Air Individual Permit Permit Limits to Avoid NSR

Transcription

1 Air Individual Permit Permit Limits to Avoid NSR Permittee: Facility name: Shakopee Distributed Generation Shakopee Distributed Generation Vierling Drive E Shakopee, Minnesota Scott County Operating permit issuance date: [ ] Expiration date: [ ] * All Title I Conditions do not expire State Permit: [Amendment Issue Date] Permit characteristics: State; Limits to avoid Part 70/Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Table. This is a first time state permit issuance that authorizes the Permittee to construct and operate 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 State Implementation Plan (SIP) under 40 CFR and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: [Type e-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. Modeling Parameters 8 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 State Individual Operating Permit 07/14/

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 U.S. 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 St. Paul, Minnesota

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The Minnesota Municipal Power Agency is proposing to build and operate a 47 megawatt electric generating plant in Shakopee, Minnesota. The facility will generate electricity with 5 Wartsila 20V34SG spark ignition (SI), natural gas fueled, lean burn, reciprocating internal combustion engines (RICE). There will also be a 500 kw emergency diesel black start compression ignition (CI) RICE. Each of the 5 SI RICE will have a pair (in series) of control devices; a selective catalytic reduction device (SCR) with urea injection for nitrogen oxides (NOx) control, and a chemical oxidation (carbon monoxide (CO) catalyst) device for CO, volatile organic compounds (VOC), and hazardous air pollutants (HAPs) control. Limits have been imposed to avoid major source classification under New Source Review (NSR) and 40 CFR Part 70 for NOx, CO, and VOC, and to avoid major source classification under 40 CFR Part 63 for Total HAPs, Acrolein, Formaldehyde, and Acetaldehyde.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description ACTV1: All IA's COMG1: Gensets COMG2: SCR Relationship Type has members has members COMG3: CO Catalyst has members Related SI ID: Description EQUI1, EQUI2, EQUI3, EQUI4, EQUI5, STRU1, STRU2, STRU3, STRU4, STRU5 TREA1, TREA2, TREA3, TREA4, TREA5 TREA6, TREA7, TREA8, TREA9, TREA10 EQUI1: Engine 1 sends to STRU1: Unit 1 Exhaust EQUI1: Engine 1 is controlled by TREA1: SCR (Selective Catalytic Reduction) EQUI1: Engine 1 is controlled by TREA6: Chemical Oxidation EQUI2: Engine 2 sends to STRU2: Unit 2 Exhaust EQUI2: Engine 2 EQUI2: Engine 2 is controlled by is controlled by TREA2: SCR (Selective Catalytic Reduction) TREA7: Chemical Oxidation EQUI3: Engine 3 sends to STRU3: Unit 3 Exhaust EQUI3: Engine 3 is controlled by TREA3: SCR (Selective Catalytic Reduction) EQUI3: Engine 3 is controlled by TREA8: Chemical Oxidation EQUI4: Engine 4 sends to STRU4: Unit 4 Exhaust EQUI4: Engine 4 EQUI4: Engine 4 is controlled by is controlled by TREA4: SCR (Selective Catalytic Reduction) TREA9: Chemical Oxidation SI ID: Relationship Related SI ID: Description Type Description EQUI5: Engine 5 sends to STRU5: Unit 5 Exhaust EQUI5: Engine 5 is controlled by TREA10: Chemical Oxidation EQUI5: Engine 5 is controlled by TREA5: SCR (Selective Catalytic Reduction) EQUI6: Generator sends to STRU6: Unit 6 Exhaust STRU1: Unit 1 Exhaust STRU2: Unit 2 Exhaust STRU3: Unit 3 Exhaust STRU4: Unit 4 Exhaust STRU5: Unit 5 Exhaust STRU6: Unit 6 Exhaust TFAC1: Shakopee Distributed Generation TREA10: Chemical Oxidation TREA1: SCR (Selective Catalytic Reduction) TREA2: SCR (Selective Catalytic Reduction) TREA3: SCR (Selective Catalytic Reduction) TREA4: SCR (Selective Catalytic Reduction) TREA5: SCR (Selective Catalytic Reduction) TREA6: Chemical Oxidation TREA7: Chemical Oxidation TREA8: Chemical is controlled in series by is controlled in series by is controlled in series by is controlled in series by is controlled in series by TREA6: Chemical Oxidation TREA7: Chemical Oxidation TREA8: Chemical Oxidation TREA9: Chemical Oxidation TREA10: Chemical Oxidation

7 Permit issued: [month day, year] Permit expires: [month day, year] Page 7 of 101 SI ID: Description Oxidation TREA9: Chemical Relationship Type Related SI ID: Description SI ID: Description Oxidation Relationship Type Related SI ID: Description

8 Permit Expires: [month day, year] Page 8 of Limits and other requirements TFAC Shakopee Distributed Generation The Permittee is authorized to construct and operate EQUI1- EQUI6, TREA1-TREA10, ACTV1, and STRU1-STRU6 within 18 months after permit issuance of Permit No The units shall meet all the requirements of this permit. [Minn. R , subp. 2] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A. Modeling Parameters in Appendix B are included for reference only as described elsewhere in this permit. [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

9 Permit Expires: [month day, year] Page 9 of 101 maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R , subp. 14, Minn. R , subp. 16(J)] 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 Tests are due as outlined in this permit. 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 60 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 an alternative format as allowed by Minn. R [Minn. R , Minn. R , subps. 1-4, Minn. R.

10 Permit Expires: [month day, year] Page 10 of , 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 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

11 Permit Expires: [month day, year] Page 11 of 101 Permittee must retain records of all calculations required under Minn. R For non-expiring permits, 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 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

12 Permit Expires: [month day, year] Page 12 of 101 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 more than 3 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 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, to be submitted on a form approved by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] The Permittee shall submit all information required to be submitted to EPA under 40 CFR 60.4(a) to the MPCA address listed in the cover pages of this permit. [40 CFR 60.4(b)] Modeled Parameters for PM2.5: The parameters used in PM2.5 modeling for permit number are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , subp.

13 Permit Expires: [month day, year] Page 13 of 101 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] COMG 1 Gensets The requirements of this group (COMG1) apply individually to each unit listed under this group (EQUI1-EQUI5). [Minn. R , subp. 2] Nitrogen Oxides <= 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. [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 ] Volatile Organic Compounds <= 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. [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 ] Carbon Monoxide <= 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. [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 ] HAPs - Total <= 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. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Acrolein <= 9.00 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. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Formaldehyde <= 9.00 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. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Acetaldehyde <= 9.00 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. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R.

14 Permit Expires: [month day, year] Page 14 of ] Engine Shakedown Period Requirements: The engine generator shakedown period for each individual COMG1 engine (EQUI1-EQUI5) is defined as the period of time commencing on the date of initial startup of the engine and terminating on the date that commissioning is complete or 180 days after the start of that engine's shakedown period, whichever is earlier. Commissioning is complete when the engine is available for commercial electric power generation. [Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Control Equipment Operation During Engine Shakedown Period: Operation of control equipment is not required during the engine shakedown period, but shall be initiated upon commencement of normal operation. [Minn. R , subp. 2] During each engine's shakedown period, all emissions from that engine shall be recorded as uncontrolled for purposes of calculating emissions as required by this permit, and for emission inventory. [Minn. R , subp. 2] Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Sulfur Dioxide <= 0.50 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] The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R , subp. 5] Fuel Type: Natural gas only, by design. [Minn. R , subp. 35a] Sulfur Content of Fuel <= 0.05 percent by weight calendar year average. [40 CFR 72.7(a)(3), Minn. R ] Average Annual Sulfur Content Determination. The 0.05% fuel sulfur content requirement is assumed to be met by combusting only natural gas. [40 CFR 72.7(d)(1), Minn. R ] Loss of exemption. An exempt unit shall be treated as an affected unit under the Acid Rain Program on the earliest of the following dates: (A) The date on which the unit first serves one or more generators with total nameplate capacity in excess of 25 MWe; (B) The date on which the unit burns any coal or coal-derived fuel except for coal-derived gaseous fuel with a total sulfur content no greater than natural gas; or (C) January 1 of the year following the year in which the annual average sulfur content for gaseous fuel burned at the unit

15 Permit Expires: [month day, year] Page 15 of 101 exceeds 0.05 percent by weight (as determined under 40 CFR Section 72.7(d)). [40 CFR 72.7(f)(4)(ii), Minn. R ] For a period of 5 years from the date the records are created, the Permittee shall retain at the source records demonstrating that the requirements of 40 CFR Section 72.7(a) are met. The 5-year period for keeping records may be extended for cause, at any time prior to the end of the period, in writing by the Administrator or the permitting authority. (i) Such records shall include, for fuel delivered to the unit continuously by pipeline, the type of fuel, the sulfur content, and the sulfur content of each sample taken. (ii) The Permittee bears the burden of proof that the requirements of 40 CFR Section 72.7(a) are met. [40 CFR 72.7(f)(3), Minn. R ] Daily Recordkeeping: On each calendar day, the Permittee shall calculate, record, and maintain records of the therms of natural gas used and the corresponding heat input in units of MMBtu, for each unit in COMG1 during the previous calendar operating day for each control equipment operating scenario: 1. Scenario 1 - Controls are operating as required, and, 2. Scenario 2 - Controls are not operating and/or not operating as required. Therms of natural gas used shall be converted to MMBtus (for each of the two control equipment operating scenarios) using a conversion factor of 0.10 MMBtu/therm. [Minn. R , Title I Condition: 40 CFR 63.2, 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 ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The NOx emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit.

16 Permit Expires: [month day, year] Page 16 of 101 (4) Calculate the monthly COMG1 NOx emissions according to the Calculation Method requirement below. (5) The 12-month rolling sum NOx emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 NOx emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, 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 ] Calculation Method - The Permittee shall calculate the monthly COMG1 NOx emissions using the following equations: Monthly COMG1 NOx emissions (tons) = sum of monthly NOx emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) + (EF3u * F3u ) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where: EF1 = EQUI1 NOx emission factor in lb/mmbtu as determined during the most recent stack test F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 NOx uncontrolled emission factor based off maximum heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = EQUI2 NOx emission factor in lb/mmbtu as determined during the most recent stack test F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 NOx uncontrolled emission factor based off maximum heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF3 = EQUI3 NOx emission factor in lb/mmbtu as determined during the most recent stack test F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF3u = lb/mmbtu EQUI3 NOx uncontrolled emission factor based off maximum heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = EQUI4 NOx emission factor in lb/mmbtu as determined during the most recent stack test F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF4u = lb/mmbtu EQUI4 NOx uncontrolled emission

17 Permit Expires: [month day, year] Page 17 of 101 factor based off maximum heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = EQUI5 NOx emission factor in lb/mmbtu as determined during the most recent stack test F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 NOx uncontrolled emission factor based off maximum heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, 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 ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The CO emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit. (4) Calculate the monthly COMG1 CO emissions according to the Calculation Method requirement below. (5) The 12-month rolling sum CO emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 CO emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, 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 ] Calculation Method - The Permittee shall calculate the monthly COMG1 CO emissions using the following equations: Monthly COMG1 CO emissions (tons) = sum of monthly CO emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) + (EF3u * F3u) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where:

18 Permit Expires: [month day, year] Page 18 of 101 EF1 = EQUI1 CO emission factor in lb/mmbtu as determined during the most recent stack test F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 CO uncontrolled emission factor based off maximum heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = EQUI2 CO emission factor in lb/mmbtu as determined during the most recent stack test F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 CO uncontrolled emission factor based off maximum heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF3 = EQUI3 CO emission factor in lb/mmbtu as determined during the most recent stack test F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF3u = lb/mmbtu EQUI3 CO uncontrolled emission factor based off maximum heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = EQUI4 CO emission factor in lb/mmbtu as determined during the most recent stack test F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF4u = lb/mmbtu EQUI4 CO uncontrolled emission factor based off maximum heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = EQUI5 CO emission factor in lb/mmbtu as determined during the most recent stack test F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 CO uncontrolled emission factor based off maximum heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, 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 ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following:

19 Permit Expires: [month day, year] Page 19 of 101 (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The VOC emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit. (4) Calculate the monthly COMG1 VOC emissions according to the Calculation Method requirement below. (5) The 12-month rolling sum VOC emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 VOC emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, 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 ] Calculation Method - The Permittee shall calculate the monthly COMG1 VOC emissions using the following equations: Monthly COMG1 VOC emissions (tons) = sum of monthly VOC emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) + (EF3u * F3u) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where: EF1 = EQUI1 VOC emission factor in lb/mmbtu as determined during the most recent stack test F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 VOC uncontrolled emission factor based off maximum heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = EQUI2 VOC emission factor in lb/mmbtu as determined during the most recent stack test F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 VOC uncontrolled emission factor based off maximum heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month

20 Permit Expires: [month day, year] Page 20 of 101 EF3 = EQUI3 VOC emission factor in lb/mmbtu as determined during the most recent stack test F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF3u = lb/mmbtu EQUI3 VOC uncontrolled emission factor based off maximum heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = EQUI4 VOC emission factor in lb/mmbtu as determined during the most recent stack test F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF4u = lb/mmbtu EQUI4 VOC uncontrolled emission factor based off maximum heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = EQUI5 VOC emission factor in lb/mmbtu as determined during the most recent stack test F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 VOC uncontrolled emission factor based off maximum heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, 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 ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The Total HAPs emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit. (4) Calculate the monthly COMG1 Total HAPs emissions according to the Calculation Method requirement below.

21 Permit Expires: [month day, year] Page 21 of 101 (5) The 12-month rolling sum Total HAPs emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 Total HAPs emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Calculation Method - The Permittee shall calculate the monthly COMG1 Total HAPs emissions using the following equations: Monthly COMG1 Total HAPs emissions (tons) = sum of monthly Total HAPs emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) + (EF3u * F3u) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where: EF1 = [Sum of all EQUI1 HAP emission factors except Acrolein, Acetaldehyde, and Formaldehyde in lb/mmbtu] + [Sum of EQUI1 Acrolein, Acetaldehyde, and Formaldehyde emission factors in lb/mmbtu] as determined during the most recent stack tests F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 Total HAPs uncontrolled emission factor based off max heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = [Sum of all EQUI2 HAP emission factors except Acrolein, Acetaldehyde, and Formaldehyde in lb/mmbtu] + [Sum of EQUI2 Acrolein, Acetaldehyde, and Formaldehyde emission factors in lb/mmbtu] as determined during the most recent stack tests F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 Total HAPs uncontrolled emission factor based off max heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF3 = [Sum of all EQUI3 HAP emission factors except Acrolein, Acetaldehyde, and Formaldehyde in lb/mmbtu] + [Sum of EQUI3 Acrolein, Acetaldehyde, and Formaldehyde emission factors in lb/mmbtu] as determined during the most recent stack tests F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month

22 Permit Expires: [month day, year] Page 22 of 101 EF3u = lb/mmbtu EQUI3 Total HAPs uncontrolled emission factor based off max heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = [Sum of all EQUI4 HAP emission factors except Acrolein, Acetaldehyde, and Formaldehyde in lb/mmbtu] + [Sum of EQUI4 Acrolein, Acetaldehyde, and Formaldehyde emission factors in lb/mmbtu] as determined during the most recent stack tests F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF4u = lb/mmbtu EQUI4 Total HAPs uncontrolled emission factor based off max heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = [Sum of all EQUI5 HAP emission factors except Acrolein, Acetaldehyde, and Formaldehyde in lb/mmbtu] + [Sum of EQUI5 Acrolein, Acetaldehyde, and Formaldehyde emission factors in lb/mmbtu] as determined during the most recent stack tests F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 Total HAPs uncontrolled emission factor based off max heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The Acrolein emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit. (4) Calculate the monthly COMG1 Acrolein emissions according

23 Permit Expires: [month day, year] Page 23 of 101 to the Calculation Method requirement below. (5) The 12-month rolling sum Acrolein emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 Acrolein emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Calculation Method - The Permittee shall calculate the monthly COMG1 Acrolein emissions using the following equations: Monthly COMG1 Acrolein emissions (tons) = sum of monthly Acrolein emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) + (EF3u * F3u) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where: EF1 = EQUI1 Acrolein emission factor in lb/mmbtu as determined during the most recent stack test F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 Acrolein uncontrolled emission factor based off maximum heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = EQUI2 Acrolein emission factor in lb/mmbtu as determined during the most recent stack test F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 Acrolein uncontrolled emission factor based off maximum heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF3 = EQUI3 Acrolein emission factor in lb/mmbtu as determined during the most recent stack test F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF3u = lb/mmbtu EQUI3 Acrolein uncontrolled emission factor based off maximum heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = EQUI4 Acrolein emission factor in lb/mmbtu as determined during the most recent stack test F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month

24 Permit Expires: [month day, year] Page 24 of 101 EF4u = lb/mmbtu EQUI4 Acrolein uncontrolled emission factor based off maximum heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = EQUI5 Acrolein emission factor in lb/mmbtu as determined during the most recent stack test F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 Acrolein uncontrolled emission factor based off maximum heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: (1) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are operating as required, by summing the daily heat input values (in MMBtus) for when controls for the specific unit are operating as required. (2) The Formaldehyde emission factor in lb/mmbtu for the previous calendar month for each unit in COMG1 as determined by the most recent performance test data. (3) The heat input in MMBtu/month for the previous calendar month for each unit in COMG1 for when controls are not operating and/or not operating as required, by summing the daily heat input values (in MMBtus) for when controls are not operating and/or not operating as required for the specific unit. (4) Calculate the monthly COMG1 Formaldehyde emissions according to the Calculation Method requirement below. (5) The 12-month rolling sum Formaldehyde emissions rate (tons/year) for the previous 12-month period by summing the monthly COMG1 Formaldehyde emissions (tons) for the previous 12 months. [Minn. R , subps. 4-5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2, To avoid major source under 40 CFR 70.2 & Minn. R ] Calculation Method - The Permittee shall calculate the monthly COMG1 Formaldehyde emissions using the following equations: Monthly COMG1 Formaldehyde emissions (tons) = sum of monthly Formaldehyde emissions from each engine = ((EF1 * F1) + (EF1u * F1u) + (EF2 * F2) + (EF2u * F2u) + (EF3 * F3) +

25 Permit Expires: [month day, year] Page 25 of 101 (EF3u * F3u) + (EF4 * F4) + (EF4u * F4u) + (EF5 * F5) + (EF5u * F5u)) * tons/lbs Where: EF1 = EQUI1 Formaldehyde emission factor in lb/mmbtu as determined during the most recent stack test F1 = EQUI1 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF1u = lb/mmbtu EQUI1 Formaldehyde uncontrolled emission factor based off maximum heat input F1u = EQUI1 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF2 = EQUI2 Formaldehyde emission factor in lb/mmbtu as determined during the most recent stack test F2 = EQUI2 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF2u = lb/mmbtu EQUI2 Formaldehyde uncontrolled emission factor based off maximum heat input F2u = EQUI2 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF3 = EQUI3 Formaldehyde emission factor in lb/mmbtu as determined during the most recent stack test F3 = EQUI3 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF3u = lb/mmbtu EQUI3 Formaldehyde uncontrolled emission factor based off maximum heat input F3u = EQUI3 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF4 = EQUI4 Formaldehyde emission factor in lb/mmbtu as determined during the most recent stack test F4 = EQUI4 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF4u = lb/mmbtu EQUI4 Formaldehyde uncontrolled emission factor based off maximum heat input F4u = EQUI4 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month EF5 = EQUI5 Formaldehyde emission factor in lb/mmbtu as determined during the most recent stack test F5 = EQUI5 heat input in MMBtu/month for the fuel used during controlled operations for the previous month EF5u = lb/mmbtu EQUI5 Formaldehyde uncontrolled emission factor based off maximum heat input F5u = EQUI5 heat input in MMBtu/month for the fuel used during uncontrolled operations for the previous month. [Minn. R , subps. 4-5, Minn. R , Title I Condition: