air emission permit no. 09100058-004 is issued to great river energy … · 2012-10-04 · great...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 09100058- 004 (PART 70 REISSUANCE PERMIT)

IS ISSUED TO

GREAT RIVER ENERGY

Lakefield Junction Station

2159 20th Avenue Trimont, Martin County, MN 56176

The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 09100058-003 and authorizes the Permittee to operate 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 State Implementation Plan under 40 CFR § 52.1220 and as such as are enforceable by U. S Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Pt 70 Reissuance/Incorporates Existing NSR Conditions/Acid Rain Program

Operating Permit Issue Date: June 17, 2009

Expiration Date : June 17, 2014

All Title I Conditions do not expire.

* The Permittee can continue to operate this facility after the expiration date of this permit per provisions under Minn. R. 7007.0450 Don Smith, PE, Manager Air Quality Permits Section Industrial Division for Paul Eger, Commissioner Minnesota Pollution Control Agency

Permit Application Type Application Date (s) Permit Action Total Facility Operating Permit - Reissuance November 5, 2004 004

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices: Appendix A: Operator’s Summary Appendix B: Insignificant Emission Units Appendix C: Acid Rain Program Requirements

Appendix D: Modeled Parameters Relied Upon to Demonstrate Compliance with the PM10, SO2, CO and NOx National and Minnesota Air Quality Standards

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: Great River Energy- Lakefield Junction owns and operates a simple-cycle combustion turbine generating plant in Cedar Township, Martin County, Minnesota. The facility consists of six 92 megawatts (MW) combustion turbines, a black-start generator, diesel fire pump, two natural gas preheaters, a fuel tank for distillate oil storage, associated fuel oil forwarding system and insignificant activities. The facility is a major source under the federal operation permits program (40 CFR pt. 70) and major source under federal New Source Review (NSR). The permit limits hazardous air pollutants (HAPs) emissions such that the facility is an area source under the National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63). This facility is subject to the Acid Rain Program and Clean Air Interstate Rule.

TABLE A: LIMITS AND OTHER REQUIREMENTS 06/17/09

Great River Energy - Lakefield Junction

09100058 - 004

Facility Name:

Permit Number:

A-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

This source is subject to U.S. EPA's Acid Rain Program, codified at 40 CFR Parts72, 73, and 75. Certain Acid Rain Program's requirements are included in Tables Aand B of this permit for MPCA tracking purposes. All other Acid Rain Programrequirements are referenced in the Phase II Permit Application attached to thispermit as Appendix C.

40 CFR pts. 72, 73, and 75

Acid Rain Sulfur Limitation: Hold allowances after January 1, 2001, as of theallowance transfer deadline, in the unit's compliance subaccount. Allowances maynot be less than the total annual emissions of sulfur dioxide from the previouscalendar year from the unit. Allowances shall be held in deducted from, ortransferred among Allowance Tracking System accounts in accordance with theAcid Rain Program.

40 CFR Section 72.9(c)

At the present time, the Permittee must comply with all the applicable requirementsin 40 CFR pt. 97 for Clean Air Interstate Rule (CAIR) NOx source, a CAIR SO2source, a CAIR NOx unit, and a CAIR SO2 unit as defined in 40 CFR Sections97.102 and 97.202. If the US Environmental Protection Agency promulgates a ruleto stay 40 CFR pt. 97 in Minnesota, this requirement will be of no further force andeffect upon the effective date of the rule.

40 CFR pt. 97; 40 CFR Section 52.1240; Minn. R.7007.0800, subp. 2

Parameters Used in Modeling: The stack heights, emission rates, and otherparameters used in the modeling permit no. 09100058-001 are listed in Appendix Dof this permit.

Title I Condition: 40 CFR Section 52.21(k); Minn. R.7007.3000

Nitrogen Oxides: less than or equal to 749.1 tons/year using 12-month Rolling Sumfrom all six turbines combined. Applies: under all conditions.

Title I Condition: BACT Limit; 40 CFR Section 52.21(j);Minn. R. 7007.3000

Nitrogen Oxides: less than or equal to 1296.0 lbs/hour using 3-hour RollingAverage from all six turbines combined. Applies to gas and oil during startup,shutdown and tuning.

Title I Condition: To avoid violation of NOx NAAQSunder 40 CFR Section 52.21(d); Minn. R.7009.0020-7009.0080

Carbon Monoxide: less than or equal to 1179.4 tons/year using 12-month RollingSum from all six turbines combined. Applies: under all conditions.

Title I Condition: BACT Limit; 40 CFR Section 52.21(j);Minn. R. 7007.3000

HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum for allsix turbines combined. Applies continuously under all conditions.

Title I Condition: To avoid major source classificationunder 40 CFR Section 63.2

HAPs - Total: less than or equal to 24.0 tons/year using 12-month Rolling Sum fromall six turbines combined. Applies continuously under all conditions.

Title I Condition: To avoid major source classificationunder 40 CFR Section 63.2

RECORDKEEPING, MONITORING AND REPORTING FOR SOURCE-SPECIFICREQUIREMENTS

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Total Facility NOx Emissions Recordkeeping and Calculations: By the 15th day ofeach month, the Permittee shall calculate and record the total facility NOxemissions for the previous month, and calculate and record the 12-month rollingsum total facility NOx emissions by summing the total facility NOx emissions fromthe previous 12 months.

Title I Condition: BACT Limit; 40 CFR Section 52.21(j);Minn. R. 7007.0800, subp. 4

Total Facility CO Emissions Recordkeeping and Calculations: By the 15th day ofeach month, the Permittee shall calculate and record the total facility CO emissionsfor the previous month, and calculate and record the 12-month rolling sum totalfacility CO emissions by summing the total facility CO emissions from the previous12 months.

Title I Condition: BACT Limit; 40 CFR Section 52.21(j);Minn. R. 7007.0800, subp. 4

HAP Emissions Recordkeeping and Calculations: By the 15th day of each month,the Permittee shall calculate and record the monthly and annual 12 month rollingsum of HAP emissions. Calculations shall be performed using emission factorsfrom the latest version of AP-42 or AP-42 for gas turbines unless specific emissionfactors for the turbines are developed through stack emissions testing.

If stack emissions testing is used to develop factors for specific HAPs, submit:

a test notification at least 30 days prior to the test;a test plan, at least 30 days prior to the test;a test report, 45 days following the test; anda microfiche copy of the test report, 105 days following the test.

Title I Condition: To avoid major source classificationunder 40 CFR Section 63.2; Minn. R. 7007.0800, subp.4



09100058 - 004

Facility Name:

Permit Number:

A-2

HAP Emission Factors Obtained from Stack Testing:

Emission factors lower than predicted by AP-42: The factor developed from thetesting may be used upon receipt of written approval of the test results from theMPCA, and may be used for 60 months following approval.

Emission factors higher than predicted by AP-42: Should stack emission testingyield emission factors that are higher than those contained in the most recentAP-42 document, the higher factors must be used until a new stack emissions testyields lower factors.

Title I Condition: To avoid major source classificationunder 40 CFR Section 63.2; Minn. R. 7007.0800, subp.4

Acid Rain Recordkeeping: Keep the certificate of representation, all emissionsmonitoring information, copies of all reports, compliance certifications and relatedsubmissions and all records made or required under the Acid Rain Program on sitefor a period of 5 years from the date the document was created.

40 CFR Section 72.9(f)

Acid Rain Excess Emission Report: If the unit has excess emissions, thedesignated representative shall submit a proposed offset plan in accordance with40 CFR Section 72.9(e).

40 CFR Section 72.9(e)

Acid Rain Do Not Exceed Allowances: Emissions from the stationary source cannotexceed any allowances that the source lawfully holds under federal acid rainregulations, except as allowed by Minn. R. 7007.0800, subp. 7.

Minn. R. 7007.0800, subp. 7

Acid Rain Program Submittals Certification: Each submission under the Acid RainProgram shall be submitted, signed, and certified by the designated representativefor all sources on behalf of which the submission is made in accordance with 40CFR Section 72.21.

40 CFR Section 72.21

Application for Acid Rain Program Reissuance: The designated representative shallsubmit a complete Acid Rain permit application for each source with an affectedunit at least 6 months prior to the expiration of an existing Acid Rain permitgoverning the unit during Phase II in accordance with 40 CFR Section 72.21.

40 CFR Section 72.30(c)

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

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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



09100058 - 004

Facility Name:

Permit Number:

A-3

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

Ambient Air Quality Standards: The Permittee shall comply with National Primaryand Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the MinnesotaAmbient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shallbe demonstrated upon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, supbs. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0100-7009.0080.

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, unlessotherwise noted in Table A.

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.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 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

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

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: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises to have access to and copy any records required by this permit, to inspectat reasonable times (which include any time the source is operating) any facilities,equipment, practices or operations, and to sample or monitor any substances orparameters at any location.

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



09100058 - 004

Facility Name:

Permit Number:

A-4

Operation Requirement for NSPS Source: At all times, including periods of startup,shutdown, and malfunction, owners and operators shall, to the extent practicable,maintain and operate any affected facility including associated air pollution controlequipment in a manner consistent with good air pollution control practice forminimizing emissions. Determination of whether acceptable operating andmaintenance procedures are being used will be based on information available tothe Administrator which may include, but is not limited to, monitoring results,opacity observations, review of operating and maintenance procedures, andinspection of the source.

40 CFR Section 60.11(d)

Malfunction means any sudden, infrequent, and not reasonably preventable failureof air pollution control equipment, process equipment, or a process to operate in anormal or usual manner. Failures that are caused in part by poor maintenance orcareless operation are not malfunctions.

40 CFR Section 60.2

Operations during periods of startup, shutdown, and malfunction shall not constituterepresentative conditions for the purpose of a performance test. Emissions inexcess of the level of the applicable emission limit during periods of startup,shutdown, and malfunction shall not be considered a violation of the applicableemission limits set by Minnesota Rules (Minn. Rules ch. 7011), or federal newsource performance standards (40 CFR pt. 60).

40 CFR 60.8(c)Minn. R. 7017.2025, subp. 1

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A and B,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)

RECORDKEEPING REQUIREMENTS hdr

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

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

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

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

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. These records shall be kept for a period of fiveyears from the date the change was made or until permit reissuance, whichever islonger. The records shall be kept at the stationary source for the current calendaryear of operation and may be kept at the stationary source or office of thestationary source for all other years. The records may be maintained in eitherelectronic or paper format.

Minn. R. 7007.1200, subp. 4

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB for additional 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, subps. 1-2



09100058 - 004

Facility Name:

Permit Number:

A-5

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 the breakdownis 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

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. Rs. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend 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 91 days after end of each calendar year starting05/04/2000 (April 1). To be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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



09100058 - 004

Facility Name:

Permit Number:

A-6

Subject Item: EU 001 Combustion Turbine 1 (natural gas- or oil-fired)

Associated Items: MR 001 CT01 NOx: SV 001

MR 002 CT01 O2: SV 001

MR 003 CT01 CO: SV 001

SV 001 Combustion Turbine 1 (gas- or oil-fired)

What to do Why to do it EMISSION LIMITS**Averaging times are specified for those emission limits where compliance isdemonstrated by continuous emission monitor. For all other emission limits theaveraging time is dictated by the appropriate test method.

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Nitrogen Oxides: less than or equal to 9.0 parts per million using 3-hour Average at15% O2 by volume on dry basis, while burning natural gas during normal operationconditions at or below base load to 70% of base load. Normal operating conditionexcludes periods of startup, shutdown, low load (<70% of load), cold weather (lessthan or equal to 0 degree F) and tuning operations. Also meets the limit set by 40CFR Section 60.332.

Title I Condition: BACT Limit, 40 CFR Section 52.21(j);Minn. R. 7007.3000; 40 CFR Section 60.332

Nitrogen Oxides: less than or equal to 25.0 parts per million using 3-hour Averageat 15% O2 by volume on dry basis, while burning natural gas during normaloperating conditions and operating at loads greater than base load (peak firing), atambient temperature less than or equal to 0F and at operating loads less that 70%of base load.

Title I Condition: BACT Limit, 40 CFR Section 52.21(j);Minn. R. 7007.3000; 40 CFR Section 60.332(a)(1)

Nitrogen Oxides: less than or equal to 42.0 parts per million using 3-hour Averageat 15% O2 by volume on dry basis, while burning fuel oil. Applies: after startup andduring normal operating conditions.

Title I Condition: BACT Limit, 40 CFR Section 52.21(j);Minn. R 7007.3000; 40 CFR Section 60.332(a)(1)

Carbon Monoxide: less than or equal to 25.0 parts per million using 3-hour RollingAverage at 15% O2 by volume, while burning natural gas at or above base load.Applies: after startup and during normal operating conditions.

Title I Condition: BACT Limit, 40 CFR Section 52.21(j);Minn. R. 7007.3000

Carbon Monoxide: less than or equal to 20.0 parts per million using 3-hour RollingAverage at 15% O2 by volume, while burning fuel oil. Applies: after startup andduring normal operating conditions.


Total Particulate Matter: less than or equal to 10.0 lbs/hour using 3-hour RollingAverage while burning natural gas.


Total Particulate Matter: less than or equal to 26.0 lbs/hour using 3-hour RollingAverage while burning fuel oil.


Particulate Matter < 10 micron: less than or equal to 10.0 lbs/hour using 3-hourRolling Average while burning natural gas.


Particulate Matter < 10 micron: less than or equal to 26.0 lbs/hour using 3-hourRolling Average while burning oil.


Particulate Matter < 2.5 micron: less than or equal to 10.0 lbs/hour using 3-hourAverage while burning natural gas.

40 CFR Section 52.21; Minn. R. 7007.3000

Particulate Matter < 2.5 micron: less than or equal to 26.0 lbs/hour using 3-hourRolling Average while burning fuel oil.


Sulfur Dioxide: less than or equal to 0.006 lbs/million Btu heat input using 3-hourRolling Average while burning natural gas. Also meets the sulfur dioxide limit set by40 CFR Section 60.333 and Minn. R. 7011.2300


Sulfur Dioxide: less than or equal to 0.05 lbs/million Btu heat input using 3-hourRolling Average while burning fuel oil. Also meets the sulfur dioxide limit set by 40CFR Section 60.333 and Minn. R. 7011.2300


Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input using 3-hourRolling Average

Minn. R. 7011.2300

Sulfur Dioxide: less than or equal to 150 parts per million less than or equal to 150ppm by volume at 15 percent O2 on a dry basis or less than or equal to 0.015percent by volume at 15% O2 on a dry basis.

40 CFR Section 60.333(a); Minn. R. 7011.2350

Volatile Organic Compounds: less than or equal to 4.0 parts per million using3-hour Rolling Average at 15% O2, when burning fuel oil at or above base load.


Volatile Organic Compounds: less than or equal to 6.0 parts per million using3-hour Rolling Average at 15% O2, when burning natural gas at or above baseload.


Opacity: less than or equal to 20 percent opacity once operating temperature hasbeen attained.

Minn. R. 7011.2300

OPERATING CONDITIONS hdr



09100058 - 004

Facility Name:

Permit Number:

A-7

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight Title I Condition: BACT Limit, 40 CFR Section 52.21(j);Minn. R. 7007.3000

Fuel Usage: Limited to pipeline quality natural gas and low sulfur distillate oil.(Maximum sulfur content 0.05% by weight.)


Sulfur Content of Fuel: less than or equal to 0.8 percent by weight (8000 ppmv) ofany fuel.

40 CFR Section 60.333 (b); Minn. R. 7011.2350

Startup Shutdown, and Malfunction: The terms "startup", "shutdown" and"malfunction" shall have the same meaning as defined in 40 CFR Section 60.2.Startup for each unit shall be completed within 25 minutes unless i)longer startup isrequired for purposes of performing maintenance on the unit or ii) longer startup isrequired for safe operation of the unit.

Minn. R. 7007.0800, subp. 2

The Permittee shall hold NOx allowances available for compliance deductionsunder 40 CFR Section 97.54(a), (b), (e), or (f) as of the NOx allowance transferdeadline, in the unit's compliance account.

40 CFR Section 97.6(c)(1)

As of the allowance transfer deadline for a control period, the Permittee shall hold,in the source's compliance account, a tonnage equivalent in CAIR SO2 allowancesavailable for compliance deductions for the control period, as determined inaccordance with 40 CFR Section 97.254(a) and (b).


MONITORING hdr

Calculate and record the applicable emission limit for NOx and CO, each hour, andcompare the actual emission rate with the limit. Since the emission limit is afunction of load, the load will be recorded also.

Load shall be monitored as a percentage of base load. To verify the load, monitorand record megawatts, % of base load and ambient temperature inlet air.

Title I Condition: BACT limits under 40 CFR Section52.21(j); Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 4

Measure CO and NOx emissions using an in-stack monitor. The CO monitor shallbe operated and maintained in accordance with 40 CFR 60, Appendix B,Performance Specification 4A. and Appendix F.


NOx CEMS: The Permittee shall install, certify, operate and maintain, inaccordance with all the requirements of 40 CFR Part 75, a NOx continuousemission monitoring system as defined in 40 CFR Part 75.

40 CFR Section 75.10(a)(2); Minn. R. 7017.1020

Emission Monitoring: The Permittee shall measure and calculate SO2, NOx, andCO2 emissions rates in accordance with 40 CFR Section 75.10

40 CFR Section 75.10; 40 CFR Section 64.3(d)

Emission Monitoring: The Permittee shall use a CEMS to measure NOx emissions,and measure or calculate SO2 and CO2 in accordance with 40 CFR Part 75. ThePermittee shall measure NOx emissions in ppmvd corrected to 15% oxygen andautomatically calculate and record the 1-hour and 3-hour averages NOx emissionrates. NOx ppmvd emission data shall also be converted to lb/mmBtu as requiredby Part 75.

40 CFR Section 75.10; 40 CFR 60.47a(c); 40 CFRSection 60.334(b); Minn. R. 7007.0800, subp. 4; Minn.R. 7011.0560, and 7011.2350

Fuel Monitoring: The Permittee shall follow the applicable fuel sulfur and nitrogencontent monitoring requirements in Section 60.334(h) and shall monitor at thefrequency specified in Section 60.334(i).

40 CFR Sections 60.334(h) and (i); Minn. R.7011.2350; Minn. R. 7007.0800, subp. 4

In accordance with Appendix D, 2.1 or 2.2; for each hour when a unit iscombusting fuel, calculate the hourly SO2 emissions. Follow procedures containedwithin the Appendix for sampling, quality control, fuel analysis, and calculation ofthe hourly SO2 mass emission rate.

40 CFR Part 75, Appendix DOptional SO2 Emissions Data Protocol for Gas and OilFired Units


Performance Test: due before end of each 60 months starting 06/10/2008 tomeasure VOC emissions from SV 001 while using natural gas. The performancetest requirement under this condition must be completed by 6/10/2013

For additional applicable performance test requirements see "General PerformanceTest Requirement" in Table A, subject item. "Total Facility"

Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months starting 06/13/2006 tomeasure VOC emissions from SV 001 while using distillate fuel oil. Theperformance test requirement under this condition must be completed by6/13/2011.


Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months starting 06/13/2006 tomeasure Opacity from SV 001 while using distillate fuel oil. The performance testrequirement under this condition must be completed by 6/13/2011.

Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-8

Recordkeeping: Maintain records of the occurrence and duration of any startup,shutdown, or malfunction in the operation of the facility including malfunction of theair pollution control equipment or any periods during which a continuous monitoringsystem or monitoring device is inoperative.

Minn. R. 7007.0800, subp. 5

The Permittee shall keep the records specified in 40 CFR Section 97.6(e)(1) for aperiod of 5 years from the date the document is created.

40 CFR Section 97.6(e)(1)

The Permittee shall keep the records specified in 40 CFR Section 97.206(e)(1) fora period of 5 years from the date the document is created.




09100058 - 004

Facility Name:

Permit Number:

A-9



MR 005 CT 02 O2: SV 002

MR 006 CT02 CO: SV 002



hdr




























Minn. R. 7011.2300








Minn. R. 7011.2300




09100058 - 004

Facility Name:

Permit Number:

A-10







Minn. R. 7007.0800, subp. 2





MONITORING hdr



















Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-11


Minn. R. 7007.0800, subp. 5







09100058 - 004

Facility Name:

Permit Number:

A-12



MR 008 CT03 O2: SV 003

MR 009 CT03 CO: SV 003



hdr




























Minn. R. 7011.2300








Minn. R. 7011.2300




09100058 - 004

Facility Name:

Permit Number:

A-13







Minn. R. 7007.0800, subp. 2





MONITORING hdr



















Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-14


Minn. R. 7007.0800, subp. 5







09100058 - 004

Facility Name:

Permit Number:

A-15



MR 011 CT04 O2: SV 004

MR 012 CT04 CO: SV 004



hdr




























Minn. R. 7011.2300








Minn. R. 7011.2300




09100058 - 004

Facility Name:

Permit Number:

A-16







Minn. R. 7007.0800, subp. 2





MONITORING hdr



















Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-17


Minn. R. 7007.0800, subp. 5







09100058 - 004

Facility Name:

Permit Number:

A-18



MR 014 CT05 O2: SV 005

MR 015 CT05 CO: SV 005



hdr




























Minn. R. 7011.2300








Minn. R. 7011.2300




09100058 - 004

Facility Name:

Permit Number:

A-19







Minn. R. 7007.0800, subp. 2





MONITORING hdr



















Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-20


Minn. R. 7007.0800, subp. 5







09100058 - 004

Facility Name:

Permit Number:

A-21



MR 017 CT06 O2: SV 006

MR 018 CT06 CO: SV 006



hdr




























Minn. R. 7011.2300



Volatile Organic Compounds: less than or equal to 4.0 parts per million using3-hour Rolling Average at 15% O2, when burning fuel oil at, or above base load.


Volatile Organic Compounds: less than or equal to 6.0 parts per million using3-hour Rolling Average at 15% O2, when burning natural gas, at or above baseload.



Minn. R. 7011.2300




09100058 - 004

Facility Name:

Permit Number:

A-22







Minn. R. 7007.0800, subp. 2





MONITORING hdr



















Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

RECORDKEEPING hdr



09100058 - 004

Facility Name:

Permit Number:

A-23


Minn. R. 7007.0800, subp. 5







09100058 - 004

Facility Name:

Permit Number:

A-24

Subject Item: EU 007 Black Start Generator (diesel)

Associated Items: SV 007 Black Start Generator (Diesel)

What to do Why to do itEMISSION LIMITS hdr

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1


Minn. R. 7011.2300, subp. 2

OPERATING RESTRICTIONS hdr

Operating Hours: less than or equal to 1000 hours/year using 12-month RollingSum to be calculated by the 15th day of each month.

Title I Condition: BACT Limit, 40 CFR 52.21; Minn. R.7007.3000

Fuel type: Diesel Fuel only by design. 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 diesel fuel, certifying that the sulfur content doesnot exceed 0.50% by weight.

Minn. R. 7007.0800, subps. 4 & 5

Recordkeeping of Operating hours: By the 15th day of each month, the Permitteeshall maintain records of 12-month rolling sum of the operating hours.

Minn. R. 7007.0800, subp. 5



09100058 - 004

Facility Name:

Permit Number:

A-25

Subject Item: TK 001 Distillate Oil

What to do Why to do itThe owner or operator shall equip the storage vessel with a permanent submergedfill pipe.

Minn. R. 7011.1505, subp. 3(B); Minn. R. 7011.1505,subp. 3C (1)-(2); Minn. R. 7011.1500, subp. 10



09100058 - 004

Facility Name:

Permit Number:

A-26

Subject Item: MR 001 CT01 NOx: SV 001

Associated Items: CM 001 CT01 CEMS

EU 001 Combustion Turbine 1 (natural gas- or oil-fired)

What to do Why to do it REQUIREMENTS FOR CEMS hdr

CEMS Quality Assurance/Quality Control (QA/QC): The owner or operator of anaffected facility shall operate, calibrate, and maintain each CEMS according to theQA/QC procedures in 40 CFR pt. 75, appendix B as amended.


CEMS Continuous Operation: CEMS must be operated and data recorded duringall periods 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 CEMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

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

40 CFR Section 60.13 (e), subp. 6; Minn. R.7017.1090, subp. 1

Daily Calibration Error (CE) Test: Conduct daily CE testing on all CEMS required bythe Acid Rain Program, in accordance with 40 CFR pt. 75, Appendix B.

40 CFR pt. 75, Appendix B, Section 2.1

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 be performed annually (i.e., once every foursuccessive QA operating quarters, rather than once every two successive QAoperating quarters or a calendar quarter that does not qualify for as a QA operatingquarter shall be excluded in determing the deadline for the next RATA. No morethan 8 successive calendar quarters shall elapse after the quarter in which a RATAwas last performed) if any of the conditions listed 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

Linearity and Leak Check Test (Acid Rain Program): due before end of each QAoperating quarter (as defined in Section 72.) in accordance with procedures in 40CFR pt. 75, Appendix B, Sections 2.2.1 and 2.2.2, and Appendix A, Section 6.2.

Perform a leak check at least once during each QA operating quarter (calendarquarter in which there are at least 168 unit operating hours) and no less than 30days apart.

40 CFR pt. 75, Appendix B, section 2.2.1, and section2.2.2; Minn. R. 7017.1020

RECORDKEEPING hdr

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.

Minn. R. 7017.1130; and 40 CFR Section 75.50

REPORTING (SEE TABLE B) hdr

Linearity Test Results Summary: due 30 days after end of each calendar quarterfollowing Linearity and Leak Check Test if performed.

Minn. R. 7017.1180, subp. 4

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

Minn. R. 7017.1180, subp. 2

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end ofeach calendar quarter in which the CEMS RATA was conducted.

Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-27

Subject Item: MR 002 CT01 O2: SV 001

















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-28

Subject Item: MR 003 CT01 CO: SV 001




CEMS 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 CEMS according to the QA/QC procedures in 40 CFRpt. 60, Appendix F as amended and maintain a written QA/QC program available ina form suitable for inspection.

40 CFR pt. 60, Appendix F; 40 CFR Section 60.13(a)

Continuous Operation: CEMS 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 CEMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

40 CFR Section 60.13(e), Minn. R. 7017.1090, subp. 1

CEMS Daily Calibration Drift Check: Permittees must automatically check the zero(low level value between 0 and 20 percent of span value) and span (50 to 100percent of span value) calibration drifts at least once daily. The zero and spanmust, at a minimum, be adjusted whenever the drift exceeds two times the limitspecified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F shall be used todetermine out-of-control periods for CEMS.

40 CFR pt. 60, Appendix F, section 4.1; 40 CFRSection 60.13(d)(1) regarding CEMS; Minn. R.7017.1170, subp. 3

Cylinder Gas Audit (CGA): due before end of each calendar quarter followingCEMS certification test. A CGA is not required during any calendar quarter inwhich a RATA was performed.

40 CFR pt. 60, Appendix F, section 5.1.2; Minn. R.7017.1170, subp. 4

CEMS Monitor Design: Each CEMS shall be designed to complete a minimum ofone cycle of sampling, analyzing, and data recording in each 15-minute period.


Monitoring Data: Reduce all to 1-hour averages, in accordance with 40 CFRSection 60.13(h). 1-hour averages shall be computed from four or more data pointsequally spaced over each 1-hour period.

40 CFR Section 60.13(h) regarding continuousmonitoring systems other than COMS.

RECORDKEEPING hdr


Minn. R. 7017.1130; 40 CFR Section 60.7(f)

CEMS QA Plan: Develop and implement a written quality assurance plan for theCEMS. The plan shall be on site and availabe for inspection within 30 days afterCEMS certification. The plan shall contain all information required by 40 CFR Part60, Appendix F, Section 3.

Minn. R. 7017.1170, subp. 2; 40 CFR pt. 60, App. F;section 3


CEMS Relative Accuracy Test Audit (RATA): due before end of each calendaryear following CEMS Certification Test. Follow the procedures in 40 CFR pt. 60,Appendix F.


Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of eachcalendar quarter following Cylinder Gas Audit (CGA).

Minn. R. 7017.1180, subp.1

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

Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-29


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-30

Subject Item: MR 005 CT 02 O2: SV 002

















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-31

















RECORDKEEPING hdr









Minn. R. 7017.1180, subp.1


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-32


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-33


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-34

















RECORDKEEPING hdr









Minn. R. 7017.1180, subp.1


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-35


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-36


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-37

















RECORDKEEPING hdr









Minn. R. 7017.1180, subp.1


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-38


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-39


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-40

















RECORDKEEPING hdr









Minn. R. 7017.1180, subp.1


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-41


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-42


















RECORDKEEPING hdr





Minn. R. 7017.1180, subp. 4


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3



09100058 - 004

Facility Name:

Permit Number:

A-43

















RECORDKEEPING hdr









Minn. R. 7017.1180, subp.1


Minn. R. 7017.1180, subp. 2


Minn. R. 7017.1180, subp. 3

TABLE B: SUBMITTALSFacility Name: Great River Energy - Lakefield Junction

Permit Number: 09100058 - 004

06/17/09B-1

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor 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

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.

Send any application for a permit or permit amendment to:

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

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: Great River Energy - Lakefield Junction


06/17/09B-2

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

PermitTotal Facility

TABLE B: RECURRENT SUBMITTALSFacility Name: Great River Energy - Lakefield Junction


06/17/09B-3

What to send When to send Portion of Facility AffectedExcess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar

quarter following CEM Certification Test(Submit Deviations 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.

MR001, MR002, MR004, MR005, MR007,MR008, MR010, MR011, MR013, MR014,MR016, MR017

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter following Initial Startup of the Monitor.The EER shall indicate all periods of monitorbypass and all periods of exceedances of thelimit including exceedances allowed by anapplicable standard, i.e. during startup,shutdown, and malfunctions.

MR003, MR006, MR009, MR012, MR015,MR018

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 05/04/2000. 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.

Excess emissions shall be included in thereport as required by 40 CFR 60.7(c).

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 05/04/2000 (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

Appendix B: Insignificant Activities Required to be Listed Facility Name: Great River Energy- Lakefield Junction Station Permit Number: 09100058-004

Insignificant Activities and Applicable Requirements

Minn. R. 7007.1300, subpart

Rule Description of Activities Likely Applicable Requirement

3 (A) Natural gas and propane fired space heaters

Minn. R. 7011. 0515

3(H)(3) Brazing, Soldering, and Welding Operations associated with maintaining equipment on site

Minn. R. 7011.0715

3(I) Parts Washers that use less than 2,000 lbs of solvent per year

Minn. R. 7011. 0715

3(J) Fugitive emissions from unpaved roads and parking lots

Minn. R. 7011.0150

3(K) Compressed air spray painting used in the maintenance of buildings and equipment

Minn. R. 7011.0715

4(B) Fuel Forwarding Fugitive Emissions

Minn. R. 7011.0150

4 (B) Fire Pump Diesel Engine Minn. R. 7011.2300 4(B) Natural Gas Fuel Heaters Minn. R. 7011.0515

Appendix C Facility Name: Great River Energy-Lakefield Junction Station Permit Number: 09100058-004

Phase II Permit Application For more information, see instructions and refer to 40 CFR 72.30 and 72.31 This submission is New Revised ⌧ Reissuance Plant Name: Lakefield Junction Generating Station

State Minnesota

ORIS Code: 7925

Compliance Plan

a Unit 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

CT01 Yes - 6/8/2001 September 2001 CT02 Yes - 6/2/2001 September 2001 CT03 Yes - 5/26/2001 September 2001 CT04 Yes - 5/22/2001 September 2001 CT05 Yes - 5/14/2001 September 2001 CT06 Yes - 5/09/2001 September 2001 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: (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: D Modeled Parameters Relied Upon to Demonstrate Compliance with

PM10, SO2, CO and NOx National and Minnesota Ambient Air Quality Standards

Technical Support Document, Permit Action Number: 09100058-004; DQ 300 Page 1 of 23 Date: 8/4/2009

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 09100058-004 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 determination to issue the final permit. 1. General Information 1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 4911)

Great River Energy-Lakefield Junction 12300 Elm Creek Boulevard Maple Grove, MN 55369

Great River Energy-Lakefield Junction 2159 20th Avenue Trimont Martin County

Contact: Greg Archer Phone: 763-445-5206

1.2. Description of the Permit Action Great River Energy(GRE or Permittee) - Lakefield Junction operates six simple-cycle combustion turbines (with natural gas and very low sulfur distillate oil, each with a nominal capacity of 92 Megawatt (MW); a black start generator, two natural gas preheaters, a distillate fuel oil tank, associated fuel oil forwarding system and insignificant activities. This permit action is a Part 70 Reissuance permit for GRE- Lakefield Junction. 1.3 Description of any Changes Allowed with this Permit Issuance GRE-Lakefield Junction proposed alternative operating limits to address periods of startup/shutdown, cold weather and variable load operation for its single cycle combustion turbines. The alternative operating limits are supported by both operational data demonstrating emissions variability and by existing modeling, presented as part of the original Prevention of Significant Deterioration (PSD) permitting action 001.

With respect to the Lakefield Junction Title V permit renewal, the Permittee requested inclusion of alternative operating scenarios and limits as a major amendment under state rules, but these changes would not be considered major modifications under PSD. There is neither a physical change to the emission unit nor a change in the method of operation associated with


incorporating the alternative operating limits. Therefore, no PSD permitting action is triggered. The existing Best Available Control Technology (BACT) permit limits are retained in this permit and additional new limits to account for alternate operating scenarios have been included. These additional limits for various operating modes such as low load, startup/shutdown, tuning all load, and cold weather conditions were overlooked during the initial BACT analysis. This permit does not authorize any new emission units or allow for increase in emissions in tons per year but permitted hourly emissions will increase during the alternative operating scenarios. The hourly emissions increase will not trigger any New Source Performance Standards (NSPS) requirements because the changes are not considered a modification as defined in 40 CFR Section 60.14. 1.4 Description of All Amendments Issued Since the Issuance of the Last Total Facility

Permit Permit Number and Issuance Date

Action Authorized

09100058-002 March 5, 2001

Administrative amendment clarifying a permit term in the permit for the notification of Continuous Emission Monitoring.

09100058-003 September 10, 2002

Major amendment authorized the Permittee to perform design improvements with the gas turbine; therefore physical modifications were made to each combustion turbine.

1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary

PM tpy

PM2.5 tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Single HAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions

231.4 231.4 231.4 235.6 753.9 1180.5 41.8 9.0 24.0

Total Facility Actual Emissions (2006)

11.07 N/A 11.07 2.01 46.0 54.3 0.31 HAPs not reported in emission inventory


Table 2. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD NOx, CO, PM, PM10, PM2.5,SO2

VOC, Pb

Part 70 Permit Program PM2.5, PM10, SO2, NOx, CO

VOC, Pb

Part 63 NESHAP HAPs 1.6. Changes to the Permit The following changes have been made in the reissued permit:

• Updated to reflect current MPCA templates and standard citation formatting; • Included the alternative operating limits to address periods of startup/shutdown, cold

weather and variable load operation for the combustion turbines 001-006; • Updated potential emissions calculations; • Removed the NSPS requirements for TK 001 which no longer apply; • Completed requirements have been removed; and • Incorporated the performance testing frequency for all combustion turbines.

2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under New Source Review regulations. No changes are authorized by this permit to change the status. The facility will retain its BACT limits for PM, PM10, SO2, NOx, CO and VOC but additional NOx limits for various operating modes such as low load, startup/shutdown, tuning above base load, and cold weather conditions were included in the permit that were overlooked during the initial BACT analysis.

Part 70 Permit Program

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

New Source Performance Standards (NSPS)

The combustion turbines are subject to the New Source Performance Standards for Gas Turbines, 40 CFR pt. 60, Subpart GG. This standard was revised on July, 8, 2004; therefore applicable changes have been made to the permit. The changes in the permit will not be considered a modification as defined in 40 CFR § 60.14.


National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility has accepted limits on HAP usage such that it is a non-major source under 40 CFR pt. 63. Thus, no NESHAPs apply. In addition, no area source NESHAPs apply.

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance: • Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

• Minn. R. 7011.2350 Standards of Performance for New Stationary Gas Turbines

• Minn. R. 7011.1505 Standards of Performance for Storage Vessels Acid Rain Program

Combustion turbines EU 001-006 are subject to the acid rain program requirements to monitor and report SO2, NOX, and CO2 emissions and to hold sufficient SO2 allowances for annual SO2 emissions. 40 CFR pt. 75 offers several monitoring provisions in addition to the general operating requirements CEMS, including Appendices D and E for peaking units, low mass emission provisions at 40 CFR § 75.19, and alternative monitoring systems under 40 CFR pt. 75, subpart E, which allows for certifying predictive emission monitoring systems (PEMS). The acid rain permit application is included Appendix C to the permit. Compliance Assurance Monitoring (CAM)

Water injection used for NOx control when combusting distillate fuel oil is an add on control device. Turbine NOx emissions are subject to the standard in 40 CFR pt. 60, subp. GG. Permitted potential NOx emissions from each turbine exceeds the Part 70 major source threshold; therefore the turbines are large pollutant-specific emission units subject to CAM for NOx emissions. The Permittee will use the NOx CEMS to meet the requirements of part 64 as required by 40 CFR § 64.3(d). Also, the subp. GG revisions made in 2004 are post 1990 and therefore would qualify under the exemption to Part 64 at 40 CFR § 64.2(b)(1)(i) Clean Air Interstate Rule (CAIR)

On July 11, 2008, the DC Circuit Court of Appeals issued an opinion pointing out several “fatal flaws” with the Clean Air Interstate Rule. In the opinion, the Court vacated the existing rule. However, the Court never issued the mandate – the vehicle that would have explicitly prevented CAIR from taking effect. EPA petitioned for rehearing, asking the Court to make substantive changes to the July opinion, and to change the remedy from vacatur to simple remand.


On December 23, 2008, the Court issued a panel opinion that changed the remedy. CAIR was remanded to EPA to be rewritten, addressing the flaws identified in the July ruling. However, the Court made no substantive changes to its opinion; EPA must therefore address all the flaws identified in July. With the remedy changing to a simple remand, the entirety of CAIR goes into effect as previously planned (including all parts that the Court identified as flawed.) One main issue that EPA needs to address on remand is whether Minnesota should continue to be included in CAIR. The Court ruled in July that EPA did not adequately respond to claims made by Minnesota Power that data on Minnesota emissions were inaccurate, and that using better data would result in Minnesota falling below the threshold impact on a non-attainment area that was used to determine inclusion. In a letter dated October 31, 2008, from Robert Meyers (Principal Deputy Assistant Administrator, Office of Air and Radiation) and Granta Nakayama (Assistant Administrator, Office of Enforcement and Compliance Assurance) to Minnesota Power’s counsel, EPA stated:

[I]t is the U.S. Environmental Protection Agency’s (EPA) intention to publish in the Federal Register a rule amending the Clean Air Interstate Rule (CAIR) to stay the effectiveness of the rule with respect to sources located in the State of Minnesota. That administrative stay will remain in effect until such time as EPA determines through a rulemaking under the Clean Air Act whether Minnesota should be included in the CAIR region for fine particulate matter. EPA believes that in light of the Court’s decision, sources in Minnesota should not be required to make any additional expenditures to comply with CAIR prior to the expiration of the administrative stay of the rule.

The Court was aware of this letter when it made its December 23 decision. EPA’s John Mooney from the Region V Office notified the MPCA that on January 15, 2009, the EPA Administrator signed the notice for the proposed rule to stay CAIR requirements in Minnesota until the Agency determines whether Minnesota should be in the CAIR region. On January 20, 2009, Mr. Rahm Emanuel, Assistant to the President and Chief of Staff, signed a “Memorandum for the Heads of Executive Departments and Agencies” on the subject of “Regulatory Review”. In this memorandum, Mr. Emanuel directs his staff to stop sending proposed and final regulations to the Office of the Federal Register (OFR) and to withdraw proposed and final regulations from the OFR that have not been published in the Federal Register. The proposed rule to stay CAIR requirements in Minnesota has not been published in the Federal Register. Copies of the signed proposed rule to stay CAIR requirements in Minnesota and its fact sheet can be found at http://epa.gov/cair/pdfs/20090114proposal.pdf http://epa.gov/cair/pdfs/20090114fs.pdf


Please also note that under the proposed rule to stay CAIR in Minnesota, EPA requires that as of June 30, 2009, each Minnesota source with recorded allowance allocations under the annual NOX trading program must hold an amount of allowances issued for the same year as the recorded allowances (e.g., 2009) equal to the amount of the recorded allocations. EPA also proposes that the Administrator deduct, and retire, these required allowance holdings and that no additional allowance allocations from the state annual NOx trading budget for Minnesota be recorded. Although these provisions could be amended after review by staff in President Obama’s administration, this should be an important consideration for management of recorded allowances by CAIR sources in Minnesota. The date for submitting allowances for the 2009 annual NOX program is not until early 2010; EPA should be able to promulgate a stay of the rule by that time. However, it is likely to be in covered sources best interests to continue to report emissions data quarterly as required by the CAIR rule. In addition, Minnesota may be included in the re-promulgated CAIR rule. It must be noted that after publication, this remains a proposed rule; a stay of the rule is not official until it has gone through the notice and comment rulemaking proceedings in the Federal Register. Such public participation and rule promulgation process could take several months. Until that time, CAIR is officially in effect in Minnesota. Therefore, for the time being, the permits for CAIR affected facilities have a condition at the total facility level requesting compliance with CAIR with a sunset provision linked to EPA’s future regulatory actions. The MPCA will not go as far as to issue a CAIR permit given the current prospects of the CAIR program in Minnesota.


Table 3. Regulatory Overview of Facility EU, GP, or

SV Applicable Regulations Comments:

Total Facility (TF)

Minn. R. chs. 7002, 7007, 7009, 7011, 7019, and 7030

Table A contains requirements that apply to all facilities in Minnesota. Reporting and monitoring requirements are contained in Table B of the permit. Monitoring provisions will be demonstrated as required by the appropriate regulations or as recommended by equipment manufacturer.

TF 40 CFR pts. 72, 73 and 75

EPA’s Acid Rain Program, codified in 40 CFR pts. 72, 73, and 75. Acid Rain program requirements are included in Tables A and B of this permit. The acid rain permit application is included in Appendix C.

TF, EU 001-006

40 CFR § 52.21 (j) and Minn. R. 7007.3000

Title I Condition: BACT limit for PM, PM10, NOx, CO and VOC. Corresponding monitoring and recordkeeping are required.

TF Title I limit to avoid NESHAPs

Limit set on HAPs emissions from total facility to avoid major source classification under 40 CFR pt. 63.

TF 40 CFR § 52.21 (d); Minn. R. 7007.3000; Minn. R. 7009.0020

Ambient Air Quality Standards: Limits for NOx set at the total facility level. Limits derived from computer dispersion modeling.

TF 40 CFR § 52.21(r)(6) and Minn. R. 7007.3000

Title I Condition: These requirements apply if a reasonable possibility exists that a proposed project, analyzed used actual-to-projected actual test that found not to be part of a major modification but may result in a significant emission increase.

EU 001-006 40 CFR pt. 97 Clean Air Interstate Rule (CAIR). The conditions at the total facility level requesting compliance with CAIR with a sunset provision link to EPA’s future regulatory actions.

EU 001-006, 007

Minn. R. 7011.2300 Standards of Performance for Internal Combustion Engines.

TF 40 CFR pt. 50; Minn. R. 7009.0010-0080

Modeling requirements to ensure emissions do not cause a violation of the ambient air quality standards.

EU 001-006 40 CFR pt. 60, subp. GG; Minn. R. 7011.2350

New Standards of Performance for Gas Turbines

TK 001 Minn. R. 7011.1505, subp. 3 (B)

Standards of Performance for Storage Vessels

TF Minn. R. 7030.0010-7030.0080

The language 'This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act' refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law. State law requirements are not enforceable by EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.


3. Technical Information In the fall of 2007, GRE proposed alternative operating limits for its facility in Lakefield Junction to address periods of startup/shutdown, cold weather and variable load operation of their combustion turbines. The alternative operating limits are supported by both operational data demonstrating emissions variability and by existing modeling, presented as part of the original PSD permitting action (PER 001). With respect to the Lakefield Junction Title V permit renewal, the requested inclusion of alternative operating limits as a major amendment under state rules, but they would not be considered major modifications under PSD. There is neither a physical change to the emission unit nor a change in the method of operation associated with incorporating the alternative operating limits. Therefore, no PSD permitting action is triggered but Title I changes are made by revising the initial BACT analysis as part of this Title V reissuance. The following are the justifications for the alternative operating limits:

1. The existing NOx BACT limit only applies during normal operation and does not apply during periods of start up or shutdown (SS);

2. General Electric (GE) has repeatedly tuned the units and has recently recommended a control system upgrade that will allow remote tuning as a final mechanism to improve turbine performance;

3. GE will not guarantee compliance with the 9 parts per million by volume (ppmvd) limit under all operating conditions even with the control system upgrade. 9ppmvd is the design value on these units. Despite frequent tunings, the turbine’s operational history demonstrates that the design value is periodically exceeded;

4. EPA has already established an alternative BACT operating limit for GE units, like the one in Lakefield, at 100ppm – (Alternative BACT Limit for Startup Shutdown and Tuning at 100 parts per million (ppm) NOx, while combusting natural gas;

5. Lakefield Junction Emission Summary Tables focus on recent emissions (fourth quarter 2006, first quarter and second quarter 2007) and support an emission rate of roughly 80ppm NOx, which includes startup/shutdown, cold weather, low load and tuning operations;

6. Lakefield Modeling - Existing Title V modeling is protective of annual NOx National Ambient Air Quality Standards (NAAQS) at 216 lb/hr per unit or roughly 65 ppm. At this level, all six units were modeled under the NOx increment, which is 1/100 of the annual NOx NAQQS. As a conservative demonstrated of NOx NAAQS, the total facility emissions will be tracked to be less than 1296 lb/hr based on a 3-hour rolling average at the facility level;

7. Total facility NOx ton/yr cap emission is inclusive of higher short term NOx emission rates and is protective of annual NAAQS, especially when viewed in conjunction with 25 minute startup requirement and all emissions as discussed in the facility first Title V permit;

8. Additional evidence includes;


a . With respect to cold weather operation, NSPS KKKK Table 1 presents an alternative NOx emission rate of 96 ppm when the ambient temperature is less than 0 degrees F. As recently as this January 2008, GRE was operating the GE Turbines with ambient temperatures below 0F and experiencing difficulties with the 9 ppmvd BACT limit. GE had a tuning engineer on site continuously for over a week, who was unable to ensure that the units could consistently operate in compliance with the BACT limit. In the NSPS KKKK preamble, EPA states that “(t)urbines do not operate optimally at temperatures below 0F…. If you are using a CEMS for demonstrating compliance, alternate emissions standards apply when the ambient temperature is below 0 F. GRE recognizes that these temperatures may increase emissions from the turbine.” (Federal Register Vol. 71, No. 129 July 6, 2009. pg 38489) Given GRE operational history with the GE turbines, it is essential that they could establish a cold weather alternative NOx at 96 ppm consistent with NSPS KKKK requirements as part of the permit renewal; and

b. Similarly, EPA acknowledges that emission rates are difficult to maintain at low load operation, which can occur during start up, shut down and significant load swings. (Federal Register Vol. 71, No. 129 July 6, 2009. pg 38484 Table 1) EPA states, “we specified in the final rule that turbine owners and operators that are continuously monitoring parameters or emissions have an alternative limit during periods when the turbine operates at less than 75 percent of peak load…” (Federal Register Vol. 71, No. 129 July 6, 2009. pg 38486). Like the alternative cold weather limit, the low load operational limit will be 96 ppm NOx. With respect to modeling, the low load operation will have lower mass (lb/hr) emissions and should be within the 216 lb/hr as has been demonstrated to be protective of the significant impact levels (SIL) (1 ug/m3) and NAAQS (100 ug/m3).

GRE-Lakefield Junction originally proposed 60MW, but the Agency suggested a percent of baseload, which is more consistent with NSPS KKKK requirements. The logic behind switching from 60MW as the low load operational level to a percent of baseload as a more restrictive, low load limit. The 60MW value was established based on the data that was submitted in late 2007. It reflected the Permittee operational difficulties during both cold weather and during variable load over a range of operations mostly in fall and winter. The 60MW was inclusive of ~2-10MW of operation between a ‘ premix on’ MW value, which is when the units moves into dry low NOx, and lowest operational load at a specific ambient temperature. As a calculated percentage of baseload, 60MW represented a range from 60 percent to 80 percent depending on ambient temperature, as noted in the table.


*Stack vision CEM data *1/13/09 data at<0F = 55-65MW. 5 of 6 units over 60MW. **11/10/08 data at~20F = 47-52MW and 3/15/08 data at ~30F 55-58MW, 12/16/08 data at ~10F 53-59MW, depending on the unit. ***The Permittee could not locate any ~59F data on short order.

****8/1/08 data at ~90F = 46-54MW depending on the unit (Please note that GE does not provide specific values for lowest operational load at ambient temps or ‘premix on’ MW values. When it was extrapolated from the data, and, as noted in the table, each unit was different with a range of values depending on ambient temperature. As a point of reference, for a specific unit, a 1-2 minute change in the ‘premix on’ value was as much as 5-10 MW difference. In other words, on a cold day, if the unit took a few extra minutes to switch into premix, which can be resulted in a 5-10MW higher ‘premix value,”. The units with the relatively lower MW values were a bit quicker at switching into premix.) In principle, the Permittee wanted to find a percent if baseload value that will cover the same ~2-10 MW above the ‘premix on’ point across the range of operation. The data was reviewed again and realized that 67 percent was not entirely inclusive. The -10F scenario from ‘variable load’ consideration was separated since that is covered by the cold weather provision. Similarly at 92F, the Permittee did not have many issues with NOx performance and is therefore not as concerned about the MW difference between ‘premix on’ and low load operation. As noted, the 70 percent baseload value was essentially equivalent to the 60MW value. The 70 percent of baseload becomes more restrictive as ambient temperatures rise. Given the proximity to the ‘premix on’ MW values for some units, especially at 10F, the Permittee preferred a 75 percent of baseload value to provide some margin for error at these colder temperatures. However, at this point, the Permittee is comfortable with the 70 percent of baseload value because it will address most of their excess emissions when combined with the <0F provision. Interestingly, the 70 percent of baseload is slightly more restrictive than the NSPS KKKK rule that establishes a low load operation at 75 percent of peak operation for combustion turbines. (Peak firing generally adds a few MW to baseload.) The KKKK preamble discussed the difficulty with NOx compliance for both variable load and cold weather operation.

Ambient Temp

Proposed - Low Load

Baseload MW (GE Data)

60MW as a % of Baseload

Calculated MW at 70% of baseload

~Premix On (MW)

-10F 60MW 98.71 60.7% 69.09 ~55 to 65* 45F 60MW 83.39 71.4% 58.37 ~47 to 59** 59F 60MW 80.09 74.1% 56.06 N/A*** 92F 60MW 74.48 80.5% 52.13 ~46 to

54****


The Pemittee has proposed the following short term and long term proposals:

1. Short Term Proposal – Issue Permit with Alternative Operating NOx limit at 65ppm

a. Establish alternative operating limits are 216 lbs/hr per unit or 1296 lbs/hr for all the units that includes SS, cold weather (<0F), low load (< 70 percent of load) and tuning based on existing modeling in an effort to renew permit expeditiously. The 9ppmvd and 25 ppmvd limits apply for normal operation conditions; and

b. Explicitly include an hourly averaging function that is consistent with Part 60 and Part 75. Essentially, the Permittee needs to operate in each quarter of the hour in order to count the entire hour for averaging. For averaging during any operational hour that includes alternative operating conditions, the higher emission rate applies to the entire hour for the purpose of averaging against the 3-hour BACT limit(s).

2. Long Term Proposal – Rescind All BACT Limits

a. The Permittee will continue to work with USEPA to create national guidance that will ultimately allow BACT rescission;

b. Bill Harnett, EPA, states that, given Lakefield’s situation, it is a good policy decision to allow BACT rescission, but there are other more pressing policy issues at this time; and

c. When EPA issues national policy, the Permittee will submit the appropriate permit amendment to rescind BACT limits and add Title I total facility limits to the permit to establish the source as non-major PSD.

In summary, the MPCA will support the Alternative NOx Emission Permit Language – less than or equal to 1296 lbs/hr based on a 3-hour rolling average. This limit is supportive of the existing modeling. The modeling must be updated and demonstrated to be protective of NAAQS, if the Permittee wants to increase the NOx emission to 100 ppm through the permit amendment process. Existing NOx Emission Permit Language – Nitrogen Oxides – 9ppm NOx limit during normal operation, which is defined as “less than or equal to 9 ppmvd at 15 percent 02 using a 3 hour average while burning natural gas at or below base load to 70 percent of baseload. Applies after startup, during normal operation and at >0F (as tracked by the ambient temperature inlet air signal). The NOx peak limit would be amended to read, “less than or equal to 25 ppmvd at 15 percent 02 using a 3 hour average while burning natural gas at operating loads greater than base load (peak firing), at ambient temperatures ≤ 0F as tracked by the ambient temperature inlet air signal, and at operating loads less than 70 percent of base load.” Other BACT Emission Limits – the other BACT limits will not be amended since the existing operational data generally support the limits.


3.1 Calculations of Potential to Emit Emissions for the total facility were calculated by the Permittee and audited by the MPCA staff. The spreadsheet is included in Attachment 1 to the TSD. The Permittee used the following calculation method to determine emissions for the facility.

1. For the Combustion Turbines: CEMS for CO and NOx; fuel certifications and fuel meters for SO2; performance test for VOC, PM and PM10; AP-42 factors for HAPs and assumed that all PM2.5 is equal to PM10 because PM is composed of organic and inorganic compounds and is generally considered to be all less that 1.0 micrometers in aerodynamic diameter;

2. For the Emergency Generators: AP-42 emission factors for all pollutants; and 3. Averaging times are specified for those emission limits where compliance is

demonstrated by continuous emission monitors. For all other emission limits the averaging time is dictated by the appropriate test method.

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.

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.


Table 4. Periodic Monitoring Emission Unit or Group

Requirement (basis) Additional Monitoring

Discussion

Total Facility

(TF), EU 001-006

NOx: 749.1 tpy on a 12-month rolling sum basis (BACT) Natural Gas Combustion • 9 ppmvd at 15% O2 for loads

at or below base load to 70% of base load (BACT)

• 1296 lbs/hr based on a 3-hour rolling average (limit to avoid NOx NAAQS)

• 25 ppmvd at 15% O2 at loads greater than base load (peak firing) at ambient temperature less than or equal to 0 degree F at operating less than 70 % of base load (BACT)

Fuel Oil Combustion • 42 ppmvd at 15% O2 at 25%

of rate load (BACT)

Daily and monthly recordkeeping NOx CEMS Records of hourly fuel usage (type of fuel) Records of hourly operating load (percent of rated load)

CEM is used to measure NOx emissions continuously; therefore, it will provide continuous assurance of compliance. The Permittee will validate the CEM consistent with Part 75 requirements. The limits are set based on operating scenarios. The Permittee will also use 12-month rolling sum emissions data to calculate the total facility 12-month rolling sum emissions.

TF, EU 001-006

CO: 1179.4 tpy on a 12-month rolling sum basis (BACT) Natural Gas Combustion 25 ppmvd at 15% O2 for loads at or above base load (BACT) Fuel Oil Combustion

20 ppmvd at 15% O2 after startup and during normal conditions (BACT)

Daily and monthly recordkeeping

CO CEMS Records of hourly fuel usage (type of fuel)

Records of hourly operating load (percent of rated load)

CEM is used to measure CO emissions continuously; therefore, it will provide continuous assurance of compliance. The Permittee will validate the CEM on an annual basis. The Permittee will also use 12-month rolling sum emissions data to calculate the total facility 12-month rolling sum emissions.


EU 001-006 SO2:

• 0.006 lbs/MMBtu heat input using natural gas (BACT)

• 0.05 lbs/MMBtu heat input using fuel oil (BACT)

• 0.015 volume percent or 150 ppmv (NSPS Subpart GG)

• 0.50 lb/MMBtu heat input (Minn. R. 7011.2300)

Fuel Monitoring based on NSPS Subpart GG and Applicable sections Part 75

The Permittee will follow the fuel sulfur monitoring requirements in 40 CFR Sections 60.334 (h) and (i). Section 60.334 (i) refers to applicable sections of Part 75, appendix D for determining fuel oil sulfur content. If the fuel oil sulfur content limit per BACT limit is met, compliance with Minn. Rules limit is ensured.

TF HAPs: ≤ 9.0/24.0 individual/combined tpy based on a 12-month rolling sum from all six turbines combined (limits to avoid NESHAP)

Monthly recordkeeping and calculations

The Permittee is required to calculate monthly 12-month rolling sum of each HAP and total HAP emissions (based on AP-42 factors or developed factors from stack testing) to demonstrate that the source is non-major for HAPs.

EU 001-006 PM/PM10

• 10.0 lbs/hr based on 3-hour rolling average burning natural gas (BACT)

• 26.0 lbs/hr based on a 3-hour rolling average burning fuel oil (BACT)

None PM emissions are negligible with natural gas firing and marginally significant with distillate oil firing because of the low ash content. The dispersion modeling performed showed that at the lowest loads, and highest emission rate of 26.0 lb/hrs, the ambient standard and SILs will not be exceed.

EU 001-006 VOC:

• 4.0 ppmvd based on a 3-hour rolling average while burning fuel oil (BACT)

• 6.00 ppmvd based on a 3-hour rolling average while burning natural gas (BACT)

Performance Test Initial performance test was done to determine VOC emissions while burning natural gas and fuel oil. A frequency plan was submitted by the Permittee to determine further performance test requirements. Based on the MPCA guidance document, the MPCA staff approved the test frequency plan with schedules which were incorporated in this permit.


EU 001-006 Opacity: less than 20% opacity once operating temperature are attained (Minn. R. 7011.2300)

Performance Test Initial performance test was done to determine visible emissions while fuel oil. A frequency plan was submitted by the Permittee to determine further performance test requirement. Based on the MPCA guidance document, the MPCA staff approved the test frequency plan with schedule which was incorporated in this permit.

EU 007 Opacity: less than 20% opacity once operating temperature are attained (Minn. R. 7011.2300)

SO2: 0.50 lb/MMBtu heat input (Minn. R. 7011.2300)

Operating Hours: less than or equal to 1000 hrs/yr based on a 12-month rolling sum (BACT)

Fuel Type: Diesel Fuel

Fuel oil certifications for each shipment and recordkeeping of hours of operating

1 See explanation below.

TK 001 Storage Tank (Minn. R. 7011.1505)

None The storage tank has a potential VOC emission rate of 0.04 lb/hr (0.18 tpy).

1 The Fuel Oil Certification is used as a monitoring requirement in permits to ensure that the sulfur content of distillate fuel oils is less than 0.49 percent by weight. Fuel oil with a sulfur content of less than 0.49 percent by weight will produce emissions of less than 0.50 lb SO2 per MMBtu heat input and will be in compliance with the limit set out in Minn. R. 7011.2300, subp. 2. The MPCA developed the Fuel Oil Certification permit requirement in order to monitor compliance with the sulfur dioxide emission limit. The requirement is modeled after 40 CFR 60 Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Although Subpart Dc does not apply to this facility, the use of a similar, but abbreviated, version of the fuel oil certification meets the requirements of Minn. R. 7007.0800, subps. 4 and 5 to provide for periodic monitoring and recordkeeping for the sulfur emissions limit. The certification with each shipment of distillate fuel oil must include the name of the supplier and the maximum sulfur content of the fuel oil.


3.3 Insignificant Activities

GRE-Lakefield Junction has several operations which are classified as insignificant activities. These are listed in Appendix B to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities.

Table 5. Insignificant Activities

Insignificant Activity

General Applicable Emission limit

Discussion

Fuel use: space heaters fueled by, kerosene, natural gas, or propane

PM < 0.6 or 0.4 lb/MMBtu, depending on year constructed Opacity < 20% with exceptions

(Minn. R. 7011.0510/515)

For this unit, based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement. In addition, these types of units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Brazing, soldering or welding equipment

PM, variable depending on airflow Opacity < 20%

(Minn. R. 7011.0710/715)

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Cleaning operations: Parts washers that use less than 2,000 lbs of solvent per year.

PM, variable depending on airflow Opacity < 20% ( Minn. R. 7011.0710/715)

While no known emissions estimation method exists for these units, based on general knowledge of how they operate, it is highly unlikely that they could generate visible emissions.

Fugitive Emissions from unpaved roads and parking lots

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)

The Facility is located in the rural area and has all paved parking lots and few private roads. Nearly all surfaces are currently paved. The draft/proposed permit does contain a general requirement that this standard must be met.

Fire Pump Diesel Engine; PTE less than 1.0 tpy for all pollutants

SO2 < 0.5 lb/MMBtu

Opacity < 20%

(Minn. R. 7011.2300

This unit was ordered and installed prior to the applicability of NSPS Subpart IIII.

Based on the fuels used and EPA published emissions factors, it is highly unlikely that this unit could violate the limits of the Minnesota Rules.

Fuel Forwarding Fugitive Emissions

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150

While no known emissions estimation method exists for this unit, based on general knowledge of how they operate, it is highly unlikely that they could generate fugitive emissions.


Insignificant Activity

General Applicable Emission limit

Discussion

Compressed infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with maintenance of the building and equipment

PM, variable depending on airflow or process weight rate Opacity < 20%

(Minn. R. 7011.0715)

While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible.


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 Comments Received Public Notice Period: April 23, 2009 – May 22, 2009 EPA 45-day Review Period: April 23, 2009 – June 5, 2009 Comments were not received from the public during the public notice period. Comments were not received from EPA during their review period. 4. Conclusion Based on the information provided by Great River Energy-Lakefield Junction, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 09100058-004, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Amrill Okonkwo (permit writer/engineer) Brent Rohne (enforcement) Marc Severin (stack testing) Marshall Cole (peer reviewer) AQ File No. 138G; DQ 300 Attachments: 1. PTE Summary Calculation Spreadsheets and Emission Summary Tables

2. Facility Description and CD-01 Forms 3. Modeling Summary


ATTACHMENT 1

PTE Summary Calculation Spreadsheets and Emission Summary Tables (Paper Copy Only)


ATTACHMENT 2

Facility Description and CD-01 Forms

(Paper Copy Only)


ATTACHMENT 3

Modeling Summary (Paper Copy Only)

air emission permit no. 09100058-004 is issued to great river energy … · 2012-10-04 · great...

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