Street

Address: State of, Ohio Environmental

Protection,

Agency Mailing Address: Lazarus Gov. Center 122 S. Front Street Columbus, OH 43215 TELE: (614)644-3020

FAX: (614) 644-2329 Lazarus Gov. CenterP.O: Box 1.049 Columbus, OH 43216-1049

FINAL PERMIT

TO INSTALL LAWRENCE COUNTY Application No: 07-00493
DATE: 2/7/2002Biomass Energy, LLC South Point Power Mark Harris65 Avenue of Champions Nich01asville• KY 40356 CERTIFIED

MAIL

Y PSD Y S YN THE TIC .M. !..N...0.R•. Y CEMSMACTNSPSNESHAPS Y NETTINGMAJOR NON-ATTAINMENT Y MODELING

SUBMITTED•G.•S•O•.•L•.I•,•ISPENSING

FACILITY

Enclosed please find an Ohio EPA Permit to Install which will allow you to install the described

source(s)in

a manner indicated

in the permit. Because

this permit contains.several

conditions

and restrictions,

I urge you to read it carefully.The OhioEPA

is urging companies

to investigate

pollution

prevention

and energy conservation.

Not only will thi• reduce pollution

and energy consumption,

but it can also save you money. If you would like to learn ways you can save money while protecting

theenvironment

please contact our Office of Pollution

Prevention

at (614) 644-3469. You are hereby notified that this action by the, Director

is final and may be appealed

to the Ohio Environmental Review Appeals

Commission

pursuant

to Chapter 3745.04 of the Ohio Revised Code. The appeal must be in Writing ,and s6t forth the action complained

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

A copy of the appeal .must be served on the Director

of the Ohio Environmental Protection

Agencywithin

three (3) days of filing with the Commission.

An appeal may be filedwith the Environmental

Review Appeals

Commission

at the following

address: Enviro •nmental Review Appeals

Commission 236 :East Town Street, Room 300 Columbus, Ohio 43215 Very truly yours,

Thomas (3. Rigo Field Operations

and Permit Section Division of Air Pollution

Control

CC." USEPA PCHDPagellof 181Biomass Energy, LLC South Point Power PTI Application:

07-00493 Issued: 2/7/2002 Facility ID: 0744000147 Emissions Unit ID: B001

Part HI SPECIAL

TERMS

AND CONDITIONS

FOR SPECIFIC

EMISSIONS

UNIT(S) A. State and,Federally

Enforceable

Section Applicable Emissions

Limitations

and/or ConWol

Requirements 1• .The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions

limitations

and/or control measures.

Emissions

from this unit shall not exceed the listed limitations,

and the listed control measures

shall be specified

in narrative

form follo%ing the table. Operations, Property, and/or Equipment B001 175 mmBtaghr

Wood Fired Boiler # 1 with baghouse,

oxidation catalyst, selective

catalytic reduction, and sodium bicarbonate injection. Applicable

Rules/Requirements OAC rule 3745-31-05(A)(3)

40 CFR Part 52.21 and OAC rule 3745-31-10 through 20

OAC rule 3745-31-05(D) Applicable

Emissions Limitations/Control Measures 24.5 pounds nitrogen

oxides (NOx) per hour, and107.4 TPY NOx*; 6-.6 pounds sulfur dioxide (SO 2 )per hour, an¢t 28 TPY SO2•.* 1.9 pounds carbon monoxide

(CO) per hour, and 8.27 TPY CO;* 0.0084 pounds

lead (Pb) per hour, and 0.02 TP¥ Pb*1.2•5 pounds ammonia

(NH3) per hour, and 5.48 TPY (NH3) 0.67 pounds• hydrogen

chloride

(HCL) per hour, and 1.28 TP¥ HCL* The requirements

of this rule als(• include complian6e with the requirements

of 40 CFR Part52.21

and OAC rule 3745=31-10 through 20, and OAC rule 3745-17-07(A)(1). See section A.I.2.fbelow. 2.7 pounds volatile organic compounds (VOC) per hour, and 11.8 TPY VOC; 8.14 pounds particulates

(PM/PM10)

per hour and 21.5 TPY PM/PM10*; See section A.I.2.a.

below. gee section A.I.2.e below.57.89 TPY CO* from B001 -. B007 totalPage

12 of 181Biomass Energy, LLC South Point Power PTI Application:

07-00493 Issued: 2/7/2002 Facility ID: 0744000147 Emissions Unit ID: B001 Synthetic Minor to avoid Prevention of Significant

Deterioration

for CO OAC rule 3745-17-07(A)(1)

OAC rule 3745-17-10(C)(1) OAf rule 3745-18-06(E)(2) OAC rule 3745-23-06(B) OAC rule 3745-21-08(B) Visible particulate

.emissions

from the baghouse stack shall not exceed 20 percent opacity as a six minute average. See section A.I.2.b. below. See section A.I.2.b. below. See section A.I.2.c. below. See section A.I.2.d. below. * the TPY mass emission

rate limitations are based on a rolling, 12 month summation of the monthly

emissions. 2. Additional

Terms and Conditions 2oa Particulate

.emissions

from the baghouse

exhaust shall not exceed 0.017 gr/dscf of exhaust gases. 2.b2.c

2.d The requirements

of this rule are less stringent

than the requirements

of OAC rule 3745- 31-05(A)(3).All stationary

sources of nitrogen

oxide shall minimize

nitrogen

oxide emissions

by use of the latest available

control techniques

and operating

practices

in accordance

with best current technology.

The permittee

shall employ the best available

technologies

described in terrn and condition

A.I.2.f. below to minimize

nitrogen

oxide emissions. All stationary

sources of •arbon monoxide

shall minimize

carbon monoxide

emissions

by
use of the latest available

control techniques

and operating

practices

in accordance

with best current technology.

The permittee

shall employ the best available

technologies described in term and condition

A.I.2.f. below to minimize

carbon monoxide

emissions. 2oe Compliance

with 40 CFR 52.21 and OAC rule 3745-31-(10)

through (20) shall be demonstrated by the following

Best Available

Control Technologies

(BACT): PM/PMI0 Use of reverse air baghouse

with 98% control efficiency.

For this permit, it is assumed

that all PM emissions

are PM10. VOC- Use of good combustion

practices

in the operation

of the boiler and use Of an oxidation

catalyst. 2.f The permittee

shall install and operate the following

control technologies

as part of the Best Available

Technology

(BAT) requirements:Page

13 of 181Biomass Energy, LLC South Point Power PTI Application:

07-00493 Issued: 2/7/2002 Facility ID: 0744000147 Emissions Unit ID: B001

Use of selective

catalytic

reduction

(SCR) with a NOx control efficiency

of 80%. Use of an oxidation

catalyst with a CO cont•'ol efficiency

of 95.7%.

II. SO2-• Use ofsodium

bicarbonate

(NaHCO3)

injection

with a SO2 control efficiency

of 7O%. Operational Restrictions These boilers will burn a mixed wood waste fuel consisting

of a mixture of Mill's Pride wood waste and sawmill wood waste products.

This fuel mixture shall not exceed 32 percent concentration of Mill's Pride wood waste product

(theworst

case in terms of annual emissions for any restricted

pollutant)

on a monthly

and an annual basis. This 32 percent mixture equates to a usage rate of 41,714 tons of Mill's Pride wood waste annually,

at full-time

operation

of one boiler.The maximum

annual combined

Mill's Pride wood waste usage rate in emissions

units B001, B002, B003, B004, B005,. B006 and B007 shall not exceed 291,998 tons, based on a rolling, 12- month rolling summation

of the usage rates. To ensure enforceability

during the first 12 Calendar

months of operation

following

the issuance of this permit, the permittee

shall not exceed the production

levels specified

in the following table: Month_ Maximum

Allowable Cumulative Tons of Fuel 1 24333.2 1-2 48666.4 1-3 72999.6 1-4 97332.8 1-5 121666 1-6 145999.2 1-7 170332.4 1-8 194665.6 1-9 218998.8 1-10 243332 1-11 267665.2 1-12 291998 After the first 12 calendar

months of operation

following

the issuance

of this permit, compliance with the annual combined

Mill's Pride wood waste fuel use limitation

shall be based upon a rolling, 12 month summation

of the fuel. The permittee

shall ensure that thorough

mixing of the fuel components

occurs prior to buming in this emission

unit, and that the mixture percentage

is maintained

at no more than 32 percent Mill's Pride content. This shall be accomplished

by means of mixed delivery

into the raw woodPage

19 Of 181Biomass Energy, LLC South Point Power PTI Application:

07-00493 Issued: 2/7/2002 Facility ID: 0744000147 Emissions Unit ID: B001

V. Testing RequirementsCompliance

with the emission

limitations

in section A.I. 1. of these terms and conditions

shall be determined in accordance

with the following

methods:

a. Emission

Limitation: 8.14 pounds PM/PM10

per hour 2.7 pounds VOC per hour Applicable Compliance

Method: The following

controlled

emission

factors were used to calculate

these emission

limits: Controlled emission

factor = 0.739 lb/ton PM/PM•0 0.22 lb/ton VOC These emission

limits were established

by multiplying

the emission

factor in lb/ton, times the tons of fuel per hour. Compliance with the allowable

pound• per hour emission

limitations

shall be demonstrated by the performance

testing as described

in condition

A.V.2. The permit-tee shall ensure that the fuel used during testing contains

a mixture of 32% Mill's Pride wood waste and 68% sawmill wood waste. b. Emission

Limitation: 1.9 pounds CO per hour Applicable Compliance

Method: This emissions

limit was established

by multiplying

the heat content of the 0.007937 MMBtu/lb of the Mill's Pride component

of the fuel, times the manufacturers recommendation (lb/MMBtu),

times the control efficiency,

times 2000 lbs/ton, times the tons of fuel per hour. Compliance with the allowable

pounds per hour emission

limitations

shall be demonstrated by the performance

testing as described

in condition

A.V.2. The permittee shall ensure that the fuel used during testing contains

a mixture Of 32% Mill's Pride wood waste and 68% sawmill wood waste.

c. Emission

Limitation: 24.5 pounds.NOx

per hour 6.6 pounds SOz per hour Applicable Compliance

Method:Page

31 of 181Biomass Energy,

LLC South Point Power PTI Application:

07-00493 Issued: 2/7/2002 Facility ID: 0744000147 Emissions Unit ID: B002

Part lII SPECIAL

TERMS

AND CONDITIONS

FOR SPECIFIC

EMISSIONS

UNIT(S) A. State and Federally

Enforceable

Section I. Applicable

Emissions

Limitations

and/or Contro !Requirements The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions

limitations

and/or control measures.

Emissions

from this unit shall not exceed the listed limitations,

and the listed control measures

shall be specified

in narrative

form following the table. Operations, Property, and/or Equipment B002 -175 mmBtu/hr

Wood FiredBoiler # 2 with baghouse,

oxidation catalyst, selective

catalytic reduction and sodium bicarbonate injection. Applicable

Rules/Requirements OAC rule 3745-31-05(A)(3)

40 CFR Part 52.21 and OAC rule 3745,-31 10 through 20

OAC rule 3745-31-05(D) Applicable

.Emissions Limitations/Control Measures 24.5 pounds nitrogen

oxides. (NOx) per hour, and107.4 TPY NOx*; 6.6 pounds sulfur dioxide (SO2) per hour, and 28 TPY SO2;* 1.9 pounds carbon monoxide

(CO) per hour, and 8.27 TPY CO;* 0.0084 pounds lead (Pb) per hour, and 0.02 TPY Pb*1.25 pounds ammonia

(NH3) per hour, and 5.48 TPY (NH3) 0.67 pounds hydrogen

chloride

(HCL) per hour, and1.28

TPY HCL* The requirementS

of this rule also include compliance with the requirements

of 40 CFR Part 52.21 and OAC rule 3745-31- 10 through 20, and OAC rule 3745-17- 07(A)(1).See section A.I'.2.fbelow. 2.7 pounds volatile-organic

compounds (VOC) per hour, and 11.8TPY VOC; 8.14 pounds particulates

(PM/PM10)

per hour and 21.5 TPY PM/PMI0*; See section A.I.2.a. below. gee section A.I.2.e below; 57.89 TPY CO* from B001 B007 totalAo

Co • •Synthetic

Minor Determination

and/or • •etting

Determination Permit To Install 07-00534 Source Description Biomass Energy, LLC South Point :Power (SPP) proposes

to modify 7 existing

175 MMBtu/hr

boilers to use a different

boiler firing configuration

which increases

the maximum

boiler firing rate to 313 MMBtu/hr (B001 B007) and add a 247 MMBtu/hr

Natural gas and No. 2 fuel oil t'wed Auxiliary boiler (B011), modify the material

handling

operation

(F001), and add an outdoor wood storage pile (F003). The 7 existing boilers were part of the SouthPoint

Ethanol

(SPE) facility which shutdown

in May 1995. The.se netting credits are being used because this modification

was requested

prior to the expiration of the previous

PTI (07-00493)

for this facility. Facility Emissions

and Attainment

Status SPP will be located in Lawrence.County,

which is .attainment

for all criteria pollutants.

The SPP facility, has potential

emissions

greater than 250 tons per year for nitrogen

oxides. Source Emissions Potential •otal annual CO emissions

from the 7 wood fired boilers (B001 B007) and the Auxiliary Boiler (B011) exceed the PSD threshold

for CO. Since the Auxiliary

boiler is intended

tobe used only to keep components

warm or when one or more of the wood boilers are not operating,

SPP has requested to restrict the annual emissions

from the Auxiliary

boiler and to restrict the operation

of the Auxiliary boilerto use only when no more than- 6 of the wood fired boilers ate in Operation.

These restrictions keep the potential

CO emissions

under the PSD threshold

level of 100 T•PY. These operational restrictions have been included-in

the terms and conditions

of the Auxiliary

Boiler (B011), SPP proposes

to net out of PSD for the pollutants

sul .fur dioxide and nitrogen,

oxide by using emissions credits from the three boilers which were in Operation

at the time SPE shutdown.

The current emissions are aotual annual emissions

based On a two year period within the. contemporaneous

time frame of the original permitting

ofthe boiler modification

(previous

Permit to Install issued 07/15/98and modification issued 2/7/02).

The current and proposed

maximum

facility emissions

are: Pollutant Current Proposed Increase/ Emissions(a) Emissions(c) Decrease Particu!ate(PM/PM10) Sulfur Dioxide

(SO2) Nitrogen Oxides(NOx) Carbon Monoxide

(CO) Volatile Organic Compo3ands(VOC

) 60.98 TPY

139.08 TPY 5604.69 TPY

207.55 TPY 1619.36 TPY.

857.85 TPY 0 TPY (b)

93.61 TPY(d) 0 TPY (b)

89.81 TPY (a) Actual emissions

for SPE boilers from June 1993 .to July 1995 shutdown.

+ 78.1 TPY5397.14 TPY761.51 TPY + 93.61 TPY + 89.81 TPY (b) No data available(c)

worst case emissions

with 7 wood boilers in operation

(does not included

fugitive PM sources F002, FO03)(d) worst case CO emissions

when operating

6 wood boilers and auxiliary

boiler ConclusionThe total emissions

from the proposed

modifications

demonstrate

that emissions

are less than PSD significant levels for nitrogen

oxides, sulfur dioxide,

carbon dioxide and lead. However,

emissions

for PM/PM•0 and VOC were over PSD significant

levels. Since each boiler has potential.to

emit lesSthan 10 TPY for any single HAP and less than 25 TPY for any combination

of HAPs, Section 112 (g) of the Clean Air Act or Ohio Administrative

Code 3745-31-28

was not•triggered.STAFF

DETERMINATION

FOR THE APPLICATION

TO CONSTRUCT •UNDER THE PREVENTION

OF SIGNIFICANT

DETERIORATION

REGULATIONS FOR BIOMASS,

LLC

SOUTH

POINT

POWER SOUTH POINT,

OHIO PTI•NUMBER 07-00534 MARCH 26• 2004
Ohio Environmental

Protection

Agency Division Of Air Pollution

Control Lazarus Government

Center 122 South

Front

Street Columbus, Ohio

43215

The CleanAir

Ac•t and regulations

promulgated

thereunder

require,

that major air pollution

sources

undergoing

construction

or modification

comply

with all applicable

Prevention

of Significant

Deterioration (PSD) provislons

.and nonattainment area New Source

Review

requirements The federal

PSD rules govern emission

increases

in attainment

areas

for ma3or

sources,

which

are• sources with the potential

tO emit 250 tons per year or more of any pollutant regulated

under

the Clean

Air Act, or. i00 tons per year or more if the sohrce • is included

in one of 28 source

categories.

In nonattainment areas, the definition

of major

source

is one having

at least

i00 tons. per year potential

emissions.

A major

modification

is one resulting

in a contemporaneous increase

in emissions

which

ex.ceeds

the significance

level of one or more pollutants.

Any changes

in actual

emissions

within

afiveyear period

a•e considered

to be contempo.raneous. In addition,

Ohionow has .incorporated

the PSD and NSR requirements

by rule under

OAC 3745-31. Both PSD .and nonattainment

rules

require

that certain

analyses

be per.formed before a facility

can obtain

a permit

authorizing

construction

of a new source or ma3or

modification

to a ma3or

source.

The principal

requirements of the PSD regulations

are: I)

2) Best Available

Control

Technology

(BACT)

review

A detailed engineerinq review

must be performed

to ensure

that BACT is being installed for the pollutanZs

for which

the new source

is a major source.Ambient Air Quality

Review

An analysis

must be completed

to ensure the continued

maintenance

of the National

Ambient

Air Quality Standards (NAAQS)

and that any increases

in ambient

air pollutant concentratLons do not exceed

the incremental,

values

set pursuant

to the Clean.Air

Act. For nonattainment

areas,

the requirements

are: Lowest Achievable

Emissions

Rate (.LAER)

New ma3or

sources

must install controls

that represent

the lowest

em±ssion

levels

(highest control efficiency)

that has been achieved

in practice. The emissions

from the new major

source

must be offset

by a reduction of existing

emissions

of the same pollutant

by at least

the same .amount, and a demonstration

must be made that the resulting

air quality shows

a net alr quality

benefit.

This is more completelydescribed in the Emission

Off.set-Interpretative Ruling

as found

•n Appendix S of 40 CFR Part 51. The facility

must certify

that all major

sources

owned

or operated

in the state

by the same entity

are eithe9

in compliance

with the existing State

Implementation Plan (SIP) or are on an •pprovgd schedule resulting

in full compliance

with the SIP.. For rural

ozone

nonatta±nment

areas,

the requirements

are: i)

2• LAER

New major

sources

must install

controls

that represent

the lowest emissions

levels

(highest

control

efficiency.)

that has been achieved in practice.. The facility

must certify

tha• all .ma3or

sources

owned

or operated

in the state

by the same entity

are either

in compliance

with the existing SIP or are on an approved

schedule

resulting

in full compliance with the SIP. Finally, New Source

Performance

Standards

(NSPS),

SIP emission

standards and public

participation

requirements

must be followed

in all cas4s. Site Description The facility

is in South

Point,

Ohio,

which

is located

in Lawrence

County. This area is classified

as attainment

for all of the criteria

pollutants: particulate matter

less than i0 microns,

sulfur

dioxide,,

nitrogen

oxides, carbon monoxide,

volatile

organic

compounds

(ozone)

and lead. Facility Description The Biomass,

LLC

South

Point

Pow•r

(Biomass)

facility

consists

of 7 boilers purchased

from the former

South

Point

Ethanol

plant.

The boilers are. being

rebuilt

to burn wood .based

fuel to generate

power.

Biomass Energy; LLC. (Biomass)intends to install

a combustion

process

that is common in the U.S.,

fixed

grate

stoker

combustion

of wood chips

and dust. The wood is blown

into th4 furnace.

The stoker

is a pin hole grate.

The wood fuel will consist

of sawmill

wood waste

.products.
New Source

Review

(NSR)/PSD

Applicability This process

will generate

criteria

pollutant

emlssions

of particulate matter (PM/PMI0),

Volatile

Organic

Compound

(VOC),

NOx, SO2 and CO emissions. For PSD purposes,

Biomass

(forgerly

South

Point

Ethanol)

is considered a major

facility..

A PSD analysis

is required

for any increase in emissions

of a pollutant

exceeding

the PSD threshold

emissions

level,

or the significance

levels.

Ofthe

pollutants

emitted,

PMI0 and VOC will result in a net increase

above

PSD levels.

This is.a netting

permit

for SO2 and NOx.

New Source

Review

is not applicable,

due to attainment status. There

are no Maximum

Achievable

Control

Technology

(MACT) requirements applicable.TABLE i
PRELIMINARY POLLUTANT

EMISSION

RATES MODIFICATION TO INCREASE

EMISSION

RATES

Pollutant CurrentEmissions ProposedEmissions Increase/.Decrease Particulate (pM/PMI0)

60.98TPY S•ifur Dioxide

(SO2)

5604.69

TPY Nitrogen Oxides(NOx) 1619.36

TPY Carbon Monoxide

(CO)

0 TPY Volatile Or.ganic

Compo•nds(VOC) 0 TPY

139.08

TPY 207•55 TPY857.85 TPY 93.61 TPY89.81 TP¥

+ 78.1 TPY5397.14 TPY 761.51 TPY + 93.61TPY + 89.81TPY

Control Technoloqy

Review -As part of the application

for any source

regulated

under

the PSD requirements, an analysis

must be conducted

that demonstrates

that Best Available Control

Technology

(BACT)

will •e employed

by the source.

The Biomass facility

iS subject

to PSD regulations

which

mandate

a case-by-case BACT anal•sis•be

performed-for

PMI0 and VOC. PMI0 BACT A number

of technologies

for the control

of particulate

matter

from large boilers can be found

in the RACT/BACT/LAER Clearinghouse, including cyclones, baghouses,

and electrostatic

precipitators (ESP). The existing

reverse

air baghouse

will be upgraded

such that it will accommodate higher

.operating

temperatures

needed

by the NOx control

system, SCR. An ESP will be used before

the baghouse,

and this will be done to make the emissions

more capable

of supporting

the Best Available

Technology (BAT) requirement

of•a SCR.

The baghouse

will capture

98 percent

[0.004 grains per dry standard

cubic

foot).

The resulting

emissions

are comparable to, and within

the emissions

range

of, similar

sources

found

in the Clearinghouse. VOC BACTA CLearinghouse

search

revealed

only one conventional

approach

to control, and that is good combustion

practices.

Good combustion

control

will be employed. An oxidation-catalyst is also .being

installed

for Carbon Monoxide control,

and the catalyst

will reduce

VOC emissions

by 30 percent as well.Ambient .Air Quality

Monitorinq

Requirements U:S. EPA regulations

require

a year of ambient

air quality

data to be obtained as part of the PSD application.

An•applicant

may conduct monitoring on-size,

model

to demonstrate

.a "de minimis"

impact,

or used existing air quality

data to fill some of the requirements

ofa PSD ambient air quality

analysis.

If monitoring

is required,.U.S. EPA•has

set up specific .conditions

on the acceptability

of existing

air qualitymonitors is to ensure

the monitor

is representative of air quality

in the area. In this instance,Biomass has conducted

ambient

a±r quality

modeling

that predicts the ambient

air quality

impact,

of the source(s)

to be less than the monitoring

de minimus

concentrations for each o• the pollutants. Therefore, Biomass

would

not be required

to conduCt

pre-application monitoring. A summary

is. below:Averaglng Predicted Pollutant Period

Concentration Monitoring De MinimusConcentration PMI0 24-hour

high

4.•97 ug/m 3

I0 ug/m 3 ModelinqOnly P.•I0 exceeded

the PSD slgnificant

emission

rates.

Air quality dispersion modeling

was conducted

to assess

the effect

of these

sources

on ambient air quality

standards

and PSD increments.

The U.S. EPA Ihdustrial Source Complex-Short

Term (ISCST3,

Version

02035)

model

was used for the refined modeling

analysls. The ISCST3,

Version

02035 model

was the appropriate

model

{or the simple

to intermediate terrain

portion

Of the analysis

due.to

the need to incorporate building wake effects,

the need to predict

both short-term

and long-term (annual) average

concentrations, and the need to incorporate

impacts

from multiple and separated

emlssions

units. The ISCST3,

Version

02035 model

was run.with

the regulatory

default

options (stack-tip downwash,

buoyancy-induced dispersion,

final plume

rise), default wind speed

profile

categories,

default

potential

temperature gradient, and no pollutant

decay.

Building

downwash

was assessed

using either the Huber-Snyder

Or Schulman-Sire

downwash

methodology,

depending

on the stack

and nearby

bUilding

.heights. The ISCST3,

Version

02035 model

was run utilizing

the National

Weather Service meteorological data processed

using

the U.S. EPA PCRAMMET

program. OEPA provided

five years

of the most recent

PCRAMMET

processed meteorological data on our bulletin

board

system.

Eollowing

OEPA modeling guidance concerning

representative meteorological data for various counties, the Huntington

Surface,

Huntington

Upper

Air (1987-1991)

PCRAMMET data were ursed in the refined

modeling

analys•s. Building wake effects

will influence

emissions

from stacks

with heights less than Good Engineering

Practice

(GEP)

The ISCST3,

Version

02035 model requires •nput of building

heights

and projected

buildin•

widths

for 36 wind directions.

The U.S. EPA Building

Profile

Input

Program

(BPIP)

was used to determine

the direction-specific building

dimensions. Siqnificant Impact

Analysis ISCST3 was applied

to the sources

at•the

proposed

facility

to determine

if the proposed

facility

would

have.impacts

above

the PSD significant

impact increments. Peak facility

impacts

are presented

in the table

below: FacilityImpacts PSD •Significance• Increments PMI0 24-hour

high

4.97 ug/m 3 5 ug/m • Annual 0.75 ug/m • l.lug/m

• PSD and NAAQS

Analyses The SIA modeling

shows

that the highest

PMI0 •mpaczs

for •he 24-hour

and annual averaging

times

are 4;97 "•/m 3 and 0.75 "•/m •, respectively. These concentrations do not exceed

the PSD significant

impact

levels,

5 "•/m •and

1 "•/m 3, respectively. Since

the SI.A analys±s

does not exceed

the PSD significance impact

thresholds,

PSD and NAAQS

modeling

analyses

are not required..Toxic Analysis The worsn

case toxic

to be increased

by thi's permit

is Acrolein.

The net impact due to this permit

will be 0'.337

"•[/m 3, 1-hour,

which

is below

the MAGLC of 5.4 °•/m3• Secondary. Impact, The closest

Class

I.area

to :the Biomass

Eacility

is the Mammouth

Cave Class I national

park Wh±ch

over, 150 miles

to the southeast•

Federal

PSD regulation regulations

require

that the revlewing

authority

provide

Writ.ten notificat±on of projects

which

may affect

a Class

i area.

"May effect"

is typically interpretedby EPA as a major

source

or major

modification

within 100 kilometers.

Since

the Biomass

Facility

is located

greater

than i00 kilometer• from any Class

I area,

and all modeled

impaCts

are below Significant Impact

Levels,

the'Biom•ss

Facility

was nor subject

to the visibility analysis,

modeling.
Most of the designated

vegetation

screenlng

levels

are equivalent

to'or exceed NAAQS

and/or

PSD increments,

so that sanisfactiOn

of NAAQS

and PSD increment assures

compliance

with sensitive

vegetation

screening

levels. For SO 2 3-hour

and Annual

averaging

periods,

sensitive

screening

levels

are more stringent

than comparable

NAAQS

standards..

The Biomass

facility

does not have significant

emissions

of SO2. No adverse

effects

are expected

upon local vegetatlon

or species.

This is a former

industrial

site,

so no major

changes

are expected

to result

in the area by the operation

of the boilers. Conclusiohs Based upon the review

of the permit

to install

application

and the supjorting documentation

provided

by Biomass,

the Ohio EPA staff

has de, termined

the installation

will comply

with all applicable

State

and Federal environmental

regulations

and that the requirements

for BACT are satisfied. Therefore,

the Ohio EPA staff,

recommends

that a permit'

to install be issued

to Biomass

for the boiler

operations.Street

Address: State of Ohio Environmental

Protection

Agency Mailing Address: Lazarus Gov. Center 122 S. Front Street Columbus, OH 43215 TELE: (614) 644-3020 FAX: (614) 644-2329 Lazarus Gov. CenterP.O. Box 1049 Columbus, OH 43216-1049

RE: DRAFT

PERMIT

TO INSTALL LAWRENCE COUNTY Application No: 07-00534
DATE: 3/29/2004 Biomass Energy, LLC South Point Power Mark Harris65 Avenue of Champions Nicholas.ville, K¥ 40356 CERTIFIED

MAIL Y ToxICREVIEW Y PSD Y SYNTHETIC

MINOR V CEM•: 40 CFR Part 60, NSPS Subpart Db

•ESHAPS Y NETTIN GMAJOR NON-ATTAINMENT MODELING SUBMITTED GASOLINE DISPENSING

F•cILITY

You.are hereby notified that the Ohio Environmental

Protection

Agency has made a draft action recommending

that the Director

issue a Permit to Install for the air contaminant

source(s)

[emissions

unit(s)] shown on the enclosed draft permit:

This draft action is not an authorization

to begin construction

or modification

of your emissions unit(s). The purpose

of this draft is to solicit public comments

on the proposed

installation.

A public notice concerning the draft permit will appear in the Ohio EPA Weekly Review and the newspaper

in the county where the facility will be located.

Public comments

will be accepted

by the field office within 30 days of the date of publication in the newspaper.

Any comments

you have on .the draft permit should be directed

to the appropriate field office within the comment

period. A copy of your comments

should also be mailed to Robert Hodanbosi, Divisionof Air Pollution

Control,

Ohio EPA, P.O. Box 1049, Columbus,

OH, 43266-0149. A Permit to Install may be issued in proposed

of final fbrm based on the draft action, any written public comments received within 30 days of the public notice, or record of a public meeting

if one is held. You will be notified in writing of a scheduled

public meeting.

Upon issuance

of a final Permit to Install a fee of $10700

will be due. Please do not submit any payment

now. The Ohio EPA is urging companies

to investigate

pollution

prevention

and energy conservation.

Not only will this reduce pollution

and energy consumption,

but it can also save you money. If you would like to learn ways you can save money while protecting

the environment,

please contact our Office of Pollution

Prevention

at (614) 644-3469. If you have any questions

about this draft permit, please contact the field office where you submitted

your application, or.Mike Ahem, Field Operations

& Permit Section at (614) 644-3631. Very truly yours• Michael W. Ahem, Supervisor Field Operations

andPermit

Section Division of Air Pollution

Control

CC: .USEPA PCHD KY

WVLawrence County PUBLIC NOTICE ISSUANCE OF DRAFT

PERMIT

TO INSTALL SUBJECT TO PREVENTION

OF SIGNIFICANT

DETERIORATION

REVIEW FOR BIOMASS,

LLC

SOUTH

POINT

POWER Public Notice

is hereby

given

that the Staff

of the Ohio Environmental Protection Agency

(EPA) has recommended

to the Director

that the Ohio EPA issue a draft

action

of a Permit

to Install

(PTI) to Biomass,

Sout•

Point, Ohio. The draft

action

(permit

no. 07-00534)

was issued

on March

29, 2004. This draft

permit

proposes

to allow

the modification

of seven

boilers

[o be fueled by 'wood waste.

Air emissions

of several

pollutants

will result. The proposed

allowable

criteria

pollutant

air emission

rates

which

result -from net increases

at the facility,

are listed

below,

in tons per year.
POLLUTANT TONS PER YEAR PM/PMI0 78.1 CO 93.61 VOC 89.81 This facility

is subject

to the applicable

provisions

of the Prevention

of Significant Deterioration (PSD) regulations

as promulgated

by U.S. EPA (40 CFR 52 21) and the Ohio EPA permit

to install

requirements

(OAC 3745-31). The maximum

ambient

increment

allowed

by U.S. EPA for PMI0 on an annual average is 17 Dg/m 3 and on a 24-hour

average

is 30 •g/m 3. The Ohio EPA allows PSD sources

to consume

less than one half the available

increment. This facility

has demonstrated

t•hat the impact

from the new sources

is less than the PSD slgnif.icant

impact

increments

of 1 zg/m 3 on an annual

basis

and 5 zg/m 3 on a 24-hour

basis,

therefoge,

the impact,

is insignificant

and increment modeling

•!s not required.

Based

on this analysis,

the project complies •ith the increment

requlrements.
A public

hearing

and information

session

on the draft

air permit

is scheduled for 6:30 p.m.,

Thursday,

May 6, 2004 at South

Point

High School Cafeteria, 302 High Street,

South

Point,

OH 45680.

A presiding

officer

will be present

and may limit

oral testimony

to ensure

that all parties

are heard. All interested

persons

are entitl•d

to attend

or be represented

and give written

or oral comments

on the draft

permit

at the hearing. The comment

period

ends May i0, 2004.

Comments

received

after

this dat•e "will not be considered

to be a part-of

the official

record.

Written comments may be submitted

at the hearing

or sent to: Anne Chamberlain, Portsmouth City Health

Department,

Air Pollution

Unit,

605 Washington Street, Portsmouth,

Ohio,

45662. Further i•formation

concerning

this application,

Which

is available

for public inspection,

may be secured

from Anne Chamberlain

of the Portsmouth Local Air Agency

at the above

address

during

normal

business

hours. Telephone number:

(740) 353-5156.LAWRENCE COUNTY

ISSUANCE OF PUBLIC

NOTICE DRAFT PERMIT

TO. INSTALL

07'00534

FOR AN AIR COIqTAMINANT

SOURCE

FOR BIOMASS ENERGY,

LLC SOUTH

POINT POWER On 3/29/2.004

the Director

of the Ohio Environmental

Protection

Agency issued a draft action Of a Permit To Install an air contaminant

source for Biomass

Energy,

LLC South Point Power, located at Ethanol

Rd• South Point, Ohio.Installation of the air contaminant

source identified

below may proceed

upon final issuance

of Permit To Install 07-00534•Modification due to seven Wood fired boilers, the additon

of a250 MMBtu/he

Natural

Gas fired Boiler and the addition

of Outside wood storage piles. Replaces

PTI 07-00493

issued 2/7/2002. Comments concerning

this draft action, or a request for a public meeting,

must be Sent in writing to the address identified below no later than thirty (30) days from the date this notice is published.

All inquiries

concerning

this draft action may be directed

to the contact identified

below. Cindy Charles,

Portsmouth

City Health Department,

740 Second Street, Portsmouth,

OH 45662 [(7.40)353- 5156],Permit

To Install Terms and Conditions STATE OF OHIO ENVIRONMENTAL PROTECTION

AGENCY Issue Date: To be entered upon final issuance Effective Date: To l•e entered uoon final issuance DRAFT PERMIT

TO INSTALL

07-00534 Application Number:

07-00534 APS Premise Number:

0744000147 Permit Fee: Name of Facility: Person to Contact:Address:

To be entered upon final issuance Biomass Energy, LLC South Point Power Mark Harris65 Avenue of Champions NicholasVille, KY 40356 Location of proposed

air contaminant

source(s)

[emissions

unit(s)]: Ethanol RdSouth Point, OhioDescription ofproposed

emissions

unit(s): Modification due to seven Wood fired boilers, the additon

of a 250 MMBtu/he

Natural

Gas fired Boiler .and the addition

of outside wood storage piles. Replaces

PTI 07-00493

issued 2/7/2002. The above named entity is hereby granted a Permit to Install for the above described

emissions

unit(s) 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 above described

emissions

unit(s) of environmental

pollutants

will operate in compliance with applicable

State and Federal laws and regulations,

and does not constitute

expressed

or implied assurance

that if constructed

ormodified

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

DirectorPage

2 of•225Biomass Energy,

LLC -South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility ID: 0744000147

Part I GENERAL

TERMS

AND CONDITIONS A. State and Federally

Enforceable

Permit To Install General

Terms and Conditions 1. Monitoring

and Related

Recordkeeping

and Reporting

Requirements Except as may otherwise

be provided

in the terms and conditions

for a specific emissions unit, the permittee

shall maintain

records that include the following,

where applicable,

for any required

monitoring

under this permit: i. The date, place (as defined in the permit),

and time of.sampling

or measurements. ii. The date(s).analyses

were performed. iii. The company

or entity tha• performed

the analyses. iv. The analytical

techniques

or methods

used.

v. The results of such analyses. vi. The operating

conditions

existing at the time of sampling

or measurement. Each record of any monitoring

data, testing data, and support information

required pursuant to this permit shall be retained

for a period of five years from the date the record was created.

Support information

shall include, but not be limited to, all calibration

and maintenance rerords and aH 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. Except as may otherwise

be provided

in the terms and conditions

for a specificemissions unit, the permittee

shall Submit required

reports in the following

manner: Reports of any required

monitoring

and/or recordkeeping

of federall•

enforceable information Shall be submitted

to the appropriate

Ohio EPA District Office or local air agency. ii. Quarterly

written repots of (i) any deviations

from federally

enforceable emission limitations.,

operational

restrictions,

and control d.evice operating parameter limitations,

excluding

deviations

resulting

frommalfunctions

reported in accordance

with OAC rule.3745-15-06,

that have been detected

by the testing, monitoring and reco•dkeeping

requirements

specified

in this permit, (ii) the probable cause of such deviations,

and (iii) any corrective

actions or preventive
measures taken, shall be made to the appropriate

Ohio EPA District Office or local air agency.

The written reports shall be submitted

qtmrterly,

i.e., by January 31, April 30, July 31, and October

31 of each yea r and shall cover thePage

3 of 22•Biomass Energy,

LLC -.South Point Power PTI Application:

07-00534 Issued: To be entered

upon final issuance Facility

ID: 0744000147 previous calendar

quarters.

See B.9 below if no deviations

occurred

during the quarter.

111. Written reports, which identify any deviations

from the federally

enforceable. monitoring, recordkeeping,

and reporting

requirements

contained

in this permit shallbe submitted

to the appropriate

Ohio EPA District Office or localair

agency every six months,

i.e., by Januai'y 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

reportl

•which states that no deviations occurred during that period. iv, Each written report shall be signed by a responsible

official certifying

that, based on information

and belief formed after reasonable

inquiry, the statements

and in-formation in the report are true, accurate,

and complete. Scheduled Maintenance/MalfunctiOn Reporting Any scheduled

maintenance

of air pollution

control equipment

shall be performed

in accordance with paragraph

(A) of OAC rule 3745-15-06.

The malfunction,

i.e., upset, of any emissions

units or any associated

air pollution

control system(s)

shall be reported

to the appropriate

Ohio EPA District Offi6e or local air agency in accordance

with paragraph

(B) of,OAC rule 3745-15-06. (The definition

of an upset condition

shall be the same as that used in OAC rule 3745-15- 06(B)(1) for a malfunction.)

The verbal and written reports shall be submitted

pursuant

to OAC rule 3745-15-06.Except as provided

in that rule, any scheduled

maintenance

or malfunction

necessitating

the shutdown or bypassing

of any air pollution.control

system(s)

shall be accompanied

by the shutdown of.the emission

unit(s) that is (are) Served by such control system(s). 3. Risk Management

Plans If the permittee

is required

to develop and register a risk management

plan pursuant

to section 112(r) of the Clean Air Act, as amended,

42 U.S.C. 7401 et seq. ("Act"), the permittee

shall comply with the requirement

to register such a plan. 4. Title IV Provisions If the permittee

is subject to the requirements

of 40 CFR Part 72 concerning

acid rain, the permittee shall ensure that any affected

emissions

unit complies

with those requirements. Emissions exceeding

any allowances

that are lawfully

held. under Title IV of the Act, or any regulations adopted thereunder,

are prohibited. So Severability

Clause A determination

that any term or condition

of this permit is invalid shall not invalidate

the force or effect of anyother

term or condition

thereof, except to the extent that any other term orPage

4 of,225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon.final

issuance Facility

ID: 0744000147

condition depends

in whole or in part for its operation

or implementation

upon the term or condition declared

invalid. 6. General

Requirements

ao The permittee

must comply with all terms and conditions

of this permit. Any noncompliance with the federally

enforceable

terms and conditions

of this permit constitutes a violation

of the Act, and is grounds

for enforcement

action or for permit revocation, revocation

and reissuance,

or modification,

or for denial of a permit renewal application. bo 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. This permit may be modified,

reopened,

revoked,

or revoked

and reissued,

for cause. The filing of a request by the permittee

for a permit modification,

revocation

and reissuance, or revocation,

or of a notification

of planned

changes

or anticipated noncompliance does not stay any term and condition

of this permit. d. This permit does not convey any property

rights of any sort, or any exclusive

privilege.

eo The permittee

shall furnish to the Director

of the Ohio.EPA,

or an authorized representative of the Director,

upon receipt of a written request and within a reasonable time, any information

that may be requested

to determine

whether

cause exists for modifying, reopening

or revoking

this permit or to determine

compliance

with this permit. Upon request, the permittee

shall also furnish to the Director

or an authorized representative of the Director,

copies of records required

to be kept by this permit, For information claimed tO be confidentialin

the submittal

to the Director,

if th• Administrator of the. U.S. EpA requests

such information,.the

permittee

may furnish such records directly to the Administrator

along with a claim of confidentiality. 7. FeesThe permittee

shall pay. fees to the Director

of the Ohio EPA in accordance

with ORC section 3745.11 and OAC Chapter

3745-78.

The permittee

shall pay all applicable

Permit To Install fees within 30 days after the issuance

of.this Permit To Install. 8. Federal

and State Enforceability Only those terms and conditions

designated

in this permit as federally

enforceable,

that are required under the Act, or any of its applicable

requirements,

including

relevant provisions designed to limit the potential

to emit of a source, are enforceable

by the Administrator

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

of this permit shall not be federally

enforceable

and shall be enforceable

underJState

law only.Page

5 of 225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be enteredupon

final issuance Facility

ID: 0744000147 Compliance Requirements

a0 Any document

(including

reports) r.e.quired

to be submitted

and required

by a federally applicable requirement

in this permit shall include a certification

by a responsible

official that, based on information

and belief formed after reasonable

inquiry, the statements

in the d•)cument

are true, accurate,

and complete. 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:_At,reasonable

times, enter upon the permittee's

premises

where a source is located or the emissions-related

activity is conducted,

or where records must be kept under the conditions

of this permit. ii. Have access to and copy, at reasonable

times, any records that must be kept under the .conditions

of this permit, sUbject to :the protection

from disclosure

to the public of confidential

information

consistent

with ORC section 3704.08.

111.

iv. Inspect at reasonable

times any facilities,

equipment(including monitoring,

and air pollution

'control equipment),

practices,

or operations

regulated

or required under this permit. As authorized

by the Act, sample or monitor

at reasonable

times substance•

or parameters fQr the•purpose

of assuring

compliance

with the permit and applicable requirements.

Co The permittee

shall submit progress

reports to the appropriate

Ohio EPA District Office or local air agency conceming

any schedule.of

compliance

for meeting

an applicable reqt•irement. Progress

reports, sha!lbesubmitted

semiannually;

or more frequently

if specified in the applicable

requirement

or by the Director

of the Ohio EPA. Progress reports shall contain thefollowing: Dates for achieving

the activities,

milestones,

or compliance

required

in any schedule of compliance,

and dates when such activities,

milestones,

or compliance were achieved. An explanation

of why.any

dates in any Scheduleof

compliance

were not or will not be met, and •any preventive

or corrective

measures

adopted. 10. Permit To Operate

Application

ao If the permittee

is required

to apply for a Title.V permit pursuant

to OAC Chapter

3745- 77, the permittee

shall submit a complete

Title V permit application

or a complete

Title V permit modification

application

within twelve (12) months after commencing operation of the emissions

units Covered by this permit. However,

if the proposed

•new orPage

6of 225-Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: TO be entered upon final issuance Facility

ID: 0744000147

bo modified

source(s)

would be prohibited

by the terms and •onditions

of an existing Title V permit, a Title V permit modification

must be obtained

before the operation

of such new or modified

source(s)

pursuant

to OAC Rile 3745-77-04(D)

and OAC rule 3745-77- 08(C)(3)(d).If the permittee

is required

to apply for permit(s)

pursuant

to OAC Chapter

3745-35;

the source(s) identified

in this Permit Tolnstall

is (are) permitted

to operate for a period of up to one year from the date the source(s)

commenced

operation.

Pelxnission

to operate is granted only if the facility complies

withrall/'equirements contained

in this permit and all applicable

air pollution

laws, regulations,

and policies.

Pursuant

to OAC Chapter 3745-35, the permittee

shall, submit a complete

operating

permit .application

within ninety (90) days after commencing

operation

of the source(s)

covered by this perm.it. 11. Best Available

Technology

12. As specified

in OAC Rule 3745-31-05,

all new sources must employ Best Available

Technology (BAT). Compliance

with the terms and conditions

of this permit will fulfill this requirement. Air Pollution

Nuisance The air contaminants

emitted by the emissions

units covered by this permit shall not cause a public, nuisance,

in violation

of OAC rule 3745-15-07.Page

7 of 225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147

B. State Only Enforceable

Permit To Install General

Terms and Conditions Compliance Requirements The emissions

unit(s) identified

in this Permit to Installshall

remain in full compliance

with .all appl!cable State laws and regulations

and the terms and conditions

of this permit. Reporting Requirements The permittee

shall submit required

reports inthe following

manner:

ao Reports of any required

monitoring

and/or recordkeeping

of state-only

enforceable information shall be submitted

to the appropriate

Ohio EPA District Office or local air agency.bo Except as otherwise

may be provided

in the terms and conditions

for a specific emissions unit, quarterly

written reports of (a) any deviations

(excursions)

from state-only

required emission limitations,

operational

restrictions,

and control device operating

parameter limi[ations 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 subrrfitted to the appropriate

Ohio EPA District Office or local air agency.

If no deviations occurred

during a calendar

quarter, the permittee

shall submit a quarterly report, Which states that no deviations

occurred

during that quarter.

The reports.shall

be submitted quarterly,

i.e., by January

31; April 30, July 31, and October

31 of each year and shall cover the previous

calendar

quarters,

(These quarterly

reports shall exclude deviations resulting

from malfunctions,

reported

in accordance

with OAC rule 3745-15- 06.) 3. Permit TransfersAny transferee

of this permit shall assume the responsibilities

of the prior permit holder. The appropriate Ohio EPA District Office or local air agency must be notified in writing of any transfer of this permit. Termination of Permit To Install This permit to install shall terminate

within eightern

months of the effective

date of the permit to install if the owner or operator

has not undertaken

a continuing

program

of installation

or modification or has not entered into a binding .contractual

obligation

to undertake

and complete within a reasonable

time a continuing

program

of installation

or modification•

This deadline

may be extended

by up to 12 months if application

is made to the Director

within a reasonable

time before the termination

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

8 of 225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147

5. Construction

of New Sources(s) The proposed

emissions

unit(s) shall be constructed

in strict accordance

with the plans and application submitted

for this permit to the Director

of the Ohio Environmental

Protection Agency. There may be no deviation

from the appr0ve•d

plans without, the express, written approval of the Agency.

Any deviations

from the approved

plans orthe above conditions

may lead to such sanctions

and penalties

as provided

under Ohio law. Approval

of these plans does not constitute

an agsurance

that the proposed

facilities

will operate in compliance

w.ith all Ohio laws and regulations.

Additional

thcilities

shall be installed

upon orders of the Ohio Environnaental Protection

Agency if the proposed

'sources cannot.meet

the requirements

of this permit or cannot meet applicable

standards. If the construction

of the proposed

emissions

unit(s) has already begun or has been .completed prior to the date the Director

of the Environmental

Protection

Agency approves

the permit application and plans, the approval

does not constitute

expressed

or implied assurance

that the proposed facility has been constructed

in accordance

with the approved

plans. The action 0f beginning and/or completing

construction

prior to obtaining

the Director's

approval

constitutes

a violation of OAC rule 3745-31-02,

Furthermore,

issuance

of the Permit to Install does not constitute an assurance

that the proposed

source will' operate in compliance

with all Ohio laws and regulations.

Approval

of the plans in any case is not to be construed

as an approval

of the facility as constructed

and/or completed.

Moreover,

issuance

of the Permit to Install is not to be construed as a waiver of any rights that the Ohio Environmental

Protection

Agency'(or/other persons) may have against the applicant

for starting construction

prior to the effective

date of the permit. Additional

facilities

shall be installed

upon. orders of the Ohio Environmental

Protection Agency if the proposed

facilities

cannot meet the requirements

of this permit or cannot meet applicable standards. 6. Public Disclosure The facility is •hereby notified that this permit, and all agency records concerning

the operation

of this permitted

source, are subject to public disclosure

in accordance

with OAC rule 3745-49-03. 7. ApplicabilityThis Permit To Install is applicable

only to the emissions

unit(s) identified

in the Permit To Install. Separate

Permit To Install for the installation

or modification

of any other emissions unit(s) are required

for any emissions

unit for which a Permit To Install is required. 8. Construction

Compliance

Certification The applicant

shall provide Ohio,EPA

with a written certification

(see enclosed

form) that the facility has been constructed

in accordance

with the Pexrnit To Install. application

and the terms and conditions

of the Permit to Install.. The Certification

shall be provided

to Ohio EPA upon completion of construction

but prior to starmp of the source.Page

9 of 225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Fa•lityID:

0744000147

Additional Reporting

Requirements

When There Are No Deviations

of Federally Enforceable Emission

Limitations,

Operational

Restrictions,

or Control

Device Operating Parameter Limitations

(See Section A of This Permit) If no deviations

Occurred

during a calendar

quarter, the permittee

shall submit a quarterly

report, which states •hat no deviations

occurred

during that quarter.

The reports shall be submitted quarterly, i.e., by January 3!, April 30, July 31, and October

31 of each year and shall cover the previous calendar

quarters. C. Permit To Install Summary

Of Allowable

Emissions The following

information

summarizes

the total allowable

emissions,

by pollutant,

based on the individual allowable

emissions

of each air contaminant

source identified

in this permit. SUMMARY (for informational

purposes

only) TOTAL PERMIT

TO INSTALL

ALLOWABLE

EMISSIONS
PollutantPM/PMl0(stack)PM (fugitive)PM10(fugitive)NOxSO2COVOCPbNH3(ammonia) HCL (HydrogenChloride) Tons Per Year139.08.22.056.32857.85207.5593.6189.8i0.13369-.39.52Page

10 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07,00534 Issued: To be entered

upon final issuance Facility ID: 0744000147

Part II FACILITY

SPECIFIC

TERMS

AND CONDITIONS A. State and Federally

Enforceable

Permit To Install Facility

Specific

Terms and Conditions I, PSD REQUIREMENTS The source described

in this Permit to Install is subject to the applicable

provisions

of the Prevention of Significant

Deterioration

(PSD) regulations

as promulgated

by the United States En,eironmental Protection Agency 40 CFR 52.21. The authority

to apply and enforce the PSD regulations

has been delegated to the Ohio Environmental

Protection

Agency.

The terms and conditions

of this permit and the requirements

of the PSD regulations

are also enforceable,

by the United States Enviromnental Protection

Agency. II. MACT "Hammer"

Requirements The permittee

may be subject to the National

Emission

Standards

for Hazardous

Air Pollutants (NESHAP)

for Industrial,

Commercial

& Institutional

Boilers, 40 ICFR Part 63, Subpart DDDDD.

U.S. EPA failed to promulgate

this standard

by May '15, 2002, the Maximum Achievable

Control Technology

(MACT)

hammer

date. In accordance

with 40 CFR Part 63, Subpart B (40 CFR Parts 63.50 through 63.56), the permittee

shall submit an application to revise the permit to include equivalent

emission

limitations

as a result of a case-by-case MACT determination.

The application

shall be submitted

in two parts;_The deadline to submit the Part I application,

as specified

in 40 CFR Part 63.53, was May 15, 2002.If the final MACT standard

is not promulgated

by the deadline

specified

by U.S. EPA, the permittee shall submit the Part II application

as specified

in 40 CFR Part 63.53. The Part II application

shall be submitted

within 60 days after the deadline

to promulgate

the .respective standard

or by May 15, 2003, whichever

is later. It must contain the following information, unless otherwise

specified

by future U.S. EPA regulations:

ao

co for a new affected

source, the anticipated

date of startup of operation; the hazardous

air pollutants

(HAPs)emitted

by each affected

source in the relevant source category

and an estimated

total uncontrolled

and. controlled

emission

rate for HAPs from the affected

source; any existing

federal, State, or local limitations

or requirements

applicable

to the affected source;for each affected

emission

point or group of affected

emission

points, an identification of c•ntrol technology

in place; information rel6vant to establishing

the MACT floor (or MACT emission

limifation), and, at the option of the permittee,

a recommended

MACT floor; and any other information

reasonably

needed by the permitting

authority

including,

atthediscretion of the permitting

authority,

information

required

pursuant

to Subpart A of 40 CFR Part 63.Page

11 of 225 Biomass Energy,

LLC,- South Point Power PTI Application:

07-00534 Issued: To be en tered upon final issuance Facility

ID: 0744000147

The Part II application

for a MACT determination

may, but is.not required

to, contain the following, information:

ao
bo

Co recommended

emission

limitations

for the affected source and support information. (the permittee

may recommend

a specific design, equipment,

work practice,

or operational standard,

or combination

thereof, as an emission

limitation);
a description

of the control technologies

that would be applied to meet the emission limitation, including

technical,

information

on the design, operation,

size, estimated control efficiency

and any other information

deemed appropriate

by the permitting authority, and identification

of the affected sources to which the control technologies must be applied;

and relevant parameters

to be monitored

and frequency

of monitoring

to demonstrate continuous compliance

with the MACT emission

limitation

over the applicable reporting period. If theNESHAP

i• promulgated

before the Part II application

is due for the relevant

source category, the permittee

may be subject to the nile as a existing major source with a compliance date as specified

in the NESHAP.

If subject, the permittee

shall submit the following notifications:

ao Unless otherwise

specified

in the relevant

Subpart,

within 120 days after promulgation of 40 CFR Part 63, Subpart DDDDD,

the permittee

shall submit an Initial Notification

Report that contains

the following

information,

in accordance with 40 CFR Part. 63.9(b)(2): i. the name and mailing address of the permittee;

11: the physical

locationofthe

source if it is different

from the mailing address;

111. identification

of the relevant

MACT standard

and the source's compliance date;iv. a brief description

of the nature, design, size, and method of operation

of the source, including

theloperating

design capacity

and an identification

of each emission point of each HAP; and

v. a statement

confirming

the facility is a major source for HAPs. Unless otherwise

specified

in the relevant

Subpart,

within 60 days folloWing completion of any required

compliance

demonstration

activity

specified

in the relevant Subpart,

the permittee

shall submit a notification

of compliance

status that contains the following

information: i. the methods

used to determine

compliance;Page

12 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility ID: 0744000147

ii.

nl the results of any performance

tests, Visible emission

observations, continuous monitoring

systems

performance

evaluations,

and/or other monitoring procedures

or methods

that were conducted; the methods

that will be used for determining

continuous

compliance, including a description

of monitoring

and reporting

requirements

and test methods; iv. the type and quantity

of HAPs emitted by the source, reported

in units and averaging times in accordance

with the test methods

specified

in the relevanl Subpart;

an analysis demonstrating

whether

the affected

source is a major source or an area source; vi. a description

of the air pollution

control equipment

or method

for each emission point, including

each control device or method for each HAP and the control efficiency

(percent)

for each control device or method;

and

III vii a statement

Of whether

or not. the permittee

has compiled

with the requirements of the relevant

Subpart. Nitrogen Oxides (NOx) Budget Trading Program

OAC Chapter

3745-14 .1. Facility Code 0744000147 The fbllowing

regulated

emissions

units are subject to the applicable

requirements

specified in OAC Chapter 3745-14. EmissionsUnitsB003 (Boiler #3), B004 (Boiler #4) •nd B007 (Boiler #7) The emissions

units identified

in Part II A.III.2 above are NOx budget units.under

OAC rule 3745-14-01 (C)(1)(b). [OAC rule 3745-14-01(C)(1)] NOx allowances

for units commencing.operation on. the dates specified

in OAC rule 3745-14-05(C)(4) shall be allocated

from the new source set-aside

in accordance

with•the provisions of OAC rule 3745-14-05(C)(4)(d). [OAC rule 3745-14-05(C)(4)] The NOx authorized

account representative

shall submit-a

complete

NOx budget permit application in accordance

with the deadlines

specified

in paragraphs

(B)(2) and (B)(3) of OAC rule 3745-14-03.

The•NOx

authorized

account representative

shall also s.ubmit, in a timely manner,

any supplemental

information

that the Director

determines

is necessary

in order to review a NOx budget permit application

and issue or deny a NOx budget permit.Page

13 of 225Biomass Energy,

LLC South Point.Power PTI Application:

07-00534 Issued: TO be entered upon final issuance Facility

ID: 0744000147
[OAC rules 3745-14-01(E)(1)(a)(i), 3745-14-01(E)(1)(a)(ii), and 3745-,14-03(B)(1)] Beginning May .31, 2004, the owners and operators

of each NOx budget source and each NOx budget unit at the source shall hold NOx allowances

available

for compliance deductions under paragraph

(E),ofOAC

rule 3745-14-06,

as of the NOx allowance

transfer deadline, in the unit's compliance

account and the source's overdraft

account in an amount not less than thetotal NOx emissions

for the control period from the unit, as determined

in accordance with OAC rule 3745-14-08,

plus any amount necessary

to account for actual utilization under paragraph

(C) (5)of OAC rule 3745-14 -05 for the control period. [OAC rules 3745-14-01(E)(3)(a)

and 3745-14-01(E)(3)(c)] NOx all0v•ances

shall be held in, deducted,

from, or transferred

among NOx allowance tracking system accounts

in accordance

with OAC rules 3745-14-05,

3745-14-06, 3745-14-07, and 3745-14-09. [OAf rule 3745-14-01

(E)(3)(d)] A NOx allowance

shall not be deducted,

in order to comply with the requirement

under paragraph (E)(3)(a)

of OAC rule 3745-14-01,

for a control period in a year prior to the year for which the NOx allowance

was allocated. [OAC rule 3745-14-01(E)(3)(e)] Each ton of NOx emitted in excess of the NOx budget emissionlimitation,

as defined in OAC rule 3745-14-01(B)(2)(yy), shall constitute

a separate

violation

of OAC Chapter 3745-14, the Clean Air Act, and applicable

Ohio law. The owners and operators

of a NOx budget unit that has excess emissions

in any control period shall surrender

the NOx allowances required

for deduction

under paragraph

(E)(4)(a)

of OAC rule 3745-14-06

and pay any fine, penalty,

or assessment

or comply with any other remedy imposed

under paragraph (E)(4)(c)

of OAC rule 3745-14.-06. [OAC rules 3745-1-4-01

(E)(3)(b),

3745-14-01

(E)(4)(a)

and 3745-14-01(E)(4)(b)] When recorded

by the Administrator

pursuant

to OAC rules 3745-14-06

and 3745-14-07, every allocation,

transfer,

or deductioia.of

a NOx allowance

to 0r from a NOx budget unit's compliance account

or the overdraft

account

of the source where the unit is located is deemed to amend automatically,

and become a part of• any NOx budget permit of the NOx budget unit by operation

of law without

any further review. [OAf rule 3745-14-01(E)(3)(h)] 11. Except as provided

below, the Director

shall revise the NOx budget permit, a• necessary,

in accordance with OAC rule 3745-77-08:

Eac.h NOx budget permit is deemed to incorporate automatically the.definitions

of terms under paragraph

(B) of OAC rule 3745-14-01

and, when recorded

by the Administrator,

in accorda•ace

with OAC rules 3745-14-06

and 3745-14-07, every allocation,

transfer,

or deduction

of a-NOxallowance

to or from the compliance accounts

of the NOx budget units covered by the permit or the overdraft

account of the NOx budget source coveredby

the permit. [OAC rules 3745-14-03(D)(2)

and 3745-14-03(E)(1)]Page

14 0f.225Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: Tobe entered upon final issuance Facility

ID: 0744000147

12. The owner or operator

of a.NOg budget unit shall comply with the prohibitions

under OAC rule 3745-14-08(A)(5). [OAf rule 3745-14-08(A)(5)] 13. The owners and operators

of•he NOx.budgetunit

shall keep on site at the source each of the following documents

for a period of five years from the date the document

is created:

(This period may be extended

for cause, at any time prior to the end of five years, in writing by the Director or Administrator.)

ao the account

certificate

of representation

for .the NOx autho.rizrd

account representative for the NOx budget unit and all documents

that demonstrate

the truth of the statements

.in the account certificate

of representation,

in accordance

with paragraph (D) of OAC rule 3745-14-02,

provided

that the certificate

and documents shall be retained

on site at the source beyond such five-year

period until such documents are superseded

because of the submission

of a new account certificate

or representation changing

the NOx authorized

account, representative; b. all emission

monitoring

information,

in accordance

with OAC rule 3745-14:08; copies ofail reports, compliance

certifications,

and other submissions

and all records made or required

under the NOx budget trading program;

and do copies ofail documents

used to complete

a NOx budget pemlit applic, ation and any other submission

under the NOx budget trading program

or to demonstrate compliance with the requirements

of the NOx budget trading program. [OAC rule 3745-14-01

(E)(5)(a)(i)

through (iv)] 14. The permittee,

and to the extent applicable,

the NOx authorized

account representative

of the NOx budget unit, shall comply with the monitoring

and reporting

requirements

as provided in OAC rule 3745-14-08

and in 40 CFR Part 75, Subpart H. For purposes

of complyirig with such-requirements

the def'mitions

in OAC rule3745-14-0

I(B) and in 40 CFR 72.2 shall apply, and the terms "affected

unit," "designated

representative,"

and "continuous emission

monitoring

system" (or "CEMS")

in 40 CFR Part 75 shall be replaced by the terms "NOx budget unit," "NOx authorized

account representative,"

and "continuous emission monitoring

system"

(or "CEMS"),

respectively,

as defined

in OAC rule 3745=14-01(B).[OAC rule 3745-14-08(A)]Page

15 of 225Bi0mass Energy,

LLC South Point Power PTI Application:

07-0053•1 Issued: To be entered upon-final

issuance Facility

ID: 0744000147

15. The permittee

shall comply with the monitoring

plan requirements

.of 40 CFR.Part

75.62, except that the monitoring

plan is only required

to include information

required

by 40 CFR Part 75, Subpart H.[OAf rule 3745-14-08(E)(2)(b)] 16.

17. The NOx authorized

account representative

of the NOx budget unit shall submit the reports and compliance

certifications

required

under the NOx budget trading program,

including those under OAC rules 3745,14-04

'and 3745-14-08,

to the Director

and Administrator. [OAC rule 3745-14-01

(E)(4)(b)] Each submission

under the NOx budget trading program

shall be submitted,

signed, and certified by the NOx authorized

account representative

for each' NOx budget source on behalf of which the •ubmission

is made. Each such submission

shall include the following certification statement

by the NOx authorized

account representative: "I am authorized

to make this submission

on behalf of the Owners and operators

of the NOx budget sources or NOx budget lanits for which the submission

is made, I certify under Oenalty of law that .I have personally

examined,

and am familiar with, the statements

and information submitted

in this document

and all its attachments.

Based on my inquiry o fthose individuals with primary

responsibility

for obtaining

the information,

I c'ertify that the statements and information

are to the best of my knowledge

and belief true, accurate,

and complete. I am aware that there are significant

penalties

for submitting

false statements

and information or omitting

required

statements

and information,

including

the possibility

of fine or imprisonment." If the NOx authorized

account rep]:esentativ•

for a NOx budget unit subject to an acid rain emission limitation

who,signed

and certified

any submission

that is made under Subpart F or G 0f40 CFR Part 75 and which includes

data and information

required

under OAC rule 3745-14-08 or. Subpart H of 40. CFR.Part

75 is not the same person as the designated representative or the alternate

desigm/ted

representative

for the unitunder

40 CFR Part 72, thei• the submission

shall also be signed by the designated

representative

or the alternate designated representative. [OAf rules 3745-14-02(A)(5)

and 3745-14-08(E)(1)(b)] 18. The NOx authorized

account

representative

shall submit quarterly

reports covering

the period May 1 through September

30 of each year and including

the data described

in 40 CFR 75.74(c)(6). The NOx authorized

account representative

shall submitsucti

quarterly

reports, beginning with the calendar

quarter covering

May 1 through June 30, 2003. The NOx authorized account representative

shall submit each quarterly

report to the Administrator within thirty daysfollowing

the end of the calendar

quarter covered by the report. Quarterly reports shall be submitted

in the manner.specified

in 40 CFR Part 75, Subpart H. [OAC rules 3745-14-08(E)(4)(b)

and 3745-14-08(E)(4)(c)(i)] 19. The NOx authorized

account representative

shall submit to the Administrator

a compliance certification in support of each quarterly

report based on a reasonable

inquiry of thosePage

16 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility ID: 0744000147

persons with primary responsibility

for ensuring

that all of the unit's emissions

are correctly and fully monitored.

The compliance

certification

shall state that: the monitoring

data submitted

were recorded

in accordance

with the applicable requh'ements of OAC rule 3745-14-08

and 40 CFR Part:75,

including

the quality
assurance procedures

and specifications;

and for. a unit with add-on NOx emission

controls

and for all hours where: data are substituted in accordance

with 40 CFR Part 75.34(a)(1),

the add-on emissioncontrol
were operating

within the range of parameters

listed in the quality assurance

program under Appendix

B of 40 CFR Part 75 and the substitute

values do not systematically underestimate the NOx emissions. [OAC rule 3745-14-08(E)(4)(d)(i) and (ii)] 20. The NOx authorized

account representative

for aNOx budget unit shall submit' written notice of monitoring

system certification

and re-certification

test dates to the Director

and the Administrator

in accordance

witti 40 CFR Part 75.61. The NOx authorized

account representative shall submita certification

application

to the Administrator,

U.S. EPA, Region V Office,

and the Director

within forty-five

days after completing

all initial or re-certification tests required

under paragraph

(B) of OAC rule 3745-14-08,

including

the information required

under Subpart H of 40 CFR Part 75. [OAC rules 3745-14-08(D)

and 3745-14-08(E)(3)] 21. For each control period in which one or more NOx budget units at a source are subject to the NOx budget emission

limitation,

the NOx authorized

account representative

of the source shall submit to the Director

and the Administrator,

by NOvember

30 of that year, a compliance certification

report for each source covering

all such units. The NOx authorized account representative

shall include the following

elements

in the compliance

certification report, in a format prescribed

by the Administrator,

concerning

each unit at the source and subject to the NOx budget emission

limitation

for the control period covered by the report:

a. identification'of

each NOx budget unit;
at the NOx authorized

account representative's

option, the serial numbers

of the NOx allowances that are to be deducted

from each unit's compliance

account under paragraph (E) of OAC rule 3745-14-06

for the control period;

Co at the NOx authorized

account representative's

option, for units sharing a common stack and having NO:• emissions

that are not monitored

separately

or apportioned

in accordance with OAC rule 3745-14-08,

the percentage

of allowances

that is to be deducted from each unit's compliance

account under paragraph

(E)(5) of OAC rule 3745-14-06; and d. the compliance

certification

under paragraph

(A)(3) of OAC rule 3745-14-04.Page

17 of 225Biomass Energy•

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance [OAC rules 3745-14-04(A)(1)

and 3745-14-04(A)(2)] Facility

ID: 0744000147

22. In the compliance

certification

report under Section A.II.21 .d above, the NOx authorized account representative

shall certify, based upon reasonableinquiry

of those persons with the primary responsibility

for operating

the source and the NOx budget units at the source in compliance with the NOx budget trading program;

whether

each NOx budget unit for which the compliance

certification

is submitted

was operated

during the calendar

year covered by the report in compliance

with the requirements

of the NOx budget trading program applicable to the unit, including

all the following: whether the unit was operated

in compliance

with the NOx budget emission limitation; bo whether

the monitoring

plan that governs the unit has been maintained

to reflect the actual, operation

and monitoring

of the unit, and contains

all information

necessary to attribute

NOx emissions

to the unit, in accordanCe

with OAC rule 3745-14-08; whether all the NOx emissions

from the unit, or group of units (including

the unit) using a common

stack, were monitored

or accounted

for through the missing data p•ocedures and reported

in the quarterly

monitoring

reports,

including

whether conditional data were reported

in the quarterly

reports in accordance

with OAC rule 3745-14-08, and if conditional

data were reported,

the permittee

shall indicate whether the status of all conditional

data has been resolved

and all necessary quarterly report submissions

have been made; and

23. d. whether the facts that form the basis for certification

under OAC rule 3745-14-08

of each monitor at the unit or group of units (including

the unit) using a common

stack,

or for using an excepted

monitoring

method

or alternative

monitoring

method approv.ed under OAC rule 3745-14-08,

if •ny, have changed. If a change is required

to be reported

under Section A.II.22.d

above, specify the nature of the change,

the reason for the change,

when the change occurred,

and how the unit's compliance status was determined

subsequent

:to the change,

including

what method was used •o determine

emissions

when a change mandated

the need for monitor re-certification. [OAC rule 3745-14-04(A)(3)] The NOxauthorized

account representative

shall submit a complete

NOx budget permit renewal application

for the NOx budget source covering

theNOx

budget units at the source in accordance

with. paragraph(E)

of OAC rule 3745-77-08. [OAC rule 3745-14-03(B)(3)(a)] 24. The emission

measurements

recorded

and reported

in accordance

with OAC rule 3745-14-08 shall be used to determine

compliance

by the unit.with

the NOx budget emission

limitation under paragraph

(E)(3) of OAC rule 3745-14-01. [OAf rule 3745-14-01

(E)(2)(b)]Page

18 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147

25, The permittee

shall develop and maintain

a written quality assurance/quality

control plan for each" continuous

NOx monitoring

system designed

to ensure continuous

v•id and representative readings

of NOx emissions

in units.of the applicable

standard.

The plan shall follow the requirements

of 40 CFR Part 75, Appendix

B. The quality assurance/quality control plan and a logbook dedicated

to the continuous

NOx monitoring

system must be kept on-site and available

for inspection

during regular office hours. [OAC rules 3745-14-08(A)(2)(c)

and 3745-14-08(A)(Z)(d)] IV. The emissions

of Hazardous

Air Pollutants

(HAPs), as defined in Section.ll

2(b) of. the Clean Air Act, from all emissions

units located at this facility combined,

shall not exceed 10 tons per year for an individual

HAP and 25 tons per year for any combination

0fHAPs*,

per rolling 12 month period. Since the potential

to emit for HAPs is below 10 tons individual

and 25 tons combined,

no monitoring, record keeping,

or reporting

requirements

are necessary

to meet these limits. V. The following

emission

units(EU)

are also being installed

as part of this project: EU BACT Emissions Wet cooling tower mist eliminator 1.72 TPY B. State Only Enforceable

Permit To Install Facility

Specific

Terms and Conditions The permit to install was evaluatedbased

on the actual materials.

(typically

coatings

and cleanup materials) and the design parameters

of the emissions

unit's exhaust system, as specified

by the permittee in the permit to install application.

The Ohio EPA's "Review

of New Sources of Air Toxic Emissions" policy ("Air Toxic Policy") was applied for each pollutant

emitted by this emissions

unit using data from the permit to install application

and the SCREEN

3.0 modeI (or other Ohio EPA approved model). The predicted

1-hour maximum

ground-level

concentration

from. the use of the SCREEN 3.0 model was compared

to the Maximum

Acceptable

Ground-Level

Concentration (MAGLC). The following

summarizes

the results of the modeling

for the "worst case" pollutant(s): Pollutant! Hydrogen

Chloride

(HCL) TLV (ug/m3):

7,500 Maximum Emission

Rate (g/s):

0.273 Predicted 1-Hour Maximum

Ground-Level

Concentration

(ug/m3):

1.25 MAGLC (ug/m3): 179 Pollutant: Styrene TLV (ug/m3):

86,000Page

19 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Maximum Emission

Rate (g/s):

0.035 Predicted 1-Hour Maximum

Ground-Level

Concentration

(ug/m3): MAGLC (ug/m3): 2100 Pollutant: Formaldehyde TLV (ug/m3):

370 Maximum Emission

Rate (g/s):

0.081 Predicted 1-Hour Maximum

Ground-Level

Concentration

(ug/m3): MAGLC (ug/m3): 9 Pollutant: Benzene TLV (ug/m3):

2,000 Maximum Emission

Rate (g/s):

0.077 Predicted l-Hour Maximum

Ground-Level

Concentration

(ug/m3): MAGLC (ug•m3): 48 Facility

ID: 0744000147

0.16

0.369

0.351

Pollutant: Ammonia TLV (ug/m3):

17,400 Maximum Emission

Rate (g/s):

1.99 Predicted 1-H0ur Maximum

Ground-Level

Concentration

(ug/m3):

9.07 MAGLC (ug/m3): 414 Physical changes toor changes in the method of operation

of the emissions

unit after its installation or modification

could affect the parameters

used to determine

whether

or not the "Air Toxic Policy" is satisfied.

Consequently,.

prior to making

a change if/at could impact such parameters,

the permittee shall conduct

an evaluation

to determine

that the "Air Toxic Policy" will still be still satisfied. If, upon evaluation,

the permit-tee

determines

that the "Air Toxic Policy" will not be satisfied, the permittee

will not make the change.

Changes

that can affect the parameters

used in applying the "Air Toxic Policy" include the following:

ao changes

in the composition

of the materials

used (typically

for coatings

or cleanup materials), or the use of new materials,

that would result in the emission

of a compound

withPage

20 of 225 Biomass Energy,

LLC South. Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147

a lower Threshold

Limit Value (TLV), as indicated

in the most recent version of the handbook entitled "American

Conference

of Governmental

Industrial

Hygienists

(ACGIH)," than the lowest TLV value previously

modeled; changes in the composition

of the materials,

or use of new materials,

that would result in an increase in emissions

of any pollutant

with a listed TLV that was proposed

in the application and modeled;

and

Co physical

changes to the emissions

unit or its exhaust .parameters

(e.g., increased/decreased exhaust flow, changes

in stack height, changes

in stack diameter,

etc.). If the permittee

determines

that the "Air Toxic PoliCy" will be satisfied

for the above changes,

the Ohio EPA will not consider

the change(s)

to be a "modification".

under OAC rule 3745-31- 01(VV)(1)(a)(ii), and a modification

of the existing permit to install will not be required.

If the change(s) is (are) defmed as a modification

under other provisions

of the modification

definition (other than (VV)(1)(a)(ii)),

then the permittee

shall obtain a final permit to install prior to the change.The permittee

shall collect, record, and retain the following

information

when it conducts evaluations to determine

that the changed

emissions

unit will still, satisfy the "Air Toxic Policy:"

a description

of the parameters

changed

(composition

of materials,

new pollutants

emitted, .change in Stack/exhaust

parameters,

etc..); bo documentation

of its evaluation

and determination

that the changed

emissions

unit still satisfies the "Air Toxic Policy";

and where computer

modeling

is performed,

a copy of the resulting

computer

model runs that show the results of the application

of the "Air Toxic Policy" for the change. Construction and operation

of the air p011utibn

sour.ces associated

with this permit cannot commence until the facility receives

a Permit to Install (PTI) and NPDES permit from Ohio EPA, Division

of Surface Water (DSW). The permittee

shall not store any wood waste fuel on site until a final DSW PTI and a f'mal NPDES permit have been issued.Page

21 of 225 Biomass Energy,

LLC--South

Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147 Emissions ,Unit ID: B001

Part III SPECIAL

TERMS

AND CONDITIONS

FOR.SPECIFIC

EMISSIONS

UNIT(S) A. State and Federally

Enforceable

Section I. Applicable

Emissions

Limitations

and/or Control

Requirements The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions limitations

and/or control measures.

Emissions

from this unit shall not exceed the listed limitations, •and the listed control measures

shall be specified

in narrative

form following

the table. Operations, Property, and/or Equipment B001 318 MMBtu/hr

wood fired boiler

# 1 ,with bagh0use, oxidation

catalyst, selective catalytic

reduction, and spray dryer absorber. Modification due to change n boiler firing configuration. Terms and conditions

in this permit supercede

those identified in PTI #07-00493 issued 2/7/2002. Applicable

Rules/Requirements OAC rule 374.5-31-05(A)(3)

40 CFR Part 52.21 and OAC rule 3745-31-10 through 20 Applicable

Emissions Limitations/Control Measures 27.98 pounds nitrogen

oxides (NOx) per hour, and122.55 TPY NOx*; 6.77 pou•nds sulfur dioxide (SO 2 )per hour, and 29.65 TPY SO 2 ;* 2.74 pounds carbon monoxide

(CO) per hour, and 12.0 TPY CO;* 0.0043 pounds

lead (Pb) per hour, and 0.019 TPY Pb*2.26 pounds ammonia

(NH3) per hour, and 9.9TPY (NH3)0.31 pounds -hydrogen

chloride

(HCL) per hour, and t:36 TPY HCL The requirements

of this rule also include compliance with the requirements

of 40 CFR Part 52.21, OAC rule 3745-31-10 through

20, and OAC rule 3745-17-07(A)(1). See section A.L2.fbelow. 2.93 pounds volatile organic compounds (VOC) per hour, 0.025 lb VOC/MMBtu and 12.83 TPY VOC; 3.84 pounds particulates

(PM/PM10)

per hour and 16.82 TPY PM/PM10*; See section A.I:2.a.

below. See section A.I.2.e below.Page

22 of 225 Biomass Energy,

LLC South Point Power PTI Application:

0%00534 Issued: •To be entered upon final issuance Facility

ID: 0744000147 Emissions Unit ID: B001

OAC rule 3 745-17-07(A)(1

)

OAC rule 3745-17-10(C)(1) OAC rule 3745-18-06(E)(2) OAC rule 3745-23-06(B) OAC rule 3745-21-08(B) 40 CFR Part 75 OAC rule 3745-103 Visible

particulate

emissions

from the baghot•se stack shall not exceed 20 percent opacity asa six minute average. See section A.I.2.b. below. See sectionA.I.2.b:

below. See section AiI.2.c. below. See section A.I.2.d. below. See section A:I.2.g below. See section A,I.2.g. below

* the TPY mass emission

rate limitations are based on a rolling,

12 month summation of the monthly

emissions_ 2. Additional

Terms and Conditions 2oa Particulate

emissions

from the baghouse

exhaust shall notexceed

0.004 gr/dscf of exhaust gases.2.b The requirements

of this rule are less stringent

than the requirements

of OAC rule 3745-31- 05(A)(3). 2oC The permittee

satisfies

the "latest available

Control tec,hnologies

and operating

practices" required pursuant

to OAC rule 3745-23-06(B)

by complying

with the best available technology requirements

established

pursuant

to OAC rule 3745-31-05(A)(3). 2.d The permittee

satisfies

the "latest available

control technologies

and operating

practices" required pursuant

to OAC rule 3745-21-08(B)

by complying

with the best available technology.requirements established

pursuant

to OAC :rule 3745-31-05(A)(3). OnN0vember 5, 2002, OAC rule 3745-21-08

was revised to delete paragraph

(B); therefore, paragraph (B) is no longer part of the State regulations.

However,

that rule revision has not yet been submitted

to the 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 rule3745-21-08, the requirements

to satisfy the -"best available

Control technologies

and operating practices"

still exists as part of the federally-approved

SIP for Ohio.Page

23 of .225 Biomass Energy,

LLC South,Point

Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147 Emissions Unit ID: B001

2.e Compliance

with 40 CFR 52.21 and OAC rule 3745-31-(10)through (20) shall be demonstrated by the following

Best Available

Control Technologies

(BACT): PM/PM10 Use of reverse air baghouse

with a design exhaust

not to exceed 0.004 gr/dscf. For this permit,

it is assumed

that all PM emissions

are PM•0. VOC- Use of good combustion

practicesin

the operation

of the boiler and use of an oxidation catalyst. 2.f The permittee

shall install ahd operatethe

following

control technologies

as part of the Best Available Technology

(BAT) requirements: NOx • Use of selective

catalytic

reduction

(SCR) with a NOx control efficiency

of 80%. Use of an oxidation

catalyst with a CO control efficiency,

of 95.7%. SO2- Useof spray dryer absorber

system with a SO 2 control efficiency

of 71.6%. 2.g The permittee

shall ensure that any effected emissions

unit comply with the requirements

of 40 CFR Part 75 and OAC rule 3745-103.

Emissions

exceeding

any allowances

that are lawfully held under Title IV of the ACT, or any iregulations

adopted

thereunder,

are prohibited. II. Operational

Restrictions The p•rmittee

shall only bum wood in this emission

unit. The pressure

drop across th e baghouse

shall be maintained

•within a range of 1 to 5 in inches of water, while the emission

unit is in operation. For the Oxidation

Catalyst,

the average temperature

of the exhaust gases-immediately

before the c.atalyst bed, for any 3-hour block of time when the emissions

unit is in operation,

shall not be mdre than 50 degrees Fahrenheit

below the average temperature

during themost

recent emission

test that demonstrated the emissions

unit was in compliance:

The average temperature

difference

across the catalyst bed, for any 3-hour block of time when'the

emissions

unit is in operation,

shall not be less than 80 percent of the average temperature

difference

during the most recent emission

test that demonstrated the emissions

unit was in compliance.

III. 4. The permittee

shall not operate the auxiliary

boiler (B011) when more than 6 of the wood fired boilers (B001 B007) are in operation. Monitoring and/or Reeordkeeping

Requirements 11 For each day during which the permittee

bums fuel other than wood, the permittee

shall maintain a record of the type and quantity

of fuel burned in this emission

unit.Page

24 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147 Emissions U•nit ID: BOO1

The permittee

shallproperly

install, operate, and maintain

equipment

to monitor the pressure

drop
across the baghouse

while the emissions

unit isin operation. The monitoring

equipment

shall be installed,

calibrated,

operated•

and maintained

in accordance with the manufacturer's

recommendations,

instructions,

and operating

manual(s).

The permittee shall record the pressure

drop across the baghouse

on a daily basis. The permittee

shall operate and maintain

continuous

temperature

monitors

and recorder(s)

which measure and record(s)

the temperature

immediately

upstream

and downstream

of the oxidation catalyst bed when the emissions

unit is in operation.

Units shall be in degrees Fahrenheit.

The monitoring and re•ording

devices shall be capable of accurately

measuring

the desired parameter. The temperature

monitors

and rec0rder(s)

shall be installed,

calibrated,,

operated

and maintained

in accordance with the manufacturer's

recommendations,

with any modifications

deemed necessary by the permittee. The permittee

shall collect and record the following

information

each day:

ao

bo All 3-hour blocks of time (when the emissions

unit was in operation)

during which the average temperature

of the exhaust gases immediately

before the catalyst bed was more than 50 degrees Fahrenheit

below the average temperature

during the most recent emission

test that demonstrated

the emissions

unit was in compliance. All 3-hour blocks of time (when the emissions

unit was in operation)

during which the average temperature.difference across the catalyst bed was less than 80 •ercent bf the average temperature,

difference

during the most recent emission

test that demonstrated

the emissions, unit was in compliance.
A log of the downtime

for the capture (collection)

system, control device, and monitoring equipment, when the associated

emissions

unit was in operation. The permittee

shall record all times when the auxiliary

boiler (B011)is

in operation

and when each wood fired boiler (B001 B007) is in operation. The permittee

shall install, operate,

and maintain

a continuous

opacity monitoring

system to continuously monitor

and record the opacity of the particul•ite

emissions

from this emissions

unit. The continuous

monitoring

and recording

equipment

shall comply with the requirements

specified in 40 CFR Part 60. The permittee

shall maintain

record• of data obtained

by the continuous

opacitymonitoring

system including, but not limited to:

Co percent opacity on an instantaneous

(one-minute)

and 6-minute

block average basis; results of daily zero/span

calibration

checks and the magnitude

bf manual calibration adjustments;hours of operation

of the emissions

unit, continuous

opacity monitoring

system, and control equipment;Page

25 of 225 Biomass Energy,

LLC South Point Power PTI Application:

07-00534 Issued: To be entered upon final issuance Facility

ID: 0744000147 Emissions Unit ID: B001

do the date, time, and hours of operation

of the emissions

unit without the control equipment and/or the continuous

opacity monitoring

system; the date, time, and hours of operation

of the emissions

unit during any malfunction

'of the control equipment

and/or the continuous

opacity monitoring

system; as well as, the reason (if known) and the corrective

actions taken (if any) for each such event in (d) and (e).Prior'to the •nstallation

of the continuous

opacity monitoring

system, the permittee

shall submit information detailing

the proposed

location

of the sampling

site in acgordance

with the siting requirementsin 40 CFR Part 60, Appendix

B, Performance

Specification

1 for approval

by the Ohio EPA, Central Office. Each continuous,

monitoring

system consists of all the equipment

used to acquire and record data in units of all applicable

standard(s),

and includes

the sample extraction

and transport

hardware, sample conditioning

hardware,

analyzers,

and data processing

hardware

and software. 7• Within 180 days of the effective'date

of this permit, the permittee

shall develop

and maintain

a written quality assurance/quality

control plan for the continuous

opacity monitoring

system, designed to ensure continuous

valid and representative

readings

of opacity and compliance

with 40 CFR Part 60. The plan shall include, at a minimum,

procedures

for conducting

and recording

dhily automatic zero/spanchecks,

provisions

for conducting

a quarterly

audit of the continuous

opacity monitoring system, and a description

of preventive

maintenance

activities.

Th• plan shall describe step by step procedures

for ensuring

that Performance

Specification

1 ismaintained

on a continuous basis. The quality assurance/quality

control plan and a logbook dedicated

to the continuous

opacity monitoring system must be kept on site and available

for inspection

during regular office hours. The permitte e shall operate and maintain

equipment

to continuously

monitor and record SO 2 from this emissions

unit in units ofthe applicable

Standard(s).

Such continuous

monitoring

and recording equipment, shall comply with the requirements

specified

in 40 CFR Part 60.13 and 40 CFR Part 75, if applicable.The permittee

shall maintain

records of data obtained

by-the continuous

SO2 monitoring

system including, but not limited to: emissions of SO 2 in parts per million on an instantaneous

(one-minute)

basis; emissions of SO• in pounds per hour and in all units of the applicable

standard(s)

in the appropriate averaging

period; results of quarterly

cylinder

gas audits or linearity

checks if applicable; results of daily zero/span

calibration

checks and the magnitude

of manual calibration adjustments;results of required

relative accuracy

test audit(s),,

including

results in units of the applicable standard(s);hours of operation

of the emissions

unit, continuous

SO/monitoring

system, and control equipment;the date, time, and hours of operation'

of the emissions

unit without the control equipment and/or the continuous

SO2 monitoring

.system;Street

Address: State of Ohio Environmental

Protection

Agency Mailing Address: Lazarus Gov. Center 122 S. Front Street Columbus, OH 43215 TELE: (614) 644-3020 FAX: (614) 644-2329 Lazarus Gov. Center P.O. Box 1049 Columbus, OH 43216-1049

RE: FINAL PERMIT

TO INSTALL WAYNE COUNTY Application No: 02-19776 Fac ID: 0285030221 DATE: 11/18/2004 Cedar Lane Farms Corp Tom Machamer 5713 Back Orrville Rd Wooster, OH 44691 CERTIFIED

MAILi TOXIC rE•'iE• PSI) Y SYNTHETIC

MINOR CEM•MACTNSPSNESHAPSNETTINGMODELING SUBMITTED GASOLINE •ISPENS1NG

FACILITY

Enclosed please find an Ohio EPA Permit to Install which will allow you to install the described

source(s)

in a manner indicated

in the permit. Because

this permit containsseveral

conditions

and restrictions,

I urge you to read it carefully.The Ohio EPA is urging companies

to investigate

pollution

prevention

and energy conservation.

Not only will this reduce pollution

and energy consumption,

but it can also save you money. If you would like to learn.ways

you-can save money while protecting

the environment,

please contact our Office of Pollution

Prevention

at (614) 644-3469. You are hereby notified that this action by the Director

is final and may be appealed

to the Ohio Environmental Review Appeals

Commission

pursuant

to Chapter 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the action complained

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

action. A copy of the appeal must be served on the Director.of

the Ohio Environmental Protection

Agency within three(3)

days of filing with the Commission.

An appeal may be filed with the Environmental

Review Appeals

Commission

at the following

address: Environmental Review Appeals

Commission 309 South Fourth Street, Room 222 Columbus, Ohio 43215 Sincerely,Michael W. Ahem, Manager Permit Issuance

and Data Management

Section Division of Air Pollution

Control CC: USEPA NEDOPermit

To Install Terms and Conditions STATE OF OHIO ENVIRONMENTAL PROTECTION

AGENCY11/18/200411/18/2004 Issue Date:Effectiye Date: FINAL PERMIT

TO INSTALL

02-19776 Application Number:Facility ID:Permit Fee: Name of Facility: PerSon tO Contact:Address:

02-197760285030221$600Cedar Lane Farms Corp Tom Machamer 5713 Back Orrville Rd Wooster, OH 44691 Location of proposed

air contaminant

source(s)

[emissions

unit(s)]: 5713 Back Orrville

Rd Wooster, OhioDescription of proposed

emissions

unit(s): 8.5 mmBtu/hr

Atmospheric

Fluidized

Bed Combuster.
The above named entity is hereby granted a Permit to Install for the above described

emissions

unit(s) pursuant

to Chapter 3745-31

of the Ohio Administrative

Code: Issuance

ofthfs 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 above described

emissions

unit(s) of environmental

pollutants

will operate in compliance

with applicable

State and Federal laws and regulations,

and does not constitute

expressed

orimplied

assurance

that if constructed

or modified in accordance

with those plans and specifications,

the above described

emissions

unit(s) of pollutants

will be granted the necessary

permits to operate (air) or NPDES permits as applicable. This permit is granted subject to the conditions

attached

hereto. Ohio Environmental

Protection

Agency

/DirectorPage

2 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility ID: 0285030221

Part I GENERAL

TERMS

AND CONDITIONS A. Permit to Install General

Terms and Conditions 1. Compliance

Requirements The emissions

unit(s) identified

in this Permit to Install shall remain in full compliance

with all applicable State laws and regulations

and the terms and conditions

of this permit. 2. Reporting

Requirements The permittee

shall submit required

reports in the following

manner:

ao Reports of any required

monitoring

and/or recordkeeping

information

shall be submitted

to the appropriate

Ohio EPA District Office or local air agency. bo Except as otherwise

may be provided

in the terms and conditions

for a specific emissions unit, quarterly

written reports of (a) any deviations

(excursions)

from 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 submiCted

to the appropriate

Ohio EPA District Offic• or local air agency.

If no deviations

occurred

during a calendar

quarter, the permittee shall submit a quarterly

report, which states that no deviations

occurred

during that quarter. The reports shall be submitted

quarterly,

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

calendar

quarters.

(These quarterly reports shall exclude deviations

resulting

from malfunctions

reported

in accordance

with OAC rule 3745-15-06.) 3. Records

Retention

Requirements Each record of any monitoring

data, testing data, and support information

required

pursuant

to this permit shall be retained

for a per!od of five years from the date the record was created.

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

and maintenance

records and all original strip-chart

recordings

for continuous

monitoring

instrumentation,

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

in computerized

form. 4. Inspections

and Information

Requests The Director

of the Ohio EPA, or an authorized

representative

of the Director,

may, subject to the safety requirements

of the permittee

and without undue delay, enter upon the premises

of this source at any reasonable

time for purposes

of making inspections,

conducting

tests, examining

records or reports pertaining

to any emission

of air contaminants,

and determining

compliance

with any applicable State air pollution

laws and regulations

and the terms and conditions

of this permit. 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 mayPage

3 of 40Cedar Lane Farms.Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221

So

St be requested

to determine

whether

cause exists for modifying,

reopening

or revoking

this permit or to determine

compliance

with this permit. Upon verbal or written request, the permittee

shall also furnish to the Director

of the Ohio EPA, or an authorized

representative

of the Director,

copies of records required

to be kept by this permit. Scheduled Maintenance/Malfunction Reporting Any scheduled

maintenance

of air pollution

control equipment

shall be performed

in accordance with paragraph

(A) of OAC rule 3745-15-06.

The malfunction

of any emissions

units or any associated air pollution

control system(s)

shall be reported

to the appropriate

Ohio EPA District Office or local air agency in accordance

with paragraph

(B) of OAC rule 3745-15-06.

Except as provided in that rule, any scheduled

maintenance

0r malfunction

necessitating

the shutdown

or bypassing of any air pollutioncontrol

system(s)

shall be accompanied

by the shutdown

of the emissions unit(s)that

is (are) served by such control system(s). Permit TransfersAny transferee

of this permit shall assume the responsibilities

of the prior permit holder.

The appropriate Ohio EPA District Office or local air agency must.be notified in writing of any transfei of this permit.Air Pollution

Nuisance The air contaminants

emitted by the emissions

units covered by this permit shall not cause a public nuisance, in violation

of OAC rule 3745-15-07. Termination of Permit to Install This Permit to Install shall terminate

within eighteen

months of the effective

date of the Permit to Install if the owner or operator

has not undertaken

a continuing

program

of.installation

or modification or has not entered into a binding contractual

obligation

to undertake

and complete within a reasonable

time a Continuing

program

of installation

or modification.

This deadline

may be extended

by up to 12 months if application

is made to the Director-within

a reasonable

time before the termination

date and the party shows good cause for any such extension. Construction of New Sources(s) The proposed

emissions

unit(s) shall be constructed

in strict accordance

with the plans and application submitted

for this permit to the Director

of the Ohio Environmental

Protection

Agency. There may be no deviation

from the approved

plans without the express,

written approval

of the Agency. Any deviations

from the approved

plans or the above conditions

may lead to such sanctionsPage

4 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221

10.

11.

12.

i3. and penalties

as provided

underOhio

law. Approval

of these plans does not constitute

anassurance that the proposed

facilities

will operate in compliance

with all Ohio laws and regulations. Additional facilities

shall be installed

upon orders of the Ohio Environmental

Protection

Agency if the proposed

sources cannot meet the requirements

of this permit or cannot meet applicable standards.If the construction

of the proposed

emissions

unit(s) has already begun or has been completed

prior to the date the Director

of the Environmental

Protection

Agency approves

the permit application

and plans, the approval

does not constitute

expressed

or implied assurance

that the proposed

facility has been constructed

in accordance

with the approved

plans. The action of beginning

and/or completing construction prior to obtaining

the Director's

approval

constitutes

a violation

of OAC rule 3745-31- 02. Furthermore,

issuance

of the Permit to Install does not constitute

an assurance

that the proposed

source will operate in compliance

with all Ohio laws and regulations.

Approval

of the plans in any case is not to be construed

as anapproval

of the facility as constructed

and/or completed.

Moreover, issuance of the Permit to Install is not to be construed

as a waiver of any rights that the Ohio Environmental Protection

Agenc•¢

(or other persons)

may have against the applicant

for starting construction prior to the effective

date of the permit. Additional

facilities

shall be installed

upon orders of the Ohio Environmental

Protection

Agency

if the proposed

facilities

cannot meet. the requirements of this permit or cannot meet applicable

standards. 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. ApplicabilityThis Permit To Install is applicable

only to the emissions

unit(s) identified

in the Permit To Install. Separate Permit To Install for th• installation

or modification

of any other emissions

unit(s) are required for any emissions

unit for which a Permit To Install is required. Best Available

Technology As specified

in OAC Rule 3745-31-05,

all new sources must employ Best Available

Technology (BAT). Compliance

with the terms and conditions

of this permit will fulfill this requirement. Source Operation

and Operating

Permit Requirements

After Completion

of Construction This facility is permitted

to operate each source described

by this Permit to Install for a period of up to one year from the date the source commenced

operation.

This permission

to operate is granted only if the facility complies,

with. all requirements

contained

in this permit and all applicable

air pollution laws, regulations,

and policies.

Pursuant

to OAC Chapter

3745-35,

the permittee

shall submit a complete

operating

permit application

within ninety (90) days after commencing

operation of the emissions

unit(s) covered by this permit.Page

5 of 40Cedar Lane Farms Corp PT ! Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221

no 14. Construction

Compliance

Certification The applicant

shall provide Ohio EPA with a written certification

(see enclosed

form) that the facility has been constructed

in accordance

with the Permit to Install application

and the terms and conditions of the Permit to Install. The certification

shall be provided

to Ohio EPA upon completion of construction

but prior to startup of the source. 15. FeesThe permittee

shall pay fees to the Director

of the Ohio EPA in accordance

with ORC section 3745.11 and OAC Chapter

3745-78.

The permittee

shall pay. all applicable

Permit to Install fees within 30 days after the issuance

of this Permit to Install: Permit to Install Summary

of Allowable

Emissions The following

information

summarizes

the total allowable

emissions,

by pollutant,

based on the individual allowable emissions

of each air contaminant

source identified

in this permit. SUMMARY (for informational

purposes

only) TOTAL PERMIT

TO INSTALL

ALLOWABLE

EMISSIONS PollutantSO2NOxCOPE Tons Per Year98.310.612.611.9Page

6 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

PART II SPECIAL

TERMS

AND CONDITIONS

FOR SPECIFIC

EMISSIONS

UNIT(S) A. Applicable

Emissions

Limitations

and/or Control

Requirements The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions

limitations

and/or control measures.

Emissions

from this unit shall not exceed the listed limitations,

and the listed control measures

shall be specified

in narrative

form following the table. Operations, Property, and/or Equipment B002 Erie City 5.56 mrnBtu/hour coal-fired, underfeed

stoker/boiler

Applicable

Rules/Requirements OAC rule 3745-31-05(A)(3)

OAC rule 3745-31-05(C) Applicable

Emissions Limitations/Control Measures Sulfur dioxide (SO2): 5.4 lbs/mmBtuNitrogen Oxides (NOx): 1.9 lbs/hourCarbon Monoxide

(CO): 2.2 lbs/hourParticulates

(PE): 0.6 lb/mmBtu

and 3.0 lbs/hour Quality of coal• See Section A.I.2.c The requirements

of this rule also include compliance

with OAC rule 3745-31-05(C) and OAC rule 3745- 17-07(A).Amount of coal usage limited to 1,400 tons per year, on a 12-month rolling basis, for emissions

units B002, B005 & B009. SO2"- 98.3 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009.

C:\pti_holding\0219776f.wpdPage

7 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002
NOx: 10.6 tons/year,

ona 12-month rolling basis, for emissions

units B002, B005 & B009.

OAC rule 3745-17-07(A) OAC rule 3745-17-10(C)(2) CO: 12.6 tons/year,

on a 12-month rolling basis,, for emissions

units B002, B005 & B009. PE: 11.9 t0ns/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. See Section A.I.2.d See Section A.I.2.a and & b. The particulate

emissions

limitation specified by this rule is equivalent

tO the particulate

emissions

limitation established by OAC rule 3745-31- 05(A)(3). 2. Additional

Terms and Conditions 2.a This emissions

unit shall comply with the following

visible particulate

emissions

limits: The visible particulate

emissions

from the exhaust stack serving this emissions unit shall not exceed an opacity of twenty(20)

percent as a six-minute

average. ii. The visible particulate

emissions

from the stack may exceed twenty (20) percent as a six-minute

average for not more than six (6) consecutive

minutes

in any sixty-minute period, but shall not exceed sixty (60) percent opacity at any time. 2.b The visible particulate

emission

limitations

specified

by OAC rule 3745-17-07(A)

shall not apply, to the following

operations,

provided

the operations

are documented

daily in a boiler operations

log kept at the facility.

The log shall clearly document

the date, beginning time, and ending time of the exempted

operations

listed below. The start-up of the source for a period of time required

to achieve stable combustion conditions,

but no more than three (3) hours from the moment

of start-up. "Start-up"

means the commencement

of firing of fuel from a coldnonfired condition.

C:\pti_holding\0219776f.wpdPage

8 of 40.Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

no ii. The shutdown

of the source for a period of not more than three (3) hours.

111. The malfunction

of the source or associated

equipment,

if the owner of the source or operator

of the equipment

complies

with the requirements

of OAC rule 3745- 15-06.iv, Intermittent

soot blowing

operations

(the cleaning

of heat transfer surfaces with pressurized air or steam).

v. Intermittent

ash removal

operations

(the dumping

or pulling of ash). vi. The commencement

of increased

coal firing from a banked condition

for a period notto exceed thir6y (30) minutes.

"Banked

condition"

means the condition

where the fuel is burned on the grates at rates which are sufficient

to maintain

ignition only. 2.C The coal received,

for use in this emissions

unit will have an ash content of less than 8.0 percent by weight, a heat content of greater than thirteen thousand

BTU per pound, and a percent sulfur content no greater than 3.70 %. Ash content, heat content, and sulfur content shall be determined

on a dry basis in accordance

with the procedures

specified

in OAC rule 3745-17-03(B)(9). 2.d The Coal usage restriction

of 1,400 tons/year

on a12-month

rolling basis pertains to all coal used in emissions

units B002, B005, and B009. The annual limits for SO2, NOx, CO and PE on a 12-month

rolling basis, are combined

for emissions

units B002, B005 and B009. Operational Restrictions Amount of coal usage is limited to 1,400 tons per year, on a 12-month

rolling basis, for emissions units B002, B005 and B 009. During the first twelve (12) months of operation

under this permit, emissions

units B002, B005 and B009 shall not exceed the cumulative

total amount of coal usage as specified

for each month in the following

table: Calendar Month

Cumulative

Allowable

Amount

of C0al Usage, in tons 175 2 350 3 525 4 700 5 875 6 1,050

C:•pti_holding\O219776•wpdPage

9 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit 1D: B002

Co 7 1,225 8 1,400 9 1,400 10 1,400 11 1,400 12 1,400 Monitoring and/or Recordkeeping

Requirements The permittee

shall maintain

a operation

log for this emissions

unit. This .operations

log shall contain, at minimum,

the following

information:

a: The dates and times of any start-up and shutdown

of this emissions

unit; b. •The duration

(in minutes)

of the exempted

operations

listed in Section A.2.b;

c. The number of hours of normal or full firing is to be recorded

for each day of operation; d. The number of hours of banked condition

is to be recorded

for each day of operation;

e. The total number of hours of operation,

i.e:, the summation

of(c) & (d); f. The amount of coal (in tons) fed to and burned in this emissions

unit each day; The dates and times of any malfunction

of this emissions

unit and any corrective

action taken;For each shipment

of coal to be burned in this emissions

unit• the permittee

shall record the following information:

a. The name of the coal supplier; b° The location of the coal when the samplewas

collected

for analysis

to determine

the properties of the coal, specifically

including

whether

the coal was sampled

as delivered

to the facility or whether

the sample was collected

from coal in storage at the mine, at a coal preparation plant, at a coal supplier's

facility, or at another location.

The report shall include the name of the coal mine (and coal seam), coal storage facility, or coal preparation plant (where the sample was collected);

c. The total quantity

(in tons) of coal received; d. The sulfur content (in percent)

of the coal on a dry basis;

e. The moisture

content of the coal on a dry basis;
C:\pti_holding\0219776 f.wpdPage

1.0 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

The ash content (in percent ) of the coal on a dry basis; The heat content (BTU per pound) of the coal on a dry basis; The methods

used to determine

the properties

&the coal. The permittee

shall maintain

the following

monthly

records for this emissions

unit, when in operation:

ao The sulfur dioxide emissions

rate, in pounds sulfur dioxide per mmBtu,

as calculated

by the equation

found in OAC rule 3745-18-04(F). ERwhere;ERHS 1,000,O00/H

x S x 1.9.

Emissions rate in pounds sulfur dioxide per mmBtu (lbs/mmBtu) Heating capacity

of the coal, in Btu per pound (Btu/lb),

on a dry basis Percent sulfur content of the coal, expressed

as a decimal,

on a dry basis The average,

hourly nitrogen

oxides (NOx), Carbon monoxide

(CO) and particulate

(PE) emissions rates by use of the following

equation,

when this emissions

unit is in operation. ER EF x CoalHours where;EREF

Coal

Hours Emissions

rate in pounds per hour Emissions Factor, taken from AP-42 Tables 1.1-3 & 4 as follows: NOx 9.5 lbs NOx/ton

of coal CO 11 lbs CO/ton of coal PE 15 lbs PE/ton of coal The amount of coal (in tons) fed to the emissions

unit and burned that day,

as recorded

in Section C. 1.f. The total number of hours of operation

(total of both full firing and banked),, as recorded

in Section C. 1. e, for the entire month. The particulate

emissions

rate, in pounds per mmBtu,

as calculated

by the following equation. C:\pfi_holding\0219776 f.wpdPage

11 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

ERwhere;ERPE Hr

HC

PE Hr / HC

Emissions rate in pounds particulate

per mmBtu Particulate hourly emissions

rate (lbs PE/hr) as calculated

in Section C.3:b.Maximum heating capacity

of emissions

unit, in mmBtu per hour The permittee

shall maintain

the following

monthly

records regarding

coal usage for emissions units .B002, B005 and B009:

a. The total amount of coal, in tons, fed to and burned in emissions

units B002 and B005. b. The total amount of coal, in tons, fed to and burned in emissions

unit B009.

c. The cumulative,

total amount of coal, in tons, fed to and burned in emissions

units B002 and B005 for the past 12-months. d. The cumulative,

total amount of coal, in tons, fed to and burned in emissions

unit B009 for the past 12-months The permittee

shall maintain

the following

monthly

records regarding

emissions

rates for emissions units B002, B005 and B009:

a. The cumulative

sulfur dioxide emissions

rate, in tons per rolling 12-months,

as calculated by the following

equation. ER [Coal amt from B002 & B005 x 140.4 lbs SOz/ton of coal x ton/2,000 lbs] + [Coal amt from B009 x 23.4 lbs SO2/ton x ton/2,000

lbs] where;ER Emissions

rate, in tons sulfur dioxide per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months, as recorded

in Section C.4.c. "140.4 lbs SO2/ton"

is the converted

value in lbs/ton from 5.4 lbs SO2/mmBtu,

which is the allowable

sulfur dioxide emissions

rate. Per AP-42 Chapter

1. ! 5, the conversion

is performed by multiplying

5.4 lbs SO2/mmBtu

with 26.0 mmBtu/ton

to produce

140.4 lbs SO2/ton.
C:\pti_holding\0219776f.wpdPage

12 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

bo

Co "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "23.4 lbs SO2/ton"

is the converted

valuein

Ibs/ton from 0.9 lb SO2/mmBtu,

which is the allowable sul.fur dioxide emissions

rate. The cumulative

NOx emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 9.5 lbs NOx/ton

of coal x ton/2,000

lbs] + [Coal amt from B009 x 15.2 lbs NOx/ton

of coal x ton/2,000

lbs] where;ER Emissions

rate, in tons NOx per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months, as recorded

in Section C.4.c. "9.5 lbs NOx/ton

of Coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-3. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "15.2 lbs NOx/ton

of coal" is an emissions

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3. The cumulative

CO emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 11 lbs CO/ton of coal x ton/2,000

lbs] + [Coal amt from B009 x 18 lbs CO/ton of coal x tord2,000

lbs] where;ER Emissions

rate, in tons CO per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months,

as recordedin

Section C.4.c. "11 lbs NOx/ton

of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-3.

C:\pti_holding\0219776 f.wpdPage

13 of 40Cedar Lane FarmsCorp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

Ot "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months, as recorded

in Section C.4.d. "18 lbs CO/ton of coal" is an emissions

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3. do, The cumulative

PE emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 15 lbs PE/ton of coal x ton/2,000

lbs] + [Coal amt from B009 x 17 lbs PE/ton 0f coal x ton/2,000

lbs x (0.07)] where;ER Emissions

rate, in tons PE per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "15 lbs PERon of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-4. "Coal amt from B009" is the total amount of coal, in tons, fed to and bumed in emissions unit B009 over the past 12 months, as recorded

in Section C.4.d. "17 lbs PE/ton of coal"is an emissions

factor, taken from AP-42, Table 1.1-4. "(0.07)" is the result of (1 minus control efficiency

ofbaghouse,

which is 93% or 0.93). Reporting Requirements The permittee

shall submit quarterly

deviation

(excursion)

reports which include the following information:An identification

of each day during which the hourly emissions

limitation(s)

for NOx, CO and/or PE was/were

exceeded,

and the actual hourly emissions

rate forthe applicable pollutant(s); bo An identification

of each day during which the sulfur dioxide emissions

limitation

(in lbs SO2/mmBtu) and/or the particulate

emissions

limitation

(lbs PE/mmBtu)

was/were exceeded, and the actual emissions

rate(s) for the applicable

pollutant(s);

Co An identification

of each day during which the visible, particulate

emissions

from the exhaust serving this emissions

trait exceeded

the limitations

specified

in OAC rules 3745- 17-07(A)(1) & (A)(2).

C \pti_ho ding\O2.19776f.wpdPage

14 of 40Cedar Lane Farms Corp PTI Application:

02,19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

EJ An identification

of any shipment

of coal used for this emissions

unit that did not meet the ash, heat, and sulfur specifications

listed in Section A.2.c.

eo An identification

of each day during which any required

monitoring

and record keeping

as listed in Section C was not performed.
An identification

of each month within the quarter when the total amount Of coal used
over the past • 2 months in emissions

units B002, B005 and B009-exceeds

1,400 tons. The actual total amount of coal for each such month shall be reported,
An identification

of each month within the quarter when the calculated

annual SO2, NOx, CO and PE emissions

rates, as recorded

per Section C.5, exceeds the appropriate allowable limit. The actual, calculated

annual emissions

rates for these pollutants

shall also be reported. The calendar

quarters

are January

March 31, April 1 June 30, Julyl • September

30, and October. 1 December

31. If no deviations

occurred.during

•he calendar

quarter, the permittee

shall submit a quarterly report, which states that no deviations

occurred

during that quarter.

The reports shall submitted quarterly, i.e., by January 31, April 30, July 31, and October

31 of each year and shall cover the previous calendar

quarter. Testing RequirementsEmissions

Limitation: 5.4 lbs SO2/mmBtu

for B002 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.a.If required

by the Ohio EPA, compliance

may be determined

in accordance

with 40 CFR Part 60, Appendix A, Method 6C. Emissions Limitation: 98.3 tons SO2/rolling

12-months

for B002, B005 & B009 Applicable Compliance

Method: Compliance with the.above

emissions

limitation

shall be determined

on the record keeping

in Section C.5•a.Emissions Limitation: 1.9 lbs NOx/hour

for B002
C:\pti_holding\0219776f.wpdPage

15 of 40Cedar Lane Farms Corp PTI.Application: 02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping,

in Section C.3.b.Emissions Limitation: 10.6 tons NOx per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.b.Emissions Limitation: 2.2 lbs CO/hour

for B002 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be detemained

on the record keeping

in Section C.3.b.Emissions Limitation: 12.6 tons CO per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.c.Emissions Limitation: 0.6 lb PE/mmBtu

for B002 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the .record keeping

in Section C.3.c.Emissions Limitation: 3.0 lbs PE/hr for B002 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.b.Emissions Limitation: 11.9 tons PE per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

ghall be determined

on the record keeping

in Section C.5.d. C:\pti_holding\0219776 f.wpdPage

16 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B002

10. Emissions

Limitation: Visible particulate

emissions

(VE) shall not exceed an opacity of twenty (20) percent as asixminute average.

VE may exceed 20 percent asa six-minute

average for not more than six (6) consecutive minutes

in any six•-minute

period, but shall not exceed sixty (60) percent opacity at any time. This emissions

limitation

applies, except as exempted

by OAC rule 3745-17-07(A)(3). Applicable Compliance

Method:. Compliance with the above emissions

limitation

shall be determined

in accordance

with 40 CFR Part 60, Appendix

A, Method 9 and the procedures

specified

in OAC rule 3745-17-03(B)(1). Miscellaneous Requirements 1. The terms and conditions

of this permit supercede

those for B002 established

in PTI # 02-2745. 2. The terms and conditions,

of this permit to install are federally

enforceable.

C:\pii:holding\0•219776f.wpdPage

17 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility ID: 0285030221 Emissions Unit ID: B005

PART II SPECIAL

TERMS

AND CONDITIONS

FOR SPECIFIC

EMISSIONS

UNIT(S) A. Applicable

Emissions

Limitations

and/or Control

Requirements The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions

limitations

and/or control measures.

Emissions

from this unit shall not exceed the listed.limitations,

and the listed control measures

shall be specified

in narrative

form following the table. Operations, Property, and/or Equipment B005 Burnhan

5.6 mmBtu/hour coal-fired underfeed

stoker/boiler

Applicable

Rules/Requirements OAC rule 3745-31-05(A)(3)

OAC rule 3745-31-05(C) Applicable

Emissions. Limitations/Control Measures Sulfur dioxide (SO2): 5.4 lbs/mmBtuNitrogen Oxides (NOx): 1.9 lbs/hourCarbon Monoxide

(CO): 2.2 lbs/hourParticulates

(PE): 0.6 lb/mmBtu

and 3.0 lbs/hour Quality of coal:See Section A.I.2.c The requirements

of this rule also include compliance

with OAC rule 3745-31-05(C) and OAC rule 3745- i7-07(A).Amount of coal usage limited to 1,400 tons per year, on a 12-month rolling basis, for emissions

units B002, B005 & B009. SO2:98.3 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009.

C:\pti_holding\0219776 f.wpdPage

18 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: BOOS

OAC rule 3745-17-07(A)(1) OAC rule 3745-17-10(C)(2) NOx: 10.6 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. CO: 12.6 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. PE: 11.9 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. See Section A.I.2.d See Section A.I.2.a and & b. The particulate

emissions

limitation specified by this rule is equivalent

to the particulate

emissions

limitation established by OAC rule 3745-31 05(1)(3). Additional Terms and Conditions 2.a This emissions

unit shall comply with the following

visible particulate

emissions

limits: The visible particulate

emissions

from the exhaust stack serving this emissions unit shall notexceed

an opacity of twenty (20) percent as a six,minute

average. ii. The visible particulate

emissions

from the stack may exceed twenty (20) percent as a six-minute

average for not more than six (6) consecutive

minutes

in any sixty-minute period, but shall not exceed sixty (60) percent opacity at any time. 2.b The visible particulate

emission

limitations

.specified

by OAC rule 3745-17-07(A)

shall not apply to the following

operations,

provided

the operations

are documented

daily in a boiler operations

log kept at the facility.

The log shall clearly document

the date, beginning time,, and ending time of the exempted

operations

listed below. The start-up of the source for a period of time required

to achieve stable combustion conditions,

but no more than three (3) hours from the moment

of start-up. "Start-up"

means the commencement

of firing of fuel from a coldnonfired condition. ii. The shutdown

of the source for a perio d of not more than three (3) hours. C:\pti_holding\0219776f.wpdPage

19 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

Bo iii. The malfunction

of the source or associated

equipment,

if the owner of the source or operator

of the equipment

complies

with the requirements

of OAC rule 3745- 15-06.iv. Intermittent

soot blowing

operations

(the cleaning

of heat transfer surfaces with pressurized air or steam).

v. Intermittent

ash removal

operations

(the dumping

or pulling of ash). vi. The commencement

of increased

coal firing from a banked condition

for a period not to exceed thirty (30) minutes.

"Banked

condition"

means the condition

where the fuel is burned on the grates at rates which are sufficient

to maintain

ignition only. 2oC The coal received

for use in this emissions

unit will have an ash content of less than 8.0 percent by weight, a heat content of greater .than thirteen thousand

BTU per pound, and a percent sulfur content no greater than 3.70 %. Ash content, heat content, and sulfur content shall be determined

on a dry basis in accordance

with the procedures

specified

in OAC rule 3745-17-03(B)(9). 2.d The coal usage restriction

of 1,400 tons/year

on a 12-month

rolling basis pertains

to all coal used in emissions

units B002, B005, and B009. The annual limits for SO2, NOx, CO and PE on a 12-month

rolling basis, are combined

for emissions

units B002, B005 and B009. Operational Restrictions Amount of coal usage is. limited to 1 ;400 tons per year, on a 12-month

rolling basis, for emissions units B002, B005 and B009. During the first twelve (12) months of operation

under this permit, emissions

units B002, B005 and B009 shall not exceed the cumulative

total amount of coal usage as specified

for each month in the following

table: Calendar Month

Cumulative

Allowable

Amount

of Coal Usage, in tons 1 175 2 350 3. 525 4 700 5 875 6 1,050 7 1,225 8 1,400

C:\pti_holding\0219776f.wpdPage

20 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

9 1,400 10 1,400 11 1.,400 12 1,400 Monitoring and/or Recordkeeping

Requirements 1. The permittee

shall maintain

a operations

log for this emissions

unit. This operations

log shall contain,, at minimum,

the following

information:

a. The dates and times of any start-up and shutdown

of this emissions

unit; b. The duration

(in minutes)

of the exempted

operations

listed in Section A.2.b;

c. The number of hours of normal or full firing is to be recorded

for each day of operation; d. The number of hours of banked condition

is to be recorded

for each day of operation;

e. The total number of hours of operation,

i.e., the summation

of (c) & (d); f. The amount of coal (in tons) fed to and burned in this emissions

unit each day; g. The dates and times of any malfunction

of this emissions

unit and any corrective

action taken;For each shipment

of coal to be burned in this emissions

unit, the permittee

shall record the following information:

a. The name of the coal supplier; b. The location

of the coal when the sample was collected

for analysis

to determine

the properties of the coal, specifically

including

whether

the coal was sampled

as delivered

to the facility or •vhether the sample was collected

from coal in storage at the mine, at a Coal preparation plant, at a coal supplier's

facility, or at another location.

The report shall include the name of the coal mine (and coal seam), coal storage facility, or coal preparation plant (where the sample was collected);

c. The total quantity

(in tons) of coal received; d. The sulfur content (in percent)

of the coal on a dry basis;

e. The moisture

content of the coal on a dry basis; £ The ash content (in perce/at)

of the coal on a dry basis;
C:\pti_holding\0219776f.wpdPage

21 of. 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

g. The heat content (BTU per pound) of the coal on a dry basis; h. The methods

used to determine

the properties

of the coal. The permittee

shall maintain

the following

monthly

records for this emissions

unit, when in operation:

a. The sulfur dioxide emissions

rate, in pounds sulfur dioxide per mmBtu,

as calculated

by the equation

found in OAC rule 3745-18-04(F). 1,000,000/H x S x 1.9.

bo

Co ERwhere;ERHS

Emissions

rate in potmds sulfur dioxide per mmBtu (lbs/mmBtu) Heating capacity

of the coal, in Btu per pound (Btu/lb),

on a dry basis Percent sulfur content of the coal, expressed

as a decimal,

on a dry basis The average,

hourly nitrogen

oxides (NOx), carbon monoxide

(CO) and particulate

(PE) emissions rates by use of the following

equation,

when this emissions

unit is in operation.
ER EF x CoalHours where;EREF

Coal

Hours Emissions

rate in pounds per hour Emissions Factor, taken from AP-42 Tables 1.1-3 & 4 as follows: NOx 9.5 lbs NOx/ton

of coal CO 11 lbs CO/ton of coal PE 15 lbs PE/ton of coal The amount of coal (in tons) fed to the emissions

unit and burned_thatday,
as recorded

in Section C. 1.f. The total number of hours of operation

(total of both full firing and banked), as recorded

in Section C. 1. e, for the entire month. The particulate

emissions

rate, in pounds per mmBtu,

as calculated

by the following equation.ER PE Hr / HC C:\pti_holding\0219776f.wpdPage

22 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004

where; Facility

ID: 0285030221 Emissions Unit ID: B005

ER Emissions

rate in pounds particulate

per mmBtu PE Hr

Particulate

hourly emissions

rate (lbs PE/hr) as calculated

in Section C.3.b. HC Maximum

heating capacity

of emissions

unit, in mmBtu per hour The permittee

shall maintain

the following

monthly

records regarding

coal usage for emissions units B002, B005 and B009:

a. The total amount of coal, in tons, fed to and burned in emissions

units B002 and B005. b. The total amount of coal, in tons, fed to and burned in emissions

unit B009.

Co The cumulative,

total amount of coal, in tons, fed to and burned in emissions

units B002 and B005 for the past 12-months. do The cumulative,

total amount of coal, in tons, fed to and burned in emissions

unit B009 for the past 12-months The permittee

shall maintain

the following

monthly

records regarding

emissions

rates for emissions units B002, B005 and B009:

ao The cumulative

sulfur dioxide emissions

rate, in tons per rolling 12-months,

as calculated by the following

equation: ER [Coal amt from B002 & B005 x 140.4 lbs SO2/ton of coal x ton/2,000 lbs] 4- [Coal amt from B009 x 23.4 lbs SO2/ton x ton/2,000

lbs] where;ER Emissions

rate, in tons sulfur dioxide per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "140.4 lbs SO2/ton"

is the converted

value in lbs/ton from 5.4 lbs SO2/mmBtu,

which is the allowable

sulfur dioxide emissions

rate. Per AP-42 Chapter

1.15, the conversion

is performed by. multiplying

5.4 lbs SO2/mmBtu

with 26.0 mmBtu/ton

to produce

140.4 lbs SO2/ton."Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. C:\pti_holding\0219776 f.wpdPage

23 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

bo "23.4 lbs SO2/ton"

is the converted

value in lbs/ton from 0.9 lb SO2/mmBtu,

which is the allowable sulfur dioxide emissions

rate. The cumulative

NOx emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 9.5 lbs NOx/ton

of coal x ton/2,000

lbs] + [Coal amt from B009 x 15.2 lbs NOx/ton

of coal x ton/2,000

lbs] where;ER Emissions

rate, in tons NOx per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed toand burned in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "9.5 lbs NOx/ton

of coal" is an emissions

factor for under feed stoker boilers, taken, from AP-42, Table 1.1-3. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "15.2 lbs NOx/ton

of coal" is an emissions

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3. The cumulative

CO emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 11 lbs CO/ton of coal x ton/2,000

lbs] + [Coal amt from B009 x 18 lbs CO/ton of coal x ton/2,000

lbs] where;ER Emissions

rate, in tons CO per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "11 lbs NOx/ton

of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-3. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d.

C:\pti_holding\0219776f.wpdPage

24 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued:.11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

Do "18 lbs CO/ton of coal" is an emissions

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3. The cumulati•,e

PE emissions

rate, in tons per rolling 12-months,

as calculated

by the -following equation. ER [Coal amt from B002 & B005 x 15 lbs PE/ton of coal x t0n/2,000

lbs] + [Coal amt from B009 x 17 lbs PE/ton of coal x ton/2,000

lbs x (0.07)] where;ER Emissions

rate, in tons PE per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 andB005

over the past 12 months, as recorded

in Section C.4.c. "15 lbs PE/ton of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-4. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "17 lbs PE/ton of coal" is an emissions

factor, taken from AP-42, Table 1.1-4. "(0.07)" is the result of(t minus control efficiency

ofbaghouse,

which is 93% or 0.93). Reporting Requirements The permittee

shall submit quarterly

deviation

(excursion)

reports which include the following information:An identification

of each-day

during which the hourly emissions

limitation(s)

for NOx, CO and/or PE was/were

exceeded,

and the actual hourly emissions

rate for the applicable pollutant(s);
An identification

of each day during which the sulfur dioxide emissions

limitation

(in lbs SO2/mmBtu) and/or the particulate

emissions

limitation

(lbs PE/mmBtu)

was/were exceeded, and the actual emissions

rate(s) for the applicable

pollutant(s);
An identification

Of each day during which the visible particulate

emissions

from the exhaust serving this emissions

unit exceeded

the limitations

specified

in OAC rules 3745- 17-07(A)(1) & (A)(2). d. An identification

of any shipment

of coal used for this emissions

unit that did not meet the ash, heat, and sulfur Specifications

listed in Section A.2.c. C:\pti_holding\0219776f.wpdPage

25 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

An identification

of each day during which any required

monitoring

and record keeping
as listed in Section C was not performed. An identification

of each month within the quarter when the total amount of coal used over the past 12 months in emissions

unitsB002,

B005 and B009 exceeds

1,400 tons. The actual total amount of coal for each such month shall be reported. An identification

of each month within the quarter when the calculated

almual SO2; NOx, CO and PE emissions

rates, as recorded

per Section C.5, exceeds the appropriate allowable limit. The actual, calculated

annual emissions

rates for these pollutants

shall also be reported. The calendar

quarters

are January

March 31, April 1 June 30, Julyl September

30, and October 1 December

31. If no deviations

occurred

during the calendar

quarter, the permittee

shall submit a quarterly report, which states that no deviations

occurred

during that quarter.

The reports shall submitted quarterly, i.e., by January 31, April 30, July 31, and October

31 of each year and shall cover the previous calendar

quarter. Testing Requirements Emissions

Limitation: 5.4 lbs SO2/mmBtu

for B005 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping,

in Section C.3.a.If required

by the Ohio EPA, compliance

may be determined

in accordance

with 40 CFR Part 60, Appendix A, Method 6C. Emissions Limitation: 98.3 tons SO2/rolling

12-months

for B002, B005. & B009 Applicable Compliance

Method: Compliance witli the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.a.Emissions Limitation: 1.9 lbs NOx/hour

for B005 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.b. C:\pti_holding\0219776 f..wpdPage

26 of 40Cedar Lane Farms Corp PTI Application:

02-19776 .issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

Emissions Limitation: 10.6 tons NOx per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.b.Emissions Limitation: 2.2 lbs CO/hour

for B005 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping in Section C.3.b.Emissions Limitation: 12.6 tons CO per year, on a i2-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping m Section C.5.c.Emissions Limitation: 0.6 lb PE/mmBtu

for B005 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.c.Emissions Limitation: 3.0 lbs PE/hr for B005 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

•n Section C.3.b.Emissions Limitation: 11.9 tons PE per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping in Section C.5.d.

C:\pti_holding\0219776f.wpdPage

27 of 40Cedar Lane Farms Corp PTIApplication: 02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B005

10. Emissions

Limitation: Visible particulate

emissions

(VE) shall not exceed an opacity of twenty (20) percentas

asixminute average•

VE may exceed 20 percent as a six-minute

average for not more than six (6) consecutive minutes

in any sixty-minute

period, but shall not exceed sixty (60) percent opacity at any time. This emissions

limitation

applies, except as exempted

by OAC rule 3745-17-07(A)(3). Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

in accordance

with 40 CFR Part 60, Appendix

A, Method 9 and the procedures

specified

in OAC rule 3745-17-03(B)(1). Miscellaneous Requirements 1. The terms and conditions

of this permit superced.e

those for B005 established

in PTI # 02-2745. 2. The terms and conditions

of this permit to install are federally

enforceable:

C:\pti_holding\0219776 f.wpdPage

28 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 FacilityID:

0285030221 Emissions Unit ID: B009

PART II SPECIAL

TERMS

AND CONDITIONS

FOR SPECIFIC

EMISSIONS

UNIT(S) A. Applicable

Emissions

Limitations

and/or Control

Requirements The specific operations(s),

property,

and/or equipment

which constitute

this emissions

unit are listed in the following

table along with the applicable

rules and/or requirements

and with the applicable emissions

limitations.and/or

control measures.

Emissions

from this unit shall not exceed the listed limitations,

and the listed control measures

shall be specified

in narrative

form following the table. Operations, Property, and/or Equipment B009 8.5 mmBtu/hr

atmospheric fluidized bed combustor

and boiler,, equipped

with a fabric filter for particulate

control Applicable

Rules/Requirements OAC rule 3745-31-05(A)(3)

OAC rule 3745-31-05(C) Applicable

Emissions Limitations/Control Measures Sulfur dioxide (SO2): 0.9 lb/mmBtuNitrogen Oxides (NOx): 4.9 lbs/hourCarbon Monoxide

(CO):

0d• e 5.9 lbs/hour

• • Particulates (PE): 0.5 lb/mmBtu

and 0.4 lb/hour. See Section A.I.2.f Coal Quality:See Section A.I.2.c Calcium to sulfur ratio: See Section A.I.2.e. The requirements

of this rule also include compliance

with OAC rule 3745-31-05(C) and OAC rule 3745- 17-07(A).Amount of Coal.usage

limited to 1,400 tons per year, on a 12-month rolling basis, for emissions

units B002, B005 & B009.

C:\p|i_holding\0219776fiwpdPage

29 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility ID: 0285030221 Emissions Unit ID: B009

OAC rule 3745-17-07(A)(1) OAC rule 3745-17-10(C)(2) SOs: 98.3 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. NOx: 10.6 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. CO: 12.6 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. PE: 11.9 tons/year,

on a 12-month rolling basis, for emissions

units B002, B005 & B009. See Section A.I.2.d See Sections

A.I.2.a & b The particulate

emissions

limitation specified by this rule is equivalent

to the particulate

emissions

limitation established by OAC rule 3745-31- 05(A)(3). Additional Terms and Conditions 2.a This emissions

unit shall comply with the following

visible particulate

emissions

limits: The visible particulate

emissions

from the exhaust stack serving this emissions unit shall not exceed an opacity of twenty (20) percent as a six-minute

average. ii. The visible particulate

emissions

from the stack may exceed twenty (20) percent as a six-minute

average for not more than six (6) consecutive

minutes

in any sixty-minute period, but shall not exceed sixty. (60) percent opacity at any time. 2.b The visible particulate

emission

limitations

specified

by OAC rule 3745-17-07(A)

shall not apply to the following

operations,

provided

the operations

are documented

daily in a boiler operations

log kept at the facility.

The log shall clearly document

the date, beginning time, and ending time of the exempted

operations

listed below. The start-up of the source for a period of time required

to achieve stable combustion conditions,

but no more than three (3) hours from the moment

of C:\pti_holding\0219776 f.wpdPage

30 of 40Cedar Lane Farms Corp PTI Application:

02--19776 Issued: 11/18/2004 Facility ID: 0285030221 Emissions Unit ID: B009

2oC

2.d

2oe

2.f2.g start-up.

"Start-up"

means the commencement

of firing of fuel from a coldnonfired condition. ii. The shutdown

of the source for a period of not more than three (3) hours. iii. The malfunction

6f the source or associated

equipment,

if the owner of the source or operator

of the equipment

complies

with the requirements

of OAC rule 3745- 15-06:iv. Intermittent

soot blowing

operations

(the cleaning

of heat transfer surfaces

with pressurized air or steam).

v. Intermittent

ash removal

operations

(the dumping

or pulling of ash). vi. The commencement

of increased

coal firing from a banked condition

for a period not to exceed thirty (30) minutes.

"Banked

condition"

means the condition

where the fuel is burned on the grates at rates which are sufficient

to maintain

ignition only.The coal received

for use in this emissions

unit will have an ash content of less than 8.0- percent by weight, a heat content of greater than thirteen thousand

BTU per pound, and a percent sulfur content no greater than 3.70 %. Ash content, heat content, and sulfur content shall be determined

on a dry basis in accordance

with the procedures

specified

in OAC rule 3745-17-03(B)(9). The coal usage restriction

of 1,400 tons/year

on a 12-month

rolling basis pertains to all coal used in emissions

units B002, B005, and B009. The annual limits for SO2, NOx, CO and PE on a l'2-month

rolling basis, are combined

for emissions

units B002, B005 and B009.This emissions

unit shall-maintain

a minimum

calcium

(from injection

of limestone

or equivalent) to sulfur (contained

in coal fuel) weight ratio within 1.08 and 1.2 in the fluid bed of the reactor at all times. The particulate

emissions

,from this emissions

unit will be Controlled

by a 93% efficient fabric filter dust collector. The restrictions

regarding

the use of fly ash re-injection

and an over fire air system found in OAC rule 3745-17-10(C)(7)(a)

are not applicable

to this bubbling

fluidized

bed coal combustion process.

C:\p ti_holding\0219776f.wpdPage

31 of 40Cedar LaneFarms

Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

Bo Operational

Restrictions Amount of coal usage is limited to 1,400 tons per year, on a 12-month

rolling basis, for emissions units B002, B005 and B009. During the first twelve (12) months of operation

under.this

permit, emissions

units B002, B005 and B009 shall not exceed the cumulative

total amount of coal usage as specified

for each month in the following

table: Calendar Month

Cumulative

Allowable

Amount

of Coal Usage, in tons 1 175 2 350 3 525 4 700 5 875 6 1,050 7 1,225 8. 1,4OO 9 1,400 10 1,400 11 1,400 12 1,400 The pressure

drop across the baghouse

shall be maintained

within the manufacturer's recoroanended range of 2 to 5 inches of water while the emissions

unit is in operation. Monitoring and/or Recordkeeping

Requirements 1. The permittee

shall maintain

a operations

log for this emissions

unit. This operations

log shall contain, at minimum,

the following

information:

a. The dates and times of any startrup and shutdown

of this emissions

unit; b. The duration

(in minutes)

of the exempted

Operations

.listed in Section A.2.b;

c. The number of hours of normal or full firing is to be recorded

for each day of operation; The number of hours of banked condition

is to be recorded

for each day of operation;

e. The total number of hours of operation,

i.e., the summation

of(c) & (d); f. The amount of coal (in tons) fed to and burned in this emissions

unit each day; The dates and times of any malfunction

of this emissions

unit and any corrective

action taken; C:\pti_holding\0219776f.wpdPage

32 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

h. The amount of limestone,,

or equivalent

(in pounds),

injected into the emissions

unit each day.For each shipment

of coal to be burned in this emissions

unit, the permittee

shall record the following information:

a. The name of the coal supplier; b. The location of the coal when the sample was collected

for analysis to determine

the properties of the coal, specifically

including

whether

the coal was sampled

as delivered

to the facility or whether

the. sample was collected

from coal in storage at the mine, at a coal preparation plant, at a coal supplier's

facility, or at another location.

The report shall include the name of the coal mine (and coal seam), coal storage facility, or coal preparation plant (where the sample was collected);

c. The total quantity

(in tons) of coal received; d. The sulfur content (in percent)

of the coal on a dry basis;

e. The moisture

content of the coal on a dry basis; f. The ash content (in percent)

of the coal on a dry basis; g. The heat content (BTU per pound) of the coal on a dry basis; h. The methods

used to determine

the properties

of the coal. The permittee

shall maintain

the following

monthly

records for this emissions

unit, when in operation:

a. The average,

hourly nitrogen

oxides (NOx) and carbon monoxide

(CO) emissions

rates by use of the following

equation,

when this emissions

unit is in operation. ER EF x CoalHours where;EREF Emissions

rate in pounds per hour Emissions Factor, taken from AP-42 Table 1.. 1-3 as follows: NOx 15.2 lbs NOx/ton

of coal CO 18 lbs CO/ton of coal

C:\pti_holding\0219776 f.wpdPage

33 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility ID: 0285030221 Emissions Unit ID: B009

Coal The amount of coal (in tons) fed to the emissions

unit and bumed that day,
as recorded

in Section C. :f. Hours The total number of hours of operation

(total of both full firing and banked), as recorded

in SectionC.

1. e, for the entire month. The average,

hourly particulate

(PE) emissions

rate by use of the.following

equation, when this emissions

unit is in operation. ER EF x Coal x (1-CE) Hours where;ER Emissions

rate in pounds per hour EF Emissions

Factor, taken from AP-42 Table 1.1-4 as follows: PE 17 lbs PE/ton of coal Coal The amount of coal (in tons) fed to the emissions

unit and burned that day,
as recorded

in section C. 1 .f. Hours The total number of hours of operation

(total of both full firing and banked), as recorded

in Section C. 1. e. I-CE Control efficiency

ofbaghouse

is 93%: (1 CE) (1 0.93) 0.07

Co The particulate

emissions

rate, in pounds per mmBtu,

as calculated

by the following equation.ER PE Hr / HC where;ER Emissions

rate in pounds particulate

per mmBtu PE Hr

Particulate

hourly emissions

rate (lbs PE/hr) as calculated

in Section C.3.b. HC Maximum

heating capacity

of emissions

unit, in mmBtu per hour do The calculation

of the calcium to sulfur weight ratio for each day of the month when limestone (or its equivalent)

and coal were. fed to this emissions

unit. This calculation may be performed

by multiplying

the amount of limestone

by the percent by weight of pure calcium carbonate,

CaCO 3. The amount Of calcium,

Ca, is then determined

by the C:\pti_holding\0219776f.wpdPage

34 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

ratio of 40/100

X/am¢ of CaCO3, where X the amount of calcium.

The amount of sulfur is determined

by multiplying

the amount of coal by the percent by weight of sulfur. The calcium to sulfur weight ratio is determined

by dividing

Ca by S, i.e., Ca/S. The permittee

shall maintain

the following

monthly

records regarding

coal usagefor

emissions units B002, B005 and B009:

a. The total amount of coal, in tons, fed to and burned in emissions

units B002 and B005. b. The total amount of coal, in tons, fed to and burned in emissions

unit B009.

Co The cumulative,

total amount of coal, in tons, fed to and burned in emissions

units B002 and B005 for the past 12-months. do The cumulative,

total amount of coal, in tons, fed to and burned in emissions

unit B009 for the past 12-months The permittee

shall maintain

the following

monthly

records regarding

emissions

rates for emissions, units B002, B005 and B009: The cumulative

sulfur dioxide emissions

rate, in tons per rolling 12-months,

as calculated by the following

equation. ER [Coal amt from B002 & B005 x 140.4 lbs SO2/ton of coal x ton/2,000 lbs] + [Coal amt from B009 x 23.4 lbs SO2/t0n x ton/2,000

lbs] where;ER Emissions

rate, in tons sulfur dioxide per rolling 12-m0nths "Coal amt from B002 & B005" is the total amount of coal; in tons, fed to and buraed in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "140.4 lbs SO2/ton"

is the converted

value in lbs/ton from 5.4 lbs SO2/mmBtu,

which is the allowable

sulfur dioxide emissions

rate. Per AP-42 Chapter

1.15, the conversion

is performed by multiplying

5.4 lbs SO2/mmBtu

with 26.0 mmBtu/ton

to produce

140.4 lbs SO2/ton."Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past. 12 months, as recorded

in Section C.4.d. "23.4 lbs SO2/ton"

is the converted

value in lbs/ton from 0.9 lb SO2/mmBtu,

which is the allowable sulfur dioxide emissions

rate.

C:\pti_holding\0219776f.wpdPage

35 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

The cumulative

NOx emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 9.5 lbs NOx/ton

of coal x ton/2,000

lbs] + [Coal amt from B009 x 15.2 lbs NOx/ton

of coal x ton/2,000

lbs] where;ER Emissions

rate, in tons NOx per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months, as recorded

in Section C.4.c. "9.5 lbs NOx/ton

of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-3. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "15.2 lbs NOx/ton

of coal" is an emissions,

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3.

Co The cumulative

CO emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 11 lbs CO/ton of coal x ton/2,000

lbs] + [Coal amt from B009 x 18 lbs CO/ton of coal x ton/2,000

lbs] where;ER Emissions

rate, in tons CO per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed toand bumed in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "11 lbs NOx/ton

of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-3. "Coal amt from B009" is the total amount of coal, in tons, fed to and bumed in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "18 lbs CO/ton of coal" is an emissions

factor for a FBC, bubbling

bed boiler, taken from AP-42, Table 1.1-3.

C:\pti_holding\0219776f.wpdPage

36 of 40Ceda r Lane Farms Corp PTI Application:

02-.19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

OJ do The cumulative

PE emissions

rate, in tons per rolling 12-months,

as calculated

by the following equation. ER [Coal amt from B002 & B005 x 15 lbs PE/ton of Coal x ton/2,000

lbs] + [Coal amt from B009 x 17 lbs PE/ton of coal x ton/2,000

lbs x (0.07)] where;ER Emissions

rate, in tons PE per rolling 12-months "Coal amt from B002 & B005" is the total amount of coal, in tons, fed to and burned in emissions units B002 and B005 over the past 12 months,

as recorded

in Section C.4.c. "15 lbs PE/ton of coal" is an emissions

factor for under feed stoker boilers, taken from AP-42, Table 1.1-4. "Coal amt from B009" is the total amount of coal, in tons, fed to and burned in emissions unit B009 over the past 12 months,

as recorded

in Section C.4.d. "17 lbs PE/ton of coal" is an emissions

factor, taken from AP-42, Table 1.1-4. "(0.07)" is the result of (1 minus control efficiency

ofbaghouse,

which is 93% or 0.93). The permittee

shall properly

install, operate, and maintain

equipment

to monitor the pressure drop across the baghouse

while the emissions

unit is in operation.

The monitoring

equipment shall be installed,

calibrated,

operated,

and maintained

in accordance

with the manufacturer's recommendations, instructions,

and operating

manual(s).

The permittee

shall record the pressure drop across the baghouse

on a daily basis. Reporting Requirements The permittee

shall submit quarterly

deviation

(excursion)

reports which include the following information:

ao An identification

of each day during which the hourly emissions

limitation(s)

for NOx, CO and/or PE was/were

exceeded,

and the actual hourly emissions

rate for the applicable pollutant(s); bo An identification

of each day during which the particulate

emissions

limitation

(lbs PE/mmBtu) was exceeded,

and the actual emissions

rate;

Co An identification

of each day during which the visible particulate

emissions

from the exhaust serving this emissions

unit exceeded

the limitations

specified

in OAC rules 3745- 17-07(A)(1) & (A)(2).
C:\pti_holding\0219776f.wpdPage

37 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility ID: 0285030221 Emissions Unit ID: B009

do An identification

of any shipment

of coal used for this emissions

unit that did .not meet the ash, heat, and sulfur specifications

listed in Section A.2.c.

eo An identification

of each day during which any required

monitoring

and record keeping
as listed in Section C was not performed. An identification

of each month within the quarter when the total amount of coal uged
over the past 12 months in emissions

units B002, B005 and B009 exceeds

1,400 tons. The actual total amount of coal for each such month shall be reported. An identification

of each month within the quarter when the calculated

annual SO2, NOx; CO and PE emissions

rates, as recorded

per Section C.5, exceeds the appropriate allowable limit. The actual, calculated

annual emissions

rates for these pollutants

shall also be reported. An identification

.of each day during which the calcium to sulfur weight ratio was not maintained within the range of 1.08 and 1.2, as required

in Section A.2.e and recorded

in Section C.3.d. The calendar

quarters are January

1 March 31, April 1 June 30, Julyl September

30, and October 1 December

31. If no deviations

occurred

during the calendar

quarter, the permittee

shall submit a quarterly report, which states that no deviations

occurred

during that quarter.

The reports shall submitted quarterly, i.e., by January 31, April 30, July 31, and October

31 of each year and shall cover the previous calendar

quarter. Testing Requirements Emissions

Limitation: 0.9 lb SO2/mmBtu

for B009 Applicable Compliance

Method: If required

by the Ohio EPA, compliance

with the above emissions

limitation

shall be determined in accordance

with 40 CFR Part 60, Appendix

A, Method 6C. Emissions Limitation: 98.3 tons SO2/rolling

12-months

for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping in Section C.5.a.Emissions Limitation: 4.9 lbs NOx/hour

for B009 C:\pti_holding\0219776f.wpdPage

38 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009

C:\pti_holding\0219776f.wpdPage

39 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Unit ID: B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

Shall be determined

on the recordkeeping

in Section C.3.a.Emissions Limitation: 10.6 tons NOx per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.b.Emissions Limitation: 5.9 lbs CO/hour

for B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.a.Emissions Limitation: 12.6 tons CO per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.c.Emissions Limitation: 0.5 lb PE/mmBtu

for B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.c.Emissions Limitation: 0.4 lb PE/hr for B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.3.b.Emissions Limitation: 11.9 tons PE per year, on a 12-month

rolling basis for B002, B005 & B009 Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

on the record keeping

in Section C.5.d. C:\pti_holding\0219776f.wpdPage

40 of 40Cedar Lane Farms Corp PTI Application:

02-19776 Issued: 11/18/2004 Facility

ID: 0285030221 Emissions Uni[ ID." B009

10. Emissions

Limitation: Visible particulate

emissions

(VE) shall not exceed an opacity of twenty (20) percent as asixminute average.

VE may exceed.20

percent as a six-minute

average for not more than six (6) consecutive minutes in any sixty-minute

period, but shall not exceed sixty (60) percent opacity, at any time. This emissions

limitation

applies, except as exempted

by OAC rule 3745-17-07(A)(3). Applicable Compliance

Method: Compliance with the above emissions

limitation

shall be determined

in accordance

with 40 CFR Part 60, Appendix

A, Method 9 and the procedures

specified

in OAC rule 3745-17-03(B)(1). Miscellaneous Requirements 1. The terms and conditions

of this permit supercede

those for B009 established

in PTI # 02-17358. 2. The terms and conditions

of this permit to install are federally

enforceable.

C:\pti_holding\0219776f.wpd