Technical Contact. Ann Quillian Sr. Environmental Specialist (919) PO Box 1551 Raleigh, NC 27602

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1 NORTH CAROLINA DIVISION OF AIR QUALITY Air Permit Review Permit Issue Date: Facility Data Region: Raleigh Regional Office County: Person NC Facility ID: Inspector s Name: Steven Carr Date of Last Inspection: 06/17/2015 Compliance Code: 3 / Compliance - inspection Permit Applicability (this application only) Applicant (Facility s Name): Facility Address: 1700 Dunnaway Road Semora, NC SIC: 4911 / Electric Services NAICS: / Fossil Fuel Electric Power Generation Facility Classification: Before: Title V After: Title V Fee Classification: Before: Title V After: Title V Contact Data Facility Contact Robert Howard Senior EHS Professional (336) Dunnaway Road Semora, NC Authorized Contact William Thacker Station Manager (336) Dunnaway Road Semora, NC Total Actual emissions in TONS/YEAR: Technical Contact Ann Quillian Sr. Environmental Specialist (919) PO Box 1551 Raleigh, NC SIP: 02Q.0400 NSPS: NESHAP: PSD: PSD Avoidance: NC Toxics: 112(r): Other: Acid Rain Program, CSAPR Removed: CAIR Application Data Application Number: A &.15C Date Received: 06/26/2014 Application Type: Renewal Application Schedule: Title IV Existing Permit Data Existing Permit Number: 01001/T48 Existing Permit Issue Date: 02/07/2014 Existing Permit Expiration Date: 01/31/2019 CY SO2 NOX VOC CO PM10 Total HAP Largest HAP Review Engineer: Russell Braswell Review Engineer s Signature: Date: Comments / Recommendations: Issue 01001/T49 Permit Issue Date: Permit Expiration Date:

2 Review of applications A &.15C Page 2 of 4 1. Purpose of Application: (Duke) currently operates under Title V Air Quality Permit 01001T48. This permit also includes a Phase II Acid Rain permit. Duke submitted application.14a in order to renew the Acid Rain portion of the permit. Duke subsequently submitted application.15c in order to modify the terms and requirements of the Acid Rain portion of the permit. Additionally, NCDAQ has taken this opportunity to update the Title V permit to reflect the expiration of the Clean Air Interstate Rule (CAIR) and the new requirements of the Cross State Air Pollution Rule (CSAPR). 2. Facility Description: According to the most recent inspection report 1, this facility is electric power plant that generates the majority of the electricity with coal-fired boilers. 3. Application Chronology: June 26, 2014 Application.14A received. June 26, 2015 Application.15A received. March 1, 2016 Application transferred to Russell Braswell March 14, 2016 An initial draft of the permit and review were sent to DAQ staff (Mark Cuilla, Tom Anderson, Samir Parekh, Steven Carr, Charles McEachern) and Duke staff (Ann Quillian, Cynthia Winston). For a summary of comments received, see Attachment 2. XXXXXXX Public / EPA notice XXXXXXXX Permit issued. 4. Regulatory Review: a. CAIR and 02D.2400 According to 40 CFR 52.35(f) and 52.36(e), CAIR no longer applies as of January 1, This rule has been replaced by CSAPR. Because the rule no longer applies, all references thereto have been removed from the permit. On February 1, 2016, the rules under 15A NCAC 02D.2400 expired. Therefore, references to those rules have also been removed from the permit. b. CSAPR requirements CSAPR (specifically, 40 CFR Part 97, Subparts AAAAA, BBBBB, and CCCCC) was originally scheduled to take effect on January 1, This rule was planned as a replacement for CAIR. However, CSAPR was challenged in court and initially vacated by the DC Circuit Court. Legal 1 Steven Carr, June

3 Review of applications A &.15C Page 3 of 4 issues were finally resolved in April 2014, when the US Supreme Court reversed that decision. Because the regulation was delayed by court proceedings, the effective date of the rule was moved to January 1, Under this rule, each of the units at the facility is considered a "large electric generating unit", per 40 CFR This rule and all requirements thereof are considered Federal-enforceable only. Compliance will be determined by the US EPA, not NC DAQ. A reference to this rule has been added to the permit. c. Phase II Acid Rain Permit requirements Facilities subject to the acid rain program have emission limits for SO2 and NOx. SO2 is limited on an annual, per-boiler basis. The exact limits are set by the USEPA based on an allowance system, and are subject to change. Ultimately, Duke will demonstrate compliance with the SO2 limits to USEPA, not NCDAQ. NOx is normally limited by a lb/mmbtu standard based on the age and configuration of the boiler. However, 40 CFR allows Duke to set its own emission limits as part of an averaging plan. The averaging plan allows Duke to take the average NOx emission rate from multiple Duke facilities. Ultimately, the average emission rate of NOx from the multiple facilities will be in compliance with the standard. In order to demonstrate compliance with the NOx emission limits, each individual boiler at participating facility is given a NOx limit and annual heat input limit (both chosen by Duke). The existing acid rain permit includes an averaging plan that covers several Duke facilities in North Carolina, South Carolina, and Florida. Duke submitted application.15c in order to update the averaging plan. The updated plan now only includes facilities in North Carolina. For this specific facility, the updated averaging plan increases the NOx emission limit for each boiler, but decreases the annual heat input limit for each boiler: 5. Facility Emissions Review Boiler Old limits New limits Boiler No lb/mmbtu lb/mmbtu 16,254,975 mmbtu/yr 10,341,180 mmbtu/yr Boiler No lb/mmbtu lb/mmbtu 32,789,849 mmbtu/yr 15,794,280 mmbtu/yr Boiler No. 3A 17,651,860 mmbtu/yr 9,331,590 mmbtu/yr Boiler No. 3B 17,651,860 mmbtu/yr 9,331,590 mmbtu/yr Boiler No. 4A 17,928,281 mmbtu/yr 9,331,590 mmbtu/yr Boiler No. 4B 17,928,281 mmbtu/yr 9,331,590 mmbtu/yr Although the emission limits as part of the Acid Rain Permit are changing, the actual operation of the facility and control devices is not. Therefore, potential emissions from the facility are not expected to change.

4 Review of applications A &.15C Page 4 of 4 6. Public Notice/EPA and Affected State(s) Review A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 2Q The notice will provide for a 30-day comment period, with an opportunity for a public hearing. Copies of the public notice shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 2Q.0522, a copy of each permit application, each proposed permit and each final permit pursuant shall be provided to EPA. Also pursuant to 2Q.0522, a notice of the DRAFT Title V Permit shall be provided to each affected State at or before the time notice provided to the public under 2Q.0521 above. 7. Recommendations Issue permit 01001T49

5 Attachment 1 to review of applications A &.15C Change List The following changes were made to the Progress Energy - Roxboro Plant Air Permit No T48: Page No.* Section No.* Description of Changes Updated dates Updated permit/application numbers Throughout Throughout Removed references to CAIR because the rule no longer applies. Added references to CSAPR. Fixed formatting 2.3. Added CAIR and 02D.2400 the to list of non-applicable regulations Updated acid rain permit to reflect new averaging plan Added CSAPR requirements. 3. Updated general conditions to v4.0. *This refers to the current permit unless otherwise stated.

6 Attachment 2 to review of applications A &.15C Ann Quillian, by on March 31, 2016 Comments received on initial draft Ann pointed out that the draft permit referred to Duke as "Inc." instead of "LLC". Also, the plant manager had changed. I have fixed these errors.