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

10/6/2017 Certified Mail

No TOXIC REVIEW Yes PSD Mr. John Hendricks No SYNTHETIC MINOR TO AVOID MAJOR NSR Conesville Power Plant Yes CEMS 1 Riverside Plaza Yes MACT/GACT Columbus, OH 43215 No NSPS No NESHAPS RE: FINAL AIR POLLUTION PERMIT-TO-INSTALL No NETTING No MAJOR NON-ATTAINMENT Facility ID: 0616000000 Yes MODELING SUBMITTED Permit Number: P0120809 No MAJOR GHG Permit Type: Administrative Modification No SYNTHETIC MINOR TO AVOID MAJOR GHG County: Coshocton

Dear Permit Holder:

Enclosed please find a final Ohio Environmental Protection Agency (EPA) Air Pollution Permit-to-Install (PTI) which will allow you to install or modify the described emissions unit(s) in a manner indicated in the permit. Because this permit contains several conditions and restrictions, we urge you to read it carefully. Because this permit contains conditions and restrictions, please read it very carefully. In this letter you will find the information on the following topics:

 How to appeal this permit  How to save money, reduce pollution and reduce energy consumption  How to give us feedback on your permitting experience  How to get an electronic copy of your permit  What should you do if you notice a spill or environmental emergency?

How to appeal this permit

The issuance of this PTI is a final action of the Director and may be appealed to the Environmental Review Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the action complained of and the grounds upon which the appeal is based. The appeal must be filed with the Commission within thirty (30) days after notice of the Director's action. The appeal must be accompanied by a filing fee of $70.00, made payable to "Ohio Treasurer Josh Mandel," which the Commission, in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would cause extreme hardship. Notice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General's Office, Environmental Enforcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address:

Environmental Review Appeals Commission 30 East Broad Street, 4th Floor Columbus, OH 43215

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) How to save money, reduce pollution and reduce energy consumption

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not only will this reduce pollution and energy consumption, but it can also save you money. If you would like to learn ways you can save money while protecting the environment, please contact our Office of Compliance Assistance and Pollution Prevention at (614) 644-3469. Additionally, all or a portion of the capital expenditures related to installing air pollution control equipment under this permit may be eligible for financing and State tax exemptions through the Ohio Air Quality Development Authority (OAQDA) under Ohio Revised Code Section 3706. For more information, see the OAQDA website: www.ohioairquality.org/clean_air

How to give us feedback on your permitting experience

Please complete a survey at www.epa.ohio.gov/survey.aspx and give us feedback on your permitting experience. We value your opinion.

How to get an electronic copy of your permit

This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or in Adobe PDF on the Division of Air Pollution Control (DAPC) Web page, www.epa.ohio.gov/dapc by clicking the "Search for Permits" link under the Permitting topic on the Programs tab.

What should you do if you notice a spill or environmental emergency?

Any spill or environmental emergency which may endanger human health or the environment should be reported to the Emergency Response 24-HOUR EMERGENCY SPILL HOTLINE toll-free at (800) 282-9378. Report non-emergency complaints to the appropriate district office or local air agency.

If you have any questions regarding your permit, please contact Ohio EPA DAPC, Southeast District Office at (740)385-8501 or the Office of Compliance Assistance and Pollution Prevention at (614) 644-3469.

Sincerely,

Michael E. Hopkins, P.E. Assistant Chief, Permitting Section, DAPC

Cc: U.S. EPA Ohio EPA-SEDO; West Virginia Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 Response to Comments

Facility ID: 0616000000 Facility Name: Conesville Power Plant Facility Description: Power plant. 47201 County Road 273 Facility Address: Conesville, OH 43811-9799 Coshocton County Permit: P0120809, Permit-To-Install - Administrative Modification (Please also refer to P0121529 Permit -To-Install) A public notice for the draft permit issuance was published in the Ohio EPA Weekly Review and appeared in the The Coshocton Tribune on 04/13/2017. The comment period ended on 05/13/2017. Hearing date (if held) Hearing Public Notice Date (if different from draft public notice)

The following comments were received during the comment period specified. Ohio EPA reviewed and considered all comments received during the public comment period. By law, Ohio EPA has authority to consider specific issues related to protection of the environment and public health. Often, public concerns fall outside the scope of that authority. For example, concerns about zoning issues are addressed at the local level. Ohio EPA may respond to those concerns in this document by identifying another government agency with more direct authority over the issue.

In an effort to help you review this document, the questions are grouped by topic and organized in a consistent format. PDF copies of the original comments in the format submitted are available upon request.

1. Topic: Permit to Install (PTI) for B007 and B008- Comments from AEP on June 13, 2017

a. Comment: AEP discovered existing Permits to Install (PTIs) for Conesville Units 5 (B007) and 6 (B008). The permits (200138 and 200139) were issued in 1972. Please combine the permit terms for B007 and B008 into the same permit as B004.

Answer to Comment 1.a: Since B007 and B008 have existing PTIs, the permit action for P0121529 (issued draft and reference above) should have been an administrative modification. Therefore, the terms for B007 and B008 were combined into P0120809 (the permit for B004, also issued draft). The terms and conditions for B007 and B008 have already gone through the public comment period via P0121529. Also, the Federal Consent Decree has been publicly noticed. Therefore, Ohio EPA’s legal obligations to establish federal enforceable permit terms for B007 and B008 have been met.

2. Topic: Permit Strategy Write-up (PSW) B004- Comments from AEP on May 12, 2017

a. Comment: Minor typos and clarifications to add under Source Description and Source Emissions.

Response to comment 2.a: The PSW is only included in the draft issuance. AEP’s corrections are noted, but since the PSW does not get issued with the final permit, the corrections will not be made to the draft issuance document. Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

b. Comment: Source Emissions: The Part 75 and Part 60 CEMS requirements are not changed by the CD, and are not relevant to this PTI. Nothing addressed in this paragraph is changed by the CD, or relevant to this PTI action.

Response to comment 2.b: AEP’s comments are noted. Since the PSW does not get issued with the final permit, the corrections will not be made to the draft issuance document.

3. Topic: Applicable Emission Limits for B004, B007 and B008- Comments from AEP on May 12, 2017

a. Comment: B004, b)(1)b. There is no need for this limit. The CD has nothing to do with opacity. Neither the application nor any change in law justifies a change in the current opacity terms for Conesville Unit 4.

Response to comment 3.a: Although OAC rule 3745-17-07 (A) is an applicable limit to B004 (and has been established in the current Title V operating permit), it was not established in PTI 06-08124. Since this is an administrative modification to incorporate CD requirements, the limit has been removed.

b. Comment: B004, b(1)c. There is no need for this limit either. The CD also has nothing to do with PE emissions.

Response to comment 3.b: Although OAC rule 3745-17-10(6)(b) is an applicable limit to B004 (and has been established in the current Title V operating permit), it was not established in PTI 06-08124. Since this is an administrative modification to incorporate CD requirements, the limit has been removed from this permit.

c. Comment: B004, b)(1)d. Shouldn’t this say that the SO2 limit established pursuant to this rule is less stringent than the SO2 limit established per OAC 3745-31-05 (F) and PTI 06-08124?

Response to comment 3.c: Although this limit is applicable and has been established in the current Title V operating permit, it is less stringent than the limit already established in PTI 06- 08124. It is less stringent because the averaging time for B004 per OAC rule 3745-18-04 is a 30-day rolling average. The language has been revised.

d. Comment: B004 b)(1)f., B007 and B008(b)(1)d.: This reference is inappropriate and unnecessary. The CD is the only citation needed. 31-05(D) is meant for synthetic minor limits on “potential to emit” 31-05(D) does not give a blanket authority to impose ‘federally enforceable’ special terms and conditions that are statutorily prohibited.

Response to Comment 3.d: The Consent Decree is a legal agreement, not a federal rule, and it is not an applicable rule citation for this permit. Just as a PTI number is not an applicable rule citation by itself, there needs to be either an Ohio rule citation or a federal rule citation. In order to make the requirements of the CD federally enforceable in this PTI, either OAC 3745-31-05 (D) or (F) must be cited. The current citation has been changed from D to F.

e. Comment: B007/B008: b)(1)a. Note the requirements of 17-07(A) are as stringent as Subpart D, except for the 60% vs. 27%cap. There are unique provisions for SIP opacity requirements, that make it appropriate to list separately. There is no ‘streamlining’ or other advantage to subsume SIP opacity into NSPS opacity. This should read “Visible PE shall not exceed 20% opacity, as a 6-minute average, except for not more than 6 consecutive minutes in any 60 minutes, but shall not exceed 60 percent opacity, as a 6-minute average at any time except as provided by rule.” Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

Revise b)(1)b. to add ‘excluding periods of startup, shutdown, and malfunction.’

Response to comment 3.e: The language in the emission limits table has been changed to separate SIP requirements from NSPS requirements. The language for b)(1)b. has been changed to exclude SSM. 40 CFR Part 60.42 does exclude SSM.

f. Comment: B007/B008: b)(1)d. Compliance with Subpart D SO2 standards is not based on CEMS and is not rolling 3-hour average. 60.46(b)(4) establishes Method 6 as the SO2 compliance test method.

Response to comment 3.f: AEP requested the three-hour average replace the 30-day average, as documented in the December 2016 courtesy draft comments sent to Ohio EPA. The reasoning given was that the NSPS requires a 3-hour average. However, it was determined from reviewing the NSPS requirements, OAC 3745-18-04 (d)(2), and the available methods of testing specified (either stack testing or coal sampling), that a 30-day rolling average is correct. Therefore, the 3-hour average language has been removed.

g. Comment: B007/B008: b(1)f: Compliance with Subpart D NOx standards is not based on CEMS and is not rolling 3-hour average 60.46(b)(5) establishes Method 7 as the NOx compliance test method. If Conesville Units 5 and 6 test NOx emissions below 70% of the O.70 standard (i.e., below 0.49 lb/MMBtu), it is exempt from the requirements in 60.45(a) and (b)(3) for NOx CEMS. Note that NOx CEMS required by the Acid Rain program or transport rules are different from Part 60 monitoring and compliance test requirements.

Response to comment 3.g: See response to comment 4.f. The language has been removed.

4. Topic: Opacity Monitoring, Recordkeeping and Reporting for B004, B007 and B008-Comments from AEP on May 12, 2017

a. Comment: B004: d)(1), d(2), and d(3): These opacity monitoring requirements have nothing to do with the CD or the application, and are not appropriate in this PTI.

Response to comment 4.a: Agreed. These requirements were not established in PTI 06-08124. They have been established in the current Title V (which AEP previously suggested that the Title V language for monitoring be added to this PTI). Therefore, these requirements have been removed from this PTI administrative modification. The opacity monitoring and recordkeeping requirements will be addressed in the Title V Renewal.

b. Comment: B004: e)(1) and e)(2) Request to be deleted.

Response to Comment 4.b: Agreed. These requirements were not established in PTI 06- 08124. They have been established in the current Title V (which AEP previously suggested that the Title V language for reporting be added to this PTI). Therefore, these requirements have been removed from this PTI administrative modification. The opacity reporting requirements will be addressed in the Title V Renewal.

c. Comment: B007/B008, d)(1)(now d)(3)): The COMS certification letter was issued on Dec. 12, 2005. Because of the wet FGD controls, the permit should state that COMS must be located in each of two ducts (for each Unit) between the ESP outlet and the FGD inlet. What is the basis or purpose of ‘instantaneous’ opacity recordkeeping? If no basis it should be removed. Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

Response to comment 4.c: The requested revisions to the permit were made, and the language regarding COMS was kept. NSPS 40 CFR Part 60.13 (f) refers to Appendix B Performance Specifications to properly install CEMS such that representative measurements of emissions or process parameters from the affected facility are obtained. It is justified to have ‘instantaneous’ opacity recordkeeping to ensure the quality of the data in order to truly ascertain compliance. This recordkeeping prevents the practice of picking and choosing data points that may not be representative.

d. Comment: B007/B008, e)(1)a. and b. Clarify that ‘applicable’ means in excess of the 1.5% of non-exempt operating time. The word ‘malfunction’ in this context should be understood to have its ordinary dictionary meaning. Emission unit ‘malfunctions’ as defined in 40 CFR 60.2 or 3745-15-06 are properly addressed elsewhere in this permit.

Response to comment 4.d: The language is standard for deviation reporting of excess emissions. Also, the reporting of downtime/malfunction applies to both the emissions unit and the monitoring system per AEPs current Title V operating permit. Although the clarification of the 1.5% has not been added, the language has been revised. Per 40 CFR Part 62, Malfunction means “any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.”

5. Topic: SO2 Monitoring, Recordkeeping and Reporting for B004, B007 and B008-Comments from AEP on May 12, 2017

a. Comment: B004: b)(2)g: This term should not in any way change the missing data and ‘calendar day’ provisions for the purposes of NSPS compliance determinations. Delete reference to Part 60.

Response to comment 5.a: B004 is not subject to NSPS subpart D. However, Ohio EPA’s rules for excess emissions reporting require the methods in 40 CFR Part 60. The language has not been removed.

b. Comment: B004: b(2)g: The current Title V permit provides for SO2 CEMS certification in accordance with Part 75, and SO2 30-day average elements in accordance with Part 60. There is no basis to impose Part 60 QA/QC requirements for the Unit 4 SO2 CEMS in this PTI or any other permit. The SO2 CEMS monitoring terms, if any belong in this PTI at all, should be an identical cut and paste of the SO2 CEMS monitoring terms for Unit 4 in the existing Title V permit.

Response to comment 5.b: PTI 06-08124 refers to the Title IV and Title V permit for any monitoring, recordkeeping and testing requirements for SO2. We will make the few revisions requested, and we will address the detailed monitoring and CEMS requirements in the Title V Renewal. Ohio EPA’s expectation is that Part 75 methods may be used in place of Part 60 for QA/QC purposes only. Any data crunching procedures must be done according to Part 60.

c. Comment: B004: d)(5)a: Why is this necessary? If not, it should be taken out.

Response to Comment 5.c: These are the units of output from the SO2 monitor. The value in letter a) (concentration) is used with either O2 or CO2 flow rate to calculate the value in letter b). The language has been removed, and we will address the detailed monitoring and CEMS requirements in the Title V Permit Renewal. Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

d. Comment: B004: e)(3)(b)iv and x. The excess emissions terminology is inappropriate for Conesville Unit 4 (which is not subject to Part 60) and the phrase ‘as specified above’ is unduly vague.

Response to comment 5.d: Agreed that B004 is not subject to Part 60. However, Ohio EPA’s expectation is that BAT be followed. Ohio EPA’s rules for excess emissions reporting require the methods in 40 CFR Part 60. However, we will address detailed reporting in the Title V Permit Renewal.

e. Comment: B007/B008: 2(b)f: Appendix C to the Consent Decree notes that the SO2 monitoring system has ‘two separate FGD inlet monitors in each of the two FGD inlet ducts for each Unit, and one FGD outlet monitor in the combined flow from the outlets of the FGD modules for each Unit, prior to the common stack.’ So technically, this isn’t a ‘stack SO2 monitoring system’. The term should not in any way change the missing data and ‘calendar day ‘provisions for purposes of NSPS compliance determinations. Last sentence of the third paragraph is a good clarification.

Response to Comment 5.e: The marked-up revisions were made to this term and condition, and AEP’s comments are noted.

f. Comment: B007/B008, d)(2)a. Why is this necessary? If not justified it should be removed.

Response to comment 5.f: These are the units of output from the SO2 monitor. The value in letter a) (concentration) is used with either O2 or CO2 flow rate to calculate the value in letter b). The language has been removed from the permit, and we will address detailed monitoring in the Title V Permit Renewal.

g. Comment: B007/B008, e)(2)b)xi and xii. Emission unit ‘malfunctions’ as defined in 40 CFR 60.2 or 3745-15-06 are properly addressed elsewhere in this permit.

Response to comment 5.g: Ohio EPA’s expectation is that BAT be followed. Ohio EPA’s rules for excess emissions reporting require the methods in 40 CFR Part 60. The language has been removed, and we will address detailed reporting in the Title V Permit Renewal.

6. Topic: NOx Monitoring, Recordkeeping and Reporting for B007 and B008-Comments from AEP on May 12, 2017

a. Comment: B007/B008, b)(2)g. Note that NOx CEMS are not the compliance test method for purposes of Subpart D.

Response to comment 6.a: We will make the few revisions requested, and we will address the detailed monitoring and CEMS requirements in the Title V Renewal. Ohio EPA’s expectation is that Part 75 methods may be used in place of Part 60 for QA/QC purposes only. Any data crunching procedures must be done according to Part 60.

b. Comment: B007/B008, d)(4)a. Why is this necessary? If not justified it should be removed.

Response to comment 6.b: These are the units of output from the NOx monitor. The value in letter a) (concentration) is used with either O2 or CO2 flow rate to calculate the value in letter b). Therefore, the language is deemed necessary , and although removed from this permit, we will address in the Title V Permit Renewal. Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

c. Comment B007/B008: d(4)b: Emission unit ‘malfunctions’ as defined in 40 CFR 60.2 or 3745- 15-06 are properly addressed elsewhere in the permit.

d. Response to comment 6.c Ohio EPA’s expectation is that BAT be followed. Ohio EPA’s rules for excess emissions reporting require the methods in 40 CFR Part 60. The language has been revised to better reflect that.

7. Topic: Testing Requirements for B004, B007 and B008-Comments from AEP on May 12, 2017

a. Comment: B004 f(1)b. and f(1)c: There is no certifiable COM on Conesville Unit 4, and it is not technically feasible to reliably monitor opacity in the Unit 4 ductwork or stack. The opacity monitoring requirements should be addressed in the Title V permit, not this PTI. This is now contrary to the Ohio SIP, and the 1.5% exception is contrary to OAC 3745-17-03(B)(1)(b)(i) (which allows ‘nonexempt opacity values in excess of twenty per cent opacity less than 1.10 percent’’ of the time) This term is not affected in any way by the CD. It should be addressed in the Title V permit renewal, not this PTI. This is probably consistent with the SIP (which requires Method 9 testing to determine compliance with OAC 3745-17-07 (A)(1)), but it’s inconsistent with current OAC 3745-17-03(B)(1)(b)(iii) (which allows the Ohio EPA to accept either the COMS or the Method 9 reading, depending on what it finds credible)

Response to Comment 7.a: OAC rule 3745-17-03 (C) is the correct requirement applicable to B004, since B004 is classified as a 40 CFR Part 51, Appendix P EGU (i.e. an EGU with an annual average capacity factor of greater than 30 percent and heat input of greater than 250 lb/MMBtu/hr). OAC rule 3745-17-03(b)(iii) is a for coal-fired boilers with heat input capacities equal to or greater than 250 MMBtu/hr that are controlled with either baghouses or electrostatic precipitators. The language is standard for deviation reporting of excess emissions. Also, the reporting of downtime/malfunction applies to both the emissions unit and the monitoring system per AEP’s current Title V operating permit. . Per 40 CFR Part 62, Malfunction means “any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.”

b. Comment: B007/B008: b)(1)d. and f)(1)a. Compliance with Subpart D SO2 standards is not based on CEMS and is not rolling 3-hour average. 60.46(b)(4) establishes Method 6 as the SO2 compliance test method. Subpart D is not a rolling 3-hour average. EPA proposed, but never finalized, a rolling 30-day average test method for Subpart D when using SO2 CEMS for compliance determination purposes. It is important not to confuse NSPS ‘excess emissions reporting with NSPS compliance determination testing. For purposes of excess emission reporting under Subpart D, ‘Excess emissions for affected facilities are defined as “For affected facilities electing not to comply with 60.43(d), any three-hour period during which the average emissions (arithmetic average of three contiguous one-hour periods) of SO2 as measured by a CEMS exceed the applicable standard in 60.43” ….”40CFR 60.45(g)(2)(i). However, the compliance test method for SO2 in Subpart D, 60.46(b)(4) is periodic Method 6 testing under representative operating conditions.

Response to comment 7.b: AEP requested the three-hour average replace the 30-day average, as documented in the December 2016 courtesy draft comments sent to Ohio EPA. The reasoning given was that the NSPS requires a 3-hour average. 40 CFR 60.68 specifies three 1 hour runs. However, B007 and B008 are specifically written into OAC rule 3745-18-04, and Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

they are given two sampling options: coal sampling or quarterly stack testing. These methods have a 30-day rolling average. Therefore, the 3-hour average language has been revised.

c. Comment B007/B008: b)(1)f. and f)(1)b: This is now contrary to the Ohio SIP, and the 1.5% exception is contrary to OAC 3745-17-03(B)(1)(b)(i) (which allows ‘nonexempt opacity values in excess of twenty per cent opacity less than 1.10 percent’’ of the time) This term is not affected in any way by the CD. It should be addressed in the Title V permit renewal, not this PTI. This is probably consistent with the SIP (which requires Method 9 testing to determine compliance with OAC 3745-17-07 (A)(1)), but it’s inconsistent with current OAC 3745-17-03(B)(1)(b)(iii) (which allows the Ohio EPA to accept either the COMS or the Method 9 reading, depending on what it finds credible)

Response to comment 7.c: The language is standard for deviation reporting of excess emissions. Also, the reporting of downtime/malfunction applies to both the emissions unit and the monitoring system per AEPs current Title V operating permit. The language has not been deleted. Per 40 CFR Part 62, Malfunction means “any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.”

d. Comment: B007/B008: f(1): Shouldn’t there be a subparagraph incorporating Part II of Appendix C of the Consent Decree (“Calculation of 30-day rolling average Removal Efficiency”).

Response to Comment 7.d: Yes, the paragraph has been added to f(1) stating the limit and the applicable compliance method.

8. Topic: General Comments from AEP on May 12, 2017

a. Comment: B004: b)(2)f. and B007/B008 b)(2)e: Performance Spec. 1 has nothing to do with QA/QC. Instead, it relates to COMS installation and initial field performance tests. See 40 CFR Part 60, Appendix B, Performance Spec. 1, paragraph 20. For B007/B008: Appendix F, Procedure 3 does not require daily automatic zero span checks. It requires, at a minimum, daily checks of (1) zero drift, (2) upscale drift, and (3) status indicators, data acquisition system error messages, and other system self-diagnostic indicators. See Procedure 3, paragraph 10.1.

Response to comment 8.a: Although this language is in our standard library of terms and conditions, there are variations based upon parameters. The language has been removed from this PTI.

9. Topic: Section A. Standard Terms and Conditions – Comments from AEP on May 12, 2017

a. Comment: Section 3, General Requirements: (3.a, b, and c): OAC 3745-31-07 contains no provisions allowing Ohio EPA to modify a PTI upon a determination of noncompliance with its conditions.

Response to comment 9.a: Ohio EPA’s Standard Terms and Conditions contain the same language in air permits for all facilities. These terms are periodically updated (per 5 yr review and/or comments from the regulated community) and are sent out for public comment prior to use. AEP’s comments are noted, but this PTI is not the proper venue to address these comments. Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 b. Comment: Section 4, Monitoring and Recordkeeping and Reporting (4c.(2) and (3)- minor additions/corrections to the language

Response to comment 9.b: See Ohio EPA’s response to comment 2.a. c. Comment: Section 5, Scheduled Maintenance/Malfunction Reporting: To the extent this language (“i.e., upset” attempts to modify the language of the Ohio Administrative Code, it is inappropriate. But because the parenthetical clarifies that “upset” means nothing more than the definition of malfunction in OAC 3745-15-06(B)(1), which the reader will have to look up anyway, this struck language here serves no useful purpose.

Response to comment 9.c: See Ohio EPA’s response to comment 2.a. d. Comment: Section 6, Compliance Requirements 6.a): U.S.EPA has approved Ohio’s electronic reporting system as consistent with the CROMERR

Response to comment 9.d: See Ohio EPA’s response to comment 2.a. e. Comment: Section 7, Best Available Technology: Generally speaking, this paragraph serves no useful purpose. A permittee must comply with the terms and conditions of a final, uncontested permit regardless, whether they’re based on BAT or not. And in the context of this permit, this paragraph is irrelevant, because there are no BAT-based requirements in this permit. “BAT is not required if the air contaminant source was installed before January 1, 1974” OAC 3745-31- 05(A)(3)(a)(i).

Response to comment 9.e: See Ohio EPA’s response to comment 2.a. f. Comment: Section 8, Air Pollution Nuisance: Emissions specifically covered and authorized by the permit cannot reasonably be subjected to superseding nuisance liability.

Response to comment 9.f: See Ohio EPA’s response to comment 2.a. g. Comment: Section 9, Reporting Requirements: minor typo corrections and revisions.

Response to comment 9.g: See Ohio EPA’s response to comment 2.a. h. Comment: Section 11, Construction of New Source(s) and Authorization to Install 11.a): This must be removed, because the source is already operating. This sentence is redundant of the first sentence. This must be removed, because the source is already operating. This seems to exceed Ohio EPA’s authorities Generally speaking, if a source cannot meet its permit’s requirements, the source could shut down, modify its operations, or seek a permit modification. But this phrase seems to give Ohio EPA carte blanche to issue orders requiring the installation of additional facilities, and suggests that the permittee must accept those orders, with no right of appeal. Minor revisions to section 11. 11.e): This subparagraph is redundant of the prior section d). Response to Comments Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000

Response to comment 9.h: See Ohio EPA’s response to comment 2.a. i. Comment: Section 12, Permit to Operate Application: The “commence operation” date of Conesville Unit 4 was long ago. This language is not appropriate for the unique circumstances of this PTI.”

Response to comment 9.i: See Ohio EPA’s response to comment 2.a. j. Comment: Section 13: This is irrelevant to the permit

Response to comment 9.j: See Ohio EPA’s response to comment 2.a. k. Comment: Sections 14, 15, and 16: Minor revisions and additions.

Response to Comment 9.k: See Ohio EPA’s response to comment 2.a.

FINAL

Division of Air Pollution Control Permit-to-Install for Conesville Power Plant

Facility ID: 0616000000 Permit Number: P0120809 Permit Type: Administrative Modification Issued: 10/6/2017 Effective: 10/6/2017

Division of Air Pollution Control Permit-to-Install for Conesville Power Plant

Table of Contents

Authorization ...... 1 A. Standard Terms and Conditions ...... 3 1. Federally Enforceable Standard Terms and Conditions ...... 4 2. Severability Clause ...... 4 3. General Requirements...... 4 4. Monitoring and Related Record Keeping and Reporting Requirements...... 5 5. Scheduled Maintenance/Malfunction Reporting ...... 6 6. Compliance Requirements...... 6 7. Best Available Technology...... 7 8. Air Pollution Nuisance...... 8 9. Reporting Requirements ...... 8 10. Applicability...... 8 11. Construction of New Sources(s) and Authorization to Install ...... 8 12. Permit-To-Operate Application...... 9 13. Construction Compliance Certification ...... 10 14. Public Disclosure ...... 10 15. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations ...... 10 16. Fees...... 10 17. Permit Transfers ...... 10 18. Risk Management Plans ...... 10 19. Title IV Provisions ...... 10 B. Facility-Wide Terms and Conditions...... 11 C. Emissions Unit Terms and Conditions ...... 13 1. B004, Unit 4 Main Boiler ...... 14 2. Emissions Unit Group -Main Boilers Units 5 and 6: B007, B008...... 19

Final Permit-to-Install Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 Effective Date: 10/6/2017

Authorization Facility ID: 0616000000 Facility Description: Power plant. Application Number(s): M0003996, A0056350 Permit Number: P0120809 Permit Description: Administrative modification permit to include the requirements of a federal consent decree in federally enforceable permit other than a Title V permit. In accordance with the consent decree entered 12/10/2007, between the United States of America and the State of New York, et. al and Ohio Citizen Action et al. v. American Electric Power Service Corp. et al, (Civil Action Nos. C2-05- 360 & C2-99-1250 (consolidated with C2-99-1182)& C2-04-1098), lodged October 9, 2007 with the U.S. District Court for the Southern District of Ohio, Eastern Division Permit Type: Administrative Modification Permit Fee: $6,000.00 Issue Date: 10/6/2017 Effective Date: 10/6/2017

This document constitutes issuance to:

Conesville Power Plant 47201 County Road 273 Conesville, OH 43811-9799 of a Permit-to-Install for the emissions unit(s) identified on the following page.

Ohio Environmental Protection Agency (EPA) District Office or local air agency responsible for processing and administering your permit:

Ohio EPA DAPC, Southeast District Office 2195 Front Street Logan, OH 43138 (740)385-8501

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or modified in accordance with the plans included in the application, the emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits to operate (air) or NPDES permits as applicable.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Craig W. Butler Director

Page 1 of 27 Final Permit-to-Install Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 Effective Date: 10/6/2017 Authorization (continued)

Permit Number: P0120809 Permit Description: Administrative modification permit to include the requirements of a federal consent decree in federally enforceable permit other than a Title V permit. In accordance with the consent decree entered 12/10/2007, between the United States of America and the State of New York, et. al and Ohio Citizen Action et al. v. American Electric Power Service Corp. et al, (Civil Action Nos. C2-05-360 & C2-99-1250 (consolidated with C2- 99-1182)& C2-04-1098), lodged October 9, 2007 with the U.S. District Court for the Southern District of Ohio, Eastern Division

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below:

Emissions Unit ID: B004 Company Equipment ID: Unit 4 Main Boiler Superseded Permit Number: 06-08124 General Permit Category and Type: Not Applicable

Group Name: Main Boilers Units 5 and 6 Emissions Unit ID: B007 Company Equipment ID: Unit 5 Main Boiler Superseded Permit Number: P0123465 General Permit Category and Type: Not Applicable Emissions Unit ID: B008 Company Equipment ID: Unit 6 Main Boiler Superseded Permit Number: P0123464 General Permit Category and Type: Not Applicable

Page 2 of 27 Final Permit-to-Install Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 Effective Date: 10/6/2017

A. Standard Terms and Conditions

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1. Federally Enforceable Standard Terms and Conditions

a) All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only:

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

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

(3) Standard Term and Condition A.6.c) and A. 6.d), Compliance Requirements

(4) Standard Term and Condition A.9., Reporting Requirements

(5) Standard Term and Condition A.10., Applicability

(6) Standard Term and Condition A.11.b) through A.11.e), Construction of New Source(s) and Authorization to Install

(7) Standard Term and Condition A.14., Public Disclosure

(8) Standard Term and Condition A.15., Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

(9) Standard Term and Condition A.16., Fees

(10) Standard Term and Condition A.17., Permit Transfers

2. Severability Clause

a) A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any other term or condition thereof, except to the extent that any other term or condition depends in whole or in part for its operation or implementation upon the term or condition declared invalid.

b) All terms and conditions designated in parts B and C of this permit are federally enforceable as a practical matter, if they are required under the Act, or any of its applicable requirements, including relevant provisions designed to limit the potential to emit of a source, are enforceable by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by section 304 of the Act) under the Act. Terms and conditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if specifically identified in this permit as such.

3. General Requirements

a) Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and re-issuance, or modification.

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b) It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the federally enforceable terms and conditions of this permit.

c) This permit may be modified, revoked, or revoked and reissued, for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit.

d) This permit does not convey any property rights of any sort, or any exclusive privilege.

e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. For information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S. EPA requests such information, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.

4. Monitoring and Related Record Keeping and Reporting Requirements

a) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit:

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

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

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

(4) The analytical techniques or methods used.

(5) The results of such analyses.

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

b) Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited to all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in computerized form.

c) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall submit required reports in the following manner:

(1) Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Ohio EPA DAPC, Southeast District Office.

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(2) Quarterly written reports of (i) any deviations from federally enforceable emission limitations, operational restrictions, and control device operating parameter limitations, excluding deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06, that have been detected by the testing, monitoring and recordkeeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) any corrective actions or preventive measures taken, shall be made to the Ohio EPA DAPC, Southeast District Office. The written reports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. See A.15. below if no deviations occurred during the quarter.

(3) Written reports, which identify any deviations from the federally enforceable monitoring, recordkeeping, and reporting requirements contained in this permit shall be submitted to the Ohio EPA DAPC, Southeast District Office every six months, by January 31 and July 31 of each year for the previous six calendar months. If no deviations occurred during a six-month period, the permittee shall submit a semi-annual report, which states that no deviations occurred during that period.

(4) This permit is for an emissions unit located at a Title V facility. Each written report shall be signed by a responsible official certifying that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete.

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

5. Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units or any associated air pollution control system(s) shall be reported to the Ohio EPA DAPC, Southeast District Office 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).

6. Compliance Requirements

a) All applications, notifications or reports required by terms and conditions in this permit to be submitted or "reported in writing" are to be submitted to Ohio EPA through the Ohio EPA's eBusiness Center: Air Services web service ("Air Services"). Ohio EPA will accept hard copy submittals on an as-needed basis if the permittee cannot submit the required documents through the Ohio EPA eBusiness Center. In the event of an alternative hard copy submission in lieu of the eBusiness Center, the post-marked date or the date the document is delivered in person will be recognized as the date submitted. Electronic submission of applications, notifications or reports required to be submitted to Ohio EPA fulfills the requirement to submit the required information to the Director, the appropriate Ohio EPA District Office or contracted

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local air agency, and/or any other individual or organization specifically identified as an additional recipient identified in this permit unless otherwise specified. Consistent with OAC rule 3745-15-03, the electronic signature date shall constitute the date that the required application, notification or report is considered to be "submitted". Any document requiring signature may be represented by entry of the personal identification number (PIN) by responsible official as part of the electronic submission process or by the scanned attestation document signed by the Authorized Representative that is attached to the electronically submitted written report.

Any document (including reports) required to be submitted and required by a federally applicable requirement in this permit shall include a certification by a Responsible Official that, based on information and belief formed after reasonable inquiry, the statements in the document are true, accurate, and complete.

b) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Director of the Ohio EPA or an authorized representative of the Director to:

(1) At reasonable times, enter upon the permittee's premises where a source is located or the emissions-related activity is conducted, or where records must be kept under the conditions of this permit.

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

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

(4) As authorized by the Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit and applicable requirements.

c) The permittee shall submit progress reports to the Ohio EPA DAPC, Southeast District Office concerning any schedule of compliance for meeting an applicable requirement. Progress reports shall be submitted semiannually or more frequently if specified in the applicable requirement or by the Director of the Ohio EPA. Progress reports shall contain the following:

(1) Dates for achieving the activities, milestones, or compliance required in any schedule of compliance, and dates when such activities, milestones, or compliance were achieved.

(2) An explanation of why any dates in any schedule of compliance were not or will not be met, and any preventive or corrective measures adopted.

7. Best Available Technology

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

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8. Air Pollution Nuisance

The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in violation of OAC rule 3745-15-07.

9. Reporting Requirements

The permittee shall submit required reports in the following manner:

a) Reports of any required monitoring and/or recordkeeping of state-only enforceable information shall be submitted to the Ohio EPA DAPC, Southeast District Office.

b) Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterly written reports of (a) any deviations (excursions) from state-only required emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and recordkeeping requirements specified in this permit, (b) the probable cause of such deviations, and (c) any corrective actions or preventive measures which have been or will be taken, shall be submitted to the Ohio EPA DAPC, Southeast District Office. If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. The reports shall be submitted quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. (These quarterly reports shall exclude deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)

10. Applicability

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

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

a) This permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. This permit does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the application and terms and conditions of this permit. The action of beginning and/or completing construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745- 31-02. Furthermore, issuance of this permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. Issuance of this permit is not to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (or other persons) may have against the applicant for starting construction prior to the effective date of the permit. Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if the proposed facilities cannot meet the requirements of this permit or cannot meet applicable standards.

b) If applicable, authorization to install any new emissions unit included in this permit shall terminate within eighteen months of the effective date of the permit if the owner or operator has not undertaken a continuing program of installation or has not entered into a binding contractual obligation to undertake and complete within a reasonable time a continuing program of installation. This deadline may be extended by up to 12 months if application is made to the

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Director within a reasonable time before the termination date and the permittee shows good cause for any such extension.

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

d) The provisions of this permit shall cease to be enforceable for each affected emissions unit after the date on which an emissions unit is permanently shut down (i.e., emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31). All records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with law. All reports required by this permit must be submitted for any period an affected emissions unit operated prior to permanent shut down. At a minimum, the permit requirements must be evaluated as part of the reporting requirements identified in this permit covering the last period the emissions unit operated.

Unless otherwise exempted, no emissions unit certified by the responsible official as being permanently shut down may resume operation without first applying for and obtaining a permit pursuant to OAC Chapter 3745-31 and OAC Chapter 3745-77 if the restarted operation is subject to one or more applicable requirements.

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

12. Permit-To-Operate Application

The permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77. The permittee shall submit a complete Title V permit application or a complete Title V permit modification application within twelve (12) months after commencing operation of the emissions units covered by this permit. However, if operation of the proposed new or modified source(s) as authorized by this permit would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit modification of such new or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 3745-77-08(C)(3)(d) must be obtained before operating the source in a manner that would violate the existing Title V permit requirements.

Page 9 of 27 Final Permit-to-Install Conesville Power Plant Permit Number: P0120809 Facility ID: 0616000000 Effective Date: 10/6/2017

13. Construction Compliance Certification

The applicant shall identify the following dates in the "Air Services" facility profile for each new emissions unit identified in this permit.

a) Completion of initial installation date shall be entered upon completion of construction and prior to start-up.

b) Commence operation after installation or latest modification date shall be entered within 90 days after commencing operation of the applicable emissions unit.

14. Public Disclosure

The facility is hereby notified that this permit, and all agency records concerning the operation of this permitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03.

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

If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. The reports shall be submitted quarterly by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters.

16. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 and OAC Chapter 3745-78. The permittee shall pay all applicable permit-to-install fees within 30 days after the issuance of any permit-to-install. The permittee shall pay all applicable permit-to-operate fees within thirty days of the issuance of the invoice.

17. Permit Transfers

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

18. Risk Management Plans

If the permittee is required to develop and register a risk management plan pursuant to section 112(r) of the Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall comply with the requirement to register such a plan.

19. Title IV Provisions

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee shall ensure that any affected emissions unit complies with those requirements. Emissions exceeding any allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder, are prohibited.

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B. Facility-Wide Terms and Conditions

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1. All the following facility-wide terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:

a) None.

2. Emissions unit B004 is not currently subject to the requirements specified in 40 CFR Part 60, Subparts D and Da, because construction did not commence and modifications were not made after the effective dates of these Subparts.

3. The following emissions units contained in this permit are subject to 40 CFR Part 60, Subparts A and D, Standards of Performance for Electric Utility Steam Generating Units (NSPS): B007 and B008. The complete NSPS requirements, including the NSPS General Provisions may be accessed via the internet from the Electronic Code of Federal Regulations (e-CFR) website http://ecfr.gpoaccess.gov or by contacting the appropriate Ohio EPA District office or local air agency.

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C. Emissions Unit Terms and Conditions

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1. B004, Unit 4 Main Boiler

Operations, Property and/or Equipment Description:

Combustion Engineering model 7868 pulverized coal-fired, dry-bottom boiler (Unit 4 Main Boiler), having a nominal capacity of 7960 million Btu/hr, and controlled with an electrostatic precipitator (ESP), selective catalytic reduction (SCR), and a flue gas desulfurization (FGD) scrubber.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(2)b.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. OAC rule 3745-31-02(A) and Sulfur dioxide (SO2) emissions shall not exceed 0.90 pound per million Btu PTI 06-08124, (6/20/2006) (MMBtu) of actual heat input, based upon a rolling, 30-day average, as verified by the operation of the certified SO2 continuous emissions monitoring system (CEMS) and the associated record keeping requirements See b)(2)c., b)(2)d., d)(2), e)(1), e)(3), f)(1)a. b. OAC rule 3745-18-22(B)(1) The SO2 limit established pursuant to this rule applies at all times and is less stringent than the SO2 emission limitation established pursuant to OAC rule 3745- 31-05 (F) and PTI 06-08124. The permittee shall comply with all applicable emission limitations (including any less stringent emission limitation) for this emissions unit. c. OAC rule 3745-31-05(F) Installation and continuous operation of a (United States of America and the flue gas desulfurization system (FGD. State of New York, et. al and Ohio Installation and continuous operation of a Citizen Action et al. v. American

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Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures Electric Power Service Corp. et al, selective catalytic reduction (SCR) (Civil Action Nos. C2-05-360 & C2- system. 99-1250 (consolidated with C2-99- See b)(2)a., c)(1), c)(2), d)(1), d)(3), and 1182) & C2-04-1098), lodged on e)(2). October 9, 2007 and entered on December 10, 2007 with the U.S. District Court for the Southern District of Ohio, Eastern Division, as amended on April 5, 2010, December 28, 2010, and May 14, 2013 (hereinafter “Consent Decree”)

(2) Additional Terms and Conditions

a. “Continuously Operate” or “Continuous Operation” means that when an SCR, FGD, DSI, ESP, or other NOx pollution controls are used at an emissions unit, except during a malfunction, they shall be operated at all times such emissions unit is in operation, consistent with the technological limitations, manufacturers’ specifications, and good engineering and maintenance practices for such equipment and the emissions unit so as to minimize emissions to the greatest extent practicable.

b. For purposes of complying with air dispersion modeling requirements as depicted in Ohio EPA's Engineering Guide 69, dated 2003, the permittee has accepted the SO2 emission rate listed in term b)(1)a. to show that this new allowable emission rate will not cause or contribute to a violation of the SO2 National Ambient Air Quality Standard (NAAQS) and/or a violation of the Prevention of Significant Deterioration (PSD) increment based upon the permittee's air dispersion modeling information, submitted on March 28, 2006, and the Permit to Install application, submitted on March 28, 2006 to Ohio EPA.

c. The permittee shall maintain a written quality assurance/quality control plan for the continuous SO2 monitoring system, designed to ensure continuous valid and representative readings of SO2 emissions in units of the applicable standard(s). Except as allowed below, the plan shall follow the relevant requirements of 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous SO2 monitoring system must be kept on site and available for inspection during regular office hours. The permittee may keep these records electronically (on or offsite), provided the record can be made readily available when requested by Ohio EPA.

The plan shall include the requirement to conduct relative accuracy test audits for the continuous SO2 monitoring system in accordance with the frequencies required pursuant to 40 CFR Part 60 and 40 CFR Part 75; or may follow relative accuracy test audit frequency requirements for monitoring systems subject to 40 CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either

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case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60.

The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or relative accuracy audits required per 40 CFR Part 60.

d. The SO2 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. c) Operational Restrictions

(1) The permittee shall continuously operate a SCR to control NOx emissions from this emissions unit.

(2) The permittee shall continuously operate a FGD to control SO2 emissions from this emissions unit. d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall record the duration of any period during which the FGD did not Continuously Operate, including the specific dates and times that the FGD did not operate, the reason why permittee did not Continuously Operate the FGD, and the measures taken to reduce emissions of SO2 controlled by the FGD.

(2) The permittee shall operate and maintain equipment to continuously monitor and record sulfur dioxide emissions from this emissions unit in units of the applicable standard(s). Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 75.

Each continuous monitoring system consists of all the equipment used to acquire data and includes the sample extraction and transport hardware, sample conditioning hardware, analyzers, and data recording/processing hardware and software.

The permittee shall maintain documentation from the USEPA or the Ohio EPA that the continuous sulfur dioxide monitoring system has been certified in accordance with 40 CFR Part 75. The letter of certification shall be made available to the Director upon request.

The permittee shall maintain records of the following data obtained by the continuous sulfur dioxide monitoring system: the average daily and rolling, 30-day average emission rates of sulfur dioxide in lb/mmBtu actual heat input, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments. In addition, the permittee shall maintain daily records of the total actual heat input values as determined through F-Factor and carbon dioxide/oxygen calculations as specified in 40 CFR Part 60, Appendix A, Method 19.

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(3) The permittee shall record the duration of any period during which the SCR did not Continuously Operate, including the specific dates and times that the SCR did not operate, the reason why permittee did not Continuously Operate the SCR, and the measures taken to reduce emissions of NOx controlled by the SCR. e) Reporting Requirements

(1) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all instances of sulfur dioxide values in excess of the applicable rolling, 30-day average sulfur dioxide emission rate (lb/mmBtu). These reports shall also contain average daily sulfur dioxide emission rates (lb/mmBtu) which are greater than 1.5 times the sulfur dioxide emission limitation specified in A.1.

The reports shall also document any continuous sulfur dioxide monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect along with the emissions unit operating time during the reporting period and the date, time, reason, and corrective action(s) taken for each time period of emissions unit, control equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report.

These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

(2) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting any period during which the SCR or the FGD did not Continuously Operate, including the specific dates and times that such pollution control did not operate, the reason why permittee did not Continuously Operate such pollution control, and the measures taken to reduce emissions of the pollutant controlled by such pollution control.

(3) The permittee shall collect, record, and maintain measurements, data, records, and reports required per 40 CFR Part 75; and shall submit certification, recertification, notifications, applications, monitoring plans, petitions for alternative monitoring

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systems, electronic quarterly reports, and any other pertinent record and/or report to the Administrator (U.S. EPA), as required by this Part. f) Testing Requirements

(1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b)(1) of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

SO2 emissions shall not exceed 0.90 pound per million Btu actual heat input, (as a rolling, 30-day average).

Applicable Compliance Method:

Compliance with the sulfur dioxide emission limitation shall be based upon a rolling, 30-day average of the daily sulfur dioxide emission rates, in accordance with the USEPA's policy entitled "Enforcement Policy for Sulfur Dioxide Emission Limitations in Ohio" and dated February 11, 1980 (45 FR 9101). The daily and rolling 30-day sulfur dioxide emission rates shall be determined and reported in accordance with the applicable requirements of paragraphs d)(2) and e(1) of this permit. The permittee may be required to perform sulfur dioxide emission tests if warranted by the USEPA's enforcement policy. In such cases, the methods and procedures specified in 40 CFR Part 60.46 shall be employed. g) Miscellaneous Requirements

(1) None.

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2. Emissions Unit Group -Main Boilers Units 5 and 6: B007, B008

EU ID Operations, Property and/or Equipment Description B007 Combustion Engineering pulverized coal-fired, dry-bottom boiler (Unit 5 Main Boiler), having a nominal capacity of 4091 million Btu/hr, and controlled with low NOx burners, an electrostatic precipitator (ESP), and a flue gas desulfurization (FGD) scrubber and GORE mercury reduction system. This unit shares a common stack with B008. B008 Combustion Engineering pulverized coal-fired, dry-bottom boiler (Unit 6 Main Boiler), having a nominal capacity of 4091 million Btu/hr, and controlled with low NOx burners, an electrostatic precipitator (ESP), and a flue gas desulfurization (FGD) scrubber and GORE mercury reduction system. This unit shares a common stack with B007.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:

(1) None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures a. OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE) shall not exceed 20% opacity, as a 6-minute average, except as provided by rule. b. OAC rule 3745-17-10(C)(1) PE shall not exceed 0.10 pound per MMBtu of actual heat input. c. OAC rule 3745-18-22(B)(2) Sulfur dioxide (SO2) emissions shall not exceed 1.2 lb/MMBtu actual heat input d. OAC rule 3745-31-05(F) Meet a 95%, 30-day rolling average (United States of America and the removal efficiency for SO2. State of New York, et. al and Ohio Citizen Action et al. v. American Continuous operation of FGD. Electric Power Service Corp. et al, (Civil Action Nos. C2-05-360 & C2- Continuous operation of the Low NOx 99-1250 (consolidated with C2-99- Burners 1182) & C2-04-1098), lodged on October 9, 2007 and entered on See b)(2)a, c)(1) - c)(3), d)(1), d)(2),d)(7), December 10, 2007 with the U.S. e)(5), f)(1)e. below. District Court for the Southern District of Ohio, Eastern Division, as amended on April 5, 2010, December 28, 2010, and May 14,

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Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures 2013 (hereinafter “Consent Decree”)

e. 40 CFR Part 60, Subpart D PE shall not exceed 0.10 pound per (40 CFR 60.40 – 60.49) MMBtu of actual heat input. [60.42(a)(1)]

Standards of Performance (NSPS) Exhaust gases shall not exhibit greater for Fossil Fuel-Fired Steam than 20% opacity, except for one 6- Generators minute period per hour of not more than 27% opacity, excluding periods of startup, shutdown, and malfunction. [60.42(a)(2)] [In accordance with 40 CFR 60.40(a), these emissions units are SO2 emissions shall not exceed 1.2 fossil fuel-fired steam generating pounds per MMBtu of actual heat input. units with a heat input capacity more [60.43(a)(2)] than 73 megawatts (250 million Btu per hour) for which construction or NOx emissions shall not exceed 0.70 modification commenced after pound per MMBtu of actual heat input. August 17, 1971, and are subject to [60.44(a)(3)] the emissions limitations and control measures specified in this section] The PE, opacity, and SO2 emission limitations specified in this subpart are equivalent to, or more stringent than, the PE, opacity, and SO2 emission limitations established pursuant to OAC rules 3745- 17-07(A), OAC rule 3745-17-10(C), and OAC rule 3745-18-22(B)(2). The permittee shall comply with all applicable emission limitations (including more stringent emission limitations) specified in this subpart.

e. 40 CFR 60.1 – 60.19 The provisions of Subpart A apply to the [40 CFR 60.1(a)] owner or operator of any stationary source which contains an affected facility that commenced construction or modification after the date of publication in 40 CFR Part 60 that is applicable to that facility.

(2) Additional Terms and Conditions

a. “Continuously Operate” or “Continuous Operation” means that when an SCR, FGD, DSI, ESP, or Other NOx pollution controls are used at an emissions unit,

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except during a malfunction, they shall be operated at all times such emissions unit is in operation, consistent with the technological limitations, manufacturers’ specifications, and good engineering and maintenance practices for such equipment and the emissions unit so as to minimize emissions to the greatest extent practicable. b. The permittee shall maintain a written quality assurance/quality control plan for the continuous opacity monitoring system (COMS), designed to ensure continuous valid and representative readings of opacity consistent with 40 CFR Part 60 Appendix F, Procedure 3 (considering the unique ductwork configuration upstream of the inlet to the wet FGD control system.) The plan shall include, at a minimum, procedures for conducting and recording daily system checks, provisions for conducting a quarterly audit of the continuous opacity monitoring system, and a description of preventive maintenance activities. The plan shall describe step by step procedures for ensuring accurate operation of the continuous opacity monitoring system 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 permittee may keep these records electronically (on or offsite), provided the record can be made readily available when requested by Ohio EPA. c. The permittee shall maintain a written quality assurance/quality control plan for the continuous SO2 monitoring system, designed to ensure continuous valid and representative readings of SO2 emissions in units of the applicable standard(s). Except as allowed below or as required by Appendix C of the Consent Decree, the plan shall follow the relevant requirements of 40 CFR Part 60, Appendix F and 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous SO2 monitoring system must be kept on site and available for inspection during regular office hours.

The plan shall include the requirement to conduct relative accuracy test audits for the continuous SO2 monitoring system in accordance with the frequencies required pursuant to 40 CFR Part 60 and 40 CFR Part 75; or may follow relative accuracy test audit frequency requirements for monitoring systems subject to 40 CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60.

The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or relative accuracy audits required per 40 CFR Part 60. The permittee may keep these records electronically (on or offsite), provided the record can be made readily available when requested by Ohio EPA. d. The permittee shall maintain a written quality assurance/quality control plan for the continuous NOx monitoring system, designed to ensure continuous valid and representative readings of NOx emissions in units of the applicable standard(s).

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Except as allowed below, the plan shall follow the relevant requirements of 40 CFR Part 60, Appendix F and 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous NOx monitoring system must be kept on site and available for inspection during regular office hours.

The plan shall include the requirement to conduct relative accuracy test audits for the continuous NOx monitoring system in accordance with the frequencies required pursuant to 40 CFR Part 60 and 40 CFR Part 75; or may follow relative accuracy test audit frequency requirements for monitoring systems subject to 40 CFR 75, Appendix B, in lieu of frequencies required in 40 CFR Part 60. In either case, results shall be recorded and reported in units of the applicable standard(s) in accordance with 40 CFR Part 60.

The plan shall include the requirement to conduct quarterly cylinder gas audits or relative accuracy audits pursuant to 40 CFR Part 60, and linearity checks pursuant to 40 CFR Part 75; however, linearity checks completed pursuant to 40 CFR Part 75, Appendix B, may be substituted for the quarterly cylinder gas or relative accuracy audits required per 40 CFR Part 60. The permittee may keep these records electronically (on or offsite), provided the record can be made readily available when requested by Ohio EPA.

e. The opacity, SO2, and NOx, continuous monitoring systems consist 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. c) Operational Restrictions

(1) The permittee shall continuously operate the upgraded FGD to control SO2 emissions from this emissions unit to meet a 95% 30-day Rolling Average Removal Efficiency.

(2) The permittee shall determine the 30-day rolling average removal efficiency for SO2 according to the monitoring plan submitted to Ohio EPA and dated December 22, 2008, and any subsequent amendments approved by US EPA and Ohio EPA.

(3) The permittee shall continuously operate Other NOx Pollution Controls (Low NOx Burners) to control NOx emissions from this emissions unit. d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall record the duration of any period during which the FGD did not Continuously Operate, including the specific dates and times that the FGD did not operate, the reason why permittee did not Continuously Operate the FGD, and the measures taken to reduce emissions of SO2 controlled by the FGD

(2) The permittee shall record the duration of any period during which the Additional NOx Pollution Controls (Low NOx Burners) did not Continuously Operate, including the specific dates and times that the Low NOx Burners did not operate, the reason why

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permittee did not Continuously Operate the Low NOx Burners, and the measures taken to reduce emissions of NOx controlled by the Low NOx Burners.

(3) The permittee shall operate and maintain equipment to continuously monitor and record the opacity of the visible particulate emissions from this emissions unit. Such continuous monitoring and recording equipment shall comply with the relevant requirements specified in 40 CFR Part 60.13.

Each continuous monitoring system consists of all the equipment used to acquire data and includes the sample extraction and transport hardware, sample conditioning hardware, analyzers, and data recording/processing hardware and software.

The permittee shall maintain a certification letter from the Ohio EPA documenting that the continuous opacity monitoring system has been certified in accordance with the requirements of 40 CFR Part 60, Appendix B, Performance Specification 1. The letter of certification shall be made available to the Director upon request.

The permittee shall maintain records of the following data obtained by the continuous opacity monitoring system: percent opacity on a 6-minute block average basis, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

(4) The permittee shall operate and maintain equipment to continuously monitor and record sulfur dioxide emissions from this emissions unit in units of the applicable standard(s). Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 75.

Each continuous monitoring system consists of all the equipment used to acquire data and includes the sample extraction and transport hardware, sample conditioning hardware, analyzers, and data recording/processing hardware and software.

The permittee shall maintain documentation from the USEPA or the Ohio EPA that the continuous sulfur dioxide monitoring system has been certified in accordance with 40 CFR Part 75. The letter of certification shall be made available to the Director upon request.

The permittee shall maintain records of the following data obtained by the continuous sulfur dioxide monitoring system: emissions of sulfur dioxide in lb/mmBtu actual heat input on an hourly average.

(5) The permittee shall operate and maintain equipment to continuously monitor and record nitrogen oxides emissions from this emissions unit in units of the applicable standard(s). Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 75.

Each continuous monitoring system consists of all the equipment used to acquire data and includes the sample extraction and transport hardware, sample conditioning hardware, analyzers, and data recording/processing hardware and software.

The permittee shall maintain documentation from the USEPA or the Ohio EPA that the continuous nitrogen oxides monitoring system has been certified in accordance with 40

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CFR Part 75. The letter of certification shall be made available to the Director upon request.

The permittee shall maintain records of the following data obtained by the continuous nitrogen oxides monitoring system: emissions of nitrogen oxides in lb/mmBtu actual heat input on an hourly average basis, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

(6) The permittee shall maintain daily records of the total actual heat input values as determined through F-Factor and carbon dioxide/oxygen calculations as specified in 40 CFR Part 60, Appendix A, Method 19.

(7) The permittee shall maintain records demonstrating compliance with the 30-day rolling average removal efficiency, calculated in accordance with the approved monitoring plan specified in Paragraph (c)(2) of this permit. e) Reporting Requirements

(1) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting all instances of opacity values in excess of the limitations specified in 40 CFR Part 60.42(a)(2) and OAC rule 3745-17-07, detailing the date, commencement and completion times, duration, magnitude (percent opacity), reason (if known), and corrective action(s) taken (if any) of each 6-minute block average above the applicable opacity limitation(s).

The reports shall also identify any excursions of the start-up and shutdown provisions specified in OAC rule 3745-17-07(A)(3) and document any continuous opacity monitoring system or control equipment downtime while the emissions unit was on line (date, time, duration and reason), along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

(2) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all sulfur dioxide values in excess of the applicable sulfur dioxide emission rate (lb/mmBtu).

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The reports shall also document any continuous sulfur dioxide monitoring system downtime while the emissions unit was on line (date, time, duration and reason), along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report.

These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

(3) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all 3-hour average nitrogen oxides values in excess of the applicable nitrogen oxides emission rate (lb/mmBtu).

The reports shall also document any continuous nitrogen oxide monitoring system downtime while the emissions unit was on line (date, time, duration and reason), along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report.

These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

(4) The permittee shall collect, record, and maintain measurements, data, records, and reports required per 40 CFR Part 75; and shall submit certification, recertification, notifications, applications, monitoring plans, petitions for alternative monitoring systems, electronic quarterly reports, and any other pertinent record and/or report to the Administrator (U.S. EPA), as required by this Part.

(5) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office

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documenting any period during which the SCR or the FGD did not Continuously Operate, including the specific dates and times that such pollution control did not operate, the reason why permittee did not Continuously Operate such pollution control, and the measures taken to reduce emissions of the pollutant controlled by such pollution control

(6) The permittee shall submit reports (hardcopy or electronic format) within 30 days following the end of each calendar quarter to the Ohio EPA Southeast District Office documenting any periods during which the 30-day rolling average SO2 removal efficiency was less than 95%, the reason (if known), and corrective actions taken (if any).

These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter. f) Testing Requirements

(1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b)(1) of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation

Visible PE from the stack shall not exceed 20 percent opacity, as a six-minute average, except as provided by rule. [OAC rule 3745-17-07(A)]

Exhaust gases shall not exhibit greater than 20% opacity, except for one 6- minute period per hour of not more than 27% opacity. [60.42(a)(2)]

Applicable Compliance Method:

The continuous opacity monitoring data shall be used to demonstrate compliance with the requirements of 40 CFR Part 60.42(a)(2) and OAC rule 3745-17- 07(A)(1).

Compliance with the visible emission limitations in 40 CFR Part 60.42(a)(2) and OAC rule 3745-17-07(A)(1) may also be determined in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures in 40 CFR Part 60.46 and OAC rule 3745-17-03(B)(1). In the event of a discrepancy between the continuous opacity monitoring data and observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 during the same time period, the Method 9 data will take precedence for that time period.

b. Emission Limitation:

PE shall not exceed 0.10 lb/MMBtu actual heat input.

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Applicable Compliance Method:

Compliance with the allowable pound PE per MMBtu limitation above shall be demonstrated based on the results of performance testing conducted in accordance with 40 CFR Part 60.46 and Methods 1 - 5 of 40 CFR Part 60, Appendix A. If not otherwise specified in the NSPS or OAC rule, subsequent testing requirements with specific testing frequencies shall be outlined in the Title V Operating Permit for the emissions unit(s).

c. Emission Limitation:

SO2 emissions shall not exceed 1.2 lbs/MMBtu actual heat input.

Applicable Compliance Method:

Compliance with the 1.2 lbs/mmBtu actual heat input SO2 emission limitation shall be based upon the applicable records and data specified in sections d)(4), d)(6), and e)(2).

If required, the permittee shall demonstrate compliance with the allowable mass emission rate for SO2 in accordance with the methods and procedures specified in 40 CFR Part 60.46.

d. Emission Limitation:

The FGD shall meet a 95%, 30-day rolling average removal efficiency for SO2.

Applicable Compliance Method:

Compliance with the SO2 removal efficiency above shall be determined using the monitoring data collected pursuant to the plan required pursuant to paragraph (c)(2) of this permit.

e. Emission Limitations:

NOx emissions shall not exceed 0.70 lb/MMBtu actual heat input

Applicable Compliance Method

Compliance with the 0.70 lb/mmBtu actual heat input NOx emission limitation shall be based upon the records and data specified in sections d)(5), d)(6), and e)(3).

If required, the permittee shall demonstrate compliance with the allowable mass emission rate for NOx in accordance with the methods and procedures specified in 40 CFR Part 60.46. g) Miscellaneous Requirements

(1) None.

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