 3.600warm start - avg hourly emissions (including downtime) lb/hr 3.84 7.44 2.98 0.24 0.80shutdown - avg hourly emissions (including downtime) lb/hr 18.82 47.06 18.24 1.03 3.65steady state average hourly 23.00 14.00 13.00 4.60 19.00cold start - self correcting? - yes yes yes yes yeshot start - self correcting? - yes no no yes yeswarm start - self correcting? - yes yes yes yes yesshutdown - self correcting? - yes no no yes yesDispersion Modeling Parameters (per turbine)ExhaustFlow Temp TempStackDiameter Exit Velocity Exit Velocityacfm F K ft ft/min m/sCold Start 830000 180 355.2 22218311.09Hot Start 915000 180 355.2 22240712.23Warm Start 904000 180 355.2 22237812.08Shutdown 846000 180 355.2 22222611.31Dispersion Modeling Emissions (per turbine)NOx COVOC SO2 PM10/PM2.5Cold Start g/s 3.23 10.75 2.68 0.33 1.02Hot Start g/s 6.05 12.30 4.82 0.35 1.14Warm Start g/s 5.76 11.18 4.47 0.37 1.20Shutdown g/s 5.77 14.41 5.58 0.32 1.12SU-SDOCE_summary of potential emissions_8_23_12.xlsxEmissions From AncillaryEquipmentOregon Clean EnergyTotal Emissions form Ancillary Equipment (tpy)NOx CO VOCTSPSO2PM10/PM2.5lead (Pb) H2SO4 CO2Auxilliary Boiler tpy 3.94 14.59 1.58 1.30 0.28 1.97 0.00 2.11E-02 46,376.47Emergency Generator tpy 4.63 2.89 0.65 0.15 0.005 0.17 0.00004927 1.09E-04 580.69Emergency Fire Pump tpy 0.36 0.36 0.05 0.018 0.0007 0.021 0.000006125 1.36E-05 72.19TOTAL tpy8.93 17.84 2.28 1.47 0.28 2.16 0.0000554 2.13E-02 47,029.35Emissions (lb/hr)NOx CO VOC TSP SO2PM10/PM2.5lead (Pb)Auxilliary Boiler 0.900 3.330 0.360 0.297 0.063 0.45 0.00E+00Emergency Generator 18.527 11.564 2.618 0.588 0.021 0.66 1.97E-04Emergency Fire Pump 1.439 1.438 0.203 0.073 0.003 0.08 2.45E-05Emissions for Modeling (g/s) - annual averageNOx CO VOC SO2PM10/PM2.5lead (Pb)Auxilliary Boiler 0.114 0.420 0.0454 0.007948 0.056750 0.00E+00Emergency Generator 0.133 0.083 0.0188 0.000152 0.004756 1.42E-06Emergency Fire Pump 0.010 0.010 0.0015 0.000019 0.000591 1.76E-07Emissions for Modeling (g/s) - hourly averageNOx CO VOC SO2PM10/PM2.5lead (Pb)Auxilliary Boiler 0.11 0.42 0.05 0.00795 0.06 0.00E+00Emergency Generator2 341 460 330 002660 082 49E 05EmergencyGenerator...0.00266.2.49E-05Emergency Fire Pump 0.18 0.18 0.03 0.00033 0.01 3.09E-06Auxilliary BoilerNOx CO VOC TSP SO2PM10/PM2.5H2SO4 CO2Maximum Input Capacity MMBtu/hr 90 90 90 90 90 90 90 90Emission Factor lb/MMscf 0.714 120000Emission Factor lb/MMBtu 0.010 0.037 0.004 0.0033 0.0007 0.005 0.00005117.65Operating Hours per Years hrs/yr 8760 8760 8760 8760 8760 8760 8760 8760Potential Emissionslb/hr 0.90 3.33 0.36 0.30 0.06 0.45 0.034 10588.235Potential Emissions tpy 3.94 14.59 1.58 1.30 0.28 1.97 0.021 46376.5emission factors for NOx, CO, VOC, PM10/PM2.5 based on emission factors from recent permit (NEC)emissions of SO2 assume a sulfur content in NG of 0.5 gr/100 dscfemissions of H2SO4 assumes a 5% conversion of SO2 --> SO3 (on a molar basis)CO2 Emission Factor from AP-42 Table 1.4-2 (provided in lb/MMscf and converted to lb/MMBtu)ancillaryequipmentOCE_summary of potential emissions_8_23_12.xlsxEmissions From AncillaryEquipmentOregon Clean EnergyEmergency GeneratorNOx CO VOC TSP SO2PM10/PM2.5lead (Pb) H2SO4 CO2Power rating kW 1500 1500 1500 1500 1500 1500 1500 1500 1500Power rating hp 2011.1 2011.1 2011.1 2011.1 2011.1 2011.1 2011.1 2011.1 2011.1emission factor g/kW hr 5.61 3.5 0.79 0.18 0.2emission factor lb/MMBtu1.40E-05 3.10E-05 165.00emission factor g/bhp hr 0.0048 4.45E-05 9.85E-05 5.24E+02emissions lb/hr 18.527 11.564 2.618 0.588 0.021 0.661 0.0002 4.36E-04 2322.763operating hours per year hrs/yr 500 500 500 500 500 500 500 500.00 500.00hourly emissions (30 min/hr) lb/hr 9.264 5.782 1.309 0.294 0.011 0.330 0.0001 0.000 1161.381Potential Emissions tpy 4.63 2.89 0.65 0.15 0.0053 0.17 4.93E-05 0.0001091 580.7emission factors for NOx, CO, VOC and PM10/PM2.5 based on Tier 2 emission standards provided in 40 CFR 89 Subpart B - Table 1.TSP emission factor = 89% of PM-10 emission factor, based on AP-42, Table 3.4-2 distribution of particulate emissions for stationary diesel engines.emission factor for SO2 based on ULSD fuel oil (sulfur contentof 15 ppmw or 0.0015 lb/MMBtu) and fuel input ratio of 7000 Btu/hp hr (AP-42 Section 3.3)emission factor for Pb based on AP-42 Section 3.1 (1.4e-5 lb/MMBtu) and fuel input of 7000 Btu/hp hr (AP-42 Section 3.3)emission factor for H2SO4 ( 0.000031 lb/MMBTu) from Page 276 of Toxic air pollutant emission factors - a compilation for selected compounds and sources (EPA, 1990) and fuel input ratio of 7000 Btu/hpemission factor for CO2 (165 lb/MMBtu) from AP-42 Table 3.4-1emission factor for CH4 (0.0081 lb/MMBtu) from AP-42 Table 3.4-1emission factor for N2O (0.6 g/MMBtu) from Climate Registry General Reporting Protocol (GRP) (Emission Factors by Fuel Type andSector)Emergency Fire PumpNOx CO VOC TSP SO2PM10/PM2.5lead (Pb) H2SO4 CO2Power rating hp 250.0 250.0 250.0 250.0 250.0 250.0 250.0 250.0 250.0Power rating kW 186.5 186.5 186.5 186.5 186.5 186.5 186.5 186.5 186.5emission factor g/kW hr 3.50 3.5 0.50 0.18 0.2lb/MMBtu1 40E-053 10E-05165 00The Tier 2 emission factor for NOx and VOC (non methane hydrocarbons (NMHC)) provided in Subpart B - Table 1 is provided as a combined factor (NOx+NMHC). The breakdown of NOx and NMHC in this total factorwas estimated using the Tier 1 factors provided in 40 CFR 89 Subpart B Table 1. For example, the NOx emission factor was determined via the following equation: 6.4 * (9.2/(9.2+1.3))lb/MMBtu1.40E 053.10E 05165.00emission factor g/bhp hr 0.0048 4.45E-05 9.85E-05 5.24E+02emissions lb/hr 1.439 1.438 0.203 0.073 0.003 0.082 2.45E-05 5.43E-05 2.89E+02operating hours per year hrs/yr 500 500 500 500 500 500 500 500 500hourly emissions (30 min/hr) lb/hr 0.720 0.719 0.102 0.037 0.001 0.041 0.00001 0.000 144.375Potential Emissions tpy 0.36 0.36 0.05 0.018 0.0007 0.021 6.13E-06 1.36E-05 72.1875emission factors for NOx, CO, VOC and PM10/PM2.5 based on post -2009 emission standards provided in 40 CFR 60 Subpart IIII - Table 4TSP emission factor = 89% of PM-10 emission factor, based on AP-42, Table 3.4-2 distribution of particulate emissions for stationary diesel engines.emission factor for SO2 based on ULSD fuel oil (sulfur contentof 15 ppmw or 0.0015 lb/MMBtu) and fuel input ratio of 7000 Btu/hp hr (AP-42 Section 3.3)emission factor for Pb based on AP-42 Section 3.1 (1.4e-5 lb/MMBtu) and fuel input of 7000 Btu/hp hr (AP-42 Section 3.3)emission factor for H2SO4 ( 0.000031 lb/MMBTu) from Toxic air pollutant emission factors - a compilation for selected compoundsand sources (EPA, 1990) and fuel input ratio of 7000 Btu/hpemission factor for CO2 (165 lb/MMBtu) from AP-42 Table 3.4-1emission factor for CH4 (0.0081 lb/MMBtu) from AP-42 Table 3.4-1emission factor for N2O (0.6 g/MMBtu) from Climate Registry General Reporting Protocol (GRP) (Emission Factors by Fuel Type andSector)The post-2009 emission factor for NOx and VOC (non methane hydrocarbons (NMHC)) provided in Subpart IIII - Table 4 is providedas a combine factor (NOx+NMHC). The breakdown of NOx and NMHC in this totalfactor was estimated using the Tier 1 factors provided in 40 CFR 89 Subpart B Table 1. For example, the NOx emission factor was determined via the following equation: 0.4 * (9.2/(9.2+1.3))ancillaryequipmentOCE_summary of potential emissions_8_23_12.xlsx

### Estimated Emissions from Cooling Tower Oregon Clean Energy

Emissions PM10 PM2.5 recirculating water flow gpm 133700 133700 drift eliminator efficiency % 0.0005% 0.0005% TDS in recirculating water mg/l 3000 3000 particle size distribution % 100% 100% estimated emissions lb/hr 1.003 1.003 estimated emissions tpy 4.394 4.394 number of cells - 12 12 estimated emissions per cell lb/hr 0.08 0.084 estimated emissions per cell g/s 0.0105 0.0105 Dispersion Modeling Parameters (per cell)

diameter m 10 diameter ft 32.8 exhaust temperature K ambient + 10 K exit velocity m/s 8.5



### cooling towerNAPD‐OregonitalicsindicatecalculationsaddedbyARCADISEstimatedEmissionsDataSheetEstimatedSGT6‐5000F(5)eeExhaustStackEmissions1.10863291810‐Aug‐12CombinedCycle/Ultra‐LowNOXCombustorSITECONDITIONS: CASE1 CASE2 CASE3 CASE4 CASE5‐ISOwithDBCASE6 CASE7‐ISOnoDBCASE8 CASE9 CASE10 MAXHOURLY‐NoMAXHOURLY‐FUELTYPE NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGasLOADLEVEL 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%NETFUELHEATINGVALUE,Btu/lbm(LHV) 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445GROSSFUELHEATINGVALUE,Btu/lbm(HHV) 22,666 22,666 22,666 22,666 22,666 22,666 22,666 22,666 22,666 22,666EVAPORATIVECOOLERSTATUS ON OFF ON OFF ON OFF ON OFF OFF OFFDUCTBURNERSTATUS ON ON OFF OFF ON ON OFF OFF ON OFF OFF ONAMBIENTDRYBULBTEMPERATURE,°F 90 90 90 90 59 59 59 59 0 0AMBIENTRELATIVEHUMIDITY,% 45 45 45 45 71 71 71 71 100 100BAROMETRICPRESSURE,psia 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387GTFUELFLOW,lbm/hr98,076 93,157 98,179 93,191 99,882 100,296 99,963 100,445 98,347 98,385GTFUELFLOW,MMBtu/hrHHV2,223 2,111 2,225 2,112 2,264 2,273 2,266 2,277 2,229 2,230DUCTBURNERFUELFLOW,lbm/hr34,307 35,807 0 0 33,821 33,303 0 0 37,115 0DUCTBURNERFUELFLOW,MMBtu/hrHHV778 812 0 0 767 755 0 0 841 0TOTALFUELFLOW,MMBtu/hrHHV3,001 2,923 2,225 2,112 3,031 3,028 2,266 2,277 3,070 2,230HRSGSTACKEXHAUSTGASEXHAUSTFLOW,lbm/hr4,477,436 4,304,309 4,443,128 4,268,502 4,506,761 4,559,203 4,472,940 4,525,900 4,317,666 4,280,552OXYGEN,Vol.% 9.47 9.42 12.19 12.38 9.66 9.83 12.33 12.42 9.25 12.31CARBONDIOXIDE,Vol.% 5.07 5.14 3.81 3.77 5.11 5.04 3.87 3.84 5.4 3.99WATER,Vol.% 12.42 12.07 10 9.43 11.24 10.96 8.85 8.64 10.63 7.88NITROGEN,Vol.% 72.18 72.5 73.13 73.55 73.12 73.29 74.06 74.21 73.83 74.92ARGON,Vol.% 0.86 0.87 0.87 0.87 0.88 0.88 0.89 0.89 0.89 0.9MOLECULARWEIGHT 28.06 28.11 28.44 28.45 28.19 28.22 28.71 28.4 28.29 28.52HRSGEXHAUSTSTACKEMISSIONS(BasedonUSEPATestMethods):NOX,ppmvd@15%O2 2 2 2 2 2 2 2 2 2 2NOX,ppmvd@15%O2 2 2NOX,lbm/hrasNO2 23 22 17 16 23 23 17 17 23 17 NOX,lbm/hrasNO2 17 23NH3,ppmvd@15%O2 5 5 5 5 5 5 5 5 5 5NH3,ppmvd@15%O2 5 5NH3,lbm/hr21 20 15 15 21 21 16 16 21 16 NH3,lbm/hr16 21CO,ppmvd@15%O2 2 2 2 2 2 2 2 2 2 2 CO,ppmvd@15%O2 2 2CO,lbm/hr14 14 10 10 14 14 10 11 14 10 CO,lbm/hr11 14CO2,lbm/hr366791 356,748 269,782 256,399 369,960 369,020 273,289 277,434 373,772 271,440 CO2,lbm/hr277434 373772VOC,ppmvd@15%O2asCH4 3.4 3.5 1 1 3.3 3.3 1 1 3.5 1 VOC,ppmvd@15%O2asCH4 1 3.5VOC,lbm/hrasCH4 13 14 2.9 2.8 13 13 3 3 14 3 VOC,lbm/hrasCH4 3 14SO2,lbm/hr4.5 4.4 3.4 3.2 4.6 4.6 3.4 3.4 4.6 3.4 SO2,lbm/hr3.4 4.6PARTICULATES,lbm/hr 19 19 11 10 19 19 11 11 20 11 PARTICULATES,lbm/hr 11 20H2SO4,lbm/hr2.41 2.36 1.82 1.72 2.47 2.47 1.82 1.82 2.47 1.82 H2SO4,lbm/hr1.82 2.47NOx(lbm/MMBtuHHV) 0.00767 0.00753 0.00764 0.00757 0.00759 0.00760 0.00750 0.00747 0.00749 0.00762 NOx(lbm/MMBtuHHV)0.0076 0.0077NH3(lbm/MMBtuHHV) 0.00700 0.00684 0.00674 0.00710 0.00693 0.00693 0.00706 0.00703 0.00684 0.00717 NH3(lbm/MMBtuHHV)0.0072 0.0070CO(lbm/MMBtuHHV) 0.00467 0.00479 0.00449 0.00473 0.00462 0.00462 0.00441 0.00483 0.00456 0.00448 CO(lbm/MMBtuHHV)0.0048 0.0048VOC(lbm/MMBtuHHV) 0.00433 0.00479 0.00130 0.00133 0.00429 0.00429 0.00132 0.00132 0.00456 0.00135 VOC(lbm/MMBtuHHV)0.0013 0.0048SO2(lbm/MMBtuHHV) 0.00150 0.00151 0.00153 0.00151 0.00152 0.00152 0.00150 0.00149 0.00150 0.00152 SO2(lbm/MMBtuHHV)0.0015 0.0015PM10/PM2.5(lbm/MMBtuHHV) 0.00633 0.00650 0.00494 0.00473 0.00627 0.00627 0.00485 0.00483 0.00651 0.00493 PM10/PM2.5(lbm/MMBtuHHV)0.0049 0.0065H2SO4(lbm/MMBtuHHV)0.00080 0.00081 0.00082 0.00081 0.00081 0.00081 0.00080 0.00080 0.00080 0.00082H2SO4(lbm/MMBtuHHV) 0.0008 0.0008NOTES:‐Alldataisestimatedandnotguaranteed.Performanceisbasedonnewandcleancondition.‐Gasfuelcompositionis96.771%CH4,1.129%C2H6,0.093%C3H8,0.014%iC4H10,0.014%nC4H10,0.004%iC5H12,0.004%nC5H12,0.009%C6H14,0.242%N2,1.68%CO2,0.005H2,and0.5grainsS/100SCF.‐GasfuelmustbeincompliancewiththeSiemensGasFuelSpecification.‐NOXemissionsassumetheuseofanSCRsystemwithammoniainjection.‐COandVOCemissionsassumetheuseofanoxidationcatalyst.‐VOCconsistoftotalhydrocarbonsexcludingmethaneandethaneandareexpressedintermsofmethane(CH4).‐ParticulatesareperUSEPAMethod5and202(frontandbackhalf).‐Emissionsexcludeambientaircontributionsandassumesteady‐stateconditions.permitapplicationdatauponrequest.SiemensEnergy,Inc.ProprietaryInformation‐Pleasebeadvisedthattheinformationcontainedinthistransmittalhasbeenpreparedandisbeingtransmittedpercustomerrequestspecificallyforinformationpurposesonly.Suchinformationisnotintendedtobeusedforevaluationofplantdesign.DataincludedinanypermitapplicationorEnvironmentalImpactStatementarestrictlythecustomer'sresponsibility.SiemensisavailabletoreviewSiemens Turbine DataOCE_summary of potential emissions_8_23_12.xlsxOregonCleanEnergyDispersionModelingParameters(perturbine)developedbyARCADISbasedonSiemensData(asprovidedbelow)SITECONDITIONS: CASE1 CASE2 CASE3 CASE4 CASE5 CASE6 CASE7 CASE8 CASE9 CASE10LOADLEVEL 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%AMBIENTDRYBULBTEMPERATURE,°F 90 90 90 90 59 59 59 59 0 0AMBIENTRELATIVEHUMIDITY,% 45 45 45 45 71 71 71 71 100 100exhaustflowrate(scfm) 1,043,0331,000,9191,021,211980,7301,045,0231,056,0591,018,3951,041,701997,637981,085stackgastemperature(K) 350 350 350 350 350 350 350 350 350 350stackgastemperature(F) 170.6 170.6 170.6 170.6 170.6 170.6 170.6 170.6 170.6 170.6exhaustflowrate(acfm) 1,224,8351,175,3811,199,2101,151,6731,227,1721,240,1321,195,9031,223,2711,171,5261,152,090stackdiameter(ft) 22 22 22 22 22 22 22 22 22 22stackexitvelocity(ft/min) 3222 3092 3155 3030 3228 3262 3146 3218 3082 3031stackexitvelocity(m/s) 16.37 15.71 16.03 15.39 16.40 16.57 15.98 16.35 15.66 15.40NOxemissions(g/s) 2.90 2.77 2.14 2.02 2.90 2.90 2.14 2.14 2.90 2.14COemissions(g/s) 1.77 1.77 1.26 1.26 1.77 1.77 1.26 1.39 1.77 1.26SO2emissions(g/s) 0.57 0.55 0.43 0.40 0.58 0.58 0.43 0.43 0.58 0.43PM10/PM2.5emissions(g/s) 2.40 2.40 1.39 1.26 2.40 2.40 1.39 1.39 2.52 1.39NAPD‐OregonEstimatedEmissionsDataSheetEstimatedSGT6‐5000F(5)eeExhaustStackEmissions10‐Aug‐12CombinedCycle/Ultra‐LowNOXCombustorSITECONDITIONS: CASE1 CASE2 CASE3 CASE4 CASE5 CASE6 CASE7 CASE8 CASE9 CASE10FUELTYPE NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGas NaturalGasLOADLEVEL100% 100% 100% 100% 100% 100% 100% 100% 100% 100%NETFUELHEATINGVALUE,Btu/lbm(LHV) 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445 20,445GROSSFUELHEATINGVALUE,Btu/lbm(HHV) 22,666 22,666 22,666 22,666 22,666 22,666 22,666 22,666222,666 22,666EVAPORATIVECOOLERSTATUSON OFF ON OFF ON OFF ON OFF OFF OFFDUCTBURNERSTATUS ON ON OFF OFF ON ON OFF OFF ON OFFAMBIENTDRYBULBTEMPERATURE,°F 90 90 90 90 59 59 59 59 0 0AMBIENTRELATIVEHUMIDITY,% 45 45 45 45 71 71 71 71 100 100BAROMETRICPRESSURE,psia 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387 14.387GTFUELFLOW,lbm/hr 98,076 93,157 98,179 93,191 99,882 100,296 99,963 100,445 98,347 98,385DUCTBURNERFUELFLOW,lbm/hr34,307 35,807‐‐‐ ‐‐‐33,821 33,303‐‐‐ ‐‐‐37,115‐‐‐HRSGSTACKEXHAUSTGASEXHAUSTFLOW,lbm/hr 4,477,436 4,304,309 4,443,128 4,268,502 4,506,761 4,559,203 4,472,940 4,525,900 4,317,666 4,280,552OXYGEN,Vol.% 9.47 9.42 12.19 12.38 9.66 9.83 12.33 12.42 9.25 12.31CARBONDIOXIDE,Vol.% 5.07 5.14 3.81 3.77 5.11 5.04 3.87 3.84 5.4 3.99WATER,Vol.% 12.42 12.07 10 9.43 11.24 10.96 8.85 8.64 10.63 7.88NITROGEN,Vol.% 72.18 72.5 73.13 73.55 73.12 73.29 74.06 74.21 73.83 74.92ARGON,Vol.% 0.86 0.87 0.87 0.87 0.88 0.88 0.89 0.89 0.89 0.9MOLECULARWEIGHT 28.06 28.11 28.44 28.45 28.19 28.22 28.71 28.4 28.29 28.52HRSGEXHAUSTSTACKEMISSIONS(BasedonUSEPATestMethods):NOX,ppmvd@15%O2 2 2 2 2 2 2 2 2 2 2NOX,lbm/hrasNO2 23 22 17 16 23 23 17 17 23 17NH3,ppmvd@15%O2 5 5 5 5 5 5 5 5 5 5NH3,lbm/hr21 20 15 15 21 21 16 16 21 16CO,ppmvd@15%O2 2 2 2 2 2 2 2 2 2 2CO,lbm/hr14 14 10 10 14 14 10 11 14 10CO2,lbm/hr 366791 356,748 269,782 256,399 369,960 369,020 273,289 277,434 373,772 271,440Turbine Data for ModelingOCE_summary of potential emissions_8_23_12.xlsxVOC,ppmvd@15%O2asCH4 3.4 3.5 1 1 3.3 3.3 1 1 3.5 1VOC,lbm/hrasCH4 13 14 2.9 2.8 13 13 3 3 14 3SO2,lbm/hr 4.5 4.4 3.4 3.2 4.6 4.6 3.4 3.4 4.6 3.4PARTICULATES,lbm/hr 19 19 11 10 19 19 11 11 20 11NOTES:‐Alldataisestimatedandnotguaranteed.Performanceisbasedonnewandcleancondition.‐Gasfuelcompositionis96.771%CH4,1.129%C2H6,0.093%C3H8,0.014%iC4H10,0.014%nC4H10,0.004%iC5H12,0.004%nC5H12,0.009%C6H14,0.242%N2,1.68%CO2,0.005H2,and0.5grainsS/100SCF.‐GasfuelmustbeincompliancewiththeSiemensGasFuelSpecification.‐NOXemissionsassumetheuseofanSCRsystemwithammoniainjection.‐COandVOCemissionsassumetheuseofanoxidationcatalyst.‐VOCconsistoftotalhydrocarbonsexcludingmethaneandethaneandareexpressedintermsofmethane(CH4).‐ParticulatesareperUSEPAMethod5and202(frontandbackhalf).‐Emissionsexcludeambientaircontributionsandassumesteady‐stateconditions.permitapplicationdatauponrequest.SiemensEnergy,Inc.ProprietaryInformation‐Pleasebeadvisedthattheinformationcontainedinthistransmittalhasbeenpreparedandisbeingtransmittedpercustomerrequestspecificallyforinformationpurposesonly.SuchinformationisnotintendedtobeTurbine Data for ModelingOCE_summary of potential emissions_8_23_12.xlsx

## Appendix C : RBLC TablesRBLC Review for Auxiliary Boiler - CO Ocean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Statuspacity (MMBTUBasis Notes Limit (LB/MMBTU)* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 35.4 Other COMMERCIAL BOILER 0.0073* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 33.48 Other COMMERCIAL BOILER 0.0075IA-0062 EMERY GENERATING STATION Cerro Gordo IA 12/20/2002 Operational 68 Other AUX BOILER 0.0164* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 31.38 Other COMMERCIAL BOILER 0.0172* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.8 Other COMMERCIAL BOILER 0.0173NV-0050 MGM MIRAGE Clark NV 11/30/2009 41.64 LAER BOILER 0.0184MD-0040 CPV ST CHARLES Charles MD 11/12/2008 Not constructed 93 BACT AUX BOILER 0.02NM-0042 DEMING ENERGY FACILITY Luna NM 12/29/2000 44.1 BACT AUX BOILER 0.022* VA-0308WARREN COUNTY FACILITY Warren VA 1/14/2008 Draft 97 N/A AUX BOILER 0.036NV-0044 HARRAH'S OPERATING COMPANY, INCClark NV 1/4/2007 35.4 BACT INDUSTRIAL BOILERS 0.036WI-0226 WPS - WESTON PLANT Marathon WI 8/27/2004 Operational 46.2 N/A BOILER 0.036* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 24 Other COMMERCIAL BOILER 0.037* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 8.37 Other COMMERCIAL BOILER 0.037OH-0252 DUKE ENERGY HANGING ROCK ENERLawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.037OH-0252 DUKE ENERGY HANGING ROCK Lawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.037WA-0292 SATSOP COMBUSTION TURBINE PROJGrays Harbor WA 10/23/2001 29.3 BACT AUX BOILER 0.037LA-0240 FLOPAM INC. Iberville LA 6/14/2010 25.1 BACT BOILER 0.037* AL-0230THYSSENKRUPP STEEL AND STAINLEMobile AL 8/17/2007 Draft 64.9 BACT BOILERS 0.04* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 14.34 Other COMMERCIAL BOILER 0.0705TX-0501 TEXSTAR GAS PROCESS FACILITY Henderson TX 7/11/2006 93 BACT INDUSTRIAL BOILERS 0.076FL-0285 PROGRESS BARTOW POWER PLANT Pinellas FL 1/26/2007 Operational 99 BACT AUX BOILER 0.08FL-0286 FPL WEST COUNTY ENERGY CENTERPalm Beach FL 1/10/2007 Not constructed 99.8 BACT AUX BOILER 0.08WI-0227 PORT WASHINGTON GENERATING STWashington WI 10/13/2004 Operational 97.1 BACT AUX BOILER 0.08* OH-032 TITAN TIRE CORPORATION OF BRYANWilliams OH 6/5/2008 Draft 50.4 BACT BOILER 0.082OH-0309 TOLEDO SUPPLIER PARK- PAINT SHOLucas OH 5/3/2007 20.4 BACT INDUSTRIAL BOILERS 0.083MN-0053 FAIRBAULT ENERGY PARK Rice MN 7/15/2004 Operational 40 BACT AUX BOILER 0.084OK-0129 CHOUTEAU POWER PLANT Mayes OK 1/23/2009 33.5 N/A AUX BOILER 0.15CA-1127 GENENTECH, INC. San Mateo CA 9/27/2005 97 BACT COMMERCIAL BOILER .0000 PPMVD@3%O1of6RBLC Review for Auxiliary Boiler - NOxOcean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Statusapacity (MMBTU/Basis Notes Limit (LB/MMBTU)CA-0946 LACORR PACKAGING Los Angeles CA 7/12/2000 21 LAER BOILER 0.009OK-0055 MUSTANG ENERGY PROJECT Canadian OK 2/12/2002 Operational 31 Other AUX BOILER 0.01CA-1006 HI-COUNTRY Riverside CA 12/16/1999 20.9 BACT BOILER 0.01* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 24 BACT COMMERCIAL BOILER 0.0108MD-0040 CPV ST CHARLES Charles MD 11/12/2008 Not constructed 93 LAER AUX BOILER 0.011* MD-003MEDIMMUNE FREDERICK CAMPUS Frederick MD 1/28/2008 29.4 LAER BOILERS 0.011* VA-038 WARREN COUNTY FACILITY Warren VA 1/14/2008 Draft 97 N/A AUX BOILER 0.011CA-0940 NATION WIDE BOILER Alameda CA 3/15/2000 28.8 LAER BOILER, PORTABLE 0.011NV-0050 MGM MIRAGE Clark NV 11/30/2009 41.64 Other BOILER 0.011* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 8.37 BACT COMMERCIAL BOILER 0.0146LA-0240 FLOPAM INC. Iberville LA 6/14/2010 25.1 LAER BOILER 0.015* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.8 BACT COMMERCIAL BOILER 0.03NM-0042 DEMING ENERGY FACILITY Luna NM 12/29/2000 44.1 BACT AUX BOILER 0.03* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 31.38 BACT COMMERCIAL BOILER 0.0306* AK-0071INTERNATIONAL STATION POWER PLAAnchorage AK 12/20/2010 12.5 BACT AUXILIARY HEATER 0.031* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 35.4 BACT COMMERCIAL BOILER 0.035OH-0309 TOLEDO SUPPLIER PARK- PAINT SHOLucas OH 5/3/2007 20.4 LAER INDUSTRIAL BOILERS 0.035NV-0044 HARRAH'S OPERATING COMPANY, INCClark NV 1/4/2007 35.4 BACT INDUSTRIAL BOILERS 0.035OH-0252 DUKE ENERGY HANGING ROCK ENERLawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.035NV-0037 COPPER MOUNTAIN POWER Clark NV 5/14/2004 Not constructed 60 BACT AUX BOILER 0.035* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 14.34 BACT COMMERCIAL BOILER 0.0353WI-0226 WPS - WESTON PLANT Marathon WI 8/27/2004 Operational 46.2 N/A BOILER 0.036* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 33.48 BACT COMMERCIAL BOILER 0.0367* NH-001 CONCORD STEAM CORPORATION Merrimack NH 2/27/2009 Draft 76.8 LAER AUX BOILER(<700 hours/yr)0.049OH-0323 TITAN TIRE CORPORATION OF BRYANWilliams OH 6/5/2008 50.4 BACT BOILER 0.049OR-0048 CARTY PLANT Morrow OR 12/29/2010 91 BACT BOILER 0.049* OK-013 PRYOR PLANT CHEMICAL Mayes OK 2/23/2009 Draft 80 BACT BOILERS 0.05FL-0286 FPL WEST COUNTY ENERGY CENTERPalm Beach FL 1/10/2007 Not constructed 99.8 BACT AUX BOILER 0.05* OK-012 CHOUTEAU POWER PLANT Mayes OK 1/23/2009 Draft 33.5 BACT AUX BOILER 0.07LA-0244 LAKE CHARLES CHEMICAL COMPLEX Calcasieu LA 11/29/2010 21 BACT START HEATER - BACT DET0.1292of6RBLC Review for Auxiliary Boiler - SO2Ocean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Statusapacity (MMBTU/Basis Notes Limit (LB/MMBTU)* NY-0095CAITHNES BELLPORT ENERGY CENTESuffolk NY 5/10/2006 Draft 29.4 BACT AUX BOILER 0.0005* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 33.48 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 35.4 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 31.83 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 14.34 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 24 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 8.37 Other COMMERCIAL BOILER 0.0006* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.7 Other COMMERCIAL BOILER 0.0006OH-0309 TOLEDO SUPPLIER PARK- PAINT SHOLucas OH 5/3/2007 20.4 BACT INDUSTRIAL BOILERS 0.0006WI-0227 PORT WASHINGTON GENERATING STWashington WI 10/13/2004 Operational 97.1 BACT AUX BOILER 0.0006AR-0077 BLUEWATER PROJECT Mississippi AR 7/22/2004 22 BACT BOILERS 0.0006IN-0108 NUCOR STEEL Montgomery IN 11/21/2003 34 BACT BOILER 0.0006IA-0062 EMERY GENERATING STATION Cerro Gordo IA 12/20/2002 Operational 68 Other AUX BOILER 0.0006IN-0095 ALLEGHENY ENERGY SUPPLY CO. LLCSt. Joseph IN 12/7/2001 Not constructed 21 BACT AUX BOILER 0.0006OH-0251 CENTRAL SOYA COMPANY INC. Huron OH 11/29/2001 91.2 BACT BOILER 0.0006IN-0087 DUKE ENERGY, VIGO LLC Vigo IN 6/6/2001 Not constructed 46 BACT AUX BOILER 0.0006IN-0086 MIRANT SUGAR CREEK, LLC Vigo IN 5/9/2001 Operational 35 BACT AUX BOILER 0.0006OH-0255 AEP WATERFORD ENERGY LLC Washington OH 3/29/2001 Operational 85.2 BACT BOILER 0.0006NV-0050 MGM MIRAGE Clark NV 11/30/2009 41.64 BACT BOILER 0.0007* OK-012 CHOUTEAU POWER PLANT Mayes OK 1/23/2009 Draft 33.5 N/A AUX BOILER 0.0009NV-0044 HARRAH'S OPERATING COMPANY, INCClark NV 1/4/2007 35.4 BACT INDUSTRIAL BOILERS 0.001OH-0252 DUKE ENERGY HANGING ROCK ENERLawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.001MN-0054 MANKATO ENERGY CENTER Blue Earth MN 12/4/2003 Not constructed 70 BACT COMMERCIAL BOILER 0.001OH-0254 DUKE ENERGY WASHINGTON COUNTYWashington OH 8/14/2003 Operational 30.6 BACT BOILER 0.001VA-0255 VA POWER - POSSUM POINT Prince William VA 11/18/2002 Operational 99 Other AUX BOILER 0.001OK-0071 MCCLAIN ENERGY FACILITY McClain OK 10/25/2001 Operational 22 BACT AUX BOILER 0.001OH-0265 DRESDEN ENERGY LLC Muskingum OH 10/16/2001 Not constructed 49 BACT BOILER 0.001AL-0168 GENPOWER KELLEY LLC Walker AL 1/12/2001 Not constructed 83 BACT BOILER 0.001AZ-0047 WELLTON MOHAWK GENERATING STAYuma AZ 12/1/2004 Not constructed 38 BACT AUX BOILER 0.0023* OK-013 PRYOR PLANT CHEMICAL Mayes OK 2/23/2009 Draft 80 BACT BOILERS 0.0025* VA-0308WARREN COUNTY FACILITY Warren VA 1/14/2008 Draft 97 N/A AUX BOILER 0.003* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.8 Other COMMERCIAL BOILER 0.0042FL-0286 FPL WEST COUNTY ENERGY CENTERPalm Beach FL 1/10/2007 Not constructed 99.8 BACT AUX BOILER 2 GS/100 SCF3of6RBLC Review for Auxiliary Boiler - PM10Ocean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Statusapacity (MMBTU/Basis Notes Limit (LB/MMBTU)OH-0323 TITAN TIRE CORPORATION OF BRYANWilliams OH 6/5/2008 50.4 N/A BOILER 0.0019* NY-0095CAITHNES BELLPORT ENERGY CENTESuffolk NY 5/10/2006 Draft 29.4 BACT AUX BOILER 0.0033AZ-0047 WELLTON MOHAWK GENERATING STAYuma AZ 12/1/2004 Not constructed 38 BACT AUX BOILER 0.0033OR-0040 KLAMATH GENERATION, LLC Klamath OR 3/12/2003 (50000 LB/H) BACT AUX BOILER 0.0042MD-0040 CPV ST CHARLES Charles MD 11/12/2008 Not constructed 93 BACT AUX BOILER 0.005LA-0240 FLOPAM INC. Iberville LA 6/14/2010 25.1 BACT BOILER 0.005* OK-013 PRYOR PLANT CHEMICAL Mayes OK 2/23/2009 Draft 80 BACT BOILERS 0.0063* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 33.48 Other COMMERCIAL BOILER 0.0075* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 14.34 Other COMMERCIAL BOILER 0.0075* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 8.37 Other COMMERCIAL BOILER 0.0075* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 24 Other COMMERCIAL BOILER 0.0075OH-0309 TOLEDO SUPPOLIER PARK- PAINT SH Lucas OH 5/3/2007 20.4 BACT INDUSTRIAL BOILERS 0.0075NV-0044 HARRAH'S OPERATING COMPANY, INCClark NV 1/4/2007 35.4 BACT INDUSTRIAL BOILERS 0.0075WI-0228 WPS - WESTON PLANT Marathon WI 10/19/2004 Operational 229.8 BACT AUX BOILER 0.0075* AK-0071INTERNATIONAL STATION POWER PLAAnchorage AK 12/20/2010 12.5 BACT AUXILIARY HEATER 0.0075* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 35.4 Other COMMERCIAL BOILER 0.0076* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 31.38 Other COMMERCIAL BOILER 0.0076* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 21 Other COMMERCIAL BOILER 0.0076* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.8 Other COMMERCIAL BOILER 0.0077NV-0050 MGM MIRAGE Clark NV 11/30/2009 41.64 Other BOILER 0.0077* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 21 Other COMMERCIAL BOILER 0.0078OH-0252 DUKE ENERGY HANGING ROCK ENERLawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.01LA-0244 LAKE CHARLES CHEMICAL COMPLEX Calcasieu LA 11/29/2010 21 BACT START HEATER - BACT DET0.01FL-0286 FPL WEST COUNTY ENERGY CENTERPalm Beach FL 1/10/2007 Not constructed 99.8 BACT AUX BOILER0000 G S/100 SCF GAOR-0048 CARTY PLANT Morrow OR 12/29/2010 91 BACT BOILER 2.5 LB/MMCF4of6RBLC Review for Auxiliary Boiler - VOC Ocean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Statusapacity (MMBTU/Basis Notes Limit (LB/MMBTU)MD-0040 CPV ST CHARLES Charles MD 11/12/2008 Not constructed 93 LAER AUX BOILER 0.002NV-0050 MGM MIRAGE Clark NV 11/30/2009 41.64 Other BOILER 0.0024IN-0108 NUCOR STEEL Montgomery IN 11/21/2003 34 BACT INDUSTRIAL BOILERS 0.0026LA-0240 FLOPAM INC. Iberville LA 6/14/2010 25.1 BACT BOILER 0.003AZ-0047 WELLINGTON MOHAWK GENERATINGYuma AZ 12/1/2004 Not constructed 38 BACT AUX BOILER 0.0033GA-0098 RINCON POWER PLANT Effingham GA 3/24/2003 Not constructed 83 Other AUX BOILER 0.004VA-0255 VA POWER - POSSUM POINT Prince William VA 11/18/2002 Operational 99 Other AUX BOILER 0.004AL-0179 TENASKA TALLADEGA GENERATINGSTalladega AL 10/3/2001 Not constructed 30 BACT AUX BOILER 0.004OH-0255 AEP WATERFORD ENERGY LLC Washington OH 3/29/2001 Operational 85.2 BACT AUX BOILER 0.0041NV-0044 HARRAH'S OPERATING COMPANY, INCClark NV 1/4/2007 35.4 BACT INDUSTRIAL BOILERS 0.005OK-0046 THUNDERBIRD POWER PLT Cleveland OK 5/17/2001 Not constructed 20 BACT AUX BOILER 0.005* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 35.4 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 33.48 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 31.38 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 16.8 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 8.37 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 24 Other COMMERCIAL BOILER 0.0054* NV-0049HARRAH'S OPERATING COMPANY, INCClark NV 8/20/2009 Draft 14.34 Other COMMERCIAL BOILER 0.0054OH-0309 TOLEDO SUPPLIER PARK- PAINT SHOLucas OH 5/3/2007 20.4 LAER INDUSTRIAL BOILERS 0.0054IA-0062 EMERY GENERATING STATION Cerro Gordo IA 12/20/2002 Operational 68 Other AUX BOILER 0.0054NC-0094 GENPOWER EARLEYS, LLC Hertford NC 1/9/2002 Not constructed 83 BACT AUX BOILER 0.0054IN-0095 ALLEGHENY ENERGY SUPPLY CO. LLCSt. Joseph IN 12/7/2001 Not constructed 21 BACT AUX BOILER 0.0054IN-0087 DUKE ENERGY, VIGO LLC Vigo IN 6/6/2001 Not constructed 46 BACT AUX BOILER 0.0054IN-0086 MIRANT SUGAR CREEK, LLC Vigo IN 5/9/2001 Operational 35 BACT AUX BOILER 0.0054WI-0227 PORT WASHINGTON GENERATING STWashington WI 10/13/2004 Operational 97.1 BACT AUX BOILER 0.00545829MS-0085 Dart Container Corporation Clarke MS 1/31/2007 33.5 BACT NATURAL GAS FIRED BOILE0.0055VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 Not constructed 97 N/A AUX BOILER 0.005979381OH-0252 DUKE ENERGY HANGING ROCK Lawrence OH 12/28/2004 Operational 30.6 BACT BOILERS 0.0165of6RBLC Review for Auxiliary Boiler - H2SO4Ocean Clean Energy ProjectFacilityCounty State Permit Date Statusapacity (MMBTU/Basis Notes Limit (LB/MMBTU)CPV ST CHARLES Charles MD 11/12/2008 Not constructed 93 BACT AUX BOILER 0.0001WPS - WESTON PLANT Marathon WI 10/19/2004 Operational 229.8 BACT natural gas heaters 0.0001 lb/MMBtuMANKATO ENERGY CENTER Blue Earth MN 12/4/2003 Not constructed 70 BACT BOILER 0.8 G S/100 SCF GAS6of6RBLC Review for Large Combined Cycle Turbines - CO Ocean Clean Energy ProjectRBLC ID Facility County State Permit Date Basis Control Limit (PPM) NotesCT-0151 KLEEN ENERGY SYSTEMS, LLC Middlesex CT 2/25/2008 BACT-PSD CO Catalyst 0.9 1.7 PPMVD @ 15 % O2 with ductb*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 BACT-PSD Oxidation catalyst 1.3 Without power augmentationCPV Valley Energy Center Wawayanda NY NA 2.0Caithness Long Island Energy New York NY NA 2.0Brockton Clean Energy Brockton MA NA 2.0TX-0590 KING POWER STATION Harris TX 8/5/2010 BACT-PSD Oxidation catalyst 2.0ID-0018 LANGLEY GULCH POWER PLANT Payette ID 6/25/2010 BACT-PSD Oxidation catalyst 2.0GA-0138 LIVE OAKS POWER PLANT Glynn GA 4/8/2010 BACT-PSD Oxidation catalyst 2.0*TX-0546 PATTILLO BRANCH POWER PLANT Fannin TX 6/17/2009 BACT-PSD Oxidation catalyst 2.0NJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 BACT-PSD Oxidation catalyst 2.0MI-0366 BERRIEN ENERGY, LLC Berrien MI 4/13/2005 BACT-PSD Oxidation catalyst 2.0 4.0 PPMVD PER TURBINE/DUCTOR-0039 COB ENERGY FACILITY, LLC Klamath OR 12/30/2003 BACT-PSD Oxidation catalyst 2.0CA-1096 VERNON CITY LIGHT & POWER Los Angeles CA 5/27/2003 BACT-PSD SCR, Oxidation catalyst 2.0CA-1097 MAGNOLIA POWER PROJECT, SCPLos Angeles CA 5/27/2003 BACT-PSD SCR, Oxidation catalyst 2.0WA-0315 SUMAS ENERGY 2 GENERATION FAWhatcom WA 4/17/2003 BACT-PSD Oxidation catalyst 2.0GA-0105 MCINTOSH COMBINED CYCLE FACEffingham GA 4/17/2003 BACT-PSD Oxidation catalyst 2.0WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 Other Oxidation catalyst 2.0NJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 Other CO Catalyst 2.0GA-0102 WANSLEY COMBINED CYCLE ENERHeard GA 1/15/2002 BACT-PSD Good combustion practices 2.0WA-0288 LONGVIEW ENERGY DEVELOPMENCowlitz WA 9/4/2001 Other Oxidation catalyst 2.0NJ-0058 PSEG FOSSIL LLC LINDEN GENERAUnion NJ 8/24/2001 BACT-PSD Oxidation catalyst 2.0NJ-0059 COGEN TECHNOLOGIES LINDEN V Union NJ 5/9/2001 Other Oxidation catalyst 2.0WA-0302 GOLDENDALE ENERGY PROJECT Klickitat WA 2/23/2001 BACT-PSD Oxidation catalyst 2.0NV-0034 LAS VEGAS COGENERATION FACILClark NV 11/13/2000 BACT-PSD Oxidation catalyst 2.0MA-0027 CABOT POWER CORPORATION Suffolk MA 5/7/2000 BACT-PSD Oxidation catalyst 2.0AZ-0043 DUKE ENERGY ARLINGTON VALLE Maricopa AZ 11/12/2003 BACT-PSD Oxidation catalyst 3.0TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Oxidation catalyst 4.0NJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 BACT-PSD Oxidation catalyst 4.0ID-0010 MIDDLETON FACILITY Canyon ID 10/19/2001 BACT-PSD None 5.0 2.0000 PPM @ 15% O2 W/ DBFL-0303 FPL WEST COUNTY ENERGY CENTPalm Beach FL 7/30/2008 BACT-PSD Good combustion practices 6.0 24-hour standardsTX-0552 WOLF HOLLOW POWER PLANT NOHood TX 3/3/2010 BACT-PSD Good combustion practices 11.0 GE7FATX-0551 PANDA SHERMAN POWER STATIONGrayson TX 2/3/2010 BACT-PSD Good combustion practices 15.0 Combined-cycle mode.*TX-0547 LAMAR POWER PARTNERS II LLC Lamar TX 6/22/2009 BACT-PSD Good combustion practices 15.0*TX-0548 MADISON BELL ENERGY CENTER Madison TX 8/18/2009 BACT-PSD Good combustion practices 17.5LA-0136 PLAQUEMINE COGENERATION FACIberville LA 7/23/2008 BACT-PSD Good combustion practices 25.01of7RBLC Review for Large Combined Cycle Turbines - NOxOcean Clean Energy ProjectRBLC ID FacilityCounty State Permit Date Basis ControlLimit (PPM NotesCPV Valley Energy Center Wawayanda NY NA LAER 2.0Caithness Long Island Energy New York NY NA LAER 2.0Brockton Clean Energy Brockton MA NA 2.0ID-0018 LANGLEY GULCH POWER PLANT Payette ID 06/25/2010 BACT-PSD DLN, SCR 2.0TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD DLN, SCR 2.0*OR-0048 CARTY PLANT Morrow OR 12/29/2010 BACT-PSD SCR 2.0TX-0590 KING POWER STATION Harris TX 8/5/2010 LAER DLN, SCR 2.0TX-0552 WOLF HOLLOW POWER PLANT NOHood TX 3/3/2010 BACT-PSD DLN, SCR 2.0TX-0551 PANDA SHERMAN POWER STATIONGrayson TX 2/3/2010 BACT-PSD DLN, SCR 2.0 Combined-cycle mode.*TX-0548 MADISON BELL ENERGY CENTER Madison TX 8/18/2009 BACT-PSD SCR 2.0*TX-0547 LAMAR POWER PARTNERS II LLC Lamar TX 6/22/2009 BACT-PSD SCR 2.0*TX-0546 PATTILLO BRANCH POWER PLANT Fannin TX 6/17/2009 BACT-PSD SCR 2.0NJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 LAER SCR, Water injection 2.0FL-0303 FPL WEST COUNTY ENERGY CENTPalm Beach FL 7/30/2008 BACT-PSD SCR 2.0 24-Hour standardsCT-0151 KLEEN ENERGY SYSTEMS, LLC Middlesex CT 2/25/2008 LAER DLN, SCR 2.0*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 BACT-PSD Premix, SCR 2.0NY-0098 ATHENS GENERATING PLANT Greene NY 1/19/2007 LAER DLN, SCR, ammonia in2.0NY-0100 EMPIRE POWER PLANT Rensselaer NY 6/23/2005 LAER DLN, SCR 2.0 3.0000 PPMVD AT 15% O2 with ducAZ-0043 DUKE ENERGY ARLINGTON VALLE Maricopa AZ 11/12/2003 BACT-PSD SCR 2.0CA-1096 VERNON CITY LIGHT & POWER Los Angeles CA 5/27/2003 BACT-PSD SCR, catalyst 2.0CA-1097 MAGNOLIA POWER PROJECT, SCPLos Angeles CA 5/27/2003 BACT-PSD SCR, catalyst 2.0WA-0315 SUMAS ENERGY 2 GENERATION FAWhatcom WA 4/17/2003 BACT-PSD DLN, SCR 2.0NJ-0058 PSEG FOSSIL LLC LINDEN GENERAUnion NJ 8/24/2001 BACT-PSD DLN, SCR 2.0WA-0302 GOLDENDALE ENERGY PROJECT Klickitat WA 2/23/2001 BACT-PSD DLN, SCR 2.0NV-0034 LAS VEGAS COGENERATION FACILClark NV 11/13/2000 BACT-PSD SCR, ammonia injectio2.0MA-0027 CABOT POWER CORPORATION Suffolk MA 5/7/2000 LAER DLN, SCR 2.0GA-0138 LIVE OAKS POWER PLANT Glynn GA 4/8/2010 BACT-PSD DLN, SCR 2.5MI-0366 BERRIEN ENERGY, LLC Berrien MI 4/13/2005 BACT-PSD DLN, SCR 2.5OR-0039 COB ENERGY FACILITY, LLC Klamath OR 12/30/2003 BACT-PSD DLN, SCR 2.5GA-0105 MCINTOSH COMBINED CYCLE FACEffingham GA 4/17/2003 BACT-PSD DLN, SCR 2.5WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 Other SCR 2.5NJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 Other SCR 2.5WA-0288 LONGVIEW ENERGY DEVELOPMENCowlitz WA 9/4/2001 Other SCR 2.5NJ-0059 COGEN TECHNOLOGIES LINDEN V Union NJ 5/9/2001 BACT-PSD DLN, SCR, ammonia in2.5NJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 LAER SCR 3.0GA-0102 WANSLEY COMBINED CYCLE ENERHeard GA 1/15/2002 BACT-PSD DLN, SCR 3.0ID-0010 MIDDLETON FACILITY Canyon ID 10/19/2001 BACT-PSD SCR, catalyst 3.0 3.5000 PPM @ 15% O2 W/ DB*AK-0071 INTERNATIONAL STATION POWER Anchorage AK 12/20/2010 BACT-PSD DLN, SCR 5.0LA-0136 PLAQUEMINE COGENERATION FACIberville LA 7/23/2008 BACT-PSD SCR 5.02of7RBLC Review for Large Combined Cycle Turbines - SO2Ocean Clean Energy ProjectRBLC ID Facility County State Permit Date Basis Control Limit (lb/MMBtu) Notes*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 N/A Good combustionpractice0.0003WA-0302 GOLDENDALE ENERGY PROJECT Klickitat WA 2/23/2001 BACT-PSD Good combustionpractice0.0005OK-0129 CHOUTEAU POWER PLANT Mayes OK 1/23/2009 0.0006 1.06 lb/hrWA-0288 LONGVIEW ENERGY DEVELOPMENCowlitz WA 9/4/2001 Other Low sulfur fuel 0.0006NJ-0059 COGEN TECHNOLOGIES LINDEN V Union NJ 5/9/2001 Other (N) 0.0010WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 Other Low sulfur fuel 0.0017MA-0027 CABOT POWER CORPORATION Suffolk MA 5/7/2000 BACT-PSD Clean fuels 0.0022CT-0151 KLEEN ENERGY SYSTEMS, LLC Middlesex CT 2/25/2008 BACT-PSD (N) 0.0023 4.9 lb/hrWA-0315 SUMAS ENERGY 2 GENERATION FAWhatcom WA 4/17/2003 BACT-PSD Low sulfur fuel 0.0030ID-0010 MIDDLETON FACILITY Canyon ID 10/19/2001 BACT-PSD Low sulfur fuel 0.0031 W/ DBNJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 Other Low sulfur fuel 0.0040NJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 BACT-PSD Clean fuels 0.0043LA-0136 PLAQUEMINE COGENERATION FACIberville LA 7/23/2008 BACT-PSD Clean fuels 0.0142 40.7000 LB/HTX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Pipeline quality natural gas 27.07 LB/HNJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 Other Clean fuels 5.6600 LB/HFL-0303 FPL WEST COUNTY ENERGY CENTPalm Beach FL 7/30/2008 BACT-PSD Pipeline quality natural gas 2.0000 GR S/100 SCFNJ-0058 PSEG FOSSIL LLC LINDEN GENERAUnion NJ 8/24/2001 BACT-PSD (N) 2.0000 LB/HNV-0034 LAS VEGAS COGENERATION FACILClark NV 11/13/2000 BACT-PSD Low sulfur fuel 0.3000 LB/H3of7RBLC Review for Large Combined Cycle Turbines - PM10Ocean Clean Energy ProjectRBLC ID Facility County State Permit Date Basis Control Limit (lb/MMBtu) NotesOK-0129 CHOUTEAU POWER PLANT Mayes OK 1/23/2009 0.0035CT-0151 KLEEN ENERGY SYSTEMS, LLC Middlesex CT 2/25/2008 BACT-PSD (N) 0.0052 11 LB/HR W/O DB15.2000 LB/Caithness Long Island Energy New York NY NA 0.0055 0.0066 W/ DBOR-0039 COB ENERGY FACILITY, LLC Klamath OR 12/30/2003 BACT-PSD Good combustion practices 0.0061NY-0100 EMPIRE POWER PLANT Rensselaer NY 6/23/2005 0.0063*AK-0071 INTERNATIONAL STATION POWER Anchorage AK 12/20/2010 BACT-PSD Good combustion practices 0.0066CPV Valley Energy Center Wawayanda NY NA 0.0073WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 LAER Natural gas 0.0080GA-0105 MCINTOSH COMBINED CYCLE FACEffingham GA 4/17/2003 BACT-PSD Clean fuels, Good combustion0.0090ID-0010 MIDDLETON FACILITY Canyon ID 10/19/2001 BACT-PSD Pollution prevention 0.0093 0.00939 LB/MMBTU W/ DBNJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 Other Clean fuels 0.0094 18.6600 LB/HAZ-0043 DUKE ENERGY ARLINGTON VALLE Maricopa AZ 11/12/2003 BACT-PSD (N) 0.0097 0.01103 LB/MMBTU W/DBGA-0102 WANSLEY COMBINED CYCLE ENERHeard GA 1/15/2002 BACT-PSD Good combustion practices 0.0110LA-0224 ARSENAL HILL POWER PLANT CADDO LA 3/20/2008 0.0115 24.2 LB/HRWA-0299 SUMAS ENERGY 2 GENERATION FAWhatcom WA 9/6/2002 BACT-PSD Good combustion practices 0.0115LA-0136 PLAQUEMINE COGENERATION FACIberville LA 7/23/2008 BACT-PSD Clean fuels 0.0116 33.5000 LB/HMI-0366 BERRIEN ENERGY, LLC Berrien MI 4/13/2005 BACT-PSD Good combustion practices 0.0120 19 LB/HR W/O DOB28.9 LB/HWMA-0027 CABOT POWER CORPORATION Suffolk MA 5/7/2000 BACT-PSD Clean fuels 0.0120NJ-0058 PSEG FOSSIL LLC LINDEN GENERAUnion NJ 8/24/2001 BACT-PSD (N) 0.0127 21.0000 LB/H*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 N/A Good combustion practices 0.0130NJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 BACT-PSD Clean fuels 0.0135NJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 BACT-PSD None 0.0150 0.0170 LB/MMBTU W/ DBNJ-0059 COGEN TECHNOLOGIES LINDEN V Union NJ 5/9/2001 BACT-PSD (N) 0.0260TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Pipeline quality natural gas 33.43 LB/H*OR-0048 CARTY PLANT Morrow OR 12/29/2010 BACT-PSD Clean fuels 2.5 LB/MMCFTX-0590 KING POWER STATION Harris TX 8/5/2010 BACT-PSD Low ash fuel 11.1 LB/HRWA-0288 LONGVIEW ENERGY DEVELOPMENCowlitz WA 9/4/2001 Other Good combustion practices 10 lb/hr4of7RBLC Review for Large Combined Cycle Turbines - PM2.5Ocean Clean Energy Project0 Brockton Clean Energy Brockton MA NA 0.0055 0.0066 LB/MMBTU W/NY-0100 EMPIRE POWER PLANT Rensselaer NY 6/23/2005 0.0063*AK-0071 INTERNATIONAL STATION POWER Anchorage AK 12/20/2010 BACT-PSD Good combustion practices 0.00660 Caithness Long Island Energy New York NY NA 0.0073 0.0062 LB/MMBTU W/TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Pipeline quality natural gas 33.43 LB/HTX-0590 KING POWER STATION Harris TX 8/5/2010 BACT-PSD Low ash fuel 11.1 LB/HRNJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 Other Clean fuels 18.6600 LB/H5of7RBLC Review for Large Combined Cycle Turbines - VOC Ocean Clean Energy ProjectRBLC ID Facility County State Permit Date Basis Control Limit (PPM) NotesCPV Valley Energy Center Wawayanda NY NA LAER 0.7 1.8 PPM W/ DB*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 N/A Oxidation catalyst 0.71.0000 PPMVD WITH DUCT BURNER,1.4000 PPMVD WITH DUCT BURNER ANDPOWER AUGMENTATIONNY-0100 EMPIRE POWER PLANT Rensselaer NY 6/23/2005 LAER Oxidation catalyst 1.0 7.0000 PPMDV AT 15 % O2 with duct burningNJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 Other CO Catalyst 1.0 1.7000 PPMVD @ 15% O2 with duct burnerMA-0027 CABOT POWER CORPORATION Suffolk MA 5/7/2000 BACT-PSD Oxidation catalyst 1.0FL-0303 FPL WEST COUNTY ENERGY CENTPalm Beach FL 7/30/2008 BACT-PSD (N) 1.2NJ-0059 COGEN TECHNOLOGIES LINDEN V Union NJ 5/9/2001 Other (N) 1.2MI-0366 BERRIEN ENERGY, LLC Berrien MI 4/13/2005 BACT-PSD Oxidation catalyst 1.6 16 LB/H W/ DUCT BURNINGTX-0590 KING POWER STATION Harris TX 8/5/2010 LAER DLN, oxidation catalyst 1.8ID-0010 MIDDLETON FACILITY Canyon ID 10/19/2001 BACT-PSD None 1.8 3.8 PPM W/ DBNJ-0074 WEST DEPTFORD ENERGY Gloucester NJ 5/6/2009 LAER Oxidation catalyst, Good combustio1.9WA-0288 LONGVIEW ENERGY DEVELOPMENCowlitz WA 9/4/2001 Other Good combustion practices 1.9ID-0018 LANGLEY GULCH POWER PLANT Payette ID 06/25/2010 BACT-PSD Oxidation catalyst 2.0TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Oxidation catalyst 2.0GA-0138 LIVE OAKS POWER PLANT Glynn GA 4/8/2010 BACT-PSD Oxidation catalyst 2.0*TX-0546 PATTILLO BRANCH POWER PLANT Fannin TX 6/17/2009 BACT-PSD Oxidation catalyst 2.0CA-1096 VERNON CITY LIGHT & POWER Los Angeles CA 5/27/2003 BACT-PSD SCR, Oxidation catalyst 2.0GA-0105 MCINTOSH COMBINED CYCLE FACEffingham GA 4/17/2003 BACT-PSD Oxidation catalyst 2.0GA-0102 WANSLEY COMBINED CYCLE ENERHeard GA 1/15/2002 BACT-PSD Good combustion practices 2.0OR-0039 COB ENERGY FACILITY, LLC Klamath OR 12/30/2003 BACT-PSD Oxidation catalyst, Good combustio2.4*TX-0548 MADISON BELL ENERGY CENTER Madison TX 8/18/2009 BACT-PSD Good combustion practices 2.5TX-0552 WOLF HOLLOW POWER PLANT NOHood TX 3/3/2010 BACT-PSD DLN, SCR 3.0 GE7FANJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 LAER Oxidation catalyst 3.0TX-0551 PANDA SHERMAN POWER STATIONGrayson TX 2/3/2010 BACT-PSD DLN, SCR 4.0 Combined-cycle mode.*TX-0547 LAMAR POWER PARTNERS II LLC Lamar TX 6/22/2009 BACT-PSD Good combustion practices 4.0NY-0098 ATHENS GENERATING PLANT Greene NY 1/19/2007 LAER Good combustion practices 4.0AZ-0043 DUKE ENERGY ARLINGTON VALLE Maricopa AZ 11/12/2003 BACT-PSD (N) 4.0CT-0151 KLEEN ENERGY SYSTEMS, LLC Middlesex CT 2/25/2008 BACT-PSD (N) 5.0WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 Other Good combustion practices 5.0WA-0315 SUMAS ENERGY 2 GENERATION FAWhatcom WA 4/17/2003 BACT-PSD Good combustion practices 5.2WA-0302 GOLDENDALE ENERGY PROJECT Klickitat WA 2/23/2001 BACT-PSD Oxidation catalyst, Good combustio6.0Caithness Long Island Energy New York NY NA 3.5 LB/H; 6.1 LB/H W/ DBBrockton Clean Energy Brockton MA NA 1.0 LB/H; 2.5 LB/H W/ DBNJ-0058 PSEG FOSSIL LLC LINDEN GENERAUnion NJ 8/24/2001 LAER Oxidation catalyst 2.1000 LB/HNV-0034 LAS VEGAS COGENERATION FACILClark NV 11/13/2000 BACT-PSD Oxidation catalyst 2.0000 LB/H6of7RBLC Review for Large Combined Cycle Turbines - H2SO4Ocean Clean Energy ProjectRBLC ID Facility County State Permit Date Basis Control Limit (lb/MMBtu) Notes*VA-0308 WARREN COUNTY FACILITY Warren VA 1/14/2008 N/A Good combustion practices 0.00010WA-0302 GOLDENDALE ENERGY PROJECT Klickitat WA 2/23/2001 Other Good combustion practices 0.00010WA-0315 SUMAS ENERGY 2 GENERATION FAWhatcom WA 4/17/2003 BACT-PSD Low sulfur fuel 0.00062WA-0291 WALLULA POWER PLANT Walla Walla WA 1/3/2003 Other Natural gas 0.00073NJ-0043 LIBERTY GENERATING STATION Union NJ 3/28/2002 Other None 0.00243NJ-0066 AES RED OAK LLC Middlesex NJ 2/16/2006 BACT-PSD Low sulfur fuel 0.00270TX-0600 THOMAS C. FERGUSON POWER PLLlano TX 9/1/2011 BACT-PSD Pipeline quality natural gas 13.68 LB/H7of7