AIR EMISSION PERMIT NO Total Facility Operating Permit - Reissuance IS ISSUED TO. Mayo Foundation

AIR EMISSION PERMIT NO. 10900008-004 Total Facility Operating Permit - Reissuance IS ISSUED TO Mayo Foundation St Marys 1216 Southwest 2nd Street Rochester, Olmsted County, MN 55902 The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. Upon issuance, this permit supersedes Air Emission Permit No. 10900008-003 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Any additions or changes to conditions incorporated into Minnesota s State Implementation Plan (SIP) under 40 CFR 52.1220, designated Title I: SIP for SO 2 NAAQS must go through the federal SIP approval process before becoming effective. 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 52.1220 and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal Permit; Part 70/Major for NSR; Title I SIP Conditions for SO 2 Operating Permit Issue Date: December 28, 2010 Expiration Date: December 28, 2015 All Title I Conditions do not expire. Each new or revised condition designated Title I Condition: SIP for SO 2 is not effective or enforceable until approved by EPA as a SIP revision under Title I of the Clean Air Act. Don Smith, Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit -Reissuance January 23, 2008 004 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule: not used in this permit Appendix A: not used in this permit Appendix B: Modeling Parameters Appendix C: Insignificant Activities Appendix D: Subpart WWWWW Requirements for New Ethylene Oxide Sterilizers Appendix E: Subpart WWWWW Requirements for Existing Ethylene Oxide Sterilizers

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: St. Marys is a tertiary care hospital which includes several buildings located on a 49 acre campus. The primary emission units at the facility are three identical boilers which exhaust through a common stack, one cogeneration turbine, two emergency generators, and one nonemergency generator. Each boiler combusts natural gas with distillate fuel as backup. The cogeneration turbine burns only natural gas. One generator burns only distillate oil; the other two can burn distillate oil or natural gas (with a small amount of distillate oil; dual fuel). While St. Marys is owned and operated by the Mayo Foundation, it is not contiguous with the majority of the Mayo facilities in Rochester, and thus is a separate source under the New Source Review and Part 70 regulations. The facility is an existing major source under New Source Review and a minor HAP source. The facility is located in an area that was previously designated as non-attainment for SO 2. However, the area currently meets the ambient air quality standards, and was officially redesignated as attainment on May 8, 2001. The previous permit (10900008-003), which includes the requirements contributing to the correction of the non-attainment problem and ultimate redesignation, was incorporated into Minnesota s State Implementation Plan (SIP) on October 12, 2010, with the requirements designated as non-expiring Title I conditions. This permit (10900008-004) does not include changes to any of those requirements.

TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 12/28/10 Facility Name: Permit Number: St Marys 10900008-004 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 SITE-SPECIFIC REQUIREMENTS hdr Why to do it Parameters Used in Modeling: The stack parameters used in the most recently approved modeling are listed in Appendix B of this permit. Before making any physical changes or changes in the method of operation which may affect parameters listed in Appendix B, the Permittee shall demonstrate to the MPCA that the SO2 plume dispersion characteristics following the physical change or change in method of operation will be equivalent to or better than the SO2 dispersion characteristics modeled using the parameters in Appendix B. The information submitted must include, at a minimum, the locations, heights, and diameters of the stacks, locations and dimensions of nearby buildings, the velocity and temperature of the gasses emitted, and the SO2 emission rates. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. ACTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility in compliance with Minnesota Rules and without obtaining a modification to the SIP as long as the change does not increase from any emission point, the SO2 emission rates (in lb/hr) or overall SO2 emissions or alter equipment or parameters described in Appendix B, which forms the basis for the SO2 modeling, unless such alteration demonstrates equivalent or better dispersion characteristics. Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS" shall be reported semiannually with the Semiannual Deviations Report required by this permit (See Table B). Reporting for these conditions shall occur even if there were no deviations for the reporting period. State Implementation Plan Recordkeeping: Retain all records at the stationary source for a period of five years from the date of the required monitoring, sample, measurement, or report that corresponds with a "Title I Condition: SIP for SO2 NAAQS" requirement. The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections 601-618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections 601-618 and 40 CFR pt. 82 to determine all the requirements that apply to your facility. DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.2(r)(6)(vi)(a). Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan 40 CFR pt. 82 hdr Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2 Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150-7007.1500.

TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 12/28/10 Permit Number: 10900008-004 Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5 The Permittee shall maintain records of this documentation. The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5 Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5 a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. OPERATIONAL REQUIREMENTS 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. 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. 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. 7011.0150. Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. RECORDKEEPING hdr Minn. R. 7011.0020 Minn. R. 7019.1000, subp. 4 Minn. R. 7011.0150 Minn. R. 7030.0010-7030.0080 Minn. R. 7007.0800, subp. 9(A) Minn. R. 7007.0800, subp. 16 hdr

TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 12/28/10 Permit Number: 10900008-004 Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Recordkeeping: 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. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. 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. REPORTING/SUBMITTALS 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. 7019.1000, 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. 7019.1000, subp. 2. Minn. R. 7007.0800, subp. 5(C) Minn. R. 7007.0800, subp. 5(B) Minn. R. 7007.1200, subp. 4 hdr Minn. R. 7019.1000, subp. 3 Minn. R. 7019.1000, 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 Minn. R. 7019.1000, subp. 1 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: Minn. R. 7019.1000, subp. 1 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. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R. 7007.1150 through Minn. R. 7007.1500 application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

TABLE A: LIMITS AND OTHER REQUIREMENTS A-4 12/28/10 Permit Number: 10900008-004 Application for a major permit amendment: If any EU 012 NOx emission factor verification test measures the EU 012 NOx emission factor at 1.040 g/hp-hr or greater, the Permittee shall submit an application for a major amendment. The application shall propose a reduction of the 2045 hr/yr EU 012 operating limit to a level that will limit EU 012 NOx emissions to no greater than 38.0 tons per year. Title I Condition: To avoid major modification status under 40 CFR Section 52.21(b)(2)(i) and Minn. R. 7007.3000 The application shall be submitted no later than 30 days after the Permittee's receipt of the MPCA letter approving the performance test results (i.e. a Notice of Verification). This requirement is repeated under Subject Item EU 012. Extension Requests: The Permittee may apply for an Administrative Amendment Minn. R. 7007.1400, subp. 1(H) to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R. 7019.3000 through Minn. R. 7019.3100 permit issuance. The report shall be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 12/28/10 Permit Number: 10900008-004 Subject Item: GP 001 Boilers Associated Items: EU 001 Boiler 1 EU 002 Boiler 2 EU 003 Boiler 3 EMISSION AND OPERATING LIMITS What to do hdr Why to do it Fuel Used: The Permittee shall burn only natural gas or very low sulfur oil, as defined in 40 CFR Section 60.41b. Sulfur Content of Fuel: less than or equal to 0.50 percent by weight (meets specifications of very low sulfur oil as defined in 40 CFR Section 60.41b) Nitrogen Oxides: less than or equal to 0.10 lbs/million Btu heat input using 30-day Rolling Average. This standard applies at all times. Opacity: less than or equal to 20 percent opacity using 6-minute Average, except for one 6-minute period per hour of not more than 27 percent opacity. This standard applies at all times except during periods of startup, shutdown, or malfunction. MONITORING REQUIREMENTS Sulfur Content of Fuel Oil: The Permittee shall obtain and maintain a fuel supplier receipt from the fuel oil supplier for each shipment of oil received, certifying that the oil meets the definition of very low sulfur oil as defined in 40 CFR Section 60.41b. The Permittee shall ensure that the fuel supplier uses an approved American Society of Testing and Materials (ASTM) method to determine the sulfur content of liquid fuels. NOx Emissions: The Permittee shall calibrate, maintain, and operate a continuous emission monitoring system (CEMS), and record the output of the system, for measuring NOx emissions discharged to the atmosphere. As allowed by 40 CFR 60.13(g), the Permittee operates one CEMS in the common duct for the three boilers. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j); Minn. R. 7011.0565 40 CFR Section 60.44b(a); 40 CFR Section 60.46b(a); Minn. R. 7011.0565 40 CFR Section 60.43b(f) and (g); 40 CFR Section 60.46b(a); Minn. R. 7011.0565 hdr Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Section 60.42b(j)(2); Minn. R. 7011.0565 40 CFR Section 60.48b(b)(1), (c), and (d); 40 CFR Section 60.13(g); Minn. R. 7011.0565 The CEMS shall be operated and data recorded during all periods of operation of the boilers, except for CEMS breakdowns and repairs. Data is recorded during calibration checks, and zero and span adjustments. The 1-hour average NOx emission rates measured by the CEMS shall be expressed in lb/million Btu heat input, and shall be used to calculate the average emission rates. At least 2 data points must be used to calculate each 1-hour average. [For additional monitoring requirements, see Subject Item MR001.] When NOx emissions data are not obtained because of CEMs breakdowns or repairs, data will be obtained by using standby monitoring systems, Method 7 or 7A, or other approved reference methods to provide data for a minimum of 75% of the operating hours in each steam generating unit operating day, in at least 22 out of 30 successive steam generating unit operating days. Opacity: The Permittee shall calibrate, maintain, and operate a continuous monitoring system for measuring the opacity of emissions discharged to the atmosphere, and record the output of the system. 40 CFR Section 60.48b(f); Minn. R. 7011.0565 40 CFR Section 60.48b(a); 40 CFR Section 60.13(g); Minn. R. 7011.0565 As allowed by 40 CFR 60.13(g), the Permittee operates one COMS in the common duct for the three boilers. [For additional monitoring requirements, see Subject Item MR003.] PERFORMANCE TESTING REQUIREMENTS hdr Upon request, the Permittee shall use a 30-day performance test to determine compliance with the NOx standard. During periods when performance tests are not requested, NOx emission data collected via the CEM shall be used to calculate a 30-day rolling average emission rate on a daily basis and used to prepare excess emission reports, but will not be used to determine compliance with the NOx emission standard. A new 30-day rolling average emission rate is calculated each steam generating unit operating day as the average of all of the hourly NOx emission data for the preceding 30 steam generating unit operating days. RECORDKEEPING AND REPORTING REQUIREMENTS 40 CFR Section 60.46b(e)(4); Minn. R. 7011.0565 hdr

TABLE A: LIMITS AND OTHER REQUIREMENTS A-6 12/28/10 Permit Number: 10900008-004 The Permittee shall record and maintain records of the amounts of each fuel combusted each day and calculate the annual capacity factor individually for distillate oil and natural gas. The annual capacity factor is determined on a 12-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. The Permittee shall maintain records of opacity.(see Subject Item MR003 for additional detail.) The Permittee shall maintain records of the following information for each steam generating unit operating day: (1) Calendar date. (2) The average hourly NOx emission rates (expressed as NO2), in lb/million Btu heat input. (3) The 30-day average NOx emission rates calculated at the end of each steam generating unit operating day. (4) Identification of the steam generating unit operating days when the calculated 30-day average NOx emission rates are in excess of the NOx emission standard, including the reasons for the excess emissions and a description of corrective actions taken. (5) Identification of the steam generating unit operation days for which data have not been obtained including reasons for not obtaining sufficient data and a description of corrective actions taken. (6) Identification of the times when emission data have been excluded from the calculation of average emission rates and the reasons for excluding data. (7) Identification of "F" factor used for calculations, method of determination, and type of fuel combusted. (8) Identification of the times when the pollutant concentration exceeded full span of the CEMS. (9) Description of any modifications to the CEMS that could affect the ability of the CEMS to comply with Performance Specification 2 or 3. 40 CFR Section 60.49b(d); Minn. R. 7011.0565 40 CFR Section 60.49b(f); Minn. R. 7011.0565 40 CFR Section 60.49b(g); Minn. R. 7011.0565 continued from above

TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 12/28/10 Permit Number: 10900008-004 Subject Item: GP 002 Boilers and Generators Associated Items: EU 001 Boiler 1 EU 002 Boiler 2 EU 003 Boiler 3 EU 004 Generator 5 EU 005 Generator 6 EU 012 Generator 7 (Non-emergency CI; <10 liter/cyl; 2500 kw) EMISSION LIMITS What to do hdr Why to do it Sulfur Dioxide: less than or equal to 65.56 tons/year using 12-month Rolling Sum calculated monthly, as described below. MONITORING AND RECORDKEEPING Daily recordkeeping: Each day, record the total quantity of each type of fuel burned, and the sulfur content by weight of fuel oil in the tank from which oil is drawn on that day. Monthly Recordkeeping: SO2 Emissions Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000 (limit originally set 3/27/91) hdr Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000 Minn. R. 7007.0800, subp. 4 and 5 By the 15th day of each month, calculate and record the following: a. The total quantity of natural gas used in the GP002 units during the previous month (G), in million cubic feet b. The total quantity of sulfur contained in distillate oil used in the GP002 units during the month (S), in pounds, calculated by multiplying the gallons of oil with sulfur content "x" by "x" and the density of the oil (pounds/gallon), plus the gallons of oil with sulfur content "y" by "y" and the density of the oil, etc. c. The SO2 emissions for the previous months (E), in tons, using the following equation: E = 0.001 S + 0.0003 G, where: 0.001 = [(2 pounds of SO2/pound of sulfur) x (1 ton/2000 pounds)] and 0.0003 = [(0.6 pounds of SO2/million cubic feet of natural gas) x (1 ton/2000 pounds)] The 12-month rolling sum is calculated by summing the values of "E" calculated for the previous 12 months.

TABLE A: LIMITS AND OTHER REQUIREMENTS A-8 12/28/10 Facility Name: Permit Number: St Marys 10900008-004 Subject Item: EU 004 Generator 5 Associated Items: GP 002 Boilers and Generators SV 002 No. 5 Generator Stack What to do Why to do it Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R. 7011.2300, subp. 1 been attained Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to Minn. R. 7011.2300, subp. 2 emit from the unit is 0.0015 lb/mmbtu due to equipment design and allowable fuels. Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 004 will contain no more than 0.0015 percent by weight sulfur (15 ppmw) beginning October 1, 2010. Subpart ZZZZ Requirements - The following requirements are not effective until May 3, 2013 Carbon Monoxide: less than or equal to 23 parts per million (ppmvd) at 15% oxygen, or reduce CO emissions by 70% or more, beginning 5/3/2013. During periods of startup, you must minimize the engine's time spent at idle and minimize the startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. Comply with the applicable portions of Table 2b of 40 CFR part 63, Subpart ZZZZ, begining 5/3/2013 (applicability depends upon whether or not an oxidiation catalyst is used). Diesel Fuel Use: Beginning 5/3/2013, diesel fuel must meet the requirements in 40 CFR 80.510(b) for non-road diesel fuel. Beginning 5/3/2013: (a) You must be in compliance with the applicable emission limitations and operating limitations at all times; and (b) At all times, you must operate and maintain the generator and any 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 you to make any further efforts to reduce emissions if levels required by the standard have been achieved. Determination of whether such O&M 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 O&M procedures, review of O&M records, and inspection of the source. Initial Performance Test: due 180 days after 05/03/2013, according to the requirements of Table 4 of 40 CFR part 63, Subpart ZZZZ, and 40 CFR Section 63.6620(d)-(g). During the initial performance test, you must establish each applicable operating limitation in Table 2b of 40 CFR part 63, Subpart ZZZZ. You must conduct an initial compliance demonstration according to Table 5 of 40 CFR part 63, Subpart ZZZZ, within 180 days after 5/3/2013. Subsequent Performance Tests: Conduct subsequent performance tests every 8760 hours or 3 years, whichever comes first. If you are using a continuous parameter monitoring system (CPMS) as specified in Table 5 of 40 CFR part 63, Subpart ZZZZ, you must install, operate, and maintain the CPMS according to the requirements in 40 CFR Section 63.6612(b)(1)-(b)(8). Beginning 5/3/2013, monitor and collect data according to the following: Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averagea and calculations used to report emission or operating levels. You must, howerver, use all the valid data collected during all other periods. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan hdr 40 CFR Section 63.6603(a); Minn. R. 7011.8150 40 CFR Section 63.6603(a); Minn. R. 7011.8150 40 CFR Section 63.6604; Minn. R. 7011.8150 40 CFR Section 63.6605; Minn. R. 7011.8150 40 CFR Section 63.6612(a); 40 CFR Section 63.6630(b); Minn. R. 7011.8150 40 CFR Section 63.6612(a); 40 CFR Section 63.6630(a); Minn. R. 7011.8150 40 CFR Section 63.6615; Minn. R. 7011.8150 40 CFR Section 63.6625(b); Minn. R. 7011.8150 40 CFR Section 63.6635; Minn. R. 7011.8150

TABLE A: LIMITS AND OTHER REQUIREMENTS A-9 12/28/10 Permit Number: 10900008-004 Beginning 5/13/2013, you must demonstrate continuous compliance with the CO concentration or reduction requirements according to the methods in Table 6 of 40 CFR part 63, Supbart ZZZZ. Notification of Intent to conduct a performance test: due 60 days before the performance test is scheduled to begin. Notification of CMS performance evaluation: due simultaneously with the Notification of Intent to conduct a performance test. Notification of Compliance Status: If the initial compliance demonstration does not include a performance test, the Notification of Compliance Status must be submitted before the close of business on the 30th day following the completion of the initial compliance demonstration. If the initial compliance demonstration does include a performance test, the Notification of Compliance Status must be submitted efore the close of business on the 60th day following the completion of the initial compliance demonstratin. Semiannual Compliance Report: A semiannual compliance report meeting the requirements shown in Table 7 of 40 CFR part 63, subpart ZZZZ is required. The report may be submitted with the Semiannual Deviations Report as listed in Table B of this permit. The Report must include the information described in 40 CFR Section 63.6650(c) and Table 7 of 40 CFR part 63, subpart ZZZZ. Recordkeeping: Beginning 5/13/2013, you must keep the following records: - A copy of each notification and report submitted to comply with Subpart ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status; 40 CFR Section 63.6640(a); Minn. R. 7011.8150 40 CFR Section 63.6645(a) and (g); 40 CFR Section 63.7(b); 40 CFR Section 63.9(e); Minn. R. 7011.8150 40 CFR Section 63.6645(a); 40 CFR Section 63.9(g); Minn. R. 7011.8150 40 CFR Section 63.6645(a); 40 CFR Section 63.6630(c); 40 CFR Section 63.9(h); Minn. R. 7011.8150 40 CFR Section 63.6650(a), (b)(5), and (c); Minn. R. 7011.8150 40 CFR Section 63.6655(a) and (d); Minn. R. 7011.8150 - Records of the occurrence and duration of each malfunction of process equipment or air pollution control and monitoring equipment; - Records of performance tests and performance evaluations; - Records of all required maintenance performed on the air pollution control and monitoring equipment; - Records of actions taken during periods of malfunction to minimize emissions, including all corrective actions; and - Applicable records required by Table 6 of 40 CFR part 63, subpart ZZZZ. Recordkeeping for CEMS or CPMS: Beginning 5/3/2013, you must keep the following records: 40 CFR Section 63.6655(b); Minn. R. 7011.8150 - Records described in 40 CFR Section 63.10(b)(2)(vi) - (xi); - Previous (superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); and - Requests for alternatives to the relative accuracy test for CEMS or CPMS as required in 40 CFR Section 63.8(f)(6)(i) (if applicable).

TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 12/28/10 Facility Name: Permit Number: St Marys 10900008-004 Subject Item: EU 005 Generator 6 Associated Items: GP 002 Boilers and Generators SV 003 No. 6 Generator Stack What to do Why to do it Fuel: The Permittee shall burn only natural gas or diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Sulfur Content of Fuel: less than or equal to 15 parts per million by weight as specified at 40 CFR Section 80.510(b)(1) for nonroad diesel fuel. This requirement is effective October 1, 2010. Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.0015 lb/mmbtu due to equipment design and allowable fuels. Operating Hours: less than or equal to 1040 hours/year using 12-month Rolling Sum Recordkeeping - Hours of Operation: By the 15th day of each month, calculate and record the hours the generator was operated during the previous month, and the total hours operated during the previous 12 months. Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 005 will contain no more than 0.0015 percent by weight sulfur (15 ppmw) beginning October 1, 2010. Subpart ZZZZ Requirements - The following requirements are not effective until May 3, 2013 Carbon Monoxide: less than or equal to 23 parts per million (ppmvd) at 15% oxygen, or reduce CO emissions by 70% or more, beginning 5/3/2013. During periods of startup, you must minimize the engine's time spent at idle and minimize the startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. Comply with the applicable portions of Table 2b of 40 CFR part 63, Subpart ZZZZ, begining 5/3/2013 (applicability depends upon whether or not an oxidiation catalyst is used). Diesel Fuel Use: Beginning 5/3/2013, diesel fuel must meet the requirements in 40 CFR 80.510(b) for non-road diesel fuel. Beginning 5/3/2013: (a) You must be in compliance with the applicable emission limitations and operating limitations at all times; and (b) At all times, you must operate and maintain the generator and any 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 you to make any further efforts to reduce emissions if levels required by the standard have been achieved. Determination of whether such O&M 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 O&M procedures, review of O&M records, and inspection of the source. Initial Performance Test: due 180 days after 05/03/2013, according to the requirements of Table 4 of 40 CFR part 63, Subpart ZZZZ, and 40 CFR Section 63.6620(d)-(g). During the initial performance test, you must establish each applicable operating limitation in Table 2b of 40 CFR part 63, Subpart ZZZZ. You must conduct an initial compliance demonstration according to Table 5 of 40 CFR part 63, Subpart ZZZZ, within 180 days after 5/3/2013. Subsequent Performance Tests: Conduct subsequent performance tests every 8760 hours or 3 years, whichever comes first. If you are using a continuous parameter monitoring system (CPMS) as specified in Table 5 of 40 CFR part 63, Subpart ZZZZ, you must install, operate, and maintain the CPMS according to the requirements in 40 CFR Section 63.6612(b)(1)-(b)(8). Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; meets requirements of Minn. R. 7011.2300, subp. 2 Minn. R. 7011.2300, subp. 1 Minn. R. 7011.2300, subp. 2 Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000. Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21 and Minn. R. 7007.3000. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan hdr 40 CFR Section 63.6603(a); Minn. R. 7011.8150 40 CFR Section 63.6603(a); Minn. R. 7011.8150 40 CFR Section 63.6604; Minn. R. 7011.8150 40 CFR Section 63.6605; Minn. R. 7011.8150 40 CFR Section 63.6612(a); 40 CFR Section 63.6630(b); Minn. R. 7011.8150 40 CFR Section 63.6612(a); 40 CFR Section 63.6630(a); Minn. R. 7011.8150 40 CFR Section 63.6615; Minn. R. 7011.8150 40 CFR Section 63.6625(b); Minn. R. 7011.8150

TABLE A: LIMITS AND OTHER REQUIREMENTS A-11 12/28/10 Permit Number: 10900008-004 Beginning 5/3/2013, monitor and collect data according to the following: 40 CFR Section 63.6635; Minn. R. 7011.8150 Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averagea and calculations used to report emission or operating levels. You must, howerver, use all the valid data collected during all other periods. Beginning 5/13/2013, you must demonstrate continuous compliance with the CO concentration or reduction requirements according to the methods in Table 6 of 40 CFR part 63, Supbart ZZZZ. Notification of Intent to conduct a performance test: due 60 days before the performance test is scheduled to begin. Notification of CMS performance evaluation: due simultaneously with the Notification of Intent to conduct a performance test. Notification of Compliance Status: If the initial compliance demonstration does not include a performance test, the Notification of Compliance Status must be submitted before the close of business on the 30th day following the completion of the initial compliance demonstration. If the initial compliance demonstration does include a performance test, the Notification of Compliance Status must be submitted efore the close of business on the 60th day following the completion of the initial compliance demonstratin. Semiannual Compliance Report: A semiannual compliance report meeting the requirements shown in Table 7 of 40 CFR part 63, subpart ZZZZ is required. The report may be submitted with the Semiannual Deviations Report as listed in Table B of this permit. The Report must include the information described in 40 CFR Section 63.6650(c) and Table 7 of 40 CFR part 63, subpart ZZZZ. Recordkeeping: Beginning 5/13/2013, you must keep the following records: - A copy of each notification and report submitted to comply with Subpart ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status; 40 CFR Section 63.6640(a); Minn. R. 7011.8150 40 CFR Section 63.6645(a) and (g); 40 CFR Section 63.7(b); 40 CFR Section 63.9(e); Minn. R. 7011.8150 40 CFR Section 63.6645(a); 40 CFR Section 63.9(g); Minn. R. 7011.8150 40 CFR Section 63.6645(a); 40 CFR Section 63.6630(c); 40 CFR Section 63.9(h); Minn. R. 7011.8150 40 CFR Section 63.6650(a), (b)(5), and (c); Minn. R. 7011.8150 40 CFR Section 63.6655(a) and (d); Minn. R. 7011.8150 - Records of the occurrence and duration of each malfunction of process equipment or air pollution control and monitoring equipment; - Records of performance tests and performance evaluations; - Records of all required maintenance performed on the air pollution control and monitoring equipment; - Records of actions taken during periods of malfunction to minimize emissions, including all corrective actions; and - Applicable records required by Table 6 of 40 CFR part 63, subpart ZZZZ. Recordkeeping for CEMS or CPMS: Beginning 5/3/2013, you must keep the following records: 40 CFR Section 63.6655(b); Minn. R. 7011.8150 - Records described in 40 CFR Section 63.10(b)(2)(vi) - (xi); - Previous (superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); and - Requests for alternatives to the relative accuracy test for CEMS or CPMS as required in 40 CFR Section 63.8(f)(6)(i) (if applicable).

TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 12/28/10 Facility Name: Permit Number: St Marys 10900008-004 Subject Item: EU 006 Turbine Engine Associated Items: SV 004 Cogeneration Turbine Stack What to do EMISSION LIMITS AND OPERATING REQUIREMENTS hdr Why to do it Nitrogen Oxides: less than or equal to 190 parts per million at 15% O2, on a dry 40 CFR Section 60.332(a)(2); Minn. R. 7011.2350 basis Sulfur Content of Fuel: less than or equal to 0.80 percent by weight 40 CFR Section 60.333(b); Minn. R. 7011.2350 Fuel is limited to natural gas, as defined in 40 CFR Section 60.331(u). Minn. R. 7007.0800, subp. 2 MONITORING REQUIREMENTS The Permittee shall monitor the total sulfur content of the fuel being fired in the turbine, except as provided under 40 CFR Section 60.334(h)(3) Notwithstanding the provisions of 40 CFR Section 60.334(h)(1), the Permittee may elect not to monitor the total sulfur content of the gaseous fuel combusted in the turbine, if the gaseous fuel is demonstrated to meet the definition of natural gas in 40 CFR Section 60.331(u), regardless of whether an existing custom schedule approved by the administrator requiring such monitoring. The permittee shall follow the requirements of either 40 CFR Section 60.334(h)(3)(i) or (ii). [Note: The Permittee has stated their intent to follow 40 CFR Section 60.334(h)(3)(i).] The Permittee shall use the gas quality characteristics in a current, valid purchase contract, tariff sheet, or transportation contract for the gaseous fuel, specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or less, to make the demonstration that the fuel meets the definition of natural gas in 40 CFR Section 60.331(u). [Note: The Permittee has stated their intent to combust pipeline quality natural gas.] Custom Nitrogen Monitoring Schedule: The requirement to monitor the nitrogen content of the fuel is waived, provided only pipeline quality natural gas is combusted in the turbine. [Note: This custom schedule was approved through and is carried forward from the original Title V permit, issued 7/23/2003.] REPORTING REQUIREMENTS Reporting: If there is a change in fuel supply, the Permittee shall notify the MPCA of such change for re-examination of the custom fuel monitoring schedule. A substantial change in fuel quality shall be considered as a change in fuel supply. Sulfur monitoring shall be conducted weekly during the interim period when the custom fuel monitoring schedule is being re-examined. hdr 40 CFR Section 60.334(h)(1); Minn. R. 7011.2350 40 CFR Section 60.334(h)(3); Minn. R. 7011.2350 40 CFR Section 60.334(h)(3)(i); Minn. R. 7011.2350 40 CFR Section 60.334(c); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987 hdr 40 CFR Section 60.334(c); Minn. R. 7011.2350; EPA guidance memo dated August 14, 1987; EPA approval letter dated May 2, 2003

TABLE A: LIMITS AND OTHER REQUIREMENTS A-13 12/28/10 Facility Name: Permit Number: St Marys 10900008-004 Subject Item: EU 012 Generator 7 (Non-emergency CI; <10 liter/cyl; 2500 kw) Associated Items: GP 002 Boilers and Generators SV 005 No. 7 Generator Stack What to do LIMITS AND OPERATING RESTRICTIONS hdr Why to do it Fuel: The Permittee shall burn only diesel fuel oil in the generator. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan Fuel Requirements - Beginning October 1, 2010, the Permittee must use diesel fuel in EU 012 that meets the following requirements of 40 CFR Section 80.510(b) for nonroad diesel fuel: (1) Sulfur content maximum 15 ppm (for nonroad diesel); and, (2) Cetane index minimum of 40 or aromatic content maximum of 35% by volume. The provisions of pt. 60, subp. IIII apply to the Permittee for operation of EU 012 because EU 012 was manufactured after April 1, 2006, and the Permittee commenced construction of EU 012 after July 11, 2005. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan; 40 CFR Sections 60.4207(b) and 80.510(b); Minn. R. 7011.3520; 40 CFR Section 63.6590(c); Minn. R. 7011.8150 40 CFR Section 60.4200(a)(2)(i); Minn. R. 7011.3520 For the purposes of pt. 60, subp. IIII, the date that construction commences is the date EU 012 is ordered by the Permittee. The Permittee must install an EU 012 engine that meets the requirements for 2007 model year engines. Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.0015 lb/mmbtu due to equipment design and allowable fuels. Operating Hours: less than or equal to 2045 hours/year using 12-month Rolling Sum calculated monthly by the last day of each month. This limit may be revised based on results from emission factor testing required by this permit. 40 CFR Section 60.4208(a); Minn. R. 7011.3520; 40 CFR Section 63.6590(c); Minn. R. 7011.8150 Minn. R. 7011.2300, subp. 1 Minn. R. 7011.2300, subp. 2 Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21(b)(2)(i) and Minn. R. 7007.3000 During the initial 12 months of operation, the applicable operating hours limit as of month 'n' shall be the following: month 1 = 400 hrs month 2 = 650 hrs month 3 = 870 hrs month 4 = 1080 hrs month 5 = 1260 hrs month 6 = 1420 hrs month 7 = 1560 hrs month 8 = 1690 hrs month 9 = 1810 hrs month 10 = 1920 hrs month 11 = 2000 hrs month 12 = 2045 hrs MONITORING AND RECORDKEEPING REQUIREMENTS Recordkeeping - Operating Hours: by the last day of each calendar month, the Permittee shall: 1. record the EU 012 operating hours during the provious calendar month; and 2. calculate and record EU 012 operating hours during the previous 12-month period by summing the monthly operating hours records for the previous 12 months. Diesel Fuel Sulfur Content Certification: The Permittee shall obtain and retain a written guarantee from the fuel supplier indicating that each shipment of diesel fuel delivered to the Facility for use in EU 012 will contain no more than 0.0015 percent by weight sulfur (15 ppmw) beginning October 1, 2010. PART 60 SUBPART IIII REQUIREMENTS hdr Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21(b)(2)(i) and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5 Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50, and MN State Implementation Plan hdr The Permittee must comply with the emission standards in Section 60.4201(b) and table 1 of subp. IIII when operating EU 012. 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520; 40 CFR Section 63.6590(c); Minn. R. 7011.8150 Hyrocarbons: less than or equal to 1.3 grams/kilowatt-hour 40 CFR Sections 60.4204(b) and 60.4201(b); pt. 60, subp. IIII table 1; Minn. R. 7011.3520; 40 CFR Section 63.6590(c); Minn. R. 7011.8150