air emission permit no. 11100002- 005 major amendment …a-2 04/28/11 the permittee must submit a...

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AIR EMISSION PERMIT NO. 11100002- 005 Major Amendment

IS ISSUED TO

Otter Tail Power Company/Otter Tail Corporation

OTTER TAIL POWER COMPANY - HOOT LAKE PLANT

1012 Water Plant Road Fergus Falls, Otter Tail County, Minnesota 56537

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No. 11100002-004, and authorizes the Permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220, and as such as are enforceable by U.S. Environmental Protection Agency Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70/Limits to Avoid NSR

Operating Permit Issue Date: April 8, 2009

Major Amendment Issue Date: April 27, 2011

Expiration Date: 04/08/2014 – Title I Conditions do not expire. Don Smith P.E., Manager Air Quality Permits Section Industrial Division for Paul Aasen Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit Reissuance 07/12/2001 004

• Supplemental Submittal #1 8/14/2006 004 • Supplemental Submittal #2 8/28/2006 004 • Supplemental Submittal #3 7/16/2008 004 • Supplemental Submittal #4 8/31/2008 004

Reopening due to Performance Testing 2/5/2009 005 Notification of Installation of Air Pollution Control Equipment

7/27/09 005

Major Permit Amendment 11/29/2010 005

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals

Appendix A: not used in this permit Appendix B: Modeled Parameters Appendix C: Insignificant Activities Appendix D: NOX Compliance Plans Appendix E: not used in this permit Appendix F: not used in this permit

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: TOTAL FACILITY PERMIT REISSUANCE (Permit Action 004)

The Hoot Lake Plant consist of three boilers, Boilers 1, 2, and 3, and fuel and ash handling equipment. Primary fuel for the boilers is coal. Particulate matter (PM) emissions are controlled by a baghouse on Boiler 1, electrostatic precipitators on Boilers 2 and 3, and baghouses on enclosed materials handling equipment. Nitrogen oxide (NOX) emissions from Boilers 2 and 3 are controlled with Low-NOX Burners and Overfired Air (LNB/OFA). Boilers 2 and 3 are utility boilers; boiler 1 is used to supply heat to the facility. MAJOR AMENDMENT DESCRIPTION (Permit Action 005)

• Boiler 1 (EU001), and associated Control Equipment (CE001) will be permanently disabled, and ultimately removed from the facility. All associated requirements have been removed from the permit.

• Temporary Boiler (EU012) is authorized to be installed and operated at the Facility as needed when Boilers 2 and 3 (EU002 and EU003) are out of service.

• Installation and operation of a dust suppression system in the coal crusher house (FS003) is included in the permit. There are no permit limits associated with the control equipment, as it is not used to avoid any applicable regulation, nor is it relied upon for purposes of emission inventory.

• Inclusion of approved Testing Frequency Plan (TFP) for CO emissions from EU002 and EU003, every 60 months.

TABLE A: LIMITS AND OTHER REQUIREMENTSOtter Tail Power Co - Hoot Lake Plant

11100002 - 005

Facility Name:

Permit Number:

04/28/11A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itSOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices. Modeling parameters in Appendix B are included for reference onlyand compliance with these parameters is achieved through meeting therequirements of the permit.

Minn. R. 7007.1300, subp. 3; 40 CFR Section 72.9; 40CFR Section 97.121; Minn. R. 7007.0800, subp. 2

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand record keeping specified in the control plan. The plan may be amended by thePermittee with the Commissioner's approval. If the Commissioner determines thePermittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan,then the Permittee may be required to amend the control plan and/or to install andoperate particulate matter ambient monitors as requested by the Commissioner.

Minn. Stat. Section 116.07, subd. 4a; Minn. R.7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R.7011.0150; Minn. R. 7009.0020

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCEREVIEW (NSR)

hdr

These requirements apply if a reasonable possibility (RP) as defined in 40 CFRSection 52.21(r)(6)(vi) exists that a proposed project, analyzed using theactual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test atSection 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, mayresult in a significant emissions increase (SEI). If the ATPA test is not used for theproject, or if there is no RP that the proposed project could result in a SEI, theserequirements do not apply to that project. The Permittee is only subject to thePreconstruction Documentation requirement for a project where a RP occurs onlywithin the meaning of Section 52.2(r)(6)(vi)(a).

Even though a particular modification is not subject to NSR, or where there isn't aRP that a proposed project could result in a SEI, a permit amendment,recordkeeping, or notification may still be required by Minn. R. 7007.1150 -7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following:

1. Project description2. Identification of any emission unit (EU) whose emissions of an NSR pollutantcould be affected3. Pre-change potential emissions of any affected existing EU, and the projectedpost-change potential emissions of any affected existing or new EU.4. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excluded dueto increases not associated with the modification and that the EU could haveaccommodated during the baseline period, an explanation of why the amountswere excluded, and any creditable contemporaneous increases and decreases thatwere considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R.7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potential emissionsin the hybrid test. The Permittee shall calculate and maintain a record of the sum ofthe actual and potential (if the hybrid test was used in the analysis) emissions of theregulated pollutant, in tons per year on a calendar year basis, for a period of 5years following resumption of regular operations after the change, or for a period of10 years following resumption of regular operations after the change if the projectincreases the design capacity of or potential to emit of any unit associated with theproject.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subps. 4 & 5


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-2

The Permittee must submit a report to the Agency if the annual summed (actual,plus potential if used in hybrid test) emissions differ from the preconstructionprojection and exceed the baseline actual emissions by a significant amount aslisted at 40 CFR Section 52.21(b)(23). Such report shall be submitted to theAgency within 60 days after the end of the year in which the exceedances occur.The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.


Before beginning actual construction of any project which includes any electricutility steam generating unit (EUSGU), the Permittee shall submit a copy of thepreconstruction documentation (items 1-4 under Preconstruction Documentation,above) to the Agency.

Title I Condition: 40 CFR Section 52.21(r)(6)(ii); Minn.R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

For any project which includes any EUSGU, the Permittee must submit an annualreport to the Agency, within 60 days after the end of the calendar year. The reportshall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The quantified annual emissions analyzed using the ATPA test, plus thepotential emissions associated with the same project analyzed as part of a hybridtest.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection, if that is the case.


For any project which does not include any EUSGU, the Permittee must submit areport to the Agency if the annual summed (actual, plus potential used in hybridtest) emissions differ from the preconstruction projection and exceed the baselineactual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23).Such report shall be submitted to the Agency within 60 days after the end of theyear in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions rate is exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.


OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-3

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Coal handling activities shall comply with requirements of Minn. R. 7011.0150. Minn. R. 7011.1110

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B foradditional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof a subsequent performance test on the same unit as specified by Minn. R.7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

MODELING REQUIREMENTS hdr

The parameters used in PM10 modeling for permit number 11100002-004 arelisted in Appendix B of this permit.


Modeling Triggers: For changes that do not require a permit amendment or thatrequire a minor permit amendment, and that affect any modeled parameter oremission rate documented in Appendix B, a Remodeling Submittal requirement isnot triggered. The Permittee shall keep updated records on site of all parametersand emission rates. The Permittee shall submit any changes to parameters andemission rates with the next required remodeling submittal.

For changes that require a moderate or major permit amendment and affect anymodeled parameter or emission rate, a Remodeling Submittal requirement istriggered. The Permittee shall include previously made changes to parameters andemission rates that did not trigger a remodeling submittal with this modelingsubmittal.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-4

Remodeling Submittal: The Permittee must submit to the Commissioner forapproval changes meeting the above criteria and must wait for a written approval(in the form of an issued permit amendment) before making such changes. Theinformation submitted must include, for stack and vent sources, source emissionrate, location, height, diameters, exit velocity, exit temperature, discharge direction,use of rain caps or rain hats, and, if applicable, locations and dimensions of nearbybuildings. For non-stack/vent sources, this includes the source emission rate,location, size and shape, release height, and, if applicable, any emission ratescalars, and the initial lateral dimensions and initial vertical dimensions andadjacent building heights.


Remodeling Submittal, continued:The plume dispersion characteristics due to the revisions of the information mustbe equivalent to or better than the dispersion characteristics modeled June 2006.The Permittee shall demonstrate this equivalency in the proposal. If the informationdoes not demonstrate equivalent or better dispersion characteristics, or if aconclusion cannot readily be made about the dispersion, the Permittee must submitfull remodeling.


RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, for a period of five (5) years from the date of monitoring,sample, measurement, or report. Records which must be retained at this locationinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-5

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

For changes that do not require a permit amendment:- The Permittee shall submit a Part 1 MACT application within 30 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(a).- The Permittee shall submit a Part 2 MACT application within 90 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(b).112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance,112(j) affected sources include industrial, commercial, and institutional boilers andprocess heaters; brick and structural clay products manufacturing; clay ceramicsmanufacturing.

40 CFR Section 63.52(b)(1) and 63.52(e)(1)

Extension Requests: The Permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-6

Subject Item: GP 001 Boilers 2 and 3 CO Limits

Associated Items: CE 010 Low Nox Burners

CE 011 Overfire Air

CE 012 Low Nox Burners

CE 013 Overfire Air

EU 002 Unit #2 Boiler


SV 002 Unit #2 & #3 Stack

What to do Why to do itAlternative Operating Scenarios

This permit contains limits on Carbon Monoxide (CO) emissions from the unitslisted in GP001. These limits are written as two Alternative Operating Scenarios(AOS). The Permittee must comply with AOS 1 or AOS 2 at all times. WhetherAOS 1 or AOS 2 applies depends on the CO emission factors for EU002 andEU003, as measured with a performance test. If the conditions of AOS 1 cannot bemet, the Permittee shall comply with AOS 2.

Title I Condition: To avoid classification as a majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000

Alternative Operating Scenario Recordkeeping. The Permittee shall keep a recordshowing which AOS the facility is operating under at all times. The record must bekept in a central location and be available for inspection upon request. The recordmust contain sufficient information, including test and/or monitoring data, so that itis clear which AOS the facility is operating under, and which one(s) it may beallowed to operate under.

The Permittee shall comply with AOS 2 if either of the CO emission factors (atEU002 and EU003) are not met. The Permittee may revert from AOS 2 to AOS 1under the following conditions:

1. Subsequent CO performance test(s) measure emissions no greater than theemission factors listed at EU002 and EU003; and

2. The Permittee has continued to follow AOS 1 recordkeeping requirements asdescribed at 40 CFR Section 52.21(r)(6) during the 5 years following theresumption of regular operation, regardless of AOS 2 recordkeeping requirements.

Minn. R. 7007.0800, subp. 11

AOS 1 hdr

The Permittee shall individually demonstrate that the post-modification EU002 COemission factor is less than or equal to 0.231 lb/mmBtu and that thepost-modification EU003 CO emission factor is less than or equal to 0.100lb/mmBtu.

Additional monitoring, recordkeeping, and reporting associated with this condition(beyond what is described under Subject Items EU002 and EU003) is as describedin 40 CFR Section 52.21(r)(6), and in this permit under Subject Item Total Facility,under the heading "Determining if a Project/Modification is Subject to New SourceReview."

If either emission factor is not demonstrated, the Permittee must comply with AOS2.

See Subject Items EU002 and EU003 for emission factor demonstrationrequirements.


AOS 2 hdr


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-7

Carbon Monoxide: less than or equal to 907 tons/year using 12-month Rolling Sumfor the two boilers combined. This limit applies beginning at the end of the 12thmonth following initial startup of EU002 following the LNB/OFA modification orimplementation of AOS2, as applicable. During the first 11 months following eitherinitial startup or implementation of AOS 2, as applicable, the following cumulativelimits apply:

Month 1: 200 tonsMonth 2: 400 tonsMonth 3: 500 tonsMonth 4: 600 tonsMonth 5: 700 tonsMonth 6: 750 tonsMonth 7: 800 tonsMonth 8: 825 tonsMonth 9: 850 tonsMonth 10: 875 tonsMonth 11: 900 tons

Month 1 is the month during which initial startup of EU002 following the month themodification occurs.


Carbon Monoxide: less than or equal to 1114 tons/year using 12-month RollingSum for the two boilers combined.

Minn. R. 7007.0800, subp. 2, to avoid requirement forAir Emission Risk Analysis

Monthly Recordkeeping: By the 15th day of each month, the Permittee shallcalculate and record:

1. The combined CO emissions for the previous calendar month from EU002 andEU003 (EU002 CO and EU003 CO, calculated as described under Subject ItemsEU002 and EU003, respectively), and

2. The combined CO emissions from EU002 and EU003 for the previous 12 months(12-month rolling sum).

Title I Condition: To avoid classification as a majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000; to avoid requirement for Air Emission RiskAnalysis


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-8

Subject Item: GP 002 Boilers 2 and 3 Front-Half Particulate Matter Limits

Associated Items: EU 002 Unit #2 Boiler


What to do Why to do itFront-half Particulate Matter: less than or equal to 349.3 tons/year using 12-monthRolling Sum for the two boilers combined. This limit applies beginning at the end ofthe 12th month following initial startup of EU002 and EU003 following the mercuryreduction modification. During the first 11 months following initial startup, thefollowing cumulative limits apply:


Month 1 is the month during which initial startup of EU002 following the monthinitial startup occurs.



1. The combined front half PM emissions for the previous calendar month fromEU002 and EU003 (FHPM2 and FHPM3, calculated as described under SubjectItems EU002 and EU003, respectively), and

2. The combined front half PM emissions from EU002 and EU003 for the previous12 months (12-month rolling sum).

Title I Condition: To avoid classification as a majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000; to avoid requirement for Air Emission RiskAnalysis


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-9

Subject Item: GP 003 NOX/SO2/CO2/flow monitors

Associated Items: MR 009 EU 002 SO2 CEMS

MR 010 EU 002 NOx CEMS

MR 011 EU 002 CO2 CEMS

MR 012 EU 002 Flow CEMS

MR 013 EU 003 SO2 CEMS




What to do Why to do itDaily Calibration Error (CE) Test: conduct daily CE testing of each gas monitoringsystem according to the procedures in section 6.3.1 of Appendix A to this part, andof each flow monitoring system according to the procedure in section 6.3.2 ofAppendix A to this part.

40 CFR pt. 75, Appendix B, section 2.1

Linearity Test (Acid Rain Program): due before end of each QA operating quarter(as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75,Appendix B, Sections 2.2.1, and Appendix A, Section 6.2.

40 CFR pt. 75, Appendix B, section 2.2.1; Minn. R.7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendarhalf-year following CEM Certification Test, i.e., once every two successive QAoperating quarters (calendar quarter in which there are at least 168 unit operatinghours). Conduct a RATA on all CEMS required by the Acid Rain Program, inaccordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may beperformed annually (i.e., once every four successive QA operating quarters, ratherthan once every two successive QA operating quarters) if any of the conditionslisted in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i)are met.

40 CFR pt. 75, Appendix B, section 2.3.1; Minn. R.7017.1020

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMSRelative Accuracy Test Audit (RATA)).

Minn. R. 7017.1180, subp. 2

CEMS QA/QC: The owner or operator of an affected facility shall operate,calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFRpt. 75, Appendix B as amended.

40 CFR Section 75.21

Recordkeeping: The owner or operator must retain records of all CEMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-10

Subject Item: GP 004 COMS

Associated Items: MR 019 EU002 COMS

MR 020 EU003 COMS

What to do Why to do itAll COMS shall complete a minimum of one cycle of sampling and analyzing foreach successive 10-second period and one cycle of data for each successive6-minute period.

Minn. R. 7017.1200, subp. 1, 2 & 3

Continuous Operation: COMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A COMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B,C and D of Minn. R. 7017.1090, subp. 2.

Minn. R. 7017.1090, subp. 1; 40 CFR Section 64.7(c);Minn. R. 7017.0200

QA Plan Required: Develop and implement a written quality assurance plan whichcovers each COMS. The plan shall be on site and available for inspection within30 days after monitor certification. The plan shall contain the written procedureslisted in Minn. R. 7017.1210, subp. 1.

Minn. R. 7017.1210, subp. 1; 40 CFR Section 64.7(b);Minn. R. 7017.0200

COMS QA/QC: The owner or operator of an affected facility is subject to theperformance specifications listed in 40 CFR pt. 60, Appendix B and shall operate,calibrate, and maintain each COMS according to the QA/QC procedures in Minn.R. 7017.1210.

Minn. R. 7017.1210; 40 CFR Section 64.7(b); Minn. R.7017.0200

COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic tothe opacity monitor, check the zero and upscale (span) calibration drifts at leastonce daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1.

For COMS without automatic zero adjustments: The optical surfaces exposed tothe effluent gases shall be cleaned prior to performing the zero and span driftadjustments.

For COMS with automatic zero adjustment: The optical surfaces shall be cleanedwhen the cumulative automatic zero compensation exceeds 4 percent opacity.Minimum procedures must include an automated method for producing a simulatedzero opacity condition and an upscale opacity condition as specified in 40 CFR60.13(d)(2).


COMS Calibration Error Audit: due before end of each calendar half-year followingPermit Issuance. Conduct three point calibration error audits at least 3 monthsapart but no greater than 8 months apart. Conduct audits in accordance with Minn.R. 7017.1210, subp. 3.


Attenuator Calibration: The Permittee shall have an independent testing companyconduct calibrations of each of the neutral density filters used in the calibrationerror audit according to the procedure in 40 CFR pt. 60, Appendix B, Section 7.


COMS Calibration Error Audit Results Summary: due 30 days after end of eachcalendar quarter in which the COMS calibration error audit was completed.

Minn. R. 7017.1220; 40 CFR Section 64.7(b); Minn. R.7017.0200

Recordkeeping: The owner or operator must retain records of all COMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

Minn. R. 7017.1130


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-11

Subject Item: EU 002 Unit #2 Boiler

Associated Items: CE 002 Electrostatic Precipitator - High Efficiency


CE 013 Overfire Air

CE 014 Carbon Injection

GP 001 Boilers 2 and 3 CO Limits

GP 002 Boilers 2 and 3 Front-Half Particulate Matter Limits





MR 017 EU002 O2 monitor

MR 019 EU002 COMS


What to do Why to do itEMISSION AND OPERATING LIMITS hdr

Particulate Matter < 10 micron: less than or equal to 0.47 lbs/million Btu heat input 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Total Particulate Matter: less than or equal to 0.60 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 3.0 lbs/million Btu heat input and 1770.0 lb/hrbased on a one-hour average.


Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 3-hourAverage

Minn. R. 7011.0510, subp. 1

Nitrogen Oxides: less than or equal to 0.40 lbs/million Btu heat input on an annualaverage basis.

40 CFR Section 76.7(a)(1) and 40 CFR Section76.8(a)(2)

Carbon Monoxide: less than or equal to 0.231 lbs/million Btu heat input. (This is anemission factor and not a limit.) The Permittee shall validate this factor throughperformance testing. If performance testing shows a factor greater than 0.231lb/mmBtu, the Permittee shall meet the requirements of AOS 2 under Subject ItemGP001.

Title I Condition: To avoid classification as a majoramendment under 40 CFR Section 52.21 and Minn. R.7007.3000

Opacity: less than or equal to 20 percent opacity using 6-minute Average except forone six-minute period per hour of not more than 60 percent opacity.

Minn. R. 7011.0510, subp. 2

Allowed Fuels: lignite, sub-bituminous coal, distillate oil, used oil, non-hazardousoil spill cleanup materials and non-hazardous boiler cleaning agents.

Minn. R. 7007.0800, subp. 2

Allowed boiler cleaning agents: EDTA type generated on-site, 5% of total mass orheat input, oxygen limited to 3% or greater, agents may only be burned while theboiler is operating at 75 percent of rated capacity or greater.

Minn. R. 7007.0800, subp. 2

Allowed oil cleanup materials: commercial floor dry, commercial sorbent pads andtubes, sawdust, rags/paper towels. Waste must be a minimum of 5000 Btu's perpound in accordance with Minn. R. 7045.0805, and is limited to 5% of mass inputunless stack emission testing for Total Particulate Matter is conducted at a higherinput level.

Minn. R. 7007.0800, subp. 2; Minn. R. 7045.0790 to 7045.0990

Combust used oil in accordance with used oil regulations, Minn. R. ch. 7045, andlimit to 5% of total mass or heat input on an hourly basis.

Minn. R. 7007.0800, subp. 2

Maintain records of total amount of used oil, boiler cleaning agents or oilcontaminated clean up materials burned per day when those materials are burned,and the ratio burned to other fuel in order to demonstrate compliance with the usedoil input limits, and used oil cleanup materials input limits.

Minn. R. 7007.0800, subp. 5

The Permittee shall operate EU002 so that excess oxygen (O2) measured by theO2 monitor meets or exceeds a value based on data measured during the mostrecent performance test evaluating the EU002 CO emission factor.


CONTROL REQUIREMENTS(see Subject Item CE002 for specific control equipment operating requirements)

hdr


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-12

The Permittee shall operate and maintain the ESP (CE002) at any time that theprocess equipment controlled by the ESP (EU002) is in operation. The Permitteeshall document periods of non-operation of the control equipment. See SubjectItem CE002 for specific operating requirements.

Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain CE002 such that it achieves a controlefficiency for Particulate Matter < 10 micron: greater than or equal to 97 percentcontrol efficiency

Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain CE002 such that it achieves a controlefficiency for Total Particulate Matter: greater than or equal to 97 percent controlefficiency

Minn. R. 7007.0800, subp. 2 and 14

If installed, the Permittee shall operate and maintain the carbon injection mercurycontrol system (CE014) at any time that the process equipment is combusting coal.The Permittee shall document periods of non-operation of the control equipment.See Subject Item CE014 for specific operating requirements.

Minn. R. 7007.0800, subp. 2 and 14

PERFORMANCE TEST REQUIREMENTS hdr

Performance Test: due before end of each calendar 60 months starting 12/03/2008to measure CO emissions while burning sub-bituminous coal, to determine a COemission factor on a lb/mmBtu basis.

If the CO emission factor is greater than 0.231 lb/mmBtu, the Permittee shallcomply with AOS 2 (See Subject Item GP001).

Title I Condition: To avoid classification as a majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000; Minn. R. 7017.2020

Performance Test: due 180 days after Startup of operations with lignite to measureCO emissions while burning lignite, to determine a CO emission factor on alb/mmBtu basis.



Initial Performance Test: due 180 days after Startup of the mercury control system(CE014). Conduct performance test to measure front half particulate matteremissions while burning coal to determine a front half PM emission factor on alb/mmBtu basis. The test shall be performed at the same (or higher) activatedcarbon injected rate as was recorded during the most recent mercury performancetest. Separate tests shall be conducted for sub-bituminous coal and lignite (if used)to determine separate emission factors.


Performance Test: due before end of each calendar 60 months starting 08/31/2006to determine compliance with the PM10 emission limit. The test shall be conductedat an interval not to exceed 60 months between test dates.

Minn. R. 7017.2020 subp. 1

Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the total particulate matter emission limit. The test shallbe conducted at an interval not to exceed 60 months between test dates.

Minn. R. 7017.2020 subp. 1

Performance Test Notifications and Submittals;

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-Test Meeting: due 7 day before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy or CD: due 105 day after eachPerformance Test.The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. R. 7017.2030, subp. 1-4; Minn. R. 7017.2018and Minn. R. 7017.2035, subp. 1-2

STET (Short Term Emergency and Testing) Operating hours limit: The boiler mayoperate up to 40 hours per year to demonstrate the Uniform Rating of GeneratingEquipment (URGE) capacity and to meet emergency energy supply needs.Maintain documentation of all STET operation to demonstrate compliance with thislimit. The boiler must meet emission limits during STET operation.

Minn. R. 7007.0800, Subp. 2.

STET Operation Definition that applies to Boilers that Meet or do Not Meet theAlternative Operating Condition for Performance Testing:

If performance test results demonstrate compliance at 80% or less of anyapplicable emission limits for any tested pollutant, STET operation is defined asoperation beyond 110% of the average operating rate achieved during thatperformance test.

If performance test results demonstrate compliance at greater than 80% anyapplicable emission limit for any tested pollutant, STET operation is defined asoperation beyond 100% of the average operating rate achieved during thatperformance test.

In no case will STET operation be higher than allowed by an existing permitcondition.

Minn. R. 7007.0800, Subp. 2.


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-13

ACID RAIN PROGRAM REQUIREMENTS hdr

Hold allowances, as of the allowance transfer deadline, in the unit's compliancesubaccount not less than the total annual emissions of sulfur dioxide for theprevious calendar year.

40 CFR Section 72.9(c)(1)(i), 40 CFR Section72.9(g)(4)

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Section 72.9(c)(1)(i), 40 CFR Section72.9(g)(4)

Keep on site at the source each of the following documents for a period of 5 yearsfrom the date of permit issuance: The certificate of representation, all emissionsmonitoring information, copies of all reports, compliance certifications, and othersubmissions or records made under the Acid Rain Program, copies of alldocuments used to complete an acid rain permit application.

40 CFR Section 72.9(f)(l)

Each submission under the Acid Rain Program shall be submitted, signed, andcertified by the designated representative for all sources on behalf of which thesubmission is made in accordance with 40 CFR Section 72.21.


EMISSIONS MONITORING hdr

Emissions Monitoring: The owner or operator shall use a CEMS to measure SO2,NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40CFR Section 75.10. See Subject Item GP003 for specific monitor requirements.


Use SO2 CEM to measure sulfur dioxide in lb/mmBtu and lb/hr, calculate anaverage 1-hour emission rate at least once per hour.

Minn. R. 7007.0800, subp. 2

Recordkeeping: Maintain records of all CEMS monitoring data and supportinformation for a period of five years from the date of the monitoring sample,measurement, or report. Records shall be kept at the source.

Minn. R. 7007.0800, subp. 5

The Permittee shall install, operate, and maintain a process O2 monitor (primarilyfor the boiler operator) upstream of the EU002 air heater, and record the indicatormeasurements. The monitoring and recordkeeping equipment shall be operated atall times during EU002 operation.

Oxygen concentration shall not fall below a value based on data recorded duringthe most recent performance test for CO. The measurement frequency andaveraging period associated with this emissions indicator will be derived orprojected by the Permittee through analysis of the correlation between indicatorreadings and the first performance test results. The results of the analysis will besummarized in a CO monitoring plan to be submitted to the Agency for approvalwithin 120 days after the initial compliance test for CO.


Emissions Monitoring: The owner or operator shall use a COMS to measureopacity emissions. The COMS shall consist of an opacity monitor on EU002 ductsand a combiner equation which will provide opacity emissions data from SV002.(See Subject Item GP004 for COMS operating requirements.)

Minn. R. 7017.1006

CALCULATIONS FOR COMPLIANCE WITH AOS 2 (under Subject Item GP001) hdr

By the 15th day of each month, beginning with the month of initial startup of EU002after completion of the LNB/OFA modification or the implementation of AOS 2, asapplicable, the Permittee shall calculate and record:

1. the usage of sub-bituminous and lignite coals during the previous calendarmonth;

2. the CO emissions from EU002 during the previous calendar month, using thefollowing equation:

EU002 CO = [ (FS x HS x EFS) / 2000] + [ (FL x HL x EFL) / 2000]

where:

EU002 CO = the CO emissions from EU002 during the previous month (tons)FS = the sub-bituminous coal usage for EU002 during the previous month (tons)FL = the lignite coal usage for EU002 during the previous month (tons)HS = the site-specific heat content of the sub-bituminous coal (mmBtu/ton)HL = the site-specific heat content of the lignite coal (mmBtu/ton)EFS = the current CO emission factor for sub-bituminous coal (lb/mmBtu)EFL = the current CO emission factor for lignite coal (lb/mmBtu)


After completion of the LNB/OFA modification, and prior to availability of stack testresults, the CO emission factor (EFS and EFL) is assumed to be 0.231 lb/mmBtu.

Once conclusive stack test results are available, the Permittee shall use the COemission factor (EFS or EFL, as applicable) derived from the test. Any calculationsof CO emissions done after completion of the LNB/OFA modification and prior toavailability of test results shall be recalculated using the appropriate CO emissionfactor.

continued from above


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-14

CALCULATIONS FOR COMPLIANCE WITH FRONT HALF PARTICULATEMATTER LIMIT (under Subject Item GP002)

hdr

By the 15th day of each month, beginning with the month of initial startup aftercompletion of the mercury reduction modification, the Permittee shall calculate andrecord:

1. the usage of sub-bituminous and lignite coals during the previous calendarmonth; and

2. the front half PM emissions from EU002 during the previous calendar month,using the following equation:

FHPM2 = [ (FS x HS x EFS) / 2000] + [ (FL x HL x EFL) / 2000]

where:FHPM2 = the front half PM emissions from EU002 during the previous month (tons)FS = the sub-bituminous coal usage for EU002 during the previous month (tons)FL = the lignite coal usage for EU002 during the previous month (tons)HS = the site-specific heat content of the sub-bituminous coal (mmBtu/ton)HL = the site-specific heat content of the lignite coal (mmBtu/ton)EFS = the current front half PM emission factor for sub-bituminous coal (lb/mmBtu)EFL = the current front half PM emission factor for lignite coal (lb/mmBtu)


Prior to availability of conclusive performance test results following the mercuryreduction modification, the front half PM emission factor (EFS and EFL) is 0.052lb/mmBtu.

Once conclusive stack test results are available, the Permittee shall use the fronthalf PM emission factor (EFS or EFL, as applicable) derived from the test. Anycalculations of front half PM emissions done after completion of the mercuryreduction modification and prior to availability of test results shall be recalculatedusing the appropriate front half PM emission factor.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-15




CE 011 Overfire Air









MR 020 EU003 COMS


What to do Why to do itEMISSION AND OPERATING LIMITS +hdr

Particulate Matter < 10 micron: less than or equal to 0.47 lbs/million Btu heat input 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Total Particulate Matter: less than or equal to 0.60 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1



Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 3-hourAverage

Minn. R. 7011.0510, subp. 1


40 CFR Section 76.7(a)(1) and 40 CFR Section76.8(a)(2)



Opacity: less than or equal to 20 percent opacity using 6-minute Average except forone six-minute period per hour of not more than 60 percent opacity.

Minn. R. 7011.0510, subp. 2

Allowed Fuels: lignite, sub-bituminous coal, distillate oil, used oil, non-hazardousoil spill cleanup materials and non-hazardous boiler cleaning agents.

Minn. R. 7007.0800, subp. 2

Allowed boiler cleaning agents: EDTA type generated on-site, 5% of total mass orheat input, oxygen limited to 3% or greater, agents may only be burned while theboiler is operating at 75 percent of rated capacity or greater.

Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 2; Minn. R. 7045.0790 to7045.0990

Combust used oil in accordance with used oil regulations, Minn. R. ch. 7045, andlimit to 5% of total mass or heat input on an hourly basis.

Minn. R. 7007.0800, subp. 2

Maintain records of total amount of used oil, boiler cleaning agents or oilcontaminated clean up materials burned per day when those materials are burned,and the ratio burned to other fuel in order to demonstrate compliance with the usedoil input limits, and used oil cleanup materials input limits.

Minn. R. 7007.0800, subp. 5



CONTROL REQUIREMENTS(see Subject Item CE 003 for specific control equipment operating requirements)

hdr


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-16


Minn. R. 7007.0800, subp. 2 and 14


Minn. R. 7007.0800, subp. 2 and 14


Minn. R. 7007.0800, subp. 2 and 14

If installed, the Permittee shall operate and maintain the carbon injection mercurycontrol system (CE015) at any time that the process equipment is combusting coal.The Permittee shall document periods of non-operation of the control equipment.

See Subject Item CE015 for specific operating requirements.

Minn. R. 7007.0800, subp. 2 and 14

PERFORMANCE TEST REQUIREMENTS hdr









Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the total particulate matter emission limit. The test shallbe conducted at an interval not to exceed 60 months between test dates.

Minn. R. 7017.2020 subp. 1

Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the PM10 emissions limit. The test shall be conductedat an interval not to exceed 60 months between test dates.

Minn. R. 7017.2020 subp. 1



Minn. R. 7017.2030, subp. 1-4; Minn. R. 7017.2018and Minn. R. 7017.2035, subp. 1-2

STET (Short Term Emergency and Testing) Operating hours limit: The boiler mayoperate up to 40 hours per year to demonstrate the Uniform Rating of GeneratingEquipment (URGE) capacity and to meet emergency energy supply needs.Maintain documentation of all STET operation to demonstrate compliance with thislimit. The boiler must meet emission limits during STET operation.

Minn. R. 7007.0800, Subp. 2.


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-17

STET Operation Definition that applies to Boilers that Meet or do Not Meet theAlternative Operating Condition for Performance Testing:




Minn. R. 7007.0800, Subp. 2.

ACID RAIN PROGRAM REQUIREMENTS hdr


40 CFR Section 72.9(c)(1)(i), 40 CFR Section72.9(g)(4)

Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. 40 CFR Section 72.9(c)(1)(i), 40 CFR Section72.9(g)(4)

Keep on site at the source each of the following documents for a period of 5 yearsfrom the date of permit issuance: The certificate of representation, all emissionsmonitoring information, copies of all reports, compliance certifications, and othersubmissions or records made under the Acid Rain Program, copies of alldocuments used to complete an acid rain permit application.

40 CFR Section 72.9(f)(l)

Each submission under the Acid Rain Program shall be submitted, signed, andcertified by the designated representative for all sources on behalf of which thesubmission is made in accordance with 40 CFR Section 72.21.


EMISSIONS MONITORING hdr

Emissions Monitoring: The owner or operator shall use a CEMS to measure SO2,NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40CFR Section 75.10. See Subject Item GP003 for specific monitor requirements.


Use SO2 CEM to measure sulfur dioxide in lb/mmBtu and lb/hr, calculate anaverage 1-hour emission rate at least once per hour.

Minn. R. 7007.0800, subp. 2

Recordkeeping: Maintain records of all CEMS monitoring data and supportinformation for a period of five years from the date of the monitoring sample,measurement, or report. Records shall be kept at the source.

Minn. R. 7007.0800, subp. 5




Emissions Monitoring: The owner or operator shall use a COMS to measureopacity emissions. The COMS shall consist of an opacity monitor on EU003 ductsand a combiner equation which will provide opacity emissions data from SV002.(See Subject Item GP004 for COMS operating requirements.)

Minn. R. 7017.1006

CALCULATIONS FOR COMPLIANCE WITH AOS 2 (under Subject Item GP001) hdr


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-18





where:



After completion of the LNB/OFA modification, and prior to availability of stack testresults, the CO emission factor (EFS and EFL) is assumed to be 0.100 lb/mmBtu.



CALCULATIONS FOR COMPLIANCE WITH FRONT HALF PARTICULATEMATTER LIMIT (under Subject Item GP002)

hdr







Prior to availability of conclusive performance test results following the mercuryreduction modification, the front half PM emission factor (EFS and EFL) is 0.059lb/mmBtu.




11100002 - 005

Facility Name:

Permit Number:

04/28/11A-19

Subject Item: EU 004 Fly Ash Silo

Associated Items: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 006 Fly Ash Tank Vent


Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Particulate Matter < 10 micron: less than or equal to 0.05 grains/dry standard cubicfoot This is a state only requirement and is not enforceable by the EPAAdministrator or citizens under the Clean Air Act.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R.7007.0100, subps 7A, 7L & 7M; Minn. R. 7007.0800,subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

CONTROL REQUIREMENTS (see Subject Item CE004 for specific controlequipment operating requirements)

hdr

The Permittee shall operate and maintain the fabric filter (CE004) at all times thatany emission unit controlled by the fabric filter (EU004) is in operation. ThePermittee shall document periods of non-operation of the control equipment.

Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Total Particulate Matter: greater than orequal to 99 percent control efficiency

Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Particulate Matter < 10 micron: greaterthan or equal to 93 percent control efficiency

Minn. R. 7007.0800, subp. 2 and 14


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-20

Subject Item: EU 005 Bottom Ash Silo


SV 007 Bottom Ash Tank Vent


Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0710, subp. 1(A)


Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R.7007.0100, subps 7A, 7L & 7M; Minn. R. 7007.0800,subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0710, subp. 1(B)

Operating Hours: less than or equal to 4.0 hours/day 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

CONTROL REQUIREMENTS (see Subject Item CE005 for specific controlequipment operating requirements)

hdr


Minn. R. 7007.0800, subp. 2 and 14


Minn. R. 7007.0800, subp. 2 and 14


Minn. R. 7007.0800, subp. 2 and 14


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-21

Subject Item: EU 006 Unit #1 Emergency Generator

Associated Items: SV 004 Unit #1 Emergency Diesel Generator

What to do Why to do itEMISSION LIMITS hdr

Opacity: less than or equal to 20 percent once operating temperatures have beenattained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input .

The potential to emit from the unit is 0.29 lb/MMBtu due to equipment design andallowable fuels.

Minn. R. 7011.2300, subp. 2

OPERATING CONDITIONS hdr

Fuel type: No. 2 fuel oil only. Minn. R. 7005.0100, subp. 35a

RECORDKEEPING REQUIREMENTS hdr

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.50% by weight.

Minn. R. 7007.0800, subps. 4 & 5


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-22




Opacity: less than or equal to 20 percent once operating temperatures have beenattained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input .


Minn. R. 7011.2300, subp. 2

OPERATING CONDITIONS hdr

Fuel type: No. 2 fuel oil only. Minn. R. 7005.0100, subp. 35a

RECORDKEEPING REQUIREMENTS hdr


Minn. R. 7007.0800, subps. 4 & 5


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-23

Subject Item: EU 012 Temporary Boiler (preauthorized)

Associated Items: SV 010 Temporary Boiler


Total Particulate Matter: less than or equal to 0.10 lbs/million Btu heat input . Thepotential to emit from the unit is 0.014 lb/MMBtu due to equipment design andallowable fuels.

Minn. R. 7011.0515, subp. 1

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0515, subp. 2

OTHER LIMITS hdr

Limit to avoid exceeding Significance Threshold for New Source Reviewmodifications. When assessing any facility modification under 40 CFR Section52.21, emissions from EU012 (pre-authorized temporary boiler) must be counted inthe applicability analysis if they occur during the contemporaneous period.

Additional monitoring, recordkeeping, and reporting associated with this condition isas described in 40 CFR Section 52.21(r)(6), and in this permit under Subject ItemTotal Facility, under the heading "Determining if a Project/Modification is Subject toNew Source Review".

Title I Condition: To avoid classification as majormodification under 40 CFR Section 52.21 and Minn. R.7007.3000

A temporary boiler may not be operated at the same time as EU002 or EU003,except for up to 8 hours during start-up and shutdown transition periods.

Minn. R. 7007.0800, subp. 2

Heat Input: less than or equal to 9.9 lbs/million Btu heat input for the purpose ofproviding steam, heat or electrical power in place of boilers or generators that aretemporarily out of operation.

Minn. R. 7007.0800, subp. 2; To avoid classification asan affected facility under 40 CFR Part 60, Subp. Dc

Fuel type: No. 2 fuel oil only Minn. R. 7005.0100, subp. 35a

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight Minn. R. 7007.0800, subp. 2

CALCULATIONS AND RECORDKEEPING hdr

Recordkeeping. For each temporary boiler brought on site, keep documentation ofthe manufacturer, model number, and heat input capacity. Records shall bemaintained on site for 5 years.

Minn. R. 7007.0800, subp. 2

Calculations: For each temporary boiler calculate the potential emissions of eachcriteria pollutant in lb/hr and lb/MMBtu (using manufacturer's provided data orAP-42 emission factors). Maintain a unique record for each temporary boiler of thepotential emission calculations. Records shall be maintained on site for 5 years.

Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subps. 4 & 5


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-24

Subject Item: CE 002 Electrostatic Precipitator - High Efficiency


What to do Why to do itOperation and Maintenance of ESP: The Permittee shall operate and maintain theESP in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andreview by MPCA staff.

40 CFR Section 64.7(b); Minn. R. 7007.0800, subp. 14

Opacity: less than or equal to 20 percent opacity using 3-hour Average . Opacity inexcess of this limit shall be considered an excursion under 40 CFR Section64.6(c)(2).

40 CFR Section 64.3; Minn. R. 7017.0200

Continuous Monitoring: The Permittee shall continuously, or at a minimum onceevery 15 minutes, monitor and record the opacity of the ESP exhaust.

[See Subject Item GP004 for specific COMS operating requirements.]

40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017. 0200

Total Power Input: greater than or equal to 40.0 kilowatts using 3-hour RollingAverage , unless a new minimum total power input is required to be set pursuant toMinn. R. 7017.2025, subp. 3. If a new minimum power input is required to be set, itwill be based on the average power input recorded during the most recent MPCAapproved performance test where compliance for Total Particulate Matter and/orParticulate Matter less than 10 microns emissions was demonstrated.


Continuous Monitoring: The Permittee shall continuously, or at a minimum once per15 minutes, record the power input for CE002, at all times that EU002 is inoperation. If the three-hour rolling average total power input is less than theminimum limit, the Permittee must take corrective action (as outlined in theoperation and maintenance plan for the facility) within 24-hours of discovery. This isconsidered an excursion as defined at 40 CFR Section 64.1. Make a record of allcorrective actions taken.

40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017.0200

Monitoring Equipment: The necessary monitoring equipment must be installed, inuse, and properly maintained, including maintaining the necessary parts for routinerepairs of the monitoring equipment, whenever operation of the monitored controlequipment is required.

40 CFR Section 64.7(b); Minn. R. 7017.0200

Periodic Inspections: At least once per calendar quarter, or more frequently ifrequired by the manufacturer, the Permittee shall inspect the control equipmentcomponents that are subject to wear or plugging, for example: bearings, belts,hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a writtenrecord of the inspection and any corrective actions taken resulting from theinspection.


Annual Inspections: At least once per calendar year, or more frequently if requiredby the manufacturer, the Permittee shall inspect the control equipment componentsnot covered by the quarterly inspections. This includes, but is not limited to,components that are not subject to wear or plugging including structuralcomponents, housings, and hoods. The Permittee shall maintain a written record ofthe inspection and any corrective actions taken resulting from the inspection.


Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the monitored opacity, averaged over any 3-hour period, exceeds 20%;-the monitored total power input, averaged over any 3-hour period, is less than 40kilowatts; or- the ESP or any of its components are found during the inspections to need repair.Corrective actions shall return operation to within the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the ESP. The Permittee shall keep a record of the type and date ofany corrective action taken for the ESP.

40 CFR Section 64.7(d); Minn. R. 7017.0200

Documentation of Need for Improved Monitoring: If the Permittee fails to achievecompliance with an emission limitation or standard for which the monitoring did notprovided an indication of an excursion or exceedance while providing valid data, orthe results of compliance or performance testing document a need to modify theexisting opacity which is considered an excursion, the Permittee shall promptlynotify the MPCA and, if necessary, submit a permit amendment application toaddress the necessary monitoring changes.

40 CFR Section 64.7(e); Minn. R. 7017.0200

Deviations Report: As required by 40 CFR Section 64.9(a)(2), for the Semi-AnnualDeviations Report listed in Table B of this permit and/or the Notification ofDeviations Endangering Human Health and the Environment listed earlier in TableA of this permit, as applicable, the Permittee shall include the following related tothe monitoring identified as required by 40 CFR pt. 64: 1) Summary information onthe number, duration, and cause of excursions or exceedances, as applicable, andthe corrective action taken; and 2) Summary information on the number, duration,and cause for monitor downtime incidents.

40 CFR Section 64.9(a)(2); Minn. R. 7017.0200


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-25

Recordkeeping: The Permittee shall maintain records of monitoring data, monitorperformance data, corrective actions taken, and other supporting informationrequired to be maintained. The Permittee may maintain records on alternativemedia, such as microfilm, computer files, magnetic tape disks, or microfiche,provided that the use of such alternative media allows for expeditious inspectionand review, and does not conflict with other applicable recordkeeping requirements.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-26



What to do Why to do itOperation and Maintenance of ESP: The Permittee shall operate and maintain theESP in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andreview by MPCA staff.






40 CFR Section 64.4(b)(4)(ii); Minn. R. 7017. 0200




40 CFR Section 64.3(b)(4)(ii); Minn. R. 7017.0200







Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the monitored opacity, averaged over any 3-hour period, exceeds 20%; -themonitored total power input, averaged over any 3-hour period, is less than 25kilowatts; or- the ESP or any of its components are found during the inspections to need repair.Corrective actions shall return operation to within the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the ESP. The Permittee shall keep a record of the type and date ofany corrective action taken for the ESP.







11100002 - 005

Facility Name:

Permit Number:

04/28/11A-27




11100002 - 005

Facility Name:

Permit Number:

04/28/11A-28

Subject Item: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 004 Fly Ash Silo

FS 004 Fly Ash Silo Loading

What to do Why to do itThe Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.


Pressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 5.5 inches of water column , unless a new range is set pursuant to Minn.R. 7017.2025, subp. 3 based on the values recorded during the most recentMPCA-approved performance test where compliance was demonstrated. The newrange shall be implemented upon receipt of the Notice of Compliance lettergranting preliminary approval. The range is final upon issuance of a permitamendment incorporating the change.

Minn. R. 7007.0800, subp. 2 and 14; Minn. R.7017.2025, subp. 3

Daily Monitoring: The Permittee shall read and record the pressure drop across thefabric filter once every 24 hours.

Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section64.3; Minn. R. 7017.0200

Visible Emissions: The Permittee shall inspect the fabric filter stack (SV006) for anyvisible emissions while in operation and during daylight hours at a minimum of onceeach week. If visible emissions exist, the Permittee shall inspect equipment forevidence of malfunction, including broken bags. The Permittee shall record theresults of the inspection, and any corrective action taken.


The Permittee shall maintain an alarm system that notifies the control roomoperators if pressure loss to the puffer bag is detected.

Minn. R. 7007.0800, subp. 2

Recordkeeping of Visible Emissions and Pressure Drop: The Permittee shall recordthe time and date of each visible emission inspection and pressure drop reading,and whether or not any visible emissions were observed, and whether or not theobserved pressure drop was within the range specified in this permit. Recordedvalues outside the range specified in this permit are considered Deviations asdefined by Minn. R. 7007.0100, subp. 8a.


Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.


Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed; or- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted range,eliminate visible emissions, and/or include completion of necessary repairsidentified during the inspection, as applicable. Corrective actions include, but arenot limited to, those outlined in the O & M Plan for the fabric filter. The Permitteeshall keep a record of the type and date of any corrective action taken for eachfilter.


Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.


The Permittee shall calibrate the pressure gauge at least once every calendar yearand shall maintain a written record of any action resulting from the calibration.


Documentation of Need for Improved Monitoring: If the Permittee fails to achievecompliance with an emission limitation or standard for which the monitoring did notprovide an indication of an excursion or exceedance while providing valid data, orthe results of compliance or performance testing document a need to modify theexisting pressure drop range, the Permittee shall promptly notify the MPCA and, ifnecessary, submit a permit amendment application to address the necessarymonitoring change.


As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Reportlisted in Table B of this permit and/or the Notification of Deviations EndangeringHuman Health and the Environment listed earlier in Table A of this permit, asapplicable, the Permittee shall include the following related to the monitoringidentified as required by 40 CFR pt. 64: 1) Summary information on the number,duration, and cause of excursions or exceedances, as applicable, and thecorrective action taken; and 2) Summary information on the number, duration, andcause for monitor downtime incidents.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-29

The Permittee shall maintain records of monitoring data, monitor performance data,corrective actions taken, and other supporting information required to bemaintained. The Permittee may maintain records on alternative media, such asmicrofilm, computer files, magnetic tape disks, or microfiche, provided that the useof such alternative media allows for expeditious inspection and review, and doesnot conflict with other applicable recordkeeping requirements.



11100002 - 005

Facility Name:

Permit Number:

04/28/11A-30


Associated Items: EU 005 Bottom Ash Silo

FS 005 Bottom Ash Silo Loading

What to do Why to do itThe Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.



Minn. R. 7007.0800, subp. 2 and 14; Minn. R.7017.2025, subp. 3



Visible Emissions: The Permittee shall inspect the fabric filter stack (SV007) for anyvisible emissions while in operation and during daylight hours at a minimum of onceeach week. If visible emissions exist, the Permittee shall inspect equipment forevidence of malfunction, including broken bags. The Permittee shall record theresults of the inspection and any corrective action taken.

















11100002 - 005

Facility Name:

Permit Number:

04/28/11A-31




11100002 - 005

Facility Name:

Permit Number:

04/28/11A-32

Subject Item: CE 014 Carbon Injection


What to do Why to do itMercury Sorbent Feed Rate: Maintain mercury sorbent volumetric feed rate (e.g., inpounds per volume of flue gas or pounds per volume coal flow) at or above thevalue measured during the most recent mercury performance test once system hasbeen installed and is operational.

Minn. R. 7007.0800, subp. 2

Mercury Sorbent Injection: Initiate corrective action to restore the mercury sorbentinjection rate as soon as possible upon discovery of a drop in the mercury sorbentinjection rate to a level below the value measured during the most recent mercuryperformance test.

Minn. R. 7007.0800, subp. 2

Mercury Sorbent Injection Monitoring: Once the Mercury Control system has beeninstalled; the Permittee shall install, maintain, and operate at all times that EU002 isoperating, a system for monitoring and recording the mercury sorbent feed rate.The Permittee shall record the time periods, reasons, and corrective actions takenfor all EU002 operating periods when mercury sorbent feed rates are below therequired minimum.

Minn. R. 7007.0800, subp. 2


11100002 - 005

Facility Name:

Permit Number:

04/28/11A-33



What to do Why to do itMercury Sorbent Feed Rate: Maintain mercury sorbent volumetric feed rate (e.g., inpounds per volume of flue gas or pounds per volume coal flow) at or above thevalue measured during the most recent mercury performance test once system hasbeen installed and is operational.

Minn. R. 7007.0800, subp. 2

Mercury Sorbent Injection: Initiate corrective action to restore the mercury sorbentinjection rate as soon as possible upon discovery of a drop in the mercury sorbentinjection rate to a level below the value measured during the most recent mercuryperformance test.

Minn. R. 7007.0800, subp. 2

Mercury Sorbent Injection Monitoring: Once the Mercury Control system has beeninstalled; the Permittee shall install, maintain, and operate at all times that EU003 isoperating, a system for monitoring and recording the mercury sorbent feed rate.The Permittee shall record the time periods, reasons, and corrective actions takenfor all EU003 operating periods when mercury sorbent feed rates are below therequired minimum.

Minn. R. 7007.0800, subp. 2

TABLE B: SUBMITTALSFacility Name: Otter Tail Power Co - Hoot Lake Plant

Permit Number: 11100002 - 005

04/28/11B-1

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

AQ Permit Document Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Otter Tail Power Co - Hoot Lake Plant


04/28/11B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Application for Permit Reissuance due 180 days before expiration of ExistingPermit (Acid Rain Program)

EU002, EU003

Application for Permit Reissuance due before 01/01/1998 or as specified in 40CFR Section 76.9 for nitrogen oxidesincluding compliance plan (Acid Rain permit).

EU002, EU003

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup EU002following completion of Mercury Reductionprojects.

EU002

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup EU003following completion of Mercury Reductionprojects.

EU003

Testing Frequency Plan due 60 days after Initial Performance Test forCO emissions from burning lignite. The planshall specify a testing frequency based on thetest data (compared to the default emissionfactor of 0.100 lb/mmBtu) and MPCAguidance. Future performance tests based onone-year (12 month), 36 month, and 60 monthintervals, or as applicable, shall be requiredupon written approval of the MPCA.

EU002, EU003

Testing Frequency Plan due 60 days after Initial Performance Test forfront half PM emissions after installation ofCE014. The plan shall specify a testingfrequency based on the test data and MPCAguidance. Future performance tests based onone-year (12 month), 36 month, and 60 monthintervals, or as applicable, shall be requiredupon written approval of the MPCA.

EU002

Testing Frequency Plan due 60 days after Initial Performance Test forfront half PM emissions after installation ofCE015. The plan shall specify a testingfrequency based on the test data and MPCAguidance. Future performance tests based onone-year (12 month), 36 month, and 60 monthintervals, or as applicable, shall be requiredupon written approval of the MPCA.

EU003

TABLE B: RECURRENT SUBMITTALSFacility Name: Otter Tail Power Co - Hoot Lake Plant


04/28/11B-3

What to send When to send Portion of Facility AffectedCOMS Audit Results Summary due 30 days after end of each calendar

quarter starting 04/08/2009 in which theCOMS calibration error audit was completed.

MR019, MR020

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter starting 04/08/2009 (SubmitDeviations Reporting Form DRF-1 asamended). The EER shall indicate all periodsof monitor bypass and all periods ofexceedances of the limit includingexceedances allowed by an applicablestandard, i.e. during startup, shutdown, andmalfunctions.

Total Facility

Linearity Test Results Summary due 30 days after end of each calendarquarter starting 04/08/2009 following Linearityand Leak Check Test if performed.

MR009, MR010, MR011, MR013, MR014,MR015

Relative Accuracy Test Audit (RATA) ResultsSummary

due 30 days after end of each calendarquarter starting 04/08/2009 in which theCEMS RATA was conducted.

MR009, MR010, MR011, MR012, MR013,MR014, MR015, MR016

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 04/08/2009 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 04/08/2009 (for the previous calendaryear). The Permittee shall submit this on aform approved by the Commissioner, both tothe Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

APPENDICES Facility Name: Otter Tail Power Co - Hoot Lake Plant Permit Number: 11100002-005 APPENDIX A – Appendix not Used APPENDIX B – Modeled Parameters Facility Name: Otter Tail Power Co - Hoot Lake Plant Permit Number: 11100002-005 The parameters in the following table are those that were the basis of the modeling in the PM10 Air Dispersion Modeling Update, June 2006.

Stack ID Stack Height (ft)

Stack Temp (°F)

Design Flow Rate (acfm)

Stack Diameter (ft)

Short-term (24 hour) PM10 (lb/hr)

Long-term (annual) PM10 (lb/hr)

SV001 133 393 80,000 6.0 25.15 25.15 SV002 225 330 774,000 13.4 916.5 676.8 SV003 6.5 45 16,500 3.5 0 0 SV004 5.0 280 3,000 0.7 0.22 0.22 SV005 8.0 265 2,000 0.5 0.14 0.14 SV006 75 350 3,123 1.0 1.34 1.34 SV007 27 45 4,000 1.0 0.57 0.57 SV008 127.5 45 7,600 1.3 3.26 3.26 SV009 122 45 0 0.3 0 0

Fugitive Source ID PM10 (lb/hr)

FS001 0.60 FS002 0.02 FS003 0.91 FS004 2.98 FS005 1.28 FS006 7.58 FS007 0.032 FS008 0.50 FS009 2.66

APPENDIX C – Insignificant Activities Facility Name: Otter Tail Power Co - Hoot Lake Plant Permit Number: 11100002-005

Insignificant Activities and Applicable Requirements The table below lists the insignificant activities that will be added to the facility under the currently proposed modifications, and their associated general applicable requirements.

Minn. R. Rule Description of the Activity Applicable Requirement

7007.1300, subpart 3

Insignificant activities required to be listed: A. Fuel use: space heaters fueled by kerosene, natural gas, or propane. A space heater is a heating unit that is not connected to piping or ducting to distribute the heat.

• Kerosene or propane gas space heater

G. Emissions from a laboratory, as defined in this item. "Laboratory" means a place or activity devoted to experimental study or teaching in any science, or to the testing and analysis of drugs, chemicals, chemical compounds or other substances, or similar activities, provided that the activities described in this sentence are conducted on a laboratory scale. Activities are conducted on a laboratory scale if the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. If a facility manufactures or produces products for profit in any quantity, it may not be considered to be a laboratory under this item. Support activities necessary to the operation of the laboratory are considered to be part of the laboratory. Support activities do not include the provision of power to the laboratory from sources that provide power to multiple projects or from sources which would otherwise require permitting, such as boilers that provide power to an entire facility.

• Water testing laboratory H. Miscellaneous: (3) brazing, soldering, or welding equipment;

• Welding K. Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

• Spray painting for maintenance activities

Minn. R. 7011.0710 Minn. R. 7011.0715

Minn. R. Rule Description of the Activity Applicable Requirement

7007.1300, subpart 4

Individual emissions units at a stationary source, each of which has: A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide; B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and C. For hazardous air pollutants, emissions units with: (1) potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in subp. 5; or (2) combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart.

• Carbon silo for storage of carbon for mercury reduction controls • VOC use less than 200 gallons per year for parts cleaning • Fuel Bunker Vacuum System

Minn. R. 7011.0715 Minn. R. 7011.0150

7008.4110

Any stationary source claiming particulate matter (PM) or particulate matter of less than ten microns (PM10) venting equipment as a conditionally insignificant activity must have: Emissions from equipment venting PM or PM10 inside a building, for example: buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, or turning equipment, must be: A. filtered through an air cleaning system; and B. vented inside of the building 100 percent of the time.

• Fuel Bunkers

Minn. R. 7011.0710 Minn. R. 7011.0150

APPENDIX D – NOX Compliance Plan (Acid Rain Program) Facility Name: Otter Tail Power Co - Hoot Lake Plant Permit Number: 11100002-005

Phase II NOx Compliance Plan For more information, see instructions and refer to 40 CFR 76.9

This submission is: New Revised Step 1 Indicate plant name, State, and ORIS code from NADB, if applicable

Hoot Lake Plant Name

MN State

1943 ORIS Code

Step 2 Identify each affected Group 1 and Group 2 boiler using the boiler ID# from NADB, if applicable. Indicate boiler type: “CB” for cell burner, “CY” for cyclone, “DBW” for dry botton wall-fired, “T” for tangetially fired, “V” for vertically fired, and “WB” for wet bottom. Indicate the compliance option selected for each unit

ID# 2

ID# 3

ID#

ID#

ID#

ID#

T Type

DBW Type

Type

Type

Type

Type

(a) Standard annual average emission limitation of 0.50 lb/mmBtu (for Phase I dry bottom wall-fired boilers)

(b) Standard annual average emission limitation of 0.45 lb/mmBtu (for Phase I tangentially fired boilers)

X

(c) EPA-approved early election plan under 40 CFR 76.8 through 12/31/07 (also indicate above emission limit specified in plan)

X

(d) Standard annual average emission limitation of 0.46 lb/mmBtu (for Phase II dry

X

X

bottom wall-fired boilers) (e) Standard annual average emission limitation of 0.40 lb/mmBtu (for Phase II tangentially fired boilers)

(f) Standard annual average emission limitation of 0.68 lb/mmBtu (for cell burner boilers)

(g) Standard annual average emission limitation of 0.86 lb/mmBtu (for cyclone boilers)

(h) Standard annual average emission limitation of 0.80 lb/mmBtu (for vertically fired boilers)

(i) Standard annual average emission limitation of 0.84 lb/mmBtu (for wet bottom boilers)

(j) NOx Averaging Plan (include NOx Averaging form)

(k) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(A) (check the standard emission limitation box above for most stringent limitation applicable to any unit utilizing stack

(l) Common stack pursuant to 40 CFR 75.17(a)(2)(i)(B) with NOx Averaging (check the NOx Averaging Plan box and include NOx Averaging form)

(m) EPA-approved common stack apportionment method pursuant to 40 CFR 75.17 (a)(2)(i)(C), (a)(2)(iii)(B), or (b)(2)

(n) AEL (include Phase II AEL Demonstration

Period, Final AEL Petition, or AEL Renewal form as appropriate) (o) Petition for AEL demonstration period or final AEL under review by U.S. EPA or demonstration period ongoing

(p) Repowering extension plan approved or under review

Standard Requirements General. This source is subject to the standard requirements in 40 CFR 72.9 (consistent with 40 CFR 76.8(e)(1)(i)). These requirements are listed in this source's Acid Rain Permit. Special Provisions for Early Election Units Nitrogen Oxides. A unit that is governed by an approved early election plan shall be subject to an emissions limitation for NO x as provided under 40 CFR 76.8(a)(2) except as provided under 40 CFR 76.8(e)(3)(iii). Liability. The owners and operators of a unit governed by an approved early election plan shall be liable for any violation of the plan or 40 CFR 76.8 at that unit. The owners and operators shall be liable, beginning January 1, 2000, for fulfilling the obligations specified in 40 CFR Part 77. Termination. An approved early election plan shall be in effect only until the earlier of January 1, 2008 or January 1 of the calendar year for which a termination of the plan takes effect. If the designated representative of the unit under an approved early election plan fails to demonstrate compliance with the applicable emissions limitation under 40 CFR 76.5 for any year during the period beginning January 1 of the first year the early election takes effect and ending December 31, 2007, the permitting authority will terminate the plan. The termination will take effect beginning January 1 of the year after the year for which there is a failure to demonstrate compliance, and the designated representative may not submit a new early election plan. The designated representative of the unit under an approved early election plan may terminate the plan any year prior to 2008 but may not submit a new early election plan. In order to terminate the plan, the designated representative must submit a notice under 40 CFR 72.40(d) by January 1 of the year for which the termination is to take effect. If an early election plan is terminated any year prior to 2000, the unit shall meet, beginning January 1, 2000, the applicable emissions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7. If an early election plan is terminated on or after 2000, the unit shall meet, beginning on the effective date of the termination, the applicable emissions limitation for NO x for Phase II units with Group 1 boilers under 40 CFR 76.7.

Phase II Permit Application For more information, see instructions and refer to 40 CFR 72.30 and 72.31 This submission is New Revised Hoot Lake Plant Name

MN State

1943 ORIS Code

Compliance Plan

a Boiler ID#

b Unit Will Hold Allowances in

Accordance with 40 CFR

72.9(c)(1)

c Repowering Plan

d New Units

Commence

Operation Date

e New Units

Monitor

Certification Deadline

2 Yes no 3 Yes no Yes Yes Yes Yes Yes Yes Yes Yes Yes Standard Requirements Permit Requirements. (1) The designated representative of each affected source and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall:

X

(i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit. Monitoring Requirements. (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR parts 74, 75, and 76. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR parts 74 and 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements. (1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the unit's compliance subaccount (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the previous calendar year from the unit; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1)(i) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements. (1) The designated representative of an affected unit that has excess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall: (i) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeeping and Reporting Requirements. (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; (ii) All emissions monitoring information, in accordance with 40 CFR part 75; (iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability.

(1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. Except as provided under 40 CFR 72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NO x averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit shall not be liable for any violation by any other affected unit of which they are not owners or operators or the designated representative and that is located at a source of which they are not owners or operators or the designated representative. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act. Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Act, including the provisions of title I of the Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold; provided, that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. APPENDIX E – Appendix not Used APPENDIX F – Appendix not Used

Technical Support Document, Permit Action Number: 11100002-005 Page 1 of 33 Date: 4/27/2011

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 11100002-005 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 4911) Otter Tail Power Company P.O. Box 496 Fergus Falls, Minnesota 56538-0496

1012 Water Plant Road Fergus Falls Otter Tail County

Contact: Mark Thoma Phone: 218-739-8526

1.2 Facility Description

The Hoot Lake Plant (Facility) consists of two boilers, Boilers 2 and 3, and fuel and ash handling equipment. Primary fuel for the boilers is coal. Particulate matter (PM) emissions are controlled by electrostatic precipitators (ESP) on Boilers 2 (EU002) and 3 (EU003), and baghouses on enclosed materials handling equipment. Nitrogen oxide (NOX) emissions from Boilers 2 and 3 are controlled with low-NOX burners and overfired air (LNB/OFA). The permit continues to authorize construction and operation of a carbon injection system to reduce Mercury emissions. Boilers 2 and 3 are utility boilers. The permit authorizes the installation of a temporary boiler to supply heat to the Facility in the event that Boilers 2 and 3 are not operational. 1.3 Description of the Activities Allowed by this Permit Action

a. This permit action is a major amendment to the permit authorizing the installation and operation of a temporary boiler. Conditions on the boiler will ensure that its operation will not trigger PSD, NESHAP, or NSPS requirements (as those rules currently exist). Potential emissions from the temporary boiler (in lb/hr) would be less than the thresholds for an insignificant modification for all criteria pollutants.


b. This permit action rolls in a reopening to include an approved Testing Frequency Plan (TFP) for CO emissions from EU002 and EU003. The TFP (postmarked 1/16/09) will require testing every 60 months from the most recent test date (See Attachment 4). The expected test date will be 12/3/2013.

• Unit No. 2 Boiler (EU002): CO ≤ 0.231 lb/MMBtu Test result: CO= 0.011 lb/MMBtu

• Unit No. 3 Boiler (EU003): CO ≤ 0.100 lb/MMBtu Test result: CO= 0.028 lb/MMBtu

• Initial testing requirements for CO emissions from burning lignite were left untouched.

c. This permit action includes a notification for the installation of new pollution control equipment. The facility installed a dust suppression spray system to reduce dust levels within the coal crusher house and conveyors, which uses a water and chemical spray. The crusher house and conveyors are enclosed structures that do not vent to the atmosphere; however they are still identified as a fugitive source, FS003. No operating or monitoring requirements are associated with the new spray system. [Permit notification received 7/27/09].

d. The permit has been updated to reflect current MPCA policy, templates and standard citation formatting.

• Standard language for modeling requirements has been included to reflect current policy. The facility qualifies as a Tier II facility.

• Standard language for CEMS required by Acid Rain (Part 75) has been updated to reflect current template language.

• PM performance test requirements for EU002 and EU003 have been separated into 2 separate requirements for clarity and trackability.

e. Completed requirements and the requirements for equipment that has been removed have

been deleted.

• EU001 has been removed from the facility, as well as associated control equipment (CE001).

i. Removed language referring to EU001 from SO2 limits for EU002 and EU003. • Clean Air Interstate Rule (CAIR) requirements have been removed.


f. Corrections • GP002 Front-half Particulate Matter limit was corrected to read LESS THAN, instead of

GREATER THAN. • Citations corrected for Acid Rain Program Requirements for EU002 and EU003. • EU003 SO2 limit listed an incorrect lb/hr limit. 3.0 lb/MMBtu calculates to 2550 lb/hr,

not 1770 lb/hr. 1770 lb/hr is the correct lb/hr limit for EU002. (See Attachment 5) • CE002 - CE005, corrected citation for Requirement 1.0 O&M. • Clarified within requirements of CE014 and CE015, that requirements are effective only

after installation of Mercury Control System. • Flow Monitors MR012 and MR016 should be subject to a RATA and not linearity testing. • O2 process monitors MR017 and MR018: Removed RATA requirement as these units are

not subject to Acid Rain, are not used to support CEMS; they are process monitors for the boiler operation.

• Updated Insignificant Activity list to reflect that space heaters are fueled by kerosene or propane, not natural gas, as requested in their previous application.

• EU001, EU008 and EU010 are inactive. This permit action also updated our database to identify the associated stacks and control equipment as inactive.

1.4. Facility Emissions:

Table 2. Title I Emissions Increase Summary

Pollutant

Emissions Increase from the

Modification (tpy)

Limited Emissions

Increase from the

Modification (tpy) Source-wide

Contemporaneous Increases and

Decreases* (tpy) Net

Emissions

Increase (tpy) PSD/112(g) Significant Thresholds

for major sources (tpy)

NSR/ 112(g) Review

Required? (Yes/No)

PM 0.62 0.62 -0.02 0.60 25 No

PM10 1.02 1.02 -0.03 0.99 15 No

PM2.5 0.48 0.48 -0.03 0.45 10 No

NOx 8.41 8.41 -0.06 8.35 40 No

SO2 2.20 2.20 -0.11 2.09 40 No

CO 6.81 6.81 -0.04 6.77 100 No

Ozone (VOC)

0.78 0.78 0.00 0.78 40 No

Lead 0.00 0.00 0.00 0.00 0.6 No

CO2e 6906 6906 -38 6868 75000 No * Other emission changes during the contemporaneous period as defined by 40 CFR § 52.21, 40 CFR § 52.24 or 40 CFR pt. 51. The Baseline period is December 2006 – December 2008. NOTE: Contemporaneous decreases are from removal of EU001. Numbers were gathered from 2006 Emission Inventory from its one day of operation.


Table 3. Non-Title I Emissions Increase Summary

(Temporary Boiler Emissions Only)

Pollutant

After Change (lb/hr) Before

Change (lb/hr) Net Change (lb/hr)

Insignificant Modification Thresholds (lb/hr <)

Minor and Moderate

Amendment Thresholds (lb/hr < or >)

Type of Amendment (Minor or Moderate)

PM10 0.23 0 0.23 0.855 3.42 Insignificant Modification

NOx 1.92 0 1.92 2.28 9.13 Insignificant Modification

SO2 0.50 0 0.50 2.28 9.13 Insignificant Modification

CO 1.55 0 1.55 5.70 22.80 Insignificant Modification

VOC 0.18 0 0.18 2.28 9.13 Insignificant Modification

Lead 8.91E-05 0 8.91E-05 0.025 0.11 Insignificant Modification

Note: The inclusion of the proposed temporary boiler would qualify as an insignificant modification based on its lb/hr increases. However, to pre-authorize the installation of a temporary boiler in the permit, requires a Title I limit to avoid exceeding significance levels for New Source Review.

Table 4. Facility Classification Classification Major/Affected

Source Synthetic Minor Minor

PSD x Part 70 Permit Program x Part 63 NESHAP x


2. Regulatory and/or Statutory Basis New Source Review

The facility is an existing major source under New Source Review (NSR) regulations. The modification contains provisions to avoid triggering a major modification under NSR regulations.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

There are no NSPSs applicable to the operations at this facility. None of the existing boilers is an affected facility because they were all installed prior to 1971, the earliest applicability date for NSPS for steam-generating units. The temporary boiler allowed by this modification will be limited to 9.9 MMBtu/hr so that it does not become an affected facility under 40 CFR Pt. 60, Subp. Dc.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

There are no major source nor area source NESHAPs applicable to the modification allowed in this permit amendment.

Compliance Assurance Monitoring (CAM)

CAM does not apply to the modification allowed in this permit amendment, since the emission unit added is not a large pollutant specific emission unit (PSEU).

Clean Air Interstate Rule (CAIR)

On November 3, 2009, EPA promulgated a final rule entitled “Administrative Stay of Clean Air Interstate Rule for Minnesota; Administrative Stay of Federal Implementation Plan to Reduce Interstate Transport of Fine Particulate Matter and Ozone for Minnesota (74 FR 56721). This rule became effective on December 3, 2009. The rule states that EPA is staying the application of CAIR and the CAIR FIP with respect to Minnesota and Minnesota sources, pending further rulemaking in response to the DC Circuit Court’s remand of CAIR to EPA. Therefore, CAIR-related requirements have been removed from this permit.

(EPA is working on promulgating the Clean Air Transport Rule in response to the court remand. That rule is expected to be finalized in Summer 2011.)

Minnesota State Rules

The temporary boiler allowed by this modification is subject to the following Minnesota Standard of Performance:

• Minn. R. 7011.0510 Standards of Performance for Indirect Heating Equipment


Environmental Review & AERA

Neither an Environmental Assessment Worksheet (EAW) nor an Air Emissions Risk Analysis (AERA) is required.

Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Level* Applicable Regulations Comments: EU 012 • Minn. R. 7011.0515

• Title I Condition: to avoid classification as major modification under 40 CFR Section 52.21

• To avoid classification

as an affected facility under 40 CFR Pt. 60, Subp. Dc

Standards of Performance for New Indirect Heating Equipment Limit to avoid exceeding Significance Threshold for New Source Review Heat input limit of 9.9 lb/MMBtu

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3. Technical Information EU012 – Temporary Boiler The potential emissions calculations for a 9.9 lb/MMBtu boiler results in a lb/hr emission rate such that it would qualify for an insignificant modification. The Permittee chose instead to include a provision in their permit to pre-authorize the installation and operation of a temporary boiler when EU002 or EU003 are not operational. The only other concern about pre-authorizing this boiler is to ensure that New Source Review considerations are addressed. Therefore, a requirement was included in the permit that has the Permittee include the emissions from the temporary boiler when assessing future modifications. Emissions Increase Analysis Attachment 1 to this TSD contains detailed spreadsheets and supporting information prepared by the Permittee. These calculations demonstrate that this modification is not a major modification for PSD. They also demonstrate that this modification qualifies as an insignificant modification due to lb/hr considerations. (The permit action is for a major modification due to pre-authorizing the installation of the boiler, and therefore the need to limit the temporary boiler’s heat input and fuel source.) The Permittee has limited themselves to a maximum heat input of 9.9 lb/MMBtu, and low sulfur No. 2 fuel


oil. These limits are used in the calculations. They used both AP-42 and sample manufacturer emission rates in their calculations, using the emission factor that was most conservative for their analysis (the exact make and model of the pre-authorized temporary boiler is unknown).

3.2 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already available for

the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere.

The table below summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 6. Periodic Monitoring

Level* Requirement (rule basis)

Additional Monitoring

Discussion

EU012 (Indirect Heating Equip.)

PM: < 0.1 lb/MMBtu; Opacity: < 20 % with exceptions

(Minn. R. 7011.0515)

Use of No. 2 fuel oil only.

Sulfur content < 0.05% by weight.

Fuel supplier certification for each shipment.

The authorized unit uses fuel oil; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning fuel oil. Since this is a permit condition, the semi-annual deviations report will document any deviations from this condition. Design based PTE for each unit, using manufacturer’s data, is 0.014 lb/MMBtu compared to the rule limit of 0.1 lb/MMBtu.


Heat Input < 9.9 lb/MMBtu (To avoid classification as an affected facility under 40 CFR Pt. 60, Subp. Dc)

Recordkeeping: For each temporary boiler brought on site, keep documentation of the manufacturer, model number, and heat input capacity.

Records shall be maintained on site for 5 years.

Limit to avoid exceeding significance thresholds for New Source Review modifications (To avoid classification as a major modification under 40 CFR Section 52.21)

For each temporary boiler calculate the potential emissions of each criteria pollutant in lb/hr and lb/MMBtu

When assessing any facility modification under 40 CFR Section 52.21, emissions from EU012 must be counted in the applicability analysis

For each temporary boiler calculate the potential emissions of each criteria pollutant in lb/hr and lb/MMBtu (using manufacturer's provided data or AP-42 emission factors). Maintain a unique record for each temporary boiler of the potential emission calculations.

Records shall be maintained on site for 5 years.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3.3 Insignificant Activities

Clarified that the space heaters at this facility use either kerosene or propane, not natural gas.

3.4 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.


3.5 Public Notice

Public Notice Period: March 9, 2011 – April 8, 2011 EPA 45-day Review Period: March 9, 2011 – April 22, 2011

Comments were not received from the public during the public notice period.

The Permittee submitted a request to clarify in our database that for inactive emission units EU001, EU008, and EU010, their associated stacks and control equipment were also inactive. This was done.

4. Permit Fee Assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes one application for a major amendment to the permit, received after the effective date of the rule (July 1, 2009). The permit action also includes an MPCA-initiated reopening to incorporate changes as a result of performance testing, and a notification from the Permittee regarding the Installation of Pollution Control Equipment. The major amendment application incorporated limits to avoid New Source Performance Standards, therefore 10 additional points were assessed.

5. Conclusion Based on the information provided by Otter Tail Power Company, the MPCA has reasonable assurance that the proposed operation of their Hoot Lake emission facility, as described in the Air Emission Permit No. 11100002-005 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Bonnie Nelson (permit writer/engineer) Rachel Studanski (enforcement) Sean O’Connor (stack testing) Adriane Lenshek (peer reviewer)

AQ File No. 116C; DQ 3323, DQ2463, Notification Attachments: 1. Emissions Increase Calculation Spreadsheets

2. Facility Description and CD-01 Forms 3. Points Calculator 4. Performance Testing Submittals and NOCs (Reopening) 5. 1990 Modeling memo


Attachment 1: Emissions Increase Calculation Spreadsheets

Temporary Boiler

Hoot Lake Plant Proposed Temporay Boiler -- Emission Calculations

Heat Input Capacity 9.9 mmbtu/hr (max)Fuel Low Sulfur No. 2 Fuel Oil

0.14 mmbtu/galMaximum Fuel Usage 70.7 gal/hrMax Sulfur Content 0.05 %

Pollutant

Emission Factor

(lbs/1000 gallons)1,2Emission Factor

(lb/mmbtu)1,3Maximum Hourly Emissions (lbs/hr)

Maximum Yearly Emissions (tons)

PM (filt.) 2 0.14 0.62PM-10 (filt. + cond.) 3.3 0.23 1.02PM-2.5 (filt. + cond.) 1.55 0.11 0.48SO2 142(S) 0.50 2.20NOx 0.194 1.92 8.41CO 0.157 1.55 6.81VOCs 0.018 0.18 0.78CO2 22300 1577 6906Lead 9.00E-06 8.91E-05 3.90E-04Mercury 4.60E-07 4.55E-06 1.99E-05HAPS - Speciated Organic Compounds 0.0412 2.91E-03 1.28E-02HAPS - Trace Elements Except Lead and Mercury 3.70E-05 3.66E-04 1.60E-03Total HAPS 3.37E-03 1.48E-02

2From AP-42 Section 1.3

1Note that either AP-42 or manufacturer emissions rates were used as emission factors depending on which gave the higher result to be conservative. Note that manufacturer emission rates are taken from an example of a temporary boiler that could potentially be brought on site and are subject to change.

3Manufacturer predicted emissions, except for HAPS which are from AP-42 Section 1.3 (Mercury Emission factor from EPRI/MPCA Instructions).

Page 1

UNIT #1 SUBB 2.9 Tons/HR18.6 MMBtu/ton

Firing Potential 53.5 Million btu/hrpermit limits 0.6 lb/mmbtu particulate limit

0.47 lb/mmbtu PM10 limit0.72 lb/mmbtu SO2 limit (100 lb/hr)

POLLUTANTEMISSION FACTOR

Emission Factor Source EMISSION RATE

lbs/ton lbs/hr

PM 11.16 Permit Limit 32.10PM10 8.74 Permit Limit 25.15SOx 34.77 Permit Limit 100.00NOx 8.80 FIRE 1-01-002-24(8.8) 25.31

VOC 0.05 FIRE 10100224 (5.0E-2) 0.14CO 5.00 FIRE 1-01-002-24 (5) 14.38

LEAD 0.0003 EPRI 0.001

HOOT LAKE PLANT UNIT 1EXTERNAL COMBUSTION BOILERS

CRITERIA POLLUTANTS

Unrestricted Potential MAXIMUM UNCONTROLLED

EMISSIONSPOLLUTION

CONTROL EFF.Hourly Potential

(lbs/hr) controlled

MAXIMUM CONTROLLED

EMISSIONStons/yr % tons/yr

Controlled EF 32.10 140.60Controlled EF 25.145 110.14

438.00 0 100.00 438.00110.87 0 25.31 110.87

0.63 0 0.1 0.6362.99 0 14.38 62.990.00 0 0.001 0.00

LIMITED CONTROLLED

EMISSIONStons/yr

140.60110.14438.00110.87

0.6362.990.00


Attachment 2: Facility Description and CD-01 Forms

ST. PAUL, MN 55155-4194

Show: Active and Pending RecordsAction:AQD Facility ID: 11100002Facility Name:

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD

17 February, 2011 13:55

FACILITY DESCRIPTION: EMISSION UNIT (EU)

MaxFuelInput

(mil Btu)

Otter Tail Power Co - Hoot Lake Plant

RetiredBy

(Action)

Operator DescriptionID No. EmissionUnit

Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity

SICManufacturer ModelNumber

Max.Design

Capacity

MaximumDesign

Capacity

Materials Units n Units d

53.51 Unit #1 BoilerEU 001 Active PER 004 CE 001SV 001 (M) Hr Steam4911Combustion Engineerin C-E13925 Type VU 30000 Lb

53.52 Unit #1 BoilerEU 001 Retired PER 005 SV 001 (M) Hr Steam4911Combustion Engineerin C-E13925 Type VU 30000 Lb

5903 Unit #2 BoilerEU 002 Active PER 003 CE 002CE 012CE 013CE 014

SV 002 (M) Hr Steam4911Combustion Engineerin C-E18659 400000 Lb

8504 Unit #3 BoilerEU 003 Active PER 003 CE 003CE 010CE 011CE 015

SV 002 (M) Hr Steam4911Babcock & Wilcox B & W 21022 625000 Lb

5 Fly Ash SiloEU 004 Active PER 003 CE 004SV 006 (M) 4911NA NA 900 Ton

6 Bottom Ash SiloEU 005 Active PER 003 CE 005SV 007 (M) 4911NA NA 400 Ton

17 Unit #1 Emergency GeneratorEU 006 Active PER 001 SV 004 (M) Energy4911Detroit Diesel Engine C 7125-7000 285 Kw

.68 Unit #3 Emergency GeneratorEU 007 Active PER 001 SV 005 (M) Energy4911Detroit Diesel Engine C 7086-7000 185 Kw

9 Rail Car Unloading BuildingEU 008 Removed PER 003 SV 003 (M) Hr 4911NA NA 450 Ton

10 Crushing & Conveying - this isFS003

EU 009 Retired PER 003 Hr 4911NA NA 450 Ton

11 Fuel Bunkers - insignificantactivity

EU 010 Retired PER 004 SV 008 (M) 4911NA NA

12 Fuel Bunker Vacuum System -insignificant activity

EU 011 Retired PER 004 CE 009SV 009 (M) 4911NA NA

9.913 Temporary Boiler(preauthorized)

EU 012 Active PER 005 SV 010 (M) 4911TBD TBD

Page 1 of 1 (a)

17 February, 2011 13:55

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat

Firing MethodAddedBy

(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status

1 EU 001 Group of SourcesPER 004 06/30/194812/31/1948 Spreader StokerActive

2 EU 001 Group of SourcesPER 005 06/30/194812/31/1948 Spreader StokerRetired

3 EU 002 PER 003 06/01/195912/31/1959 Pulverized Coal: Dry Bottom (Tangential)Active

4 EU 003 PER 003 06/01/196412/31/1964 Pulverized Coal: Dry BottomActive

5 EU 004 PER 003 06/01/197412/31/1974Active

6 EU 005 PER 003 06/01/195912/31/1959Active

7 EU 006 PER 001 06/01/196712/31/1967Active

8 EU 007 PER 001 06/01/196712/31/1967Active

9 EU 008 PER 003 06/01/195912/31/1959Removed

10 EU 009 PER 003 06/01/195912/31/1959Retired

11 EU 010 PER 004 01/01/1970Retired

12 EU 011 PER 004 01/01/1960Retired

13 EU 012 PER 005Active

Page 1 of 1 (b)

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

Show:Action:AQD Facility ID:Facility Name:

Active and Pending Records

11100002Otter Tail Power Co - Hoot Lake Plant

FACILITY DESCRIPTION: GROUPS (GP)

17 February, 2011 13:53

ID No. AddedBy

(Action)

RetiredBy

(Action)

Includein EI

OperatorID

for Item

Group Description Group ItemsGroupStatus

1 GP 001 PER 003 Boilers 2 and 3 CO Limits CE 010, CE 011, CE 012, CE 013, EU 002, EU 003, SV 002Active

2 GP 002 PER 004 Boilers 2 and 3 Front-Half Particulate Matter Limits EU 002, EU 003Active

3 GP 003 PER 003 NOX/SO2/CO2/flow monitors MR 009, MR 010, MR 011, MR 012, MR 013, MR 014, MR 015, MR 016Active

4 GP 004 PER 004 COMS MR 019, MR 020Active

Page 1 of 1


Show: Active and Pending RecordsAction:AQD Facility ID: 11100002Facility Name: Otter Tail Power Co - Hoot Lake Plant

17 February, 2011 13:55

FACILITY DESCRIPTION: FUGITIVE SOURCES (FS)

ID No. Fugitive Source Description YearInstalled

YearRemoved

AddedBy

(Action)

RetiredBy

(Action)

Insignif-icant

Activity

OperatorID

for Item

Pollutant(s)Emitted

ControlEquip.

ID No(s).

FugitiveSourceStatus

1 FS 001 PER 001 PM Coal StockpileActive

2 FS 002 PER 001 PM CE 006 Rail Car UnloadingActive

3 FS 003 PER 003 PM Crusher House & ConveyingActive

4 FS 004 PER 001 PM CE 004 Fly Ash Silo LoadingActive

5 FS 005 PER 001 PM CE 005 Bottom Ash Silo LoadingActive

6 FS 006 PER 003 PM Ash Haul Road - 0.7 miles, ash hauled by scraperActive

7 FS 007 PER 001 PM Ash Unloading at Disposal SiteActive

8 FS 008 PER 003 PM Coal Stockpile - scraper in & outActive

9 FS 009 PER 001 Ash Disposal SiteActive

Page 1 of 1


Show: Active and Pending RecordsAction:AQD Facility ID: 11100002Facility Name: Otter Tail Power Co - Hoot Lake Plant

17 February, 2011 13:54

FACILITY DESCRIPTION: STACK/VENTS (SV)

ID No. Discharge DirectionFlow Rate/Temperature

Information Source

Exit GasTemperature

at Top(ºF)

DesignFlow Rate

at Top(ACFM)

Width(feet)

Diameteror Length

(feet)

Inside DimensionsHeight ofOpening

FromGround(feet)

AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Operators DescriptionStack/Vent

Status

1 SV 001 Up, No CapManufacturer393800006133PER 003 Unit #1 StackActive

2 SV 002 Up, No CapManufacturer33077400013.39225PER 003 Unit #2 & #3 StackActive

3 SV 003 HorizontalManufacturer45165004.826.5PER 003 Rail Car BaghouseActive

4 SV 004 HorizontalManufacturer2803000.675PER 003 Unit #1 Emergency Diesel GeneratorActive

5 SV 005 HorizontalManufacturer2652000.58PER 003 Unit #3 Emergency Diesel GeneratorActive

6 SV 006 HorizontalManufacturer3503123175PER 003 Fly Ash Tank VentActive

7 SV 007 HorizontalManufacturer454000127PER 003 Bottom Ash Tank VentActive

8 SV 008 Up, No CapManufacturer4576001.33127.5PER 003 Fuel Bunker Filter VentActive

9 SV 009 Up, No CapManufacturer45.33122PER 003 Fuel Bunker Vacuum VentActive

10 SV 010 Up, With CapManufacturer43026601.3317.2PER 005 Temporary BoilerActive

Page 1 of 1

17 February, 2011 13:57

Show: Active Records Only

FACILITY DESCRIPTION: Potential-to-emit (by pollutant)

RetiredBy

(Action)

AddedBy

(Action)

ItemPollutant ActualEmissions

(tons per yr)

LimitedPotential

(tons per yr)

UnrestrictedPotential

(tons per yr)

HourlyPotential

(lbs per hr)

AQD Facility ID: 11100002Facility Name: Otter Tail Power Co - Hoot Lake Plant


Acetaldehyde

PER 004EU 001 1.710E-04 7.499E-04 7.499E-04

PER 003EU 002 1.890E-03 8.270E-03 8.270E-03

PER 003EU 003 2.720E-03 1.190E-02 1.190E-02

Totals 2.092E-02 2.092E-02 0.000E+00

Acetophenone

PER 004EU 001 5.880E-05 2.578E-04 2.578E-04

PER 003EU 002 7.080E-04 3.100E-03 3.100E-03

PER 003EU 003 1.020E-03 4.470E-03 4.470E-03

Totals 7.828E-03 7.828E-03 0.000E+00

Acrolein

PER 004EU 001 1.017E-04 4.452E-04 4.452E-04

PER 003EU 002 1.120E-03 4.910E-03 4.910E-03

PER 003EU 003 1.620E-03 7.070E-03 7.070E-03

Totals 1.243E-02 1.243E-02 0.000E+00

Benzene

PER 004EU 001 2.086E-04 9.139E-04 9.139E-04

PER 003EU 002 2.300E-03 1.010E-02 1.010E-02

PER 003EU 003 3.320E-03 1.450E-02 1.450E-02

Totals 2.551E-02 2.551E-02 0.000E+00

Arsenic compounds

PER 004EU 001 4.948E-04 2.167E-03 2.167E-03

PER 003EU 002 1.920E-03 8.400E-03 8.400E-03

PER 003EU 003 3.090E-03 1.350E-02 1.350E-02

Totals 2.407E-02 2.407E-02 0.000E+00

Benzyl chloride

PER 004EU 001 1.498E-05 6.561E-05 6.561E-05 0.000E+00

PER 003EU 002 1.650E-04 7.240E-04 7.240E-04

PER 003EU 003 2.380E-04 1.040E-03 1.040E-03

Totals 1.830E-03 1.830E-03 0.000E+00

Biphenyl

PER 004EU 001 8.560E-06 3.749E-05 3.749E-05

PER 003EU 002 9.440E-05 4.130E-04 4.130E-04

PER 003EU 003 1.360E-04 5.960E-04 5.960E-04

Totals 1.046E-03 1.046E-03 0.000E+00

Bromomethane

PER 004EU 001 4.762E-05 2.086E-04 2.086E-04

Page 1 of 11

17 February, 2011 13:57



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Bromomethane

PER 003EU 002 5.250E-04 2.300E-03 2.300E-03

PER 003EU 003 7.570E-04 3.310E-03 3.310E-03

Totals 5.819E-03 5.819E-03 0.000E+00

Beryllium

PER 004EU 001 4.633E-05 2.029E-04 2.029E-04

PER 003EU 002 1.320E-04 5.780E-04 5.780E-04

PER 003EU 003 2.200E-04 9.620E-04 9.620E-04

Totals 1.743E-03 1.743E-03 0.000E+00

Carbon disulfide

PER 004EU 001 5.885E-05 2.578E-04 2.578E-04

PER 003EU 002 6.490E-04 2.840E-03 2.840E-03

PER 003EU 003 9.350E-04 4.100E-03 4.100E-03

Totals 7.198E-03 7.198E-03 0.000E+00

Chlorobenzene

PER 004EU 001 8.560E-06 3.749E-05 3.749E-05

PER 003EU 002 9.440E-05 4.130E-04 4.130E-04

PER 003EU 003 1.360E-04 5.960E-04 5.960E-04

Totals 1.046E-03 1.046E-03 0.000E+00

Chloroform

PER 004EU 001 4.280E-05 1.875E-04 1.875E-04

PER 003EU 002 4.720E-04 2.070E-03 2.070E-03

PER 003EU 003 6.800E-04 2.980E-03 2.980E-03

Totals 5.237E-03 5.237E-03 0.000E+00

Cadmium compounds

PER 004EU 001 1.656E-04 7.253E-04 7.253E-04

PER 003EU 002 9.870E-04 4.320E-03 4.320E-03

PER 003EU 003 1.520E-03 6.650E-03 6.650E-03

Totals 1.170E-02 1.170E-02 0.000E+00

Carbon Monoxide

PER 004EU 001 1.450E+01 6.351E+01 6.351E+01

PER 003EU 002 1.363E+02 5.970E+02 5.970E+02

PER 003EU 003 8.500E+01 3.723E+02 3.723E+02

PER 001EU 006 7.140E-01 3.130E+00 1.800E-01

PER 001EU 007 4.590E-01 2.010E+00 1.100E-01

Totals 1.038E+03 1.033E+03 0.000E+00

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Cobalt compounds

PER 004EU 001 2.716E-04 1.190E-03 1.190E-03

PER 003EU 002 1.280E-03 5.610E-03 5.610E-03

PER 003EU 003 2.020E-03 8.850E-03 8.850E-03

Totals 1.565E-02 1.565E-02 0.000E+00

Chromium compounds

PER 004EU 001 8.522E-04 3.733E-03 3.733E-03

PER 003EU 002 4.600E-03 2.020E-02 2.020E-02

PER 003EU 003 7.160E-03 3.130E-02 3.130E-02

Totals 5.523E-02 5.523E-02 0.000E+00

Copper

PER 004EU 001 6.812E-04 2.984E-03 2.984E-03

PER 003EU 002 4.160E-03 1.820E-02 1.820E-02

PER 003EU 003 6.390E-03 2.800E-02 2.800E-02

Totals 4.918E-02 4.918E-02 0.000E+00

Dibenzofuran

PER 004EU 001 3.103E-05 1.359E-04 1.359E-04 0.000E+00

PER 003EU 002 3.420E-04 1.500E-03 1.500E-03

PER 003EU 003 4.930E-04 2.160E-03 2.160E-03

Totals 3.796E-03 3.796E-03 0.000E+00

Dibutyl phthalate

PER 004EU 001 5.885E-06 2.578E-05 2.578E-05

PER 003EU 002 6.490E-05 2.840E-04 2.840E-04

PER 003EU 003 9.350E-05 4.100E-04 4.100E-04

Totals 7.198E-04 7.198E-04 0.000E+00

1,4-Dichlorobenzene

PER 004EU 001 5.880E-05 2.578E-04 2.578E-04

PER 003EU 002 6.490E-04 2.840E-03 2.840E-03

PER 003EU 003 9.350E-04 4.100E-03 4.100E-03

Totals 7.198E-03 7.198E-03 0.000E+00

1,3-Dichloropropene

PER 004EU 001 3.852E-05 1.687E-04 1.687E-04

PER 003EU 002 4.250E-04 1.860E-03 1.860E-03

PER 003EU 003 6.120E-04 2.680E-03 2.680E-03

Totals 4.709E-03 4.709E-03 0.000E+00

Dimethyl phthalate

PER 004EU 001 4.815E-06 2.109E-05 2.109E-05

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Dimethyl phthalate

PER 003EU 002 5.310E-05 2.330E-04 2.330E-04

PER 003EU 003 7.650E-05 3.350E-04 3.350E-04

Totals 5.891E-04 5.891E-04 0.000E+00

2,4-Dinitrotoluene

PER 004EU 001 1.070E-05 4.686E-05 4.686E-05

PER 003EU 002 1.180E-04 5.170E-04 5.170E-04 0.000E+00

PER 003EU 003 1.700E-04 7.450E-04 7.450E-04

Totals 1.309E-03 1.309E-03 0.000E+00

Ethylbenzene

PER 004EU 001 4.280E-05 1.875E-04 1.875E-04

PER 003EU 002 4.720E-04 2.070E-03 2.070E-03

PER 003EU 003 6.800E-04 2.980E-03 2.980E-03

Totals 5.237E-03 5.237E-03 0.000E+00

Formaldehyde

PER 004EU 001 1.391E-04 6.093E-04 6.093E-04

PER 003EU 002 1.530E-03 6.720E-03 6.720E-03

PER 003EU 003 2.210E-03 9.680E-03 9.680E-03

Totals 1.701E-02 1.701E-02 0.000E+00

Hydrogen fluoride

PER 004EU 001 4.644E-02 2.034E-01 2.034E-01

PER 003EU 002 5.120E-01 2.240E+00 2.240E+00

PER 003EU 003 7.380E-01 3.230E+00 3.230E+00

Totals 5.673E+00 5.673E+00 0.000E+00

Methyl methacrylate

PER 004EU 001 5.885E-05 2.578E-04 2.578E-04

PER 003EU 002 6.490E-04 2.840E-03 2.840E-03

PER 003EU 003 9.350E-04 4.100E-03 4.100E-03

Totals 7.198E-03 7.198E-03 0.000E+00

Naphthalene

PER 004EU 001 3.317E-05 1.453E-04 1.453E-04

PER 003EU 002 3.660E-04 1.600E-03 1.600E-03

PER 003EU 003 5.270E-04 2.310E-03 2.310E-03

Totals 4.055E-03 4.055E-03 0.000E+00

HAPs - Total

PER 004EU 001 8.278E-02 3.626E-01 3.626E-01

PER 004EU 002 8.712E-01 3.816E+00 3.816E+00

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



HAPs - Total

PER 004EU 003 1.269E+00 5.558E+00 5.558E+00

Totals 9.736E+00 9.736E+00 0.000E+00

Mercury

PER 004EU 001 2.025E-04 8.869E-04 8.869E-04

PER 003EU 002 3.311E-03 1.450E-02 1.450E-02

PER 003EU 003 3.311E-03 1.450E-02 1.450E-02

Totals 2.989E-02 2.989E-02 0.000E+00

Phenol

PER 004EU 001 1.766E-04 7.733E-04 7.733E-04

PER 003EU 002 1.950E-03 8.530E-03 8.530E-03

PER 003EU 003 2.810E-03 1.230E-02 1.230E-02

Totals 2.160E-02 2.160E-02 0.000E+00

Styrene

PER 004EU 001 3.745E-05 1.640E-04 1.640E-04

PER 003EU 002 4.130E-04 1.810E-03 1.810E-03

PER 003EU 003 5.950E-04 2.610E-03 2.610E-03

Totals 4.584E-03 4.584E-03 0.000E+00

2,3,7,8-TCDD (dioxin)

PER 004EU 001 2.500E-09 1.080E-08 1.080E-08

PER 003EU 002 2.710E-08 1.190E-07 1.190E-07

PER 003EU 003 3.910E-08 1.710E-07 1.710E-07

Totals 3.008E-07 3.008E-07 0.000E+00

Tetrachloroethylene

PER 004EU 001 2.247E-05 9.842E-05 9.842E-05

PER 003EU 002 2.480E-04 1.090E-03 1.090E-03

PER 003EU 003 3.570E-04 1.560E-03 1.560E-03

Totals 2.748E-03 2.748E-03 0.000E+00

Toluene

PER 004EU 001 9.095E-05 3.984E-04 3.984E-04

PER 003EU 002 1.000E-03 4.390E-03 4.390E-03

PER 003EU 003 1.450E-03 6.330E-03 6.330E-03

Totals 1.112E-02 1.112E-02 0.000E+00

1,1,1-Trichloroethane

PER 004EU 001 3.264E-05 1.429E-04 1.429E-04

PER 003EU 002 3.600E-04 1.580E-03 1.580E-03

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



1,1,1-Trichloroethane

PER 003EU 003 5.190E-04 2.270E-03 2.270E-03

Totals 3.993E-03 3.993E-03 0.000E+00

Vinyl acetate

PER 004EU 001 1.659E-05 7.264E-05 7.264E-05

PER 003EU 002 1.830E-04 8.010E-04 8.010E-04

PER 003EU 003 2.640E-04 1.150E-03 1.150E-03

Totals 2.024E-03 2.024E-03 0.000E+00

Vinyl chloride

PER 004EU 001 3.906E-05 1.711E-04 1.711E-04 0.000E+00

PER 003EU 002 4.310E-04 1.890E-03 1.890E-03

PER 003EU 003 6.210E-04 2.720E-03 2.720E-03

Totals 4.781E-03 4.781E-03 0.000E+00

Hydrochloric acid

PER 003EU 001 6.960E-02 3.050E-01 3.050E-01

PER 003EU 002 3.000E-01 1.310E+00 1.310E+00

PER 003EU 003 4.320E-01 1.890E+00 1.890E+00

Totals 3.505E+00 3.505E+00 0.000E+00

Manganese compounds

PER 004EU 001 2.177E-03 9.537E-03 9.537E-03

PER 003EU 002 1.150E-02 5.030E-02 5.030E-02

PER 003EU 003 1.790E-02 7.830E-02 7.830E-02

Totals 1.381E-01 1.381E-01 0.000E+00

Acenaphthene

PER 004EU 001 1.280E-06 5.624E-06 5.624E-06

PER 003EU 002 1.420E-05 6.200E-05 6.200E-05

PER 003EU 003 2.040E-05 8.940E-05 8.940E-05

Totals 1.570E-04 1.570E-04 0.000E+00

Acenaphthylene

PER 004EU 001 4.170E-07 1.828E-06 1.828E-06

PER 003EU 002 4.600E-06 2.020E-05 2.020E-05

PER 003EU 003 6.630E-06 2.900E-05 2.900E-05

Totals 5.103E-05 5.103E-05 0.000E+00

Anthracene

PER 004EU 001 6.955E-07 3.046E-06 3.046E-06

PER 003EU 002 7.670E-06 3.360E-05 3.360E-05

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Anthracene

PER 003EU 003 1.110E-05 4.840E-05 4.840E-05

Totals 8.505E-05 8.505E-05 0.000E+00

Benz(a)anthracene

PER 004EU 001 4.012E-07 1.758E-06 1.758E-06

PER 003EU 002 4.420E-06 1.940E-05 1.940E-05

PER 003EU 003 6.380E-06 2.790E-05 2.790E-05

Totals 4.906E-05 4.906E-05 0.000E+00

Benzo(a)pyrene

PER 004EU 001 1.017E-07 4.452E-07 4.452E-07

PER 003EU 002 1.120E-06 4.910E-06 4.910E-06

PER 003EU 003 1.610E-06 7.070E-06 7.070E-06

Totals 1.243E-05 1.243E-05 0.000E+00

Benzo(b)fluoranthene

PER 004EU 001 5.136E-07 2.250E-06 2.250E-06

PER 003EU 002 5.660E-06 2.480E-05 2.480E-05

PER 003EU 003 8.160E-06 3.570E-05 3.570E-05

Totals 6.275E-05 6.275E-05 0.000E+00

Benzo(ghi)perylene

PER 004EU 001 8.030E-08 3.515E-07 3.515E-07

PER 003EU 002 8.850E-07 3.880E-06 3.880E-06

PER 003EU 003 1.270E-06 5.580E-06 5.580E-06

Totals 9.812E-06 9.812E-06 0.000E+00

Chrysene

PER 004EU 001 2.943E-07 1.289E-06 1.289E-06

PER 003EU 002 3.245E-06 1.420E-05 1.420E-05 0.000E+00

PER 003EU 003 4.680E-06 2.050E-05 2.050E-05

Totals 3.599E-05 3.599E-05 0.000E+00

Dibenz(a,h)anthracene

PER 004EU 001 4.810E-08 2.109E-07 2.109E-07

PER 003EU 002 5.310E-07 2.330E-06 2.330E-06

PER 003EU 003 7.650E-07 3.350E-06 3.350E-06

Totals 5.891E-06 5.891E-06 0.000E+00

Fluoranthene

PER 004EU 001 8.025E-06 3.515E-05 3.515E-05

PER 003EU 002 8.850E-05 3.880E-04 3.880E-04

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RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Fluoranthene

PER 003EU 003 1.280E-04 5.580E-04 5.580E-04

Totals 9.811E-04 9.811E-04 0.000E+00

Fluorene

PER 004EU 001 7.490E-06 3.281E-05 3.281E-05

PER 003EU 002 8.260E-05 3.620E-04 3.620E-04

PER 003EU 003 1.190E-04 5.210E-04 5.210E-04

Totals 9.158E-04 9.158E-04 0.000E+00

Indeno(1,2,3-cd)pyrene

PER 004EU 001 9.100E-08 3.984E-07 3.984E-07

PER 003EU 002 1.000E-06 4.390E-06 4.390E-06

PER 003EU 003 1.450E-06 6.330E-06 6.330E-06

Totals 1.112E-05 1.112E-05 0.000E+00

Isophorone

PER 004EU 001 6.420E-05 2.812E-04 2.812E-04

PER 003EU 002 7.080E-04 3.100E-03 3.100E-03

PER 003EU 003 1.020E-03 4.470E-03 4.470E-03

Totals 7.851E-03 7.851E-03 0.000E+00

m-Xylenes

PER 004EU 001 4.387E-05 1.922E-04 1.922E-04

PER 003EU 002 4.840E-04 2.120E-03 2.120E-03

PER 003EU 003 6.970E-04 3.050E-03 3.050E-03

Totals 5.362E-03 5.362E-03 0.000E+00

Methylene chloride (dichlorome

PER 004EU 001 1.926E-04 8.436E-04 8.436E-04

PER 003EU 002 2.120E-03 9.300E-03 9.300E-03

PER 003EU 003 3.060E-03 1.340E-02 1.340E-02

Totals 2.354E-02 2.354E-02 0.000E+00

o-Xylenes

PER 004EU 001 2.354E-05 1.031E-04 1.031E-04

PER 003EU 002 2.600E-04 1.140E-03 1.140E-03

PER 003EU 003 3.740E-04 1.640E-03 1.640E-03

Totals 2.883E-03 2.883E-03 0.000E+00

Phenanthrene

PER 004EU 001 2.247E-05 9.842E-05 9.842E-05

PER 003EU 002 2.480E-04 1.090E-03 1.090E-03

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(Action)


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(tons per yr)


(tons per yr)

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(lbs per hr)



Phenanthrene

PER 003EU 003 3.570E-04 1.560E-03 1.560E-03

Totals 2.748E-03 2.748E-03 0.000E+00

Propionaldehyde

PER 004EU 001 1.017E-04 4.452E-04 4.452E-04

PER 003EU 002 1.120E-03 4.910E-03 4.910E-03

PER 003EU 003 1.620E-03 7.070E-03 7.070E-03

Totals 1.243E-02 1.243E-02 0.000E+00

Pyrene

PER 004EU 001 3.531E-06 1.547E-05 1.547E-05

PER 003EU 002 3.890E-05 1.710E-04 1.710E-04

PER 003EU 003 5.610E-05 2.460E-04 2.460E-04

Totals 4.325E-04 4.325E-04 0.000E+00

Nickel compounds

PER 004EU 001 8.334E-04 3.650E-03 3.650E-03

PER 003EU 002 5.090E-03 2.230E-02 2.230E-02

PER 003EU 003 7.810E-03 3.420E-02 3.420E-02

Totals 6.015E-02 6.015E-02 0.000E+00

Nitrogen Oxides

PER 004EU 001 2.552E+01 1.118E+02 1.118E+02

PER 003EU 002 1.518E+02 1.034E+03 1.034E+03

PER 003EU 003 3.910E+02 1.713E+03 1.713E+03

PER 001EU 006 3.283E+00 8.200E-01 8.200E-01

PER 001EU 007 2.111E+00 5.300E-01 5.300E-01

Totals 2.859E+03 2.859E+03 0.000E+00

PM < 2.5 micron

PER 004EU 001 2.515E+01 4.625E+02 1.102E+02

PER 004EU 002 3.995E+02 1.371E+03 1.215E+03

PER 004EU 003 5.170E+02 1.970E+03 1.750E+03

PER 004EU 004 1.340E+00 5.870E+00

PER 004EU 005 3.430E+00 1.500E+01 2.500E+00

PER 004EU 006 2.240E-01 9.800E-01 6.000E-02

PER 004EU 007 1.440E-01 6.300E-01 4.000E-02

Totals 3.820E+03 3.083E+03 0.000E+00

Lead

PER 004EU 001 8.074E-04 3.537E-03 3.537E-03

PER 003EU 002 3.000E-01 1.300E+00 1.300E+00

Page 9 of 11

17 February, 2011 13:57



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Lead

PER 003EU 003 4.300E-01 1.900E+00 1.900E+00

Totals 3.204E+00 3.204E+00 0.000E+00

PM < 10 micron

PER 003EU 001 2.515E+01 4.625E+02 1.102E+02

PER 003EU 002 3.995E+02 1.371E+03 1.215E+03

PER 003EU 003 5.170E+02 1.970E+03 1.750E+03

PER 003EU 004 1.340E+00 5.870E+00

PER 003EU 005 3.430E+00 1.500E+01 2.500E+00

PER 001EU 006 2.240E-01 9.800E-01 6.000E-02

PER 001EU 007 1.440E-01 6.300E-01 4.000E-02

PER 003FS 001 1.400E-01 6.000E-01 6.000E-01

PER 003FS 002 4.600E-03 8.700E-01 2.000E-02

PER 003FS 003 2.100E-01 2.630E+00 9.100E-01

PER 003FS 004 6.800E-01 2.980E+00 2.980E+00

PER 003FS 005 2.900E-01 1.280E+00 1.280E+00

PER 003FS 006 2.100E+00 9.100E+00 9.100E+00

PER 003FS 007 7.000E-03 3.160E-02 3.160E-02

PER 003FS 008 1.100E-01 5.000E-01 5.000E-01

PER 003FS 009 3.000E-01 1.330E+00 1.330E+00

PER 003SV 008 3.260E+00 1.430E+01

Totals 3.840E+03 3.114E+03 0.000E+00

Polycyclic organic matter

PER 001EU 002 1.000E-03 6.300E-03

PER 001EU 003 2.000E-03 7.800E-03

Totals 1.410E-02 0.000E+00 0.000E+00

Total Particulate Matter

PER 003EU 001 3.210E+01 2.313E+03 1.406E+02

PER 003EU 002 5.100E+02 5.957E+03 1.551E+03

PER 003EU 003 6.600E+02 8.563E+03 2.234E+03

PER 003EU 004 1.340E+00 5.870E+00 0.000E+00

PER 003EU 005 3.430E+00 1.500E+01 2.500E+00 0.000E+00

PER 001EU 006 2.345E-01 1.030E+00 6.000E-02

PER 001EU 007 1.508E-01 6.600E-01 4.000E-02

PER 003EU 008 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 003FS 001 1.400E-01 6.000E-01 6.000E-01

Page 10 of 11

17 February, 2011 13:57



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Total Particulate Matter

PER 003FS 002 4.600E-03 8.700E-01 2.000E-02

PER 003FS 003 2.100E-01 2.630E+00 9.100E-01

PER 003FS 004 6.800E-01 2.980E+00 2.980E+00

PER 003FS 005 2.900E-01 1.280E+00 1.280E+00

PER 003FS 006 5.810E+00 2.546E+01 2.546E+01

PER 003FS 007 7.000E-03 3.160E-02 3.160E-02

PER 003FS 008 1.100E-01 5.000E-01 5.000E-01

PER 003FS 009 3.000E-01 2.660E+00 2.660E+00

PER 003SV 003 0.000E+00 0.000E+00 0.000E+00

PER 003SV 008 3.260E+00 1.427E+03 1.430E+01 0.000E+00

Totals 1.831E+04 3.982E+03 0.000E+00

Antimony compounds

PER 004EU 001 1.660E-04 7.260E-04 7.260E-04

PER 003EU 002 8.410E-04 3.680E-03 3.680E-03

PER 003EU 003 1.320E-03 5.770E-03 5.770E-03

Totals 1.018E-02 1.018E-02 0.000E+00

Selenium compounds

PER 004EU 001 4.660E-05 2.041E-04 2.041E-04

PER 003EU 002 5.140E-04 2.250E-03 2.250E-03

PER 003EU 003 7.400E-04 3.240E-03 3.240E-03

Totals 5.694E-03 5.694E-03 0.000E+00

Sulfur Dioxide

PER 004EU 001 1.000E+02 4.380E+02 4.380E+02

PER 003EU 002 1.770E+03 7.753E+03 7.753E+03

PER 003EU 003 2.550E+03 1.117E+04 1.117E+04

PER 001EU 006 2.184E-01 9.600E-01 5.000E-02

PER 001EU 007 1.404E-01 6.100E-01 4.000E-02

Totals 1.936E+04 1.936E+04 0.000E+00

Volatile Organic Compounds

PER 004EU 001 1.500E-01 6.400E-01 6.400E-01

PER 003EU 002 1.890E+00 8.300E+00 8.300E+00

PER 003EU 003 2.760E+00 1.190E+01 1.190E+01

PER 001EU 006 2.247E-01 6.000E-02 6.000E-02

PER 001EU 007 1.445E-01 4.000E-02 4.000E-02

Totals 2.094E+01 2.094E+01 0.000E+00

Page 11 of 11

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Otter Tail Power Co - Hoot Lake Plant


27 Apr, 2011 13:37Page 1 of 44

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr SOURCE-SPECIFIC REQUIREMENTS1.0

CD Minn. R. 7007.1300, subp. 3; 40CFR Section 72.9; 40 CFRSection 97.121; Minn. R.7007.0800, subp. 2

Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices. Modeling parameters in Appendix B are included for reference onlyand compliance with these parameters is achieved through meeting therequirements of the permit.

2.0

CD Minn. Stat. Section 116.07, subd.4a; Minn. R. 7007.0100; Minn. R.7007.0800, subp. 2; Minn. R.7011.0150; Minn. R. 7009.0020

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand record keeping specified in the control plan. The plan may be amended by thePermittee with the Commissioner's approval. If the Commissioner determines thePermittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan,then the Permittee may be required to amend the control plan and/or to install andoperate particulate matter ambient monitors as requested by the Commissioner.

3.0

CD hdr DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCEREVIEW (NSR)

4.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.0800, subp. 2

These requirements apply if a reasonable possibility (RP) as defined in 40 CFRSection 52.21(r)(6)(vi) exists that a proposed project, analyzed using theactual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test atSection 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, mayresult in a significant emissions increase (SEI). If the ATPA test is not used for theproject, or if there is no RP that the proposed project could result in a SEI, theserequirements do not apply to that project. The Permittee is only subject to thePreconstruction Documentation requirement for a project where a RP occurs onlywithin the meaning of Section 52.2(r)(6)(vi)(a).

Even though a particular modification is not subject to NSR, or where there isn't aRP that a proposed project could result in a SEI, a permit amendment,recordkeeping, or notification may still be required by Minn. R. 7007.1150 -7007.1500.

5.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.1200, subp. 4;Minn. R. 7007.0800, subps. 4 & 5

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following:

1. Project description2. Identification of any emission unit (EU) whose emissions of an NSR pollutantcould be affected3. Pre-change potential emissions of any affected existing EU, and the projectedpost-change potential emissions of any affected existing or new EU.4. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excluded dueto increases not associated with the modification and that the EU could haveaccommodated during the baseline period, an explanation of why the amountswere excluded, and any creditable contemporaneous increases and decreases thatwere considered in the determination.

The Permittee shall maintain records of this documentation.

6.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potential emissionsin the hybrid test. The Permittee shall calculate and maintain a record of the sum ofthe actual and potential (if the hybrid test was used in the analysis) emissions of theregulated pollutant, in tons per year on a calendar year basis, for a period of 5years following resumption of regular operations after the change, or for a period of10 years following resumption of regular operations after the change if the projectincreases the design capacity of or potential to emit of any unit associated with theproject.

7.0




27 Apr, 2011 13:37Page 2 of 44


The Permittee must submit a report to the Agency if the annual summed (actual,plus potential if used in hybrid test) emissions differ from the preconstructionprojection and exceed the baseline actual emissions by a significant amount aslisted at 40 CFR Section 52.21(b)(23). Such report shall be submitted to theAgency within 60 days after the end of the year in which the exceedances occur.The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.

8.0

CD Title I Condition: 40 CFR Section52.21(r)(6)(ii); Minn. R. 7007.3000;Minn. R. 7007.0800, subps. 4 & 5

Before beginning actual construction of any project which includes any electricutility steam generating unit (EUSGU), the Permittee shall submit a copy of thepreconstruction documentation (items 1-4 under Preconstruction Documentation,above) to the Agency.

9.0


For any project which includes any EUSGU, the Permittee must submit an annualreport to the Agency, within 60 days after the end of the calendar year. The reportshall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The quantified annual emissions analyzed using the ATPA test, plus thepotential emissions associated with the same project analyzed as part of a hybridtest.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection, if that is the case.

10.0


For any project which does not include any EUSGU, the Permittee must submit areport to the Agency if the annual summed (actual, plus potential used in hybridtest) emissions differ from the preconstruction projection and exceed the baselineactual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23).Such report shall be submitted to the Agency within 60 days after the end of theyear in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions rate is exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.

11.0

CD hdr OPERATIONAL REQUIREMENTS12.0

CD 40 CFR pt. 50; Minn. Stat. Section116.07, subds. 4a & 9; Minn. R.7007.0100, subps. 7A, 7L & 7M;Minn. R. 7007.0800, subps. 1, 2 &4; Minn. R. 7009.0010-7009.0080

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

13.0

CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

14.0

CD Minn. R. 7007.0800, subp. 2;Minn. R. 7007.0800, subp. 16(J)

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated.

15.0

CD Minn. R. 7007.0800, subps. 14and 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

16.0




27 Apr, 2011 13:37Page 3 of 44

CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

17.0

CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

18.0

CD Minn. R. 7011.1110 Coal handling activities shall comply with requirements of Minn. R. 7011.0150.19.0

CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

20.0

CD Minn. R. 7007.0800, subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

21.0

CD Minn. R. 7007.0800, subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

22.0

CD hdr PERFORMANCE TESTING23.0

CD Minn. R. ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

24.0

CD Minn. Rs. 7017.2030, subp. 1-4,7017.2018 and Minn. R.7017.2035, subp. 1-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B foradditional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

25.0

CD Minn. R. 7017.2025, subp. 3 Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof a subsequent performance test on the same unit as specified by Minn. R.7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

26.0

CD hdr MONITORING REQUIREMENTS27.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

28.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

29.0

CD hdr MODELING REQUIREMENTS30.0


The parameters used in PM10 modeling for permit number 11100002-004 arelisted in Appendix B of this permit.

31.0




27 Apr, 2011 13:37Page 4 of 44


Modeling Triggers: For changes that do not require a permit amendment or thatrequire a minor permit amendment, and that affect any modeled parameter oremission rate documented in Appendix B, a Remodeling Submittal requirement isnot triggered. The Permittee shall keep updated records on site of all parametersand emission rates. The Permittee shall submit any changes to parameters andemission rates with the next required remodeling submittal.

For changes that require a moderate or major permit amendment and affect anymodeled parameter or emission rate, a Remodeling Submittal requirement istriggered. The Permittee shall include previously made changes to parameters andemission rates that did not trigger a remodeling submittal with this modelingsubmittal.

32.0


Remodeling Submittal: The Permittee must submit to the Commissioner forapproval changes meeting the above criteria and must wait for a written approval(in the form of an issued permit amendment) before making such changes. Theinformation submitted must include, for stack and vent sources, source emissionrate, location, height, diameters, exit velocity, exit temperature, discharge direction,use of rain caps or rain hats, and, if applicable, locations and dimensions of nearbybuildings. For non-stack/vent sources, this includes the source emission rate,location, size and shape, release height, and, if applicable, any emission ratescalars, and the initial lateral dimensions and initial vertical dimensions andadjacent building heights.

33.0


Remodeling Submittal, continued:The plume dispersion characteristics due to the revisions of the information mustbe equivalent to or better than the dispersion characteristics modeled June 2006.The Permittee shall demonstrate this equivalency in the proposal. If the informationdoes not demonstrate equivalent or better dispersion characteristics, or if aconclusion cannot readily be made about the dispersion, the Permittee must submitfull remodeling.

34.0

CD hdr RECORDKEEPING35.0

CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, for a period of five (5) years from the date of monitoring,sample, measurement, or report. Records which must be retained at this locationinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

36.0

CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

37.0

CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

38.0

CD hdr REPORTING/SUBMITTALS39.0

CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

40.0




27 Apr, 2011 13:37Page 5 of 44

CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

41.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

42.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

43.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearstarting 04/08/2009 . The first semiannual report submitted by the Permittee shallcover the calendar half-year in which the permit is issued. The first report of eachcalendar year covers January 1 - June 30. The second report of each calendar yearcovers July 1 - December 31. If no deviations have occurred, the Permittee shallsubmit the report stating no deviations.

44.0

CD Minn. R. 7007.1150 through Minn.R. 7007.1500

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

45.0

CD 40 CFR Section 63.52(b)(1) and63.52(e)(1)

For changes that do not require a permit amendment:- The Permittee shall submit a Part 1 MACT application within 30 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(a).- The Permittee shall submit a Part 2 MACT application within 90 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(b).112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance,112(j) affected sources include industrial, commercial, and institutional boilers andprocess heaters; brick and structural clay products manufacturing; clay ceramicsmanufacturing.

46.0

S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit

47.0

CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

48.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting04/08/2009 (for the previous calendar year). The Permittee shall submit this on aform approved by the Commissioner, both to the Commissioner and to the US EPAregional office in Chicago. This report covers all deviations experienced during thecalendar year.

49.0


Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

50.0

S/A 40 CFR Section 75.64; Minn. R.7017.1110, subp. 1 & 2

Excess Emissions/Downtime Reports (EER's): due 30 days after end of eachcalendar quarter starting 04/08/2009 (Submit Deviations Reporting Form DRF-1 asamended). The EER shall indicate all periods of monitor bypass and all periods ofexceedances of the limit including exceedances allowed by an applicable standard,i.e. during startup, shutdown, and malfunctions.

51.0


Emission Fees: due 60 days after receipt of an MPCA bill.52.0




27 Apr, 2011 13:37Page 6 of 44

Subject Item: GP 001 Boilers 2 and 3 CO Limits

Associated Items: CE 010 Low Nox Burners

CE 011 Overfire Air


CE 013 Overfire Air




NC/CA


CD Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000

Alternative Operating Scenarios

This permit contains limits on Carbon Monoxide (CO) emissions from the unitslisted in GP001. These limits are written as two Alternative Operating Scenarios(AOS). The Permittee must comply with AOS 1 or AOS 2 at all times. WhetherAOS 1 or AOS 2 applies depends on the CO emission factors for EU002 andEU003, as measured with a performance test. If the conditions of AOS 1 cannot bemet, the Permittee shall comply with AOS 2.

1.0

CD Minn. R. 7007.0800, subp. 11 Alternative Operating Scenario Recordkeeping. The Permittee shall keep a recordshowing which AOS the facility is operating under at all times. The record must bekept in a central location and be available for inspection upon request. The recordmust contain sufficient information, including test and/or monitoring data, so that itis clear which AOS the facility is operating under, and which one(s) it may beallowed to operate under.

The Permittee shall comply with AOS 2 if either of the CO emission factors (atEU002 and EU003) are not met. The Permittee may revert from AOS 2 to AOS 1under the following conditions:

1. Subsequent CO performance test(s) measure emissions no greater than theemission factors listed at EU002 and EU003; and

2. The Permittee has continued to follow AOS 1 recordkeeping requirements asdescribed at 40 CFR Section 52.21(r)(6) during the 5 years following theresumption of regular operation, regardless of AOS 2 recordkeeping requirements.

2.0

CD hdr AOS 13.0


The Permittee shall individually demonstrate that the post-modification EU002 COemission factor is less than or equal to 0.231 lb/mmBtu and that thepost-modification EU003 CO emission factor is less than or equal to 0.100lb/mmBtu.

Additional monitoring, recordkeeping, and reporting associated with this condition(beyond what is described under Subject Items EU002 and EU003) is as describedin 40 CFR Section 52.21(r)(6), and in this permit under Subject Item Total Facility,under the heading "Determining if a Project/Modification is Subject to New SourceReview."

If either emission factor is not demonstrated, the Permittee must comply with AOS2.

See Subject Items EU002 and EU003 for emission factor demonstrationrequirements.

4.0

CD hdr AOS 25.0




27 Apr, 2011 13:37Page 7 of 44

LIMIT Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000

Carbon Monoxide: less than or equal to 907 tons/year using 12-month Rolling Sumfor the two boilers combined. This limit applies beginning at the end of the 12thmonth following initial startup of EU002 following the LNB/OFA modification orimplementation of AOS2, as applicable. During the first 11 months following eitherinitial startup or implementation of AOS 2, as applicable, the following cumulativelimits apply:


Month 1 is the month during which initial startup of EU002 following the month themodification occurs.

6.0

LIMIT Minn. R. 7007.0800, subp. 2, toavoid requirement for Air EmissionRisk Analysis

Carbon Monoxide: less than or equal to 1114 tons/year using 12-month RollingSum for the two boilers combined.

7.0

CD Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000; to avoid requirementfor Air Emission Risk Analysis


1. The combined CO emissions for the previous calendar month from EU002 andEU003 (EU002 CO and EU003 CO, calculated as described under Subject ItemsEU002 and EU003, respectively), and

2. The combined CO emissions from EU002 and EU003 for the previous 12 months(12-month rolling sum).

8.0




27 Apr, 2011 13:37Page 8 of 44

Subject Item: GP 002 Boilers 2 and 3 Front-Half Particulate Matter Limits



NC/CA


LIMIT Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000

Front-half Particulate Matter: less than or equal to 349.3 tons/year using 12-monthRolling Sum for the two boilers combined. This limit applies beginning at the end ofthe 12th month following initial startup of EU002 and EU003 following the mercuryreduction modification. During the first 11 months following initial startup, thefollowing cumulative limits apply:


Month 1 is the month during which initial startup of EU002 following the monthinitial startup occurs.

1.0

CD Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000; to avoid requirementfor Air Emission Risk Analysis


1. The combined front half PM emissions for the previous calendar month fromEU002 and EU003 (FHPM2 and FHPM3, calculated as described under SubjectItems EU002 and EU003, respectively), and

2. The combined front half PM emissions from EU002 and EU003 for the previous12 months (12-month rolling sum).

2.0




27 Apr, 2011 13:37Page 9 of 44

Subject Item: GP 003 NOX/SO2/CO2/flow monitors

Associated Items: MR 009 EU 002 SO2 CEMS








NC/CA


CD 40 CFR pt. 75, Appendix B,section 2.1

Daily Calibration Error (CE) Test: conduct daily CE testing of each gas monitoringsystem according to the procedures in section 6.3.1 of Appendix A to this part, andof each flow monitoring system according to the procedure in section 6.3.2 ofAppendix A to this part.

1.0

CD 40 CFR pt. 75, Appendix B,section 2.2.1; Minn. R. 7017.1020

Linearity Test (Acid Rain Program): due before end of each QA operating quarter(as defined in Section 72.) in accordance with procedures in 40 CFR pt. 75,Appendix B, Sections 2.2.1, and Appendix A, Section 6.2.

2.0

CD 40 CFR pt. 75, Appendix B,section 2.3.1; Minn. R. 7017.1020

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendarhalf-year following CEM Certification Test, i.e., once every two successive QAoperating quarters (calendar quarter in which there are at least 168 unit operatinghours). Conduct a RATA on all CEMS required by the Acid Rain Program, inaccordance with 40 CFR pt. 75, Appendix B. Relative accuracy test audits may beperformed annually (i.e., once every four successive QA operating quarters, ratherthan once every two successive QA operating quarters) if any of the conditionslisted in 40 CFR pt. 75, Appendix B, Section 2.3.1.2(a) through Section 2.3.1.2(i)are met.

3.0

CD Minn. R. 7017.1180, subp. 2 Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMSRelative Accuracy Test Audit (RATA)).

4.0

CD 40 CFR Section 75.21 CEMS QA/QC: The owner or operator of an affected facility shall operate,calibrate, and maintain each CEMS according to the QA/QC procedure in 40 CFRpt. 75, Appendix B as amended.

5.0

CD 40 CFR Section 75.57 Recordkeeping: The owner or operator must retain records of all CEMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

6.0




27 Apr, 2011 13:37Page 10 of 44

Subject Item: GP 004 COMS

Associated Items: MR 019 EU002 COMS

MR 020 EU003 COMS

NC/CA


CD Minn. R. 7017.1200, subp. 1, 2 &3

All COMS shall complete a minimum of one cycle of sampling and analyzing foreach successive 10-second period and one cycle of data for each successive6-minute period.

1.0

CD Minn. R. 7017.1090, subp. 1; 40CFR Section 64.7(c); Minn. R.7017.0200

Continuous Operation: COMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A COMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B,C and D of Minn. R. 7017.1090, subp. 2.

2.0

CD Minn. R. 7017.1210, subp. 1; 40CFR Section 64.7(b); Minn. R.7017.0200

QA Plan Required: Develop and implement a written quality assurance plan whichcovers each COMS. The plan shall be on site and available for inspection within30 days after monitor certification. The plan shall contain the written procedureslisted in Minn. R. 7017.1210, subp. 1.

3.0

CD Minn. R. 7017.1210; 40 CFRSection 64.7(b); Minn. R.7017.0200

COMS QA/QC: The owner or operator of an affected facility is subject to theperformance specifications listed in 40 CFR pt. 60, Appendix B and shall operate,calibrate, and maintain each COMS according to the QA/QC procedures in Minn.R. 7017.1210.

4.0


COMS Daily Calibration Drift Check: The Permittee must automatically, intrinsic tothe opacity monitor, check the zero and upscale (span) calibration drifts at leastonce daily. The acceptable range is as defined in 40 CFR pt. 60, Appendix B, PS-1.

For COMS without automatic zero adjustments: The optical surfaces exposed tothe effluent gases shall be cleaned prior to performing the zero and span driftadjustments.

For COMS with automatic zero adjustment: The optical surfaces shall be cleanedwhen the cumulative automatic zero compensation exceeds 4 percent opacity.Minimum procedures must include an automated method for producing a simulatedzero opacity condition and an upscale opacity condition as specified in 40 CFR60.13(d)(2).

5.0


COMS Calibration Error Audit: due before end of each calendar half-year followingPermit Issuance. Conduct three point calibration error audits at least 3 monthsapart but no greater than 8 months apart. Conduct audits in accordance with Minn.R. 7017.1210, subp. 3.

6.0


Attenuator Calibration: The Permittee shall have an independent testing companyconduct calibrations of each of the neutral density filters used in the calibrationerror audit according to the procedure in 40 CFR pt. 60, Appendix B, Section 7.

7.0

CD Minn. R. 7017.1220; 40 CFRSection 64.7(b); Minn. R.7017.0200

COMS Calibration Error Audit Results Summary: due 30 days after end of eachcalendar quarter in which the COMS calibration error audit was completed.

8.0

CD Minn. R. 7017.1130 Recordkeeping: The owner or operator must retain records of all COMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

9.0




27 Apr, 2011 13:37Page 11 of 44

NC/CA


CD hdr EMISSION AND OPERATING LIMITS1.0

LIMIT Minn. R. 7011.0510, subp. 1 Total Particulate Matter: less than or equal to 0.60 lbs/million Btu heat input2.0

LIMIT 40 CFR pt. 50; Minn. Stat. Section116.07, subds. 4a & 9; Minn. R.7007.0100, subps. 7A, 7L & 7M;Minn. R. 7007.0800, subps. 1, 2 &4; Minn. R. 7009.0010-7009.0080

Particulate Matter < 10 micron: less than or equal to 0.47 lbs/million Btu heat inputusing 3-hour Block Average

3.0


Sulfur Dioxide: less than or equal to 100 lbs/hour using 1-Hour Average4.0

LIMIT Minn. R. 7011.0510, subp. 1 Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 3-hourAverage .

5.0

LIMIT Minn. R. 7011.0510, subp. 2 Opacity: less than or equal to 20 percent opacity using 6-minute Average except forone six-minute period per hour of not more than 60 percent opacity.

6.0

CD Minn. R. 7007.0800, subp. 2 Limit fuels to: bituminous coal, sub-bituminous coal, used oil, non-hazardous oilspill cleanup materials, boiler cleaning agents and for startup only: wood, cardboardand paper.

7.0

CD Minn. R. 7007.0800, subp. 2 Boiler cleaning agents limited to: EDTA type generated on-site, 5% of total mass orheat input, oxygen limited to 3% or greater, agents may only be burned while theboiler is operating at 75 percent of rated capacity or greater.

8.0

CD Minn. R. 7045.0790 to 7045.0990 Limit oil cleanup materials to: commercial floor dry, commercial sorbent pads andtubes, sawdust, rags/paper towels. Waste must be a minimum of 5000 Btu's perpound in accordance with Minn. R. 7045.0805, and is limited to 5% of mass inputunless stack emission testing for particulate is conducted at a higher input level.

9.0

CD Minn. R. 7045.0790 to 7045.0990 Combust used oil in accordance with used oil regulations, Minn. R. ch. 7045, andlimit to 5% of total mass or heat input on an hourly basis.

10.0

CD Minn. R. 7007.0800 subp. 2 When burning coal, the Permittee shall sample coal daily, and analyze daily usingcurrent ASTM methods for determining sulfur content in percent by weight and fordetermining heating value in Btu/lb.

Each operating day the Permittee shall calculate and record pounds of SO2 emittedper hour and per MMBtu and compare to the limit. Keep all records of analysesand results of calculations on site. The SO2 emission rates shall be calculatedusing the formulas specified in Appendix F of this permit.

11.0

CD hdr PERFORMANCE TEST REQUIREMENTS12.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 09/13/2001 todetermine compliance with particulate matter, PM10, opacity and sulfur dioxideemission limits in Minn. R. 7011.0510. The tests shall be conducted at an intervalnot to exceed 60 months between test dates.

The next test is due by September 13, 2011.

13.0

CD hdr EMISSIONS MONITORING14.0

CD Minn. R. 7007.0800, subp. 5 Maintain records of total amount of used oil, boiler cleaning agents or oilcontaminated clean up materials burned per day when those materials are burned,and the ratio burned to other fuel in order to demonstrate compliance with the usedoil input limits, and used oil cleanup materials input limits.

15.0

CD hdr CONTROL REQUIREMENTSSee Subject Item CE 001 for specific control equipment operating requirements

16.0

CD Minn. R. 7007.0800, subps. 2 and14

The Permittee shall operate and maintain the fabric filter (CE 001) at all times thatany emission unit controlled by the fabric filter (EU 001) is in operation. ThePermittee shall document periods of non-operation of the control equipment.

Include in the quarterly report required for deviations and CEMs the number ofBoiler No. 1 startups, and the number of hours of operation without the baghousethat occurred with each startup.

17.0




27 Apr, 2011 13:37Page 12 of 44




CE 013 Overfire Air









MR 019 EU002 COMS


NC/CA




Particulate Matter < 10 micron: less than or equal to 0.47 lbs/million Btu heat input2.0




4.0

LIMIT Minn. R. 7011.0510, subp. 1 Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 3-hourAverage

5.0

LIMIT 40 CFR Section 76.7(a)(1) and 40CFR Section 76.8(a)(2)


6.0

CD Title I Condition: To avoidclassification as a majoramendment under 40 CFRSection 52.21 and Minn. R.7007.3000


7.0


8.0

CD Minn. R. 7007.0800, subp. 2 Allowed Fuels: lignite, sub-bituminous coal, distillate oil, used oil, non-hazardousoil spill cleanup materials and non-hazardous boiler cleaning agents.

9.0

CD Minn. R. 7007.0800, subp. 2 Allowed boiler cleaning agents: EDTA type generated on-site, 5% of total mass orheat input, oxygen limited to 3% or greater, agents may only be burned while theboiler is operating at 75 percent of rated capacity or greater.

10.0

CD Minn. R. 7007.0800, subp. 2; Minn. R. 7045.0790 to 7045.0990


11.0

CD Minn. R. 7007.0800, subp. 2 Combust used oil in accordance with used oil regulations, Minn. R. ch. 7045, andlimit to 5% of total mass or heat input on an hourly basis.

12.0


13.0




27 Apr, 2011 13:37Page 13 of 44



14.0

CD hdr CONTROL REQUIREMENTS(see Subject Item CE002 for specific control equipment operating requirements)

15.0

CD Minn. R. 7007.0800, subp. 2 and14


16.0

LIMIT Minn. R. 7007.0800, subp. 2 and14


17.0



18.0

CD Minn. R. 7007.0800, subp. 2 and14

If installed, the Permittee shall operate and maintain the carbon injection mercurycontrol system (CE014) at any time that the process equipment is combusting coal.The Permittee shall document periods of non-operation of the control equipment.See Subject Item CE014 for specific operating requirements.

19.0


S/A Title I Condition: To avoidclassification as a majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000; Minn. R. 7017.2020



21.0




22.0



23.0

S/A Minn. R. 7017.2020 subp. 1 Performance Test: due before end of each calendar 60 months starting 08/31/2006to determine compliance with the PM10 emission limit. The test shall be conductedat an interval not to exceed 60 months between test dates.

24.0

S/A Minn. R. 7017.2020 subp. 1 Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the total particulate matter emission limit. The test shallbe conducted at an interval not to exceed 60 months between test dates.

25.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for COemissions from burning lignite. The plan shall specify a testing frequency based onthe test data (compared to the default emission factor of 0.100 lb/mmBtu) andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

26.0

CD Minn. R. 7017.2030, subp. 1-4;Minn. R. 7017.2018 and Minn. R.7017.2035, subp. 1-2



27.0




27 Apr, 2011 13:37Page 14 of 44

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for front halfPM emissions after installation of CE014. The plan shall specify a testing frequencybased on the test data and MPCA guidance. Future performance tests based onone-year (12 month), 36 month, and 60 month intervals, or as applicable, shall berequired upon written approval of the MPCA.

28.0

CD Minn. R. 7007.0800, Subp. 2. STET (Short Term Emergency and Testing) Operating hours limit: The boiler mayoperate up to 40 hours per year to demonstrate the Uniform Rating of GeneratingEquipment (URGE) capacity and to meet emergency energy supply needs.Maintain documentation of all STET operation to demonstrate compliance with thislimit. The boiler must meet emission limits during STET operation.

29.0

CD Minn. R. 7007.0800, Subp. 2. STET Operation Definition that applies to Boilers that Meet or do Not Meet theAlternative Operating Condition for Performance Testing:




30.0

CD hdr ACID RAIN PROGRAM REQUIREMENTS31.0

CD 40 CFR Section 72.9(c)(1)(i), 40CFR Section 72.9(g)(4)


32.0


Comply with the applicable Acid Rain emissions limitation for sulfur dioxide.33.0

CD 40 CFR Section 72.9(f)(l) Keep on site at the source each of the following documents for a period of 5 yearsfrom the date of permit issuance: The certificate of representation, all emissionsmonitoring information, copies of all reports, compliance certifications, and othersubmissions or records made under the Acid Rain Program, copies of alldocuments used to complete an acid rain permit application.

34.0

CD 40 CFR Section 72.21 Each submission under the Acid Rain Program shall be submitted, signed, andcertified by the designated representative for all sources on behalf of which thesubmission is made in accordance with 40 CFR Section 72.21.

35.0

S/A 40 CFR Section 72.30(c) Application for Permit Reissuance: due 180 days before expiration of ExistingPermit (Acid Rain Program)

36.0

S/A 40 CFR Section 76.9(b)(2) Application for Permit Reissuance: due before 01/01/1998 or as specified in 40CFR Section 76.9 for nitrogen oxides including compliance plan (Acid Rain permit).

37.0


CD 40 CFR Section 75.10 Emissions Monitoring: The owner or operator shall use a CEMS to measure SO2,NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40CFR Section 75.10. See Subject Item GP003 for specific monitor requirements.

39.0

CD Minn. R. 7007.0800, subp. 2 Use SO2 CEM to measure sulfur dioxide in lb/mmBtu and lb/hr, calculate anaverage 1-hour emission rate at least once per hour.

40.0

CD Minn. R. 7007.0800, subp. 5 Recordkeeping: Maintain records of all CEMS monitoring data and supportinformation for a period of five years from the date of the monitoring sample,measurement, or report. Records shall be kept at the source.

41.0




42.0




27 Apr, 2011 13:37Page 15 of 44

CD Minn. R. 7017.1006 Emissions Monitoring: The owner or operator shall use a COMS to measureopacity emissions. The COMS shall consist of an opacity monitor on EU002 ductsand a combiner equation which will provide opacity emissions data from SV002.(See Subject Item GP004 for COMS operating requirements.)

43.0

CD hdr CALCULATIONS FOR COMPLIANCE WITH AOS 2 (under Subject Item GP001)44.0






where:


45.0

CD continued from above After completion of the LNB/OFA modification, and prior to availability of stack testresults, the CO emission factor (EFS and EFL) is assumed to be 0.231 lb/mmBtu.


46.0

CD hdr CALCULATIONS FOR COMPLIANCE WITH FRONT HALF PARTICULATEMATTER LIMIT (under Subject Item GP002)

47.0

S/A Minn. R. 7007.0800, subp. 6 Notification of the Actual Date of Initial Startup: due 15 days after Initial StartupEU002 following completion of Mercury Reduction projects.

48.0







49.0

CD continued from above Prior to availability of conclusive performance test results following the mercuryreduction modification, the front half PM emission factor (EFS and EFL) is 0.052lb/mmBtu.


50.0




27 Apr, 2011 13:37Page 16 of 44




CE 011 Overfire Air









MR 020 EU003 COMS


NC/CA


CD +hdr EMISSION AND OPERATING LIMITS1.0


Particulate Matter < 10 micron: less than or equal to 0.47 lbs/million Btu heat input2.0




4.0

LIMIT Minn. R. 7011.0510, subp. 1 Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 3-hourAverage

5.0

LIMIT 40 CFR Section 76.7(a)(1) and 40CFR Section 76.8(a)(2)


6.0



7.0


8.0

CD Minn. R. 7007.0800, subp. 2 Allowed Fuels: lignite, sub-bituminous coal, distillate oil, used oil, non-hazardousoil spill cleanup materials and non-hazardous boiler cleaning agents.

9.0

CD Minn. R. 7007.0800, subp. 2 Allowed boiler cleaning agents: EDTA type generated on-site, 5% of total mass orheat input, oxygen limited to 3% or greater, agents may only be burned while theboiler is operating at 75 percent of rated capacity or greater.

10.0

CD Minn. R. 7007.0800, subp. 2;Minn. R. 7045.0790 to 7045.0990


11.0

CD Minn. R. 7007.0800, subp. 2 Combust used oil in accordance with used oil regulations, Minn. R. ch. 7045, andlimit to 5% of total mass or heat input on an hourly basis.

12.0


13.0




27 Apr, 2011 13:37Page 17 of 44



14.0

CD hdr CONTROL REQUIREMENTS(see Subject Item CE 003 for specific control equipment operating requirements)

15.0

CD Minn. R. 7007.0800, subp. 2 and14


16.0



17.0



18.0

CD Minn. R. 7007.0800, subp. 2 and14

If installed, the Permittee shall operate and maintain the carbon injection mercurycontrol system (CE015) at any time that the process equipment is combusting coal.The Permittee shall document periods of non-operation of the control equipment.

See Subject Item CE015 for specific operating requirements.

19.0





21.0




22.0



23.0

S/A Minn. R. 7017.2020 subp. 1 Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the total particulate matter emission limit. The test shallbe conducted at an interval not to exceed 60 months between test dates.

24.0

S/A Minn. R. 7017.2020 subp. 1 Performance Test: due before end of each 60 months starting 08/31/2006 todetermine compliance with the PM10 emissions limit. The test shall be conductedat an interval not to exceed 60 months between test dates.

25.0

CD Minn. R. 7017.2030, subp. 1-4;Minn. R. 7017.2018 and Minn. R.7017.2035, subp. 1-2



26.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for COemissions from burning lignite. The plan shall specify a testing frequency based onthe test data (compared to the default emission factor of 0.100 lb/mmBtu) andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

27.0




27 Apr, 2011 13:37Page 18 of 44

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for front halfPM emissions after installation of CE015. The plan shall specify a testing frequencybased on the test data and MPCA guidance. Future performance tests based onone-year (12 month), 36 month, and 60 month intervals, or as applicable, shall berequired upon written approval of the MPCA.

28.0

CD Minn. R. 7007.0800, Subp. 2. STET (Short Term Emergency and Testing) Operating hours limit: The boiler mayoperate up to 40 hours per year to demonstrate the Uniform Rating of GeneratingEquipment (URGE) capacity and to meet emergency energy supply needs.Maintain documentation of all STET operation to demonstrate compliance with thislimit. The boiler must meet emission limits during STET operation.

29.0

CD Minn. R. 7007.0800, Subp. 2. STET Operation Definition that applies to Boilers that Meet or do Not Meet theAlternative Operating Condition for Performance Testing:




30.0

CD hdr ACID RAIN PROGRAM REQUIREMENTS31.0



32.0


Comply with the applicable Acid Rain emissions limitation for sulfur dioxide.33.0

CD 40 CFR Section 72.9(f)(l) Keep on site at the source each of the following documents for a period of 5 yearsfrom the date of permit issuance: The certificate of representation, all emissionsmonitoring information, copies of all reports, compliance certifications, and othersubmissions or records made under the Acid Rain Program, copies of alldocuments used to complete an acid rain permit application.

34.0

CD 40 CFR Section 72.21 Each submission under the Acid Rain Program shall be submitted, signed, andcertified by the designated representative for all sources on behalf of which thesubmission is made in accordance with 40 CFR Section 72.21.

35.0

S/A 40 CFR Section 72.30(c) Application for Permit Reissuance: due 180 days before expiration of ExistingPermit (Acid Rain Program)

36.0

S/A 40 CFR Section 76.9(b)(2) Application for Permit Reissuance: due before 01/01/1998 or as specified in 40CFR Section 76.9 for nitrogen oxides including compliance plan (Acid Rain permit).

37.0


CD 40 CFR Section 75.10 Emissions Monitoring: The owner or operator shall use a CEMS to measure SO2,NOx, and CO2 emissions and flow rate for each affected unit in accordance with 40CFR Section 75.10. See Subject Item GP003 for specific monitor requirements.

39.0

CD Minn. R. 7007.0800, subp. 2 Use SO2 CEM to measure sulfur dioxide in lb/mmBtu and lb/hr, calculate anaverage 1-hour emission rate at least once per hour.

40.0

CD Minn. R. 7007.0800, subp. 5 Recordkeeping: Maintain records of all CEMS monitoring data and supportinformation for a period of five years from the date of the monitoring sample,measurement, or report. Records shall be kept at the source.

41.0




42.0




27 Apr, 2011 13:37Page 19 of 44

CD Minn. R. 7017.1006 Emissions Monitoring: The owner or operator shall use a COMS to measureopacity emissions. The COMS shall consist of an opacity monitor on EU003 ductsand a combiner equation which will provide opacity emissions data from SV002.(See Subject Item GP004 for COMS operating requirements.)

43.0

CD hdr CALCULATIONS FOR COMPLIANCE WITH AOS 2 (under Subject Item GP001)44.0






where:


45.0

CD continued from above After completion of the LNB/OFA modification, and prior to availability of stack testresults, the CO emission factor (EFS and EFL) is assumed to be 0.100 lb/mmBtu.


46.0

CD hdr CALCULATIONS FOR COMPLIANCE WITH FRONT HALF PARTICULATEMATTER LIMIT (under Subject Item GP002)

47.0

S/A Minn. R. 7007.0800, subp. 6 Notification of the Actual Date of Initial Startup: due 15 days after Initial StartupEU003 following completion of Mercury Reduction projects.

48.0







49.0

CD continued from above Prior to availability of conclusive performance test results following the mercuryreduction modification, the front half PM emission factor (EFS and EFL) is 0.059lb/mmBtu.


50.0




27 Apr, 2011 13:37Page 20 of 44

Subject Item: EU 004 Fly Ash Silo


SV 006 Fly Ash Tank Vent

NC/CA



LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

2.0

LIMIT Minn. Stat. Section 116.07, subds.4a & 9; Minn. R. 7007.0100,subps 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn.R. 7009.0010-7009.0080


3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity4.0

CD hdr CONTROL REQUIREMENTS (see Subject Item CE004 for specific controlequipment operating requirements)

5.0

CD Minn. R. 7007.0800, subps. 2 and14


6.0



7.0



8.0




27 Apr, 2011 13:37Page 21 of 44

Subject Item: EU 005 Bottom Ash Silo


SV 007 Bottom Ash Tank Vent

NC/CA



LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

2.0

LIMIT Minn. Stat. Section 116.07, subds.4a & 9; Minn. R. 7007.0100,subps 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn.R. 7009.0010-7009.0080


3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

4.0


Operating Hours: less than or equal to 4.0 hours/day5.0

CD hdr CONTROL REQUIREMENTS (see Subject Item CE005 for specific controlequipment operating requirements)

6.0

CD Minn. R. 7007.0800, subp. 2 and14


7.0



8.0



9.0




27 Apr, 2011 13:37Page 22 of 44



NC/CA


CD hdr EMISSION LIMITS1.0

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have beenattained.

2.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input .


3.0

CD hdr OPERATING CONDITIONS4.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only.5.0

CD hdr RECORDKEEPING REQUIREMENTS6.0

CD Minn. R. 7007.0800, subps. 4 & 5 Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.50% by weight.

7.0




27 Apr, 2011 13:37Page 23 of 44



NC/CA



LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have beenattained.

2.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input .


3.0

CD hdr OPERATING CONDITIONS4.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only.5.0

CD hdr RECORDKEEPING REQUIREMENTS6.0


7.0




27 Apr, 2011 13:37Page 24 of 44

Subject Item: EU 012 Temporary Boiler (preauthorized)

Associated Items: SV 010 Temporary Boiler

NC/CA



LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.10 lbs/million Btu heat input . Thepotential to emit from the unit is 0.014 lb/MMBtu due to equipment design andallowable fuels.

2.0

LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

3.0

CD hdr OTHER LIMITS4.0

CD Title I Condition: To avoidclassification as majormodification under 40 CFRSection 52.21 and Minn. R.7007.3000

Limit to avoid exceeding Significance Threshold for New Source Reviewmodifications. When assessing any facility modification under 40 CFR Section52.21, emissions from EU012 (pre-authorized temporary boiler) must be counted inthe applicability analysis if they occur during the contemporaneous period.

Additional monitoring, recordkeeping, and reporting associated with this condition isas described in 40 CFR Section 52.21(r)(6), and in this permit under Subject ItemTotal Facility, under the heading "Determining if a Project/Modification is Subject toNew Source Review".

5.0

CD Minn. R. 7007.0800, subp. 2 A temporary boiler may not be operated at the same time as EU002 or EU003,except for up to 8 hours during start-up and shutdown transition periods.

6.0

LIMIT Minn. R. 7007.0800, subp. 2; Toavoid classification as an affectedfacility under 40 CFR Part 60,Subp. Dc

Heat Input: less than or equal to 9.9 lbs/million Btu heat input for the purpose ofproviding steam, heat or electrical power in place of boilers or generators that aretemporarily out of operation.

7.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only8.0

LIMIT Minn. R. 7007.0800, subp. 2 Sulfur Content of Fuel: less than or equal to 0.05 percent by weight9.0

CD hdr CALCULATIONS AND RECORDKEEPING10.0

CD Minn. R. 7007.0800, subp. 2 Recordkeeping. For each temporary boiler brought on site, keep documentation ofthe manufacturer, model number, and heat input capacity. Records shall bemaintained on site for 5 years.

11.0

CD Minn. R. 7007.0800, subp. 2 Calculations: For each temporary boiler calculate the potential emissions of eachcriteria pollutant in lb/hr and lb/MMBtu (using manufacturer's provided data orAP-42 emission factors). Maintain a unique record for each temporary boiler of thepotential emission calculations. Records shall be maintained on site for 5 years.

12.0


13.0




27 Apr, 2011 13:37Page 25 of 44



NC/CA


CD 40 CFR Section 64.7(b); Minn. R.7007.0800, subp. 14

Operation and Maintenance of ESP: The Permittee shall operate and maintain theESP in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andreview by MPCA staff.

1.0

LIMIT 40 CFR Section 64.3; Minn. R.7017.0200


2.0

CD 40 CFR Section 64.3(b)(4)(ii);Minn. R. 7017. 0200



3.0



4.0

CD 40 CFR Section 64.3(b)(4)(ii);Minn. R. 7017.0200


5.0

CD 40 CFR Section 64.7(b); Minn. R.7017.0200


6.0

CD 40 CFR Section 64.3; Minn. R.7017.0200


7.0



8.0

CD 40 CFR Section 64.7(d); Minn. R.7017.0200

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the monitored opacity, averaged over any 3-hour period, exceeds 20%;-the monitored total power input, averaged over any 3-hour period, is less than 40kilowatts; or- the ESP or any of its components are found during the inspections to need repair.Corrective actions shall return operation to within the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the ESP. The Permittee shall keep a record of the type and date ofany corrective action taken for the ESP.

9.0

CD 40 CFR Section 64.7(e); Minn. R.7017.0200


10.0




27 Apr, 2011 13:37Page 26 of 44

CD 40 CFR Section 64.9(a)(2); Minn.R. 7017.0200


11.0



12.0




27 Apr, 2011 13:37Page 27 of 44



NC/CA



Operation and Maintenance of ESP: The Permittee shall operate and maintain theESP in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andreview by MPCA staff.

1.0



2.0

CD 40 CFR Section 64.4(b)(4)(ii);Minn. R. 7017. 0200



3.0



4.0

CD 40 CFR Section 64.3(b)(4)(ii);Minn. R. 7017.0200


5.0



6.0



7.0



8.0


Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the monitored opacity, averaged over any 3-hour period, exceeds 20%; -themonitored total power input, averaged over any 3-hour period, is less than 25kilowatts; or- the ESP or any of its components are found during the inspections to need repair.Corrective actions shall return operation to within the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the ESP. The Permittee shall keep a record of the type and date ofany corrective action taken for the ESP.

9.0



10.0




27 Apr, 2011 13:37Page 28 of 44



11.0



12.0




27 Apr, 2011 13:37Page 29 of 44


Associated Items: EU 004 Fly Ash Silo

FS 004 Fly Ash Silo Loading

NC/CA



The Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

1.0

LIMIT Minn. R. 7007.0800, subp. 2 and14; Minn. R. 7017.2025, subp. 3


2.0

CD Minn. R. 7007.0800, subps. 2 and14; 40 CFR Section 64.3; Minn. R.7017.0200


3.0


Visible Emissions: The Permittee shall inspect the fabric filter stack (SV006) for anyvisible emissions while in operation and during daylight hours at a minimum of onceeach week. If visible emissions exist, the Permittee shall inspect equipment forevidence of malfunction, including broken bags. The Permittee shall record theresults of the inspection, and any corrective action taken.

4.0

CD Minn. R. 7007.0800, subp. 2 The Permittee shall maintain an alarm system that notifies the control roomoperators if pressure loss to the puffer bag is detected.

5.0



6.0



7.0



8.0



9.0



10.0



11.0




27 Apr, 2011 13:37Page 30 of 44



12.0



13.0




27 Apr, 2011 13:37Page 31 of 44


Associated Items: EU 005 Bottom Ash Silo

FS 005 Bottom Ash Silo Loading

NC/CA



The Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

1.0

LIMIT Minn. R. 7007.0800, subp. 2 and14; Minn. R. 7017.2025, subp. 3


2.0



3.0


Visible Emissions: The Permittee shall inspect the fabric filter stack (SV007) for anyvisible emissions while in operation and during daylight hours at a minimum of onceeach week. If visible emissions exist, the Permittee shall inspect equipment forevidence of malfunction, including broken bags. The Permittee shall record theresults of the inspection and any corrective action taken.

4.0



5.0



6.0



7.0



8.0



9.0



10.0




27 Apr, 2011 13:37Page 32 of 44



11.0



12.0




27 Apr, 2011 13:37Page 33 of 44



NC/CA


CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Feed Rate: Maintain mercury sorbent volumetric feed rate (e.g., inpounds per volume of flue gas or pounds per volume coal flow) at or above thevalue measured during the most recent mercury performance test once system hasbeen installed and is operational.

1.0

CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Injection: Initiate corrective action to restore the mercury sorbentinjection rate as soon as possible upon discovery of a drop in the mercury sorbentinjection rate to a level below the value measured during the most recent mercuryperformance test.

2.0

CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Injection Monitoring: Once the Mercury Control system has beeninstalled; the Permittee shall install, maintain, and operate at all times that EU002 isoperating, a system for monitoring and recording the mercury sorbent feed rate.The Permittee shall record the time periods, reasons, and corrective actions takenfor all EU002 operating periods when mercury sorbent feed rates are below therequired minimum.

3.0




27 Apr, 2011 13:37Page 34 of 44



NC/CA


CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Feed Rate: Maintain mercury sorbent volumetric feed rate (e.g., inpounds per volume of flue gas or pounds per volume coal flow) at or above thevalue measured during the most recent mercury performance test once system hasbeen installed and is operational.

1.0

CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Injection: Initiate corrective action to restore the mercury sorbentinjection rate as soon as possible upon discovery of a drop in the mercury sorbentinjection rate to a level below the value measured during the most recent mercuryperformance test.

2.0

CD Minn. R. 7007.0800, subp. 2 Mercury Sorbent Injection Monitoring: Once the Mercury Control system has beeninstalled; the Permittee shall install, maintain, and operate at all times that EU003 isoperating, a system for monitoring and recording the mercury sorbent feed rate.The Permittee shall record the time periods, reasons, and corrective actions takenfor all EU003 operating periods when mercury sorbent feed rates are below therequired minimum.

3.0




27 Apr, 2011 13:37Page 35 of 44

Subject Item: MR 009 EU 002 SO2 CEMS

Associated Items: CM 006 EU 002: 3.0 lb/SO2/mmBtu, 1 hr ave. If EU 001 operating, then 2.59 lb SO2/mmBtu


GP 003 NOX/SO2/CO2/flow monitors

NC/CA


S/A Minn. R. 7017.1180, subp. 4 Linearity Test Results Summary: due 30 days after end of each calendar quarterstarting 04/08/2009 following Linearity and Leak Check Test if performed.

1.0

S/A Minn. R. 7017.1180, subp. 3 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end ofeach calendar quarter starting 04/08/2009 in which the CEMS RATA wasconducted.

2.0




27 Apr, 2011 13:37Page 36 of 44

Subject Item: MR 010 EU 002 NOx CEMS

Associated Items: CM 008 EU 002: 0.45 lb NOx/mmBtu annual average (0.40 lb NOx/mmBtu as of 2008)



NC/CA



1.0


2.0




27 Apr, 2011 13:37Page 37 of 44

Subject Item: MR 011 EU 002 CO2 CEMS


CM 008 EU 002: 0.45 lb NOx/mmBtu annual average (0.40 lb NOx/mmBtu as of 2008)



NC/CA



1.0


2.0




27 Apr, 2011 13:37Page 38 of 44

Subject Item: MR 012 EU 002 Flow CEMS



NC/CA



1.0




27 Apr, 2011 13:37Page 39 of 44

Subject Item: MR 013 EU 003 SO2 CEMS




NC/CA



1.0


2.0




27 Apr, 2011 13:37Page 40 of 44

Subject Item: MR 014 EU 003 NOx CEMS

Associated Items: CM 009 EU 003: 0.46 lb NOx/mmBtu annual average



NC/CA



1.0


2.0




27 Apr, 2011 13:37Page 41 of 44

Subject Item: MR 015 EU 003 CO2 CEMS


CM 009 EU 003: 0.46 lb NOx/mmBtu annual average



NC/CA



1.0


2.0




27 Apr, 2011 13:37Page 42 of 44

Subject Item: MR 016 EU 003 Flow CEMS



NC/CA



1.0




27 Apr, 2011 13:37Page 43 of 44

Subject Item: MR 019 EU002 COMS


GP 004 COMS

NC/CA


S/A Minn. R. 7017.1220 COMS Audit Results Summary: due 30 days after end of each calendar quarterstarting 04/08/2009 in which the COMS calibration error audit was completed.

1.0




27 Apr, 2011 13:37Page 44 of 44

Subject Item: MR 020 EU003 COMS


GP 004 COMS

NC/CA


S/A Minn. R. 7017.1220 COMS Audit Results Summary: due 30 days after end of each calendar quarterstarting 04/08/2009 in which the COMS calibration error audit was completed.

1.0


Attachment 3: Points Calculator

Sheet1

1) AQ Facility ID No.: 11100002 Total Points2) Facility Name: Otter Tail Power Company - Hoot Lake Facility 353) Small business? y/n? n 4) DQ Numbers (including all rolled) : 3323; 2463 5) Date of each Application Received: 1/13/2011; reopening based on NOC 2/5/20096) Final Permit No. 11100002-0057) Permit Staff Bonnie J Nelson8) "Work completed" in which xls file (i e unit 2b unit 1a biofuels)? N

Page 1

8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)? No

TotalApplication Type DQ No. Qty. DQ No. Qty. Points Points DetailsAdministrative Amendment 1 0Minor Amendment 4 0Applicability Request 10 0Moderate Amendment 15 0

Initial Secondary

Moderate Amendment 15 0Major Amendment 3323 1 25 25Individual State Permit (not reissuance) 50 0Individual Part 70 Permit (not reissuance) 75 0

Additional PointsModeling Review 15 0

BACT Review 15 0BACT Review 15 0LAER Review 15 0CAIR/Part 75 CEM analysis 10 0NSPS Review 10 0NESHAP Review 10 0Case-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 3323 1 10 10Plantwide Applicability Limit (PAL) 20 0AERA review 15 0Variance request under 7000.7000 35 0Confidentiality request under 7000.1300 2 0EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16 items A & D; 17 items A to C & E to G;

35 0A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0

NOTES: Limits to avoid triggering an NSPS

Page 1


Attachment 4: Performance Testing Submittals and NOCs (Reopening)


February 5, 2009 Mr. Mark Thoma Otter Tail Power Company 215 South Cascade Street Fergus Falls, MN 56537 RE: (1) Notice of Verification for the December 2 and 4, 2008, Engineering Performance Tests on Unit

No.2 Boiler (EU002) and Unit No.3 Boiler (EU003) Pursuant to Air Emission Permit No. 11100002-003 and Test Plan Approval Letter Dated November 20, 2008

Dear Mr. Thoma: The Minnesota Pollution Control Agency (MPCA) staff has reviewed the final test reports for the engineering tests conducted on the emission units referenced above at the Otter Tail Power - Hoot Lake Plant (Company) facility located in Fergus Falls, Minnesota. The test reports were postmarked January 13, 2009. The compact disc copies were postmarked January 29, 2009. The MPCA staff has determined that the test results demonstrate the following under test conditions:

SUMMARY OF PERFORMANCE TEST RESULTS

Emission Unit Tested Limitation Basis Pollutant and Emission

Limit Test Result Compliance Status

Unit No. 2 Boiler

(EU002) Title I Condition: to

avoid classification as a major source or

modification under 40 CFR § 52.21 and Minn. R. 7007.3000;

Carbon Monoxide (CO): Testing to help establish

a correlation between boiler excess oxygen

and stack carbon monoxide emissions

CO (A): Run 1 -0.004 lbs/

mmBtu

Verified CO(A):

Run 2 -0.023 lbs/ mmBtu CO(A):

Run 3 -0.128 lbs/ mmBtu

Unit No. 3 Boiler

(EU003)

CO(A): Run 1 - 0.068 lbs/

mmBtu

Verified CO(A):

Run 2 - 0.088 lbs/ mmBtu CO(A):

Run 3 - 0.114 lbs/ mmBtu

Table References: (A) Carbon Monoxide as determined by U.S. Environmental Protection Agency (EPA) Method 10.


The tests were conducted while combusting sub bituminous coal in each unit. Unit No.2 produced an average of 54.57 megawatts per hour and 404,266 pounds per hour of steam. Unit No. 3 produced an average of 77.25 megawatts per hour and 677,700 pounds per hour of steam. These parameters are within the ranges defined in the approved test plan. In addition, please be advised of the following: 1. If an operating/production limit is exceeded, it must be reported in accordance with the deviation

reporting requirements of Minn. R. 7007.0800, subp. 6(A). 2. The operating conditions met the worst-case operating condition as defined in the approved test plan.

Therefore, no new operating limit is applicable pursuant to Minn. R. 7017.2025, subp. 3. However, please be aware that should operating practices change such that the current definition of worst-case becomes outdated, the MPCA may require a performance test at the new worst-case condition.

3. The Emission Inventory rule, Minn. R. 7019.3000 to 7019.3100, requires the calculation of emissions

based on an established hierarchy. In the absence of Continuous Emission Monitor data meeting the requirements of Minn. R. 7019.3040, the next method of calculation, a performance test, must be used. When a performance test for particulate matter, particulate matter with an aerodynamic diameter less than or equal to a nominal ten micrometers, carbon monoxide, nitrogen oxides, sulfur oxides, volatile organic compounds or lead is conducted and meets the requirements of Minn. R. 7017.2001 to 7017.2060, the results must be used to calculate emissions, unless specified otherwise by Minn. R. 7019.3000 to 7019.3100. It is the Company’s responsibility to ensure the results of performance tests are accounted for in their annual emission inventory submittal. Note that the final decision to approve the emission factor for any given inventory year will be made by the Emission Inventory Coordinator.

If you have questions or comments regarding the content of this letter, please contact me at 651-757-2620. Your continued cooperation is appreciated. Sincerely, Sean W. O'Connor Pollution Control Specialist Compliance and Enforcement Section Industrial Division SWO:ch cc: AQ Correspondence File No. 116C


CERTIFIED MAIL NO. 7007 3020 0000 0962 6666 RETURN RECEIPT REQUESTED Mr. Mark Thoma Senior Compliance Specialist Environmental Services Ottertail Power Company Hoot Lake Plant 1012 Water Plant Road Fergus Falls, MN 56537 RE: (1) Notice of Compliance for the August 16, 2006, Performance Test on Unit No. 2 Boiler

(EU002) Pursuant to Air Emission Permit No. 11100002-002 (Permit) and Test Plan Approval Dated July 31, 2006;

(2) Notice of Compliance for the August 24, 2006, Performance Test on Unit No. 3 Boiler (EU003) Pursuant to Air Emission Permit No. 11100002-002 and Test Plan Approval Dated July 31, 2006;

(3) Notice of Noncompliance/Notice of Compliance for the December 19, 2006, Performance Test on Unit No. 1 Boiler (EU001) Pursuant to Air Emission Permit No. 11100002-002 and Test Plan Approval December 7, 2007;

(4) Notice of Compliance for the December 20, 2006, Performance Test on Unit No. 3 Boiler Pursuant to Air Emission Permit No. 11100002-002 and Test Plan Approval December 7, 2007;

(5) Acceptance Determination of the August 10 through 15, 2006, Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Dioxide (CO2), and Flow Continuous Emission Monitoring System (CEMS) Certification Test Serving EU002 Outlet Duct; and,

(6) Acceptance Determination of the August 22 and 23, 2006, SO2, NOx, CO2, and Flow CEMS Certification Test Serving EU003 Outlet Duct

Dear Mr. Thoma: The Minnesota Pollution Control Agency (MPCA) staff has reviewed the final test reports for the tests conducted on the emission units referenced above at the Ottertail Power (Company) Hoot Lake Plant facility located in Fergus Falls, Minnesota. The test reports and compact disc (CD) copies were postmarked as outlined in the table below.

Test Date Type of Report

Interpoll Report No.

Hardcopy Postmark CD Copy Postmark

August 10-15, 2006 Certification 6-23339R September 29, 2006 November 14, 2006 August 16 2006 Performance 6-23339 September 26, 2006 November 14, 2006

August 22-23, 2006 Certification 6-23406R October 5, 2006 November 14, 2006 August 24, 2006 Performance 6-23406 October 4, 2006 November 14, 2006

December 19, 2006 Performance 6-24135 January 30, 2007 February 27, 2007 December 20, 2006 Performance 6-24135CAM January 30, 2007 February 27, 2007


This letter documents emission violations. For the purpose of enforcing the emission limit, the period of noncompliance begins at the date of the initial noncompliant performance test. Therefore, the Company should take immediate measures to minimize emissions. The measures taken are important and should be documented as they will become part of the record of corrective actions.

The MPCA staff has determined that the test results demonstrate the following under test conditions:

SUMMARY OF PERFORMANCE TEST RESULTS

Emission Unit Tested

Limitation Basis

Pollutant and Emission Limit

Test Result

Compliance Status

EU002 (Tested 8/06)

Minn. R. 7011.0510, subp. 1

Particulate (B): 0.6 pounds/ million BTU

(lbs/MMBTU)

Particulate (B): 0.036 lbs/MMBTU

Compliant

EU003 (Tested 8/06)


Compliant

EU001 (Tested 12/06)


Compliant

Minn. R. 7011.0510, subp. 2

Opacity: 20%

Opacity: 17.9%

Compliant

NA NA NOx: 0.39 lbs/MMBTU

Verified

Minn. R. 7009.0020; Minn. R. 7007.0800,

subp. 2

SO2: 0.72 lbs/MMBTU

SO2: 0.78 lbs/MMBTU

Noncompliant

EU003 (Tested 12/06

for CAM Determination)

Minn. R. 7011.0510, subp. 1



Compliant

Table References: (A) Filterable particulate matter as determined by U.S. Environmental Protection Agency (EPA) Method 5. (B) Filterable plus organic condensible particulate matter as determined by EPA Method 5 and

Method 202.

(C) Particles with an aerodynamic diameter less than or equal to a nominal ten micrometers (PM10) as determined by EPA Methods 201(A) and 202 or Methods 5 and 202.

The tests were conducted while operating at the following rates.

Unit Tested

Heat Input (MMBtu/Hour)

Steam Production (103 lbs/hour)

Control Equipment

Rate

Units

EU002 563.7 454.146 ESP – CE002 94.7 kilowatts EU003 883.5 709.780 ESP – CE003 56.1 kilowatts EU001 26.8 16.400 Baghouse – CE001 1.5 inches water

column EU003

for CAM 831.2 679.900 ESP-CE002 81.6* kilowatts


*Electrostatic Precipitator (ESP) rates varied significantly for each run of the test. 81.6 kilowatts is the average of all runs. During the December 20, 2007, performance test on EU002 the continuous opacity monitoring system (COMS) recorded opacity was 20.1 percent. These parameters are within the ranges defined in the approved test plans. The MPCA staff have determined that the Company has demonstrated that the following continuous emissions monitoring system (CEMS) are in compliance with the requirements of the appropriate Performance Specifications in accordance with 40 Part 75.

Accordingly, the data generated by this system will become a continuous record that may be used for determining compliance with applicable emission limits. In addition, please be advised of the following:

1. The Company shall comply with the appropriate option:

OPTION A: i. Conduct a retest for EU001 SO2 on or before thirty (30) days after receipt of this letter. ii. Provide advance written notice of testing, submit a test plan and schedule a pretest meeting at

least twenty-one (21) days prior to the retest date. The pretest meeting shall be held at least seven (7) working days prior to the date of the retest.

iii. Submit the final performance test results within forty-five (45) days of conducting the retest.

iv. Include, with the final test results, a description of corrective action taken by the Company to

achieve compliance. If the MPCA staff determines that compliance has been demonstrated, the Company shall incorporate this corrective action into its standard operating procedures. This description should include information describing the duration of the alleged violation, cause(s) of the alleged violation, corrective actions taken or planned to correct the alleged violation, and any other information relevant to the test failure.

Emission Unit Monitored

Manufacturer

Model Number

Pollutant

Serial Number

EU002 TECO 42i NOx 0615116988 TECO 42i SO2 0615116991 CAI 601 CO2 T04028

Optical Scientific OFS-2000 Flow 05080198 EU003 TECO 42i NOx 0615116989

TECO 42i SO2 0615116990 CAI 601 CO2 T04027

Optical Scientific OFS-2000 Flow 05080199


v. Submit a microfiche or compact disc version of the final test report within one hundred and five (105) days of conducting the retest. The complete AQ file number, complete facility name and the exact date of testing must be provided on the label of the microfiche or compact disc.

OPTION B: (Option B can ONLY be used if one of the following special circumstances apply: seasonal or temporary shutdown of the affected emissions units; malfunction or breakdown of the affected emission units; weather conditions that prevent using the applicable test methods or prevent operation of the affected emissions units at the required operating conditions; any other conditions beyond the control of the owner or operator that prevent using the applicable test methods or prevent operation of the affected emissions units at the required operating conditions; or any other condition beyond the control of the owner or operator that prevents completion of a retest within the schedule required in Option A; or if the owner or operator has accepted that a retest would not demonstrate compliance. Generally, extensions of up to 30 days beyond the completion of the event qualifying as a special circumstance may be granted.) i. Submit a proposed written compliance plan which specifies the reasons why the extension is

needed and a proposed alternative retest schedule which includes all tests as described in Option A. The proposed compliance plan also must include a detailed summary of the measures the Company will take to bring the affected units into compliance. The proposed compliance plan is subject to the commissioner’s written approval. A requested extension shall not be effective unless the commissioner has given written approval of the extension. Once approved, the compliance plan is enforceable and the owner or operator must implement the alternative retest schedule and compliance measures. The compliance plan may also include a detailed summary of additional measures the owner or operator will implement if the retest demonstrates noncompliance. The proposed compliance plan shall be submitted in writing on or before thirty (30) days after receipt of this letter.

2. The operating conditions met the worst-case operating condition as defined in the approved test plan.

Therefore, no new operating limit is applicable pursuant to Minn. R. 7017.2025, subp. 3. However, please be aware that should operating practices change such that the current definition of worst-case becomes outdated, the MPCA may require a performance test at the new worst-case condition.

4. The Emission Inventory rule, Minn. R. 7019.3000 to 7019.3100, requires the calculation of emissions based on an established hierarchy. In the absence of Continuous Emission Monitor data meeting the requirements of Minn. R. 7019.3040, the next method of calculation, a performance test, must be used. When a performance test for particulate matter, particulate matter with an aerodynamic diameter less than or equal to a nominal ten micrometers, NOX, or SO2 is conducted and meets the requirements of Minn. R. 7017.2001 to 7017.2060, the results must be used to calculate emissions, unless specified otherwise by Minn. R. 7019.3000 to 7019.3100. It is the Company’s responsibility to ensure the results of performance tests are accounted for in their annual emission inventory submittal. Note that the final decision to approve the emission factor for any given inventory year will be made by the Emission Inventory Coordinator.

4. Enforcement staff has been informed of the noncompliance status for SO2. Enforcement staff will

delay enforcement action for the above listed noncompliance until after the results of the retest or


Option B compliance plan have been submitted and reviewed. After review of the results of the original test along with the results of the retest or compliance plan, enforcement staff will determine the appropriate enforcement action, which may include a monetary penalty assessment. Note: since performance test failures indicate emissions above limits (excess actual emissions to the environment); failures commonly result in assessment of a monetary penalty.

Please note that failure to demonstrate compliance during a retest will result in issuance of a written notice of a second performance test failure. If such a notice is received, the Company is required by Minn. R. 7017.2025, subp. 5., to shut down the noncompliant emission units and not operate the emissions units unless the Company meets the requirements of Minn. R. 7017.2025, subp. 5. Enforcement staff has currently identified the following violation. Please review for accuracy the following description of the current alleged violation. Violation 1:

Air Emissions Permit No. 11100002-002: EU001 – Sulfur Dioxide ≤ 0.72 lbs/MMBTU

SUMMARY OF PERFORMANCE TEST RESULTS Emission Unit

Tested

Limitation Basis Pollutant and

Emission Limit

Test Result Compliance

Status EU001 Minn. R. 7009.0020; Minn.

R. 7007.0800, subp. 2 SO2:

0.72 lbs/MMBTU SO2:

0.78 lbs/MMBTU Compliant

On December 19, 2006, the Company conducted a performance test for SO2 on EU001 at the Company’s Fergus Falls, Minnesota facility. The results of this test showed that this Emission Point was emitting SO2 at a rate of 0.78 lbs/MMB. This emission rate is in excess of the permitted limit of 0.72 lbs/MMBTU, by 8 percent. The above alleged violation has been recorded and documented by the MPCA. If you believe that any of the information presented above is incorrect, please respond in writing including your response in with your final retest performance results. Your response should contain a detailed explanation in support of your version of the events in question. If you believe that those events do not constitute a violation, you can also discuss that in your response. You are also required to submit information regarding the duration of the alleged violation, cause(s) of the alleged violation, corrective actions taken or planned to correct the alleged violation, and any other information relevant to the test failure as required under Option A.iv. above. This letter and your response do not preclude the MPCA from taking further action with respect to the above alleged violations. The MPCA reserves the right to pursue any and all remedies available under Minn. Stat. §§ 115.071, 116.072, 116.073, and 609.671, and all applicable rules or permits for any violation cited in this letter. It is important that you give this matter your full attention. The MPCA will consider your response in determining whether and what level of enforcement action is appropriate. Please note that such enforcement action may require payment of a monetary penalty.


Please submit responses to this letter directly to Andy Place, with a copy to Cary Hernandez, MPCA, 714 Lake Avenue, Detroit Lakes, Minnesota 56501. If you have questions or comments regarding the content of this letter, please contact Andy Place at 651-296-7169. Your continued cooperation is appreciated. Sincerely, Beth G. Lockwood Supervisor, Air Quality Compliance and Enforcement Unit St. Paul Office Industrial Division BGL/AP:map cc: Kathleen Winters, Attorney General's Office Cary Hernandez, MPCA, Detroit Lakes Regional Office Andy Place, MPCA, St Paul – 5th Bob Beresford, MPCA, Duluth Regional Office AQ Enforcement File No. 116C


Attachment 5: 1990 Modeling memo

air emission permit no. 11100002- 005 major amendment …a-2 04/28/11 the permittee must submit a...

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