## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia Prevention ofSignificant Deterioration Permit For Greenhouse Gas Emissions Permit PSD-EPA-R4013

In accordance with theprovisions ofthe Clean AirAct (CAA), Subchapter I, Part C, 42 U.S.C. § 7470, and the implementing Prevention ofSignificant Deterioration (PSD) of Air Quality Regulations at the Code ofFederal Regulations (CFR) Title 40, Section 52.21 (40 CFR § 52.21), and the Federal Implementation Plan at 40 CFR § 52.37 (effective December 30, 2010 and published at 75 FR 82246 (Dec. 30, 2010)) the U.S. Environmental Protection AgencyRegion 4 hereby authorizes: EFS Shady Hills LLC 800 Long Ridge Road Stamford, Connecticut 06927 to construct and operate Greenhouse Gas (GHG) air emissions units as a modification to the existing Shady Hills Generating Station located at 14240 Merchant EnergyWaynearthe Cityof Spring Hill, in Pasco County, Florida. This modification to the ShadyHills facility shall be constructed and operated in accordance with the terms and conditions set forth inthis permit. This permit becomes effective on February 15, 2014. This permit addresses greenhouse gas-related PSD requirements, only. For this Project, the State ofFlorida, through the Florida Department ofEnvironmental Protection, retainsjurisdiction over PSDpermitting for regulated pollutants other than greenhouse gases. This permit shall not relieve the owner or operator ofthe responsibility to comply fully with all applicable provisions offederal and state law.



# ~¢<(~ Jeaneanne M. ettle 

# V

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# ' Acting Director Air, Pesticides, and Toxics Management Division

EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1/13/14AUTHORITY TheEPA issues this permitpursuant to Subchapter I, Part C, ofthe Clean AirAct (CAA), 42 U.S.C. § 7470, and the implementing PSD Regulations at 40 CFR § 52.21, and the Federal Implementation Plan at 40 CFR § 52.37 (effective December 30,2010 andpublished at 75 FR 82246 (Dec. 30, 2010)). This permit isbasedupon application materials submitted to the EPAby EFS Shady Hills LLC (Shady Hills), dated September 25, 2012, November 30, 2012, March 27, 2013, and July 26, 2013, supplemental submittals inthe administrative record for this permit action, and upon the technical analysis performedbythe EPA.
APPLICANT EFS Shady Hills LLC 800 Long Ridge Road Stamford, Connecticut 06927
PROJECT LOCATION The existing ShadyHills's facility and theproject are located at 14240 Merchant EnergyWay nearthe City ofSpring Hill, inPasco County, Florida
PROJECT DESCRIPTION ShadyHills has applied for a GHGPSD airpermit pursuantto the CAA from the EPA Region 4 for theproposed Project. ShadyHills is proposing to build two additional simple cycle combustion turbines (Model: General Electric 7FA.OS) at their existing facility. The GE7FA.OS output is 218 megawatts (MW) (gross) when firing natural gas and 223 MW (gross) when firing ultra-low sulfur distillate (ULSD) fuel oil. Theprimary fuel willbenatural gas withULSD fuel oil, with sulfur content ofis 0.015 percent, as backup fuel. Theheat input perturbine wouldbe 2,135 million British thermal units perhour (MMBtu!hour), highheating value (HHV) at 59 deg. F, 60 percentrelativehumidity (ISO conditions). Ancillaryequipment consists ofa 2.5 MW emergency generator (EU 007), a natural gas fuel heater (EU 008), a 2.8 million gallon (Mgal) ULSD fuel oil storage tank (EU 009), SF6 circuit breakers (EU 010), and new on-site natural gas pipeline. Shady Hills's existing facility consists ofthree, dual-fuel, 170 MW (nominal) GE PG7241FA simple cycle combustion turbine (SCCT)-electrical generators, three 75 feet high exhaust stacks, and one 2.8 million gallon fuel oil storage tank. The combustion turbine units can operate in simple-cycle mode and intermittent duty mode. Theunits are equippedwith dry low-nitrogen oxides (NOx) combustors and water injection capability. Thethree units are regulatedunder Phase IT ofthe Federal Acid Rain Program. The existing facility and the Project are located at 14240 Merchant EnergyWaynear the City ofSpring Hill, in Pasco County, Florida. TheProject

EFS Shady Hills LLC Project (PSD-EPA-R4013)- Final PSD Permit 1113/14 2will be located within the existing Shady Hills boundaries. The existing facility has been in operation since 2002 and operates usually during peakhours ofelectrical use. This PSD permit for the Project requires the use ofBest Available Control Technology (BACT) to limit emissions ofGHGs, to the greatest extent feasible. EQUIPMENT LIST devices and activities are sub·ect to this PSD 223 MW GE 7F A.05 simple cycle combustion turbine-electrical generator 223 MW GE 7FA.05 simple cycle combustion turbine-electrical generator 2,500 kilowatt (kW) emergency generator firing ULSD fuel oil 10 MMBtu/hrNatural Gas Heater 2.8 Mgal Distillate Fuel Oil Storage Tank

PERMIT CONDITIONS I. PERMIT EXPIRATION As provided in 40 CFR § 52.21(r), this PSDPermit shall become invalid ifconstruction: A. is not commenced (as defmed in 40 CFR § 52.21(b)(9)) within 18 months after the approval takes effect; or B. is discontinued for a period of 18 months or more; or C. is not completed within a reasonable time.
II. PERMITNOTIFICATION REQUIREMENTS Pursuant to Condition IX: 

### SPECIAL CONDITIONS, Permittee shall notify the EPA Region 4 byletter or electronic mail ofthe: A. date construction is commenced, postmarked within 30 days ofsuch date; B. actual date ofinitial setting in operation for anypurpose, postmarked within 15 days ofsuch date; and

EFS Shady Hills LLC Project (PSD-EPA-R4013) -FinalPSD Permit 1113/14 3C. date upon which initial certification tests will commence, in accordance with the provisions ofCondition IX.E, postmarked not less than 21 days prior to such date. Notification maybeprovided with the submittal ofthe certification test protocol required pursuant to Condition IX.E. ill. FACILITY OPERATION A. At all times, including periods ofstartup, shutdown, shakedown, and malfunction, Permittee shall, to the extentpracticable, maintain and operate the facility in a manner consistent with good air pollution control practices for minimizing emissions. Determination ofwhether acceptable operating and maintenanceprocedures are being used will bebased on information available to the EPA, which mayinclude, but is not limited to, monitoring results, review ofoperating maintenanceprocedures and inspection ofthe facility. B. The Permittee shall operate and maintain the CTs and associated components in a manner consistent with good engineeringpractices for its full utilization. C. As soon as practicable following initial startup ofthe CTs (as defmed in 40 CFR § 60.2) butpriorto commencement ofcommercial operation (as defmed in 40 CFR § 72.2), and thereafter, the Permittee shall develop and implement an operation and maintenanceplan for the facility, consistent with Condition ID.B above. At a minimum, theplan shall identify measures for assessing theperformance ofthe facility, the acceptable range ofthe plant performance measures for achieving the design electrical output, the methods for monitoring the plant performance measures, and theroutine procedures for maintaining the facility in good operating condition.

IV. MALFUNCTION REPORTING A. Permittee shall notifythe EPA Region 4 viathe contact information provided in ConditionX:

### AGENCY NOTIFICATIONSwithin two (2) calendardays following the discovery ofany failure ofprocess equipment orfailure ofa process to operate in a normal manner, which results in an increase in emissions above the allowable emission limits stated in Condition IX: 

### SPECIAL CONDITIONS ofthis permit. B. In addition, pursuant to Condition X:

### AGENCY NOTIFICATIONS, Permittee shall provide written notification to the EPA within fifteen (15) calendar days ofany such failure described under Condition IV.A. This notification shall include a description ofthe malfunctioning equipment or abnormal operation, the date ofthe initial malfunction, theperiod oftime over which emissions were increased due to the failure, the cause ofthe failure, the estimated resultant emissions in excess ofthose allowed in Condition IX: 

### SPECIAL CONDITIONS, and the methods utilized to mitigate emissions and restore normal operations. C. Compliance with this malfunction notification provision shall not excuse or otherwise EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 4constitute a defense to any violation ofthis permit or any law orregulation such malfunction may cause. 

### V. RIGHT OF ENTRY The EPA Regional Administrator, and/or an authorized representative, upon the presentation ofcredentials, shall bepermitted: A. to enter the premises where the facility is located orwhere anyrecords are required to bekept under the terms and conditions ofthis PSD Permit; B. during normal business hours, to have access to and to copy anyrecords required to bekept under the terms and conditions ofthis PSD Permit; C. to inspect any equipment, operation, ormethod subject to requirements in this PSD Permit; and D. to sample materials and emissions from the source(s).


### VI. TRANSFER OF OWNERSHIP Inthe event ofany changes in control or ownership ofthe facility, this PSD Permit shall bebinding on all subsequent owners and operators. Within 14 days ofany such change in control orownership, Permittee shall notify the succeeding owner and operator ofthe existence ofthis PSD Permit and its conditions by letter. Permittee shall send a copy of this letterpursuant to 

### ConditionX: AGENCY NOTIFICATIONSto the EPA Region 

### 4 within thirty (30) days ofits issuance.
VII. SEVERABILITY The provisions ofthis PSD Permit are severable, and, ifany provision ofthe PSD Permit is held invalid, the remainder ofthis PSD Permit shall not be affected.


### Vill. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS A. Permittee shall construct the Project in compliance with this PSD permit, the application on which this permit is based, and all other applicable federal, state, and local air qualityregulations. This PSD permit does not release the Permittee from any liability for compliance with other applicable federal, state and local environmental laws and regulations, including the Clean Air Act. B. Ifprehistoric orhistoric artifacts, such as pottery orceramics, stone tools ormetal EFS Shady Hills LLC Project (PSD-EPA-R4013) -FinalPSD Permit 1/13/14 5implements, or any otherphysical remains that could be associated with Native American cultures, orearly colonial orAmerica settlement are encountered at any time within the project site area, the permitted project should cease all activities involving subsurface disturbance in the immediate vicinity ofsuch discoveries. Upon such discovery, Permittee, or other designee, shall immediately contact the Florida Department ofState, Division ofHistorical Resources, Review and Compliance Section at 850.245.6333 or 800.847.7278, as well as the appropriate permitting agency offices (FDEP and the EPA Region 4). Project activities shall not resume without verbal and/or written authorization from the Division ofHistorical Resource. Inthe event that unmarked human remains are encountered during permitted activities, all work shall stop immediately and the proper authorities notified in accordance with Section 872.05, Florida Statutes. IX. SPECIAL CONDITIONS A. AirPollution Control and Equipment Operation Permittee shall perform any necessary operations to minimize emissions so that emissions are at orbelow the emission limits specified in this permit. B. Combustion Turbines (EU 005 & 006) Emission Limits 1. Except as noted belowunder Condition IX.C. and ConditionIX.I., on and after the date ofinitial startup and completion ofthe shakedown period, Permittee shall not discharge or cause the discharge ofemissions from the SCCT Units into the atmosphere in excess ofthe following:



### 1 ,377 pounds (lb) ofcarbon dioxide equivalent**(C~e)** per megawatt-hour (MWh)

12-month rollin avera e 1,928 lb C02e/MWh (12-month rolling average)

2. Ifboth, EU 005 and 006 are constructed, they shall not operate an average ofmore than 3,390 hours per year per CT on a 12-monthrolling total basis. No single unit shall operate more than 5,000 hours per year on a 12-monthrolling total basis. Ifonly one combustion turbines is installed, it shall operate no morethan 3,390 hours per year on a 12-monthrolling total basis. Permittee shall monitor and record the number ofhours each CT operates monthly and totalled every month for the previous 12 months.

EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 63. Ifboth, EU 005 and 006 are constructed, they shall not fire ULSD fuel oil more than 1,000 combined hours peryear on a 12-monthrolling total. The Permittee shall monitor and record the number ofhours each CT operates on ULSD monthly and totalled every month for the previous 12 months. Ifonly one SCCT is installed, the CT mayoperateup to 500 hours firing ULSD oil per year on a 12-monthrolling total. The single combustion turbine may fire additional 250 hours ofULSD oil, provided that for everyhour ofULSD oil fired beyond the 500 hours, the CT must reduce its capability to fire natural gas byfive hours (i.e., 5:1 natural gas to ULSD fuel oil ratio). {Example: 

### If the single combustion turbine operates on ULSD fuel oil for 750 hoursper year on a 12-month rolling total, then itmay only operate for only 1,640 hours on natural gas during the sameperiod{(3,390-500)-5(750-500)]} 

### C. Combustion Turbines (EU 005 & 

### 006) Startup and Shutdown Emission Limits 1. Startup is defmed to begin on the minute when fuel is fust ignited in the CT and terminates onthe minute when the CT reaches 50% load. 2. Shutdown occurs on the minute when the CT load is less than 50% load until the minute that fuel flow to the CT stops. 3. Total time (in hours) during startup and shutdown shall be included in the limit on total hours ofoperation in Condition IX.B.2. When ULSD oil is used during startup or shutdown, the total time (in hours) ofsuch use shall be included in the limit onhours of operation firing ULSD oil in Condition IX.B.3. 4. Permittee shall not discharge or cause the discharge ofemissions from the CT Unit into the atmosphere in excess ofthe following during startup and shutdown events:

21 tons C02eper event (12-monthrolling average) 28 tons C02eper event (12-month rolling average) "' Compliancewith the above limits shall be demonstrated in accordance withCondition I.X.E.8. 

### D. Auxiliary Equipment Emission and Operational Limits and Work Practices 1. At all times, the Permittee shall not discharge orcause the discharge ofemissions from each unit into the atmosphere in excess ofthe following, and shall otherwise comply with the following specifications on a 12-monthrolling total:

EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 7Work Practice Standards 3,966 TPY
Work Practice Standards

2. EU 007 Emergency Generator shall beproperly operated and maintained in accordance to manufacturer's specifications. 3. The EU 007 Emergency Generator maybe operated for emergency and non-emergency situations. Combined, the total annual hours ofoperation ofEU 007 Emergency Generator (as defmed in 40 CFR63 Subpart ZZZZ) for maintenance and testing, emergency demand response, voltage deviation, and non-emergency situations shall not exceed 100 hours per 12-month rolling total, as defined by40 CFR 63.6640(f)(2) and (4). EU 007 maybe operated for up to 50 hours per 12-monthrolling total in non-emergency situations, which will be included in the maximum total annual hours ofoperation of 100 hours per 12-month rolling total. Permittee shall monitor and record the number ofhours the emergency generator operates as well as the purpose ofthe operation. Permittee shall calculate the total hours of operation otherthan for emergency situations monthly and totalled every month for the previous 12 months. 4. EU 008 Natural Gas Heater shall operate exclusively on natural gas and in accordance with manufacturer's specifications, in order to maintain a minimum thermal efficiency of 75%. 5. EU 010 Circuit Breakers shall beused as electrical interrupters in the event ofa power surge. EU 010 Circuit Breakers shall be totally enclosed. Permittee shall install and maintain a leak detection system on the circuit breakers that signals an alarm in the facility's control room in the event that any circuit breaker looses pressure. Any detected leaks must berepaired immediately. Records ofinspection shall bekept in accordance with 

### Condition IX.G
. 6. The on-site pipeline and natural gas supply system pressure shall be monitored and EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 8recorded continuously against alarm set points to be determined upon system design and implementation to identify any leaks. Permitte shall use natural gas treated with mercaptan for leak detection byodor. Anydetected leaks must berepaired immediately. Records ofinspection, detected leaks, and repairs (including action taken and duration) shall be kept in accordance with 

### Condition IX.G. 

### E. Monitoring and Compliance with GHG Emission Limits for CTs (EU005 and 006) 1. Permittee shall install, certify, operate, and maintain fuel flow monitoring systems on each CT in accordance with the applicable requirements of40 CFRPart 75, Appendix D, which shall constitutethe "compliance monitoring system" for this permit. Consistent with §75.4(b), all applicable certification tests shall be completed within 180 calendar days afterthe date theunit commences commercial operation (as defined in40 CFR 72.2). 2. Following initial certification, the fuel flow continuous monitoring system shall be quality assured in accordance with the applicablerequirements of40 CFRPart 75. 3. Data from the fuel flow continuous monitoring system and the procedure provided in 40 CFR75.10(a)(3)(ii) along with the Global Warming Potential (GWP) factors provided in Condition Jbelow shall beused to producehourly determinations ofC02e emissions in tons perhour (tons/hr). Thepermitte shall calculate C02 emissions using the Equation G4 from 40 CFR75 Appendix G and the

**C~** and N20 emissions using Equation C-8 from 40 CFR98 Subpart C. 4. In accordance with §75.62, an initial monitoring plan shall be submitted identifying the methodology for which fuel flow will be continuouslymonitored. The initial monitoring plan shall be submitted no later than 21 days priorto the initial certification tests. 5. Permittee shall provide notifications as specified in §75.61 for anyevent related to the continuous measurement ofthe fuel flow. 6. Permittee shall measure and record, for each CT, the following on an hourlybasis:
a. Gross energyoutput rate (MW); b. Heat input rate (MMBtu/hr; HHV), in accordance with 40 CFRPart 75, Appendix D;

c. Unit operating time as described in §75.57(b)(2); and d. The type (natural gas or ULSD) and amount offuel (scfor gals) burned.
e. Ambient conditions (temperature, humidity, and pressure). 7. Permittee shall calculate and record, for each CT, the following on a 12-monthrolling EFS Shady Hills LLC Project (PSD-EPA-R4013) -FinalPSD Permit 1113/14 9average basis, in each case corrected to ISO conditions:

a. The 12-monthrolling average C02eemission rate (lbs C02e/12-monthrolling total) (for each fuel combusted in the previous 12 months) shall be calculated based onthe total fuel fired during theprior 12 calendarmonths, at all times other than startup and shutdown, using the global warmingpotential (GWP) factors in 

### Condition J: 

### GLOBAL WARMINGPOTENTIAL (GWP). b. The 12-monthrolling gross output (MWh) (for each fuel combusted in the previous 12 months) shall be calculatedbased on the total fuel fired, at all times other than startup and shutdown, during theprior 12 calendarmonths using the global warmingpotential (GWP) factors in 

### ConditionJ.

c. The 12-monthrolling total C02e emission rate shall bedivided bythe 12-month rolling gross outputrate to determine the lb/MWh rolling average. 8. Fordemonstrating compliance with the limits specified in 

### Condition IX.B.l, Permittee shall usetheprocedures set forth in 40 CFRparts 75 and 98 to determineresulting GHG emissions (as C02e)using the GWP as specified in 

### Condition

### J. Permittee shall keep adequate records ofthese GHG emission calculations according to requirements in 

### Condition IX.H.l. F. Monitoring and Compliancewjth GHG Emission Limits for CTs (EUOOS and 006) During Startup and Shutdown 1. For each fuel, a new startup and shutdown C02 e 12-monthrolling average (tons C02e/event) is calculated each calendar monthbased on the summation offuel consumption during all startup and shutdown events during the prior 12 consecutive calendar months divided bythe number ofstartup and shutdown events in the 12-month period. 2. Permittee shall monitor and record thetime, date, fuel type, and duration ofeach startup and shutdown event. These records mustbekept for five years following the date ofsuch events. 3. For demonstrating compliance with the limits specified in 

### Condition IX.C.3, Permittee shall use theprocedures set forth in 40 CFRparts 75 and 98 to determine resulting GHG emissions (as C02e) based on the combination ofmeasured C02 emissions and calculated C02e ofother GHGpollutants (as specified in 

### Condition J). Permittee shall keep adequate records ofthese GHG emission calculations according to requirements in 

### Condition IX.H.l. G. Monitoring and Compliancefor Auxiliary Equipment 1. Permittee shall install, operate, and maintain an operational non-resettable totalizing mass EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 10orvolumetric flow meter in each fuel line to measure fuel use for the 10.0 MMBtu/hr natural gas heater (EU 008) to berecorded monthly and totalled everymonth for the previous 12 months. 2. Permittee shall install, operate, and maintain a non-resettable elapsed time meter for 2,500 kW emergencyuse engine (EU 007) and 10.0 MMBtu/hrNatural gas heater (EU 008) to be recorded monthly and totalled every month for theprevious 12 months. 3. Permittee shall calculate and record the thermal efficiency ofthe 10.0 MMBtu/hrnatural gas heater (EU 008) on a monthlybasis. To maintain the EU 008 operating at a high efficiency, the Permittee shall perform annual tune-ups and meet the associated requirements as follows (iftheunit is not operating on the required date for a tune-up, the tune-up must be conducted within one week of startup) in accordance with manufacturer's specifications:

a. Inspect the burner, and clean orreplace any components ofthe burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, but you must inspect eachburner at least once every 18 months). b. Inspect the flame pattern, and adjust the burner as necessary to optimizethe flame pattern. The adjustment shouldbe consistent with the manufacturer's specifications.

c. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and functioning properly 4. On a monthlybasis, Permittee shall use the annual heat input as calculatedusing the data obtained from monitoring required by Conditions G.1 and G.2, and data from 40 CFR Part 98, Table C-1 to calculate and record C02e emissions from the 10.0 MMBtu/hr natural gas heater (EU 008) on a 12-monthrolling average using the Global Warming Potential factors as established in Condition J. 5. Permittee shall:

a. Continuouslymonitor and record circuit breakers pressure; b. Visually inspect, in accordance with manufacturer's standards, circuit breakers and components on a daily basis;

c. Provide periodic maintenance to the circuit breaks and its components; d. Repair any leaks and replace equipment as needed; 

### H. Recordkeeping and Reporting
EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1/13/14 111. Permittee shall maintain a file ofall records, data, measurements, reports, and documents related to the operation ofthe facility, including, but not limited to, the following:

a. all records orreports pertaining to adjustments and/or maintenanceperformed on any system ordevice at the facility that are part ofthe emissionunits and activities regulated bythis permit; b. all records relating to performancetests and monitoring ofauxiliary combustion equipment; and

c. all other information that this permit requires Permitteeto obtain, maintain, or develop, recorded in a permanent form suitable for inspection. 2. Permittee shall maintain continuous monitoring system records that include the following: the occurrence and duration ofany startup, shutdown, shakedown, or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration ofanyperiods during which a continuous monitoring system or monitoring device is inoperative, and corresponding emission measurements. 3. Permittee shall maintain records ofall source tests and monitoring and compliance information required bythis permit. 4. Permittee shall maintain records and submit a written report ofall deviations from permit requirements to the EPA semi-annually, except when: more frequent reporting is specificallyrequired by an applicable subpart; or the Administrator, on a case-by-case basis, determines that more frequent reporting is necessary to accurately assess the compliance status ofthe source. The report is due on September 30th and March 31st and shall include the following:

a. Ifapplicable, time intervals, data and magnitude ofthe excess emissions, the nature and cause (ifknown), corrective actions taken and preventive measures adopted; b. Ifapplicable, the time and date ofeachperiod during which the continuous monitoring system was inoperative (monitor down-time), except for zero and span checks, and the nature ofcontinuous monitoring system repairs or adjustments;

c. A statement in the report ofa negative declaration; that is, a statement when no excess emissions occurred orwhen the continuous monitoring system has notbeen inoperative, repaired, or adjusted;; d. Any failure to conduct anyrequired source testing, monitoring, or other compliance activities; and

e. Any violation oflimitations on operation, including but not limited to restrictions
EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 12on hours ofoperation. 5. Excess emissions shall be defmed as anyperiod in which the facility emissions exceed the maximum emission limits based onthe applicable averaging period as set forth in this permit. 6. A period ofmonitor down-time shall be any unit operating clockhour in which sufficient data are not obtained bythe continuous monitoring system to validate the hour for C02. 7. Excess emissions indicated by 

### Section IX.E.

### Monitoring and Compliance with GHG EmissionLimits for CTs (EU005 and006) and 

### Section IX.F

### Monitoring and Compliance with GHGEmission Limits for CTs (EU005 and006) DuringStartup and Shutdown shall be considered violations ofthe applicable emission limit for the purpose ofthis permit. 8. Permittee shall maintain a copyofthe current operation and maintenanceplan for the facility, and shall keep a copyofall prior versions ofthe plan for a minimum offive years. The Permittee shall also keep records ofthe monitoring data for each ofthe facility performance measures and all maintenance activities; the Permittee shall maintain such records for a minimum offive years following the date they are created 9. Unless otherwise specified herein, all records required bythis PSDPermit shall be retained for not less than five years following the date ofsuch measurements, maintenance, reports, and/or records. These records shall bemade available for review uponrequest bythe Agency or authorizedrepresentative during the course ofan inspection. 

### I. Shakedown Periods The combustion turbine and auxiliary equipment emission limits and requirements in 

### Conditions IX.B, IX.C, and IX.D shall not apply during combustion shakedown periods. Shakedown is defined as theperiod beginning with initial startup and ending no later than the successful completion ofinitial performance testing, during which the Permittee conducts operational and contractual testing and tuning to ensure the safe, efficient and reliable operation oftheplant. The shakedown period shall not exceed 180 days. Therequirements ofSection illofthis permit shall apply at all times. 

### J. GlobalWarming Potential (GWP) Forthepurposes ofshowing compliance with any GHG emission limit in this permit, the GWP factors listed in 40 CFRPart 98 Subpart A, Table A-1 amended on November 29, 2013 [78 FR 71948] and effective on January, 1 ,2014 as ofthe date ofthis permit shall beused. The current GWP factors are listed below:

EFS Shady Hills LLC Project (PSD-EPA-R4013) -Final PSD Permit 1113/14 1325 298 22,800



### X. AGENCY NOTIFICATIONS All notifications, reporting orother communications relating to this permit shall be submitted to: Chief Air & EPCRAEnforcement Branch Air, Pesticides and Toxics Management Division U.S. EPARegion 4 61 Forsyth Street, SW Atlanta, Georgia 30303 In addition, electronic copies ofthe above-referenced notifications and communications shall be submitted to the following individuals at their corresponding email address: Name Jason Dressler Katy 

### R. Lusky Heather Ceron Email dressler.jason@epa.gov fomey.kathleen@epa.gov ceron.heather@epa.gov

EFS Shady Hills LLC Project (PSD-EPA-R4013) -FinalPSD Permit l/13/14 14 Phone 404-562-9208 404-562-9130 404-562-9185