AIR EMISSION PERMIT NO IS ISSUED TO. St Cloud State University 720 South Fourth Avenue St Cloud, Stearns County, Minnesota 56301

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1 AIR EMISSION PERMIT NO IS ISSUED TO St Cloud State University 720 South Fourth Avenue St Cloud, Stearns County, Minnesota 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 Total Facility Operating Permit March 11, 1996 This permit authorizes the permittee to 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 as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70 Issue Date: October 23, 2000 Expiration: October 23, 2005 All Title I Conditions do not expire. Ann Foss Ann M. Foss Manager North/South Major Facilities CT:lk for Karen A. Studders Commissioner Minnesota Pollution Control Agency

2 TABLE OF CONTENTS Air Emission Permit No Page 2 of 4 Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices: Attached and Referenced in Table A

3 Air Emission Permit No Page 3 of 4 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. Notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: St. Cloud State University is an educational institution located in St. Cloud, MN. The main air pollution sources at the facility are shown below: Emission Unit ID # Stack Vent ID # Description Capacity Year Installed EU001 SV001 Boiler No million Btu/hr 1995 EU002 SV001 Boiler No million Btu/hr 1966 EU003 SV001 Boiler No million Btu/hr 1966 EU004 SV002 Math-Science Generator Set 85 kw 1972 EU005 SV003 Heating Plant Generator Set 300 kw 1979 EU006 SV004 Ice Arena Generator Set 75 kw 1989 EU007 SV005 Shoemaker Hall Generator Set 150 kw 1992

4 Air Emission Permit No Page 4 of 4 EU008 SV006 Sherburne Hall Generator Set 150 kw 1992 Boiler No. 1 is fired on natural gas and distillate fuel oil. Boiler Nos. 2 and 3 are fired on natural gas and No. 6 fuel oil. The Math-Science Generator Set is fired on natural gas, while the other four generator sets are fired on No. 2 diesel fuel. Those emission units identified as insignificant activities are listed in Appendix I of this permit.

5 TABLE A: LIMITS AND OTHER REQUIREMENTS 10/23/00 Facility Name: St Cloud State University Permit Number: 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 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. Monitoring Equipment: Install or make needed repairs to monitoring equipment within 60 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). 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, 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. 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. 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 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. Why to do it Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R Minn. R , subp. 3 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. 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. 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. 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. 1 Minn. R , subp. 1 Minn. R , subp. 4 A-1

6 TABLE A: LIMITS AND OTHER REQUIREMENTS 10/23/00 Facility Name: St Cloud State University Permit Number: 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. 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 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. Application for Permit Reissuance: due 180 days before expiration of existing permit. 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). 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. Record keeping: 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 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). 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. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. 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. Emissions Inventory Report: due 91 days after end of each calendar year following Permit Issuance. To be submitted on a form approved by the Commissioner. Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 3 Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R A-2

7 TABLE A: LIMITS AND OTHER REQUIREMENTS 10/23/00 Facility Name: St Cloud State University Permit Number: Subject Item: GP 001 Boiler Nos. 2 and 3 Associated Items: EU 002 Boiler No. 2 EU 003 Boiler No. 3 What to do Why to do it Opacity: less than or equal to 20 percent opacity except for one six-minute period Minn. R , subp. 2 per hour of not more than 60 percent opacity. Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R , subp. 1 Sulfur Content of Fuel: less than or equal to 2.0 percent by weight. This limit is applicable to fuel oil burned in Boiler Nos. 2 and 3. Fuel type is limited to No. 6 fuel oil and natural gas. The Permittee shall monthly record the total annual No. 6 fuel oil usage on a 12-month rolling sum basis. Fuel Usage: less than or equal to gallons/year using 12-month Rolling Sum of No. 6 fuel oil. The Permittee shall obtain a fuel oil certification from the fuel supplier specifying that the sulfur content of each delivery of No. 6 fuel oil is below 2.0 percent by weight. Title I Condition to avoid classification as a major stationary source under 40 CFR and Minn. R Title I Condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R Title I Condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R Title I Condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R Title I Condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R A-3

8 TABLE A: LIMITS AND OTHER REQUIREMENTS 10/23/00 Facility Name: St Cloud State University Permit Number: Subject Item: Associated Items: GP 002 Emergency Generator Sets EU 004 Math-Science Generator Set EU 005 Heating Plant Generator Set EU 006 Ice Arena Generator Set EU 007 Shoemaker Hall Generator Set EU 008 Sherburne Hall Generator Set What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 Fuel type is limited to natural gas for EU004 and No. 2 diesel fuel for EU005, EU006, EU007 and EU008. Operating Hours: less than or equal to 1000 hours/year using 12-month Rolling Sum. The limit on operating hours is applicable to each generator set. The Permittee shall monthly record the hours of operation of each generator set on a 12-month rolling sum basis. Minn. R , subp. 2 Title I condition to avoid classification as a major stationary source under 40 CFR and Minn. R Title I condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R A-4

9 TABLE A: LIMITS AND OTHER REQUIREMENTS 10/23/00 Facility Name: St Cloud State University Permit Number: Subject Item: EU 001 Boiler No. 1 Associated Items: SV 001 Main Stack What to do Why to do it Opacity: less than or equal to 20 percent opacity using 6-minute Average except for 40 CFR 60.43c(c) and Minn. R one six-minute period per hour not to exceed 27% opacity. Sulfur Content of Fuel: less than or equal to 0.5 percent by weight. This limit is 40 CFR 60.42c and Minn. R applicable to fuel oil burned in Boiler No. 1. Fuel type is limited to distillate (No. 1 or No. 2) fuel oil or natural gas. 40 CFR 60.42c and Minn. R Fuel Usage: less than or equal to gallons/year using 12-month Rolling Sum of distillate oil. The Permittee shall monthly record the total annual distillate fuel oil and natural gas usage on a 12-month rolling sum basis. The Permittee shall obtain a certification from the fuel supplier specifying that the sulfur content of each delivery of distillate fuel oil is below 0.5 percent by weight. Title I Condition to avoid classification as a major stationary source under 40 CFR 52.21and Minn. R CFR 60.48c(g) and Minn. R CFR 60.44c(h) and Minn. R A-5

10 TABLE B: SUBMITTALS Facility Name: St Cloud State University Permit Number: /23/00 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts 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 any application for a permit or permit amendment to: Permit Technical Advisor Permit Section Air Quality Division 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 Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Unless another person is identified in the applicable Table, send all other submittals to: Supervisor Compliance Determination Unit Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 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 B-1

11 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: St Cloud State University 10/23/00 Permit Number: What to send When to send Portion of Facility Affected Computer Dispersion Modeling Protocol due 1,096 days after Permit Issuance. This Total Facility protocol will describe the proposed modeling methodology and input data, in accordance with all requirements of 40 CFR pt. 51, App. W. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Computer Dispersion Modeling Results due 1,462 days after Permit Issuance. To be submitted after the MPCA has reviewed and approved the modeling protocol. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Total Facility B-2

12 TABLE B: RECURRENT SUBMITTALS Facility Name: St Cloud State University 10/23/00 Permit Number: What to send When to send Portion of Facility Affected Quarterly Report due 30 days after end of each calendar EU001 quarter following Permit Issuance. The report shall include the name of the oil supplier, a statement from the supplier that the oil complies with the specifications under the definition of distillate oil in Section 60.41c, and a certified statement that the records of fuel supplier certifications submitted represent all of the fuel combusted during the quarter. Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations occur the Permittee will submit the report stating that no deviations occurred. Compliance Certification due 30 days after end of each calendar year following Permit Issuance. To be submitted on a form approved by the Commissioner. The report covers all deviations experienced during the calendar year. A copy of this report shall also be submitted to the U.S. EPA Regional Office. Total Facility B-3

13 APPENDIX MATERIAL Facility Name: St Cloud State University Permit Number: Appendix I Insignificant Activities and Applicable Requirements Minn. R , subpart Activity Applicable Requirement(s) 3(A) Fuel use: space heaters fueled by kerosene, natural gas, or propane. Minn. R /0515 3(E) One 6,000 gallon gasoline storage tank. Minn. R (G) Emissions from laboratories. Minn. R /0110 3(H) Brazing, soldering or welding equipment. Minn. R /0515, Minn. R and Minn. R /0715 3(J) Fugitive emissions from parking lots. Minn. R

14 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document is for all the interested parties of the permit. The purpose of this document is to set forth the legal and factual basis for the permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location: Owner and Operator Address Facility Address and Phone Number (SIC Code: 8221) St. Cloud State University 720 S 4th Ave 720 S. 4 th Avenue St. Cloud, MN St. Cloud, MN Stearns County Contact: Mr. Chuck Lindgren Description of the facility St. Cloud State University is an educational institution located in St. Cloud, MN. The main air pollution sources at the facility are shown below: Emission Unit ID # Stack Vent ID # Description Capacity Year Installed EU001 SV001 Boiler No million Btu/hr 1995 EU002 SV001 Boiler No million Btu/hr 1966 EU003 SV001 Boiler No million Btu/hr 1966 EU004 SV002 Math-Science Generator Set 85 kw 1972 EU005 SV003 Heating Plant Generator Set 300 kw 1979 EU006 SV004 Ice Arena Generator Set 75 kw 1989 EU007 SV005 Shoemaker Hall Generator Set 150 kw 1992 EU008 SV006 Sherburne Hall Generator Set 150 kw 1992 Boiler No. 1 is fired on natural gas and distillate fuel oil. Boiler Nos. 2 and 3 are fired on natural gas and No. 6 fuel oil. The Math-Science Generator Set is fired on natural gas, while the other four generator sets are fired on No. 2 diesel fuel. 1.3 Description of any changes allowed with this permit issuance This permit does not allow for the construction or installation of any equipment at the facility which was not previously permitted. However, existing fuel usage and Permit Action Number: Date: 3/5/2004

15 operational limits are being changed (see discussion in Section PSD Applicability). 1.4 Description of all amendments issued since the issuance of the last total facility permit and to be included in the Part 70 Permit. Permit Number Action Authorized and Issuance Date OT-1 Last total facility permit. March 27, Authorizes the replacement of the existing Boiler No. 1 with an 86.1 (Amendment No. 1 million Btu/hr gas/distillate oil-fired boiler. to OT-1) May 16, Facility Emissions: Table 1. Total Facility Potential to Emit Summary: EU # SV# Emission Unit Description PM PM10 SO2 Tpy NOx CO Tpy VOC Pb All HAPs Boiler No * & Boiler Nos. 2 and * Math-Science Generator** Heating Plant Generator** Ice Arena Generator** Shoemaker Hall Generator** Sherburne Hall Generator** * To avoid classification as a major stationary source under 40 CFR 52.21, sulfur dioxide emissions from Boiler No. 1 are limited to 26.6 tons per year and combined sulfur dioxide emissions from Boiler Nos. 2 and 3 are limited to tons per year (see discussion in Section 3 of this analysis). ** Emissions are based on 1,000 hours of operation per year. Permit Action Number: Date: 3/5/2004 PM PM10 SO2 Tpy NOx CO Tpy VOC Pb All HAPs Total Facility Limited Potential Emissions Total Facility Actual Emissions* < 2.0 * Based on 1998 emissions.

16 . Table 2. Facility(TF) and Permit Classification PSD Classification Major/Affected Source *Synthetic Minor NO x, SO 2 *Minor CO, VOC, PM, PM 10 NAAR Not Applicable NO x, SO 2 CO VOC, PM 10 Part 70 Permit Program * Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt Regulatory and/or Statutory Basis Summary Regulatory and/or Statutory Basis of the Emission or operational Limit Regulatory Overview of Facility EU, Applicable Regulations Comments: GRP, or SV # EU CFR 60 Subp. Dc Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units EU001 Minn. R Standards of Performance for New Indirect Heating EU002 & EU003 EU004, EU005, EU006, EU007 & EU008 Minn. R Minn. R Equipment Standards of Performance for Existing Indirect Heating Equipment Standards of Performance for Stationary Internal Combustion Engines Permit Action Number: Date: 3/5/2004

17 3. Technical Information CFR 60, Subpart Dc (applicable to EU001) 40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units establishes an opacity standard of 20%, except for one six-minute period per hour not to exceed 27% opacity and a fuel oil sulfur content limit of 0.5 percent by weight. To demonstrate compliance with the above requirements, Subpart Dc requires the Permittee to record the total annual fuel use and to also obtain a certification from the fuel supplier specifying that the sulfur content of each delivery of oil is below 0.5 percent by weight. These requirements have been incorporated into the permit. 3.2 Minn. R (applicable to Boiler No. 1) Minn. R , Standards of Performance for New Indirect Heating Equipment, is applicable to EU establishes a particulate matter emission limit for Boiler No. 1 of 0.4 lb/million BTU heat input and an opacity limit of 20% opacity, except for one six-minute period per hour not to exceed 60% opacity. When burning natural gas or distillate oil, emissions are expected to be well below 20% opacity and 0.4 lb/million BTU heat input for particulate. The permit restricts the fuel burned in Boiler No. 1 to distillate oil and natural gas. 3.3 Minn. R (applicable to Boiler Nos. 2 & 3) Minn. R , Standards of Performance for Existing Indirect Heating Equipment, is applicable to Boiler Nos. 2 and limits particulate matter to 0.6 lb/million BTU heat input and the opacity of emissions to 20% opacity, except for one six-minute period per hour not to exceed 60% opacity. When burning natural gas or No. 6 fuel oil, emissions are expected to be well below 20% opacity and 0.6 lb/million BTU heat input for particulate. The permit restricts the fuel burned in Boiler Nos. 2 and 3 to No. 6 fuel oil and natural gas. 3.4 Minn. R (applicable to the generators) Minn. R , Standards of Performance for Stationary Internal Combustion Engines, is applicable to the generators at the facility limits sulfur dioxide emissions to 0.5 lb/million BTU heat input and opacity to 20% once operating temperatures have been attained. The math-science generator (EU004) burns natural gas, so opacity and sulfur dioxide emissions will be well below the above limits. The permit restricts the fuel burned in EU004 to natural gas. The other generators (EU005 through EU008) burn diesel fuel. When burning diesel fuel, the opacity of emissions is expected to be well below the 20% limit. AP-42 gives a sulfur dioxide Permit Action Number: Date: 3/5/2004

18 emission factor for diesel industrial engines of 0.29 lb/million BTU heat input, which is below the limit of 0.5 lb/million BTU heat input. The permit restricts the fuel burned in the generators to No. 2 diesel fuel. 3.5 PSD Applicability The most recent permit issued for the facility (on May 16, 1995) limits the amount of fuel oil burned in Boiler No. 1 to 50,000 gallons per month. This permit also limits the hours of operation of two generators (EU007 and EU008) to 300 hours per year. The limits on the hours of operation of EU007 and EU008 were initially established in the March 27, 1992 total facility permit to limit emissions from the two generators to less than the PSD significant level for nitrogen oxides of 40 tons per year. The limit on the amount of fuel oil burned in Boiler No. 1 was established to keep emissions from Boiler No. 1 below the PSD significant level for sulfur dioxide of 40 tons per year. The Title V permit application requests that the amount of fuel oil burned in the boilers be restricted to 750,000 gallons per year for Boiler No. 1 and 1,400,000 gallons per year (combined) for Boilers 2 and 3 (the amount of fuel oil burned in Boilers 2 and 3 is not currently restricted). The purpose of restricting the amount of fuel oil burned in all three boilers is to avoid classification of the facility as a major stationary source under PSD. The source is currently classified as a major stationary source since sulfur dioxide emissions are not restricted to less than 250 tons per year. Sulfur dioxide emissions associated with the proposed fuel oil limits are calculated as follows: Boiler 1 Proposed limit = 750,000 gal/yr SO 2 emissions = 750,000 gal/yr[142(0.5) lb/10 3 gal](1 ton/2,000 lb) = 26.6 tons/year Boilers 2 and 3 Proposed limit = 1,400,000 gal/yr SO 2 emissions = 1,400,000 gal/yr[157(2.0) lb/10 3 gal](1 ton/2,000 lb) = tons/year In addition to the above, SO 2 emissions from the generators need to be included. The mathscience generator set (EU004) is fired on natural gas, so SO 2 emissions are negligible. Emissions are calculated at 1,000 hours of operation per year (the units actually operate approximately 12 hours per year). Emissions from EU005 through EU008 are calculated as follows: AP-42 Emission Factor (diesel industrial engines)= lb/hp-hr Total horsepower (EU005 through EU008) = 1,138 hp SO 2 emissions = 1,138 hp( lb/hp-hr)(1,000 hr/yr)(1 ton/2,000 lb) = 1.2 tons/year Based upon the above restrictions, total combined SO 2 emissions from the source are limited to tons per year. The permit will limit the amount of distillate fuel oil burned in Boiler No. 1 to 750,000 gallons per year and the amount of No. 6 oil burned in Boilers 2 and 3 to 1,400,000 gallons per year. The permit will also limit the hours of operation of the generator sets to 1,000 Permit Action Number: Date: 3/5/2004

19 hours per year. These limits will restrict SO 2 emissions to less than 250 tons per year and the source will no longer be classified as a major stationary source under 40 CFR Emission calculations for pollutants other than sulfur dioxide are attached. 4. Conclusion Based on the information provided by St. Cloud State University, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Craig Thorstenson, David Crowell Peer Review: Trent Wickman Attachments: Calculations Permit Action Number: Date: 3/5/2004