Draft Air Individual Permit Major Amendment Brooks Ave South Thief River Falls, MN Pennington County

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1 Draft Air Individual Permit Major Amendment Permittee: Facility name: Digi-Key Corp Digi-Key Corp 701 Brooks Ave South Thief River Falls, MN Pennington County Operating permit issuance date: February 12, 2014 Expiration date: Expiration date: Non-expiring Permit - All Title I Conditions do not expire Major Amendment: [Amendment Issue Date] Permit characteristics: State; Limits to avoid Part 70/ Limits to avoid NSR; Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the submittals listed in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No and authorizes the Permittee to operate and construct the stationary source at the address listed above unless otherwise noted in the permit. 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. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such are enforceable by the U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: [ ] for This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B. NESHAP ZZZZ Compliance Determination with the Percent Reduction Requirement Appendix C. Design Parameters Appendix D. Natural-Gas-Fired Air Handling Units Collectively Represented As EQUI Appendix E. 40 CFR 60 Subpart A General Provisions Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Major Amendment 03/13/2018, with supplemental information received on 05/30/ State Operating Permit 04/05/

4 Permit issued: [month day, year] Permit expires: [month day, year] Page 4 of Where to send submittals Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be 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 Send any application for a permit or permit amendment to: Fiscal Services 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term 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 Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The Digi-Key Corp (Facility) is located at 701 Brooks Ave S in Thief River Falls, Pennington County, Minnesota. The permittee is a distributor of electronic parts. Digi-Key currently has three diesel-fired engines and numerous small natural-gas-fired air handling units. The main pollutants from this facility are nitrogen oxides (NOx) and carbon monoxide (CO). This permit action is a Major Amendment to Digi-Key's State Operating Permit. This permit authorizes Digi-Key to construct and operate eight diesel-fired emergency engines, one fire pump engine, and ninety-nine natural-gas-fired air handling units to a set of new buildings at its facility.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description TFAC 1: Digi-Key Corp ACTV 3: All IAs COMG 4: COMG 4 EQUI 1: Generator 1: CI 805 Hp EQUI 1: Generator 1: CI 805 Hp EQUI 1: Generator 1: CI 805 Hp EQUI 1: Generator 1: CI 805 Hp EQUI 1: Generator 1: CI 805 Hp EQUI 1: Generator 1: CI 805 Hp EQUI 2: Generator 2: CI 1676 Hp EQUI 2: Generator 2: CI 1676 Hp EQUI 2: Generator 2: CI 1676 Hp EQUI 2: Generator 2: CI 1676 Hp EQUI 2: Generator 2: CI 1676 Hp EQUI 2: Generator 2: CI 1676 Hp Relationshi p Type has members is monitored by is monitored by is monitored by is monitored by Related SI ID: Description EQUI 1, EQUI 2, EQUI 3, EQUI 7, EQUI 8, EQUI 9, EQUI 10, EQUI 11, EQUI 12, EQUI 13, EQUI 14, EQUI 15, EQUI 16, EQUI 17, EQUI 18 EQUI 19: Pressure Drop for EQUI 1 EQUI 21: Temperature for EQUI 1 EQUI 25: Pressure Drop for EQUI 1 EQUI 27: Temperature for EQUI 1 sends to STRU 1: Generator 1 Stack is controlled by is monitored by is monitored by is monitored by is monitored by TREA 3: Catalytic Converter EQUI 20: Pressure Drop for EQUI 2 EQUI 22: Temperature for EQUI 1 EQUI 26: Pressure Drop for EQUI 2 EQUI 28: Temperature For EQUI 2 sends to STRU 2: Generator 2 Stack is controlled by TREA 4: Catalytic Converter SI ID: Description Relationshi p Type Related SI ID: Description EQUI 3: Generator 3: CI 2514 Hp Emergency sends to STRU 3: Generator 3 Stack EQUI 7: Data Center 1 sends to STRU 5: Data Center 1 EQUI 8: Data Center 2 sends to STRU 6: Data Center 2 EQUI 9: West Service sends to STRU 7: West Gen EQUI 10: East Service 1 sends to STRU 8: East Gen 1 EQUI 11: East Service 2 sends to STRU 9: East Gen 2 EQUI 12: Middle Service 1 sends to STRU 10: Middle Gen 1 EQUI 13: Middle Service 2 sends to STRU 11: Middle Gen 2 EQUI 14: Middle Service Backup sends to STRU 12: Spare/Middle Gen EQUI 15: Fire Pump sends to STRU 13: Fire Pump EQUI 16: ARU-1 sends to STRU 14: ARU- 1 EQUI 17: ARU-8 sends to STRU 15: ARU- 8 EQUI 18: Natural gas fired air handling units EQUI 19: Pressure Drop for EQUI 1 sends to EQUI 23: DAS for EQUI 1 EQUI 20: Pressure Drop for EQUI 2 sends to EQUI 24: DAS for EQUI 2 EQUI 21: Temperature for EQUI 1 sends to EQUI 23: DAS for EQUI 1 EQUI 22: Temperature for EQUI 1 sends to EQUI 24: DAS for EQUI 2 EQUI 23: DAS for EQUI 1 EQUI 24: DAS for EQUI 2 EQUI 25: Pressure Drop for EQUI 1 sends to EQUI 23: DAS for EQUI 1 EQUI 26: Pressure Drop for EQUI 2 sends to EQUI 24: DAS for EQUI 2 EQUI 27: Temperature sends to EQUI 23: DAS for EQUI 1 EQUI 28: Temperature For EQUI 2 STRU 1: Generator 1 Stack sends to for EQUI 1 EQUI 24: DAS for EQUI 2

7 Permit Expires: [month day, year] Page 7 of 192 SI ID: Description STRU 2: Generator 2 Stack STRU 3: Generator 3 Stack STRU 5: Data Center 1 STRU 6: Data Center 2 STRU 7: West Gen STRU 8: East Gen 1 STRU 9: East Gen 2 STRU 10: Middle Gen 1 STRU 11: Middle Gen 2 STRU 12: Spare/Middle Gen STRU 13: Fire Pump STRU 14: ARU-1 STRU 15: ARU-8 STRU 16: Administration Relationshi p Type Related SI ID: Description SI ID: Description Building (Building 1) STRU 17: East Warehouse (Building 2) STRU 18: West Warehouse (Building 3) STRU 19: Maintenance Building (Building 5) STRU 20: Bldg. 4 STRU 21: High Performance Building (Building 6, has two tiers lxwxh Tier 1: 150x60x12; Tier 2 125x60x18) TREA 3: Catalytic Converter TREA 4: Catalytic Converter Relationshi p Type Related SI ID: Description

8 Permit Expires: [month day, year] Page 8 of Limits and other requirements Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Digi-Key Corp Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices: A: Insignificant Activities and General Applicable Requirements; B: NESHAP ZZZZ Compliance Determination with Percent Reduction Requirement; C: Design Parameters; D: Natural-Gas-Fired Air Handling Units Collectively Represented As EQUI 18; and E: 40 CFR 60 Subpart A -- General Provisions. [Minn. R , subp. 2] 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. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R , (A)(2)] 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. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] 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. 14, Minn. R , subp. 16(J)]

9 Permit Expires: [month day, year] Page 9 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] 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 [Minn. R ] 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 only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in this permit. [Minn. R. ch. 7017] Performance Test Notifications and Submittals: Performance Test Notification and 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 The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R , Minn. R , subps. 1-4, Minn. R , subps. 1-2] Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 3] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's

10 Permit Expires: [month day, year] Page 10 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original 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). [Minn. R , subp. 5(C)] 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. [Minn. R , subp. 5(B)] If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R These records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R , subp. 4] 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. At the time of notification, the owner or operator shall inform the

11 Permit Expires: [month day, year] Page 11 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R , subp. 3] 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. [Minn. R , subp. 2] 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. [Minn. R , subp. 1] 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. [Minn. R , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. [Minn. R , subp. 3, Minn. R ] Extension Requests: The Permittee may apply for an Administrative Amendment to 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). Performance

12 Permit Expires: [month day, year] Page 12 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate Subject Item numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R , subp. 2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units, stack/vents, group information, and the emission source associations on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the Subject Item numbers used in this permit and shall include the data on GI-04, GI-05B, GI-05E, and GI-05F. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] The Permittee shall not have engines that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as the engine it replaced will be included in calculating the consecutive time period. [40 CFR ] For a nonroad engine that is excluded from any requirements of 40

13 Permit Expires: [month day, year] Page 13 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part The Permittee may not circumvent or attempt to circumvent the residence-time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section [40 CFR (b)(3)] The Permittee shall conduct an inventory of all engines on-site that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section , once each calendar quarter; inventories shall not take place in consecutive months. This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite and operated by a vendor or contractor. The inventory shall include the following: 1) Date that the nonroad engine is inventoried. 2) Identification number. 3) Function of the nonroad engine (e.g. compressor, welder). 4) Location of the engine within the stationary source. 5) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section As of the issuance date of this permit, the permittee has one nonroad engine with a rated mechanical output of 2206 horsepower. [40 CFR (nonrd engn)(1)(iii), Minn. R , subps. 4-5] A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if: 1. At any time, it meets the criteria specified in section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroad engine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). [40 CFR (e)] COMG 4 COMG The Permittee shall limit emissions of Nitrogen Oxides <= 90 tons per year 12-month rolling sum. If the Permittee replaces any existing COMG 4 unit, modifies any existing COMG 4 unit, adds any new diesel-fired emergency engine, or adds any new natural-gasfired air handling unit, such equipment is subject to this permit limit as well as all of the requirements of COMG 4 and any other applicable requirements contained elsewhere in this permit. Prior

14 Permit Expires: [month day, year] Page 14 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete NOx calculations described in Minn. R , subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. For the purposes of this permit, "natural-gas-fired air handling unit" means heating, ventilation, and/or air conditioning equipment that is designed to be fueled by natural gas only. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ] The Permittee shall limit emissions of Carbon Monoxide <= 90 tons per year 12-month rolling sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. If the Permittee replaces any existing COMG 4 unit, modifies any existing COMG 4 unit, adds any new diesel-fired emergency engine, or adds any new natural-gas-fired air handling unit, such equipment is subject to this permit limit as well as all of the requirements of COMG 4 and any other applicable requirements contained elsewhere in this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. The Permittee is not required to complete CO calculations described in Minn. R , subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. For the purposes of this permit, "natural-gas-fired air handling unit" means heating, ventilation, and/or air conditioning equipment that is designed to be fueled by natural gas only. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ] Daily Recordkeeping. On each day of operation, the Permittee shall record, and maintain the number of operating hours for each engine in COMG 4. This shall be based on a non-resettable hour meter. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ]

15 Permit Expires: [month day, year] Page 15 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total number of operating hours for the previous calendar month for each engine in COMG 4, using the daily records each engine's operating hours as a basis; 2) The quantity of natural gas combusted at the facility. This shall be based on monthly bills from the permittee's natural gas supplier; 3) The Nitrogen Oxides emissions for the previous month using the formula specified in COMG 4 of this permit; 4) The 12-month rolling sum of Nitrogen Oxides emissions for the previous 12-month period by summing the monthly Nitrogen Oxides emissions data for the previous 12 months; 5) The Carbon Monoxide emissions for the previous month using the formulas specified in COMG 4 of this permit; and 6) The 12-month rolling sum of Carbon Monoxide emissions for the previous 12 months. [Minn. R , subps. 4-5] Nitrogen Oxides: Monthly Calculation. The Permittee shall calculate Nitrogen Oxides emissions from the COMG4 equipment using the following equations: NOx (tons/month) = (Engine NOx + NG NOx) x (1/2000) Engine NOx = (A x Bi x Ci) + (ER1 x Q1) + (ER2 x Q2) +... NG NOx = EFNG x QNG Where: Engine NOx is the total NOx emitted from engines in tons/month NG NOx is the total NOx emitted from natural-gas-fired air handling units in tons/month 1/2000 = conversion factor, lb to ton A = lb NOx/hp-hr Bi = summation of the number of hours of operation for the previous calendar month, for the engine i Ci = maximum rated output of engine i in horsepower i = an index for each engine that has been added under the precap at COMG4 after the issuance date of permit Q# = number of hours of operation of engine EQUI # in the previous month ER# is the emission rate in lb/hr from engine EQUI # ER1 = lb NOx/hr ER2 = lb NOx/hr ER3 = lb NOx/hr ER7 = lb NOx/hr ER8 = lb NOx/hr ER9 = lb NOx/hr ER10 = lb NOx/hr ER11 = lb NOx/hr ER12 = lb NOx/hr ER13 = lb NOx/hr ER14 = lb NOx/hr

16 Permit Expires: [month day, year] Page 16 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation ER15 = 3.05 lb NOx/hr EFNG = 100 lb NOx/mmscf QNG = amount of natural gas combusted in the previous month in mmscf. [Minn. R , subps. 4-5] Carbon Monoxide: Monthly Calculation. The Permittee shall calculate Carbon Monoxide emissions from the COMG4 equipment using the following equations: CO (tons/month) = (Engine CO + NG CO) x (1/2000) Engine CO = (A x Bi x Ci) + (ER1 x Q1) + (ER2 x Q2) +... NG CO = EFNG x QNG Where: Engine CO is the total CO emitted from engines in tons/month NG CO is the total CO emitted from natural-gas-fired air handling units in tons/month 1/2000 = conversion factor, lb to ton A = lb CO/hp-hr Bi = summation of the number of hours of operation for the previous calendar month, for the engine i Ci = maximum rated output of engine i in horsepower i = an index for each engine that has been added under the precap at COMG4 after the issuance date of permit Q# = number of hours of operation of engine EQUI # in the previous month ER# is the emission rate in lb/hr from engine EQUI # ER1 = 4.43 lb CO/hr ER2 = 4.77 lb CO/hr ER3 = lb CO/hr ER7 = 0.42 lb CO/hr ER8 = 0.42 lb CO/hr ER9 = 1.94 lb CO/hr ER10 = 2.40 lb CO/hr ER11 = 2.40 lb CO/hr ER12 = 2.40 lb CO/hr ER13 = 2.40 lb CO/hr ER14 = 2.40 lb CO/hr ER15 = 0.46 lb CO/hr EFNG = 84 lb CO/mmscf QNG = amount of natural gas combusted in the previous month in mmscf. [Minn. R , subps. 4-5] EQUI 1 EU001 Generator 1: CI 805 Hp Sulfur Dioxide <= pounds per million Btu heat input The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. [Minn. R , subp. 2(B)]

17 Permit Expires: [month day, year] Page 17 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Carbon Monoxide <= 23 parts per million, volumetric dry at 15 percent oxygen; or reduce CO emissions by 70 percent or more. [40 CFR (a), 40 CFR pt. 63, Subp. ZZZZ(Table 2d), Minn. R ] Pressure Drop <= 2 inches of water column change (i.e. plus or minus 2 inches of water column change) from the pressure drop across the catalyst that was measured during the initial performance test. [40 CFR (a)(Table 2b), Minn. R ] Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Fuel type: Diesel fuel meeting the requirements of 40 CFR Section (c) only by design. [Minn. R , subp. 35a] Temperature >= 450 and <= 1350 degrees Fahrenheit. [40 CFR (a), 40 CFR pt. 63, Subp. ZZZZ(Table 2b), Minn. R ] Diesel Fuel Use: the Permittee shall use diesel fuel that meets the requirements of 40 CFR (b) for nonroad diesel fuel. [40 CFR (a), Minn. R ] The Permittee shall install a closed crankcase ventilation system that prevents crankcase emissions from being emitted to the atmosphere, or install an open crankcase filtration emission control system that reduces emissions from the crankcase by filtering the exhaust stream to remove oil mist, particulates, and metals. The Permittee shall follow the manufacturer's specified maintenance requirements for operating and maintaining the open or closed crankcase ventilation systems and replacing the crankcase filters, or can request to the Administrator to approve different maintenance requirements that are as protective as manufacturer requirements. [40 CFR (g), Minn. R ] At all times, the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR (b), Minn. R ] The Permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. After which time the emissions standards applicable to all times other than startup in Table 2d of 40 CFR pt. 63, subp. ZZZZ

18 Permit Expires: [month day, year] Page 18 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation apply. [40 CFR (h), Minn. R ] Compliance with the numerical emission limitations established in 40 CFR pt. 63, subp. ZZZZ is based on the results of testing the average of three 1-hour runs using the testing requirements and procedures in 40 CFR Section and 40 CFR pt. 63, subp. ZZZZ, Table 4. [40 CFR , 40 CFR , 40 CFR pt. 63, Subp. ZZZZ(Table 4), Minn. R ] The Permittee shall conduct each performance test in Table 4 of 40 CFR pt. 63, subp. ZZZZ that applies. Each performance test shall be conducted according to the requirements specified in 40 CFR pt. 63, subp. ZZZZ, Table 4. The Permittee shall conduct three separate test runs for each performance test required by 40 CFR Section , as specified in 40 CFR Section 63.7(e)(3). Each test run shall last at least 1 hour. [40 CFR (a),(b),&(d), 40 CFR pt. 63, Subp. ZZZZ(Table 3)(Table 4), Minn. R ] The Permittee shall be in compliance with the emission limitations and operating limitations in this subpart that apply at all times. [40 CFR (a), Minn. R ] Performance Testing Quality assurance program and Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Administrator, shall submit a site-specific test plan to the Administrator for approval. The test plan shall include a test program summary, the test schedule, data quality objectives, and both an internal and external quality assurance (QA) program. Data quality objectives are the pretest expectations of precision, accuracy, and completeness of data. [40 CFR (a), 40 CFR , 40 CFR 63.7(c), Minn. R , Minn. R , subp. 3(A)] The engine percent load during a performance test shall be determined by documenting the calculations, assumptions, and measurement devices used to measure or estimate the percent load in a specific application. A written report of the average percent load determination shall be included in the notification of compliance status. The following information shall be included in the written report: the engine model number, the engine manufacturer, the year of purchase, the manufacturer's site-rated brake horsepower, the ambient temperature, pressure, and humidity during the performance test, and all assumptions that were made to estimate or calculate percent load during the performance test shall be clearly explained. If measurement devices such as flow meters, kilowatt meters, beta analyzers, stain gauges, etc. are used, the model number of the measurement device and an estimate of its accuracy in percentage of true value shall be provided. [40 CFR (i), Minn. R ] EQUI 1 is defined as existing, non-emergency, not-limited-use, non-

19 Permit Expires: [month day, year] Page 19 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation black start, CI stationary RICE greater than 500 hp located at an area source of HAPs. [40 CFR (a),(c),&(d), 40 CFR , Minn. R ] (a) The Permittee shall demonstrate initial compliance with each emission and operating limitation that applies according to 40 CFR pt. 63, subp. ZZZZ, Table 5. (b) During the initial performance test, the Permittee shall establish each operating limitation in Table 2b of 40 CFR pt. 63, subp. ZZZZ that applies. (c) The Permittee shall submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements of 40 CFR Section [40 CFR (a)(b) and (c), Minn. R ] The Permittee shall install, operate, and maintain a CPMS to monitor the temperature at the catalyst inlet according to the requirements in 40 CFR Section (b)(1) through (b)(6). (1) The Permittee shall prepare a site-specific monitoring plan that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in 40 CFR Section (b)(1)(i)-(v) and in 40 CFR Section 63.8(d). The Permittee may request approval of monitoring system quality assurance and quality control procedures alternative to those specified in 40 CFR Section (b)(1)-(5) the site-specific monitoring plan. (i) The performance criteria and design specifications for the monitoring system equipment, including the sample interface, detector signal analyzer, and data acquisition and calculations; (ii) Sampling interface (e.g., thermocouple) location such that the monitoring system will provide representative measurements; (iii) Equipment performance evaluations, system accuracy audits, or other audit procedures; (iv) Ongoing operation and maintenance procedures in accordance with provisions in 40 CFR Section 63.8(c)(1)(ii) and (c)(3); and (v) Ongoing reporting and recordkeeping procedures in accordance with provisions in 40 CFR Section 63.10(c), (e)(1), and (e)(2)(i). (2) The Permittee must install, operate, and maintain each CPMS in continuous operation according to the procedures in the sitespecific monitoring plan. (3) The CPMS must collect data at least once every 15 minutes. (4) For a CPMS for measure temperature range, the temperature sensor must have a minimum tolerance of 2.8 degrees Celsius (5 degrees Fahrenheit) or 1 percent of the measurement range, whichever is larger. (5) The Permittee must conduct the CPMS equipment performance evaluation, system accuracy audits, or other audit procedures specified in the site-specific monitoring plan at least annually. (6) The Permittee must conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. [40 CFR (b), 40 CFR pt. 63, subp. ZZZZ(Table 5), Minn. R ]

20 Permit Expires: [month day, year] Page 20 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Daily Recordkeeping: The Permittee shall install and maintain a nonresettable hour meter no later than 180 days after Permit Issuance if one is not already installed. [Minn. R , subps. 4-5] Monthly Recordkeeping: The Permittee shall maintain monthly records of hours of operation of EQUI 1, and calculate a running calendar year total on a monthly basis. [Minn. R , subps. 4-5] The Permittee shall determine compliance with the percent reduction requirement according to the procedures in 40 CFR Section (e)(1) as described in Appendix B of this permit. The Permittee shall normalize the carbon monoxide concentrations at the inlet and outlet of the control device to a dry basis and to 15 percent oxygen, or an equivalent percent carbon dioxide. If pollutant concentrations are to be corrected to 15 percent oxygen and carbon dioxide concentration is measured in lieu of oxygen concentration measurement, a carbon dioxide correction factor is needed. The Permittee shall calculate the carbon dioxide correction factor as described in paragraphs (e)(2)(i) through (iii) of 40 CFR Section and in Appendix B. [40 CFR (e), Minn. R ] The Permittee shall demonstrate initial compliance with the requirements of 40 CFR pt. 63, subp. ZZZZ by: (i) determining that the average reduction of emissions of CO from the initial performance test achieves the required CO percent reduction, or that the average CO concentration determined from the initial performance test is less than or equal to the CO emission limitation; and (ii) installing a CPMS to continuously monitor catalyst inlet temperature according to the requirements in (b); and (ii) recording the catalyst pressure drop and catalyst inlet temperature during the initial performance test. [40 CFR (a), 40 CFR (a), 40 CFR pt. 63, subp. ZZZZ(Table 5), Minn. R ] (a) The Permittee shall monitor and collect data according to the requirements of 40 CFR Section (b) Except for monitor malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall monitor continuously at all times that the stationary RICE is operating. (c) The Permittee may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. The Permittee shall use all the valid data collected during all other periods. [40 CFR , Minn. R ] The Semiannual Compliance Report shall contain the information in paragraphs (c)(1) through (c)(6) of 40 CFR Section [40 CFR

21 Permit Expires: [month day, year] Page 21 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation (c), Minn. R ] The Permittee shall demonstrate continuous compliance with each emission limitation and operating limitation in Tables 2b and 2d of 40 CFR pt. 63, subp. ZZZZ that apply by: (i) conducting performance tests every 8,760 hours of operation or 3 years, whichever comes first, for CO, to demonstrate that the required CO percent reduction is achieved or that emissions remain at or below the CO concentration limit; and (ii) collecting the catalyst inlet temperature data according to 40 CFR Section (b); and (iii) reducing these data to 4-hour rolling averages; and (iv) maintaining the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (v) measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop across the catalyst is within the operating limitation established during the performance test. [40 CFR (a), 40 CFR pt. 63, subp. ZZZZ(Table 6), Minn. R ] The Permittee shall maintain the following records: 1. A copy of each notification and report submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted, according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section (b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR (a), Minn. R ] The Permittee shall maintain the following records: 1. Records described in 40 CFR Section 63.10(b)(2)(vi)-(xi). 2. Previous (i.e. superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3). 3. Requests for alternatives to the relative accuracy test for CPMS as required in 40 CFR Section 63.8(f)(6)(i). [40 CFR (b), Minn. R ] The Permittee shall keep the records required in Table 6 of 40 CFR pt. 63, subp. ZZZZ, to show continuous compliance with each emission or operating limitation that applies. [40 CFR (d), Minn. R ] The Permittee shall maintain all records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1).

22 Permit Expires: [month day, year] Page 22 of 192 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR section 63.10(b)(1). [40 CFR 63.10(b)(1), 40 CFR , Minn. R , Minn. R , subp. 2(B)] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of diesel fuel oil, certifying that the sulfur content does not exceed percent by weight. [Minn. R , subps. 4-5] For each deviation from an emission or operating limitation that occurs, the Semiannual Compliance report shall contain the information in paragraphs (c)(1)-(c)(4) and (e)(1)-(e)(12) of 40 CFR Section [40 CFR (e), Minn. R ] EQUI 2 EU002 Generator 2: CI 1676 Hp Sulfur Dioxide <= pounds per million Btu heat input The potential to emit from the unit is lb/mmbtu due to equipment design and allowable fuels. [Minn. R , subp. 2(B)] Carbon Monoxide <= 23 parts per million, volumetric dry at 15 percent oxygen; or reduce CO emissions by 70 percent or more. [40 CFR (a), 40 CFR pt. 63, Subp. ZZZZ(Table 2d), Minn. R ] Temperature >= 450 and <= 1350 degrees Fahrenheit. [40 CFR (a), 40 CFR pt. 63, Subp. ZZZZ(Table 2b), Minn. R ] Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Pressure Drop <= 2.0 inches of water column change (i.e. plus or minus 2 inches of water column change) from the pressure drop across the catalyst that was measured during the initial performance test. [40 CFR (a)(Table 2b), Minn. R ] Fuel type: Diesel fuel meeting the requirements of 40 CFR Section (c) only by design. [Minn. R , subp. 35a] Diesel Fuel Use: the Permittee shall use diesel fuel that meets the requirements of 40 CFR (b) for nonroad diesel fuel. [40 CFR (a), Minn. R ] The Permittee shall install a closed crankcase ventilation system that prevents crankcase emissions from being emitted to the

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