AIR EMISSION PERMIT NO IS ISSUED TO. Minnesota Power Division of ALLETE, Inc.

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Minnesota Power Division of ALLETE, Inc. MINNESOTA POWER - LASKIN ENERGY CENTER County Road 633 Aurora, St. Louis County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Issue Date Action Number Total Facility Operating Permit 09/15/ /12/ Major Amendment 12/23/ /05/ Minor Amendment 02/11/ /04/ Total Facility Operating Permit - 11/14/2001 Not Issued 004 Reiss. Major Amendment 04/07/2006 See below 005 This permit authorizes the permittee to operate and modify 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 to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70/Major for NSR Authorization to Construct and Operate (40 CFR 52.21) Issuance Date: August 30, 2006 Authorization to Construct and Operate (40 CFR 52.21) Effective Date: August 30, 2006 Final Permit Issuance Date: September 18, 2006 Expiration: Upon re-issuance of Part 70 permit (Existing Part 70 permit expired 05/12/2002 and re-issuance application was timely) Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Brad Moore Acting Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule - not used in this permit Appendix: Phase II NO X Compliance Plan Phase II NO X Averaging Plan Phase II Permit Application

3 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) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 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 , 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 and , 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. The permit shield, however does not apply to: The state noise pollution control rules at Minn. R. ch

4 FACILITY DESCRIPTION: The Laskin Energy Center is an electric generating facility located near Aurora, Minnesota. This electric power facility contains two identical steam generating boilers, coal receiving, handling, and storage facilities, and ash handling and storage capabilities. The net generating capacity is 110 megawatts (MW) when firing coal alone or coal with waste oil/solvent/natural gas in the boiler ignitors. All operations and equipment within the facility boundary: (1) provide electrical power for onsite and off-site use, (2) provide fuel for electrical power production or support activities, (3) monitor and control air pollutants generated from electrical power production, (4) handle waste material and energy generated by the on-site operations, and (5) provide support activities. ACTION 002 Action 002 was a major amendment that added applicable NO X requirements to the Phase II Acid Rain portion of the Title V operating permit. The requirements state that power boilers 1 and 2 shall limit NO X emissions in a manner consistent with the NO X averaging plan application (see attached). ACTION 003 Action 003 was a minor amendment that allowed the Permittee to replace the 12 existing distillate oil-fired ignitors in Boilers 1 and 2, with 12 new ignitors that can burn distillate oil and natural gas. To accommodate this, natural gas has been added to the list of permitted fuels. ACTION 004 Action 004 was the reissuance of the title V operating permit. Drafting of this reissuance permit commenced during January 2006, but was discontinued when the application for permit action 005 was received. The title V operating permit will be reissued after issuance of permit action 005. ACTION 005 Action 005 is a major amendment authorizing installation of low-nitrogen oxide burners and overfire air controls in each boiler. The modifications will reduce emissions of nitrogen oxides but may be accompanied by a collateral increase in Carbon Monoxide (CO). The permit limits the CO increase to less than the prevention of significant deterioration significant emissions threshold.

5 TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 09/18/06 Facility Name: Permit Number: Minnesota Power - Laskin Energy Center Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take 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 facility requirements. Subject Item: Total Facility What to do DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW These requirements apply where there is a reasonable possibility that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test and found to not be part of a major modification, may result in a significant emissions increase. If the ATPA test is not used for a particular project, or if there is not a reasonable possibility that the proposed project could result in a significant emissions increase, then these requirements do not apply to that project. Even though a particular modification is not subject to New Source Review, a permit amendment, recordkeeping, or notification may still be required under Minn. R Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following information: hdr Why to do it Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R ; Minn. R , subp. 4 & 5 1. A description of the project 2. Identification of the emission unit(s) whose emissions of an NSR pollutant could be affected 3. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the potential emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the unit(s) could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-3 under Preconstruction Documentation, above) to the Agency. For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain: Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R ; Minn. R , subp. 4 & 5 Title I Condition: 40 CFR Section 52.21(r)(6)(ii) and Minn. R ; Minn. R , subp. 4 & 5 Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R ; Minn. R , subp. 4 & 5 a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project and analyzed using potential emissions c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case.

6 TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual plus potential, if applicable) emissions differ from the preconstruction projection and exceed the baseline actual 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 the year in which the exceedances occur. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual plus potential, if any part of the project was analyzed using potential emissions) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. OPERATING REQUIREMENTS Title I Condition: 40 CFR Section 52.21(r)(6) and Minn. R ; Minn. R , subp. 4 & 5 hdr The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Comply with Fugitive Emissions Control Plan: Follow the actions and record keeping specified in the control plan. The plan may be amended with the Commissioner's approval. If the Commissioner determines that you are out of compliance with Minn. R or the control plan, then you may be required to amend the control plan and/or install and operate particulate matter ambient monitors. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit and completion of permit reopening and reissuance. If limits serve to cause more stringent operating conditions, resulting changes to facility operation need to be made immediately. If limits serve to relax current operating conditions, resulting changes to facility operation must not be made prior to issuance of permit amendment with new limit incorporated. Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state requirement only and is not federally enforceable. Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, to enter the Permittee's premises, to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. The Permittee may require that MPCA inspectors be accompanied by MP staff during the inspection. Permittee's staff shall be available whenever the plant is operating. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Combustion Of Oily Cellulose-Based Sorbents (including rags): The permit is permitted to burn oily cellulose-based sorbent and rags in both boilers. The materials must be cellulose-based and are subject to the following limits: 1) 1.25 tons per hour; and 2) 25 tons per year (on a 12-month rolling sum basis). The Permittee shall record the quantity of sorbent materials burned on an hourly and 12-month rolling sum basis. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R , subp. 16 Minn. R Minn. Stat. Section , subd. 4a and Minn. R , subp. 2 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R Minn. R , subp. 9(A) Minn. R Title I Condition: to ensure that the emissions increase from the addition of the fuel type is less than significant as defined by 40 CFR Section and Minn. R Minn. R , subp. 14 and Minn. R , subp. 16(J)

7 TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards at 40 CFR part 50, and the Minnesota Ambient Air Quality Standards at Minn. R to Compliance shall be demonstrated upon written request by the MPCA. PERFORMANCE TESTING REQUIREMENTS Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. 40 CFR pt. 50; Minn. Stat. Section , subds. 4a & 9; Minn. R , subps. 1, 2 & 4; Minn. R hdr Minn. R , subp. 1-4, Minn. R , subp. 1-2, & Minn. R Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. MONITORING REQUIREMENTS Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, such as for system breakdowns, repairs, calibration checks, and zero and span adjustments (as applicable). Monitoring records should reflect any such periods of process shutdown. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Monitoring and Recordkeeping Requirements For Fabric Filters: For all fabric filters controlling emissions from solid fuel handling equipment: Minn. R. ch hdr Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. Stat. Section , subd. 4a; Minn. R , subp Inspect as required by manufacturing specifications, all components that are not subject to wear or plugging, including structural components, housing, ducts, and hoods. 2. Inspect as required by manufacturing specifications, all components that are subject to wear or plugging. Maintain a written record of the inspection and any action resulting from the inspection. 3. Check visible emissions once weekly when the fuel handling equipment is operating. If visible emissions exist, inspect equipment for evidence of malfunction. Record results of the inspection, and any corrective action taken. RECORDKEEPING REQUIREMENTS Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. 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 which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). REPORTING AND SUBMITTAL REQUIREMENTS Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. hdr Minn. R , subp. 5(B) Minn. R , subp. 5(C) hdr Minn. R , subp. 1

8 TABLE A: LIMITS AND OTHER REQUIREMENTS A-4 09/18/06 Facility Name: Permit Number: Minnesota Power - Laskin Energy Center Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. 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 yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. Minn. R , subp. 1 Minn. R , subp. 3 At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Shutdown and Breakdown Reporting Requirement for the Dust Collector Systems for Material Handling Equipment: Minn. R , subp. 2 Minn. R , subp. 2 Shutdowns and breakdowns shall be reported on a quarterly basis to the Agency. The quarterly report shall include an identification of any dust collector that experienced a breakdown and/or shutdown, the time and reason for the breakdown or shutdown, a description of any repairs made, and the date and time the dust collector was placed back in service. Application for Permit Amendment: If you need a permit amendment, submit Minn. R through Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The permittee may apply for an Administrative Amendment to Minn. R , subp. 1(H) extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Emission Fees: due 60 days after receipt of an MPCA bill Minn. R through Minn. R Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit the report on a form approved by the Commissioner. Minn. R through Minn. R

9 TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: Subject Item: Associated Items: GP 001 Boilers CE 004 Low Nox Burners CE 005 Low Nox Burners CE 006 Overfire Air CE 007 Overfire Air EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006 EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007 SV 001 Common Boiler Stack What to do Existing Boiler Modifications: The Permittee is authorized to install low-nox burners (LNB) and overfire air (OFA) systems on each boiler. The Permittee intends to make the modifications during scheduled outages in 2006 and One boiler will be modified during each scheduled outage. Post-LNB & OFA Modification Requirements. The Permittee shall meet either option 1 or option 2: hdr Why to do it Title I Condition: 40 CFR Sections 52.21(b) & 52.21(r)(6) and Minn. R a. Individually validate EU 001 and EU 002 CO emissions are less than or equal to the EU 001 and EU 002 CO lb/mmbtu emission factor, and 1.b. Monitor, record, and report GP 001 emissions as required by 40 CFR Section 52.21(r)(6); OR 2. Meet the GP ton per year (12-month rolling sum basis) CO limit and all associated monitoring, recordkeeping, and reporting requirements in table A of this permit. If either EU 001 or EU 002 CO emission factor testing results in a factor greater than lb/mmbtu, the Permittee shall follow option 2 and associated CO monitoring and recordkeeping requirements in EU 001, EU 002, and GP 001 in table A of this permit. Reverting From Option 2 To Option 1: The Permittee may revert from option 2 to option 1 under the following conditions: Title I Condition: 40 CFR Sections 52.21(b) & 52.21(r)(6) and Minn. R a subsequent CO performance test on the same emission unit that previously tested above lb/mmbtu measures CO emissions no greater than lb/mmbtu; 2. the Permittee continues to follow option I Section 52.21(r)(6) requirements during the five-year period following the resumption of regular operation after completion of modifications of both units, regardless if option 2 applies. If both units previously tested above lb/mmbtu, subsequent CO performance tests must show CO emissions no greater than lb/mmbtu for both units in order to revert to option 1. This permit provision expires 5 years following resumption of regular operations after completion of modifications of both units. Carbon Monoxide: less than or equal to 630 tons/year using 12-month Rolling Sum for both boilers combined. This limit applies at the end of the twelfth month after initial startup of the first modified boiler, if the Permittee elects or is required to meet this limit. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R

10 TABLE A: LIMITS AND OTHER REQUIREMENTS A-6 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: Carbon Monoxide: If the Permittee elects to or is required to meet the GP ton per year CO limit, the following cumulative limit as of month 'n' where n = 1, 2, 3, etc. applies after initial startup of the first modified boiler: Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R Month 1: 100 tons Month 2: 200 tons Month 3: 275 tons Month 4: 350 tons Month 5: 400 tons Month 6: 450 tons Month 7: 490 tons Month 8: 520 tons Month 9: 550 tons Month 10: 580 tons Month 11: 610 tons Month 1 includes the month of initial startup of the first modified boiler. This requirement terminates at the end of the twelfth month following initial startup of the first modified boiler. Carbon Monoxide: less than or equal to 738 tons/year on a calendar year basis for both boilers combined. This limit becomes effective upon initial startup of the first modified boiler. This limit and associated recordkeeping is suspended if post-modification CO emission factor testing of EU 001 and EU 002 demonstrates a CO emission factor less than or equal to lb/mmbtu for each emission unit. This limit is re-instated if a subsequent EU 001 or EU 002 CO emission factor test measures CO in excess of lb/mmbtu. GP 001 CO Emissions Monitoring and Recordkeeping: If the Permittee elects to or is required to meet the 630 ton per year GP 001 CO limit, by the last day of each month the Permittee shall calculate and record: Minn. R , subp. 2 to avoid 100 tpy environmental review potential emission increase threshold Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R monthly GP 001 CO emissions for the previous calendar month by summing the EU 001 CO and EU 002 CO emissions determined according to the requirements listed under EU 001 and EU 002, respectively, from the previous calendar month; 2. GP 001 CO emissions from the previous twelve-month period by summing the monthly GP 001 CO emissions from the previous twelve months. GP 001 CO Emissions Monitoring and Recordkeeping: The Permittee shall calculate and record the GP 001 calendar year CO emissions by January 30 of each year, for the previous calendar year. If either EU 001 or EU 002 CO emission factor testing results in a factor greater than lb/mmbtu, the Permittee may opt to perform additional analyses to demonstrate that the CO emissions performance satisfies Prevention of Significant Deterioration requirements under 40 CFR Section 52.21, and obtain a permit according to 40 CFR Section Minn. R , subp. 4 and 5 to avoid 100 tpy environmental review potential emission increase threshold 40 CFR Section 52.21(a)(2)(iii)

11 TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 09/18/06 Facility Name: Permit Number: Minnesota Power - Laskin Energy Center Subject Item: SV 001 Common Boiler Stack Associated Items: EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006 EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007 GP 001 Boilers MR 001 MR 002 MR 003 MR 004 MR 005 What to do Sulfur Dioxide: less than or equal to 2.04 lbs/million Btu heat input using 1-Hour Average. Why to do it Minn. R , subp. 2 Refer to EU 001 and EU 002 for the SO2 limit applicable to each emission unit. COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to Minn. R , subp. 2 a one-minute averaging period. Opacity averages shall be calculated from all equally spaced consecutive 10-second (or shorter) data points in the one-minute averaging period. COMS Calibration Error Audit: due before end of each calendar half-year following Minn. R , subp. 2 COMS Certification Test. Conduct audits at least 3 months apart but no greater than 8 months apart. COMS Continuous Operation: Except for system breakdowns, repairs, calibration Minn. R , subp. 2 checks, and zero and span adjustments, all COMS shall be in continuous operation. COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recorded Minn. R ; Minn. R , subp. 2 at zero (low-level) and upscale (high-level) opacity at least once daily. The COMS must be adjusted whenever the calibration drift (CD) exceeds twice the specification of PS-1 of 40 CFR 60, Appendix B. Recordkeeping: The owner or operator must retain records of all COMS/CEMS Minn. R , subp. 5 monitoring data and support information for a period of five years from the date of the monitoring sample, measurement, or report. Records shall be kept at the source. CEMS QA/QC The owner or operator of an affected facility shall operate, calibrate, 40 CFR Section and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 75, Appendix B as amended. Daily Calibration Error (CE) Test: conduct daily CE testing on all CEMS required by 40 CFR pt. 75 App B, section 2.1 the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar 40 CFR pt. 75 App B, section 2.3 half-year following CEM Certification Test (or due each year, depending on the results of the previous test). Conduct a RATA on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B. If the RATA results indicate a relative accuracy of 7.5% or less, the next RATA is not required for another year. Linearity and Leak Check Test (Acid Rain Program): due before end of each 40 CFR pt. 75 App B, section 2.2 calendar quarter following CEM Certification Test. Conduct a quarterly linearity test on all CEMS required by the Acid Rain Program, in accordance with 40 CFR pt. 75 App B.

12 TABLE A: LIMITS AND OTHER REQUIREMENTS A-8 09/18/06 Facility Name: Permit Number: Minnesota Power - Laskin Energy Center Subject Item: EU 001 Boiler - Unit #1; CE 001, CE 004, CE 006 Associated Items: CE 004 Low Nox Burners CE 006 Overfire Air GP 001 Boilers SV 001 Common Boiler Stack What to do LIMITS AND OPERATING REQUIREMENTS hdr Why to do it Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour Average period for solid fuels, and 2.0 lb/mmbtu when burning liquid fuels. When fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat input from solid fossil fuels. Refer to SV 001 for additional SO2 limit applicable to the common stack. Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 365-day Rolling Average. If EU 001 is the first boiler modified, this limit applies 270 days after completion of LNB and OFA modifications. If EU 001 is the second boiler modified, this limit applies 60 days after completion of LNB and OFA modifications. Post-LNB and OFA Modification Requirements: The Permittee shall either: Minn. R , subp. 2 Minn. R , subp. 1 Minn. R , subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citiziens under the Clean Air Act Title I Condition: 40 CFR Section 52.21(r)(6) 1.a. Conduct EU 001 CO performance testing to confirm EU 001 CO emissions do not exceed the EU 001 CO lb/mmbtu emission factor, and 1.b. Monitor, record, and report GP 001 emissions as required by 40 CFR Section 52.21(r)(6); OR 2. Conduct EU 001 CO performance testing and meet the GP ton-per-year (12-month rolling sum basis) CO limit if performance testing demonstrates the EU 001 CO factor exceeds lb/mmbtu. Carbon Monoxide: less than or equal to lbs/million Btu heat input (this is an emission factor and not a limit). The Permittee shall validate this factor through performance testing. If performance testing shows a factor greater than lb/mmbtu, the Permittee shall meet the GP tpy limit. Fuel use: limited to sub-bituminous and bituminous coal, distillate oil, natural gas, boiler cleaning agents, non-hazardous petroleum distillate solvents and derived fuels, used oil, oily coal (coal with oil spilled on it), and oily cellulose-based sorbents (including rags). Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, not to exceed 720 gallons per hour and 2,500,000 gallons annually. EU 001 Bituminous Coal Operations: If the Permittee combusts any bituminous coal after EU 001 LNB and OFA modifications, the Permittee shall conduct a post-modification CO performance test while burning bituminous coal. The Permittee may continue burning bituminous coal in EU 001 after completion of testing. EU 001 CO Emissions Indicator: The Permittee shall operate EU 001 so that CO (ppm) measured by the emissions indicator does not exceed a value based on values measured during the most recent MPCA-approved performance stack test for evaluating the EU 001 CO emission factor. ACID RAIN PROGRAM REQUIREMENTS Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. Takes effect for years beginning January 1, Application for NOx limits: Submit a complete permit application and compliance plan for NOx emissions in accordance with 40 CFR Section Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R hdr 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4) 40 CFR Section 76.9(b)(2)

13 TABLE A: LIMITS AND OTHER REQUIREMENTS A-9 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: NOx Averaging Plan 40 CFR Section Beginning January 1, 2000 either: Maintain an annual average NOx emission rate of 0.40 lbs/mmbtu and limit the annual heat input to less than or equal to 3,500,000 mmbtu per year. OR Maintain a Btu-weighted annual average emission rate in lbs/mmbtu, averaged over the units specified in the NOx averaging plan, that is less than or equal to the Btu-weighted annual average emission rate averaged over the same units had they each been operated during the same period of time in compliance with the applicable emission limitations in 40 CFR Sections 76.5, 76.6, or Units covered in the plan are: Plant Boiler ID# Clay Boswell 1, 2, 3, 4 Syl Laskin 1, 2 Taconite Harbor 1, 2, 3 Recordkeeping: Keep on site at the source each of the following documents for a period of 5 years from the date the document is created: The certificate of representation, all emissions monitoring information, copies of all reports, compliance certifications, and other submissions or records made under the Acid Rain Program, copies of all documents used to complete an acid rain permit application. Apply for Acid Rain Program Permit reissuance: The designated representative shall submit a complete Acid Rain permit application for each source with an affected unit at least 6 months prior to the expiration of an existing Acid Rain Permit in accordance with 40 CFR Section 72.30(c). Certify Acid Rain Program Submittals. Each submission under the Acid Rain Program shall be submitted, signed, and certified by the designated representative or the alternate designated representative for all sources on behalf of which the submission is made in accordance with 40 CFR Section Hold allowances as of the allowance transfer deadline, in the unit's compliance subaccount not less than the total annual emissions of sulfur dioxide for the previous calendar year. Takes effect for years beginning January 1, Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. The owner or operator shall measure opacity, and all SO2, NOx, and CO2 emissions for each affected unit in accordance with 40 CFR Section PERFORMANCE TESTING 40 CFR Section 72.9(f)(l) 40 CFR Section 72.30(c) 40 CFR Section CFR Section 72.9(c)(1)(i), 40 CFR Section 72.9(g)(4) 40 CFR Section hdr Initial Performance Test: due 270 days after Initial Startup of EU 001 after completion of LNB and OFA modifications to determine the CO emission factor on a lb/mmbtu basis, if EU 001 is the first boiler modified. If EU 001 is the second boiler modified, the initial performance test shall be completed within 60 days after initial startup after the modification. Separate tests shall be conducted for sub-bituminous coal and bituminous coal. The Permittee may avoid EU 001 bituminous coal testing if the Permittee does not burn any bituminous coal in EU 001 after LNB and OFA modifications. Performance Test: due before end of each 60 months following Initial Performance Test to determine compliance with the particulate matter emissions limit in Minn. R subp 1. The tests shall be conducted at an interval not to exceed 60 months between test dates. Boiler Alternative Operating Conditions for Performance Testing: Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R ; Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 2.A. and 3.B. Alternative Operating Conditions during testing are defined as 90% to 100% of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing. In no case will the new operating rate limit be higher than allowed by an existing permit condition.

14 TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing: Minn. R , subp. 3.B. If performance testing is not conducted at or above the established alternative operating condition, then the boiler operating rate will be limited on an 8-hour block average based on the following: (1) If the results of the performance test are greater than 80% of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate. (2) If results are less than or equal to 80% of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to the tested operating rate. In no case will the new operating rate limit be higher than allowed by an existing permit condition. STET (Short Term Emergency and Testing) Operating hours limit: The boiler may operate up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. Maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. STET Operation Definition that applies to Boilers that Meet or do Not Meet the Alternative Operating Condition for Performance Testing: Minn. R , subp. 2 Minn. R , subp. 2 If performance test results demonstrate compliance at 80% or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110% of the average operating rate achieved during that performance test. If performance test results demonstrate compliance at greater than 80% of any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100% of the average operating rate achieved during that performance test. In no case will STET operation be higher than allowed by an existing permit condition. The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R MONITORING AND RECORDKEEPING Recordkeeping: maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. Excess emissions and monitoring system performance reports shall include the information required in 40 CFR Section 60.7(c) and (d). MPCA supplied forms DRF-1 and DRF-2 may be used to meet this requirement. EU 001 CO Emissions Indicator Monitoring and Recordkeeping: The Permittee shall install, operate, and maintain a process CO monitor (ppm monitor primarily for the boiler operator) upstream of the EU 001 air heater, and record the indicator measurements. The monitoring and recordkeeping equipment shall be operated and maintained at all times during EU 001 operation. Minn. R , subp. 4 hdr Minn. R , supb. 2 Minn. R , subp. 2 Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R CO concentration will not exceed a value based on values recorded during the most recent MPCA-approved performance test. The measurement frequency and averaging period associated with this emissions indicator will be derived by the Permittee through analysis of the correlation between indicator readings and the first performance test results. The results of the analysis will be summarized in a CO monitoring plan to be submitted to the Agency for approval within 120 days after the first performance test.

15 TABLE A: LIMITS AND OTHER REQUIREMENTS A-11 09/18/06 Facility Name: Minnesota Power - Laskin Energy Center Permit Number: EU 001 CO Emissions Monitoring and Recordkeeping: If the Permittee elects or is required to meet the 630 tpy (on a 12-month rolling sum basis) limit in GP 001, by the last day of each month commencing with the month of initial startup of the first boiler after LNB and OFA modifications are completed, the Permittee shall: Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R calculate and record EU 001 monthly fuel usage of bituminous and sub-bituminous coal; 2. calculate and record monthly EU 001 CO emissions using the following equation: EU 001 CO = (FU * HC * EF)/2000 where: EU 001 CO = monthly EU 001 CO emissions for each coal type (tons) FU = EU 001 monthly fuel consumption for each coal type (tons) HC = fuel heat content for each coal type (mmbtu/ton) EF = current EU 001 CO emission factor for each coal type (lb/mmbtu) If EU 001 is the second boiler modified, the CO factor prior to modification shall be lb/mmbtu. (continued below) EU 001 CO Emissions Monitoring and Recordkeeping (continued from above) If EU 001 is the first boiler to be modified, the Permittee shall use lb/ mmbtu for the CO emission factor until receipt of written MPCA approval of the EU 001 CO emission factor evaluation stack test results. After receipt of approval, the Permittee shall use the CO factor determined during EU 001 testing. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R If EU 001 is the second boiler to be modified, the Permittee shall use the MPCA-approved EU 002 CO emissions factor, if available, until EU 001 testing is completed and written approval is received from the MPCA to use the EU 001 CO factor determined during EU 001 testing. If the EU 002 factor is not available and/or was not approved, the Permittee shall use the default lb/mmbtu CO factor until receipt of written MPCA approval of EU 001 CO emission factor testing results. EU 001 Bituminous Coal CO Monitoring: If the Permittee combusts bituminous coal after LNB and OFA modifications, the Permittee shall calculate bituminous coal CO emissions using the EU 001 subbituminous coal CO emission factor until receipt of written MPCA confirmation of the EU 001 bituminous coal CO test results. Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R After receipt of written MPCA confirmation of the EU 001 bituminous coal CO test results, the Permittee shall determine EU 001 bituminous coal CO emissions using the approved EU 001 bituminous coal emission factor. The Permittee shall also recalculate EU 001 bituminous coal CO emissions that were initially determined using the subbituminous coal CO emission factor, using the approved EU 001 bituminous coal emission factor.

16 TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 09/18/06 Facility Name: Permit Number: Minnesota Power - Laskin Energy Center Subject Item: EU 002 Boiler - Unit #2; CE 002, CE 005, CE 007 Associated Items: CE 005 Low Nox Burners CE 007 Overfire Air GP 001 Boilers SV 001 Common Boiler Stack What to do LIMITS AND OPERATING REQUIREMENTS hdr Why to do it Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity using 6-minute Average except for one six-minute period per hour of not more than 60 percent opacity. Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input using 1-Hour Average period for solid fuels, and 2.0 lb/mmbtu when burning liquid fuels. When fossil fuels are burned simultaneously in any combination, the applicable standard shall be determined by proration using the following formula: w=[2y+4z]/(y+z) where y is the % heat input from liquid fossil fuel and z is the % heat input from solid fossil fuels. Refer to SV 001 for additional SO2 limit applicable to the common stack. Nitrogen Oxides: less than or equal to 0.20 lbs/million Btu heat input using 365-day Rolling Average. If EU 002 is the first boiler modified, this limit applies 270 days after completion of LNB and OFA modifications. If EU 002 is the second boiler modified, this limit applies 60 days after completion of LNB and OFA modifications. Post-LNB and OFA Modification Requirements: The Permittee shall either: Minn. R , subp. 2 Minn. R , subp. 1 Minn. R , subp. 2; this is a state-only requirement not enforceable by the EPA administrator or citiziens under the Clean Air Act Title I Condition: 40 CFR Section 52.21(r)(6) 1.a. Conduct EU 002 CO performance testing to confirm EU 002 CO emissions do not exceed the EU 002 CO lb/mmbtu emission factor, and 1.b. Monitor, record, and report GP 001 emissions as required by 40 CFR Section 52.21(r)(6); OR 2. Conduct EU 002 CO performance testing and meet the GP ton-per-year (12-month rolling sum basis) CO limit if performance testing demonstrates the EU 002 CO factor exceeds lb/mmbtu. Carbon Monoxide: less than or equal to lbs/million Btu heat input (this is an emission factor and not a limit). The Permittee shall validate this factor through performance testing. If performance testing shows a factor greater than lb/mmbtu, the Permittee shall meet the GP tpy limit. Fuel use: limited to sub-bituminous and bituminous coal, distillate oil, natural gas, boiler cleaning agents, non-hazardous petroleum distillate solvents and derived fuels, used oil, oily coal (coal with oil spilled on it), and oily cellulose-based sorbents (including rags). Boiler cleaning agents limited to: EDTA type and Ammonium Bromate, are generated on-site, 5% of total fuel mass, oxygen limited to 3% or greater, agents may only be burned while the boiler is operating at 75 percent of rated capacity or greater. Burn off-specification and on-specification used oil in accordance with Minn. R. ch. 7045, not to exceed 720 gallons per hour and 2,500,000 gallons annually. EU 002 Bituminous Coal Operations: If the Permittee combusts any bituminous coal after EU 002 LNB and OFA modifications, the Permittee shall conduct a post-modification CO performance test while burning bituminous coal. The Permittee may continue burning bituminous coal in EU 002 after completion of testing. EU 002 CO Emissions Indicator: The Permittee shall operate EU 002 so that CO (ppm) measured by the emissions indicator does not exceed a value based on values measured during the most recent MPCA-approved performance stack test for evaluating the EU 002 CO emission factor. ACID RAIN PROGRAM REQUIREMENTS Comply with the applicable Acid Rain emissions limitation for sulfur dioxide. Takes effect for years beginning January 1, Application for NOx limits: Submit a complete permit application and compliance plan for NOx emissions in accordance with 40 CFR Section Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R Title I Condition: To avoid major modification under 40 CFR Section 52.21(b) and Minn. R hdr 40 CFR Section 72.9(c)(1)(ii), 40 CFR Section 72.9(g)(4) 40 CFR Section 76.9(b)(2)