NCDENR. North Carolina Department of Environment and Natural Resources Division of Air Quality Sheila C. Holman Director

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1 Pat McCrory Governor NA NCDENR North Carolina Department of Environment and Natural Resources Division of Air Quality Sheila C. Holman Director John E. Skvarla, Ill Secretary September 18, 2013 Mr. John Krakuszeski Plant General Manager Duke Energy Progress - Brunswick Plant PO Box Southport, NC Subject: Air Permit No R17 Duke Energy Progress - Brunswick Plant Southport, Brunswick County, North Carolina Permit Class: Synthetic Minor Facility ID# Dear Mr. Krakuszeski: In accordance with your completed application received June 25, 2013, we are forwarding herewith Permit No R17 to Duke Energy Progress - Brunswick Plant, Southport, Brunswick County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q.0102 have been listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt ofthis permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G. S. 150B-22. This request must be submitted in writing to the Director and must identify the specific Wilmington Regional Office - Division of Air Quality 127 Cardinal Drive Extension, Wilmington, North Carolina Phone: / FAX: Internet: An Equal Opportunity\ Affirmative Action Employer- Made in part by Recycled Paper

2 John Krakuszeski September 18, 2013 Page2 provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 150B-23. Unless exempted by a condition of this permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S and may subject the Permittee to civil or criminal penalties as described in G.S A and B. This permit shall be effective from September 18, 2013 until September 1, 2021, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. This permit revision is the result of a permit renewal request with no other changeshowever, ES-Securitv Gen (350 kw) was added as an existing source to the permit equipment list. Also, the NSPS IIII condition (A.B.) and the NESHAP ZZZZ condition (A.13.) were both updated per DAQ review procedures. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Should you have any questions concerning this matter, please contact Dean Carroll, P.E., at (910) Sincerely, Brad Newland, P.E. Regional Air Quality Supervisor Enclosures c: Wilmington Regional Office, DAQ file WiRO Permit Coordinator Ibeam Doc Mod

3 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF AIR QUALITY AIR PERMIT NO R17 Issue Date: September 18, 2013 Expiration Date: September 1, 2021 Effective Date: September 18, 2013 Replaces Permit: 05556R16 To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes ofnorth Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations, Duke Energy Progress - Brunswick Plant River Road Highway 87 Southport, Brunswick County, North Carolina Permit Class: Synthetic Minor Facility ID# (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: ES-Main- C (NESHAP) Emergency diesel generator C (4,900 hp firing ultra low sulfur No. 2 diesel fuel, installed 1977, stationary) ~S-Main---D------~Emergency di-es_e_l g-e-n-er- at_o_r -D-(-4,-9-00_h_p r--- I NESHAP) firing ultra low sulfur No. 2 diesel fuel, N/A 1 N/A installed 1977, stationary) ftj~~~;~f -- -= ~~~~;~t-1~~:~~t~~~:~~r (3o"Ok;-,----~ --==-N/ ~~~~== ~-~~-~-~~~~~~-----~~--- N/A N/A -- ~

4 Page 2 i ~:;~~~~ ~ ~~---- ~ E~::~~r7:: ~; ~-- s~~::~b-~-----~-~~c~}f::::~:t=~~ - ifj:;~~u-mp-~---~--~ r~ ;:~~~2~~~~1,~~:~~~:::;) Pu;;pTngi~~-,-~---~--~~-; ~- r-~------~-~;~ ~-- -- ' ~-- ~--~------~ ~~ ~---~-~ ~- r ~---~ ~ :Es-SECURITY GEN One Emergency Security Diesel Generator,(NSPS, NESHAP) (350 kw/470 hp September 2010 model N/A N/A! unit, installed 2012, stationary) r; ~ ~ ~---~--~ ~ ~ :ES-12 (NSPS, One Emergency Diesel Generator (5,400 :NESHAP) hp firing ultra low sulfur No.2 fuel oil, N/A N/A,manufactured April2012, installed July (est.), stationary) in accordance with the completed application B received June 25,2013 including any plans, specifications, previous applications, and other supporting data, all of which are filed with the Department of Environment and Natural Resources, Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D.0202, 2D.0503, 2D.0516, 2D.0521, 2D.0524 (40 CFR 60, Subpart De and Subpart IIII), 2D.0535, 2D.0540, 2D.1100 NC TAP, 2D.1111 (40 CFR 63, Subpart JJJJJJ and Subpart ZZZZ (RICE)), and 2Q PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q.0304(d) and (f). Pursuant to 15A NCAC 2Q.0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification Sheet) in accordance with 15A NCAC 2D.0202, pursuant to N.C. General Statute The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2020 calendar year. 3. INITIAL REPORTING REQUIREMENT- in addition to the initial reporting requirements specified in 40 CFR Part 60, Subpart De for the temporary boiler, the permittee shall submit the following information before constructing and operating the temporary boiler (ID No. ES-2): a. the temporary boiler manufacturer and model number, and b. the maximum capacity of the temporary boiler in million Btu per hour.

5 Page 3 4. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D.0503 "Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below: , Emission Limit ' Source j (lbs/million Btu) 1 f~~~~;:~i~~ ~;~,r~~;;:i~:gb;~;:~~s-~~i~- -~~- -=-J In accordance with 15A NCAC 2D.0503, the Permittee shall not exceed the following emission limitations: 1 Source Boiler (ID No. ES-1) TEMP Boiler (ID No. ES-2) Pollutant patiiculate particulate Emission Limit(s) E = 1.09 X (Q ) E = 1.09 X (Q -2594) Where E = allowable emission limit, in lb/million Btu, and Q =maximum heat input (cumulative), in Million Btu/hr. Only one boiler, either ES-1 or ES-2, may operate at a time. 5. SULFUR DIOXIDE CONTROL REQUIREMENT- As required by 15A NCAC 2D.0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 6. VISIBLE EMISSIONS CONTROL REQUIREMENT- As required by 15A NCAC 2D.0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with 15A NCAC 2D.0524 "New Source Performance Standards" or.1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein A NCAC 2D.0524 "NEW SOURCE PERFORMANCE STANDARDS"- For the No.2 fuel oil-fired auxiliary boiler (25.5 MM Btu/hr nominal firing rate, ID No. ES-1), the Permittee shall comply with all applicable provisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart De, including Subpart A "General Provisions." a. NSPS Reporting Requirements - In addition to any other notification requirements to the Environmental Protection Agency (EPA), the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, ofthe following:

6 Page 4 1. The sulfur content of the distillate oil com busted in an affected source shall not exceed 0.5 percent by weight. Within 30 days after each six-month period of the calendar year (by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June), the Permittee must submit in writing to the Regional Supervisor, DAQ, the sulfur content of the distillate oil combusted in an affected source. If fuel supplier certification is used to demonstrate compliance, fuel supplier certification shall include the following information: A. The name of the oil supplier; B. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil in 40 CFR (c); and C. A certified statement signed by the owner or operator of an affected source that the records of fuel supplier certification submitted represent all of the fuel com busted during the reporting period. b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping requirements of the EPA, the Permittee is required to maintain records as follows: 1. The amounts of each fuel com busted during each month; and 11. All records required under this section shall be maintained for a period of two years following the date of such record A NCAC 2D.0524 "NEW SOURCE PERFORMANCE STANDARDS"- For the following equipment, The Permittee shall comply with all applicable provisions, including the notification, testing, repmiing, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart 1111 indicated below, and including Subpart A "General Provisions." _ _ ~ Emission Source(s) ES- SECURITY GEN, One Emergency Security Diesel Generator (350 kw/470 hp September 2010 model unit, installed 20 12, stationary) r ES-12, One Emergency Diesel Generator (5,400 hp firing ultra low sulfur No.2 fuel oil, manufactured April2012, installed July 2013 (est.), stationary) Regulation 40 CFR 60, Subpart 1111 "Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE)" a. Emission Standards: 1. Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieve the emission standards as required in 40 CFR and over the entire life of the engine.

7 Page For the pre-2007 model year emergency stationary CI ICE with a displacement of less than 10 liters per cylinder that are not fire pump engines, the Permittee must comply with the emission standards in Table 1 of 40 CFR 60, Subpart IIII.[ (a)] 111. For the pre-2007 model year emergency stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder that are not fire pump engines, the Permittee must comply with the emission standards in 40 CFR 94.8(a)(1).[ (a)] iv. For the 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines, the Permittee must comply with the emission standards for new nonroad CI engines in 40 CFR , for all pollutants, for the same model year and maximum engine power.[ (b)] v. For the fire pump engines with a displacement of less than 30 liters per cylinder, the Permittee must comply with the emission standards in Table 4 of 40 CFR 60 Subpart IIII, for all pollutants.[ (c)] VI. For the emergency stationary CI ICE with a displacement of greater than or equal to 30 liters per cylinder, the Permittee must meet the following requirements: b. Fuel Requirements: A. Limit the emissions ofnox in the stationary CI ICE exhaust as listed in 40 CFR (d).[ (d)(l) and (d)(2)] B. Limit the emissions of PM in the stationary CI ICE exhaust to 0.40 g/kw-hr (0.30 g/hp-hr).[ (d)(3)] 1. Engines subject to this subpart with a displacement of less than 30 liters per cylinder that use diesel fuel must use diesel fuel that meets the requirements of 40 CFR (b) for nonroad diesel fuel, as follows: [ (b)] A. Has a maximum sulfur content of 15 ppm; and [ 40 CFR O(b )] B. Has a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.[40 CFR (b)] 11. Beginning June 1, 2012, owners and operators of stationary CI ICE subject to this subpart with a displacement of greater than or equal to 30 liters per cylinder must use fuel that meets a maximum per-gallon sulfur content of 1,000 parts per million (ppm).[ (d)] c. Monitoring Requirements:

8 Page 6 1. For the emergency stationary CI ICE that does not meet the standards applicable to non-emergency engines, the Permittee must install a nonresettable hour meter prior to startup of the engine.[ (a)] d. Compliance Requirements: 1. The Permittee must do all the following, except as permitted under 40 CFR (g): [ (a)] A. Operate and maintain the stationary CI ICE and control device according to the manufacturer's written emission-related instructions or procedures developed by the Permittee that are approved by the engine manufacturer.[ (a)(l)] B. Change only those emission-related settings that are permitted by the manufacturer [ (a)(2)]; and C. Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable.[ (a)(3)] 11. For the pre-2007 model year stationary CI ICE with a displacement of less than 1 0 liters per cylinder that is not a fire pump engine, or for the CI fire pump engine that is manufactured prior to the model years in Table 3 of 40 CFR 60 Subpart IIII and must comply with the emission standards specified in 40 CFR ( c), the Permittee must demonstrate compliance according to one ofthe methods specified below:[ (b)] A. Purchasing an engine certified according to 40 CFR part 89 or 40 CFR part 94, as applicable, for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's specifications.[ (b)(l)] B. Keeping records of performance test results for each pollutant for a test conducted on a similar engine. The test must have been conducted using the same methods specified in this subpart and these methods must have been followed correctly.[ (b)(2)] C. Keeping records of engine manufacturer data indicating compliance with the standards.[ (b)(3)] D. Keeping records of control device vendor data indicating compliance with the standards.[ (b)(4)] E. Conducting an initial performance test to demonstrate compliance with the emission standards according to the requirements specified in 40 CFR , as applicable.[ (b)(5)] 111. For the 2007 model year and later stationary CI ICE that must comply with the emission standards specified in 40 CFR (b) or 4205 (b), or for the

9 Page 7 CI fire pump engine that is manufactured during or after the model year that applies to the fire pump engine power rating in Table 3 to 40 CFR 60 Subpart IIII that must comply with the emission standards specified in 40 CFR (c), the Permittee must comply by purchasing an engine certified to the emission standards in 40 CFR (b), or 4205(b) or (c), as applicable, for the same model year and maximum (or in the case of fire pumps, NFP A nameplate) engine power. The engine must be installed and configured according to the manufacturer's emission-related specifications, except as permitted in 40 CFR (g).[ (c)] IV. For the stationary CI ICE with a displacement of greater than or equal to 30 liters per cylinder, the Permittee must demonstrate compliance according to the following requirements: A. Conducting an initial performance test to demonstrate initial compliance with the emission standards as specified in 40 CFR [ (d)(l)] B. Establishing operating parameters to be monitored continuously to ensure the stationary ICE continues to meet the emission standards. The Permittee must petition EPA for approval of operating parameters to be monitored continuously. The petition must include the information described in 40 CFR 60.42ll(d)(2)(i) through (v). [ (d)(2)] C. For non-emergency engines with a displacement of greater than or equal to 30 liters per cylinder, conducting annual performance tests to demonstrate continuous compliance with the emission standards as specified in 40 CFR [ (d)(3)] v. An owner or operator of a modified or reconstructed stationary CI ICE that must comply with the emission standards of 40 CFR (e) or ( ) must demonstrate compliance according to.q.!!.!: of the following methods:[ (e)] A. Purchasing, or otherwise owning or operating an engine certified to the emission standards in 40 CFR (e) or ( ), as applicable.[ (e)] B. Conducting a performance test to demonstrate initial compliance with the emission standards according to the requirements specified in 40 CFR or , as appropriate. The test must be conducted within 60 days after the engine commences operation after the modification or reconstruction.[ (e)] v1. If the Permittee does not install, configure, operate, and maintain the engine and control device according to the manufacturer's emission-related written instructions, or if the Permittee changes emission-related settings in a way

10 Page 8 that is not permitted by the manufacturer, the Permittee must demonstrate compliance per the requirements of 40 CFR (g).[ (g)] vu. The Permittee must operate the emergency stationary ICE according to the requirements in paragraphs A through C below. In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs A through C below, is prohibited. If you do not operate the engine according to the requirements in paragraphs A through C below, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. [ ( )] A. There is no limit on the use of emergency stationary ICE in emergency situations. B. You may operate your emergency stationary ICE for any combination of the purposes specified in paragraphs I through III below for a maximum of 100 hours per calendar year. Any operation for nonemergency situations as allowed by paragraph C below counts as part of the 1 00 hours per calendar year allowed by this paragraph B. I. Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. II. III. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

11 Page 9 C. Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 1 00 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph B above. Except as provided in paragraph I below, the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. I. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (a) The engine is dispatched by the local balancing authority or local transmission and distribution system operator; (b) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (c) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (d) The power is provided only to the facility itself or to support the local transmission and distribution system. (e) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf ofthe engine owner or operator. e. Notification Requirements: In addition to any other notification requirements to the Environmental Protection Agency (EPA), the Permittee is required to notify the Regional Supervisor, DAQ, in WRITING, ofthe following: 1. The date construction (40 CFR 60.7) or reconstruction (40 CFR 60.15) of an affected source is commenced, postmarked no later than 30 days after such date. This requirement shall not apply in the case of mass-produced facilities which are purchased in completed form.[40 CFR 60.7(a)(l)]

12 Page A notification of the actual date of initial startup of an affected facility postmarked within 15 days after such date.[40 CFR 60.7(a)(3)] 111. If the stationary CI ICE is greater than 2,237 KW (3,000 HP), or has a displacement of greater than or equal to 10 liters per cylinder, or is a pre model year engine that is greater than 130 KW (175 HP) and not certified, then the Permittee must submit an initial notification as required in 40 CFR 60.7(a)(l). The notification must include the information listed in 40 CFR (a)(1).[ (a) and (a)(1)] 1v. If the engine is an emergency stationary ICE, the Permittee is not required to submit an initial notification.[ (b)] f. Recordkeeping Requirements: 1. If the stationary CI ICE is greater than 2,237 KW (3,000 HP), or has a displacement of greater than or equal to 10 liters per cylinder, or is a pre model year engine that is greater than 130 KW (175 HP) and not certified, then the Permittee must keep records of the following: A. All notifications submitted to comply with 40 CFR 60 Subpart IIII and all documentation supporting any notification;[ (a)(2)(i)] B. Maintenance conducted on the engine;[ (a)(2)(ii)] C. If the stationary CI ICE is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards;[ ( a)(2)(iii)] D. Ifthe stationary CI ICE is not a certified engine, documentation that the engine meets the emissions standards;[ (a)(2)(iv)] E. If the stationary CI ICE is equipped with a diesel particulate filter, the Permittee must keep records of any corrective action taken after the backpressure monitor has notified the Permittee that the high backpressure limit of the engine is approached.[ (c)] F. All records required under this section shall be maintained for a period of two (2) years following the date of such record. All records shall be kept on-site and made available to DAQ personnel upon request. The Permittee shall be deemed in non-compliance with 15A NCAC 2D.0524 ifrecordkeeping requirements are not maintained.[40 CFR 60.7(±)] G. Starting with the model years in Table 5 to 40 CFR 60, Subpart IIII, if the emergency engine does not meet the standards applicable to nonemergency engines in the applicable model year, the Permittee must keep records of the operation of the engine in emergency and nonemergency service that are recorded through the non-resettable hour

13 Page 11 g. Reporting Requirements: meter. The Permittee must record the time of operation of the engine and the reason the engine was in operation during that time.[ (b )] 1. If you own or operate an emergency stationary CI ICE with a maximum engine power more than 100 HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for purposes specified in paragraphs d.vii.b and C above or that operates for the purposes specified in paragraph d.vii.c.i above, you must submit an annual repmi according to the following requirements: [ (d)] A. The report must contain the following information: I. Company name and address where the engine is located. II. III. IV. Date of the report and beginning and ending dates of the reporting period. Engine site rating and model year. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place. V. Hours operated for the purposes specified in paragraphs d.vii.b.ii and III above, including the date, start time, and end time for engine operation for the purposes specified in paragraphs d.vii.b.ii and III above. VI. VII. Number of hours the engine is contractually obligated to be available for the purposes specified in paragraphs d.vii.b.ii and III above. Hours spent for operation for the purposes specified in paragraph d.vii.c.i above, including the date, start time, and end time for engine operation for the purposes specified in paragraph d.vii.c.i above. The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. B. The first annual report must cover the calendar year 2015 and must be submitted no later than March 31, Subsequent annual reports for each calendar year must be submitted no later than March 3 I of the following calendar year. C. The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central

14 Page 12 Data Exchange (CDX) ( However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in 40 CFR NOTIFICATION REQUIREMENT- As required by 15A NCAC 2D.0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00a.m. Eastern time ofthe Division's next business day of becoming aware ofthe occurrence and describe: 1. the name and location of the facility, 11. the nature and cause of the malfunction or breakdown, 111. the time when the malfunction or breakdown is first observed, IV. the expected duration, and v. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 10. FUGITIVE DUST CONTROL REQUIREMENT- As required by 15A NCAC 2D.0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D.0540( ). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads). 11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT- Pursuant to 15A NCAC 2D.1100 "Control of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration, the following permit limits shall not be exceeded:

15 Page 13 ISAffect~(d)--~ Toxic Air p:~:ta~ ~---eml~~s~to~--~ I ~ ource s 1m1 Fa ~ _ ac 11 Y _. '1 ' Tt W"d. Arsenic & Compounds (total mass of elemental AS, arsine 1 e and all inorganic compounds ASC ( )) 1'2 1 lb/ yr [Facility Wide [Be~e~e (7l~43-2) ri-:j1tib/y;---j ~-- ~ ; ral:111ty Wide 1Beryllium Metal (umeacted) (Component ofbec ) :38.1 lb/yr [Facility ~i:-~~~~~~~~:w~~km~1~1~~~(co-~ron~~1~tc6c) r~ ;_ 1-1 b~y~ - ~F-~l"t W"d--~Chromium (VI) Soluble Chromate Comp~unds (C~mp~~ent_/_ lrac b/d 11 1 y e ofcrc SolCR6) ;. ay ' a. Operating Restrictions- To remain in compliance with this permit, the facility shall operate only ONE boiler at a time, and the total number of hours of use for each generator shall be less than 500 hr/yr (each). b. Recordkeeping Requirements- The following recordkeeping requirements apply: 1. the facility shall record the actual hours of use of each boiler and the actual number of hours of use of each generator at the facility. (The facility modeled 8,760 hr/yr in one boiler and 500 hours of use for each generator, which resulted in 48% AAL for arsenic (the highest).) c. Reporting Requirements- The facility is not required to report any records or documents to the DAQ Wilmington Regional Office for NC TAP; the records contained in paragraph (b) above shall be retained on site at all times and made available for DAQ inspector review upon request. 12. GENERALLY AVAILABLE CONTROL TECHNOLOGY- For the No.2 fuel oil-fired auxiliary boiler (25.5 MM Btulhr nominal firing rate, ID No. ES-1), the Permittee shall comply with all applicable provisions, including the notification, testing, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.1111, as promulgated in 40 CFR 63, Subpart JJJJJJ, "National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers", including Subpart A "General Provisions." a. Compliance Dates ( 40 CFR ) - The owner or operator of an existing source is required to comply with the tune-up and the energy assessment requirements no later than March 21, b. Compliance Requirements -As required by 15A NCAC 2D.1111, the Permittee shall comply with the following requirements: 1. General Duty Clause (40 CFR (a))- At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions.

16 Page 14 n. Boiler Tune-up (40 CFR )- An initial boiler tune-up is required by March 21, Ifthe unit is not operating on the required date for a tune-up, the tune-up must be conducted within thirty days of startup. The Permittee shall comply with the following with respect to the tune-up: A. Periodic tune-ups: A biennial tune-up is required and shall be conducted no more than 25 months after the previous tune-up. The following units are only required to conduct a tune-up every five years: seasonal boilers (shutdown for 7 consecutive months or 210 consecutive days each 12-month period due to seasonal conditions; only biomass or oil), limited-use boilers, and units with oxygen trim systems, as defined in 40 CFR Each five-year tune-up must be conducted within 61 months of the previous tune-up. B. Fuel required for the tune-up: The permittee shall conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. C. As applicable, inspect the burner, and clean or replace any components of the burner as necessary. The Permittee may delay the burner inspection until the next scheduled unit shutdown, but must inspect each burner at least once every 36 months (72 months for 5- year tune-ups). D. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. E. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. The Permittee may delay the air to fuel ratio inspection until the next scheduled unit shutdown, but must conduct the inspection at least once every 36 months (72 months for 5-year tune-ups). F. Optimize total emissions of carbon monoxide. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. G. Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken with a portable CO analyzer.

17 Page Energy Assessment (40 CFR (c))- A one-time initial energy assessment is required by March 21, The energy assessment must be performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this section satisfies the energy assessment requirement. This energy assessment requirement does not apply to limited use boilers as defined in 40 CFR A facility that operates under an energy management program compatible with ISO that includes the affected units satisfies the energy assessment requirement. The energy assessment must include: A. A visual inspection of the boiler system. B. An evaluation of operating characteristics of the facility, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. C. Inventory of major systems consuming energy from affected boilers and which are under control of the boiler owner or operator. D. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. E. A list of major energy conservation measures that are within the facility's control. F. A list of the energy savings potential of the energy conservation measures identified. G. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. c. Notification and Reporting Requirements- In addition to the notification and reporting requirements of the Environmental Protection Agency (EPA), the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following: 1. Initial Notification (per 40 CFR 63.9(b) and 40 CFR (a)(2)) is required by January 20, (this was received on September 13, 2011.) 11. Notification of Compliance Status (per 40 CFR (a)( 4)) is required by July 19,2014. (this was received in WiRO on August 7, 2012.) 111. Compliance Report must be prepared by March 1 of every other year (or every five years depending on the frequency of the tune-up requirements) starting March 1 the year following the first periodic tune-up, and submitted upon request. If the source experiences any deviations from the applicable

18 Page 16 requirements then the report must be submitted by March 15. The report must meet the requirements of 40 CFR (b)(l-4). d. Recordkeeping Requirements - In addition to any other recordkeeping requirements of the EPA, the Permittee shall maintain the following records as defined under 40 CFR (c): 1. Copies of all required notifications. 11. Maintain the following records to document conformance with the work practices, emission reduction measures, and management practices: A. Tune-up records - records must identify each boiler, the date of tuneup, the procedures followed for tune-up, the manufacturer's specifications to which the boiler was tuned, and the following: I. The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tuneup of the boiler. II. III. A description of any corrective actions taken as a part of the tune-up of the boiler. The type and amount of fuel used over the 12 months prior to the tune-up ofthe boiler but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. B. A copy the Energy Assessment required by 40 CFR (c). C. Seasonal boilers- For each boiler that meets the definition of seasonal boiler, you must keep records of days of operation per year. D. Records of non-waste determinations per 40 CFR (c)(2)(ii) Malfunction Records- Records of the occurrence and duration of each malfunction of the boiler, or of the associated air pollution control and monitoring equipment. Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR ( a), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. 1v. Record Retention - You must keep each record for 5 years following the date of each recorded action A NCAC 2D.1111 "National Emission Standards for Hazardous Air Pollutants"- For the 255 hp/187 kw Diesel Fire Pump Engine (1974 yr model, ID No. ES-FIRE PUMP),

19 Page 17 Emergency diesel generator A ( 4,900 hp firing ultra low sulfur No. 2 diesel fuel, installed 1975, ID No. ES-Main- A), Emergency diesel generator B (4,900 hp firing ultra low sulfur No.2 diesel fuel, installed 1975, ID No. ES-Main- B), Emergency diesel generator C ( 4,900 hp firing ultra low sulfur No. 2 diesel fuel, installed 1977, ID No. ES-Main- C), Emergency diesel generator D ( 4,900 hp firing ultra low sulfur No. 2 diesel fuel, installed 1977, ID No. ES-Main- D), and Emergency diesel generator (300 kw, installed 1983, ID No. ES TSC/EOF), the Permittee shall comply with all applicable provisions, including the maintenance and recordkeeping requirements contained in Environmental Management Commission Standard 15A NCAC 2D.1111, as promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE)", including Subpart A "General Provisions." The Permittee shall comply with the definition of emergency stationary RICE in 40 CFR and the following stationary RICE provisions. a. Compliance Date- The compliance date is/was May 3, b. Maintenance and Work Practices- Pursuant to 40 CFR (a), (e), (f), and (h) and ( ) the Permittee shall comply with the following: 1. Change the oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option to utilize an oil analysis program as described in Section c. below in order to extend the specified oil change requirements. 11. Inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. IV. Operate and maintain the engine and control device (if any) according to the manufacturer's emission related written instructions or maintenance plan developed by the Permittee that minimizes emissions from the engine to the extent practicable. v. Install a non-resettable hour meter if one is not already installed. v1. Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. vn. If the engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedules required in Sections b.i., b.ii., and b.iii., above, or if performing the management practice on the required schedules would otherwise pose an unacceptable risk under federal, state or local law, the management practices can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The

20 Page 18 management practice shall be performed as soon as possible after the emergency has ended or the unacceptable risk has abated. The Permittee shall report any failure to perform the management practice on the schedule required and the federal, state, or local law under which the risk was deemed unacceptable. vm. If the Permittee does not operate the engine according to the requirements in Sections A. through C. below, then the engine will not be considered an emergency engine under NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines. A. There is no time limit on the use in emergency situations. B. The Permittee may operate the engine for any combination of the purposes specified in Sections (i) through (iii) below for a maximum of 1 00 hours per calendar year. (i) The engine may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission authority or equivalent balancing authority and transmission operator, or the insurance company associated with the engme. The Permittee may petition the Division of Air Quality (DAQ) Regional Supervisor for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of the engine beyond 100 hours per calendar year. (ii) The engine may operate for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergency or other authorized entity as determined by the Reliability Coordinator has declared an Energy Emergency Ale1i Level 2 as defined in the NERC Reliability Standard EOP (iii) The engine may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. C. Pursuant to 40 CFR ( )(4), the engine may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 1 00 hours per calendar year for maintenance and testing and emergency demand response provided in Section b.viii.b above. Except as provided in Sections (i) and (ii) below, the 50 hours per

21 Page 19 year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for the facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for the facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system. (ii) The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if ALL of the following conditions are met: (I) The engine is dispatched by the local balancing authority or local transmission or distribution system operator. (II) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (III) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (IV) The power is provided only to the facility itself or to support the local transmission and distribution system. (V) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. IX. At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to DAQ which may include, but is not limited to,

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