epa draft permit-to-install 11.30.11

8/3/2019 EPA Draft Permit-To-Install 11.30.11

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Ohio I Em'lvi r "Onmenl taJProtQctiolll AgemeyJol: ln R. Ka's .Hch ,GO\M! r I ' lOrMar;T,a'lIlcr, Lt. GovernorSco t t J, Nanv . Diretto r

11/30/2011 Certified Mail

RE: DRAFT AIR POLLUTION PERMIT-TO-INSTALLFacility ID: 1318008750Permit Number: P0107767Permit Type: Initial InstallationCounty: Cuyahoga

No TOXIC REVIEWNo PSDYes SYNTHETIC MINOR TO AVOID MAJOR NSRYes CEMSNo MACT/GACTYes NSPSNo NESHAPSNo NETTINGNo MAJOR NON-ATTAINMENTYes MODELING SUBMITTED

Ivan HendersonCleveland Public Power - Ridge Rd1300 Lakeside AvenueCleveland, OH 44114

Dear Permit Holder:A draft of the Ohio Administrative Code (OAC) Chapter 3745-31 Air Pollution Permit-to-Install for the referenced facilityhas been issued for the emissions unit(s) listed in the Authorization section of the enclosed draft permit. This draft actionis not an authorization to begin construction or modification of your emissions unit(s). The purpose of this draft is to solicitpublic comments on the permit. A public notice will appear in the Ohio EPA Weekly Review and the local newspaper, ThePlain Dealer. A copy of the public notice and the draft permit are enclosed. This permit can be accessed electronically onthe Division of Air Pollution Control (DAPC) Web page ,www.epa.ohio.gov/dapc by clicking the "Issued Air PollutionControl Permits" link. Comments will be accepted as a marked-up copy of the draft permit or in narrative format. Anycomments must be sent to the following:

Andrew HallPermit Review/Development SectionOhio EPA, DAPC50 West Town Street, Suite 700P.O. Box 1049Columbus, Ohio 43216-1049

and Cleveland Division of Air Quality2nd Floor75 Erieview PlazaCleveland, OH 44114

Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in thenewspaper. You will be notified in writing if a public hearing is scheduled. A decision on issuing a final permit-to-installwill be made after consideration of comments received and oral testimony if a public hearing is conducted.Any permit feethat will be due upon issuance of a final Permit-to-Install is indicated in the Authorization section. Please do not submitany payment now. If you have any questions, please contact Cleveland Division of Air Quality at (216)664-2297.

Sincerely,N~v~Michael W. Ahern, ManagerPermit Issuance and Data Management Section, DAPC

Cc: U.S. EPA Region 5 -Via E-Mail NotificationCDAQ; Pennsylvania; Canada

50 West Town street, Suite 700P.O. Box 1049Columbus, OH 43216-1049

614 I 644 3020614 I 644 3184 (fax)www.epa.ohio.gov
http://%2Cwww.epa.ohio.gov/dapchttp://www.epa.ohio.gov/http://www.epa.ohio.gov/http://%2Cwww.epa.ohio.gov/dapc


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Ohio EnvironmentalProtection Agency Permit Strategy Write-UpCleveland Public Power - Ridge RdPermit Number: P0107767Facility 10: 1318008750

Permit Strategy Write-Up1. Check all that apply:

XSynthetic Minor Determination (to avoid PSD and NNSR)Netting Determination

2. Source Description:Municipal solid waste (MSW) is preprocessed in a Material Recovery Facility (MRF) and blended toproduce the desired characteristics (heat content, etc.) for introduction into one of the Kinsei Sangyo batchgasifiers that operate in tandem for each gasifier line. A small amount of natural gas is burned at the onsetof the batch gasification process and heat for the remainder of the process is provided from the combustionof a portion of the syngas produced. The majority of the syngas produced by the Kinsei Sangyo batchgasifiers is combusted in a furnace (refer to the Fuel Combustion EAC) to produce heat that is thenconverted to steam in the Heat Recovery Steam Generator (HRSG). There are no direct emissions fromthe operation of the batch gasifiers. The syngas produced by the Kinsei Sangyo batch gasifiers is burned inthe furnace with the hot exhaust gases routed through the HRSG and then through the air pollution controlsystem (sorbent injection, baghouse, SCR and wet-FGD) prior to discharging to the atmosphere from thestack.

3. Facility Emissions and Attainment Status:The CPP - Ridge Rd. gasifier project has a potential to emit (PTE) of 108.96 TPY of PM (filterable pluscondensable), 108.46 TPY S02, 271.74 TPY of NOx, 121.6 TPY of CO, 36.80 TPY ofVOC, 10.16 TPY ofH2S04, 0.35 TPY of Lead, and 10.28 TPY of total HAPs.Cuyahoga County is currently in non-attainment for PM2.5and partial non-attainment for lead.

4. Source Emissions:The allowable emissions are based on an annual maximum heat input of 2,045,401.6 mmBtu/yr, based ona rolling, 12-month summation, for emissions units B001-B004 combined. This is 72.24% of the combinedmaximum capacity of the 4 furnaces. Each emissions unit will be equipped with a baghouse to control PMemissions, a Selective Catalytic Reduction (SCR) system to control NOx emissions, and a Wet Flue - GasDesulfurization (FGD) scrubber system to control S02, HCI, and HF. These control measures, along withthe annual heat input restriction, are in place for the facility to avoid the PSD requirements.The allowable emissions, based on the restricted annual heat input, are the following: 78.75 TPY of PM (F+ C), 78.75 TPY of S02, 194.31 TPY of NOx , 87.95 TPY of CO, 26.59 TPY of VOC, 7.36 TPY of H2S04,0.25 TPY of Lead, and 7.32 TPY of Total HAPs.The C02e emissions from biogenic components of the facility are 112,795.84 TPY, and 92,286.77 TPYfrom non-biogenic components of the facility based on the annual heat input restriction. The PSD majorsource threshold for C02e is 100,000 tons/year. However, the CPP- Ridge Rd. gasifier project qualifies fora biogenic CO2 deferral issued by US EPA. This means that if the non-biogenic portion is less than100,000 tons/year, then the PSD requirements do not apply. Ohio EPA has determined that the current


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Ohio EnvironmentalProtection Agency Permit Strategy Write-UpCleveland Public Power - Ridge RdPermit Number: P0107767Facility 10: 1318008750

OAC rules that address greenhouse gas emissions has sufficient language to incorporate the deferral. Themajority of C02e emissions are from the CO2 portion of the total C02e.5. Conclusion:

Extensive stack testing for most of the pollutants has been required in the permit for this new source as thesource emissions are based on the manufacturer's calculation estimates. In addition, the permit requiresthe use of a continuous emission monitor (CEM) for NOx, S02, C02, and CO along with a continuousopacity monitor requirement. The use of control equipment, restricted annual heat input, and the CO2biogenic deferral will allow the facility to avoid PSD.

6. Please provide additional notes or comments as necessary:None

7. Total Permit Allowable Emissions Summary (for informational purposes only):Total TPY EmissionsPollutant 4 Gasifier/Furnance/HRSG Linesat 72.24% heat input

PM(F+C) 78.75S02 78.75NOx 194.31CO 87.95VOC 26.59H2S02 7.36

Lead (Pb) 0.25Ammonia 16.36

HCI 6.55Dioxin 1.27 E-5

Cadmium (Cd) 0.013Mercury (Hg) 0.13

HF 0.63Total HAPs 7.32

C02e Total Emissions

92,286.77tons of C02e from the biomass component of the MSW12,795.84tons of C02e from the non-biomass component of the MSW

100,000 tons/year is the major source threshold for C02e for projects in Phase 2 of US EPA'sTailoring Rule


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PUBLIC NOTICE PUBLIC HEARING11/30/2011 Issuance of Draft Air Pollution Permit-To-Install

Cleveland Public Power - Ridge Rd3727 Ridge Rd,Cleveland, OH 44413Cuyahoga CountyFACILITY DESC: Other Electric Power Generation, Solid Waste Combustors and IncineratorsPERMIT#: P0107767PERMIT TYPE: Initial InstallationPERMIT DESC: This is an initial permit for the Cleveland Public Power Ridge Road facility for new emissionunits not yet installed. The emissions units involve four municipal solid waste gasifier processing lines (B001 -B004). The gasifier lines produce a syngas which is then burned in a furnace to produce heat that is thenconverted to steam in the Heat Recovery Steam Generator. The facility has requested a Synthetic Minorrestriction on the combined annual heat input in order to avoid the PSD and NNSR permitting requirements.The emissions units will be controlled using a baghouse, selective catalytic reduction (SCR), and wet flue-gasdesulfurization scrubber system.The Director of the Ohio Environmental Protection Agency, 50 West Town Street, Columbus Ohio, issued theabove draft permit. A public hearing on this permit will be held as follows: 6 p.m. Monday, Jan. 9, 2012 atEstabrook Recreation Center, 4125 Fulton Rd, Cleveland. All interested parties may attend and comment.You may obtain the permit and complete instructions for submitting comments online athttp://epa.ohio.gov/dapc/permitsonline.aspx (enter permit number and click Go) or by contacting DavidHearne at Cleveland Division of Air Quality, 2nd Floor 75 Erieview Plaza, Cleveland, OH 44114 or (216)664-2297. All comments must be received by Jan. 13,2012.
http://epa.ohio.gov/dapc/permitsonline.aspxhttp://epa.ohio.gov/dapc/permitsonline.aspx


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Ohio EnvironmentalProtection AgencyDRAFT

Division of Air Pollution ControlPerm it-to-I nstall

forC leveland Public Power - R idge Rd

Facility 10: 1318008750Permit Number: P0107767Permit Type: Initial InstallationIssued: 11/30/2011Effective: To be entered upon final issuance


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Ohio EnvironmentalProtection AgencyDivision of Air Pollution ControlPerm it-to-Install

forCleveland Public Power - Ridge Rd

Table of ContentsAuthorization 1A. Standard Terms and Conditions 3

1. Federally Enforceable Standard Terms and Conditions 42. Severability Clause 43. General Requirements 44. Monitoring and Related Record Keeping and Reporting Requirements 55. Scheduled Maintenance/Malfunction Reporting 66. Compliance Requirements 67. Best Avai lable Tech nology 78. Air Pollution Nuisance 79. Reporting Requirements 710. Applicability 811. Construction of New Sources(s) and Authorization to Install 812. Permit-To-Operate Application 913. Construction Compliance Certification 914. Public Disclosure 915. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable EmissionLimitations, Operational Restrictions, or Control Device Operating Parameter Limitations 1016. Fees 1017. Permit Transfers 1018. Risk Management Plans 1019. Title IV Provisions 10

B. Facility-Wide Terms and Conditions 11C. Emissions Unit Terms and Conditions 18

1. Emissions Unit Group -Four Gasification Lines: B001 ,B002,B003,B004, 19


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Ohio EnvironmentalProtection Agency Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750

Effective Date:To be entered upon final issuance

AuthorizationFacility 10 : 1318008750Facility Description:Application Number(s): A0041 047, A0043120Permit Number: P0107767Permit Description: This is an initial permit for the Cleveland Public Power Ridge Road facility for new

emission units not yet installed. The emissions units involve four municipal solid wastegasifier processing lines (B001 - B004). The gasifier lines produce a syngas which isthen burned in a furnace to produce heat that is then converted to steam in the HeatRecovery Steam Generator. The facility has requested a Synthetic Minor restriction onthe combined annual heat input in order to avoid the PSD and NNSR permittingrequirements. The emissions units will be controlled using a baghouse, selectivecatalytic reduction (SCR), and wet flue-gas desulfurization scrubber system.

Initial Installation$4,000.0000 NOT send payment at this time, subject to change before final issuance11/30/2011

Permit Type:Permit Fee:Issue Date:Effective Date: To be entered upon final issuanceThis document constitutes issuance to:

Cleveland Public Power - Ridge Rd3727 Ridge RdCleveland, OH 44413

of a Permit-to-Install for the emissions unit(s) identified on the following page.

Ohio EPA District Office or local air agency responsible for processing and administering your permit:Cleveland Division of Air Quality2nd Floor75 Erieview PlazaCleveland, OH 44114(216)664-2297

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this sectionpursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constituteexpressed or implied approval or agreement that, if constructed or modified in accordance with the plansincluded in the application, the emissions unit(s) of environmental pollutants will operate in compliance withapplicable State and Federal laws and regulations, and does not constitute expressed or implied assurancethat if constructed or modified in accordance with those plans and specifications, the above describedemissions unit(s) of pollutants will be granted the necessary permits to operate (air) or NPDES permits asapplicable.This permit is granted subject to the conditions attached hereto.Ohio Environmental Protection AgencyScott J. NallyDirector

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Ohio EnvironmentalProtection Agency Oraft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility 10 : 1318008750

Effective Oate:To be entered upon final issuance

Authorization (continued)Permit Number: P0107767Permit Description: This is an initial permit for the Cleveland Public Power Ridge Road facility for new

emission units not yet installed. The emissions units involve four municipal solid wastegasifier processing lines (B001 - B004). The gasifier lines produce a syngas which isthen burned in a furnace to produce heat that is then converted to steam in the HeatRecovery Steam Generator. The facility has requested a Synthetic Minor restriction onthe combined annual heat input in order to avoid the PSD and NNSR permittingrequirements. The emissions units will be controlled using a baghouse, selectivecatalytic reduction (SCR), and wet flue-gas desulfurization scrubber system.

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

Group Name: Four Gasification LinesEmissions Unit 10 : 8001_ _ _ _ _ _ 9 _ ~ I ! l _ f ? ? _ n _ ~~ g _ u _ i p _ f ! l~ ~ !~ : < ? _ ~ ~ l f l E ? ~ ~ ~ ~ ! ~ ~ ~ E ? [ t l _ f 3 .~ < ? _' ! < ? ~ _ 1_ _ _ _ _ _ ~ _ u _ f ? E ? ! ~ ~ _ ~ E ? 9 _~ ~ I ! l _ i ! _ ~ ~ _ f ! l _ ~ E ? ~ :_ _ _ _ _ _ < ? _ ~ ~ ~ _ r 9 _ 1 _ ~ ~ r _ f ! l 1 ! ~ ? ! E ? g _ ~ I ) '~ ~ 9 I ~ f ? ~ ~ i " J _ ~ ! A f ? p ! i _ c _ ~ ~ ! ~Emissions Unit 10 : 8002_ _ _ _ _ _ 9 _ ~ I ! l J ? ? _ n x _ ~ g _ u _ i p _ f ! l~ ~ !~ : < ? _ ~ ~ l f l E ? ~ ~ ~ ~ ! ~ ~ ~ E ? [ t l _ f 3 .~ < ? _' ! < ? ~ _ ~_ _ _ _ _ _ ~ _ u _ f ? E ? ! ~ ~ _ ~ E ? 9 _~ ~ I ! l _ i ! _ ~ ~ _ f ! l _ ~ E ? ~ :_ _ _ _ _ _ < ? _ ~ ~ ~ _ r 9 _ 1 _ ~ ~ r _ f ! l 1 ! ~ ? ! E ? g _ ~ I ) '~ ~ 9 I ~ f ? ~ ~ i " J _ ~ ! A f ? p ! i _ c _ ~ ~ ! ~Emissions Unit 10 : 8003_ _ _ _ _ _ 9 _ ~ I ! l _ f ? ? _ n _ ~~ g _ u _ i p _ f ! l~ ~ !~ : < ? _ ~ ~ l f l E ? ~ ~ ~ ~ ! ~ ~ ~ E ? [ t l _ f 3 .~ < ? _' ! < ? ~ _ ~_ _ _ _ _ _ ~ _ u _ f ? E ? ! ~ ~ _ ~ E ? 9 _~ ~ I ! l _ i ! _ ~ ~ _ f ! l _ ~ E ? ~ :_ _ _ _ _ _ < ? _ ~ ~ ~ _ r 9 _ 1 _ ~ ~ r _ f ! l 1 ! ~ ? ! E ? g _ ~ I ) '~ ~ 9 I ~ p ~ ~ i " J _ ~ ! A p p ! i _ c _ ~ ~ ! ~Emissions Unit 10 : 8004_ _ _ _ _ _ 9 _ ~ I ! l _ f ? ? _ n _ ~~ g _ u _ i p _ f ! l~ ~ !~ : < ? _ ~ ~ l f l E ? ~ ~ ~ ~ ! ~ ~ ~ E ? [ t l _ f 3 .~ < ? _' ! < ? ~ _ 4 :_ _ _ _ _ _ ~ _ u _ f ? E ? ! ~ ~ _ ~ E ? 9 _~ ~ I ! l _ i ! _ ~ ~ _ f ! l _ ~ E ? ~ :General Permit CategoryandType: NotApplicable

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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767

Facility ID: 1318008750Effective Date:To be entered upon final issuance

A. Standard Terms and Conditions

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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750Effective Date:To be entered upon final issuance

1. Federally Enforceable Standard Terms and Conditions

a) All Standard Terms and Conditions are federally enforceable, with the exception of those listedbelow 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.1 0., 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 ThereAre 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 Clausea) 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 conditiondepends in whole or in part for its operation or implementation upon the term or conditiondeclared invalid.b) All terms and conditions designated in parts Band C of this permit are federally enforceable asa 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 enforceableby the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed bysection 304 of the Act) under the Act. Terms and conditions in parts Band C of this permit shallnot be federally enforceable and shall be enforceable under State law only, only if specificallyidentified in this permit as such.

3. General Requirementsa) The permittee must comply with all terms and conditions of this permit. Any noncompliance with

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

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Facility ID: 1318008750Effective Date:To be entered upon final issuanceb) 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 thefederally enforceable terms and conditions of this permit.c) This permit may be modified, revoked, or revoked and reissued, for cause. The filing of arequest 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 andcondition 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 thatmay be requested to determine whether cause exists for modifying or revoking this permit or todetermine compliance with this permit. Upon request, the permittee shall also furnish to theDirector or an authorized representative of the Director, copies of records required to be kept bythis permit. For information claimed to be confidential in the submittal to the Director, if theAdministrator of the U.S. EPA requests such information, the permittee may furnish suchrecords directly to the Administrator along with a claim of confidentiality.

4. Monitoring and Related Record Keeping and Reporting Requirementsa) 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 tothis 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 recordsand all original strip-chart recordings for continuous monitoring instrumentation, and copies of alreports 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 record keeping of federally enforceable

information shall be submitted to the Cleveland Division of Air Quality.

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Facility ID: 1318008750Effective Date:To be entered upon final issuance(2) Quarterly written reports of (i) any deviations from federally enforceable

emissionlimitations, operationalrestrictions,andcontroldeviceoperatingparameterlimitations, excluding deviations resulting frommalfunctions reported in accordance with OAC rule 3745-15-06, that have been detectedby the testing, monitoring and record keeping requirements specified in this permit, (ii)the probable cause of such deviations, and (iii) any corrective actions or preventivemeasures taken, shall be made to the Cleveland Division of Air Quality. The writtenreports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31,and October 31 of each year and shall cover the previous calendar quarters. See A.15.below if no deviations occurred during the quarter.

(3) Written reports, which identify any deviations from the federally enforceable monitoring,recordkeeping, andreportingrequirements contained in this permit shall be submitted(i.e., postmarked) to the Cleveland Division of Air Quality every six months, by January31 and July 31 of each year for the previous six calendar months. If no deviationsoccurred 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 shallbe signed by a responsible official certifying that, based on information and belief formedafter 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 purposeof collecting Air Pollution Control Fees.

5. Scheduled Maintenance/Malfunction ReportingAny scheduled maintenance of air pollution control equipment shall be performed in accordance withparagraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units or anyassociated air pollution control system(s) shall be reported to the Cleveland Division of Air Quality inaccordance with paragraph (B) of OAC rule 3745-15-06. (The definition of an upset condition shall bethe same as that used in OAC rule 3745-15-06(B)(1) for a malfunction.) The verbal and written reportsshall be submitted pursuant to OAC rule 3745-15-06.Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdownor bypassing of any air pollution control system(s) shall be accompanied by the shutdown of theemission unit(s) that is (are) served by such control system(s).

6. Compliance Requirementsa) The emissions unit(s) identified in this Permit shall remain in full compliance with all applicableState laws and regulations and the terms and conditions of this permit.b) Any document (including reports) required to be submitted and required by a federallyapplicable 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 thedocument are true, accurate, and complete.

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Facility ID: 1318008750Effective Date:To be entered upon final issuancec) 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 orthe emissions-related activity is conducted, or where records must be kept under theconditions of this permit.(2) Have access to and copy, at reasonable times, any records that must be kept under theconditions 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 thispermit.

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

d) The permittee shall submit progress reports to the Cleveland Division of Air Quality concerningany schedule of compliance for meeting an applicable requirement. Progress reports shall besubmitted semiannually or more frequently if specified in the applicable requirement or by theDirector of the Ohio EPA. Progress reports shall contain the following:(1) Dates for achieving the activities, milestones, or compliance required in any schedule ofcompliance, 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 eachsubject emissions unit.

8. Air Pollution NuisanceThe air contaminants emitted by the emissions units covered by this permit shall not cause a publicnuisance, in violation of OAC rule 3745-15-07.

9. Reporting RequirementsThe permittee shall submit required reports in the following manner:a) Reports of any required monitoring and/or recordkeeping of state-only enforceable informationshall be submitted to the Cleveland Division of Air Quality.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 emissionlimitations, operational restrictions, and control device operating parameter limitations that havePage 7 of 40


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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750Effective Date:To be entered upon final issuancebeen detected by the testing, monitoring, and recordkeeping requirements specified in thispermit, (b) the probable cause of such deviations, and (c) any corrective actions or preventivemeasures which have been or will be taken, shall be submitted to the Cleveland Division of AirQuality. If no deviations occurred during a calendar quarter, the permittee shall submit aquarterly report, which states that no deviations occurred during that quarter. The reports shallbe submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 ofeach year and shall cover the previous calendar quarters. (These quarterly reports shallexclude deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)

10. ApplicabilityThis 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 otheremissions unit(s).

11. Construction of NewSources(s) and Authorization to Installa) This permit does not constitute an assurance that the proposed source will operate incompliance 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 theapplication and terms and conditions of this permit. The action of beginning and/or completingconstruction 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 proposedsource will operate in compliance with all Ohio laws and regulations. Issuance of this permit isnot to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (orother persons) may have against the applicant for starting construction prior to the effective dateof the permit. Additional facilities shall be installed upon orders of the Ohio EnvironmentalProtection Agency if the proposed facilities cannot meet the requirements of this permit orcannot meet applicable standards.

b) If applicable, authorization to install any new emissions unit included in this permit shallterminate within eighteen months of the effective date of the permit if the owner or operator hasnot undertaken a continuing program of installation or has not entered into a binding contractualobligation to undertake and complete within a reasonable time a continuing program ofinstallation. This deadline may be extended by up to 12 months if application is made to theDirector within a reasonable time before the termination date and the party shows good causefor 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 waythat it can no longer operate without a subsequent "modification" or "installation" as defined inOAC Chapter 3745-31) by submitting a certification from the authorized official that identifies thedate on which the emissions unit was permanently shut down. Authorization to operate theaffected emissions unit shall cease upon the date certified by the authorized official that theemissions unit was permanently shut down. At a minimum, notification of permanent shut downshall be made or confirmed by marking the affected emissions unit(s) as "permanently shutdown" in Ohio EPA's "Air Services" along with the date the emissions unit(s) was permanentlyremoved and/or disabled. Submitting the facility profile update will constitute notifying of thepermanent shutdown of the affected emissions unit(s).

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d) The provisions of this permit shall cease to be enforceable for each affected emissions unit afterthe date on which an emissions unit is permanently shut down (i.e., emissions unit has beenphysically removed from service or has been altered in such a way that it can no longer operatewithout a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31). Allrecords relating to any permanently shutdown emissions unit, generated while the emissionsunit was in operation, must be maintained in accordance with law. All reports required by thispermit must be submitted for any period an affected emissions unit operated prior to permanentshut down. At a minimum, the permit requirements must be evaluated as part of the reportingrequirements identified in this permit covering the last period the emissions unit operated.No emissions unit certified by the authorized official as being permanently shut down mayresume operation without first applying for and obtaining a permit pursuant to OAC Chapter3745-31.

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

12. Permit-lo-Operate ApplicationThe permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77. Thepermittee shall submit a complete Title V permit application or a complete Title V permit modificationapplication within twelve (12) months after commencing operation of the emissions units covered bythis permit. However, if the proposed new or modified source(s) would be prohibited by the terms andconditions of an existing Title V permit, a Title V permit modification must be obtained before theoperation of such new or modified source(s) pursuant to OAC rule 3745-77-04(0) and OAC rule 3745-77-08(C)(3)(d).

13. Construction Compliance CertificationThe applicant shall identify the following dates in the online facility profile for each new emissions unitidentified 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 thispermitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03.

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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750Effective Date:To be entered upon final issuance15. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable

Emission Limitations, Operational Restrictions, or Control Device Operating ParameterLimitationsIf no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, whichstates that no deviations occurred during that quarter. The reports shall be submitted quarterly (i.e.,postmarked), by January 31, April 30, July 31, and October 31 of each year and shall cover theprevious calendar quarters.

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

17. Permit TransfersAny transferee of this permit shall assume the responsibilities of the prior permit holder. The newowner must update and submit the ownership information via the "Owner/Contact Change" functionalityin Air Services once the transfer is legally completed.The change must be submitted through AirServices within thirty days of the ownership transfer date.

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

19. Title IV ProvisionsIf the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permitteeshall ensure that any affected emissions unit complies with those requirements. Emissions exceedingany 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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Facility ID: 1318008750Effective Date:To be entered upon final issuance1. All the following facility-wide terms and conditions are federally enforceable with the exception of those

listed below which are enforceable under state law only:a) None.

2. The emissions units contained in this permit are subject to 40 CFR Part 60, Subpart AAAA, Standardsof Performance for Small Municipal Waste Combustion Units for Which Construction is CommencedAfter August 30, 1999 or for Which Modification or Reconstruction is Commenced After June 6,2001.The complete NSPS requirements from Subpart AAAA, including the Subpart A GeneralProvisions, may be accessed via the internet from the Electronic Code of Federal Regulations (e-CFR)website at http://ecfr.gpoaccess.gov or by contacting the Cleveland Division of Air Quality (ClevelandOAQ).The permittee must comply with all applicable requirements of 40 CFR Part 60, Subpart AAAA. Thepermittee shall also comply with all applicable requirements of 40 CFR Part 60, Subpart A, GeneralProvisions. Compliance with all applicable requirements shall be achieved by the dates set forth in 40CFR Part 60, Subpart AAAA, and Subpart A.

a) 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 emissionslimitations and/or control measures are identified below. Emissions from each unit shallnot exceed the listed limitations, and the listed control measures shall be specified innarrative form following the table.

Applicable Emissions Limitations/ControlMeasures

Applicable Rules/Requirementsa. OAC rule 3745-31-05(0) See a)(2), b), c), d) and e).b. 40 CFR Part 51, Subpart I (40 CFR See a)(2) and f)(1).

51.166)[In accordance with 40 CFR 51.166,for the purposes of this paragraph(b)(48)(ii)(a), prior to July 21, 2014,the mass of greenhouse gas carbondioxide shall not include carbondioxide emissions resulting from thecombustion or decomposition of non-fossilized and biodegradable organicmaterial originating form plants,animals, or micro-organisms(including products, by-products,residues and waste from agriculture,forestry and related industries aswell as the non-fossilized andbiodegradable organic fractions ofindustrial and municipal wastes,including gases and liquids

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http://ecfr.gpoaccess.gov/http://ecfr.gpoaccess.gov/


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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750Effective Date:To be entered upon final issuanceApplicable Rules/Requirements Applicable Emissions Limitations/Control

Measuresrecovered from the decomposition ofnon-fossilized and biodegradableorganic materiaL]

c. 40 CFR Part 98, Subpart C See d)(2).

(2) Additional Terms and Conditionsa. The total, combined mass emissions from emissions units as a 12-month rollingsummation for the facility, including B001-B004, and any de minimis, exempt or

insignificant emissions units shall not exceed the following:PM (F+C) 78.75 tons/year (tpy) (F+C = filterable plus condensable)S02 78.75 tpyNOx 194.31 tpyCO 87.95 tpyVOC 26.59 tpyLead 0.25 tpyHCI 6.55 tpyDioxin 1.27E-05 tpyCd 0.013 tpyHg 0.13 tpyHF 0.63 tpyCOl EmissionsCO2 112,750.21 tpy - BiogenicCO2 92,250.17 tpy - non-BiogenicTotal COle EmissionsC02e 112,795.84 tpy - BiogenicC02e 92,286.77 tpy - non-Biogenic

b. The total facility-wide mass emissions shall not exceed the following tons peryear, based upon a rolling, 12 month summation of the monthly emissions. Toensure enforceability during the first 12 calendar months of operation or the first12 calendar months following the issuance of this permit, the permittee shall notexceed the emission levels specified in the following table:

Maximum Allowable Cumulative Emissions of the following pollutants (Tons)

Month(s) PM 502 NOx CO VOC Lead HCI CO2 CO2(filterable + Biogenic Non-condensable

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Facility ID: 1318008750Effective Date:To be entered upon final issuance) Biogenic

1 10.0 10.0 25.0 12.0 3.4 0.025 0.8 12,000 5,000

1 - 2 20.0 20.0 50.0 24.0 6.8 0.050 1.6 24,000 19,0001 - 3 30.0 30.0 75.0 36.0 10.2 0.075 2.4 36,000 28,500

1 - 4 40.0 40.0 100.0 48.0 13.6 0.10 3.2 48,000 38,000

1 - 5 50.0 50.0 125.0 60.0 17.0 0.125 4.0 60,000 47,500

1 - 6 60.0 60.0 150.0 72.0 20.4 0.150 4.8 72,000 57,000

1 - 7 70.0 70.0 175.0 84.0 23.8 0.175 5.6 84,000 66,500

1 - 8 78.75 78.75 194.31 87.95 26.59 0.25 6.55 112,750.21 92,250.17

1 - 9 78.75 78.75 194.31 87.95 26.59 0.25 6.55 112,750.21 92,250.171 - 1 0 78.75 78.75 194.31 87.95 26.59 0.25 6.55 112,750.21 92,250.17

1 - 1 1 78.75 78.75 194.31 87.95 26.59 0.25 6.55 112,750.21 92,250.17

1 - 1 2 78.75 78.75 194.31 87.95 26.59 0.25 6.55 112,750.21 92,250.17

b) Operational Restrictions(1) The total combined heat input to emission units B001, B002, B003, and B004 shall not

exceed 2,045,401.6 million Btu (mmBtu) as a rolling, 12-month summation.To ensure enforceability during the first 12 calendar months of operation the permitteeshall not exceed the mmBtu limitation specified in the following table:Month(s) Maximum allowable combined

heat input (mmBtu)

1 260,000

1 - 2 520,000

1 - 3 780,000

1 - 4 1,040,0001 - 5 1,300,000

1 - 6 1,560,000

1 - 7 1,820,000

1 - 8 2,045,401.6

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Facility ID: 1318008750Effective Date:To be entered upon final issuance1-9 2,045,401.61-10 2,045,401.61-11 2,045,401.61-12 2,045,401.6

After the first 12 calendar months of operation or the first 12 calendar months followingthe issuance of this permit, compliance with the annual combined heat input limitationshall be based upon a rolling, 12-month summation of the combined heat input.

c) Monitoring and/or Recordkeeping Requirements(1) The permittee shall collect a representative grab sample of the syngas that is burned inemissions units B001 - B004 for each day when the emissions unit is in operation. I

natural gas is used on a day when the emissions unit is in operation, the permittee shallrecord the heat content of the natural gas as provided by the supplier. The permitteeshall maintain records of the total quantity of both natural gas and syngas burned eachday, the permittee's analyses for heat content of the syngas, and the heat content of thenatural gas (in Btu/cf). The total combined heat input (in MMBtu/day) shall be calculatedbased on the total amount of each fuel burned per day (cf/day) and the correspondingheat content of each fuel.The permittee shall perform or have a certified lab perform the analyses for the heatcontent of the syngas in accordance with federal reference methods, the appropriateASTM methods if available, or equivalent methods as approved by the Cleveland DAQ.

(2) The permittee shall maintain monthly records of the heat input to emission units B001,B002, B003, and B004 determined by summing the daily heat input determined fromc)(1) above; and, beginning after the first 12 calendar months of operation or the first 12calendar months following the issuance of this permit, the rolling, 12-month summationof the combined heat input.Also, during the first 12 calendar months of operation or the first 12 calendar monthsfollowing the issuance of this permit, the permittee shall record the cumulative combinedheat input for each calendar month.

d) Reporting Requirements(1) The permittee shall submit quarterly deviation reports to the Cleveland DAQ

documenting all exceedances of the rolling, 12-month annual combined heat input of2,045,401.6 mmBtu for emissions units B001, B002, B003 and B004; and for the first 12calendar months of operation or the first 12 calendar months following the issuance ofthis permit, all exceedances of the maximum allowable cumulative combined heat inputlevels.

(2) See 40 CFR Part 98, Subpart C (40 CFR 98.30 - 98.38 and Tables C-1 through C-2)

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Facility ID: 1318008750Effective Date:To be entered upon final issuancee) Testing Requirements

(1) Compliance with the Emissions Limitations and/or Control Requirements specified insection b) of these terms and conditions shall be determined in accordance with thefollowing methods:a. Emission Limitations:Facility wide emissions, as a 12-month rolling summation, shall not exceed anyof the following:

PM (F+C) 78.75 tons/year (tpy) (F+C = filterable plus condensable)S02 78.75 tpyNOx 194.31 tpyCO 87.95 tpyVOC 26.59 tpyLead 0.25 tpyHCI 6.55 tpyDioxin 1.27 E-05 tpyCd 0.013 tpyHg 0.13 tpyHF 0.63 tpyCOl EmissionsCO2 112,750.21 tpy - BiogenicCO2 92,250.17 tpy - non-BiogenicTotal COle EmissionsC02e 112,795.84 tpy - BiogenicC02e 92,286.77 tpy - non-BiogenicApplicable Compliance Method:The permittee shall calculate the facility-wide emissions for each pollutant listedabove on a monthly basis.i. The emissions may be determined, for both natural gas and syngas

combustion, using one or more of the following with the approval of theCleveland DAQ:(a) USEPA's Compilation of Air Pollution Emission Factors, AP-42,

Fifth Edition or the most recent edition of AP-42;(b) stack test emission data;(c) CEM data;(d) material balance calculations; or(e) other Agency-approved emission factors.

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The permittee shall calculate the rolling, twelve-month emissions as the sum ofthe emissions from the current calendar month and the previous 11 calendarmonths.

f) Miscellaneous Requirements(1) As stated in the Federal Registerl Vol. 76, No. 139 1 Wednesday, July 20, 20111 Rulesand Regulations, the US EPA deferral for CO2 Emissions From Bioenergy and OtherBiogenic Sources Under the Prevention of Significant Deterioration (PSD) and Title V

Programs has an effective date of July 20,2011. The CO2 deferral affects 40 CFR Parts51, 52, 70, and 71. The emissions units in this permit are considered affected entities aslisted in Table 1 of the above mentioned Federal Register (Solid waste combustors andincinerators ).As stated in the Summary of Final Action:"This action defers for a period of three (3) years the consideration of CO2 emissionsfrom bioenergy and other biogenic sources (hereinafter referred to as "biogenic CO2emissions") when determining whether a stationary source meets the PSD and Title Vapplicability thresholds, including those for the application of BACT. Stationary sourcesthat combust biomass (or otherwise emit biogenic CO2 emissions) and construct ormodify during the deferral period will avoid the application of PSD to the biogenic CO2emissions resulting from those actions. This deferral applies only to biogenic CO2emissions and does not affect non-GHG pollutants or other GHGs (e.g., methane (CH4)and nitrous oxide (N20)) emitted from the combustion of biomass fuel.Also, this deferral only pertains to biogenic CO2 emissions in the PSD and Title Vprogram and does not pertain to any other EPA programs such as the GHG ReportingProgram."

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C. Emissions Unit Terms and Conditions

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1. Emissions Unit Group -Four Gasification Lines: 8001,8002,8003,8004,EUIDB001

B002

B003

B004

, Operations, Property and/or Equipment DescriptionMSW Gasifier Line No.1 - Processing line using Kinsei Sangyo or comparable technologythat includes two batch gasifiers, a furnace, a Heat Recovery Steam Generator (HRSG)and air pollution control equipment including a baghouse, Selective Catalytic Reduction(SCR) system, and Wet Flue-Gas Desulfurization (FGD) scrubber system.MSW Gasifier Line No.2 - Processing line using Kinsei Sangyo or comparable technologythat includes two batch gasifiers, a furnace, a Heat Recovery Steam Generator (HRSG)and air pollution control equipment including a baghouse, Selective Catalytic Reduction

, (SCR) system, and Wet Flue-Gas Desulfurization (FGD) scrubber system.MSW Gasifier Line No.3 - Processing line using Kinsei Sangyo or comparable technologythat includes two batch gasifiers, a furnace, a Heat Recovery Steam Generator (HRSG)and air pollution control equipment including a baghouse, Selective Catalytic Reduction

, (SCR) system, and Wet Flue-Gas Desulfurization (FGD) scrubber system.MSW Gasifier Line No.4 - Processing line using Kinsei Sangyo or comparable technologythat includes two batch gasifiers, a furnace, a Heat Recovery Steam Generator (HRSG)and air pollution control equipment including a baghouse, Selective Catalytic Reduction, (SCR) system, and Wet Flue-Gas Desulfurization (FGD) scrubber system.

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

b) Applicable Emissions Limitations and/or Control Requirements(1) d)(1 0) through d)(13) and e )(7)

(1) The specific operation(s), property, and/or equipment that constitute each emissions unitalong with the applicable rules and/or requirements and with the applicable emissionslimitations and/or control measures are identified below. Emissions from each unit shallnot exceed the listed limitations, and the listed control measures shall be specified innarrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/ControlMeasuresa. ORC 3704.03(T) Stack Emissions:

(BAT for emissions greater than orequal to 10 TPY) Particulate emissions (PM) shall notexceed 20 rnq/rn", (filterable pluscondensable)Sulfur Dioxide (S02) emissions shall notexceed 19.5 ppm.Nitrogen Oxides (NOx ) emissions shallnot exceed 68 ppm.

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Applicable Rules/Requirements Applicable Emissions Limitations/ControlMeasuresCarbon Monoxide (CO) emissions shallnot exceed 50 ppm.Carbon Dioxide (C02) emissions shall notexceed 140.04 g/m3.Volatile organicemissions shallIb/mmBtu.

compoundnot exceed

(VOC)0.026

b. OAC rule 3745-31-05(A)(3),effective 11/30/01

as Lead (Pb) emissions shall not exceed0.14 rnq/rn",See b)(2)i - j.

c. OAC rule 3745-31-05(A)(a)(ii), as See b)(2)j.effective 12/1/2006d. OAC rule 3745-31-05(F) Hydrogen Chloride (HCI) emissions shallnot exceed 2.9 ppm.

e.

f.

OAC rule 3745-17-07(A)

OAC rule 3745-17-07(B)

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Cadmium (Cd) emissions shall notexceed 0.01 rnq/rn",Mercury (Hg) emissions shall not exceed0.05 rnq/rn",Hydrofluoric Acid (HF) emissions shall notexceed 0.5 ppm.Lead (Pb) emissions shall not exceed0.14 rnq/rn",The visible particulate emission limitationrequired by this applicable rule is lessstringent than the visible particulateemissions limitation established pursuantto 40 CFR Part 60, Subpart AAAA.The visible emission limitation for fugitivedust required by this applicable rule isless stringent than the visible emissionlimitation for fugitive dust establishedpursuant to 40 CFR Part 60, SubpartAAAA.


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g ..

h.

Applicable Rules/RequirementsOAC rule 3745-17-10(B)

OAC rule 3745-18-06

Applicable Emissions Limitations/ControlMeasuresThe emission limitation required by thisapplicable rule is less stringent than theemissions limitation established pursuantto ORC 3704.03(T) or 40 CFR Part 60,Subpart AAAA.The emission limitation required by thisapplicable rule is less stringent than theemission limitation established pursuantto ORC 3704.03(T) or 40 CFR Part 60,Subpart AAAA.

i.j.

OAC rule 3745-114-01NSPS, 40 CFR Part 60, SubpartAAAA (40 CFR 60.1000 - 60.1465)[In accordance with 40 CFR60.1045, this emissions unit is aClass I unit. Class I units are smallmunicipal waste combustion unitsthat are located at municipal wastecombustion plants with an aggregateplant combustion capacity great than250 tons per day of municipal waste.See definitions in 60.1465.]

(2) Additional Terms and Conditions

See d)(10) - d)(13) and e)(7) below.The emission limitations specified in thisrule are equivalent to or less stringentthan the emission limitations establishedpursuant to OAC rule 3745-31-05(F) andORC 3704.03(T).The visible particulate emissions from anystack serving this emissions unit shall notexceed 10% opacity as a six-minuteaverage.Dioxin emissions shall not exceed 1.30E-05 rnq/rn" (i.e., 13 nanoqrarns/m"),The visible emissions of fugitive ash shallnot exceed 5% of an hourly observationperiod (i.e., there shall be visibleemissions for no more than 3 minutes inany 60-minute observation period).

a. See 40 CFR Part 60, Subpart AAAA (40 CFR 60.1000 - 1465 and Tables 1through 5)

b. The emissions from emissions units B001-B004 shall be vented to a baghousewhen one or more of the emissions units are in operation.

c. The emissions from emissions units B001-B004 shall be vented to a wet FGDscrubber when one or more of the emissions units are in operation.

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Facility ID: 1318008750Effective Date:To be entered upon final issuanced. The emissions from emissions units B001-B004 shall be vented to a Selective

Catalytic Reduction (SCR) system when one or more of the emissions units arein operation.e. Each continuous opacity monitoring system shall be certified to meet therequirements of 40 CFR Part 60, Appendix B, Performance Specification 1. At

least 45 days before commencing certification testing of the continuous opacitymonitoring system(s), the permittee shall develop and maintain a written qualityassurance/quality control plan designed to ensure continuous valid andrepresentative readings of opacity and compliance with PerformanceSpecification 1. The plan shall include, at a minimum, procedures for conductingand recording daily automatic zero/span checks, provisions for conducting aquarterly audit of the continuous opacity monitoring system, and a description ofpreventive maintenance activities. The plan shall describe step by stepprocedures for ensuring that Performance Specification 1 is maintained on acontinuous basis. The quality assurance/quality control plan and a logbookdedicated to the continuous opacity monitoring system must be kept on site andavailable for inspection during regular office hours.

f. The continuous opacity monitoring system consists of all the equipment used toacquire data and record opacity.

g. Each continuous S02, NOx, CO and CO2 monitoring system shall be certified tomeet the requirements of 40 CFR Part 60, Appendix B, PerformanceSpecification 2, 3, 4 or 4a as appropriate. At least 45 days before commencingcertification testing of the continuous S02, NOx, CO and CO2 monitoringsystem(s), the permittee shall develop and maintain a written qualityassurance/quality control plan designed to ensure continuous valid andrepresentative readings of S02, NOx, CO and CO2 emissions from thecontinuous monitor(s), in units of the applicable standard(s). The plan shallfollow the requirements of 40 CFR Part 60, Appendix F. The qualityassurance/quality control plan and a logbook dedicated to the continuous S02,NOx, CO and CO2 monitoring system must be kept on site and available forinspection during regular office hours.The plan shall include the requirement to conduct quarterly cylinder gas audits orrelative accuracy audits as required in 40 CFR Part 60; and to conduct relativeaccuracy test audits in units of the standard(s), in accordance with and at thefrequencies required per 40 CFR Part 60.

h. The continuous emission monitoring system consists of all the equipment used toacquire data to provide a record of emissions and includes the sample extractionand transport hardware, sample conditioning hardware, analyzers, and datarecording/processing hardware and software.i. The permittee has satisfied the Best Available Tehnology (BAT) requirementspursuant to OAC paragraph 3745-31-05(A)(3), as effective November 30,2001,

in this permit. On December 1, 2006, paragraph (A)(3) of OAC rule 3745-31-05was revised to conform to ORC changes effective August 3, 2006 (S.B. 265changes), such that BAT is no longer required by State regulations for NAAQS

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Facility ID: 1318008750Effective Date:To be entered upon final issuancepollutant less than ten tons per year. However, that rule revision has not yet beenapproved by U.S. EPA as a revision to Ohio's State Implementation Plan (SIP).Therefore, when the SIP revision occurs and the U.S. EPA approves therevisions to OAC rule 3745-31-05, these emission limits/control measures nolonger apply.

j. This rule paragraph applies once U.S. EPA approves the December 1, 2006version of OAC rule 3745-31-05 as part of the State Implementation Plan.The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the Lead (Pb) emissions from this air contaminantsource since the uncontrolled potential to emit for Lead (Pb) emissions is lessthan 10 tons per year.

c) Operational Restrictions(1) See 40 CFR Part 60, Subpart AAAA (40 CFR 60.1000 - 60.1465 and tables 1 through5)(2) Natural gas shall be used as fuel for startup purposes only.(3) The baghouse inlet temperature shall not exceed 17 degrees Celsius above the

maximum demonstrated temperature of the baghouse as 4-hour block average (referto 40 CFR 60.1200 and 60.1465).d) Monitoring and/or Recordkeeping Requirements

(1) See 40 CFR Part 60, Subpart AAAA (40 CFR 60.1000 - 60.1465 and Tables 1 through5)

(2) Prior to the installation of the continuous opacity monitoring system, the permittee shallsubmit information detailing the proposed location of the sampling site in accordancewith the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification1. The Ohio EPA, Central Office shall approve the proposed sampling site and certifythat the continuous opacity monitoring system meets the requirements of PerformanceSpecification 1. Once received, the letter/document of certification shall be maintainedon-site and shall be made available to the Cleveland Division of Air Quality (ClevelandDAQ) upon request.Each continuous monitoring system consists of all the equipment used to acquire andrecord data in units of all applicable standard(s), and includes the sample extraction andtransport hardware, sample conditioning hardware, analyzers, and data processinghardware and software.

(3) Prior to the installation of the continuous S02, NOx , CO and CO2 monitoring system, thepermittee shall submit information detailing the proposed location of the sampling site inaccordance with the siting requirements in 40 CFR Part 60, Appendix B, PerformanceSpecification 2, 3, 4 or 4a, as appropriate. The Ohio EPA, Central Office shall approvethe proposed sampling site and certify that the continuous S02, NOx , CO and CO2monitoring system meets the requirements of Performance Specification 2, 3, 4 or 4a, as

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Facility ID: 1318008750Effective Date:To be entered upon final issuanceappropriate. Once received, the letter/document of certification shall be maintained on-site and shall be made available to the Cleveland DAQ upon request.Each continuous monitoring system consists of all the equipment used to acquire andrecord data in units of all applicable standard(s), and includes the sample extraction andtransport hardware, sample conditioning hardware, analyzers, and data processinghardware and software.

(4) The permittee shall install, operate, and maintain a continuous opacity monitoringsystem to continuously monitor and record the opacity of the particulate emissions fromthis emissions unit. The continuous opacity monitoring and recording equipment shallcomply with the requirements specified in 40 CFR Part 60.The permittee shall maintain records of data obtained by the continuous opacitymonitoring system including, but not limited to:a. percent opacity on a one-minute block average basis (i.e., there are 60 discreteone-minute block averages each hour) and 6-minute block average basis (i.e.there are ten discrete 6-minute block averages each hour);b. results of daily zero/span calibration checks and the magnitude of manual

calibration adjustments;c. hours of operation of the emissions unit, continuous opacity monitoring system,

and control equipment;d. the date, time, and hours of operation of the emissions unit without the control

equipment and/or the continuous opacity monitoring system;e. the date, time, and hours of operation of the emissions unit during anymalfunction of the control equipment and/or the continuous opacity monitoringsystem; as well as,f. the reason (if known) and the corrective actions taken (if any) for each suchevent in (d) and (e).

(5) The permittee shall properly install, operate, and maintain equipment to continuouslymonitor the pressure drop, in inches of water, across the baghouse when the controlledemissions unit(s) is/are in operation, including periods of startup and shutdown. Thepermittee shall record the pressure drop across the baghouse on a once per shift basis.The monitoring equipment shall be installed, calibrated, operated, and maintained inaccordance with the manufacturer's recommendations, instructions, and operatingmanual(s), with any modifications deemed necessary by the permittee. The acceptablepressure drop shall be based upon the manufacturer's specifications until such time asany required performance testing is conducted and the appropriate range is establishedto demonstrate compliance.Whenever the monitored value for the pressure drop deviates from the limit or rangeestablished in accordance with this permit, the permittee shall promptly investigate the

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Facility ID: 1318008750Effective Date:To be entered upon final issuancecause of the deviation. The permittee shall maintain records of the following informationfor each investigation:a. the date and time the deviation began;b. the magnitude of the deviation at that time;c. the date the investigation was conducted;d. the name(s) of the personnel who conducted the investigation; ande. the findings and recommendations.In response to each required investigation to determine the cause of a deviation, thepermittee shall take prompt corrective action to bring the operation of the controlequipment within the acceptable range specified in this permit, unless the permitteedetermines that corrective action is not necessary and documents the reasons for thatdetermination and the date and time the deviation ended. The permittee shall maintainrecords of the following information for each corrective action taken:a. a description of the corrective action;b. the dates the corrective action was begun and completed;c. the date and time the deviation ended;d. the total period of time (in minutes) during which there was a deviation;e. the pressure drop readings immediately after the corrective action was

implemented; andf. the name(s) of the personnel who performed the work.Investigation and records required by this paragraph do not eliminate the need to complywith the requirements of OAC rule 3745-15-06 if it is determined that a malfunction hasoccurred.The range or limit on the pressure drop across the baghouse is effective for the durationof this permit, unless revisions are requested by the permittee and approved in writing bythe Cleveland DAQ. The permittee may request revisions to the permitted limit or rangefor pressure drop based upon information obtained during future testing thatdemonstrate compliance with the allowable particulate emission rate for the controlledemissions unit(s). In addition, approved revisions to the range or limit will not constitute arelaxation of the monitoring requirements of this permit and may be incorporated into thispermit by means of an administrative modification.

(6) The permittee shall properly install, operate, and maintain equipment to continuouslymonitor the pressure drop across the scrubber (in pounds per square inch, gauge), thescrubber liquid flow rate (in gallons per minute), and the scrubber liquid pH duringoperation of this emissions unit, including periods of startup and shutdown. Thepermittee shall record the pressure drop across the scrubber and the scrubber liquid's

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Facility ID: 1318008750Effective Date:To be entered upon final issuancepH and flow rate on a once per shift basis. The monitoring equipment shall be installed,calibrated, operated, and maintained in accordance with the manufacturer'srecommendations, instructions, and operating manual(s), with any modifications deemednecessary by the permittee. The acceptable pressure drop, liquid flow rate, and theliquid pH shall be based upon the manufacturer's specifications until such time as anyrequired performance testing is conducted and the appropriate range for each parameteris established to demonstrate compliance.Whenever the monitored value for any parameter deviates from the range(s) or minimumlimit(s) established in accordance with this permit, the permittee shall promptlyinvestigate the cause of the deviation. The permittee shall maintain records of thefollowing information for each investigation:a. the date and time the deviation began;b. the magnitude of the deviation at that time;c. the date the investigation was conducted;d. the name(s) of the personnel who conducted the investigation; ande. the findings and recommendations.In response to each required investigation to determine the cause of a deviation, thepermittee shall take prompt corrective action to bring the control equipment parameterswithin the acceptable range(s), or at or above the minimum limit(s) specified in thispermit, unless the permittee determines that corrective action is not necessary anddocuments the reasons for that determination and the date and time the deviationended. The permittee shall maintain records of the following information for eachcorrective action taken:a. a description of the corrective action;b. the dates the corrective action was begun and completed;c. the date and time the deviation ended;d. the total period of time (in minutes) during which there was a deviation;e. the pressure drop, flow rate, and pH readings immediately after the corrective

action was implemented; andf. the name(s) of the personnel who performed the work.Investigation and records required by this paragraph do not eliminate the need to complywith the requirements of OAC rule 3745-15-06 if it is determined that a malfunction hasoccurred.These range(s) and/or limit(s) for the pressure drop, liquid flow rate, and pH are effectivefor the duration of this permit, unless revisions are requested by the permittee andapproved in writing by the Cleveland DAQ. The permittee may request revisions to the

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Facility ID: 1318008750Effective Date:To be entered upon final issuancepermitted range or limit for the pressure drop, liquid flow rate, or pH based uponinformation obtained during future performance tests that demonstrate compliance withthe allowable S02, Hydrogen Flouride (HF) and Hydrochloric Acid (HCI) emission rate forthis/these emissions unit(s). In addition, approved revisions to the range or limit will notconstitute a relaxation of the monitoring requirements of this permit and may beincorporated into this permit by means of an administrative modification.

(7) The permittee shall properly install, operate, and maintain equipment to continuouslymonitor the ammonia solution injection rate (in kg/hr) and the inlet gas flow rate into theSCR System, when the emissions unit is in operation, including periods of startup andshutdown. The ammonia injection rate and inlet gas flow rate shall be recorded on aonce per shift basis. The monitoring equipment shall be installed, calibrated, operated,and maintained in accordance with the manufacturer's recommendations, instructions,and operating manual(s), with any modifications deemed necessary by the permittee.The acceptable ammonia injection rate and inlet gas flow rate shall be based upon themanufacturer's specifications until such time as any required performance testing isconducted and the appropriate range is established to demonstrate compliance.Whenever the monitored value for any parameter deviates from the range(s) or minimumlimit(s) established in accordance with this permit, the permittee shall promptlyinvestigate the cause of the deviation. The permittee shall maintain records of thefollowing information for each investigation:a. the date and time the deviation began;b. the magnitude of the deviation at that time;c. the date the investigation was conducted;d. the name(s) of the personnel who conducted the investigation; ande. the findings and recommendations.In response to each required investigation to determine the cause of a deviation, thepermittee shall take prompt corrective action to bring the control equipment parameterswithin the acceptable range(s), or at or above the minimum limit(s) specified in thispermit, unless the permittee determines that corrective action is not necessary anddocuments the reasons for that determination and the date and time the deviationended. The permittee shall maintain records of the following information for eachcorrective action taken:a. a description of the corrective action;b. the dates the corrective action was begun and completed;c. the date and time the deviation ended;d. the total period of time (in minutes) during which there was a deviation;

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Facility ID: 1318008750Effective Date:To be entered upon final issuancee. the ammonia injection rate and inlet gas flow rate immediately after the corrective

action was implemented; andf. the name(s) of the personnel who performed the work.Investigation and records required by this paragraph do not eliminate the need to complywith the requirements of OAC rule 3745-15-06 if it is determined that a malfunction hasoccurred.These range(s) and/or limit(s) for the ammonia injection rate and the inlet gas flow rateto the SCR are effective for the duration of this permit, unless revisions are requested bythe permittee and approved in writing by the Cleveland DAQ. The permittee mayrequest revisions to the permitted range or limit for the ammonia injection rate and inletgas flow rate based upon information obtained during future performance tests thatdemonstrate compliance with the allowable NOx emission rate for this/these emissionsunit(s). In addition, approved revisions to the range or limit will not constitute arelaxation of the monitoring requirements of this permit and may be incorporated into thispermit by means of an administrative modification.

(8) The permittee shall install, operate and maintain equipment to continuously monitor andrecord S02, NOx , CO2, and CO emissions from this emissions unit in units of theapplicable standard(s). The continuous monitoring and recording equipment shallcomply with the requirements specified in 40 CFR Part 60.The permittee shall maintain records of data obtained by the continuous emissionmonitoring system including, but not limited to:a. emissions of S02, NOx , and CO in parts per million for each cycle time of the

analyzer, with no resolution less than one data point per minute required;b. emissions of S02, NOx , CO2 and CO in all units of the applicable emission limit(s)in the appropriate averaging period;c. results of quarterly cylinder gas audits;d. results of daily zero/span calibration checks and the magnitude of manual

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

applicable emission limit;f. hours of operation of the emissions unit, each continuous monitoring system, andcontrol equipment;g. the date, time, and hours of operation of the emissions unit without the controlequipment and/or each continuous monitoring system;h. the date, time, and hours of operation of the emissions unit during any

malfunction of the control equipment and/or each continuous monitoring system;and

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Facility ID: 1318008750Effective Date:To be entered upon final issuancei. the reason (if known) and the corrective actions taken (if any) for each such

event in (g) and (h).All valid data points generated and recorded by the continuous emission monitoring anddata acquisition and handling systems shall be used in the calculation of the pollutantconcentration and/or emission rate over the appropriate averaging period.

(9) The permittee shall maintain monthly records of the time periods when natural gas isburned in this emissions unit for startup purposes along with the amount of natural gasburned during each startup event.

(10) The permit-to-install (PTI) application for emissions units B001, B002, B003, and B004was evaluated based on the actual materials and the design parameters of theemissions unit's(s') exhaust system, as specified by the permittee. The "Toxic AirContaminant Statute", ORC 3704.03(F), was applied to these emissions units for eachtoxic air contaminant listed in OAC rule 3745-114-01, using data from the permitapplication; and modeling was performed for each toxic air contaminants emitted at overone ton per year using an air dispersion model such as SCREEN3 or AERMOD. Thepredicted 1-hour maximum ground-level concentration results from the approved airdispersion model, was compared to the Maximum Acceptable Ground-LevelConcentration (MAGLC), calculated as described in the Ohio EPA guidance documententitled: Review of New Sources of Air Toxic Emissions, Option A, as follows:a. the exposure limit, expressed as a time-weighted average concentration for a

conventional 8-hour workday and a 40-hour work week, for each toxiccompound(s) emitted from the emission unit(s), (as determined from the rawmaterials processed and/or coatings or other materials applied) has beendocumented from one of the following sources and in the following order ofpreference (TLV was and shall be used, if the chemical is listed):i. threshold limit value (TLV) from the American Conference of

Governmental Industrial Hygienists (ACGIH) "Threshold Limit Value forChemical Substances and Physical Agents Biological Exposure Indices";or

ii. STEL (short term exposure limit) or the ceiling value from the AmericanConference of Governmental Industrial Hygienists (ACGIH) "ThresholdLimit Values for Chemical Substance and Physical Agents BiologicalExposure Indices"; the STEL or ceiling value is multiplied by 0.737 toconvert the 15-minute exposure limit to an equivalent 8-hour TLV.

b. The TLV is divided by ten to adjust the standard from the working population tothe general public (TLV/10).

c. This standard is/was then adjusted to account for the duration of the exposure orthe operating hours of the emissions unit(s), i.e., "X" hours per day and "Y" daysper week, from that of 8 hours per day and 5 days per week. The resultingcalculation was (and shall be) used to dermine the Maximum AcceptableGround-Level Concentration (MAGLC):

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Facility ID: 1318008750Effective Date:To be entered upon final issuanceTLV/10 x 8/X x 5N = 4 TLV/XY = MAGLC

d. The following summarizes the results of dispersion modeling for the significanttoxic contaminants (emitted at 1 or more tons/year) or "worst case" toxiccontaminant(s):Toxic Contaminant: hydrogen chlorideTLV (ppm): 2 ppm - (STEL value)Maximum Hourly Emission Rate (Ibs/hr): 0.52Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 5.08MAGLC (ug/m3): 2,199Toxic Contaminant: sulfuric acidTLV (mg/m3): 0.2Maximum Hourly Emission Rate (Ibs/hr): 0.58Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 5.58MAGLC (ug/m3): 200Toxic Contaminant: AmmoniaTLV (ppm): 25 ppm - (TWA value)Maximum Hourly Emission Rate (Ibs/hr): 1.27Predicted 1-Hour Maximum Ground-Level Concentration (ug/m3): 12.14MAGLC (ug/m3): 17,413The permittee, has demonstrated that emissions of each air contaminant fromemissions unit(s) B001, B002, B003, and B004, is calculated to be less thaneighty percent of the maximum acceptable ground level concentration (MAGLC);any new raw material or processing agent shall not be applied without evaluatingeach component toxic air contaminant in accordance with the Toxic AirContaminant Statute, ORC 3704.03(F).

(11) Prior to making any physical changes to or changes in the method of operation of theemissions unit(s), that could impact the parameters or values that were used in thepredicted 1-hour maximum ground-level concentration, the permittee shall re-model thechange(s) to demonstrate that the MAGLC has not been exceeded. Changes that canaffect the parameters/values used in determining the 1-hour maximum ground-levelconcentration include, but are not limited to, the following:

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Facility ID: 1318008750Effective Date:To be entered upon final issuancea. changes in the composition of the materials used or the use of new materials,

that would result in the emission of a new toxic air contaminant with a lowerThreshold Limit Value (TLV) than the lowest TLV previously modeled;b. changes in the composition of the materials, or use of new materials, that wouldresult in an increase in emissions of any toxic air contaminant listed in OAC rule

3745-114-01, that was modeled from the initial (or last) application; andc. physical changes to the emissions unit(s) or its/their exhaust parameters (e.g.,

increased/ decreased exhaust flow, changes in stack height, changes in stackdiameter, etc.)

If the permittee determines that the "Toxic Air Contaminant Statute" will be satisfied forthe above changes, the Ohio EPA will not consider the change(s) to be a "modification"under OAC rule 3745-31-01 solely due to a non-restrictive change to a parameter orprocess operation, where compliance with the "Toxic Air Contaminant Statute", ORC3704.03(F), has been documented. If the change(s) meet(s) the definition of a"modification", the permittee shall apply for and obtain a final PTI prior to the change.The Director may consider any significant departure from the operations of theemissions unit, described in the permit application, as a modification that results ingreater emissions than the emissions rate modeled to determine the ground levelconcentration; and he/she may require the permittee to submit a permit application forthe increased emissions.

(12) The permittee shall collect, record, and retain the following information for each toxicevaluation conducted to determine compliance with the "Toxic Air Contaminant Statute",ORC 3704.03(F):a. a description of the parameters/values used in each compliance demonstrationand the parameters or values changed for any re-evaluation of the toxic(s)

modeled (the composition of materials, new toxic contaminants emitted, changein stack/exhaust parameters, etc.);

b. the Maximum Acceptable Ground-Level Concentration (MAGLC) for eachsignificant toxic contaminant or worst-case contaminant, calculated inaccordance with the Toxic Air Contaminant Statute, ORC 3704.03(F);

c. a copy of the computer model run(s), that established the predicted 1-hourmaximum ground-level concentration that demonstrated the emissions unit(s) tobe in compliance with the Toxic Air Contaminant Statute, ORC 3704.03(F),initially and for each change that requires re-evaluation of the toxic aircontaminant emissions; and

d. the documentation of the initial evaluation of compliance with the "Toxic AirContaminant Statute", ORC 3704.03(F), and documentation of any determinationthat was conducted to re-evaluate compliance due to a change made to theemissions unit(s) or the materials applied.

(13) The permittee shall maintain a record of any change made to a parameter or value usedin the dispersion model, used to demonstrate compliance with the "Toxic Air

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Facility ID: 1318008750Effective Date:To be entered upon final issuanceContaminant Statute", ORC 3704.03(F), through the predicted 1-hour maximumground-level concentration. The record shall include the date and reason(s) for thechange and if the change would increase the ground-level concentration.

e) Reporting Requirements(1) See 40 CFR Part 60, Subpart AAAA (40 CFR 60.1000 - 1465 and Tables 1 through 5)(2) Unless other arrangements have been approved by the Director, all notifications and

reports shall be submitted through the Ohio EPA's eBusiness Center: Air Servicesonline web portal (i.e., a submission through the eBusiness Center fulfills therequirements for submission to the Cleveland DAQ).

(3) The permittee shall submit quarterly deviation (excursion) reports that identify thefollowing information concerning the operation of the following control devices during theoperation of the emissions unit(s):a. Baghouse:

i. each period of time (start time and date, and end time and date) when thepressure drop across the baghouse was outside of the range specified bythe manufacturer and outside of the acceptable range following anyrequired compliance demonstration;

ii. any period of time (start time and date, and end time and date) when theemissions unit(s) was/were in operation and the process emissions werenot vented to the bag house;

iii. each incident of deviation described in e)(3)a.i. (above) where a promptinvestigation was not conducted;iv. each incident of deviation described in e)(3)a.i where prompt corrective

action, that would bring the pressure drop into compliance with theacceptable range, was determined to be necessary and was not taken;and

v. each incident of deviation described in e)(3)a.i. where proper recordswere not maintained for the investigation and/or the corrective action(s),as identified in the monitoring and record keeping requirements of thispermit.

b. Wet - FGD scrubber:i. each period of time (start time and date, and end time and date) when thepressure drop across the scrubber, the liquid flow rate, or the liquid pHwas outside of the appropriate range or limit specified by the

manufacturer and outside of the acceptable range for each parameterfollowing any required compliance demonstration;

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Draft Permit-to-InstallCleveland Public Power - Ridge RdPermit Number: P0107767Facility ID: 1318008750Effective Date:To be entered upon final issuanceii. any period of time (start time and date, and end time and date) when the

emissions unit(s) was/were in operation and the process emissions werenot vented to the scrubber;iii. each incident of deviation described in e)(3)b.i. or ii. (above) where aprompt investigation was not conducted;iv. each incident of deviation described in e)(3)b.i. or ii. where promptcorrective action, that would bring the pressure drop, liquid flow rate, or

scrubber liquid pH into compliance with the acceptable range, wasdetermined to be necessary and was not taken; and

v. each incident of deviation described in e)(3)b.i. or ii. where proper recordswere not maintained for the investigation and/or the corrective action(s),as identified in the monitoring and record keeping requirements of thispermit.

c. SCR:i. each period of time (start time and date, and end time and date) when the

ammonia injection rate, or the inlet gas flow rate across the SCR wasoutside of the appropriate range or limit specified by the manufacturerand outside of the acceptable range for each parameter following anyrequired compliance demonstration;

ii. any period of time (start time and date, and end time and date) when theemissions unit(s) was/were in operation and the process emis

epa draft permit-to-install 11.30.11

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