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West Virginia Department of Environmental Protection Division of Air Quality Fact Sheet For Final Renewal Permitting Action Under 45CSR30 and Title V of the Clean Air Act Permit Number: R30-05100006-2009 Application Received: July 14, 2008 Plant Identification Number: 05100006 Permittee: Ohio Power Company Facility Name: Kammer Plant/Cresap Mailing Address: P.O. Box K, Moundsville, WV 26041 Physical Location: UTM Coordinates: Directions: Moundsville, Marshall County, West Virginia 515.52 km Easting • 4,410.48 km Northing • Zone 17 From Charleston, take I-77 North to exit 179. Travel north on State Route 2 approximately 70 miles to Cresap. Facility is located on Route 2 approximately 9 miles south of Moundsville, WV. Facility Description The Kammer Plant is a fossil fuel fired electric generation facility and operates under Standard Industrial Classification (SIC) code 4911. The facility consists of three (3) coal-fired steam generators with a rated design capacity of 2156 mmBtu/hr each, various supporting operations such as coal handling, limestone handling and ash handling, and various tanks with insignificant emissions. The facility has the potential to operate seven (7) days per week, twenty-four (24) hours per day and fifty-two (52) weeks per year. This renewal also includes Coal blending project submitted as minor modification to the current permit on October 3, 2008. Title V Fact Sheet R30-05100006-2009 Ohio Power Company Kammer Plant/Cresap Page 2 of 9 Emissions Summary Plantwide Emissions Summary [Tons per Year] Regulated Pollutants Potential Emissions 2006 Actual Emissions Carbon Monoxide (CO) 2,179 329.5 Nitrogen Oxides (NOX) 31,234 10,896.2 Particulate Matter (PM2.5) 537.35 N/A Particulate Matter (PM10) 1,012.15 N/A Total Particulate Matter (TSP) 1,515.3 68.7 Sulfur Dioxide (SO2) 76,491 41,155.9 Volatile Organic Compounds (VOC) 249.3 73.0 PM10 is a component of TSP. Hazardous Air Pollutants Potential Emissions 2006 Actual Emissions Hydrogen Chloride 5,783 1,530 Hydrogen Fluoride 502 81 Selenium 22.7 2 Other HAPs 16.25 0.84 Some of the above HAPs may be counted as PM or VOCs. Title V Program Applicability Basis This facility has the potential to emit 76,491 tons per year of SO 2, 31,234 tons per year NOX, 1,515.3 tons per year PM, 2,179 tons per year CO and 249.3 tons per year VOCs and 6,324 tons per year HAPs. Due to this facility's potential to emit over 100 tons per year of criteria pollutant, over 10 tons per year of a single HAP, and over 25 tons per year of aggregate HAPs, Kammer Plant is required to have an operating permit pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30. This facility is also subject to Title IV (Acid Rain) requirements and therefore is required to have an operating permit pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30. Legal and Factual Basis for Permit Conditions The State and Federally-enforceable conditions of the Title V Operating Permits are based upon the requirements of the State of West Virginia Operating Permit Rule 45CSR30 for the purposes of Title V of the Federal Clean Air Act and the underlying applicable requirements in other state and federal rules. This facility has been found to be subject to the following applicable rules: Federal and State: 45CSR1 45CSR2 45CSR6 45CSR10 NOX Budget Trading Program as a Means of Control and Reduction of Nitrogen Oxides Control of particulate matter emissions from indirect heat exchangers. Open burning prohibited. Control of sulfur dioxide emissions from indirect heat exchangers. West Virginia Department of Environmental Protection Division of Air Quality Title V Fact Sheet R30-05100006-2009 Ohio Power Company Kammer Plant/Cresap Page 3 of 9 45CSR11 45CSR13 Standby plans for emergency episodes. Permits for Construction, Modification, Relocation and Operation of Stationary sources 45CSR16 Standards of performance for new stationary sources pursuant to 40 C.F.R. Part 60 WV Code § 22-5-4 (a) (14) The Secretary can request any pertinent information such as annual emission inventory reporting 45CSR26 NOX Budget Trading Program as A Means of Control and Reduction of Nitrogen Oxides from Electric Generating Units 45CSR30 Operating permit requirement. 45CSR33 Acid Rain Provisions and Permits 45CSR38 Determination of Compliance With Air Quality Management Rules 40 C.F.R. Part 61 Asbestos inspection and removal 40 C.F.R. Part 64 Compliance Assurance Monitoring 40 C.F.R. Part 72 Permits Regulation 40 C.F.R. Part 73 Sulfur Dioxide Allowance System Permits Regulation 40 C.F.R. Part 74 Sulfur Dioxide Opt-ins 40 C.F.R. Part 75 Continuous Emissions Monitoring 40 C.F.R. Part 76 Nitrogen Oxides Reduction Program 40 C.F.R. Part 77 Excess Emissions 40 C.F.R. Part 78 Appeals Procedure for Acid Rain Program 40 C.F.R. Part 82, Subpart F Ozone depleting substances 40 C.F.R. Part 60, Subpart Y Coal Preparation Plants State Only: 45CSR4 WVDAQ Letter WVDAQ Letter 45CSR37 45CSR39 45CSR40 45CSR41 No objectionable odors. Letter dated September 3, 2002 addressed to Mr. Greg Wooten and signed by Jesse D. Adkins regarding the thermal decomposition of boiler cleaning solutions. Letter dated January 21, 2004 addressed to Mr. Frank Blake and signed by Jesse D. Adkins regarding the combustion of Demineralizer Resins. Mercury Budget Trading Program NOx Annual Trading Program NOx Ozone Season Trading Program SO2 Trading Program Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 45CSR30 or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such. The Secretary's authority to require standards under 40 C.F.R. Part 60 (NSPS), 40 C.F.R. Part 61 (NESHAPs), and 40 C.F.R. Part 63 (NESHAPs MACT) is provided in West Virginia Code §§ 22-5-1 et seq., 45CSR16, 45CSR15, 45CSR34 and 45CSR30. Active Permits/Consent Orders Permit or Consent Order Number Date of Issuance August 11, 2005 R13-1679A Permit Determinations or Amendments That Affect the Permit (if any) PD05-119; no permit needed for delivery of coal by truck May 12, 2006 West Virginia Department of Environmental Protection Division of Air Quality Title V Fact Sheet R30-05100006-2009 Ohio Power Company Kammer Plant/Cresap Page 4 of 9 R13-1582C February 12, 2009 U.S.District Court Consent Decree regarding Civil Actions C2-99-1182, C2-05-360 and C2-04-1098 December 10, 2007 Consent Decree for NSR lawsuits R33-3947-2012-3 December 18, 2007 Title IV Acid Rain Permit NOx Budget Permit - Unit 1, 2 & 3 October 29, 2002 CO-R37-C-2008-4 April 7, 2008 Compliance order in response to decision to vacate federal Clean Air Mercury Rule Conditions from this facility's Rule 13 permit(s) governing construction-related specifications and timing requirements will not be included in the Title V Operating Permit but will remain independently enforceable under the applicable Rule 13 permit(s). All other conditions from this facility's Rule 13 permit(s) governing the source's operation and compliance have been incorporated into this Title V permit in accordance with the "General Requirement Comparison Table B" which may be downloaded from DAQ's website. Determinations and Justifications Wherever the language “current permit” is used throughout this fact sheet, it is in reference to Title V operating permit R30-05100006-2004 last modified on August 28, 2007, unless otherwise noted. U.S.District Court issued a consent decree on December 10, 2007 limiting SO2 emission beginning on Jan 1, 2010 – to address this, conditions 4.1.7 and 4.5.7 have been added to the permit. Boilers and associated equipment 45CSR2 – To Prevent and Control Particulate Air Pollution from Combustion of Fuel in Indirect Heat Exchangers PM testing in accordance with Permit Section 4.3.1 - A test was completed on July 13, 2006 and resulted in mass emission rates