DRAFT PROPOSED PERMIT. San Diego County Air Pollution Control District Old Grove Rd San Diego, CA (858)

Transcription

1 DRAFT PROPOSED PERMIT San Diego County Air Pollution Control District Old Grove Rd San Diego, CA (858) TITLE V OPERATING PERMIT Issued To: Applied Energy North Island, Inc. APCD1988-SITE Site Address: Quay and Rogers Rd., Building 370 San Diego, CA (619) Mailing Address: 8835 Balboa Ave. #D San Diego, CA Responsible Official David Sweigart, General Manager Facility Contact Mike Stewart Permit Information Contact - John R. Dow Issued by the San Diego County Air Pollution Control District on Operating Permit expires on. (Renewed under APCD2010-APP ).. This Title V Signed by Robert Kard, Air Pollution Control Officer Date

2 TABLE OF CONTENTS PAGE PREAMBLE 1 SECTION I. REGULATION XIV PERMIT REQUIREMENTS 2 A. ADMINISTRATIVE PERMIT TERMS 2 B. RENEWAL REQUIREMENTS AND TERMS 2 C. MONITORING, RECORDKEEPING & REPORTING REQUIREMENTS 3 D. GENERAL PERMIT REQUIREMENTS 4 SECTION II. FACILITY-WIDE REQUIREMENTS 5 A. GENERAL PERMIT PROGRAM APPLICABLE REQUIREMENTS 5 B. GENERAL PROHIBITORY APPLICABLE REQUIREMENTS 5 C. 40 CFR PART 68, CHEMICAL ACCIDENT PREVENTION PROVISIONS 5 D. PERMIT SHIELDS 6 E. ADDITIONAL TERMS 5 SECTION III. EMISSION UNIT REQUIREMENTS 6 A. DISTRICT PERMITTED EMISSION UNITS 6 B. REGISTERED AND LEASED EMISSION UNITS 7 C. INSIGNIFICANT EMISSION UNITS AND ACTIVITIES 7 D. PERMIT SHIELDS 7 SECTION IV. DISTRICT-ONLY PROVISIONS 9 A. VARIANCE PROCEDURES 9 B. COMPLIANCE SCHEDULES 9 SECTION V. APPENDIXES A. DISTRICT PERMITS B. RULE REFERENCE TABLE C. ABBREVIATIONS i

3 NAS North Island, Applied Energy, Inc. Title V Permit No PREAMBLE This Title V Operating Permit consists of this document and all appendixes, including District permits incorporated by reference. The facility is subject to all applicable requirements identified within this permit, unless a specific permit shield is specified within this permit. If an applicable requirement is omitted from this permit, the facility is still obligated to comply with such an applicable requirement. The permittee must comply with all of the terms listed in each section of this permit. This permit contains five major sections: Section I contains the Regulation XIV requirements required to carry out the Title V Operating Permit program. Section II contains the requirements that are applicable to the facility on a facility-wide basis. Section III contains the requirements that are applicable to individual emission units which have been issued District permits or District registration, or which have been determined to be insignificant emission units. Section IV contains terms and requirements pertaining to (District-only) variance procedures and compliance schedules, if applicable to the facility. Section V contains three appendixes. Appendix A contains all the District permits incorporated within this permit. Appendix B contains a table of all SIP approved and District approved rules. Appendix C contains a list of abbreviations used within this permit. Copies of the Rules and Regulations of the Air Pollution Control District of San Diego County and the Rules and Regulations for San Diego County contained in the State Implementation Plan (SIP) approved by EPA may be obtained at the District. Copies are also available for review at the following locations: SD Air Pollution Control District (Library & Public Review Area) County of SD Law Library (Downtown) County of SD Law Library (North County) Old Grove Rd 1105 Front St. 325 S. Melrose Suite 300 San Diego, CA San Diego, CA Vista, CA (858) (619) (760) The current Rules and Regulations of the Air Pollution Control District of San Diego County may also be viewed and downloaded using the following internet address: The following addresses should be used to submit any certifications, reports or other information required by this permit: SD Air Pollution Control District USEPA Region IX Compliance Division Director of the Air Division Attn: Air Old Grove Rd 75 Hawthorne Street San Diego, CA San Francisco, CA

4 NAS North Island, Applied Energy, Inc. Title V Permit No SECTION I. REGULATION XIV PERMIT REQUIREMENTS A. ADMINISTRATIVE PERMIT TERMS 1. This Title V Operating Permit expires 5 years from the date of issuance. [Rule 1410] 2. Commencing or continuing operation under this permit to operate shall be deemed acceptance of all terms and conditions specified within this permit. This does not limit the right of the applicant to seek judicial review or seek federal EPA review of a permit term or condition. [Rule 1421] 3. This permit may be modified, revoked, reopened and reissued, or terminated by the District for cause. [Rule 1421] 4. The filing of a request by the facility for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay the applicability of any permit condition. [Rule 1421] 5. This permit does not convey any property rights of any sort, nor any exclusive privilege. [Rule 1421] 6. The need for the permittee to halt or reduce a permitted activity in order to maintain compliance with any term or condition of this permit shall not be a defense for any enforcement action brought as a result of a violation of any such term or condition. [Rule 1421] 7. In the event of challenge to any portion of this permit, the rest of the permit remains valid. [Rule 1421] 8. For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any applicable requirement in this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [Rule 1421] B. RENEWAL REQUIREMENTS AND TERMS 1. The permittee shall submit a complete application for renewal of this permit to the Air Pollution Control Officer at least 12 months, but not more than 18 months prior to permit expiration. [Rule 1410] 2. If an administratively complete application for renewal of this permit has been submitted to the Air Pollution Control Officer within the dates specified in Section I.B.1., the terms and conditions of this permit shall remain in effect and the source may continue operations under these terms and conditions until the Air Pollution Control Officer issues or denies the permit renewal. [Rule 1410] 2

5 NAS North Island, Applied Energy, Inc. Title V Permit No C. MONITORING, RECORDKEEPING & REPORTING REQUIREMENTS 1. The permittee shall provide the District access to the facility and all equipment subject to this permit, and access to all required records pursuant to California Health and Safety Code Section [Rule 1421] 2. The permittee shall maintain all records required by this permit including any calibration, maintenance, and other supporting information and copies of all reports required by this permit for at least five years from their date of creation. Such records shall be maintained on-site for a minimum of three years. [Rule 1421] 3. The permittee shall submit monitoring and recordkeeping summary reports and all other monitoring and recordkeeping reports required by this permit to the District every six months, unless a shorter time frame is required by a specific permit condition contained in Section III of this permit. Unless other dates are specified in Section III, reports for data required to be collected from January 1 through June 30, shall be submitted no later than September 1 of the calendar year, and reports for data required to be collected from July 1 through December 31, shall be submitted no later than March 1 of the following calendar year. The report for the final six months of the year may be consolidated with the annual compliance certification required below. All instances of noncompliance from federally enforceable applicable requirements shall be clearly identified in these reports. (Timely completion of District Certification Reports Form J1 and Form J2, if applicable, and all indicated attachments, fulfills the requirements of this condition.) [Rule 1421] 4. Each calendar year, the permittee shall submit to the District and to the federal EPA an annual compliance certification, in a manner and form approved in writing by the District, for the previous calendar year that includes the identification of each applicable term or condition of the final permit for which the compliance status is being certified, the compliance status and whether the facility was in continuous or intermittent compliance during the previous calendar year, identification of the method used to determine compliance during the previous calendar year, and any other information required by the District to determine the compliance status. The annual compliance certification for a calendar year shall be submitted no later than March 1 of the following calendar year and may be consolidated with the monitoring and recordkeeping report for the last six months of the year for which compliance is certified. (Timely completion of District Certification Reports Form J1 and Form J2, if applicable, and all indicated attachments, fulfills the requirements of this condition.) [Rule 1421] 5. Any report submitted to the District or federal EPA pursuant to this permit to comply with a federally enforceable applicable requirement, shall be certified by a responsible official stating that, based on information and belief formed after reasonable inquiry, the report is true, accurate and complete. [Rule 1421] 6. The permittee shall make any trade secret designations of records, documents, or other information submitted to the District or federal EPA in accordance with District Rule 176. [Rule 176] 3

6 NAS North Island, Applied Energy, Inc. Title V Permit No The permittee shall report all deviations from any and all federally enforceable permit terms and conditions including: (a) breakdowns, whether or not they result in excess emissions, (b) deviations that result in excess emissions of any regulated air pollutant, and (c) deviations from monitoring, recordkeeping, reporting and other administrative requirements that do not result in excess emissions. For deviations that result from breakdowns under District Rule 98, the permittee shall report the breakdown within two hours of detection of the breakdown and provide a follow-up written report after corrective actions have been taken. For deviations not due to a breakdown but which result in excess emissions, the permittee shall report the deviation within ten calendar days of detection. For all other deviations where no specific time frame for reporting a deviation applies, the permittee shall report the deviation at the time of the next semiannual monitoring summary or annual compliance certification, whichever occurs first. If an underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, then the criteria for the applicable requirement shall apply. The report must include the probable cause of such deviations and any corrective actions or preventive measures taken. [Rule 1421] D. GENERAL PERMIT REQUIREMENTS 1. The permittee shall comply with all terms and conditions of this permit. This permit consists of this document and Appendixes A, B and C. Any noncompliance with the federally applicable terms and conditions of this permit shall constitute a violation of the federal Clean Air Act. Noncompliance with any federally applicable permit term or condition will be grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. Noncompliance with any District permit term or condition will be grounds for enforcement action by the District. [Rule 1421] 2. Upon a written request by the District, the permittee shall furnish to the District any information needed to determine whether cause exists for modifying, revoking and reissuing this permit, or terminating this permit; any information to determine compliance with this permit; or any records required to be maintained pursuant to this permit. Such information shall be provided by the date specified within the District's written request. [Rule 1421] 3. The permittee shall pay annual fees in accordance with District Rule 40. [Rule 1421] 4. The permittee shall provide access, facilities, utilities and any necessary safety equipment for source testing and inspection upon request of the District. [Rule 19] 5. This permit shall be maintained on-site at all times and be made available to the District upon request. [Rule 1410] 6. The Rule Reference Table provided in Appendix B shall be used to determine whether a cited rule is a federally and District enforceable requirement or a District only enforceable requirement. Any new or revised District rule shall not be considered federally enforceable until the rule is approved by EPA into the SIP. In cases where SIP 4

7 NAS North Island, Applied Energy, Inc. Title V Permit No approval is pending for a revised District rule, the rule citation shall refer to both the current SIP approved rule and the revised District rule. [Rule 1421] SECTION II. FACILITY-WIDE REQUIREMENTS A. GENERAL PERMIT PROGRAM APPLICABLE REQUIREMENTS The permittee shall comply with the applicable requirements specified in the Rules and Regulations cited below, unless specifically exempted by the same Rule or Regulation. Regulation Rule Citation Title SDCAPCD Reg. II 10 Permits Required SDCAPCD Reg. II 19 Provision of Sampling & Testing Facilities SDCAPCD Reg. II 19.3 Emission Information SDCAPCD Reg. II 21 Permit Conditions SDCAPCD Reg. IV 60 Circumvention SDCAPCD Reg. V 98 Breakdown Conditions: Emergency Variance B. GENERAL PROHIBITORY APPLICABLE REQUIREMENTS The permittee shall comply with the generally applicable requirements specified in the Rules and Regulations cited below, unless specifically exempted by the same Rule or Regulation. These generally applicable requirements apply on a facility-wide basis to all permitted equipment, registered equipment, and insignificant activities. In cases where a requirement, in addition to being generally applicable, is also specifically applicable to one or more permitted emission units, the requirement is also included in Section III.A. of this permit. Regulation Rule Citation Title SDCAPCD Reg. IV 50 Visible Emissions SDCAPCD Reg. IV 51 Nuisance SDCAPCD Reg. IV 67.0 Architectural Coatings SDCAPCD Reg. IV Storage of Materials Containing VOC SDCAPCD Reg. IV 71 Abrasive Blasting SDCAPCD Reg. X Subpart A, Part 60 NSPS - General Provisions 40 CFR Part 60 Subpart A, Part 60 Appendices B&F NSPS Continuous Emissions Monitoring C. 40 CFR Part 68, Chemical Accident Prevention Provisions (RMP Requirements) Applied Energy is subject to an RMP plan for the storage of ammonia above the 10,000 lb threshold level of Part The permittee shall comply with all of the requirements of their approved RMP. [40 CFR 68.12] 5

8 NAS North Island, Applied Energy, Inc. Title V Permit No The permittee shall submit additional relevant information requested to ensure compliance with Part 68 and/or with a schedule of compliance or a compliance certification statement. [40 CFR ] 3. The permittee shall submit a revised RMP for a subject facility within 3 years after a new substance is listed or a listed substance is stored at the source above threshold quantities. [40 CFR ] 4. Any information and documents required by conditions I.C.2. and I.C.3. above, shall be submitted to the proper implementing agency. [Rule 1421] D. PERMIT SHIELDS 1. The permittee is shielded from enforcement action for the following requirements in accordance with the provisions of District Rule 1410(p) and 40 CFR 70.6(f) and shall not exceed the provisions of these regulations. For any shielded requirement that is based on an exemption provided within an otherwise applicable rule, the requirement shall only be shielded to the extent of the exemption. Regulation Rule Citation Title SDCAPCD Reg. IV 52 Particulate Matter SDCAPCD Reg. IV 54 Specific Contaminants SDCAPCD Reg. X Subpart Kb Standards of Performance for Volatile Organic Liquid Storage Vessels E. ADDITIONAL TERMS 1. No federal offset requirements were applicable to this facility when each Authority to Construct was issued for the emission units listed in Section III. 2. The District Permits to Operate listed in Section III.A. were issued in accordance with the applicable Prevention of Significant Deterioration (PSD) Program requirements, as delegated to the District. 3. Any emission unit described in this Title V operating permit as being fired on natural gas, shall only use Public Utility Commission (PUC)-quality natural gas, unless the emission unit permit specifies otherwise. [Rules 53, 62] 4. The permittee shall comply with all applicable requirements, including but not limited to, those applicable requirements of 40 CFR Parts 60 and 63. SECTION III. EMISSION UNIT REQUIREMENTS A. DISTRICT PERMITTED EMISSION UNITS The District Permits listed below and attached in Appendix A, including all terms and conditions of such permits, constitute the emission unit portion of this Title V Operating Permit document. Permit Numbers Source Category 6

9 NAS North Island, Applied Energy, Inc. Title V Permit No , Boilers Combustion Turbine IC Engine B. REGISTERED AND LEASED EMISSION UNITS The permittee shall comply with the source specific applicable requirements specified in the Rules and Regulations cited below for all registered and leased emission units, unless specifically exempted by the same Rule or Regulation. Regulation Rule Citation Title SDCAPCD Reg. IV 62 Sulfur Content of Fuels SDCAPCD Reg. IV 69.4 Stationary Reciprocating Internal Combustion Engines C. INSIGNIFICANT EMISSION UNITS AND ACTIVITIES Permit : FIRE PUMP: CATERPILLAR ENGINE, MODEL 3208, 165 BHP, S/N 90N71269 Note: Pursuant to Rule 1411, section (o)(34)(ii), stationary IC engines rated at < 200 bhp installed and operated before November 15, 2000, and which operate < 200 hr/yr are exempt from Title V permitting. However, since the engine is subject to a federal regulation, 40 CFR Part 63, Subpart ZZZZ, IC engine is included in the Title V permit. D. PERMIT SHIELDS The permittee is shielded from enforcement action for the following requirements in accordance with the provisions of District Rule 1410(p) and 40 CFR 70.6(f) and shall not exceed the provisions of these regulations. For any shielded requirement that is based on an exemption provided within an otherwise applicable rule, the requirement shall only be shielded to the extent of the exemption. Permit Number Rule or Regulation Basis SDAPCD Rule 69.2 Not applicable to equipment NSPS Subpart Db Not applicable to equipment Enforcement action on SDAPCD Rules 53, 62, 68, 69.3 Equivalent or more stringent requirements are given in the permit for Monitoring, Recordkeeping, and Reporting Enforcement action on Equivalent or more stringent requirements are 7

10 NAS North Island, Applied Energy, Inc. Title V Permit No NSPS Subpart GG & Db Enforcement action on 40CFR Parts 60.4(b) & 60.7(c) (Records) Rule 53, 62, 69.3, NSPS Subpart GG & Db Enforcement action on Rule 53, Rule 62, Rule 68, Rule 69.2(d) & NSPS Subpart Db Enforcement action on Rule 69.2 (d), (e)(2), (f), and (g) given in the permit for Monitoring, Recordkeeping, and Reporting Equivalent requirements are given in the permit for Monitoring, Recordkeeping, and Reporting Equivalent or more stringent conditions are provided. Equivalent or more stringent conditions are provided Equivalent or more stringent conditions are provided SECTION IV. DISTRICT-ONLY PROVISIONS A. VARIANCE PROCEDURES 1. The permittee may seek relief from District enforcement action for District-only provisions in the event of a breakdown in accordance with District Rule 98. Notwithstanding the foregoing, the granting by the District of breakdown relief or the issuance by the Hearing Board of a variance does not provide relief from federal enforcement or citizen's suits. [Rule 98] B. COMPLIANCE SCHEDULES Not applicable to this source. 8

11 NAS North Island, Applied Energy, Inc. Title V Permit No SECTION V. APPENDICES APPENDIX A. DISTRICT PERMITS Permit Numbers Source Category 5272, Boilers Combustion Turbine IC Engine

12 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO PERMIT TO OPERATE THE FOLLOWING IS HEREBY GRANTED A PERMIT TO OPERATE THE ARTICLE, MACHINE, EQUIPMENT OR CONTRIVANCE DESCRIBED BELOW. THIS PERMIT IS NOT TRANSFERABLE TO A NEW OWNER NOR IS IT VALID FOR OPERATION OF THE EQUIPMENT AT ANOTHER LOCATION, EXCEPT FOR PORTABLE EQUIPMENT. RULE 10C REQUIRES THIS PERMIT TO OPERATE OR COPY BE POSTED ON OR WITHIN 25 FEET OF THE EQUIPMENT, OR MAINTAINED READILY AVAILABLE AT ALL TIMES ON THE OPERATING PREMISES. PERMITTEE EQUIPMENT ADDRESS APPLIED ENERGY APPLIED ENERGY GEN MGR SAN DIEGO FACILITIES QUAY & ROGERS RD, # BALBOA AVE. #D NAS NORTH ISLAND CNTRL STM PLT SAN DIEGO CA SAN DIEGO CA EQUIPMENT DESCRIPTION COGENERATION NATURAL GAS FIRED COMBUSTION TURBINE, MAKE GE, MODEL LM6000PD, 42 MEGAWATT MAXIMUM RATED POWER OUTPUT, WITH DRY LOW NOX (DLN) BURNER, 50 MMBTU/HOUR JOHN ZINK DUCT BURNER, STEAM TURBINE, EMISSION CONTROL EQUIPMENT INCLUDE SCR (AT LEAST 650 CUBIC FEET OF CATALYST) WITH AMMONIA INJECTION AND OXIDATION CATALYST, SYSTEM EQUIPPED WITH VIM TECHNOLOGIES DATA ACQUISITION SYSTEM (DAS), AND CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) EVERY PERSON WHO OWNS OR OPERATES THIS EQUIPMENT IS REQUIRED TO COMPLY WITH THE CONDITIONS LISTED BELOW AND ALL APPLICABLE REQUIREMENTS AND DISTRICT RULES, INCLUDING BUT NOT LIMITED TO RULES 53, 62, 68, FAILURE TO OPERATE IN COMPLIANCE IS A MISDEMEANOR AND IS SUBJECT TO CIVIL AND CRIMINAL PENALTIES. A. FEDERALLY- ENFORCEABLE AND DISTRICT-ENFORCEABLE CONDITIONS 1. The combustion turbine is subject to 40 CFR Part 60 Subpart KKKK ( through ) STANDARDS OF PERFORMANCE FOR STATIONARY COMBUSTION TURBINES, which includes, but is not limited to, those conditions of this permit that are applicable requirements pursuant to this federal regulation. (40 CFR 60 Subpart KKKK) 2. The permittee shall comply with the applicable requirements in 40 CFR Part 60. (Rule 1421) 3. Air pollution control equipment, monitoring equipment, and the stationary combustion turbine shall be operated and maintained in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown, and malfunction. [40 CFR 60 Subpart KKKK (a)] 4. For the purposes of this Permit to Operate, startup period shall be defined as the time fuel flow begins following a non-operational period and shall continue for no longer than 60 consecutive minutes. Shutdown period shall be defined as the 30 minute period preceding the moment at which fuel flow ceases. The Data Acquisition System (DAS) shall record these events. (40 CFR Part 60, Appendix B and Appendix F)

13 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO Power output (net MW) to the grid shall not exceed 42 MW. (NSR) 6. The Emission unit shall be fired on Public Utility Commission (PUC) quality natural gas only. The permittee shall maintain quarterly records of sulfur content (grains/100 dscf) and higher and lower heating values (Btu/dscf) of the natural gas and provide such records to the District personnel upon request. [Rule 62; 40 CFR 60 Subpart KKKK] 7. The fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel must specify that the total sulfur content for natural gas is 20 grains of sulfur or less per 100 standard cubic feet. (40 CFR 60 Subpart KKKK (a)) 8. The performance test must be done at any load condition within plus or minus 25 percent of 100 percent of peak load. Testing may be performed at the highest achievable load point, if at least 75 percent of peak load cannot be achieved in practice. Three separate test runs are required for each performance test. The minimum time per run is 20 minutes. (40 CFR 60 Subpart KKKK (b); Rule 21) 9. For purposes of determining compliance based on source testing, the average of three subtests shall be used. For purposes of determining compliance with emission limits based on the CEMS, data collected in accordance with the CEMS protocol shall be used and averaging periods shall be as specified herein. (District Rule (g)(6 ) & (7)) 10. Emissions of oxides of nitrogen (NOx), including during startup and shutdown periods, shall not exceed 25 ppm at 15 percent O2, on a 30 day rolling average basis, as described in 40 CFR Subpart KKKK (b)(1) when the turbine is operating at 75% or more of peak load. (40 CFR Subpart KKKK , (b)(1) and Table I of Appendix) 11. Emissions of oxides of nitrogen (NOx), including during startup and shutdown periods, shall not exceed 96 ppm at 15 percent O2, on a 30 day rolling average basis, as described in 40 CFR Subpart KKKK (b)(1) when the turbine is operating at less than 75% of peak load. (40 CFR Subpart KKKK , (b)(1) and Table I of Appendix) 12. During any startup period, the emissions from the unit exhaust stack shall not exceed the following limits as determined by the continuous emission monitoring system (CEMS): Pollutant Limit, lbs/event Oxides of Nitrogen (NOx), calculated as NO2 43 Carbon Monoxide (CO) 57 (NSR)

14 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO During any shutdown period, the emissions from the unit exhaust stack shall not exceed the following limits as determined by the continuous emission monitoring system (CEMS): Pollutant Limit, lbs/event Oxides of Nitrogen (NOx), calculated as NO Carbon Monoxide (CO) 40.8 (NSR) 14. The emissions of oxides of nitrogen (NOx), calculated as nitrogen dioxide (NO2), from the unit emission stack shall not exceed 2.0 parts per million by volume on a dry basis (ppmvd) corrected to 15% oxygen. Compliance with this limit shall be demonstrated continuously based on the CEMS data and during source testing. This limit shall be based on a clock hour averaging period. This limit shall not apply during the startup and shutdown periods as defined herein. (NSR) 15. The emissions of CO from the unit exhaust stack shall not exceed 24 parts per million by volume on a dry basis (ppmvd) corrected to 15% oxygen. Compliance with this limit shall be demonstrated continuously based on the CEMS data and during source testing. This limit shall be based on a clock hour averaging period. This limit shall not apply during the startup and shutdown periods as defined herein. (NSR) 16. The emissions of VOC, calculated as methane, from the unit exhaust stack, shall not exceed 2.0 ppmvd corrected to 15% oxygen. Compliance with this limit shall be demonstrated during source testing. This limit shall be based on a clock hour averaging period. This limit shall not apply during startup and shutdown periods as defined herein. (NSR) 17. The emissions from the unit exhaust stack shall not exceed the following limits, except during the startup and shutdown periods, as determined by the continuous emission monitoring system (CEMS) for NOx and CO, and based upon source testing calculated as the average of three subtests. These limits shall be based on a clock hour averaging period: Pollutant Limit, lbs/hour Oxides of Nitrogen (NOx), calculated as NO2 3.4 Carbon Monoxide (CO) 24.6 Volatile Organic Compounds (VOC) 1.2 (NSR) 18. The emissions from the unit exhaust stack shall not exceed the following limits, as determined by the continuous emission monitoring system (CEMS) for NOx and CO. VOC emissions shall be based upon emission factors derived from annual source testing. Compliance with each limit shall be based on a rolling 12-calendar month averaging period.

15 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO Pollutant Limit, tons/year Oxides of Nitrogen (NOx), calculated as NO Carbon Monoxide (CO) Volatile Organic Compounds (VOC) 5.2 (NSR) 19. For each affected unit required to continuously monitor parameters or emissions the permittee must submit reports of excess emissions and monitor downtime, in accordance with 60.7(c). Excess emissions must be reported for all periods of unit operation, including start-up, shutdown, and malfunction. (40 CFR 60 Subpart KKKK (a)) 20. An excess emissions is any unit operating period in which the 30-day rolling average NOX emission rate exceeds 25 ppm for periods of operation at 75 percent of peak load or greater, or 96 ppm for periods of operation at less than 75 percent of peak load.. For the purposes of this subpart, a 30-day rolling average NOX emission rate is the arithmetic average of all hourly NOX emission data in ppm measured by the continuous emission monitoring equipment for a given day and the twenty-nine unit operating days immediately preceding that unit operating day. A new 30-day average is calculated each unit operating day as the average of all hourly NOX emissions rates for the preceding 30 unit operating days if a valid NOX emission rate is obtained for at least 75 percent of all operating hours. (40 CFR 60 Subpart KKKK (b)(1) and Subpart KKKK Appendix, Table 1) 21. The permittee must identify excess emissions for the CEMS according to 40 CFR (40 CFR 60 Subpart KKKK ) 22. Monitoring and compliance reports must be submitted pursuant to 40 CFR as follows: (a) For each affected unit required to continuously monitor parameters or emissions, the permittee must submit reports of excess emissions and monitor downtime, in accordance with 60.7(c). Excess emissions must be reported for all periods of unit operation, including start-up, shutdown, and malfunction. (40 CFR 60 Subpart KKKK (a)) 23. For a combined cycle and CHP turbine system with supplemental heat (duct burner), the permittee must measure the total NOX emissions after the duct burner rather than directly after the turbine. The duct burner must be in operation during the performance test. (40 CFR Part 60 KKKK, (b)(2)) 24. Unless otherwise specified in this permit or authorized in writing by the District, within 45 calendar days after completion of a source test or RATA performed by an independent contractor, a final test report shall be submitted to the District for review and approval. (District Rules 20.3(d)(1) and 1200 and 40 CFR 60 Subpart KKKK; 40

16 CFR 60.8) COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO When the CEMs is not recording data and the unit is operating, hourly NOx emissions for the annual emission calculations shall be determined in accordance with 40 CFR 75 Appendix C. Additionally, hourly CO emissions for the annual emission calculations shall be determined using the hourly emission rate recorded by the CEMs during the most recent hours in which the unit operated 3 continuous hours at no less than 80% of full power rating. Alternate CO emission factors shall be determined from compliance source test emissions data. The alternate hourly CO emission rate shall be reviewed and approved by the District, in writing. (NSR) 26. Ammonia emissions from the unit exhaust stack shall not exceed 10 parts per million volume on a dry basis (ppmvd) corrected to 15% oxygen, averaged over a clock hour. This limit shall not apply during the startup and shutdown periods. Compliance with this limit shall be demonstrated by source testing and utilizing one of the following procedures: a. Calculate ammonia emissions using the following equation: NH3 =( (a - b*(c*1.2) / 1,000,000) * (1,000,000 / b) ) * d Where: a = ammonia injection rate (lbs/hour) / (17.0 lbs/lb-mole), b = dry exhaust flow rate (scft/hr) / (385 scft/lb-mol) c = change in measured NOx concentration 15% oxygen) across the catalyst, d = ratio of measured ammonia slip to calculated ammonia slip as derived during annual source testing b. Other calculation method using measured surrogate parameters to determine the ammonia emissions in oxygen, as approved by the District. (Rule 1200) 27. Visible emissions, including emissions from the lube oil vents and the exhaust stack of the unit shall not exceed 20% opacity for more than three (3) minutes in any period of 60 consecutive minutes. (Rule 50) 28. The emissions of any single federal Hazardous Air Pollutant (HAP) shall not equal or exceed 10 tons, and the aggregate emissions of all federal HAPs shall not equal or exceed 25 tons in any rolling 12-calendar month period. Compliance with these single and aggregate HAP limits shall be based on a methodology approved by the District for the purpose of calculating HAP emissions for this permit. If emissions exceed these limits, the permittee shall apply to amend permit to reflect applicable federal Maximum Achievable Control Technology (MACT) standards and requirements in accordance with applicable provisions (including timing requirements) of 40 CFR Part 63. (40 CFR Part 63) 29. When the combustion turbine is operating, ammonia shall be injected at all times that the associated SCR catalyst inlet temperature is 650 degrees Fahrenheit or greater. (NSR) 30. Except during startups and shutdowns the air pollution control system including the

17 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO water injection system, if equipped with water injection, and the ammonia injection system serving the SCR, shall be in operation in accordance with manufacturer's specifications at all times when the unit is in operation. All manufacturer's specifications shall be maintained on site or at a District-approved alternate location and made available to District personnel within 48 hours after request. (NSR, Rule 1200) 31. In the event of a breakdown in an automatic ammonia injection control system, the unit shall be shut down or a trained operator shall operate the ammonia injection control system manually and the breakdown shall be reported to the District Compliance Division pursuant to Rule 98(b)(1) and 98(e). (Rule 98) 32. The unit shall be equipped with continuous monitors to measure or calculate and record the following operational characteristics: i. Hours of operation (hours), ii. Natural gas flow rate (kscfh) for the turbine and the duct burner individually, iii. Heat input rate (MMBtu /hr) for the turbine and the duct burner individually, iv. Exhaust gas temperature (ºF), v. Power output (MW). vi. SCR inlet temperature( F) vii. Ammonia injection rate (lbs/hour) These parameters shall be continuously monitored. These monitors shall be calibrated and maintained in accordance with the manufacturer's recommended procedures and a protocol approved by the District. Calibrating records for the continuous monitors shall be maintained on site and made available to the District upon request. (District Rules 69.3, , 20.3(d)(1); 40 CFR Part 60 and Subpart KKKK ) 33. Fuel flow meters shall be installed and maintained to measure the fuel flow rate corrected for temperature and pressure. Correction factors and constants shall be maintained on site and made available to the District upon request. (District Rules 69.3, , 20.3(d)(1); 40 CFR Part 60 and Subpart KKKK ) 34. This unit shall be source tested once each permit year (annual source test) to demonstrate compliance with the NOx, CO, VOC, and Ammonia emission standards of this permit, using District approved methods. For the purposes this permit, a permit year is the 12-month period ending on the last day of the permit expiration month. It is the responsibility of the permittee to schedule the source test with the District. The source test shall be performed or witnessed by the District. Each annual source test shall be separated by at least 90 days from any annual source test

18 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO performed in a different permit year. (District Rules 69.3, , 1200, 20.3(d)(1); 40 CFR 60 Subpart KKKK ) 35. Continuous emission monitoring system (CEMS) shall be installed and properly maintained and calibrated to measure, calculate and record the following, in accordance with the District approved CEMS protocol: a. Percent oxygen (O2) in the exhaust gas (%); b. Average concentration of oxides of nitrogen (NOx) for each clock hour period, in parts per million (ppmvd) corrected to 15% oxygen; c. Average concentration of carbon monoxide (CO) for each clock hour period, in parts per million (ppmvd) corrected to 15% oxygen; d. Hourly mass emissions of oxides of nitrogen (NOx), in pounds/hour; e. Hourly mass emissions of carbon monoxide (CO), in pounds/hour; f. Cumulative mass emissions of oxides of nitrogen (NOx) in each startup and shutdown period, in pounds; g. Cumulative mass emissions of carbon monoxide (CO) in each startup and shutdown period, in pounds; h. Annual mass emissions of oxides of nitrogen (NOX), in tons; i. Annual mass emission of carbon monoxide (CO), in tons. j. Natural gas flow rate to turbine in hscf/hr. k. Natural gas flow rate to duct burner in hscf/hr l. Calculated ammonia slip concentration for each clock hour period, in parts per million corrected to 15% oxygen. (District Rules 69.3, , 20.3; 40 CFR 60 Subpart KKKK; 40 CFR Part 75) 36. Any violation of any emission standard as indicated by the CEMS shall be reported to the District's Compliance Division within 96 hours after such occurrence. (CA Health and Safety Code, Division 26, Part 4, Chapter ) 37. The CEMs shall be maintained and operated, and reports submitted, in accordance with the requirements of Rule 19.2 sections (d), (e), (f)(2),(f)(3), (f)(4) and (f)(5) and CEMs protocol approved by the District. (NSR) 38. The oxides of nitrogen (NOx) and oxygen (O2) components of the CEMS shall be certified and maintained in accordance with Rule (e)(2). The carbon monoxide

19 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO (CO) component of the CEMS shall be certified and maintained in accordance with District Rule 19, 40 CFR 60, appendices B and F and the CEMS Protocol approved by the District. (District Rules 69.3, , 20.3(d)(1); 40 CFR 60 Subpart KKKK; 40 CFR 60, appendices B and F) 39. The CEMS shall be in operation in accordance with the District approved CEMS Protocol at all times when the turbine is in operation. A copy of the District approved CEMS Protocol shall be maintained on site and made available to District personnel upon request. (District Rules 69.3, , and 20.3(d)(1); 40 CFR 60 Subpart KKKK) 40. An operating log or data acquisition and handling system (DAHS) records shall be maintained either on site or at a District-approved alternate location to record actual times and durations of all startups and shutdowns, quantity of fuel used (scf) and energy generated (MW-hr), (monthly and annually by calendar year), hours of daily operation and total cumulative hours of operation (monthly and annually by calendar year). (NSR, District Rule ; 40 CFR 60 Subpart KKKK) 41. The District shall be notified at least two weeks prior to any changes made in CEMS software that affect the measurement, calculation or correction of data displayed and/or recorded by the CEMS. [NSR] 42. The permittee shall file semiannual reports in accordance with 40 CFR (40 CFR 60 Subpart KKKK (a)) 43. Each semiannual report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. Each such semiannual compliance report shall be postmarked or delivered no later than January 30 or July 30, whichever date is the first date following the end of the semiannual reporting period. (40 CFR 60 Subpart KKKK; Rule 21) 44. All semiannual compliance reports shall be submitted to the District Compliance Division. (40 CFR 60.7) 45. Except as specified herein, all records required by this permit shall be maintained onsite for a minimum of five years and made available to District personnel upon request. If this site becomes unmanned, the permittee shall submit an alternate site for the maintenance of records to the District for approval. (Rule 1421) 46. Access, facilities, utilities and any necessary safety equipment for source testing and inspection shall be provided upon request of the Air Pollution Control District. Rule 19) B. DISTRICT-ONLY--ENFORCEABLE CONDITIONS 47. This Air Pollution Control District Permit does not relieve the holder from obtaining permits or authorizations required by other governmental agencies.

20 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2010-PTO The permittee shall, upon determination of applicability and written notification by the District, comply with all applicable requirements of the Air Toxics "Hot Spots" Information and Assessment Act (California Health and Safety Code Section et seq.)

21 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO. APCD2006-PTO PERMIT TO OPERATE THE FOLLOWING IS HEREBY GRANTED A PERMIT TO OPERATE THE ARTICLE, MACHINE, EQUIPMENT OR CONTRIVANCE DESCRIBED BELOW. THIS PERMIT IS NOT TRANSFERABLE TO A NEW OWNER NOR IS IT VALID FOR OPERATION OF THE EQUIPMENT AT ANOTHER LOCATION, EXCEPT FOR PORTABLE EQUIPMENT. RULE 10C REQUIRES THIS PERMIT TO OPERATE OR COPY BE POSTED ON OR WITHIN 25 FEET OF THE EQUIPMENT, OR MAINTAINED READILY AVAILABLE AT ALL TIMES ON THE OPERATING PREMISES. PERMITTEE EQUIPMENT ADDRESS APPLIED ENERGY APPLIED ENERGY GEN MGR SAN DIEGO FACILITIES QUAY & ROGERS RD, # BROADWAY #1500 NAS NORTH ISLAND CNTRL STM PLT SAN DIEGO CA SAN DIEGO CA EQUIPMENT DESCRIPTION BOILER, STEAM GENERATOR (179 MM BTU/HR INPUT): NEBRASKA MODEL NS-6-99, DISTILLATE OIL- FIRED, MFR. ID #2D1752. FUEL LINE IS EQUIPPED WITH A NON-RESETTABLE, TOTALIZING FUEL FLOW METER. EVERY PERSON WHO OWNS OR OPERATES THIS EQUIPMENT IS REQUIRED TO COMPLY WITH THE CONDITIONS LISTED BELOW AND ALL APPLICABLE REQUIREMENTS AND DISTRICT RULES, INCLUDING BUT NOT LIMITED TO RULES 53, 62, 68 AND FAILURE TO OPERATE IN COMPLIANCE IS A MISDEMEANOR AND IS SUBJECT TO CIVIL AND CRIMINAL PENALTIES. A. FEDERALLY-ENFORCEABLE AND DISTRICT-ENFORCEABLE CONDITIONS 1. Permittee shall comply with all applicable requirements of Rules 53 and 62. [Rules 53 & 62] 2. Provided the equipment described above is operated in compliance with all of the section A conditions listed below as they exist on the date of issuance of this permit, a permit shield is granted from enforcement action for the following applicable requirements: Rule 69.2 sections (d), (e)(2), (f) and (g). [Rule 1410] 3. Permittee shall tune the boiler annually according to the procedures outlined in Rule 69.2 section (j). The tune-up shall be performed prior to annual permit renewal, unless otherwise directed in writing by the District. [Rule 69.2] 4. Permittee shall comply with the applicable monitoring and recordkeeping requirements of Rule 69.2 section (e). [Rule 69.2] 5. Maximum calendar year fuel usage shall not exceed 10 percent of the annual capacity factor. [Rule 69.2] 6. The maximum emissions of NOx shall not exceed 225 ppmv, calculated as nitrogen 3% oxygen, on a dry basis. [Rule 68] 7. The applicable test methods listed in rule 68 section (f) and SDCAPCD test method 100 shall be used to determine compliance with the NOx emission limits listed above. [Rule 68] 8. Access, facilities, utilities and any necessary safety equipment for source testing and inspection shall be provided upon request of the Air Pollution Control District. (Rule 19) Page 1

22 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT 9150 CHESAPEAKE DRIVE, SAN DIEGO, CA (858) FAX(858) PERMIT NO. APCD2006-PTO PERMIT TO OPERATE B. DISTRICT-ONLY--ENFORCEABLE CONDITIONS 8. The permittee shall, upon determination of applicability and written notification by the District, comply with all applicable requirements of the Air Toxics Hot Spots Information and Assessment Act (California Health and Safety Code Section et. seq.). [Air Toxics Hots Spots] 9. This Air Pollution Control District permit does not relieve the holder from obtaining permits or authorization required by other governmental agencies. Page 2

23 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO PERMIT TO OPERATE THE FOLLOWING IS HEREBY GRANTED A PERMIT TO OPERATE THE ARTICLE, MACHINE, EQUIPMENT OR CONTRIVANCE DESCRIBED BELOW. THIS PERMIT IS NOT TRANSFERABLE TO A NEW OWNER NOR IS IT VALID FOR OPERATION OF THE EQUIPMENT AT ANOTHER LOCATION, EXCEPT FOR PORTABLE EQUIPMENT. RULE 10C REQUIRES THIS PERMIT TO OPERATE OR COPY BE POSTED ON OR WITHIN 25 FEET OF THE EQUIPMENT, OR MAINTAINED READILY AVAILABLE AT ALL TIMES ON THE OPERATING PREMISES. PERMITTEE EQUIPMENT ADDRESS APPLIED ENERGY APPLIED ENERGY GEN MGR SAN DIEGO FACILITIES QUAY & ROGERS RD, # BALBOA AVE. #D NAS NORTH ISLAND CNTRL STM PLT SAN DIEGO CA SAN DIEGO CA EQUIPMENT DESCRIPTION FIRE PUMP: CATERPILLAR ENGINE, MODEL 3208, 165 BHP, S/N 90N71269 EVERY PERSON WHO OWNS OR OPERATES THIS EQUIPMENT IS REQUIRED TO COMPLY WITH THE CONDITIONS LISTED BELOW AND ALL APPLICABLE REQUIREMENTS AND DISTRICT RULES, INCLUDING BUT NOT LIMITED TO RULES 53, 62, 68, 69.3, AND NSPS SUBPART GG. FAILURE TO OPERATE IN COMPLIANCE IS A MISDEMEANOR AND IS SUBJECT TO CIVIL AND CRIMINAL PENALTIES. A. FEDERALLY- ENFORCEABLE AND DISTRICT-ENFORCEABLE CONDITIONS 1. The engine shall be operated exclusively during emergencies as defined in Rule or Rule 12 or 17CCR93115 as applicable, or for maintenance and testing. (Rule 12 or Rule or 17CCR93115) 2. Engine operation for maintenance and testing purposes shall not exceed 35 hours per calendar year unless otherwise required by the National Fire Protection Association (NFPA) Section 25. (17 CCR 93115) 3. Permittee must operate and maintain the stationary engine and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The periodic maintenance shall be conducted at least once per calendar year. [Rule 12, 17 CCR 93115, and 40CFR Subpart ZZZZ (e)(6)] 4. The engine and any associated control equipment and monitoring equipment, shall be operated and maintained at all times in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require further efforts to reduce emissions if the equipment is in compliance with all requirements of this authorization. Compliance with this requirement will be based on available information, including but not limited to operations and maintenance procedures, control systems statements, records, test results and reports and equipment inspection. (40 CFR Subpart ZZZZ (b))

24 COUNTY OF SAN DIEGO, AIR POLLUTION CONTROL DISTRICT OLD GROVE RD, SAN DIEGO, CA (858) FAX (858) PERMIT NO The owner or operator shall minimize engine operating 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.(40 CFR Subpart ZZZZ (h)) 6. This engine shall not operate for non-emergency use during the following periods, as applicable: (a) whenever there is any school sponsored activity, if engine is located on school grounds or (b) between 7:30am and 3:30pm on days when school is in session, if the engine is located within 500 feet of, but not on, school grounds. This condition shall not apply to an engine located at or near any school grounds that also serve as the students' place of residence. (17 CCR 93115) 7. This engine shall only use CARB diesel fuel. (Rule 12, 17 CCR 93115) 8. The equipment described above shall not cause or contribute to a public nuisance. (Rule 51) 9. Visible emissions including crank case smoke shall comply with Air Pollution Control District Rule 50. (Rule 50) 10. A non-resettable engine hour meter shall be installed on this engine, maintained in good working order, and used for recording engine operating hours. If a meter is replaced, the Air Pollution Control District's Compliance Division shall be notified in writing within 10 calendar days. The written notification shall include the following information: (a) old meter's hour reading (b) replacement meter's manufacturer name, model and serial number if available and current hour reading on replacement meter, and (c) copy of receipt of new meter or of installation work order. A copy of the meter replacement notification shall be maintained on site and made available to the Air Pollution Control District upon request. (Rule 12, 17 CCR 93115) 11. The owner or operator shall change engine oil and filter every 500 hours of operation or annually, whichever comes first; or test the oil in accordance with 40 CFR (i). (40 CFR 63 Subpart ZZZZ (a) and Table 2d(4)(a)) 12. The owner or operator shall inspect the air cleaner of a compression ignition engine or inspect spark plugs of a spark ignition engine, every 1,000 hours of operation or