+ All Categories
Home > Documents > Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul...

Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul...

Date post: 17-Mar-2020
Category:
Upload: others
View: 3 times
Download: 0 times
Share this document with a friend
133
Draft Air Individual Permit Major Amendment 12300063-101 Permittee: District Energy St Paul Inc-Hans O Nyman Co-permittee name: St Paul Cogeneration; Ever-Green Energy, Inc.; Environmental Wood Supply, LLC Facility name: District Energy St Paul Inc-Hans O Nyman 76 Kellogg Blvd W Saint Paul, MN 55102-1611 Ramsey County Operating permit issuance date: January 29, 2016 Expiration date: January 29, 2021 * All Title I Conditions do not expire Major Amendment: [Amendment Issue Date] Permit characteristics: Federal; Part 70/ Major for NSR; True Minor for NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit amend are as described in the submittals listed in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No. 12300063-004 and authorizes the Permittee to modify 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. 7007.1150 to 7007.1500. 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 are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: [ ] This document has been electronically signed. for the Minnesota Pollution Control Agency for Don Smith, P.E., Manager Air Quality Permits Industrial Division
Transcript
Page 1: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Draft Air Individual Permit Major Amendment

12300063-101 Permittee: District Energy St Paul Inc-Hans O Nyman

Co-permittee name: St Paul Cogeneration; Ever-Green Energy, Inc.; Environmental Wood Supply, LLC

Facility name: District Energy St Paul Inc-Hans O Nyman 76 Kellogg Blvd W Saint Paul, MN 55102-1611 Ramsey County

Operating permit issuance date: January 29, 2016 Expiration date: January 29, 2021 * All Title I Conditions do not expire Major Amendment: [Amendment Issue Date] Permit characteristics: Federal; Part 70/ Major for NSR; True Minor for NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit amend are as described in the submittals listed in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No. 12300063-004 and authorizes the Permittee to modify 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. 7007.1150 to 7007.1500. 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 are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Signature: [ ] This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Air Quality Permits Industrial Division

Page 2: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 4. Summary of subject items ........................................................................................................................................... 6 5. Limits and other requirements .................................................................................................................................... 8 6. Submittal/action requirements ............................................................................................................................... 101 7. Appendices ............................................................................................................................................................... 116

Appendix A. Insignificant Activities and General Applicable Requirements .......................................................... 116 Appendix B. Fuel Mixture Procedure for EQUI 11 ................................................................................................. 118 Appendix C. Sulfur Dioxide Compliance Calculation for Boilers 2, 3, and 4 .......................................................... 119 Appendix D. Environmental Wood Supply PM10 Modeling Parameters ................................................................ 121 Appendix E. PM10 and NOx Modeling Parameters ............................................................................................... 123 Appendix F. SO2 Modeling Parameters .................................................................................................................. 124 Appendix G. Modeling Parameters used in Significant Impact Analysis for permit #12300063-101 .................... 125 Appendix H. Fugitive Emission Control Plan .......................................................................................................... 126

Page 3: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit issued: [month day, year] 12300063-101 Permit expires: [month day, year] Page 3 of 133

1. Permit applications table

Subsequent permit applications: Title description Application receipt date Action number Major Amendment 4/17/2018 (supplemental information

received 8/10/2018) 12300063-101

Page 4: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit issued: [month day, year] 12300063-101 Permit expires: [month day, year] Page 4 of 133

2. Where to send submittals

Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, 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. 20460

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

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 55155-4194

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)

Page 5: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit issued: [month day, year] 12300063-101 Permit expires: [month day, year] Page 5 of 133

3. Facility description

The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey County, Minnesota. District Energy St. Paul (the facility) provides heating and cooling services to downtown St. Paul and adjacent areas. The facility has seven boilers that produce hot water (Boilers 5 and 6) or steam (Boilers 1 through 4 and 7) for heating and electrical generation. Boilers 1, 4, 5, and 6 combust natural gas and distillate fuel oil. Boilers 2 and 3 combust coal, biomass, and natural gas. Boiler 7 combusts biomass and natural gas. The facility also has several emission sources such as wood and coal receiving, and ash handling and storage that qualify as insignificant sources. District Heating Development Company d/b/a District Energy St. Paul, Inc. (District Energy) is a majority owner of Ever-Green Energy, LLC (formerly Market Street Energy Company, LLC), and District Cooling St. Paul, Inc. is a minority owner. Ever-Green Energy, LLC manages operations at District Energy. Boiler 7 is a combined heat and power (CHP) boiler and is owned by St. Paul Cogeneration. St. Paul Cogeneration is jointly owned by Ever-Green Energy, LLC and DTE St. Paul LLC. St. Paul Cogeneration has a 20-year Power Purchase Agreement for the sale of electricity generated by the CHP boiler to District Energy. Environmental Wood Supply, LLC (EWS) is owned by Ever-Green Energy, Inc. EWS and District Energy are considered a single source under Prevention of Significant Deterioration (PSD) regulations. EWS is located approximately 3 miles south of the District Energy St. Paul facility and supplies clean cellulosic biomass to the District Energy St. Paul facility. The main pollutants of concern at the facility are the products of combustion: particulate matter (PM), particulate matter < 10 microns (PM10), particulate matter < 2.5 microns (PM2.5), sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic carbon (VOC), carbon dioxide equivalents (CO2e), and Hazardous Air Pollutants (HAPs). Particulate Matter from Boilers 2 and 3 is controlled by multiple cyclones. Particulate matter from coal ash storage is controlled by a medium-efficiency centrifugal collector and a fabric filter. NOx emissions from Boiler 7 are controlled by selective non-catalytic reduction (SNCR) with urea injection, and particulate matter from Boiler 7 is controlled by a high-efficiency centrifugal collector and an electrostatic precipitator (ESP). With this permit action, District Energy will be authorized to replace the existing burners in Boilers 2 and 3 with burners capable of burning natural gas, distillate fuel oil, and biodiesel. When this conversion is complete, District Energy will no longer receive, handle, or combust coal at their facility. At that time, the multiple cyclones controlling Boiler No. 2 and 3, the coal ash silo and associated controls, will be decommissioned in-place or removed from the facility. District Energy expects to continue burning coal through the 2018/2019 winter season and expect to begin the transition to burning primarily natural gas in Boilers 2 and 3 in time for the 2019/2020 season. Regardless of expectations, the permit is written with no set date required to cease coal combustion and the facility may continue to comply with their current requirements as long as they choose. A number of requirements will no longer apply once coal burning has ceased and are indicated as such in the permit.

Page 6: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit issued: [month day, year] 12300063-101 Permit expires: [month day, year] Page 6 of 133

4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

TFAC 1: District Energy St Paul Inc-Hans O Nyman

ACTV 3: All AI's COMG 1: Control Equipment for Boiler 7

has members

EQUI 11, TREA 3, TREA 4, TREA 14

COMG 2: Multiple Cyclones

has members

EQUI 1, EQUI 2, TREA 5, TREA 6

COMG 3: Wood Handling - EWS

has members

FUGI 1, FUGI 2, FUGI 3, FUGI 4, FUGI 5

COMG 4: NESHAP DDDDD Common Requirements

has members

EQUI 1, EQUI 2, EQUI 11, EQUI 14, EQUI 19, EQUI 20, EQUI 21

COMG 5: Continuous Emission Monitors (State)

has members

EQUI 1, EQUI 2, EQUI 3, EQUI 4, EQUI 9, EQUI 11, EQUI 14, STRU 5

COMG 6: NESHAP DDDDD Gas 1 Boiler with Curtailment

has members

EQUI 14, EQUI 19, EQUI 20, EQUI 21

COMG 7: Boilers 1, 5, and 6

has members

EQUI 19, EQUI 20, EQUI 21

COMG 8: Boilers 2, 3, and 4

has members

EQUI 1, EQUI 2, EQUI 14, STRU 5

COMG 9: Continuous Emission Monitors (NSPS)

has members

EQUI 5, EQUI 6, EQUI 7, EQUI 11, STRU 5

EQUI 1: Boiler 2 is monitored by

EQUI 31: Teledyne Opacity Monitor

EQUI 1: Boiler 2 is monitored by

EQUI 3: Sulfur Dioxide

EQUI 1: Boiler 2 is monitored by

EQUI 4: Diluent CO2 Monitor

EQUI 1: Boiler 2 sends to STRU 5: Boilers 2, 3, 4, and 7

EQUI 1: Boiler 2 is TREA 5:

SI ID: Description

Relationship Type

Related SI ID: Description

controlled by

Multiclone wo Fly Ash Reinj

EQUI 2: Boiler 3 is monitored by

EQUI 31: Teledyne Opacity Monitor

EQUI 2: Boiler 3 is monitored by

EQUI 3: Sulfur Dioxide

EQUI 2: Boiler 3 is monitored by

EQUI 4: Diluent CO2 Monitor

EQUI 2: Boiler 3 sends to STRU 5: Boilers 2, 3, 4, and 7

EQUI 2: Boiler 3 is controlled by

TREA 6: Multiclone wo Fly Ash Reinj

EQUI 3: Sulfur Dioxide EQUI 4: Diluent CO2 Monitor

EQUI 5: NOx Monitor EQUI 6: Diluent CO2 Monitor

EQUI 7: SO2 Monitor EQUI 8: Opacity monitor EQUI 9: NOx Monitor for Ammonia

EQUI 11: Boiler 7 is monitored by

EQUI 28: Oxygen analyzer

EQUI 11: Boiler 7 is monitored by

EQUI 29: Flow Monitor

EQUI 11: Boiler 7 is monitored by

EQUI 30: Teledyne CO Monitor

EQUI 11: Boiler 7 is monitored by

EQUI 5: NOx Monitor

EQUI 11: Boiler 7 is monitored by

EQUI 6: Diluent CO2 Monitor

EQUI 11: Boiler 7 is monitored by

EQUI 7: SO2 Monitor

EQUI 11: Boiler 7 is monitored by

EQUI 8: Opacity monitor

EQUI 11: Boiler 7 is EQUI 9: NOx

Page 7: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 7 of 133

SI ID: Description

Relationship Type

Related SI ID: Description

monitored by

Monitor for Ammonia

EQUI 11: Boiler 7 sends to STRU 5: Boilers 2, 3, 4, and 7

EQUI 11: Boiler 7 is controlled by

TREA 14: Selective Noncatalytic Reduction for NOX

EQUI 11: Boiler 7 is controlled by

TREA 3: Centrifugal Collector - High Efficiency

EQUI 11: Boiler 7 is controlled by

TREA 4: Electrostatic Precipitator - High Efficiency

EQUI 12: Coal Ash Silo sends to STRU 8: Coal Ash Silo

EQUI 12: Coal Ash Silo is controlled by

TREA 7: Centrifugal Collector - Medium Efficiency

EQUI 12: Coal Ash Silo is controlled by

TREA 8: Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EQUI 14: Boiler 4 is monitored by

EQUI 31: Teledyne Opacity Monitor

EQUI 14: Boiler 4 is monitored by

EQUI 3: Sulfur Dioxide

EQUI 14: Boiler 4 is monitored by

EQUI 4: Diluent CO2 Monitor

EQUI 14: Boiler 4 sends to STRU 5: Boilers 2, 3, 4, and 7

EQUI 19: Boiler 1 sends to STRU 6: Boiler 1

EQUI 20: Boiler 5 sends to STRU 7: Boilers 5 and 6

EQUI 21: Boiler 6 sends to STRU 7: Boilers 5 and 6

EQUI 28: Oxygen analyzer

EQUI 29: Flow Monitor

SI ID: Description

Relationship Type

Related SI ID: Description

EQUI 30: Teledyne CO Monitor

EQUI 31: Teledyne Opacity Monitor

FUGI 1: Unpaved Roads- Delivery and Haul Trucks

FUGI 2: Wood Chip Pile FUGI 3: Unpaved Roads- Front-end Loaders

FUGI 4: Wood Chip Loading

FUGI 5: Wood Grinders STRU 5: Boilers 2, 3, 4, and 7

STRU 6: Boiler 1 STRU 7: Boilers 5 and 6 STRU 8: Coal Ash Silo TREA 3: Centrifugal Collector - High Efficiency

TREA 4: Electrostatic Precipitator - High Efficiency

TREA 5: Multiclone wo Fly Ash Reinj

TREA 6: Multiclone wo Fly Ash Reinj

TREA 7: Centrifugal Collector - Medium Efficiency

is controlled in series by

TREA 8: Fabric Filter - Low Temperature, i.e., T<180 Degrees F

TREA 8: Fabric Filter - Low Temperature, i.e., T<180 Degrees F

TREA 14: Selective Noncatalytic Reduction for NOX

is controlled in series by

TREA 3: Centrifugal Collector - High Efficiency

TREA 14: Selective Noncatalytic Reduction for NOX

is controlled in series by

TREA 4: Electrostatic Precipitator - High Efficiency

Page 8: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit issued: [month day, year] 12300063-101 Permit expires: [month day, year] Page 8 of 133

5. Limits and other requirements

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 1 12300063 District Energy St

Paul Inc-Hans O Nyman

5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices: A. Insignificant Activities and General Applicable Requirements, B. Fuel Mixture Procedure for EQUI 11, C. Sulfur Dioxide Compliance Calculation for Boilers 2, 3, and 4, and H. Fugitive Emission Control Plan. Modeling parameters in Appendices D (Environmental Wood Supply PM10 Modeling Parameters), E (PM10 and NOx Modeling Parameters), F (SO2 Modeling Parameters), and G (Modeling Parameters used in Significant Impact Analysis for permit 12300063-101) are included for reference only as described elsewhere in this permit. [Minn. R. 7007.0800, subp. 2]

5.1.2 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. 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. 7007.1800(A)(2)]

5.1.3 Access areas, road, parking facilities: No person shall cause or permit the use of access areas surrounding coal stockpiles and use of all active truck haul roads and parking facilities which are located within a coal handling facility whose coal throughput by truck is less than 200,000 tons per year unless such areas and roads are treated with water, oils, or chemical agents. This requirement will no longer apply when the facility is no longer a coal handling facility. [Minn. R. 7011.1105(A)(2)]

5.1.4 Coal loading stations: Control fugitive particulate emissions from the loading of trucks, haulers, and railcars by dust suppression methods so that emissions from such sources are minimized. This requirement will no longer apply when the facility is no longer a coal handling facility. [Minn. R. 7011.1105(B)]

5.1.5 Truck and hauler unloading stations: Control fugitive particulate emissions from the unloading of trucks or haulers by dust suppression methods so that emissions from such sources are minimized. This requirement will no longer apply when the facility is no longer a coal handling facility. [Minn. R. 7011.1105(C)]

Page 9: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 9 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.1.6 Clean up all coal spilled on roads or access areas as soon as

practicable using methods that minimize the amount of dust suspended. This requirement will no longer apply when the facility is no longer a coal handling facility. [Minn. R. 7011.1105(I)]

5.1.7 Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the fugitive emission control plan in Appendix H of this permit. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0020, Minn. R. 7011.0150, Minn. Stat. 116.07, subd. 4a]

5.1.8 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 52.21(r)(6)(vi)(b). 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. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.9 Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing emission unit, and the projected post-change potential emissions of any affected existing or new emission unit. 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 emission unit 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.

Page 10: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 10 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.10 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. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.11 Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1-4 under Preconstruction Documentation, above) to the Agency. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6)(ii) and Minn. R. 7007.3000]

5.1.12 For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person. b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project analyzed as part of a hybrid test. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.13 For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual, plus potential 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: 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 rate is exceeded.

Page 11: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 11 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.14 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0090. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.15 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. 7011.0020]

5.1.16 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

5.1.17 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

5.1.18 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. 7019.1000, subp. 4]

5.1.19 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. [Minn. R. 7011.0150]

5.1.20 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. [Minn. R. 7030.0010-7030.0080]

Page 12: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 12 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.1.21 Inspections: The Permittee shall comply with the inspection

procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

5.1.22 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

5.1.23 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]

5.1.24 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. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

5.1.25 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. 7007.0800, subp. 4(D)]

5.1.26 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. 7007.0800, subp. 4(D)]

5.1.27 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. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

5.1.28 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.

Page 13: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 13 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.29 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. For expiring permits, 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. [Minn. R. 7007.1200, subp. 4]

5.1.30 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. [Minn. R. 7019.1000, subp. 3]

5.1.31 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. 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. 7019.1000, subp. 2]

5.1.32 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. 7019.1000, subp. 1]

5.1.33 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description:

Page 14: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 14 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 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. 7019.1000, subp. 1]

5.1.34 Application for Permit Amendment: If a permit amendment is needed, submit an 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. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

5.1.35 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. 7007.1400, 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. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

5.1.36 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.37 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

5.1.38 Modeled Parameters for PM10 at the wood handling facility: The parameters used in PM10 modeling of the wood handling facility are listed in Appendix D 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. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.39 Modeled Parameters for NOx and PM10 at the District Energy St. Paul facility: The parameters used in NOx and PM10 modeling are listed in Appendix E 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. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.40 Modeled Parameters for SO2 at the District Energy St. Paul facility:

Page 15: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 15 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The parameters used in SO2 modeling are listed in Appendix F 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. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.41 Changes to Modeled Parameters for NOx or PM10: Any permit amendment that affects any modeled parameter or emission rate for NOx or PM10 listed in Appendix E must be a major amendment. Any addition to the information documented in Appendix E requires a major amendment. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.42 Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for SO2: Any changes that affect any modeled SO2parameter or emission rate listed in Appendix E, or an addition to the information documented in Appendix E, trigger the EBD Remodeling Submittal requirement. This includes changes that do not require a permit amendment as well as changes that require any type of permit amendment. Changes made under the Administrative amendment process are excluded from this requirement. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.43 EBD Modeling Submittal for SO2: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. For changes that do not require a moderate or major amendment, written approval of the EBD modeling may be given before permit issuance; however, this approval applies only to the EBD modeling and not to any other changes. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.44 EBD Modeling Submittal Content for SO2: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2,

Page 16: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 16 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.45 Outdated EBD Baseline Modeling for SO2: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.46 EBD Modeling Results for SO2: The dispersion characteristics due to the revisions of the information in Appendix F must be equivalent to or better than the dispersion characteristics modeled in 1995. The Permittee shall demonstrate this equivalency in the proposal. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.47 Computer Dispersion Modeling Triggers for SO2: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.48 Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for SO2 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.49 Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for

Page 17: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 17 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation SO2 modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.50 Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for SO2. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0010-7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.51 Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for NOx or PM10: Changes that affect any modeled parameter or emission rate listed in Appendix E, or an addition to the information documented in Appendix E, trigger the EBD Modeling Submittal requirement. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.52 EBD Modeling Submittal for NOx or PM10: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (in the form of an issued permit amendment) before making such changes. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.53 EBD Modeling Submittal Content for NOx or PM10: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.54 Outdated EBD Baseline Modeling for NOx or PM10: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

Page 18: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 18 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.1.55 EBD Modeling Results for NOx or PM10: The dispersion

characteristics due to the revisions of the information in Appendix E must be equivalent to or better than the dispersion characteristics modeled in 2001. The Permittee shall demonstrate this equivalency in the proposal. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.56 Computer Dispersion Modeling Triggers for NOx or PM10: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.57 Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for NOx or PM10 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.58 Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for NOx or PM10 modeling. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.59 Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for NOx or PM10. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

COMG 1 GP004 Control

Equipment for Boiler 7

5.2.1 The Permittee shall vent emissions from EQUI 11 to TREA 3 and TREA 4 whenever EQUI 11 operates, and operate and maintain TREA 3 and TREA 4 at all times that any emissions are vented to TREA 3 and TREA 4. The Permittee shall document periods of non-operation of TREA3 or TREA4 whenever EQUI 11 is operating. See TREA 3 and TREA 4 for monitoring and recordkeeping requirements. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R.

Page 19: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 19 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.3000]

5.2.2 The Permittee shall operate and maintain TREA 3 and TREA 4 such that they achieve an overall control efficiency for Particulate Matter >= 91.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.2.3 The Permittee shall operate and maintain TREA 3 and TREA 4 such that they achieve an overal control efficiency for PM < 10 micron >= 90.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.2.4 The Permittee shall operate and maintain TREA 3 and TREA 4 such that they achieve an overall control efficiency for PM < 2.5 micron >= 81 percent control efficiency. [Minn. R. 7007.0800, subps.2&14]

COMG 2 GP003 Multiple

Cyclones

5.3.1 The Permittee shall vent emissions from EQUI 1 to TREA 5 whenever EQUI 1 operates, and operate and maintain TREA 5 at all times that any emissions are vented to TREA 5. The Permittee shall document periods of non-operation of the control equipment when EQUI 1 is operating. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0800, subp. 14]

5.3.2 The Permittee shall vent emissions from EQUI 2 to TREA 6 whenever EQUI 2 operates, and operate and maintain TREA 6 at all times that any emissions are vented to TREA 6. The Permittee shall document periods of non-operation of the control equipment when EQUI 2 is operating. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0800, subp. 14]

5.3.3 The Permittee shall operate and maintain each control equipment such that it achieves a control efficiency for Particulate Matter >= 90.0 percent control efficiency. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.3.4 The Permittee shall operate and maintain each control equipment such that it achieves a control efficiency for PM < 10 micron >= 72.0 percent control efficiency. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.3.5 The Permittee shall operate and maintain each control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 72.0 percent control efficiency. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.3.6 Pressure Drop >= 0.5 and <= 4.0 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new

Page 20: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 20 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.3.7 The Permittee shall operate and maintain the control equipment in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. This requirement will no longer apply after the facility ceases coal combustion. [Minn. R. 7007.0800, subp. 14]

5.3.8 The Permittee shall maintain and operate a pressure drop monitoring device that continuously indicates and records the pressure drop across each multiclone. The recording device shall also calculate the three-hour rolling average pressure drop. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.3(b)(4)(ii), Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. R. 7017.0200, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.3.9 The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop readings and calculated three hour rolling average pressure drop. Recorded values outside the range specified in this permit are considered deviations as defined by Minn. R. 7007.0100, subp. 8a. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.3.10 Annual Calibration: The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.3, Minn. R. 7017.0200]

5.3.11 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.3, Minn. R. 7017.0200]

5.3.12 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded 3-hr average pressure drop is outside the required operating range; or - the multiclones or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the

Page 21: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 21 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the multiclones. The Permittee shall keep a record of the type and date of any corrective action taken for each control device. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

5.3.13 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored multiclone is in operation. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.3.14 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.3.15 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed in this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.3.16 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. This requirement will no longer apply after the facility ceases coal combustion. [40 CFR 64.9(b), Minn. R. 7017.0200]

COMG 3 GP009 Wood Handling -

EWS

5.4.1 Process Throughput <= 425000 tons per year 12-month rolling sum of wood processed through the wood grinders (FUGI 5). [CAAA of

Page 22: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 22 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 1990, Minn. R. 7007.0100, subps. 7(A) & 7(B), Minn. R. 7007.0800, subps. 1-2, Minn. Stat. 116.07, subds.4a&9, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.2 Process Throughput <= 48.5 tons per hour on a 24-hr rolling average of wood processed through the wood grinders (FUGI 5). [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0090, Minn. R. 7011.0150, Minn. Stat. 116.07, subds.4a&9]

5.4.3 The Permittee shall post and enforce a site-wide speed limit of 5 miles per hour. This limit shall apply to all haul trucks and front-end loaders traversing the site. [CAAA of 1990, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.100, subps. 7(A) & 7(B), Minn. Stat. 116.07, subds.4a&9, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.4 The Permittee shall water once per 12-hour period all haul routes traveled by all front-end loaders and haul trucks traversing the site unless there is a 0.16 inches or greater of rainfall in that time period, the road is visibly muddy or wet, or the temperature is below freezing. Watering is not required between November 1st and March 31st. [CAAA of 1990, Minn. R. 7007.0100, subps. 7(A) & 7(B), Minn. R. 7007.0800, subps. 1-2, Minn. Stat. 116.07, subds.4a&9, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.5 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. [Minn. R. 7011.0150]

5.4.6 Daily Recordkeeping - Throughput: On each day of operation, the Permittee shall record and maintain records of the total quantity of all wood processed by the wood grinders (FUGI 5) in tons. This shall be based on delivery records and processing logs. [CAAA of 1990, Minn. R. 7007.0100, subps. 7(A) & 7(B), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. Stat. 116.07, subds.4a&9, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.4.7 Monthly Recordkeeping - Throughput: By the 15th of the month, the Permittee shall calculate and record the following using daily production records: 1) Throughput of wood processed through the wood grinders (FUGI 5) for the previous month in tons using daily records. 2) The 12-month rolling sum of throughput of wood processed through the wood grinders (FUGI 5) for the previous 12 month period by summing the monthly data for the previous 12 months. 3) The Permittee shall calculate and record the 24-hour rolling average of process throughput average for the previous month using the daily hours of operation records to demonstrate compliance with the tons/hour process throughput limit. [Minn. R.

Page 23: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 23 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.0800, subps. 4-5]

5.4.8 Daily Recordkeeping: The Permittee shall keep records of the water applications, including the following: a. Day and time of water application. If water was not applied, it must be noted in the record along with the reason for not watering (i.e. on-site rain gauge or road condition observation or temperature). b. Records of watering equipment breakdowns and repairs, and records of contingency efforts undertaken. c. Whether or not visible emissions were observed. If visible emissions are observed record the source of those emissions and the corrective actions undertaken. [CAAA of 1990, Minn. R. 7007.0100, subps. 7(A) & 7(B), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. Stat. 116.07, subds.4a&9, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

COMG 4 GP008 NESHAP DDDDD

Common Requirements

5.5.1 40 CFR pt. 63 General Provisions: 40 CFR pt. 63, subp. DDDDD, Table 10 shows which parts of the General Provisions in 40 CFR Sections 63.1-63.15 apply. [40 CFR 63.7565, Minn. R. 7011.7050]

5.5.2 At all times, the Permittee must operate and maintain any affected source (as defined in 40 CFR Section 63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR 63.7500(a)(3), Minn. R. 7011.7050]

5.5.3 General Compliance Requirements. The Permittee must be in compliance with the emission limits, work practice standards, and operating limits in 40 CFR pt. 63, subp. DDDDD. These limits apply at all times the affected unit is operating, except during periods of startup and shutdown during which time the Permittee must comply only with 40 CFR pt. 63, subp. DDDDD, Table 3. [40 CFR 63.7500(f), 40 CFR 63.7505(a), Minn. R. 7011.7050]

5.5.4 General Compliance Requirements. The Permittee must demonstrate compliance with all applicable emission limits using performance stack testing, fuel analysis, or CMS, including a CEMS, COMS, CPMS, or PM CPMS, where applicable. The Permittee may demonstrate compliance with the applicable emission limit for HCl, mercury, or TSM using fuel analysis if the emission rate calculated according to 40 CFR Section 63.7530(c) is less than the applicable emission limit. (For gaseous fuels, the Permittee may not use fuel analyses to comply with the TSM alternative standard or the HCl

Page 24: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 24 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation standard.) Otherwise, the Permittee must demonstrate compliance for HCl, mercury, or TSM using performance testing, if subject to an applicable emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7505(c), Minn. R. 7011.7050]

5.5.5 General Compliance Requirements - Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with 40 CFR pt. 63, subp. DDDDD. Such concealment includes, but is not limited to: - the use of diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD based on the concentration of a pollutant in the effluent discharged to the atmosphere; or - the use of gaseous diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

5.5.6 General Compliance Requirements. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(2)(iii). [40 CFR 63.6(f)(2), Minn. R. 7011.7000]

5.5.7 Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(f)(3), Minn. R. 7011.7000]

5.5.8 Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with an opacity or visible emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD and any information available needed to determine whether proper operation and maintenance practices are being used. [40 CFR 63.6(h)(8), Minn. R. 7011.7000]

5.5.9 If the Commissioner or the Administrator finds that the affected source is in compliance with all relevant standards for which initial performance tests were conducted, but during the time such performance tests were conducted fails to meet any relevant opacity emission standard, the Permittee may petition the Administrator to make appropriate adjustment to the opacity emission standard for the affected source. Until the Administrator notifies the Permittee, the relevant opacity emission standard remains applicable. [40 CFR 63.6(h)(9), Minn. R. 7011.7000]

5.5.10 The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR Section 63.6(g). [40 CFR 63.6(g), Minn. R. 7011.7000]

5.5.11 Methods for Determining Compliance. Compliance with opacity

Page 25: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 25 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation emission standards shall be determined by using the results from the COMS. [40 CFR 63.6(h)(2), Minn. R. 7011.7000]

5.5.12 The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). [40 CFR 63.6(i), Minn. R. 7011.7000]

5.5.13 Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. [40 CFR 63.6(i)(1), Minn. R. 7011.7000]

5.5.14 The Permittee must meet the work practice standard according to 40 CFR pt. 63, subp. DDDDD, Table 3. During startup and shutdown, the Permittee must only follow the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7530(h), Minn. R. 7011.7050]

5.5.15 For each boiler that is required or that the Permittee elects to demonstrate compliance with any of the applicable emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2 through performance testing, the initial compliance requirements include all the following: - Conduct performance tests according to 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5. - Conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6, except as specified in 40 CFR Section 63.7510(a)(2)(i)-(iii). - Establish operating limits according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7. - Conduct CMS performance evaluations according to 40 CFR Section 63.7525. [40 CFR 63.7510(a), Minn. R. 7011.7050]

5.5.16 For existing affected sources (as defined in 40 CFR Section 63.7490) that have not operated between the effective date of 40 CFR pt. 63, subp. DDDDD and January 31, 2016, the Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) no later than 30 days after the re-start of the affected source and complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3, no later than the compliance date specified in 40 CFR Section 63.7495. [40 CFR 63.7510(j), Minn. R. 7011.7050]

5.5.17 The Permittee must demonstrate initial compliance with each emission limit that applies by conducting initial performance tests and fuel analyses and establishing operating limits, as applicable, according to 40 CFR Section 63.7520, 40 CFR Section 63.7530(b) and (c), and 40 CFR pt. 63, subp. DDDDD, Tables 5 and 7. The requirement to conduct a fuel analysis is not applicable for units that burn a single type of fuel, as specified by 40 CFR Section 63.7510(a)(2)(i). If applicable, the Permittee must also install, operate, and maintain all applicable CMS (including CEMS, COMS, and CPMS) according to 40 CFR Section 63.7525. [40 CFR 63.7530(a), Minn. R. 7011.7050]

Page 26: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 26 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.5.18 Following the date on which the initial compliance demonstration is

completed or is required to be completed under 40 CFR Sections 63.7 and 63.7510, whichever date comes first, operation above the established maximum or below the established minimum operating limits shall constitute a deviation of established operating limits listed in 40 CFR pt. 63, subp. DDDDD, Table 4 except during performance tests conducted to determine compliance with the emission limits or to establish new operating limits. Operating limits must be confirmed or reestablished during performance tests. [40 CFR 63.7540(a)(1), Minn. R. 7011.7050]

5.5.19 The Permittee must report each instance in which the Permittee did not meet each emission limit and operating limit in 40 CFR pt. 63, subp. DDDDD, Tables 2-4 that apply. These instances are deviations from the emission limits or operating limits, respectively, in 40 CFR pt. 63, subp. DDDDD. These deviations must be reported according to the requirements in 40 CFR Section 63.7550. [40 CFR 63.7540(b), Minn. R. 7011.7050]

5.5.20 The Permittee must report the results of performance tests and the associated fuel analyses within 60 days after the completion of the performance tests. This report must also verify that the operating limits for each boiler have not changed or provide documentation of revised operating limits established according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7, as applicable. The reports for all subsequent performance tests must include all applicable information required in 40 CFR Section 63.7550. [40 CFR 63.7515(f), Minn. R. 7011.7050]

5.5.21 For affected sources that have not operated since the previous compliance demonstration and more than one year has passed since the previous compliance demonstration, you must complete the subsequent compliance demonstration, if subject to the emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2, no later than 180 days after the re-start of the affected source and according to the applicable provisions in 40 CFR Section 63.7(a)(2) as cited in 40 CFR pt. 63, subp. DDDDD, Table 10. The Permittee must complete a subsequent tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) and the schedule described in 40 CFR Section 63.7540(a)(13) for units that are not operating at the time of their scheduled tune-up. [40 CFR 63.7515(g), Minn. R. 7011.7050]

5.5.22 The Permittee must conduct tune-ups of boilers demonstrate compliance as specified below: - As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned

Page 27: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 27 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation entries into the storage vessel or process equipment; - Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; - Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; - Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; - Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [40 CFR 63.7540(a)(10)(i)-(v), Minn. R. 7011.7050]

5.5.23 Maintain on-site and submit, if requested by the Administrator, a report containing the information below: - The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler; - A description of any corrective actions taken as a part of the tune-up; and - The type and amount of fuel used over the 12 months prior to the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [40 CFR 63.7540(a)(10)(vi), Minn. R. 7011.7050]

5.5.24 The energy assessment must include the following with extent of the evaluation for the items below appropriate for the on-site technical hours listed in 40 CFR Section 63.7575: - A visual inspection of the boiler system; - An evaluation of operating characteristics of the boiler systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints; - An inventory of major energy use systems consuming energy from affected boilers and which are under the control of the Permittee; - A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage; - A review of the facility's energy management practices, and provide recommendations for improvements consistent with the definition of energy management practices, if identified; - A list of cost-effective energy conservation measures that are within the facility's control;

Page 28: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 28 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation - A list of the energy savings potential of the energy conservation measures identified; and - A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. [40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.5.25 The energy assessment for facilities with affected boilers and process heaters with a combined heat input capacity greater than 1.0 TBtu/year will be up to 24 on-site technical labor hours in length for the first TBtu/yr plus 8 on-site technical labor hours for every additional 1.0 TBtu/yr not to exceed 160 on-site technical hours, but may be longer at the discretion of the Permittee. The boiler system(s), process heater(s), and any on-site energy use system(s) accounting for at least 20 percent of the energy (e.g., steam, process heat, hot water, or electricity) production, as applicable, will be evaluated to identify energy savings opportunities. [40 CFR 63.7575, Minn. R. 7011.7050]

5.5.26 Stack Tests and Procedures. The Permittee must conduct all performance tests according to 40 CFR Section 63.7(c), (d), (f), and (h). The Permittee must also develop a Site-Specific Test Plan according to the requirements in 40 CFR Section 63.7(c). The Permittee shall conduct all performance tests under such conditions as the Administrator specifies based on the representative performance of each boiler for the period being tested. Upon request, the Permittee shall make available to the Administrator such records as may be necessary to determine the conditions of the performance tests. [40 CFR 63.7520(a), Minn. R. 7011.7050]

5.5.27 Stack Tests and Procedures. The Permittee must conduct each performance test according to the requirements in 40 CFR pt. 63, subp. DDDDD, Table 5. [40 CFR 63.7520(b), Minn. R. 7011.7050]

5.5.28 Stack Tests and Procedures. The Permittee must conduct each performance test under the specific conditions listed in 40 CFR pt. 63, subp. DDDDD, Tables 5 and 7. The Permittee must conduct performance tests at representative operating load conditions while burning the type of fuel or mixture of fuels that has the highest content of chlorine and mercury and the Permittee must demonstrate initial compliance and establish operating limits based on these performance tests. These requirements could result in the need to conduct more than one performance test. Following each performance test and until the next performance test, the Permittee must comply with the operating limit for operating load conditions specified in 40 CFR pt. 63, subp. DDDDD, Table 4. [40 CFR 63.7520(c), Minn. R. 7011.7050]

5.5.29 Stack Tests and Procedures. The Permittee must conduct a minimum of three separate test runs for each performance test required in 40 CFR Section 63.7520, as specified in 40 CFR Section 63.7(e)(3). Each test run must comply with the minimum applicable sampling times or volumes specified in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7520(d), Minn. R. 7011.7050]

5.5.30 Stack Tests and Procedures. To determine compliance with the

Page 29: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 29 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation emission limits, the Permittee must use the F-Factor methodology and equations in Sections 12.2 and 12.3 of EPA Reference Method 19 to convert the measured PM concentrations that result from the performance test to pounds per million Btu heat input emission rates. [40 CFR 63.7520(e), Minn. R. 7011.7050]

5.5.31 Stack Tests and Procedures. Except for a 30-day rolling average based on CEMS data, if measurement results for any pollutant are reported as below the method detection level, the Permittee must use the method detection level as the measured emissions level for that pollutant in calculating compliance. The measured result for a multiple component analysis may include a combination of method detection level data and analytical data reported above the method detection level. [40 CFR 63.7520(f), Minn. R. 7011.7050]

5.5.32 Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must collect a minimum of 2 dry standard cubic meters of sample gas per run. [40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.5.33 Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must: - Select sampling ports location and the number of traverse points using Method 1 at 40 CFR pt. 60, Appendix A-1; - Determine velocity and volumetric flow-rate of the stack gas using Method 2, 2F, or 2G at 40 CFR pt. 60, Appendix A-1 or A-2; - Determine oxygen or carbon dioxide concentration of the stack gas using Method 3A or 3B at 40 CFR pt. 60, Appendix A-2, or ANSI/ASME PTC 19.10-1981; - Measure the moisture content of the stack gas using Method 4 at 40 CFR pt. 60, Appendix A-3; - Measure the PM emission concentration using Method 5 or 17 at 40 CFR pt. 60, Appendix A-3 or A-6; and - Convert emissions concentration to lb per MMBtu emission rates using Method 19 F-factor methodology at 40 CFR pt. 60, Appendix A-7. [40 CFR pt. 63, subp. DDDDD(Table 5), Minn. R. 7011.7050]

5.5.34 Stack Tests and Procedures. To conduct a performance test for mercury, the Permittee must: a. Select sampling ports location and the number of traverse points using Method 1 at 40 CFR part 60, appendix A-1. b. Determine velocity and volumetric flow-rate of the stack gas using Method 2, 2F, or 2G at 40 CFR part 60, appendix A-1 or A-2. c. Determine oxygen or carbon dioxide concentration of the stack gas using Method 3A or 3B at 40 CFR part 60, appendix A-1 , or ANSI/ASME PTC 19.10-1981.a d. Measure the moisture content of the stack gas using Method 4 at 40 CFR part 60, appendix A-3. e. Measure the mercury emission concentration using Method 29, 30A, or 30B (M29, M30A, or M30B) at 40 CFR part 60, appendix A-8 or Method 101A at 40 CFR part 61, appendix B , or ASTM Method D6784.a f. Convert emissions concentration to lb per MMBtu emission rates using Method 19 F-factor methodology at 40 CFR part 60, appendix

Page 30: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 30 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation A-7. [40 CFR pt. 63, DDDDD(Table 5), Minn. R. 7011.7050]

5.5.35 Stack Tests and Procedures. To conduct a performance test for hydrogen chloride, the Permittee must: a. Select sampling ports location and the number of traverse points using Method 1 at 40 CFR part 60, appendix A-1. b. Determine velocity and volumetric flow-rate of the stack gas using Method 2, 2F, or 2G at 40 CFR part 60, appendix A-2. c. Determine oxygen or carbon dioxide concentration of the stack gas using Method 3A or 3B at 40 CFR part 60, appendix A-2 , or ANSI/ASME PTC 19.10-1981.a d. Measure the moisture content of the stack gas using Method 4 at 40 CFR part 60, appendix A-3. e. Measure the hydrogen chloride emission concentration using Method 26 or 26A (M26 or M26A) at 40 CFR part 60, appendix A-8. f. Convert emissions concentration to lb per MMBtu emission rates using Method 19 F-factor methodology at 40 CFR part 60, appendix A-7. [40 CFR pt. 63, DDDDD(Table 5), Minn. R. 7011.7050]

5.5.36 Site-Specific Test Plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Commissioner or the Administrator, shall submit a Site-Specific Test Plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). [40 CFR 63.7(c)(2), Minn. R. 7017.2015]

5.5.37 Site-Specific Test Plan. The Administrator will notify the Permittee of approval or intention to deny approval of the Site-Specific Test Plan (if review of the Site-Specific Test Plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. [40 CFR 63.7(c)(3), Minn. R. 7017.2015]

5.5.38 Performance Testing Facilities. The Permittee, at the request of the Commissioner or the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). [40 CFR 63.7(d), Minn. R. 7017.2015]

5.5.39 Conduct of Performance Tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in 40 CFR pt. 63, subp. DDDDD, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). [40 CFR 63.7(e)(2), Minn. R. 7017.2015]

5.5.40 Conduct of Performance Tests. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in 40 CFR pt. 63, subp. DDDDD. For the purpose of determining compliance with 40 CFR pt. 63, subp. DDDDD, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). [40 CFR 63.7(e)(3), Minn. R. 7017.2015]

Page 31: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 31 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.5.41 Data Analysis, Recordkeeping, and Reporting. Unless otherwise

specified in 40 CFR pt. 63, subp. DDDDD or test method, or as otherwise approved by the Commissioner or Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The Permittee shall report the results of the performance test to the Commissioner or Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in 40 CFR pt. 63, subp. DDDDD or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. [40 CFR 63.7(g), Minn. R. 7017.2015]

5.5.42 Waiver of Performance Tests. Until a waiver of a performance testing requirement has been granted by the Commissioner or the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). [40 CFR 63.7(h), Minn. R. 7017.2015]

5.5.43 Conduct of Opacity or Visible Emission Observations. For initial compliance, opacity or visible emission observations shall be conducted concurrently with the initial performance test unless otherwise specified in 40 CFR Section 63.6(h)(5)(A) and (B). [40 CFR 63.6(h)(5), Minn. R. 7011.7000]

5.5.44 General Fuel Analysis Requirements. The Permittee must conduct fuel analyses for chloride and mercury according to the procedures in 40 CFR Section 63.7521(b)-(e) and 40 CFR pt. 63, subp. DDDDD, Table 6, as applicable. The Permittee is not required to conduct fuel analyses for fuels used for only startup, unit shutdown, and transient flame stability purposes. The Permittee is required to conduct fuel analyses only for fuels and units that are subject to emission limits for mercury or HCl in 40 CFR pt. 63, subp. DDDDD, Table 2. Gaseous and liquid fuels are exempt from the sampling requirements in 40 CFR Section 63.7521(c) and (d) and 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(a), Minn. R. 7011.7050]

5.5.45 Site-Specific Fuel Monitoring Plan. The Permittee must develop a Site-Specific Fuel Monitoring Plan according to the procedures and requirements in 40 CFR Section 63.7521(b)(1) and (2). [40 CFR 63.7521(b), Minn. R. 7011.7050]

5.5.46 Site-Specific Fuel Monitoring Plan. If the Permittee intends to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must submit the fuel analysis plan to the Administrator for review and approval no later than 60 days before the date that the Permittee intends to conduct the initial compliance demonstration described in 40 CFR Section 63.7510. [40 CFR 63.7521(b)(1), Minn. R. 7011.7050]

5.5.47 Site-Specific Fuel Monitoring Plan. The Permittee must include the information below in the fuel analysis plan. - The identification of all fuel types anticipated to be burned in each

Page 32: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 32 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation boiler; - For each anticipated fuel type, the notification of whether the Permittee or a fuel supplier will be conducting the fuel analysis; - For each anticipated fuel type, a detailed description of the sample location and specific procedures to be used for collecting and preparing the composite samples if the procedures are different from 40 CFR Section 63.7521(c) or (d). Samples should be collected at a location that most accurately represents the fuel type, where possible, at a point prior to mixing with other dissimilar fuel types; - For each anticipated fuel type, the analytical methods from 40 CFR pt. 63, subp. DDDDD, Table 6, with the expected minimum detection levels, to be used for the measurement of chlorine or mercury; - If the Permittee requests to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must also include a detailed description of the methods and procedures that the Permittee is proposing to use. Methods in 40 CFR pt. 63, subp. DDDDD, Table 6 shall be used until the requested alternative is approved; and - If the Permittee will be using fuel analysis from a fuel supplier in lieu of site-specific sampling and analysis, the fuel supplier must use the analytical methods required by 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(b)(2), Minn. R. 7011.7050]

5.5.48 Fuel Analysis Procedure. At a minimum, the Permittee must obtain three composite fuel samples for each fuel type according to the procedures in 40 CFR Section 63.7521(c)(1) or (2), or the methods listed in 40 CFR pt. 63, subp. DDDDD, Table 6, or use an automated sampling mechanism that provides representative composite fuel samples for each fuel type that includes both coarse and fine material. [40 CFR 63.7521(c), Minn. R. 7011.7050]

5.5.49 Fuel Analysis Procedure. If sampling from a belt (or screw) feeder, the Permittee must collect fuel samples according to the requirements below. - Stop the belt and withdraw a 6-inch wide sample from the full cross-section of the stopped belt to obtain a minimum two pounds of sample. The Permittee must collect all the material (fines and coarse) in the full cross-section. The Permittee must transfer the sample to a clean plastic bag. - Each composite sample will consist of a minimum of three samples collected at approximately equal one-hour intervals during the testing period for sampling during performance stack testing. For monthly sampling, each composite sample shall be collected at approximately equal 10-day intervals during the month. [40 CFR 63.7521(c)(1), Minn. R. 7011.7050]

5.5.50 Fuel Analysis Procedure. If sampling from a fuel pile or truck, the Permittee must collect fuel samples according to the requirements below. - For each composite sample, the Permittee must select a minimum

Page 33: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 33 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation of five sampling locations uniformly spaced over the surface of the pile. - At each sampling site, the Permittee must dig into the pile to a uniform depth of approximately 18 inches. The Permittee must insert a clean shovel into the hole and withdraw a sample, making sure that large pieces do not fall off during sampling; use the same shovel to collect all samples. - The Permittee must transfer all samples to a clean plastic bag for further processing. [40 CFR 63.7521(c)(2), Minn. R. 7011.7050]

5.5.51 Fuel Analysis Procedure. The Permittee must prepare each composite sample according to the procedures below. - The Permittee must thoroughly mix and pour the entire composite sample over a clean plastic sheet; - The Permittee must break large sample pieces (e.g., larger than 3 inches) into smaller sizes; - The Permittee must make a pie shape with the entire composite sample and subdivide it into four equal parts; - The Permittee must separate one of the quarter samples as the first subset; - If this subset is too large for grinding, the Permittee must repeat the procedure in 40 CFR Section 63.7521(d)(3) with the quarter sample and obtain a one-quarter subset from this sample; - The Permittee must grind the sample in a mill; and - The Permittee must use the procedure in 40 CFR Section 63.7521(d)(3) to obtain a one-quarter subsample for analysis. If the quarter sample is too large, subdivide it further using the same procedure. [40 CFR 63.7521(d), Minn. R. 7011.7050]

5.5.52 Fuel Analysis Procedure. The Permittee must determine the concentration of pollutants in the fuel (mercury and/or chlorine) in units of pounds per million Btu of each composite sample for each fuel type according to the procedures in 40 CFR pt. 63, subp. DDDDD, Table 6, for use in Equations 7, 8, and 9 of 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7521(e), Minn. R. 7011.7050]

5.5.53 Mercury Fuel Analysis. To conduct a fuel analysis for mercury, the Permittee must: - Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or EPA 1631 or EPA 1631E or ASTM D6323 (for solid), or EPA 821-R-01-013 (for liquid or solid), or ASTM D4177 (for liquid), or ASTM D4057 (for liquid), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; - Prepare composited fuel samples using EPA SW-846-3050B (for solid samples), EPA SW-846-3020A (for liquid samples), ASTM D2013/D2013M (for coal), ASTM D5198 (for biomass), or EPA 3050 (for solid fuel), or EPA 821-R-01-013 (for liquid or solid), or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), or ASTM D5864 (for liquids and

Page 34: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 34 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation other solids), or ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173, ASTM E871, or ASTM D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Measure mercury concentration in fuel sample using ASTM D6722 (for coal), EPA SW-846-7471B (for solid samples), or EPA SW-846-7470A (for liquid samples), or equivalent; - Convert concentration into units of pounds of mercury per MMBtu of heat content using Equation 8 in 40 CFR Section63.7530; and - Calculate the mercury emission rate from the boiler in units of pounds per million Btu using Equations 10 and 12 in 40 CFR Section 63.7530. [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

5.5.54 HCl Fuel Analysis. To conduct a fuel analysis for HCl, the Permittee must: - Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or ASTM D6323 (for coal or biomass), ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; - Prepare composited fuel samples using EPA SW-846-3050B (for solid samples), EPA SW-846-3020A (for liquid samples), ASTM D2013/D2013M (for coal), or ASTM D5198 (for biomass), or EPA 3050 or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), ASTM D5864, ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173 or ASTM E871, or D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels) or equivalent; - Measure chlorine concentration in fuel sample using EPA SW-846-9250, ASTM D6721, ASTM D4208 (for coal), or EPA SW-846-5050 or ASTM E776 (for solid fuel), or EPA SW-846-9056 or SW-846-9076 (for solids or liquids) or equivalent. - Convert concentrations into units of pounds of HCl per MMBtu of heat content using Equation 7 in 40 CFR Section 63.7530; and - Calculate the HCl emission rate from the boiler in units of pounds per million Btu using Equations 10 and 11 in 40 CFR Section 63.7530. [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

5.5.55 General Compliance Requirements: If the Permittee demonstrates compliance with any applicable emission limit through performance testing and subsequent compliance with operating limits (including the use of CPMS), or with a CEMS, or COMS, the Permittee must develop a Site-Specific Monitoring Plan according to the requirements in 40 CFR Section 63.7505(d)(1)-(4) for the use of any CEMS, COMS, or CPMS. This requirement also applies if the Permittee petitions the EPA Administrator for alternative

Page 35: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 35 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation monitoring parameters under 40 CFR Section 63.8(f). [40 CFR 63.7505(d), Minn. R. 7011.7050]

5.5.56 Site-Specific Monitoring Plan. For each CMS required in 40 CFR Section 63.7505 (including CEMS, COMS, or CPMS), the Permittee must develop, and submit to the Administrator for approval upon request, a Site-Specific Monitoring Plan that addresses design, data collection, and the quality assurance and quality control elements outlined in 40 CFR Section 63.8(d) and the elements described below: - Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device); - Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and - Performance evaluation procedures and acceptance criteria (e.g., calibrations, accuracy audits, analytical drift). [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]

5.5.57 Site-Specific Monitoring Plan. The Permittee must submit this Site-Specific Monitoring Plan, if requested, at least 60 days before the initial performance evaluation of the CMS. This requirement to develop and submit a Site-Specific Monitoring Plan does not apply to affected sources with existing CEMS or COMS operated according to the performance specifications under 40 CFR pt. 60, Appendix B and that meet the requirements of 40 CFR Section 63.7525. Using the process described in 40 CFR Section 63.8(f)(4), the Permittee may request approval of alternative monitoring system quality assurance and quality control procedures in place of those specified in 40 CFR Section 63.7505(d)(1) and, if approved, include the alternatives in the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]

5.5.58 Site-Specific Monitoring Plan. In the Site-Specific Monitoring Plan, the Permittee must also address the items below: - Ongoing operation and maintenance procedures in accordance with the general requirements of 40 CFR Section 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii); - Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR Section 63.8(d); and - Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR Section 63.10(c) (as applicable in 40 CFR pt. 63, subp. DDDDD, Table 10), (e)(1), and (e)(2)(i). [40 CFR 63.7505(d)(2), Minn. R. 7011.7050]

5.5.59 Site-Specific Monitoring Plan. The Permittee must conduct a performance evaluation of each CMS in accordance with the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(3), Minn. R. 7011.7050]

5.5.60 Site-Specific Monitoring Plan. The Permittee must operate and

Page 36: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 36 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation maintain the CMS in continuous operation according to the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(4), Minn. R. 7011.7050]

5.5.61 Monitoring Data. the Permittee must monitor and collect data according to 40 CFR Section 63.7535 and the Site-Specific Monitoring Plan required by 40 CFR Section 63.7505(d). [40 CFR 63.7535(a), Minn. R. 7011.7050]

5.5.62 Monitoring Data. The Permittee must operate the monitoring system and collect data at all required intervals at all times that each boiler is operating and compliance is required, except for periods of monitoring system malfunctions or out of control periods, and required monitoring system quality assurance or control activities, including, as applicable, calibration checks, required zero and span adjustments, and scheduled CMS maintenance as defined in the Site-Specific Monitoring Plan. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. The Permittee is required to complete monitoring system repairs in response to monitoring system malfunctions or out-of-control periods and to return the monitoring system to operation as expeditiously as practicable. [40 CFR 63.7535(b), Minn. R. 7011.7050]

5.5.63 Monitoring Data. The Permittee may not use data recorded during monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, or required monitoring system quality assurance or control activities in data averages and calculations used to report emissions or operating levels. The Permittee must record and make available upon request results of CMS performance audits and dates and duration of periods when the CMS is out of control to completion of the corrective actions necessary to return the CMS to operation consistent with the Site-Specific Monitoring Plan. The Permittee must use all the data collected during all other periods in assessing compliance and the operation of the control device and associated control system. [40 CFR 63.7535(c), Minn. R. 7011.7050]

5.5.64 Monitoring Data. Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits, calibration checks, and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. In calculating monitoring results, do not use any data collected during periods when the monitoring system is out of control as specified in the Site-Specific Monitoring Plan, while conducting repairs associated with periods when the monitoring system is out of control, or while conducting required monitoring system quality assurance or quality control activities. The Permittee must calculate monitoring results using all other monitoring data collected while the process is operating. The Permittee must report

Page 37: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 37 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation all periods when the monitoring system is out of control in the annual report. [40 CFR 63.7535(d), Minn. R. 7011.7050]

5.5.65 Notification Requirements. The Permittee must meet the notification requirements in 40 CFR Section 63.7545 according to the schedule in 40 CFR Section 63.7545 and in 40 CFR pt. 63, subp. A. Some of the notifications must be submitted before the Permittee is required to comply with the emission limits and work practice standards in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7495(d), Minn. R. 7011.7050]

5.5.66 General Notifications. The Permittee must submit to the Administrator all of the notifications in 40 CFR Sections 63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b)-(h) that apply by the dates specified. [40 CFR 63.7545(a), Minn. R. 7011.7050]

5.5.67 Notification of Intent. The Permittee must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin. [40 CFR 63.7545(d), 40 CFR 63.9(e), Minn. R. 7011.7050, Minn. R. 7019.0100]

5.5.68 Notification of Compliance Status Content. The Notification of Compliance Status must contain a description of the affected unit(s) including identification of which subcategories the unit is in, the design heat input capacity of the unit, a description of the add-on controls used on the unit to comply with 40 CFR pt. 63, subp. DDDDD, description of the fuel(s) burned, including whether the fuel(s) were a secondary material determined by the Permittee or the EPA through a petition process to be a non-waste under 40 CFR Section 241.3, whether the fuel(s) were a secondary material processed from discarded non-hazardous secondary materials within the meaning of 40 CFR Section 241.3, and justification for the selection of fuel(s) burned during the compliance demonstration. [40 CFR 63.7545(e)(1), Minn. R. 7011.7050]

5.5.69 Notification of Compliance Status Content. The Notification of Compliance Status must contain a summary of the results of all performance tests and fuel analyses, and calculations conducted to demonstrate initial compliance including all established operating limits, and including: - Identification of whether the Permittee is complying with the PM emission limit; - Identification of whether the Permittee is complying with the output-based emission limits or the heat input-based (i.e., lb/MMBtu or ppm) emission limits; and - Identification of whether the Permittee is complying the arithmetic mean of all valid hours of data from the previous 30 operating days or of the previous 720 hours. This identification shall be specified separately for each operating parameter. [40 CFR 63.7545(e)(2), Minn. R. 7011.7050]

5.5.70 Notification of Compliance Status Content. The Notification of Compliance Status must contain identification of whether the Permittee plans to demonstrate compliance with each applicable emission limit through performance testing, a CEMS, or fuel analysis. [40 CFR 63.7545(e)(4), Minn. R. 7011.7050]

Page 38: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 38 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.5.71 Notification of Compliance Status Content. The Notification of

Compliance Status must contain identification of whether the Permittee plans to demonstrate compliance by emissions averaging and identification of whether the Permittee plans to demonstrate compliance by using efficiency credits through energy conservation. If the Permittee plans to demonstrate compliance by emission averaging, report the emission level that was being achieved or the control technology employed on January 31, 2013. [40 CFR 63.7545(e)(5), Minn. R. 7011.7050]

5.5.72 Notification of Compliance Status Content. The Notification of Compliance Status must contain a signed certification that the Permittee has met all applicable emission limits and work practice standards. [40 CFR 63.7545(e)(6), Minn. R. 7011.7050]

5.5.73 Notification of Compliance Status Content. If the Permittee had a deviation from any emission limit, work practice standard, or operating limit, the Permittee must also submit a description of the deviation, the duration of the deviation, and the corrective action taken in the Notification of Compliance Status report. [40 CFR 63.7545(e)(7), Minn. R. 7011.7050]

5.5.74 Notification of Compliance Status Content. In addition to the information required in 40 CFR Section 63.9(h)(2), the Notification of Compliance Status must include the following certification(s) of compliance, as applicable, and signed by a responsible official: - "This facility completed the required initial tune-up for all of the boilers covered by 40 CFR part 63 subpart DDDDD at this site according to the procedures in 40 CFR Section 63.7540(a)(10)(i)-(vi)." - "This facility has had an energy assessment performed according to 40 CFR Section 63.7530(e)." - Except for units that burn only natural gas, refinery gas, or other gas 1 fuel, or units that qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act, include the following: "No secondary materials that are solid waste were combusted in any affected unit.". [40 CFR 63.7545(e)(8), Minn. R. 7011.7050]

5.5.75 Notification of Compliance Status Content. The Permittee must include with the Notification of Compliance Status a signed certification that the energy assessment was completed according to 40 CFR pt. 63, subp. DDDDD, Table 3 and that the assessment is an accurate depiction of the facility at the time of the assessment. [40 CFR 63.7530(e), Minn. R. 7011.7050]

5.5.76 Notification of Compliance Status. Each time a Notification of Compliance Status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Commissioner a Notification of Compliance Status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with 40 CFR pt. 63, subp. DDDDD. The notification must be sent by the 60th day following the

Page 39: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 39 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation completion of the relevant compliance demonstration activity specified in 40 CFR pt. 63, subp. DDDDD. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met. [40 CFR 63.9(h), Minn. R. 7019.0100]

5.5.77 Notification of Solid Waste Combustion. If the Permittee intends to commence or recommence combustion of solid waste, the Permittee must provide 30 days prior notice of the date upon which the Permittee will commence or recommence combustion of solid waste. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that will commence burning solid waste, and the date of the notice. - The currently applicable subcategories under 40 CFR pt. 63, subp. DDDDD. - The date on which the Permittee became subject to the currently applicable emission limits. - The date upon which the Permittee will commence combusting solid waste. [40 CFR 63.7545(g), Minn. R. 7011.7050]

5.5.78 Notification of Fuel Switch or Physical Change. If the Permittee has switched fuels or made a physical change to the boiler and the fuel switch or physical change resulted in the applicability of a different subcategory, the Permittee must provide notice of the date upon which the Permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that have switched fuels, were physically changed, and the date of the notice; - The currently applicable subcategory under this subpart; and - The date upon which the fuel switch or physical change occurred. [40 CFR 63.7545(h), Minn. R. 7011.7050]

5.5.79 Notification of Performance Test. - The Permittee must notify the Commissioner and the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. - In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Commissioner and the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. [40 CFR 63.7(b), Minn. R. 7017.2015]

5.5.80 Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible

Page 40: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 40 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation emission observations in accordance with 40 CFR Section 63.9(f). [40 CFR 63.6(h)(4), Minn. R. 7011.7000]

5.5.81 Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible emission observations. The notification shall be submitted with the notification of the performance test date, or if no performance test is required or visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the initial performance test. The Permittee shall deliver or postmark the notification not less than 30 days before the opacity or visible emission observations are scheduled to take place. [40 CFR 63.9(f), Minn. R. 7019.0100]

5.5.82 Change in Information Already Provided. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

5.5.83 Compliance Status Report Content. A compliance report must contain: - Information required in 40 CFR Section 63.7550(c)(1)-(5); - If there are no deviations from any emission limitation (emission limit and operating limit) that applies and there are no deviations from the requirements for work practice standards in 40 CFR pt. 63, subp. DDDDD, Table 3 that apply, a statement that there were no deviations from the emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, including CEMS, COMS, CPMS, were out-of-control as specified in 40 CFR Section 63.8(c)(7), a statement that there were no periods during which the CMSs were out-of-control during the reporting period; - If the Permittee has a deviation from any emission limitation (emission limit and operating limit) where the Permittee is not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard during the reporting period, the report must contain the information in 40 CFR Section 63.7550(d); and - If there were periods during which the CMSs, in including CEMS, COMS, CPMS, were out-of-control as specified in 40 CFR Section 63.8(c)(7), or otherwise not operating, the report must contain the information in 40 CFR Section 63.7550(e). [40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.5.84 Compliance Status Report Content. A compliance report must contain the following information: - Company and Facility name and address; - Process unit information, emissions limitations, and operating parameter limitations; - Date of report and beginning and ending dates of the reporting period; and

Page 41: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 41 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation - The total operating time during the reporting period. [40 CFR 63.7550(c)(5)(i)-(iv), Minn. R. 7011.7050]

5.5.85 Compliance Status Report Content. A compliance report must contain the monitoring equipment manufacturer(s) and model numbers and the date of the last CMS certification or audit. [40 CFR 63.7550(c)(5)(v), Minn. R. 7011.7050]

5.5.86 Compliance Status Report Content. A compliance report must contain the total fuel use by each individual boiler subject to an emission limit within the reporting period, including, but not limited to, a description of the fuel, whether the fuel has received a non-waste determination by the EPA or the basis for concluding that the fuel is not a waste, and the total fuel usage amount with units of measure. [40 CFR 63.7550(c)(5)(vi), Minn. R. 7011.7050]

5.5.87 Compliance Status Report Content. If the Permittee is conducting performance tests once every 3 years consistent with 40 CFR Section 63.7515(b) or (c), a compliance report must contain the date of the last 2 performance tests and a statement as to whether there have been any operational changes since the last performance test that could increase emissions. [40 CFR 63.7550(c)(5)(vii), Minn. R. 7011.7050]

5.5.88 Compliance Status Report Content. A compliance report must contain a statement indicating that the Permittee burned no new types of fuel in an individual boiler subject to an emission limit. Or, if the Permittee did burn a new type of fuel, the Permittee must submit the calculation of HCl emission rate using Equation 16 of 40 CFR Section 63.7530 that demonstrates that the source is still meeting the emission limit for HCl emissions and the calculation of mercury emission rate using Equation 17 of 40 CFR Section 63.7530 that demonstrates that the source is still meeting the emission limit for mercury emissions. [40 CFR 63.7550(c)(5)(viii), Minn. R. 7011.7550]

5.5.89 Compliance Status Report Content. If the Permittee wishes to burn a new type of fuel in an individual boiler subject to an emission limit and cannot demonstrate compliance with the maximum chlorine input operating limit using Equation 7 of 40 CFR Section 63.7530 or the maximum mercury input operating limit using Equation 8 of 40 CFR Section 63.7530, the Permittee must include in the Compliance Report a statement indicating the intent to conduct a new performance test within 60 days of starting to burn the new fuel. [40 CFR 63.7550(c)(5)(ix), Minn. R. 7011.7050]

5.5.90 Compliance Status Report Content. A compliance report must contain a summary of any monthly fuel analyses conducted to demonstrate compliance according to 40 CFR Sections 63.7521 and 63.7530 for individual boilers subject to emission limits, and any fuel specification analyses conducted according to 40 CFR Sections 63.7521(f) and 63.7530(g). [40 CFR 63.7550(c)(5)(x), Minn. R. 7011.7050]

5.5.91 Compliance Status Report Content. If there are no deviations from any emission limits or operating limits in 40 CFR pt. 63, subp. DDDDD that apply, a compliance report must contain a statement

Page 42: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 42 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation that there were no deviations from the emission limits or operating limits during the reporting period. [40 CFR 63.7550(c)(5)(xi), Minn. R. 7011.7050]

5.5.92 Compliance Status Report Content. If there were no deviations from the monitoring requirements including no periods during which the CMSs, including CEMS, COMS, and CPMS, were out of control as specified in 40 CFR Section 63.8(c)(7), a compliance report must contain a statement that there were no deviations and no periods during which the CMS were out of control during the reporting period. [40 CFR 63.7550(c)(5)(xii), Minn. R. 7011.7050]

5.5.93 Compliance Status Report Content. If a malfunction occurred during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the Permittee during a malfunction of a boiler or associated air pollution control device or CMS to minimize emissions in accordance with 40 CFR Section 63.7500(a)(3), including actions taken to correct the malfunction. [40 CFR 63.7550(c)(5)(xiii), Minn. R. 7011.7050]

5.5.94 Compliance Status Report Content. A compliance report must contain the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown. [40 CFR 63.7550(c)(5)(xiv), Minn. R. 7011.7050]

5.5.95 Compliance Status Report Content. For each reporting period, the Compliance Reports must include all of the calculated 30 day rolling average values for CEMS, 10 day rolling average values for CO CEMS when the limit is expressed as a 10 day instead of 30 day rolling average, and the PM CPMS data. [40 CFR 63.7550(c)(5)(xvi), Minn. R. 7011.7050]

5.5.96 Compliance Status Report Content. A compliance report must contain a statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [40 CFR 63.7550(c)(5)(xvii), Minn. R. 7011.7050]

5.5.97 Compliance Status Report Content. For each instance of startup or shutdown, include the information required to be monitored, collected, or recorded according to the requirements of 40 CFR Section 63.7555(d). [40 CFR 63.7550(c)(5)(xviii), Minn. R. 7011.7050]

5.5.98 Compliance Status Report Content. For each deviation from an emission limit or operating limit, or from the work practice standards for periods if startup and shutdown, in 40 CFR pt. 63, subp. DDDDD that occurs at an individual boiler where the Permittee is not using a CMS to comply with that emission limit or operating limit, the Compliance Report must additionally contain the information required in 40 CFR Section 63.7550(d)(1)-(3). - A description of the deviation and which emission limit or

Page 43: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 43 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation operating limit, or work practice standard, from which the Permittee deviated; - Information on the number, duration, and cause of deviations (including unknown cause), as applicable, and the corrective action taken; and - If the deviation occurred during an annual performance test, provide the date the annual performance test was completed. [40 CFR 63.7550(d), Minn. R. 7011.7050]

5.5.99 Compliance Status Report Content. For each deviation from an emission limit, operating limit, and monitoring requirement in 40 CFR pt. 63, subp. DDDDD occurring at an individual boiler where the Permittee is using a CMS to comply with that emission limit or operating limit, the compliance report must additionally contain the information required in 40 CFR Section 63.7550(e)(1)-(9). This includes any deviations from the Site-Specific Monitoring Plan as required in 40 CFR Section 63.7505(d). - The date and time that each deviation started and stopped and description of the nature of the deviation; - The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks; - The date, time, and duration that each CMS was out of control, including the information in 40 CFR Section 63.8(c)(8); - The date and time that each deviation started and stopped; - A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period; - A characterization of the total duration of the deviations during the reporting period into those that are due to control equipment problems, process problems, other known causes, and other unknown causes; - A summary of the total duration of CMS's downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during that reporting period; - A brief description of the source for which there was a deviation; and - A description of any changes in CMSs, processes, or controls since the last reporting period for the source for which there was a deviation. [40 CFR 63.7550(e), Minn. R. 7011.7050]

5.5.100 Compliance Status Report Submittal. The Permittee must submit the reports according to the procedures specified below. (1) Within 60 days after the date of completing each performance test (as defined in 40 CFR Section 63.2) required by 40 CFR pt. 63, subp. DDDDD, the Permittee must submit the results of the performance tests, including any fuel analyses, following the procedure specified in either 40 CFR Section 63.7550(h)(1)(i) or (ii). (i) For data collected using test methods supported by the EPA's Electronic Reporting Tool (ERT) as listed on the EPA's ERT Web site (http://www.epa.gov/ttn/chief/ert/index.html), the Permittee must submit the results of the performance test to the EPA via the

Page 44: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 44 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Compliance and Emissions Data Reporting Interface (CEDRI). (CEDRI can be accessed through the EPA's Central Data Exchange (CDX) (https://cdx.epa.gov/).) Performance test data must be submitted in a file format generated through use of the EPA's ERT or an electronic file format consistent with the extensible markup language (XML) schema listed on the EPA's ERT Web site. If the Permittee claims that some of the performance test information being submitted is confidential business information (CBI), the Permittee must submit a complete file generated through the use of the EPA's ERT or an alternate electronic file consistent with the XML schema listed on the EPA's ERT Web site, including information claimed to be CBI, on a compact disc, flash drive, or other commonly used electronic storage media to the EPA. The electronic media must be clearly marked as CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: Group Leader, Measurement Policy Group, MD C404-02, 4930 Old Page Rd., Durham, NC 27703. The same ERT or alternate file with the CBI omitted must be submitted to the EPA via the EPA's CDX as described earlier in this requirement. (ii) For data collected using test methods that are not supported by the EPA's ERT as listed on the EPA's ERT Web site at the time of the test, the Permittee must submit the results of the performance test to the Administrator at the appropriate address listed in 40 CFR Section 63.13. [40 CFR 63.7550(h)(1), Minn. R. 7011.7050]

5.5.101 Compliance Status Report Submittal. The Permittee must submit the reports according to the procedures specified below. (2) Within 60 days after the date of completing each CEMS performance evaluation (as defined in 40 CFR Section 63.2), the Permittee must submit the results of the performance evaluation following the procedure specified in either 40 CFR Section 63.7550(h)(2)(i) or (ii). (i) For performance evaluations of continuous monitoring systems measuring relative accuracy test audit (RATA) pollutants that are supported by the EPA's ERT as listed on the EPA's ERT Web site at the time of the evaluation, the Permittee must submit the results of the performance evaluation to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) Performance evaluation data must be submitted in a file format generated through the use of the EPA's ERT or an alternate file format consistent with the XML schema listed on the EPA's ERT Web site. If the Permittee claims that some of the performance evaluation information being transmitted is CBI, the Permittee must submit a complete file generated through the use of the EPA's ERT or an alternate electronic file consistent with the XML schema listed on the EPA's ERT Web site, including information claimed to be CBI, on a compact disc, flash drive, or other commonly used electronic storage media to the EPA. The electronic media must be clearly marked as CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: Group Leader, Measurement Policy Group, MD C404-02, 4930 Old Page Rd., Durham, NC 27703. The same ERT or alternate file with the CBI omitted must be submitted to the EPA via the EPA's

Page 45: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 45 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation CDX as described earlier in this requirement. (ii) For any performance evaluations of continuous monitoring systems measuring RATA pollutants that are not supported by the EPA's ERT as listed on the ERT Web site at the time of the evaluation, the Permittee must submit the results of the performance evaluation to the Administrator at the appropriate address listed in 40 CFR Section 63.13. (3) The Permittee must submit all reports required by Table 9 of this subpart electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) The Permittee must use the appropriate electronic report in CEDRI for this subpart. Instead of using the electronic report in CEDRI for this subpart, the Permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the Permittee must submit the report to the Administrator at the appropriate address listed in 40 CFR Section 63.13. The Permittee must begin submitting reports via CEDRI no later than 90 days after the form becomes available in CEDRI. [40 CFR 63.7550(h)(2-3), Minn. R. 7011.7050]

5.5.102 Use of a COMS. - The Permittee required to use a COMS shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results in accordance with the provisions of 40 CFR Section 63.10(e)(4). - The Permittee may submit, for compliance purposes, COMS data results produced during any performance test required under 40 CFR Section 63.7 in lieu of Method 9 data in accordance with the process specified in 40 CFR Section 63.6(h)(7). - COMS data shall be reduced to 6-minute averages over the duration of the mass emission performance test. - The Permittee is responsible for demonstrating that they have complied with the performance evaluation requirements of 40 CFR Section 63.8(e), that the COMS has been properly maintained, operated, and data quality-assured, as specified in 40 CFR Sections 63.8(c) and (d), and that the resulting data have not been altered in any way. [40 CFR 63.6(h)(7), Minn. R. 7011.7000]

5.5.103 General Reporting Requirements. The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]

5.5.104 Progress Reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. [40 CFR 63.10(d)(4), Minn. R. 7019.0100]

5.5.105 Additional Reporting Requirements for Sources with Continuous

Page 46: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 46 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Monitoring Systems. - When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. - The Permittee shall furnish the Commissioner and the Administrator a copy of a written report of the results of the CMS performance evaluation simultaneously with the results of the performance test, unless otherwise specified in 40 CFR pt. 63, subp. DDDDD. The Permittee using a COMS to determine opacity compliance during any performance test shall furnish the Commissioner and the Administrator two or, upon request, three copies of a written report of the results of the COMS performance evaluation. The copies shall be furnished at least 15 calendar days before the performance test is conducted. [40 CFR 63.10(e)(1) and (2), Minn. R. 7019.0100]

5.5.106 Excess Emissions and Continuous Monitoring System Performance Report and Summary Report. Excess emissions and parameter monitoring exceedances are defined in 40 CFR pt. 63, subp. DDDDD. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner and the Administrator semiannually, except when more frequent reporting is specifically required by 40 CFR pt. 63, subp. DDDDD or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). [40 CFR 63.10(e)(3)(i) - (iv), Minn. R. 7019.0100]

5.5.107 Content and Submittal Dates for Excess Emissions and Monitoring System Performance Reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedances of process or control system parameters shall include all the information required in 40 CFR Section 63.10(c)(5)- (c)(13), in 40 CFR Section 63.8(c)(7) and 40 CFR Section 63.8(c)(8), and in 40 CFR pt. 63, subp. DDDDD, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. [40 CFR 63.10(e)(3)(v), Minn. R. 7019.0100]

5.5.108 Summary Report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless 40 CFR pt. 63, subp. DDDDD standard specifies that more than one summary report is required). The summary report shall be entitled "Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi). [40 CFR 63.10(e)(3)(vi), Minn. R. 7019.0100]

5.5.109 If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent

Page 47: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 47 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. [40 CFR 63.10(e)(3)(vii), Minn. R. 7019.0100]

5.5.110 Reporting Continuous Opacity Monitoring System Data Produced During a Performance Test. The Permittee shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results. The report of COMS data shall be submitted simultaneously with the report of the performance test results. [40 CFR 63.10(e)(4), Minn. R. 7019.0100]

5.5.111 General Recordkeeping Requirements. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(1), Minn. R. 7019.0100]

5.5.112 Records to Keep. The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Status Reports submitted, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv). [40 CFR 63.7555(a)(1), Minn. R. 7011.7050]

5.5.113 Records to Keep. The Permittee must keep records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). [40 CFR 63.7555(a)(2), Minn. R. 7011.7050]

5.5.114 Records to Keep. For each CEMS, COMS, and CMS, the Permittee must keep the following records: - Records described in 40 CFR Section 63.10(b)(2)(vii)-(xi); - Monitoring data for COMS during a performance evaluation as required in 40 CFR Section 63.6(h)(7)(i) and (ii); - Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); - Requests for alternatives to relative accuracy test for CEMS as required in 40 CFR Section 63.8(f)(6)(i); and - Records of the date and time that each deviation started and stopped. [40 CFR 63.7555(b), Minn. R. 7011.7050]

5.5.115 Records to Keep. The Permittee must keep the records required in 40 CFR pt. 63, subp. DDDDD, Table 8 including records of all monitoring data and calculated averages for applicable operating limits, such as opacity and operating load, to show continuous compliance with each emission limit and operating limit that applies. [40 CFR 63.7555(c), Minn. R. 7011.7050]

5.5.116 Records to Keep. The Permittee must keep records of monthly fuel use including the type(s) of fuel and amount(s) used. [40 CFR 63.7555(d)(1), Minn. R. 7011.7050]

5.5.117 Records to Keep. If the Permittee combusts non-hazardous

Page 48: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 48 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation secondary materials that have been determined not to be solid waste pursuant to 40 CFR Section 241.3(b)(1) and (2), the Permittee must keep a record that documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If the Permittee combusts a fuel that has been processed from a discarded non-hazardous secondary material pursuant to 40 CFR Section 241.3(b)(4), the Permittee must keep records as to how the operations that produced the fuel satisfy the definition of processing in 40 CFR Section 241.2. If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR Section 241.3(c), the Permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary materials as fuel per 40 CFR Section 241.4, the Permittee must keep records documenting that the material is listed as a non-waste under 40 CFR Section 241.4(a). Units exempt from the incinerator standards under Section 129(g)(1) of the Clean Air Act because they are qualifying facilities burning a homogeneous waste stream do not need to maintain the records described in 40 CFR Section 63.7555(d)(2). [40 CFR 63.7555(d)(2), Minn. R. 7011.7050]

5.5.118 Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of HCl emission rates, using Equation 16 of 40 CFR Section 63.7530, that were done to demonstrate compliance with the HCl emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of HCl emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate HCl emission rate for each boiler. [40 CFR 63.7555(d)(3), Minn. R. 7011.7050]

5.5.119 Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of mercury emission rates, using Equation 17 of 40 CFR Section 63.7530, that were done to demonstrate compliance with the mercury emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum mercury emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate mercury emission rates for each boiler. [40 CFR 63.7555(d)(4), Minn. R. 7011.7050]

5.5.120 Records to Keep. If, consistent with 40 CFR Section 63.7515(b), the Permittee chooses to stack test less frequently than annually, the Permittee must keep a record that documents that the emissions in the previous stack test(s) were less than 75 percent of the applicable emission limit and document that there was no change in source operations including fuel composition and operation of air pollution control equipment that would cause emissions of the relevant pollutant to increase within the past year. [40 CFR 63.7555(d)(5), Minn. R. 7011.7050]

Page 49: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 49 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.5.121 Records to Keep. The Permittee must keep records of the

occurrence and duration of each malfunction of the boiler or of the associated air pollution control and monitoring equipment. [40 CFR 63.7555(d)(6), Minn. R. 7011.7050]

5.5.122 Records to Keep. The Permittee must keep records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR Section 63.7500(a)(3), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. [40 CFR 63.7555(d)(7), Minn. R. 7011.7050]

5.5.123 Records to Keep. The Permittee must maintain records of the calendar date, time, occurrence and duration of each startup and shutdown. [40 CFR 63.7555(d)(9), Minn. R. 7011.7050]

5.5.124 Records to Keep. The Permittee must maintain records of the type(s) and amount(s) of fuels used during each startup and shutdown. [40 CFR 63.7555(d)(10), Minn. R. 7011.7050]

5.5.125 Recordkeeping Requirements. The Permittee must keep records in accordance with 40 CFR Sections 63.7560 and 63.10(b)(1). [40 CFR 63.10(b)(1), 40 CFR 63.7560, Minn. R. 7011.7050, Minn. R. 7019.0100, subp. 2(B)]

5.5.126 Recordkeeping - Visible Emissions. The Permittee shall make available, upon request by the Commissioner or Administrator, such records to determine the conditions under which the visual observations were made and shall provide evidence indicating proof of current visible observer emission certification. [40 CFR 63.6(h)(6), Minn. R. 7011.7000]

5.5.127 Additional Recordkeeping Requirements for Sources with Continuous Monitoring Systems. The Permittee shall maintain records as specified within 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions. [40 CFR 63.10(c), Minn. R. 7019.0100]

COMG 5 GP005 Continuous

Emission Monitors (State)

5.6.1 Emissions Monitoring: The following CEMS are subject to the requirements of COMG 5 and shall be used to measure emissions from the Subject Items listed: EQUI 3 SO2 Monitor for EQUI 1, 2, and 14 (Boiler 2, 3, and 4). This monitor will no longer be required when EQUI 1 and 2 can longer combust coal. EQUI 4 CO2 Monitor for EQUI 1, 2, and 14 (Boiler 2, 3, and 4). This monitor will no longer be required when EQUI 1 and 2 can longer combust coal. EQUI 9 NOx Monitor for Ammonia for EQUI 11 (Boiler 7). Additional requirements for the monitors are listed at the individual

Page 50: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 50 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation monitor. [Minn. R. 7017.1006]

5.6.2 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]

5.6.3 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [Minn. R. 7017.1090]

5.6.4 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. Each hourly average starts at the beginning of the hour and ends at the beginning of the following hour. In order for an hour of data to be considered valid, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. Monitoring data shall be recorded in the same units of measurement and averaging period as the facility's emission standard. [Minn. R. 7017.1160]

5.6.5 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R. 7017.1170, subp. 2]

5.6.6 CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures listed in Minn. R. 7017.1170, subp. 3(A) and (B), 40 CFR Section 60.13(d)(1) or 40 CFR pt. 75, Appendix B as applicable for each pollutant concentration, each diluent monitor, and for each monitor range. If no span value is specified in the applicable requirement or in a compliance document, the Permittee shall use

Page 51: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 51 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation a span value equivalent to 1.5 times the emission limit. [Minn. R. 7017.1170, subp. 3]

5.6.7 Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA). [Minn. R. 7017.1180, subp. 2]

5.6.8 CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

5.6.9 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

COMG 6 GP007 NESHAP DDDDD

Gas 1 Boiler with Curtailment

5.7.1 Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.7.2 The Permittee shall submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CFR Section 63.7575. The notification must include the following information: (1) Company name and address. (2) Identification of the affected unit. (3) Reason that natural gas is not able to be used, including the date when the natural gas curtailment was declared or the natural gas supply interruption began. (4) Type of alternative fuel that will be used. (5) Dates when the alternative fuel use is expected to begin and end. [40 CFR 63.7545(f), Minn. R. 7011.7050]

5.7.3 The Permittee shall keep records of the total hours per calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. [40 CFR 63.7555(h), Minn. R. 7011.7050]

5.7.4 For each boiler in COMG 6 that has a continuous oxygen trim system that maintains an optimum air to fuel ratio, the Permittee shall conduct a tune-up of the boiler every 5 years as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the burner must be inspected at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, the Permittee shall set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR

Page 52: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 52 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.7.5 For each boiler in COMG 6 that does not have a continuous oxygen trim system installed, the Permittee shall conduct a tune-up of the boiler annually as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Each annual tune-up must be conducted no more than 13 months after the previous tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(10), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

COMG 7 GP001 Boilers 1, 5, and

6

5.8.1 Nitrogen Oxides <= 39.0 tons per year 12-month rolling sum. This limit is for cumulative emissions from EQUI 19, EQUI 20, and EQUI 21. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.8.2 Daily Recordkeeping - Fuel Usage Records Maintain records of the type and amount of each fuel burned in each emission unit each day. Daily usage of natural gas and diesel fuel oil shall be determined with fuel meters and recorded each day that fuel is combusted. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.8.3 Monthly Recordkeeping - Fuel Usage Records By the 15th day of each month, the fuel usage for each emission unit for the previous 12 months shall be summed to obtain the 12-month fuel usage for the emission unit. The 12-month fuel usage shall be used for calculating 12-month rolling sum NOx emissions as required by this permit. [Minn. R. 7007.0800, subps. 4-5]

5.8.4 Monthly Recordkeeping - NOx by the 15th of each month, the Permittee shall calculate and record the 12-month rolling sum of NOx emissions for the previous 12 month period. The emissions shall be calculated using the following equation: NOx = (100(NG1) + 20(OIL1) + 100(NG5) + 20(OIL5) + 100(NG6) + 20(OIL6))/2000 where NOx = NOx emissions in tons NG1 = past 12 months gas use in EQUI 19, in million cubic feet OIL1 = past 12 months oil use in EQUI 19, in thousands of gallons NG5 = past 12 months gas use in EQUI 20, in million cubic feet OIL5 = past 12 months oil use in EQUI 20, in thousands of gallons NG6 = past 12 months gas use in EQUI 21, in million cubic feet OIL6 = past 12 months oil use in EQUI 21, in thousands of gallons. [Minn. R. 7007.0800, subps. 4-5]

COMG 8 GP002 Boilers 2, 3, and

4

5.9.1 Opacity: Emissions Monitoring: The Permittee shall calibrate,

Page 53: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 53 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation maintain, and operate a continuous opacity monitor at the common stack of EQUI 1, EQUI 2, and EQUI 14 (STRU 5). This requirement will no longer apply when EQUI 1 and 2 can no longer combust coal. [Minn. R. 7007.0800, subp. 4, Minn. R. 7017.1006]

5.9.2 Sulfur Dioxide: Emissions Monitoring: The Permittee shall calibrate, maintain and operate a sulfur dioxide continuous emissions monitor at the common stack of EQUI 1, EQUI 2, and EQUI 14 (STRU 5). The system shall be capable of monitoring the emission rate in lb/mmBtu on an hourly basis. The emission rate, in lb/mmBtu from EQUI 1, EQUI 2, and EQUI 14, shall be determined using the equations in Appendix C. This requirement will no longer apply when EQUI 1 and 2 can no longer combust coal. [Minn. R. 7007.0800, subp. 4, Minn. R. 7017.1006]

5.9.3 Carbon Dioxide: Emissions Monitoring: The Permittee shall calibrate, maintain and operate a diluent CO2 continuous emissions monitor at the common stack of EQUI 1, EQUI 2, and EQUI 14 (STRU 5). This requirement will no longer apply when EQUI 1 and 2 can no longer combust coal. [Minn. R. 7007.0800, subp. 4, Minn. R. 7017.1006]

5.9.4 Emissions Monitoring: The Permittee shall operate and maintain a monitoring system that provides a continuous readout of individual steam production from EQUI 1, EQUI 2, and EQUI 14 for use in the equations to calculate SO2 emissions from the boilers in Appendix C. This requirement will no longer apply when EQUI 1 and 2 can no longer combust coal. [Minn. R. 7007.0800, subp. 4, Minn. R. 7017.1006]

COMG 9 GP006 Continuous

Emission Monitors (NSPS)

5.10.1 The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

5.10.2 Emissions Monitoring: The following CEMS are subject to the requirements of COMG 9 and shall be used to measure emissions from the Subject Items listed: EQUI 5 NOx Monitor for EQUI 11 (Boiler 7) EQUI 6 CO2 Monitor for EQUI 11 (Boiler 7) EQUI 7 SO2 Monitor for EQUI 11 (Boiler 7) Additional requirements for the monitors are listed at the individual monitor. [40 CFR pt. 60, subp. Da, Minn. R. 7017.1010, subp 1]

5.10.3 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format

Page 54: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 54 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]

5.10.4 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), Minn. R. 7017.1090]

5.10.5 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R. 7017.1170, subp. 2]

5.10.6 CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F]

5.10.7 CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R. 7017.1170, subp. 3]

5.10.8 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R. 7017.1130]

5.10.9 CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)]

5.10.10 CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [40 CFR 60.13(b)]

EQUI 1 EU002 Boiler 2 5.11.1 If the Permittee switches fuels or makes a physical change to the

Page 55: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 55 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation boiler that results in the applicability of a different subcategory, the Permittee must be in compliance with the applicable existing source provisions of 40 CFR Part 63, Subpart DDDDD on the effective date of the fuel switch or physical change. [40 CFR 63.7495(h), Minn. R. 7011.7050]

5.11.2 Fuel use is limited to coal, clean cellulosic biomass (as defined in 40 CFR Section 241.2), and natural gas. Once EQUI 1 can no longer combust coal, fuel use will be limited to natural gas, No. 2 fuel oil, and liquid biofuel/biodiesel and the boiler will be categorized as a unit designed to burn gas 1 fuel as defined in 40 CFR 63.7575. Liquid biofuel produced from woody biomass must be derived from clean cellulosic biomass (as defined in 40 CFR Section 241.2). [Minn. R. 7007.0800, subp. 2]

5.11.3 In order to comply with the definition of units designed to burn gas 1 fuels in 40 CFR 63.7575, the number of hours that any liquid fuel is burned for the purposes of periodic testing, maintenance, or operator training shall not exceed a combined total of 48 hours during any calendar year. The 48 hours does not include times when liquid fuels are burned due to natural gas curtailment. [40 CFR 63.7575, Minn. R. 7011.7050]

5.11.4 Heat Input <= 10 percent calendar year maximum of the potential heat input to the boiler to meet the requirements of classification as a limited-use boiler as defined in 40 CFR Section 63.7575. 10% of the Annual Heat Input Capacity of EQUI 1 is 170,820 MMBtu. This requirement will no longer apply once EQUI 1 can no longer combust coal. [40 CFR 63.7555(a)(3), 40 CFR 63.7575, Minn. R. 7011.7050]

5.11.5 Particulate Matter <= 0.40 pounds per million Btu heat input. Once EQUI 1 can no longer combust coal, the potential to emit from the unit will be 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.11.6 PM < 10 micron <= 0.40 pounds per million Btu heat input on a 24 hour average. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.11.7 Sulfur Dioxide <= 1.64 pounds per million Btu heat input. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.11.8 Sulfur Dioxide <= 2.0 pounds per million Btu heat input. The potential to emit from the unit is 0.51 lb/MMBtu due to equipment design and allowable fuels. This limit applies while burning liquid fuel. [Minn. R. 7011.0510, subp. 1]

5.11.9 Sulfur Dioxide <= 4.0 pounds per million Btu heat input. The potential to emit from the unit is 1.50 lb/MMBtu when burning

Page 56: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 56 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation solid fuel. This limit applies while burning solid fuels and will no longer apply once EQUI 1 can no longer combust coal. [Minn. R. 7011.0510, subp. 1]

5.11.10 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.11.11 The Permittee may conduct fuel analysis following ASTM D5865 to determine the heat content of coal. The results may be used in the monthly calculation of total heat input used in EQUI1. The results of the fuel analysis may be used only for the monthly calculation for the month the sample was collected in. In the absence of fuel analysis, the Permittee shall use 14,000 Btu/lb of coal in the calculation. This requirement will no longer apply once EQUI 1 can no longer combust coal. [Minn. R. 7007.0800, subp. 2]

5.11.12 For units in the limited use subcategory, the Permittee shall keep a copy of the federally enforceable permit that limits the annual capacity factor to less than or equal to 10 percent and fuel use records for the days the boiler or process heater was operating. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [40 CFR 63.7555(a)(3), Minn. R. 7011.7050]

5.11.13 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the amount of natural gas, biomass, and coal combusted in EQUI1. This shall be based on throughput logs, meters, and/or delivery records. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [40 CFR 63.7525(k), Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7050]

5.11.14 Recordkeeping: By the 15th day of each month for the previous month, the Permittee shall calculate the amount of natural gas, biomass, and coal combusted in EQUI1 during the previous calendar month. These records shall consist of daily throughput logs and/or meters. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [Minn. R. 7007.0800, subs.4-5]

5.11.15 Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the total mmBtu heat input to EQUI1 for the calendar year (January 1 through the end of the previous month) using the following equation: HI = (NG(1020) + BIT(CHC) + BIO(5000))/10^6 HI = heat input in mmBtu NG = natural gas consumption in standard cubic feet for EQUI1 for January 1 through the end of the previous month BIT = bituminous coal consumption in pounds for EQUI1 for January 1 through the end of the previous month CHC = coal heat content in Btu/lb. This value is determined by an average of the results of fuel analysis using ASTM D5865; in absence of sample results, the Permittee shall use 14,000 Btu/lb. BIO = biomass in pounds for EQUI1 for January 1 through the end of

Page 57: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 57 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation the previous month. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [Minn. R. 7007.0800, subps. 4-5]

5.11.16 Recordkeeping: When the boiler is categorized as a unit designed to burn gas 1 fuel, the Permittee shall keep records of: 1) the total hours per calendar year that liquid fuel is burned for the purposes of alternative liquid fuel testing, maintenance, or operator training; and 2) the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. [40 CFR 63.7555(h), Minn. R. 7011.7050]

5.11.17 The Permittee must meet each applicable emission limit, operating limit, or work practice standard in Tables 1 - 4, and 11 - 13 of 40 CFR pt. 63, subp. DDDDD. However, Limited-use boilers are not subject to the emission limits in Tables 1 and 2 or 11 - 13, the annual tune-up, the energy assessment requirements in Table 3, or the operating limits in Table 4 to 40 CFR pt. 63 subp. DDDDD. The Permittee must be in compliance with the all applicable standards and limits of 40 CFR pt. 63, subp. DDDDD at all times the affected unit is operating except during periods of startup and shutdown during which time the Permittee must comply only with Table 3 to 40 CFR pt. 63 subp. DDDDD. Once startup on natural gas is complete, EQUI 1 will no longer be categorized as a limited-use Boiler. [40 CFR 63.7500(a)(1) and (2), 40 CFR 63.7500(c), 40 CFR 63.7500(f), Minn. R. 7011.7050]

5.11.18 While the boiler is categorized as a limited-use boiler, the Permittee must complete a tune-up every 5 years beginning January 31, 2016. Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. [40 CFR 63.7500(c), 40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.11.19 When the boiler is categorized as a gas 1 boiler, and if a continuous oxygen trim system that maintains an optimum air to fuel ratio is installed, then the Permittee shall conduct a tune-up of the boiler every 5 years as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the burner must be inspected at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, the Permittee shall set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.11.20 When the boiler is categorized as a gas 1 boiler, and if a continuous oxygen trim system is not installed, then the Permittee shall

Page 58: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 58 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation conduct a tune-up of the boiler annually as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Units in the gas 1 subcategory will conduct this tune-up as a work practice for all regulated emissions under 40 CFR Part 63, Subpart DDDDD. The Permittee must conduct the tune-up while burning the type of fuel (or fuels in case of units that routinely burn a mixture) that provided the majority of the heat input to the boiler over the 12 months prior to the tuneup. Each annual tune-up must be conducted no more than 13 months after the previous tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(10), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.11.21 If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.11.22 The Permittee shall submit a notification of fuel switch or physical change : Due by 30 days after the date the fuel switch or physical change occurred. The notification must identify: (1) The name of the owner or operator of the affected source, as defined in 40 CFR Section 63.7490, the location of the source, the boiler(s) that have switched fuels or were physically changed, and the date of the notice; (2) The currently applicable subcategory under 40 CFR Part 63, Subpart DDDD; and (3) The date upon which the fuel switch or physical change occurred. [40 CFR 63.7545(h), Minn. R. 7011.7050]

5.11.23 The Permittee shall submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CFR Section 63.7575. The notification must include the following information: (1) Company name and address. (2) Identification of the affected unit. (3) Reason that natural gas is not able to be used, including the date when the natural gas curtailment was declared or the natural gas supply interruption began. (4) Type of alternative fuel that will be used. (5) Dates when the alternative fuel use is expected to begin and end. [40 CFR 63.7545(f), Minn. R. 7011.7050]

5.11.24 The Permittee shall submit all notifications to the MPCA and shall submit a copy of all notifications to the Administrator at the appropriate address listed in 40 CFR Section 63.13. [40 CFR 63.9(a)(4)(ii), Minn. R. 7019.0100]

5.11.25 The Permittee shall submit a Compliance Report with the information specified in the following section. The Permittee must report each instance in which an applicable emission or operating limit in Tables 1 - 4 or 11 - 13 was not met. These instances are deviations and must be reported according to the requirements in 40 CFR Section 63.7550. If there were no deviations from any applicable emission limitations or work practice standards of 40 CFR pt. 63, subp. DDDDD, include a statement that there were no deviations during the reporting period. [40 CFR 63.7540(b), 40 CFR

Page 59: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 59 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.11.26 Compliance Report Contents: 1. Company and Facility name and address. 2. Process unit information, and any emission or operating parameter limitations. 3. Date of report and beginning and ending dates of the reporting period. 4. The total operating time during the reporting period. 5. Include the date of the most recent tune-up for each unit. Include the date of the most recent burner inspection if it was not done on a 5-year period and was delayed until the next scheduled or unscheduled unit shutdown. [40 CFR 63.7550(c)(1), 40 CFR 63.7550(c)(5)(i)-(iv), 40 CFR 63.7550(c)(5)(xiv), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.11.27 The Permittee shall submit the Compliance Report described above, electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) The Permittee must use the appropriate electronic report in CEDRI for 40 CFR pt. 63, subp. DDDDD. Instead of using the electronic report in CEDRI for this subpart, the Permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If the reporting form specific to 40 CFR pt. 63, subp. DDDDD is not available in CEDRI at the time that the report is due, the Permittee must submit the report to the Administrator at the appropriate address listed in 40 CFR Section 63.13. The Permittee must begin submitting reports via CEDRI no later than 90 days after the form becomes available in CEDRI. [40 CFR 63.10(a)(4)(ii), 40 CFR 63.7550(h)(3), Minn. R. 7011.7050, Minn. R. 7019.0100]

5.11.28 For all other reports besides the Compliance Report, the Permittee shall submit the report to the MPCA and shall submit a copy of the report to the Administrator at the appropriate address listed in 40 CFR Section 63.13. [40 CFR 63.10(a)(4)(ii), Minn. R. 7019.0100]

5.11.29 The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Report submitted. The Permitee shall also maintain records of any performance tests, fuel analyses, or other compliance demonstrations and performance evaluations. The Permittee shall keep a copy of the federally enforceable permit that limits the annual capacity factor to less than or equal to 10 percent and fuel use records for the days the boiler was operating. [40 CFR 63.10(b)(2)(viii), 40 CFR 63.10(b)(2)(xiv), 40 CFR 63.7555(a), Minn. R. 7011.0100, Minn. R. 7011.7050]

5.11.30 Notification of information change. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

5.11.31 Records must be maintained according to the following

Page 60: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 60 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation requirements: 1. All records must be in a form suitable and readily available for expeditious review. 2. The Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. 3. The Permittee must keep each record on site, or the records must be accessible from onsite (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee may keep the records off site for the remaining 3 years. [40 CFR 63.10(b)(1), 40 CFR 63.7560, Minn. R. 7011.7050, Minn. R. 7019.0100]

EQUI 2 EU003 Boiler 3 5.12.1 If the Permittee switches fuels or makes a physical change to the

boiler that results in the applicability of a different subcategory, the Permittee must be in compliance with the applicable existing source provisions of 40 CFR Part 63, Subpart DDDDD on the effective date of the fuel switch or physical change. [40 CFR 63.7495(h), Minn. R. 7011.7050]

5.12.2 Fuel use is limited to coal, clean cellulosic biomass (as defined in 40 CFR Section 241.2), and natural gas. Once EQUI 1 can no longer combust coal, fuel use will be limited to natural gas, No. 2 fuel oil, or liquid biofuel and the boiler will be categorized as a unit designed to burn gas 1 fuel as defined in 40 CFR 63.7575. Liquid biofuel produced from woody biomass must be derived from clean cellulosic biomass (as defined in 40 CFR Section 241.2). [Minn. R. 7007.0800, subp. 2]

5.12.3 In order to comply with the definition of units designed to burn gas 1 fuels in 40 CFR 63.7575, the number of hours that any liquid fuel is burned for the purposes of periodic testing, maintenance, or operator training shall not exceed a combined total of 48 hours during any calendar year. The 48 hours does not include times when liquid fuels are burned due to natural gas curtailment. [40 CFR 63.7575, Minn. R. 7011.7050]

5.12.4 Heat Input <= 10 percent calendar year maximum of the potential heat input to the boiler to meet the requirements of classification as a limited-use boiler as defined in 40 CFR Section 63.7575. 10% of the Annual Heat Input Capacity of EQUI 2 is 170,820 MMBtu. This requirement will no longer apply once EQUI 2 can no longer combust coal. [40 CFR 63.7555(a)(3), 40 CFR 63.7575, Minn. R. 7011.7050]

5.12.5 PM < 10 micron <= 0.40 pounds per million Btu heat input on a 24 hour average. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

Page 61: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 61 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.12.6 Sulfur Dioxide <= 1.64 pounds per million Btu heat input. [Minn. R.

7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.12.7 Particulate Matter <= 0.40 pounds per million Btu heat input. Once EQUI 2 can no longer combust coal, the potential to emit from the unit will be 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.12.8 Sulfur Dioxide <= 2.0 pounds per million Btu heat input. The potential to emit from the unit is 0.51 lb/MMBtu due to equipment design and allowable fuels. This limit applies while burning liquid fuel. [Minn. R. 7011.0510, subp. 1]

5.12.9 Sulfur Dioxide <= 4.0 pounds per million Btu heat input. The potential to emit from the unit is 1.50 lb/MMBtu when burning solid fuel. This limit applies while burning solid fuels and will no longer apply once EQUI 2 can no longer combust coal. [Minn. R. 7011.0510, subp. 1]

5.12.10 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.12.11 The Permittee may conduct fuel analysis following ASTM D5865 to determine the heat content of coal. The results may be used in the monthly calculation of total heat input used in EQUI2. The results of the fuel analysis may be used only for the monthly calculation for the month the sample was collected in. In the absence of fuel analysis, the Permittee shall use 14,000 Btu/lb of coal in the calculation. This requirement will no longer apply once EQUI 2 can no longer combust coal. [Minn. R. 7007.0800, subp. 2]

5.12.12 For units in the limited use subcategory, the Permittee shall keep a copy of the federally enforceable permit that limits the annual capacity factor to less than or equal to 10 percent and fuel use records for the days the boiler or process heater was operating. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [40 CFR 63.7555(a)(3), Minn. R. 7011.7050]

5.12.13 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the amount of natural gas, biomass, and coal combusted in EQUI2. This shall be based on throughput logs and/or meters. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [40 CFR 63.7525(k), Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.7050]

5.12.14 Recordkeeping: By the 15th day of each month for the previous month, the Permittee shall calculate the amount of natural gas, biomass, and coal combusted in EQUI2 during the previous calendar month. These records shall consist of daily throughput logs and/or meters. This requirement will no longer apply once the boiler is re-

Page 62: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 62 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation categorized as a unit designed to burn gas 1 fuel. [Minn. R. 7007.0800, subs.4-5]

5.12.15 Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the total mmBtu heat input to EQUI2 for the calendar year (January 1 through the end of the previous month) using the following equation: HI = (NG(1020) + BIT(CHC) + BIO(5000))/10^6 HI = heat input in mmBtu NG = natural gas consumption in standard cubic feet for January 1 through the end of the previous month BIT = bituminous coal consumption in pounds for EQUI2 for January 1 through the end of the previous month CHC = coal heat content in Btu/lb. This value is determined by an average of the results of fuel analysis using ASTM D5865; in absence of sample results, the Permittee shall use 14,000 Btu/lb. BIO = biomass in pounds for EQUI2 for January 1 through the end of the previous month. This requirement will no longer apply once the boiler is re-categorized as a unit designed to burn gas 1 fuel. [Minn. R. 7007.0800, subps. 4-5]

5.12.16 Recordkeeping: When the boiler is categorized as a unit designed to burn gas 1 fuel, the Permittee shall keep records of: 1) the total hours per calendar year that liquid fuel is burned for the purposes of alternative liquid fuel testing, maintenance, or operator training; and 2) the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. [40 CFR 63.7555(h), Minn. R. 7011.7050]

5.12.17 The Permittee must meet each applicable emission limit, operating limit, or work practice standard in Tables 1 - 4, and 11 - 13 of 40 CFR pt. 63, subp. DDDDD. However, Limited-use boilers are not subject to the emission limits in Tables 1 and 2 or 11 - 13, the annual tune-up, the energy assessment requirements in Table 3, or the operating limits in Table 4 to 40 CFR pt. 63 subp. DDDDD. The Permittee must be in compliance with the all applicable standards and limits of 40 CFR pt. 63, subp. DDDDD at all times the affected unit is operating except during periods of startup and shutdown during which time the Permittee must comply only with Table 3 to 40 CFR pt. 63 subp. DDDDD. Once startup on natural gas is complete, EQUI 1 will no longer be categorized as a limited-use Boiler. [40 CFR 63.7500(a)(1) and (2), 40 CFR 63.7500(c), 40 CFR 63.7500(f), Minn. R. 7011.7050]

5.12.18 While the boiler is categorized as a limited-use boiler, the Permittee must complete a tune-up every 5 years beginning January 31, 2016. Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. [40 CFR 63.7500(c), 40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.12.19 When the boiler is categorized as a gas 1 boiler, and if a continuous oxygen trim system that maintains an optimum air to fuel ratio is

Page 63: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 63 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation installed, then the Permittee shall conduct a tune-up of the boiler every 5 years as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the burner must be inspected at least once every 72 months. If an oxygen trim system is utilized on a unit without emission standards to reduce the tune-up frequency to once every 5 years, the Permittee shall set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.12.20 When the boiler is categorized as a gas 1 boiler, and if a continuous oxygen trim system is not installed, then the Permittee shall conduct a tune-up of the boiler annually as specified in 40 CFR Section 63.7540(a)(10)(i)-(v). Units in the gas 1 subcategory will conduct this tune-up as a work practice for all regulated emissions under 40 CFR Part 63, Subpart DDDDD. The Permittee must conduct the tune-up while burning the type of fuel (or fuels in case of units that routinely burn a mixture) that provided the majority of the heat input to the boiler over the 12 months prior to the tuneup. Each annual tune-up must be conducted no more than 13 months after the previous tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(10), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.12.21 If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.12.22 The Permittee shall submit a notification of fuel switch or physical change : Due by 30 days after the date the fuel switch or physical change occurred. The notification must identify: (1) The name of the owner or operator of the affected source, as defined in 40 CFR Section 63.7490, the location of the source, the boiler(s) that have switched fuels or were physically changed, and the date of the notice; (2) The currently applicable subcategory under 40 CFR Part 63, Subpart DDDD; and (3) The date upon which the fuel switch or physical change occurred. [40 CFR 63.7545(h), Minn. R. 7011.7050]

5.12.23 The Permittee shall submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CFR Section 63.7575. The notification must include the following information: (1) Company name and address. (2) Identification of the affected unit. (3) Reason that natural gas is not able to be used, including the date when the natural gas curtailment was declared or the natural gas supply interruption began. (4) Type of alternative fuel that will be used. (5) Dates when the alternative fuel use is expected to begin and end. [40 CFR 63.7545(f), Minn. R. 7011.7050]

Page 64: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 64 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.12.24 The Permittee shall submit all notifications to the MPCA and shall

submit a copy of all notifications to the Administrator at the appropriate address listed in 40 CFR Section 63.13. [40 CFR 63.9(4)(iii), Minn. R. 7019.0100]

5.12.25 If the Permittee is required to conduct tune-ups every 5 years the Permittee shall submit a compliance report : Due by 01/31/2021 and every 5 year thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2021. 2. The first compliance report must be postmarked or submitted no later than January 31, 2021. 3. Each subsequent compliance report must cover 5-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.12.26 If the Permittee is required to conduct tune-ups annually the Permittee shall submit a compliance report : Due by January 31 of the year after the boiler is re-categorized as a unit designed to burn gas 1 fuel, and annually thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on the date of startup on natural gas and ending on December 31 of the year of startup. 2. The first compliance report must be postmarked or submitted no later than January 31. 3. Each subsequent compliance report must cover 1-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.12.27 The Permittee shall submit a Compliance Report with the information specified in the following section. The Permittee must report each instance in which an applicable emission or operating limit in Tables 1 - 4 or 11 - 13 was not met. These instances are deviations and must be reported according to the requirements in 40 CFR Section 63.7550. If there were no deviations from any applicable emission limitations or work practice standards of 40 CFR pt. 63, subp. DDDDD, include a statement that there were no deviations during the reporting period. [40 CFR 63.7540(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.12.28 Compliance Report Contents: 1. Company and Facility name and address. 2. Process unit information, and any emission or operating parameter limitations. 3. Date of report and beginning and ending dates of the reporting period. 4. The total operating time during the reporting period. 5. Include the date of the most recent tune-up for each unit. Include the date of the most recent burner inspection if it was not done on a 5-year period and was delayed until the next scheduled or

Page 65: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 65 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation unscheduled unit shutdown. [40 CFR 63.7550(c)(1), 40 CFR 63.7550(c)(5)(i)-(iv), 40 CFR 63.7550(c)(5)(xiv), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.12.29 The Permittee shall submit the Compliance Report described above, electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) The Permittee must use the appropriate electronic report in CEDRI for 40 CFR pt. 63, subp. DDDDD. Instead of using the electronic report in CEDRI for this subpart, the Permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If the reporting form specific to 40 CFR pt. 63, subp. DDDDD is not available in CEDRI at the time that the report is due, the Permittee must submit the report to the Administrator at the appropriate address listed in 40 CFR Section 63.13. The Permittee must begin submitting reports via CEDRI no later than 90 days after the form becomes available in CEDRI. [40 CFR 63.10(a)(4)(ii), 40 CFR 63.7550(h)(3), Minn. R. 7011.7050, Minn. R. 7019.0100]

5.12.30 For all other reports besides the Compliance Report, the Permittee shall submit the report to the MPCA and shall submit a copy of the report to the Administrator at the appropriate address listed in 40 CFR Section 63.13. [40 CFR 63.10(a)(4)(ii), Minn. R. 7019.0100]

5.12.31 Notification of information change. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

5.12.32 The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Report submitted. The Permitee shall also maintain records of any performance tests, fuel analyses, or other compliance demonstrations and performance evaluations. The Permittee shall keep a copy of the federally enforceable permit that limits the annual capacity factor to less than or equal to 10 percent and fuel use records for the days the boiler or process heater was operating. [40 CFR 63.10(b)(2)(viii), 40 CFR 63.10(b)(2)(xiv), 40 CFR 63.7555(a), Minn. R. 7011.0100, Minn. R. 7011.7050]

5.12.33 Records must be maintained according to the following requirements: 1. All records must be in a form suitable and readily available for expeditious review. 2. The Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. 3. The Permittee must keep each record on site, or the records must be accessible from onsite (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record.

Page 66: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 66 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The Permittee may keep the records off site for the remaining 3 years. [40 CFR 63.10(b)(1), 40 CFR 63.7560, Minn. R. 7011.7050, Minn. R. 7019.0100]

EQUI 8 MR007 Opacity monitor 5.13.1 The CEMS/COMS requirements listed in this permit outline the

typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

5.13.2 The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(2), Minn. R. 7011.7050]

5.13.3 As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. [40 CFR 63.7525(c)(3), Minn. R. 7011.7050]

5.13.4 The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(c)(4), Minn. R. 7011.7050]

5.13.5 The Permittee must include in the Site-Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

5.13.6 The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFR Section 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6-minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR 63.7525(c)(6), Minn. R. 7011.7050]

5.13.7 The Permittee must determine and record all the 6-minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR 63.7525(c)(7), Minn. R. 7011.7050]

5.13.8 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. [Minn. R. 7017.1200, subp. 1-3]

5.13.9 Monitoring Data: All COMS data must be reduced to six-minute

Page 67: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 67 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation averages. Six-minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R. 7017.1200, subp. 1-3]

5.13.10 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]

5.13.11 Opacity: Emissions Monitoring: The owner or operator shall use a COMS to measure emissions from EQUI 11. [40 CFR pt. 60, Subp. Da, Minn. R. 7017.1010, subp 1]

5.13.12 Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), Minn. R. 7017.1090]

5.13.13 QC Program: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [Minn. R. 7017.1215]

5.13.14 COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R. 7017.1215]

5.13.15 COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R. 7017.1220]

5.13.16 Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

5.13.17 Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Part 60, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)]

Page 68: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 68 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 11 EU007 Boiler 7 5.14.1 The Permittee shall vent emissions from EQUI 11 to TREA 3 and

TREA 4 whenever EQUI 11 operates, and operate and maintain TREA 3 and TREA 4 at all times that any emissions are vented to TREA 3 and TREA 4. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.2 Total Particulate Matter <= 0.03 pounds per million Btu heat input. [40 CFR 60.42Da(a), Minn. R. 7011.0560, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.3 PM < 10 micron: less than or equal to 0.03 lbs/million Btu heat input [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.4 Opacity: less than or equal to 20 percent opacity on a 6-minute average, except for one 6-minute period per hour of not more than 27 percent opacity. [40 CFR 60.42Da(b), Minn. R. 7011.0560]

5.14.5 Sulfur Dioxide: less than or equal to 39.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.14.6 Sulfur Dioxide <= 1.20 pounds per million Btu heat input gross energy output when combusting clean cellulosic biomass and/or resinated wood using a 30 boiler operating day rolling average. [40 CFR 60.43Da(d)(2), Minn. R. 7011.0560]

5.14.7 Sulfur Dioxide <= 0.20 pounds per million Btu heat input when combusting natural gas, based on a 30 boiler operating day rolling average. [40 CFR 60.43Da, 40 CFR 60.48Da(b), Minn. R. 7011.0560]

5.14.8 Sulfur Dioxide: When clean cellulosic biomass and/or resinated wood and natural gas are combusted simultaneously the SO2 emission limit shall be determined by the following equation: Es = (0.20x + 1.20y)/100 where: Es = the SO2 emission limit in lb/mmBtu x = percentage of total heat input from natural gas during the past 30 boiler operating days y = percentage of total heat input from clean cellulosic biomass and/or resinated wood during the past 30 boiler operating days. [40 CFR 60.43Da(h), Minn. R. 7011.0560]

5.14.9 Nitrogen Oxides: less than or equal to 0.15 lbs/million Btu heat input using 30-day Rolling Average (boiler operating day) when combusting clean cellulosic biomass and/or resinated woodfuels [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.10 Nitrogen Oxides: less than or equal to 0.11 lbs/million Btu heat input using 30-day Rolling Average (boiler operating day) when combusting natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

Page 69: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 69 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.14.11 Nitrogen Oxides: When clean cellulosic biomass and/or resinated

wood and natural gas are combusted simultaneously, or during the previous 30 boiler operating day period, the NOx emission limit shall be determined by the following equation: En = (0.11x + 0.15y)/(100) where: x = percentage of total heat input derived from natural gas during the past 30 boiler operating days y = percentage of total heat input derived from clean cellulosic biomass and/or resinated wood during the past 30 boiler operating days. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.12 Nitrogen Oxides <= 1.60 pounds per megawatt-hour using 30 boiler operating day rolling average. [40 CFR 60.44Da(a)(1), Minn. R. 7011.0560]

5.14.13 Carbon Monoxide: less than or equal to 0.30 lbs/million Btu heat input when combusting clean cellulosic biomass and/or resinated wood, based on a 4-hour block average. "Four-hour block average" means the average of all hourly emission rates when the emissions unit is operating and combusting clean cellulosic biomass and/or resinated wood measured over six discrete four-hour periods beginning at midnight. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.14 Carbon Monoxide: less than or equal to 0.10 lbs/million Btu heat input when combusting natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.15 Carbon Monoxide: When clean cellulosic biomass and/or resinated wood and natural gas are combusted together, or both are combusted during the previous 30 day period, the CO emission limit shall be determined by the following equation: En = (0.10x + 0.30y)/(100) where: En = the CO emission limit in lb/mmBtu x = percentage of total heat input derived from natural gas during the past 30 boiler operating days y = percentage of total heat input derived from clean cellulosic biomass and/or resinated wood during the past 30 boiler operating days. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.16 Ammonia Slip: Limited to less than or equal to 25 ppm. If the ammonia slip exceeds this level, the SNCR system shall be adjusted to reduce the ammonia slip to less than 25 ppm, or shut down until repairs are made and ammonia slip is reduced to 25 ppm or less. [Minn. R. 7007.0800, subp. 2]

5.14.17 The Permittee shall adjust or shut down the SNCR system (TREA 14) when the ammonia slip exceeds the limit set in this permit. The SNCR system (TREA 14) shall not be operated until repairs are made

Page 70: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 70 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation and ammonia slip is reduced to 25 ppm or less. The number of hours that the boiler is operated while the SNCR system (TREA 14) is not operating and results in the BACT emission limit being exceeded, shall not exceed more than 5% of total operating hours per year, based on a 12 month rolling sum. If the ammonia slip limit cannot be met and the SNCR system has been shut down for the maximum number of hours resulting in emissions excess of the BACT limit, then the boiler shall not operate. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.18 Fuel use limited to: natural gas, clean cellulosic biomass (as defined below) and resinated wood (as defined below). When wood and agricultural biomass are burned, the wood must comprise at least 51% of heat input (see Appendix C for the fuel mixing procedure). The agricultural biomass rate of input may not exceed the input rate during the most recent stack emissions testing that demonstrated compliance with particulate matter, PM10, opacity, and carbon monoxide limits. [Minn. R. 7007.0800, subp. 2]

5.14.19 Clean cellulosic biomass is defined as those residuals that are akin to traditional cellulosic biomass such as forest-derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, and tree harvesting residuals from logging and sawmill materials), corn stover and other biomass crops used specifically for energy production (e.g., energy cane, other fast growing grasses), bagasse and other crop residues (e.g., peanut shells), wood collected from forest fire clearance activities, trees and clean wood found in disaster debris, clean biomass from land clearing operations, and clean construction wood. Clean biomass is biomass that does not contain contaminants at concentrations not normally associated with virgin biomass materials. Resinated wood is defined as wood products (containing resin adhesives) derived from primary and secondary wood products manufacturing and comprised of such items as board trim, sander dust, and panel trim. [Minn. R. 7007.0800, subp. 2]

5.14.20 The wood the Permittee uses shall meet the definition of clean cellulosic biomass and the following conditions: 1) residuals from manufacturing processes such as furniture, cabinet, and pallet making, and other wood product manufacture; 2) construction waste; 3) urban and park tree trimming and forest residuals; 4) wood from trees downed by storms; 5) trees removed for urban development; or 6) trees removed as part of a timber management plan. The Permittee shall not use trees cut solely for the purpose of fuel use, unless the trees were specifically planted and grown to be used for fuel. This is a state only requirement and is not federally

Page 71: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 71 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2]

5.14.21 Test Burns: Alternative fuels may be burned in EQUI 11 on a test burn basis under the following conditions: 1. Emissions of any criteria pollutant do not exceed the significant net emission increase levels as defined by 40 CFR Section 52.21. The Permittee shall calculate the emissions that will result from the trial burn prior to commencement of the burn by assuming the expected maximum emission rate of pollutants regulated under 40 CFR Section 52.21 in pounds per hour and multiplying by the maximum number of hours operating with the alternative fuel. 2. No emission limits set in the permit are exceeded. The Permittee shall monitor wherever possible to assure that emission limits are not exceeded. If no continuous monitoring system is available for the pollutant in question, the Permittee shall verify using emission factors that the emission limits will not be exceeded. 3.Testing an alternative fuel must be accommodated with existing emission units and control equipment at the facility. In no instance does this permit authorize the Permittee to make any physical or operational changes that would trigger the applicability of a New Source Performance Standard, Maximum Achievable Control Technology, or Prevention of Significant Deterioration. 4. The Permittee is authorized to conduct test burns of alternative clean cellulosic biomass and/or resinated wood fuels except for peat, wood that has been painted, stained, or pressure treated, waste oil, farm chemicals, pesticide containers, demolition waste except for clean or resinated wood, waste from farms from an open dump, tire derived fuels, non-agricultural industrial process wastes, animal manures and wastes, or any material meeting the definition of a hazardous waste. [Minn. R. 7007.0800, subp. 2]

5.14.22 Alternative Fuel Testing Restrictions: Test burns for any potential fuel shall be limited to 4,000 tons, not more than 45 cumulative days of operation using the fuel, during a test period not to exceed 180 days. The purpose of the test burn shall be to determine the feasibility of the fuel type for the emission source, and shall be conducted only for as long as necessary to make the determination but no longer than limited herein. [Minn. R. 7007.0800, subp. 2]

5.14.23 Alternative Fuel Testing Requirements: Test burns shall be conducted to measure air pollutant emissions and may include measuring PM, PM10, VOC and single and total HAPs emissions, including HCl, monitoring CO, NOx and SO2 emissions, and determining the fuel chlorine content. The final list of air pollutants to be measured and monitored during the test burn will depend on the type of fuel burned and will be finalized in the test plan approved by the MPCA. [Minn. R. 7007.0800, subp. 2]

Page 72: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 72 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.14.24 Alternative Fuel Testing Submittals: 30 days prior to testing of an

alternative fuel, the Permittee shall submit a written performance test notification and test plan. The test plan shall meet the requirements of Minn. R. 7017.2030 and shall also include: 1) the type(s) and estimated amount of alternative fuel to be tested, 2) operating parameters and anticipated fuel mixes during testing for the process heater to be tested, 3) air pollutants that will be monitored and measured during testing, and 4) a testing schedule. [Minn. R. 7017.2018, Minn. R. 7017.2030]

5.14.25 The applicable PM emissions limit and opacity standard under 40 CFR Section 60.42Da, SO2 emissions limit under 40 CFR Section 60.43Da, and NOx emissions limit under 40 CFR Section 60.44Da apply at all times except during periods of startup, shutdown, or malfunction. [40 CFR 60.48Da(a), Minn. R. 7011.0560]

5.14.26 At the end of each boiler operating day, calculate the average emission rate for 30 successive boiler operating days for sulfur dioxide and nitrogen oxides. Compliance is determined by calculating the arithmetic average of all hourly emission rates for sulfur dioxide and nitrogen oxides for the 30 successive boiler operating days, except for data obtained during startup, shutdown, malfunction. [40 CFR 60.48Da(b) and (d), Minn. R. 7011.0560]

5.14.27 Malfunction does include periods when the SNCR system must be shut down and adjusted due to high ammonia slip. For each malfunction, record the date, time, reason, corrective action, and downtime. [Minn. R. 7007.0800, subp. 2]

5.14.28 Determine compliance with applicable daily average PM emissions limit by calculating the arithmetic average of all hourly emission rates each boiler operating day, except for data obtained during periods of startup, shutdown, or malfunction. Daily averages shall be calculated for boiler operating days that have out-of-control periods totaling no more than 6 hours of unit operation during which the standard applies. [40 CFR 60.48Da(f), Minn. R. 7011.0560]

5.14.29 Sulfur Dioxide Monitoring: By the 15th of each month, calculate and record the 12-month rolling sum of sulfur dioxide emissions for the previous 12 months. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.14.30 In conducting the performance tests to determine compliance with the PM emission limits in 40 CFR Section 60.42Da the Permittee shall (1) Measure filterable PM to determine compliance with the applicable PM emissions limit in 40 CFR Section 60.42Da as follows: (i) The dry basis F factor (O2) procedures in Method 19 of appendix A of this part shall be used to compute the emission rate of PM. (ii) For the PM concentration, Method 5 of appendix A of this part shall be used for an affected facility that does not use a wet FGD.

Page 73: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 73 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation For an affected facility that uses a wet FGD, Method 5B of appendix A of this part shall be used downstream of the wet FGD. (A) The sampling time and sample volume for each run shall be at least 120 minutes and 1.70 dscm (60 dscf). The probe and filter holder heating system in the sampling train may be set to provide an average gas temperature of no greater than 160 14 C (320 25 F). (B) For each particulate run, the emission rate correction factor, integrated or grab sampling and analysis procedures of Method 3B of appendix A of this part shall be used to determine the O2 concentration. The O2 sample shall be obtained simultaneously with, and at the same traverse points as, the particulate run. If the particulate run has more than 12 traverse points, the O2 traverse points may be reduced to 12 provided that Method 1 of appendix A of this part is used to locate the 12 O2 traverse points. If the grab sampling procedure is used, the O2 concentration for the run shall be the arithmetic mean of the sample O2 concentrations at all traverse points. (2) In conjunction with a performance test performed according to the requirements in paragraph (b)(1), the owner or operator of an affected facility for which construction, reconstruction, or modification commenced after May 3, 2011, shall measure condensable PM using Method 202 of appendix M of part 51. (3) Method 9 of appendix A of this part and the procedures in 40 CFR Section 60.11 shall be used to determine opacity. [40 CFR 60.50Da(b)(1)-(2), Minn. R. 7011.0560]

5.14.31 The Permittee shall determine compliance with the sulfur dioxide standards in 40 CFR Section 60.43Da as follows: (1) The percent of potential SO2 emissions (%Ps) to the atmosphere shall be computed using the following equation: %P = ((100 -%Rf)*(100-%Rg))/100 Where: %Ps = Percent of potential SO2 emissions, percent; %Rf = Percent reduction from fuel pretreatment, percent; and %Rg = Percent reduction by SO2 control system, percent. (2) The procedures in Method 19 of appendix A of this part may be used to determine percent reduction (%Rf) of sulfur by such processes as fuel pretreatment (physical coal cleaning, hydrodesulfurization of fuel oil, etc.), coal pulverizers, and bottom and fly ash interactions. This determination is optional. (3) The procedures in Method 19 of appendix A of this part shall be used to determine the percent SO2 reduction (%Rg) of any SO2 control system. Alternatively, a combination of an "as fired" fuel monitor and emission rates measured after the control system, following the procedures in Method 19 of appendix A of this part, may be used if the percent reduction is calculated using the average emission rate from the SO2 control device and the average SO2

Page 74: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 74 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation input rate from the "as fired" fuel analysis for 30 successive boiler operating days. (4) The appropriate procedures in Method 19 of appendix A of this part shall be used to determine the emission rate. (5) The CEMS in 40 CFR Section 60.49Da(b) and (d) shall be used to determine the concentrations of SO2 and CO2 or O2. [40 CFR 60.50Da(c), Minn. R. 7011.0560]

5.14.32 The Permittee shall determine compliance with the nitrogen oxides standards in 40 CFR Section 60.44Da as follows: (1) The appropriate procedures in Method 19 of appendix A of this part shall be used to determine the emission rate of NOX. (2) The continuous monitoring system in 40 CFR Section 60.49Da(c) and (d) shall be used to determine the concentrations of NOX and CO2 or O2. [40 CFR 60.50Da(d), Minn. R. 7011.0560]

5.14.33 Install, calibrate, maintain, and operate a continuous opacity monitoring system, and record the output of the system for measuring the opacity of emissions discharged to the atmosphere. [40 CFR 60.49Da(a)(1), Minn. R. 7011.0560]

5.14.34 Install, calibrate, maintain, and operate a continuous emission monitoring system, and record the output of the system, for measuring sulfur dioxide emissions discharged to the atmosphere. [40 CFR 60.49Da(b)(2), Minn. R. 7011.0560]

5.14.35 Install, calibrate, maintain, and operate a continuous emission monitoring system, and record the output of the system, for measuring nitrogen oxides emissions discharged to the atmosphere. [40 CFR 60.49Da(c)(1), Minn. R. 7011.0560]

5.14.36 Install, calibrate, maintain, and operate a continuous emission monitoring system, and record the output of the system, for measuring the oxygen or carbon dioxide content of the flue gases at each location where sulfur dioxide or nitrogen oxide emissions are monitored. [40 CFR 60.49Da(d), Minn. R. 7011.0560]

5.14.37 Install, calibrate, maintain, and operate a continuous emission monitoring system, and record the output of the system for measuring the carbon monoxide emissions discharged to the atmosphere. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.38 Install, calibrate, maintain, and operate a continuous emission monitoring system, and record the output of the system for measuring the ammonia emissions discharged to the atmosphere. [Minn. R. 7007.0800, subp. 2]

5.14.39 The continuous monitoring systems are to be operated and data recorded during all periods of operation of the affected facility including periods of startup, shutdown, malfunction or emergency conditions, except for continuous monitoring systems breakdowns, repairs, calibration checks, and zero and span adjustments. [40 CFR 60.49Da(e), Minn. R. 7011.0560]

Page 75: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 75 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.14.40 The following procedure shall be used to determine gross energy

output for demonstrating compliance with an output-based standard: (1) The Permittee shall install, calibrate, maintain, and operate a wattmeter; measure gross electrical output in MWh on a continuous basis; and record the output of the monitor. (2) The Permittee shall install, calibrate, maintain, and operate meters for steam flow, temperature, and pressure; measure gross process steam output in joules per hour (or Btu per hour) on a continuous basis; and record the output of the monitor. (3) For an affected facility generating process steam in combination with electrical generation, the gross energy output is determined according to the definition of "gross energy output" specified in 40 CFR Section 60.41Da: The gross electrical or mechanical output from the affected facility plus 75 percent of the useful thermal output measured relative to ISO conditions that is not used to generate additional electrical or mechanical output or to enhance the performance of the unit. [40 CFR 60.49Da(k), Minn. R. 7011.0560]

5.14.41 The Permittee shall obtain emission data for at least 18 hours in at least 22 out of 30 successive boiler operating days. If this minimum data requirement cannot be met with a continuous monitoring system, supplement emission data with other monitoring systems approved by the Administrator or the reference methods and procedures as described in 40 CFR Section 60.49Da(h). [40 CFR 60.49Da(f)(1), Minn. R. 7011.0560]

5.14.42 The Permittee shall install, certify, operate, and maintain a continuous flow monitoring system meeting the requirements of Performance Specification 6 of appendix B of this part and the calibration drift (CD) assessment, relative accuracy test audit (RATA), and reporting provisions of procedure 1 of appendix F of this part, and record the output of the system, for measuring the volumetric flow rate of exhaust gases discharged to the atmosphere. [40 CFR 60.49Da(l), Minn. R. 7011.0560]

5.14.43 Requirements pertaining to the installation, operation and maintenance of continuous emission monitoring systems are specified under COMG 5 and COMG 9. [Minn. R. 7007.0800, subp. 2]

5.14.44 The Permittee using a SO2, NOx, CO2, and O2 CEMS to meet the requirements of 40 CFR pt. 60, subp. Da shall install, certify, operate, and maintain the CEMS as specified in 40 CFR Section 60.49Da(w)(1) through (w)(5). [40 CFR 60.49Da(w), Minn. R. 7011.0560]

5.14.45 Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total fuel use and the type of fuel. This shall be based on throughput logs, meter readings, and/or delivery records. [Minn. R. 7007.0800, subps. 4-5]

Page 76: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 76 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.14.46 Recordkeeping: By the 15th day of each month, the Permittee shall

record the amount of natural gas and clean cellulosic biomass and/or resinated wood combusted in the boilers during the previous calendar month. These records shall consist of throughput logs, meter readings, and/or delivery records. [Minn. R. 7007.0800, subps. 4-5]

5.14.47 Monthly Recordkeeping - SO2 By the 15th of each month, the Permittee shall calculate and record the 12-month rolling sum of SO2 emissions for the previous 12 month period. Emissions shall be calculated using CEMS data. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.14.48 Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

5.14.49 Recordkeeping: Maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR pt. 60, subp. Da recorded in a permanent form suitable for inspection. The file shall be retained for at least two years following the date of such measurements, maintenance, reports, and records. [40 CFR 60.7(f), Minn. R. 7019.0100, subp. 1]

5.14.50 Permittee shall not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. [40 CFR 60.12, Minn. R. 7011.0050]

5.14.51 For SO2, NOx, and PM, the performance test data from the initial and subsequent performance test and from the performance evaluation of the continuous monitors must be reported to the Administrator. [40 CFR 60.51Da(a), Minn. R. 7011.0560]

5.14.52 For SO2 and NOX the following information is reported to the Administrator for each 24-hour period: (1) Calendar date. (2) The average SO2 and NOX emission rates (lb/MMBtu) for each 30 successive boiler operating days, ending with the last 30-day period in the quarter; reasons for non-compliance with the emission standards; and, description of corrective actions taken.

Page 77: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 77 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation (3) For owners or operators of affected facilities complying with the percent reduction requirement, percent reduction of the potential combustion concentration of SO2 for each 30 successive boiler operating days, ending with the last 30-day period in the quarter; reasons for non-compliance with the standard; and, description of corrective actions taken. (4) Identification of the boiler operating days for which pollutant or diluent data have not been obtained by an approved method for at least 75 percent of the hours of operation of the facility; justification for not obtaining sufficient data; and description of corrective actions taken. (5) Identification of the times when emissions data have been excluded from the calculation of average emission rates because of startup, shutdown, or malfunction. (6) Identification of "F" factor used for calculations, method of determination, and type of fuel combusted. (7) Identification of times when hourly averages have been obtained based on manual sampling methods. (8) Identification of the times when the pollutant concentration exceeded full span of the CEMS. (9) Description of any modifications to CEMS which could affect the ability of the CEMS to comply with Performance Specifications 2 or 3. [40 CFR 60.51Da(b), Minn. R. 7011.0560]

5.14.53 For any periods for which opacity, SO2 or NOx emissions data are not available, the Permittee shall submit a signed statement indicating if any changes were made in the operation of the emission control system during the period of unavailability. Operations of the control system and affected facility during periods of data unavailability are to be compared with operation of the control system and affected facility before and following the period of unavailability. [40 CFR 60.51Da(f), Minn. R. 7011.0560]

5.14.54 The Permittee shall submit a signed statement indicating whether: 1) The required CEMS calibration, span, and drift checks or other periodic audits have or have not been performed as specified. 2) The data used to show compliance was or was not obtained in accordance with approved methods and procedures of this part and is representative of plant performance. 3) The minimum data requirements have or have not been met; or, the minimum data requirements have not been met for errors that were unavoidable. 4) Compliance with the standards has or has not been achieved

Page 78: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 78 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation during the reporting period. [40 CFR 60.51Da(h), Minn. R. 7011.0560]

5.14.55 Opacity levels in excess of the applicable opacity standard and the date of such excesses are to be submitted to the administrator each calendar quarter. Periods of excess emissions are defined as all 6-minute periods during which the average opacity exceeds the applicable opacity standards under 40 CFR Section 60.42Da(b). [40 CFR 60.51Da(i), Minn. R. 7011.0560]

5.14.56 The Permittee shall submit the reports required under 40 CFR pt. 60, subps. A and Da to the Administrator semiannually for each six-month period. All semiannual reports shall be postmarked by the 30th day following the end of each six-month period. [40 CFR 60.51Da(j), Minn. R. 7011.0560]

5.14.57 Front-half Particulate Matter <= 0.037 pounds per million Btu heat input (filterable PM). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.14.58 Opacity <= 10 percent opacity 24-hour block average. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.14.59 Carbon Monoxide <= 720 parts per million 30-day rolling average calculated by volume on a dry basis @ 3% oxygen. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.14.60 Hydrochloric acid <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.14.61 Mercury <= 5.7E-6 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.14.62 Compliance Date: For EQUI 11, the Permittee must comply with 40 CFR pt. 63, subp. DDDDD no later than January 31, 2016, except as provided in 40 CFR Section 63.6(i). [40 CFR 63.7495(b), Minn. R. 7011.7050]

5.14.63 Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated according to 40 CFR Section 63.7530(c) are less than the HCl and mercury emission limits. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.14.64 Boiler Load. The Permittee must maintain the operating load of each unit such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.14.65 Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra-low sulfur diesel, fuel oil-soaked

Page 79: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 79 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation rags, kerosene, hydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.14.66 Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.14.67 The Permittee shall complete the initial compliance demonstration no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(e), Minn. R. 7011.7050]

5.14.68 CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to 40 CFR Section 63.7525(a) no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(c) and (e), Minn. R. 7011.7050]

5.14.69 Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(d) and (e), Minn. R. 7011.7050]

5.14.70 Filterable PM Limit. The Permittee must install, operate, certify and

Page 80: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 80 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation maintain a COMS according to the procedures in 40 CFR Section 63.7525(c)(1)-(7) by 01/31/2016. [40 CFR 63.7525(c), Minn. R. 7011.7050]

5.14.71 Tune-Ups. The Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) no later than January 31, 2016, except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(e), 40 CFR pt. 63, DDDDD(Table 3), Minn. R. 7011.7050]

5.14.72 Energy Assessment. The Permittee must complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3 no later than January 31, 2016 except as specified in 40 CFR Section 63.7510(j). An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. DDDDD, Table 3, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement. [40 CFR 63.7510(e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.14.73 The Permittee shall report the results of performance tests and the associated fuel analyses within 60 days after the completion of the performance tests. This report must also verify that the operating limits for each boiler have not changed or provide documentation of revised operating limits established according to 40 CFR Section 63.7530 and Table 7 , as applicable. The reports for all subsequent performance tests must include all applicable information required in 40 CFR Section 63.7550. [40 CFR 63.7515(f), Minn. R. 7011.7050]

5.14.74 HCl & Mercury Limits. As specified in 40 CFR Section 63.7555(d), the Permittee must keep records of the type and amount of all fuels burned in each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in equal to or lower fuel input of chlorine and mercury than the maximum values calculated during the last performance test. [40 CFR 63.7540(a)(2)(ii), Minn. R. 7011.7050]

5.14.75 HCl Limit. If the Permittee plans to burn a new type of fuel or a new mixture of fuels, the Permittee shall recalculate the maximum chlorine input using Equation 7 of 40 CFR Section 63.7530. If the results are greater than the maximum chlorine input level established during the previous performance test, the Permittee must conduct a new performance test within 60 days of burning the new fuel type or fuel mixture according to the procedures in 40 CFR Section 63.7520 to demonstrate that the HCl emissions do not exceed the emission limit. The Permittee must also establish new operating limits based on this performance test according to the procedures in 40 CFR Section 63.7530(b). In recalculating the maximum chlorine input and establishing the new operating limits, the Permittee is not required to conduct fuel analyses for and include the fuels described in 40 CFR Section 63.7510(a)(2)(i) through (iii). [40 CFR 63.7540(a)(4), Minn. R. 7011.7050]

5.14.76 Mercury Limit. If the Permittee plans to burn a new type of fuel or a

Page 81: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 81 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation new mixture of fuels, you must recalculate the maximum mercury input using Equation 8 of 40 CFR Section 63.7530. If the results are higher than the maximum mercury input level established during the previous performance test, then the Permittee shall conduct a new performance test within 60 days of burning the new fuel type or fuel mixture according to the procedures in 40 CFR Section 63.7520 to demonstrate that the mercury emissions do not exceed the emission limit. The Permittee shall also establish new operating limits based on this performance test according to the procedures in 40 CFR Section 63.7530(b). The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Sections 63.7510(a)(2)(i) through (iii). The may exclude the fuels described in 40 CFR Sections 63.7510(a)(2)(i) through (iii) when recalculating the mercury emission rate. [40 CFR 63.7540(a)(6), Minn. R. 7011.7050]

5.14.77 CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below. - Continuously monitor CO according to 40 CFR Sections 63.7525(a) and 63.7535. - Maintain a CO emission level below or at the CO emission limit at all times the affected unit is subject to numeric emission limits - Keep records of CO levels according to 40 CFR Section 63.7555(b). - Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site-Specific Monitoring Plan. [40 CFR 63.7540(a)(8), Minn. R. 7011.7050]

5.14.78 Opacity Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: a. Collecting the opacity monitoring system data according to 40 CFR Sections 63.7525(c) and 63.7535; b. Reducing the opacity monitoring data to 6-minute averages; and c. Maintaining opacity to less than or equal to 10 percent (24-hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.14.79 Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: a. Collecting operating load data or steam generation data every 15 minutes; and b. Maintaining the operating load such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test according to 40 CFR Section 63.7520(c). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.14.80 Tune-Ups. The Permittee must conduct an annual tune-up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)-(vi). Each annual tune-up must be no more than 13 months after the previous tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

Page 82: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 82 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.14.81 Tune-Ups. If the unit is not operating on the required date for a

tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.14.82 Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7540(d), Minn. R. 7011.7050]

5.14.83 Fuel Usage recordkeeping by daily inspection reports 4 times per year: The Permittee shall keep records to show that EQUI 11 combusts more than 75 percent non-fossil fuel on a quarterly (calendar) heat input basis to meet the definition of a resource recovery unit. [40 CFR 60.41Da, 40 CFR 60.43Da(d)(2), Minn. R. 7011.0560]

5.14.84 The Permittee shall submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in 40 CFR Section 63.7545(e). [40 CFR 63.7530(f), Minn. R. 7011.7050]

5.14.85 The Permittee shall include with the Notification of Compliance Status a signed certification that either the energy assessment was completed according to Table 3, and that the assessment is an accurate depiction of the facility at the time of the assessment, or that the maximum number of on-site technical hours specified in the definition of energy assessment applicable to the facility has been expended. [40 CFR 63.7530(e), Minn. R. 7011.7050]

5.14.86 The Permittee shall establish parameter operating limits according to Section 40 CFR 63.7530 (b)(4)(i) through (ix). As indicated in Table 4, the Permittee is not required to establish and comply with the operating parameter limits when using a CEMS to monitor and demonstrate compliance with the applicable emission limit for that control device parameter. [40 CFR 63.7530(b)(4), Minn. R. 7011.7050]

5.14.87 Any pollutant for which compliance is demonstrated by a performance test with operating limits based on boiler operating load, The Permittee shall establish a unit specific limit for maximum operating load according to 40 CFR Section 63.7520 (b) and (c) using data from the operating load monitors or from steam generation monitors according to the following requirements: a. The Permittee shall collect operating load or steam generation data every 15 minutes during the entire period of the performance test. b. Determine the average operating load by computing the hourly averages using all of the 15-minute readings taken during each performance test. c. Determine the highest hourly average of the three test run averages during the performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR 63.7530(a)-(b), 40 CFR pt. 63, DDDDD(Table 7), Minn. R. 7011.7050]

5.14.88 Following the date on which the initial compliance demonstration is completed or is required to be completed under 40 CFR Sections 63.7 and 63.7510, whichever date comes first, operation above the

Page 83: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 83 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation established maximum or below the established minimum operating limits shall constitute a deviation of established operating limits listed in Table 4 of this subpart except during performance tests conducted to determine compliance with the emission limits or to establish new operating limits. Operating limits must be confirmed or reestablished during performance tests. [40 CFR 63.7540(a)(1), Minn. R. 7011.7050]

5.14.89 The Permittee shall report each instance in which each emission limit and operating limit in Tables 1 through 4 or 11 through 13 to this subpart that applies was not met. These instances are deviations from the emission limits or operating limits, respectively. These deviations must be reported according to the requirements in 40 CFR Section 63.7550. [40 CFR 60.7540(b), Minn. R. 7011.7050]

5.14.90 The Permittee shall meet the work practice standard according to Table 3. During startup and shutdown, the Permittee must only follow the work practice standards according to items 5 and 6 of Table 3. [40 CFR 60.7530(h), Minn. R. 7011.7050]

EQUI 12 EU008 Coal Ash Silo 5.15.1 The Permittee shall vent emissions from EQUI 12 to TREA 7 and

TREA 8 whenever EQUI 12 operates, and operate and maintain TREA 7 and TREA 8 at all times that any emissions are vented to TREA 7 and TREA 8. The Permittee shall document periods of non-operation of the control equipment. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.15.2 Opacity <= 20 percent opacity except for one six-minute per hour of not more than 60 percent opacity. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7011.0710, subp. 1(B)]

5.15.3 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7011.0710, subp. 1(A)]

EQUI 14 EU004 Boiler 4 5.16.1 Fuel use is limited to natural gas and No. 2 fuel oil. [Minn. R.

7007.0100, subps. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.16.2 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.16.3 Nitrogen Oxides <= 39.0 tons per year 12-month rolling sum basis. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

Page 84: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 84 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.16.4 PM < 10 micron <= 0.40 pounds per million Btu heat input on a 24

hour average. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.16.5 Particulate Matter <= 0.40 pounds per million Btu heat input. The potential to emit from the unit is 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.16.6 Sulfur Content of Fuel <= 0.050 percent by weight for No. 2 fuel oil. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0080]

5.16.7 Sulfur Dioxide <= 1.64 pounds per million Btu heat input. [Minn. R. 7007.0100, subp. 7(A), Minn. R. 7007.0100, subp. 7(L), Minn. R. 7007.0100, subp. 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 4, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.16.8 Sulfur Dioxide <= 24.0 pounds per million Btu heat input when burning liquid fuel. The potential to emit from the unit is 0.056 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.16.9 Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed the limit. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. R. 7009.0010-7009.0080]

5.16.10 Daily Recordkeeping - Fuel Usage Records Maintain records of the type and amount of each fuel burned each day. Daily usage of natural gas and No. 2 fuel oil shall be determined with fuel meters and recorded each day that fuel is combusted. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.16.11 Monthly Recordkeeping - Fuel Usage Records By the 15th day of each month, the fuel usage for the previous 12 months shall be summed to obtain the 12-month fuel usage of each fuel. The 12-month fuel usage shall be used for calculating 12-month rolling sum NOx emissions as required by this permit. [Minn. R. 7007.0800, subps. 4-5]

5.16.12 Monthly Recordkeeping - NOx By the 15th of each month, the Permittee shall calculate and record the 12-month rolling sum of NOx emissions for the previous 12 month period. Emissions shall be calculated using the following equation: NOx = (100(NG14) + 10(OIL14))/2000

Page 85: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 85 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation where NOx = NOx emissions in tons NG14 = past 12 months gas use in EQUI 14, in million cubic feet OIL14 = past 12 months oil use in EQUI 14, in thousands of gallons. [Minn. R. 7007.0800, subps. 4-5]

5.16.13 Monthly Recordkeeping - Fuel Usage Records Maintain records of the type and amount of each fuel burned in each emission unit each month. By the 15th day of each month, the fuel usage for each emission unit for the previous 12 months shall be summed to obtain the 12-month fuel usage for the emission unit. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

EQUI 19 EU001 Boiler 1 5.17.1 Fuel Types: Natural gas and No. 2 fuel oil only. [Minn. R. 7007.0800,

subp. 2] 5.17.2 Sulfur Content of Fuel <= 0.05 percent by weight of No. 2 fuel oil.

[Minn. R. 7007.0800, subp. 2] 5.17.3 Fuel Supplier Certification: The Permittee shall obtain and maintain

a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed the limit. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. R. 7009.0010-7009.0080, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.17.4 Particulate Matter <= 0.40 pounds per million Btu heat input. The potential to emit from the unit is 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.17.5 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

5.17.6 Sulfur Dioxide <= 2.0 pounds per million Btu The potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]

5.17.7 Sulfur Dioxide <= 0.050 pounds per million Btu heat input The potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

EQUI 20 EU005 Boiler 5 5.18.1 Fuel Types: Natural gas and No. 2 fuel oil only. [Minn. R. 7007.0800,

subp. 2] 5.18.2 Sulfur Content of Fuel <= 0.05 percent by weight of No. 2 fuel oil.

[Minn. R. 7007.0800, subp. 2]

Page 86: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 86 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.18.3 Fuel Supplier Certification: The Permittee shall obtain and maintain

a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed the limit. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. R. 7009.0010-7009.0080, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.18.4 Particulate Matter <= 0.40 pounds per million Btu heat input The potential to emit from the unit is 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

5.18.5 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515, subp. 2]

5.18.6 Sulfur Dioxide <= 2.0 pounds per million Btu heat input The potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

5.18.7 Sulfur Dioxide <= 0.050 pounds per million Btu heat input. The potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

EQUI 21 EU006 Boiler 6 5.19.1 Fuel Types: Natural gas and No. 2 fuel oil only. [Minn. R. 7007.0800,

subp. 2] 5.19.2 Sulfur Content of Fuel <= 0.05 percent by weight of No. 2 fuel oil.

[Minn. R. 7007.0800, subp. 2] 5.19.3 Fuel Supplier Certification: The Permittee shall obtain and maintain

a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed the limit. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1-2, Minn. R. 7007.0800, subps. 4-5, Minn. R. 7009.0010-7009.0080, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.19.4 Particulate Matter <= 0.40 pounds per million Btu heat input The potential to emit from the unit is 0.024 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

5.19.5 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515, subp. 2]

5.19.6 Sulfur Dioxide <= 2.0 pounds per million Btu heat input. The potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

Page 87: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 87 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.19.7 Sulfur Dioxide <= 0.050 pounds per million Btu heat input. The

potential to emit from the unit is 0.050 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

EQUI 28 Oxygen analyzer 5.20.1 Emissions Monitoring. The Permittee shall use an oxygen analyzer

to measure oxygen emissions from EQUI11. [40 CFR 63.7525(a), Minn. R. 7011.7050, Minn. R. 7017.1006]

5.20.2 The Permittee must install, certify, operate and maintain an oxygen analyzer according to the procedures in 40 CFR Section 63.7525(a)(1)-(6). [40 CFR 63.7525(a), Minn. R. 7011.7050]

5.20.3 Install the oxygen analyzer by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1), Minn. R. 7011.7050]

5.20.4 The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

5.20.5 Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR 63.7525(a)(3), Minn. R. 7011.7050]

5.20.6 CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

5.20.7 CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)(i), Minn. R. 7017.1010]

5.20.8 CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R. 7017.1010]

5.20.9 CEMS Representative Location: Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be

Page 88: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 88 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)(e)]

5.20.10 CEMS Certification Test Plan: due 60 days before CEMS Certification Test CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test CEMS Certification Test Report: due 45 days after CEMS Certification Test CEMS Certification Test Report - Microfiche Copy: due 105 days after CEMS Certification Test The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R. 7017.1120, subp. 2. [40 CFR 63.8(e), Minn. R. 7017.1060, subps. 1-3, Minn. R. 7017.1080, subps. 1-4]

5.20.11 Continuous Operation: Except for system breakdowns, repairs, calibration checks, and zero and span adjustments, all CEMS shall be in continuous operation. [40 CFR 63.8(c)(4)]

5.20.12 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR pt. 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR 63.8(d), Minn. R. 7017.1170, subp. 2]

5.20.13 CEMS Startup, Shutdown, and Malfunction Plan: Develop and implement a written startup, shutdown, and malfunction plan which complies with 40 CFR Section 63.6(e)(3). [40 CFR 63.8(e)(3)]

5.20.14 CEMS Daily Calibration Drift Test: Check the zero (low level value) and high level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan developed under 40 CFR Sections 63.8(e)(3)(i) and (ii). The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR Sections 63(e)(3)(i) and (ii). The zero and high level must be adjusted at a minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the applicable performance specification. [40 CFR 63.8(c)(6), Minn. R. 7017.1170, subp. 3]

5.20.15 Cylinder Gas Audit (CGA) Results Summary: Due 30 days after the end of each calendar quarter following Permit Issuance in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

5.20.16 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

5.20.17 Relative Accuracy Test Audit (RATA) Notification: Due 30 days before the CEMS Relative Accuracy Test Audit. [Minn. R. 7017.1180, subp. 2]

Page 89: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 89 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.20.18 Recordkeeping: The owner or operator must retain records of all

CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

5.20.19 The CEMS/COMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minnesota Rules. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI 29 Flow Monitor 5.21.1 The Permittee shall install, certify, operate, and maintain a

continuous flow monitoring system meeting the requirements of Performance Specification 6 of appendix B of this part and the calibration drift (CD) assessment, relative accuracy test audit (RATA), and reporting provisions of procedure 1 of appendix F of this part, and record the output of the system, for measuring the volumetric flow rate of exhaust gases discharged to the atmosphere. [40 CFR 60.49Da(l), Minn. R. 7011.0560]

EQUI 30 Teledyne CO

Monitor

5.22.1 The CEMS/COMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minnesota Rules. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

5.22.2 Emissions Monitoring. The Permittee shall use a CO CEMS to measure CO emissions from EQUI11. [40 CFR 63.7525(a), Minn. R. 7011.7050, Minn. R. 7017.1006]

5.22.3 The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 40 CFR Section 63.7525(a)(1)-(6). [40 CFR 63.7525(a), Minn. R. 7011.7050]

5.22.4 Install the CO CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1), Minn. R. 7011.7050]

5.22.5 The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in in 40 CFR

Page 90: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 90 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Sections 63.7540(a)(8) and 63.7525(a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

5.22.6 The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: - The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 4, 4A, or 4B at 40 CFR part 60, Appendix B. - During each relative accuracy test run of the CO CEMS, the Permittee must collect emission data for CO concurrently (or within a 30- to 60-minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. -The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable CO emission limit, expressed as a concentration. - Any CO CEMS that does not comply with 40 CFR Section 63.7525(a) cannot be used to meet any requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. - Complete the initial performance evaluation no later than July 29, 2016. [40 CFR 63.7525(a)(2)(i)-(v), Minn. R. 7011.7050]

5.22.7 Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR 63.7525(a)(3), Minn. R. 7011.7050]

5.22.8 Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(a)(4), Minn. R. 7011.7050]

5.22.9 Calculate one-hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one-hour arithmetic averages required shall be used to calculate the 30-day or 10-day rolling average emissions. Use Equation 19-19 in Section 12.4.1 of Method 19 of 40 CFR pt. 60, Appendix A-7 for calculating the average CO concentration from the hourly values. [40 CFR 63.7525(a)(5), Minn. R. 7011.7050]

5.22.10 For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section 63.7535(b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section 63.7535(c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section 63.7535(d). [40 CFR 63.7525(a)(6), Minn. R. 7011.7050]

Page 91: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 91 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.22.11 CEMS O&M. The Permittee shall maintain and operate the CO CEMS

in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

5.22.12 CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)(i), Minn. R. 7017.1010]

5.22.13 CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R. 7017.1010]

5.22.14 CEMS Representative Location: Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)(e)]

5.22.15 CEMS Certification Test Plan: due 60 days before CEMS Certification Test CEMS Certification Test Pretest Meeting: due 7 days before CEMS Certification Test CEMS Certification Test Report: due 45 days after CEMS Certification Test CEMS Certification Test Report - Microfiche Copy: due 105 days after CEMS Certification Test The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R. 7017.1120, subp. 2. [40 CFR 63.8(e), Minn. R. 7017.1060, subps. 1-3, Minn. R. 7017.1080, subps. 1-4]

5.22.16 Continuous Operation: Except for system breakdowns, repairs, calibration checks, and zero and span adjustments, all CEMS shall be in continuous operation. [40 CFR 63.8(c)(4)]

5.22.17 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR pt. 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR 63.8(d), Minn. R. 7017.1170, subp. 2]

5.22.18 CEMS Startup, Shutdown, and Malfunction Plan: Develop and implement a written startup, shutdown, and malfunction plan which complies with 40 CFR Section 63.6(e)(3). [40 CFR 63.8(e)(3)]

5.22.19 CEMS Daily Calibration Drift Test: Check the zero (low level value) and high level calibration drifts at least once daily in accordance

Page 92: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 92 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation with the written procedure specified in the performance evaluation plan developed under 40 CFR Sections 63.8(e)(3)(i) and (ii). The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR Sections 63(e)(3)(i) and (ii). The zero and high level must be adjusted at a minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the applicable performance specification. [40 CFR 63.8(c)(6), Minn. R. 7017.1170, subp. 3]

EQUI 31 Teledyne Opacity

Monitor

5.23.1 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1200, subp. 1-3]

5.23.2 Emissions Monitoring: The owner or operator shall use a COMS to measure Opacity at STRU 5. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1006]

5.23.3 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1090]

5.23.4 COMS Daily Calibration Drift Test: The owner or operator of a COMS shall conduct daily instrument zero and upscale drift checks according to Procedure 3, section 10.1 of 40 CFR Pt. 60, Appendix F. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1215]

5.23.5 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1200, subp. 1-3]

5.23.6 COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1220]

5.23.7 Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. This requirement will no

Page 93: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 93 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1130]

5.23.8 COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the COMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1050, subp. 1]

5.23.9 QC Program: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1215]

TREA 3 CE008 Centrifugal

Collector - High Efficiency

5.24.1 The Permittee shall vent emissions from EQUI 11 to TREA 3 whenever EQUI 11 operates, and operate and maintain TREA 3 at all times that any emissions are vented to TREA 3. The Permittee shall document periods of non-operation of the control equipment TREA 3 whenever EQUI 11 is operating. See COMG 1 for control efficiency requirement. [Title I Condition: 40 CFR pt. 52, 21(j)(BACT) & Minn. R. 7007.3000]

5.24.2 Pressure Drop >= 0.5 and <= 7.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.24.3 If the Permittee replaces TREA 3, the replacement control must meet or exceed the control efficiency requirements of TREA 3 as well as comply with all other requirements of TREA 3. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.24.4 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of

Page 94: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 94 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.24.5 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.24.6 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.24.7 The Permittee shall operate and maintain the cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.24.8 The Permittee shall maintain and operate a pressure drop monitoring device that continuously indicates and records the pressure drop across the cyclone. The recording device shall also calculate the three-hour rolling average pressure drop. [40 CFR 64.3(b)(ii), Minn. R. 7017.0200]

5.24.9 The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop readings. Readings outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [40 CFR 64.9(b), Minn. R. 7017.0200, Title I Condition: Avoid major source under 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

5.24.10 Pressure Drop: Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.24.11 Annual Calibration: The Permittee shall calibrate the pressure drop monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

5.24.12 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the

Page 95: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 95 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [40 CFR 64.3, Minn. R. 7017.0200]

5.24.13 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the cyclone. The Permittee shall keep a record of the type and date of any corrective action taken for each control device. [40 CFR 64.7(d)]

TREA 4 CE009 Electrostatic

Precipitator - High Efficiency

5.25.1 The Permittee shall vent emissions from EQUI 11 to TREA 4 whenever EQUI 11 operates, and operate and maintain TREA 4 at all times that any emissions are vented to TREA 4. The Permittee shall document periods of non-operation of the control equipment TREA 4 whenever EQUI 11 is operating. See COMG 1 for control efficiency requirements. [Title I Condition: Avoid major source under 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

5.25.2 Total fields online: greater than or equal to 2. Unless a new minimum fields online is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum of fields online is required to be set, it will be based on the fields online recorded during the most recent MPCA approved performance test where compliance for PM and PM10 emissions was demonstrated. [40 CFR 64.3, Minn. R. 7017.0200]

5.25.3 Secondary Voltage >= 25000 volts 3-hour block average, unless a new minimum total power input is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum power input is required to be set, it will be based on the average power input recorded during the most recent MPCA approved performance test where compliance for PM and PM10 emissions was demonstrated. If the three-hour rolling average total power input drops below the minimum limit, this shall be reported as a deviation. [40 CFR 64.3, Minn. R. 7017.0200]

5.25.4 If the Permittee replaces TREA 4, the replacement control must meet or exceed the control efficiency requirements of TREA 4 as well as comply with all other requirements of TREA 4. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee

Page 96: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 96 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.25.5 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing number of fields required to be online or the secondary voltage limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.25.6 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.25.7 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.25.8 The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.25.9 Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI 8 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R. 7017.0200]

5.25.10 Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.25.11 Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles,

Page 97: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 97 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.25.12 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.25.13 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: 1. the total fields online is less than 2 fields; 2. the monitored secondary voltage, averaged over any 3�hour period, is less than 25,000 volts; or 3. the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R. 7017.0200]

TREA 7 CE001 Centrifugal

Collector - Medium Efficiency

5.26.1 The Permittee shall vent emissions from EQUI 12 to TREA 7 whenever EQUI 12 operates, and operate and maintain TREA 7 at all times that any emissions are vented to TREA 7. The Permittee shall document periods of non-operation of the control equipment. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 2]

5.26.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 80.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.26.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 60.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.26.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 60.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800,

Page 98: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 98 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation subp. 14, Minn. R. 7007.0800, subp. 2]

5.26.5 The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14]

5.26.6 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.26.7 Corrective Actions: The Permittee shall take corrective action as soon as possible if the Centrifugal Collector or any of its components are found during the inspections to need repair. Corrective actions include completion of necessary repairs identified during the inspection, as applicable. The Permittee shall keep a record of the type and date of any corrective action taken for each control device. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

TREA 8 CE003 Fabric Filter -

Low Temperature, i.e., T<180 Degrees F

5.27.1 The Permittee shall vent emissions from EQUI 12 to TREA 8 whenever EQUI 12 operates, and operate and maintain TREA 8 at all times that any emissions are vented to TREA 8. The Permittee shall document periods of non-operation of the control equipment. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.27.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.27.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.27.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93.0 percent control efficiency. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800,

Page 99: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 99 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation subp. 14, Minn. R. 7007.0800, subp. 2]

5.27.5 Maintain the pressure drop across the baghouse between 0.5 and 4.0 inches. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.27.6 Visible Emissions: The Permittee shall check the fabric filter stack (STRU 8) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subps. 4-5]

5.27.7 Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subps. 4-5]

5.27.8 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.27.9 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 4]

5.27.10 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.27.11 The Permittee shall operate and maintain the Fabric Filter in accordance with the Operation and Maintenance (O & M) Plan. The

Page 100: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 100 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. This requirement will no longer apply once coal ash is no longer stored in the silo. [Minn. R. 7007.0800, subp. 14]

TREA 14 CE007 Selective

Noncatalytic Reduction for NOX

5.28.1 Nitrogen Oxides: greater than or equal to 32.0 percent control efficiency when combusting clean cellulosic biomass and/or resinated wood. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.28.2 Nitrogen Oxides: greater than or equal to 39.0 percent control efficiency when combusting natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.28.3 Operation and Maintenance of SNCR: The Permittee shall operate and maintain the SNCR in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and review by MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.28.4 Emission Monitoring for NOx: the Permittee shall use a Continuous Emissions Monitoring System (CEMS) to measure NOx emissions from EQUI 11. [40 CFR 64.3(d), Minn. R. 7017.0200]

5.28.5 Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.28.6 Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.28.7 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.28.8 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored NOx emission rate exceeds the permit limit; or - the SNCR or any of its components are found during the inspections to need repair.

Page 101: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 101 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the SNCR. The Permittee shall keep a record of the type and date of any corrective action taken for the SNCR. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

5.28.9 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limit or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity which is considered an excursion, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.28.10 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Section 5 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.28.11 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 1 12300063 District Energy St

Paul Inc-Hans O Nyman

6.1.1 The Permittee shall submit an application for permit reissuance :

Page 102: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 102 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Due 180 calendar days before Permit Expiration Date. [Minn. R. 7007.0400, subp. 2]

6.1.2 The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

6.1.3 The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(C)]

6.1.4 The Permittee shall submit excess emission/downtime report : Due by 30 days after the end of each calendar quarter following permit issuance. Submit this on form DRF-1 (Excess Emissions Reporting) as amended. The EER shall indicate all periods of monitor bypass and exceedances of the limit including those allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions, as well as a summary of audit results and frequencies. If no excess emissions, downtime or bypasses occurred during the quarter, submit a signed report supplying the necessary monitor data needed to verify this. [Minn. R. 7017.1110, subp. 1-2]

COMG 6 GP007 NESHAP DDDDD

Gas 1 Boiler with Curtailment

6.2.1 For each boiler in COMG 6 that is required to have a tune-up every 5 years the Permittee shall submit a compliance report with the information required in 50 CFR Section 63.7550(c) : Due by 01/31/2021 and every 5 years thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2021. 2. The first compliance report must be postmarked or submitted no later than January 31, 2021. 3. Each subsequent compliance report must cover 5-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.2.2 For each boiler in COMG 6 that is required to have a tune-up annually the Permittee shall submit a compliance report with the

Page 103: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 103 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation information required in 40 CFR Section 63.7550(c) : Due annually by January 31 of each year, according to the following requirements. 1. The compliance report must cover the applicable 1-year reporting period from January 1 through December 31. 2. Each compliance report must be postmarked or submitted no later than January 31 of the year in which it is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

EQUI 1 EU002 Boiler 2 6.3.1 The Permittee shall complete an initial tune-up by following the

procedures described in 40 CFR Section 63.7540(a)(10) no later than 180 days after startup as a unit designed to burn gas 1 fuel. [40 CFR 63.7495(b), 40 CFR 63.7510(e), Minn. R. 7011.7050]

6.3.2 If the Permittee is required to conduct tune-ups every 5 years the Permittee shall submit a compliance report : Due by 01/31/2021 and every 5 years thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2021. 2. The first compliance report must be postmarked or submitted no later than January 31, 2021. 3. Each subsequent compliance report must cover 5-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.3.3 If the Permittee is required to conduct tune-ups annually the Permittee shall submit a compliance report : Due by January 31 of the year after the boiler is re-categorized as a unit designed to burn gas 1 fuel, and annually thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on the date of startup on natural gas and ending on December 31 of the year of startup. 2. The first compliance report must be postmarked or submitted no later than January 31. 3. Each subsequent compliance report must cover 1-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.3.4 PM < 10 micron: The Permittee shall conduct a performance test due before 2/14/2020 and every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests

Page 104: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 104 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation shall be completed every 36 months thereafter by the set due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. This requirement will no longer apply once EQUI 1 would no longer burn coal. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.3.5 Particulate Matter: The Permittee shall conduct a performance test due before 2/14/2020 and every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests shall be completed every 36 months thereafter by the set due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. This requirement will no longer apply once EQUI 1 can no longer burn coal. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.3.6 Opacity: The Permittee shall conduct an initial performance test due 180 calendar days after Initial Startup Date on fuel oil to measure Opacity. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, while combusting fuel oil, using EPA Reference Method 9, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.3.7 Opacity: The Permittee shall submit a test frequency plan for

Page 105: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 105 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Opacity: Due 60 calendar days after Initial Performance Test Date for Opacity. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 2 EU003 Boiler 3 6.4.1 The Permittee shall complete an initial tune-up by following the

procedures described in 40 CFR Section 63.7540(a)(10) no later than 180 days after startup as a unit designed to burn gas 1 fuel. [40 CFR 63.7495(b), 40 CFR 63.7510(e), Minn. R. 7011.7050]

6.4.2 If the Permittee is required to conduct tune-ups every 5 years the Permittee shall submit a compliance report : Due by 01/31/2021 and every 5 years thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2021. 2. The first compliance report must be postmarked or submitted no later than January 31, 2021. 3. Each subsequent compliance report must cover 5-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.4.3 If the Permittee is required to conduct tune-ups annually the Permittee shall submit a compliance report : Due by January 31 of the year after the boiler is re-categorized as a unit designed to burn gas 1 fuel, and annually thereafter according to the following requirements. 1. The first compliance report must cover the period beginning on the date of startup on natural gas and ending on December 31 of the year of startup. 2. The first compliance report must be postmarked or submitted no later than January 31. 3. Each subsequent compliance report must cover 1-year periods with each year starting January 1 and ending December 31. 4. Each subsequent compliance report must be postmarked or submitted no later than January 31 of the year the report is due. [40 CFR 63.7550(a), 40 CFR 63.7550(b), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.4.4 PM < 10 micron: The Permittee shall conduct a performance test due before 12/9/2020 and every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests shall be completed every 60 months thereafter by the set due date (month and day) and as described below. The performance

Page 106: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 106 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. This requirement will no longer apply once EQUI 1 can no longer burn coal. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.4.5 Particulate Matter: The Permittee shall conduct a performance test due before 12/9/2020 and every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests shall be completed every 60 months thereafter by the set due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. This requirement will no longer apply once EQUI 2 can no longer burn coal. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.4.6 Opacity: The Permittee shall conduct an initial performance test due 180 calendar days after Initial Startup Date on fuel oil to measure Opacity. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, while burning fuel oil, using EPA Reference Method 9, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

6.4.7 Opacity: The Permittee shall submit a test frequency plan for Opacity: Due 60 calendar days after Initial Performance Test Date for Opacity. The plan shall specify a testing frequency based

Page 107: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 107 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 3 MR001 Sulfur Dioxide 6.5.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30

days after end of each calendar quarter in which a RATA was conducted. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1180, subp. 3]

6.5.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1180, subp. 1]

6.5.3 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7019.1170, subp. 4a]

6.5.4 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1170, subp. 5a]

EQUI 4 MR002 Diluent CO2

Monitor

6.6.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1180, subp. 3]

6.6.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1180, subp. 1]

6.6.3 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due

Page 108: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 108 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7019.1170, subp. 4a]

6.6.4 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. This requirement will no longer apply once EQUI 1 and 2 can no longer burn coal. [Minn. R. 7017.1170, subp. 5a]

EQUI 5 MR004 NOx Monitor 6.7.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30

days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.7.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.7.3 The Permittee shall conduct a relative accuracy test audit: Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

6.7.4 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.7.5 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of

Page 109: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 109 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 6 MR005 Diluent CO2

Monitor

6.8.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.8.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.8.3 The Permittee shall conduct a cylinder gas audit: Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2]

6.8.4 The Permittee shall conduct a relative accuracy test audit: Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

6.8.5 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.8.6 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 7 MR006 SO2 Monitor 6.9.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30

days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.9.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.9.3 The Permittee shall conduct a cylinder gas audit: Due by the end

Page 110: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 110 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2]

6.9.4 The Permittee shall conduct a relative accuracy test audit: Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

6.9.5 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.9.6 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 8 MR007 Opacity monitor 6.10.1 COMS Certification/Recertification Test: due 90 days after the

first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

6.10.2 The Permittee shall conduct quarterly COMS performance audits: Due once per QA operating quarter (calendar quarter in which the unit operates at least 168 hours) after COMS certification test. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation according to Procedure 3 of 40 CFR Pt. 60, Appendix F, section 10.0(2) . [40 CFR pt. 60, Appendix F]

6.10.3 The Permittee shall perform annual zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, Appendix F]

EQUI 9 MR009 NOx Monitor for

Ammonia

6.11.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was

Page 111: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 111 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation conducted. [Minn. R. 7017.1180, subp. 3]

6.11.2 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.11.3 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.11.4 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 11 EU007 Boiler 7 6.12.1 PM < 10 micron: The Permittee shall conduct a performance test

due before 3/25/2019 and every 12 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests shall be completed every 12 months thereafter by the set due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. The performance test frequency may be modified as described below by an approved Performance Test Frequency Plan or within a Notice of Compliance letter.

Page 112: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 112 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation If a performance test result is greater than or equal to 90% of the emission limit, then the testing frequency shall continue or revert to a 12 month frequency until subsequent yearly testing produces three consecutive performance tests which satisfy the criteria listed below: 1. If three consecutive test results are less than 90% of the limit, then the next performance test is due 36 months after the due date of the third test, or 2. if three consecutive test results are less than 60% of the limit, then the next performance test is due in 60 months after the due date of the third test. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.12.2 Particulate Matter: The Permittee shall conduct a performance test due before 3/25/2019 and every 12 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests shall be completed every 12 months thereafter by the set due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. The performance test frequency may be modified as described below by an approved Performance Test Frequency Plan or within a Notice of Compliance letter. If a performance test result is greater than or equal to 90% of the emission limit, then the testing frequency shall continue or revert to a 12 month frequency until subsequent yearly testing produces three consecutive performance tests which satisfy the criteria listed below: 1. If three consecutive test results are less than 90% of the limit, then the next performance test is due 36 months after the due date of the third test, or 2. if three consecutive test results are less than 60% of the limit, then the next performance test is due in 60 months after the due date of the third test. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.12.3 Front-half Particulate Matter: The Permittee shall conduct a

Page 113: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 113 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation performance test due before 3/15/2020 and every 37 months thereafter to measure emissions. Performance tests must be completed no more than 37 months after the previous performance test, except as described below. The test shall be conducted according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b) through (e), (g), and (h), using EPA Reference Method 5 or 17 at 40 CFR part 60, appendix A-3 or A-6. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive 2 year period are at or below 75 percent of the emission limit. When annual tests are required, each such performance test must be conducted no more the 12 months after the previous performance test. [40 CFR 60.7515(a)-(c), Minn. R. 7011.7050, Minn. R. 7017.2015, subp. 3]

6.12.4 Mercury: The Permittee shall conduct a performance test due before 3/15/2020 and every 37 months thereafter to measure emissions. Performance tests must be completed no more than 37 months after the previous performance test, except as described below. The test shall be conducted according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b) through (e), (g), and (h), using EPA Reference Method 29, 30A, or 30B (M29, M30A, or M30B) at 40 CFR part 60, appendix A8 or Method 101A at 40 CFR part 61, appendix B, or ASTM Method D6784a. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive

Page 114: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 114 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 2 year period are at or below 75 percent of the emission limit. When annual tests are required, each such performance test must be conducted no more the 12 months after the previous performance test. [40 CFR 60.63.7515(a)-(c), Minn. R. 7011.7050, Minn. R. 7017.2015, subp. 3]

6.12.5 Hydrochloric acid: The Permittee shall conduct a performance test due before 3/15/2020 and every 37 months thereafter to measure emissions. Performance tests must be completed no more than 37 months after the previous performance test, except as described below. The test shall be conducted according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b) through (e), (g), and (h), using EPA Reference Method 26 or 26A (M26 or M26A) at 40 CFR part 60, appendix A8. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive 2 year period are at or below 75 percent of the emission limit. When annual tests are required, each such performance test must be conducted no more the 12 months after the previous performance test. [40 CFR 60.7515(a)-(c), Minn. R. 7011.7050, Minn. R. 7017.2015, subp. 3]

EQUI 28 Oxygen analyzer 6.13.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30

days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.13.2 Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

6.13.3 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.13.4 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within

Page 115: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 115 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.13.5 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 29 Flow Monitor 6.14.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30

days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.14.2 Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

6.14.3 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

6.14.4 The Permittee shall conduct a cylinder gas audit: Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2]

6.14.5 The Permittee shall conduct a relative accuracy test audit: Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

EQUI 30 Teledyne CO

Monitor

6.15.1 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

6.15.2 Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

6.15.3 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

Page 116: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 116 of 133

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 6.15.4 The Permittee shall conduct CEMS cylinder gas audit (CGA): Due

by the end of every second QA operating quarter (calendar quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA is performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7019.1170, subp. 4a]

6.15.5 The Permittee shall conduct a relative accuracy test audit: Due by the end of every fourth QA operating quarter (calendar quarter in which there are at least 168 unit operating hours). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]

EQUI 31 Teledyne Opacity

Monitor

6.16.1 The Permittee shall conduct quarterly COMS performance audits : Due once per QA operating quarter (calendar quarter in which the unit operates at least 168 hours) after COMS certification test. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation according to Procedure 3 of 40 CFR Pt. 60, Appendix F, section 10.0(2). This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7017.1215]

6.16.2 The Permittee shall perform annual zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. This requirement will no longer apply once EQUI 1 and 2 can no longer combust coal. [Minn. R. 7019.1215]

7. Appendices

Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. Rule description of the activity General applicable requirement Minn. R. 7007.1300, subp. 4 Individual units with potential or actual

emissions meeting the criteria in Minn. R. 7007.1300, subp. 4(A)-(D)

PM, variable depending on airflow Opacity <= 20%, except for one six-minute period per hour of not more than 60%

Page 117: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 117 of 133

Minn. R. Rule description of the activity General applicable requirement The facility has coal, wood, and ash handling activities.

(Minn. R 7011.0610); or PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)

Page 118: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 118 of 133

Appendix B. Fuel Mixture Procedure for EQUI 11 Fuel Mixture Procedure: At the Wood Handling Facility: The following procedure shall be posted at Environmental Wood Supply and followed at all times: When loading trucks with a mixture of wood and agricultural waste, at least three front end loader scoops of wood will be added with two or less scoops of agricultural waste. Each truckload of a mixture of wood and agricultural waste will contain at a minimum 54% wood by weight based on the requirement above and a density of 20 pounds per cubic foot wood and 26 pounds per cubic foot agricultural waste: (3 vol. Wood)(20 lbs/cf)/((3 vol. Wood (20 lbs/cf) + 2 vol. Ag. Waste)(26 lbs/cf)) = 0.54 Onsite: The number of trucks carrying each type of fuel: wood, agricultural waste, and a mixture will be tracked and recorded, including the percentage of each fuel in each truck load. Each calendar day, the total weight of wood and agricultural waste will be calculated, and the percentage of wood heat input into the boiler will be calculated, and the percentage of wood into the boiler will be calculated from the following: Total wood into boiler (lbs)(heating value of wood (Btu/lb)/ ((Total wood into boiler (lbs)(heating value of wood (Btu/lb) + total agricultural waste into boiler (lbs)(heating value of agricultural waste))

Page 119: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 119 of 133

Appendix C. Sulfur Dioxide Compliance Calculation for Boilers 2, 3, and 4 Boilers 2, 3, and 4 Sulfur Dioxide Compliance Calculation

SO2 emissions will be calculated from the following equations for both lbs/hr SO2 and lbs/MMBtu SO2:

Equation 1:

(MCEMS x TOTEXH x MCONVF) – (7CEMS x 7EXH x 7CONVF) = SO2-lbs/hr-2,3,4

Equation 2:

(SO2-lbs/hr-2,3,4)/(H2 + H3 + H4) = SO2-lbs/MMBtu-2,3,4

NOTE: When any boiler is burning only natural gas, propane, or very low sulfur distillate oil its heat input will no longer be included in the Equation 2 calculation. (Its exhaust flowrate will still be included in the total exhaust flowrate calculation).

WHERE:

MCEMS = Main stack SO2 CEMS reading, ppmv

TOTEXH = Exhaust through main stack, total of Boiler 7 exhaust flowmeter and Boilers 2, 3, and 4 exhaust flowrates (from F factor calculations), scfh

TOTEXH = 7EXH + 2EXH + 3EXH + 4EXH

WHERE:

2EXH = (H2)(F2){20.9/(20.9-O2,2)} = Exhaust Flowrate Boiler 2

3EXH = (H3)(F3){20.9/(20.9-O2,3)} = Exhaust Flowrate Boiler 3

4EXH = (H4)(F4){20.9/(20.9-O2,4)} = Exhaust Flowrate Boiler 4

Hi = Boiler i heat input, see calculation method below for H2, H3, and H4

Fi = Boiler i F-factor from EPA reference values, 9,860 dscf/million Btu for coal and 8,710 dscf/million Btu for natural gas

O2,i = Boiler i exhaust oxygen concentration in percent by volume, measured by an oxygen analyzer in the exhaust for each boiler

MCONVF = Appropriate factors to convert concentration and exhaust to pounds per hour SO2 emissions = (1 lb·mole exh/385.6 scf exh)(1 lb·mole SO2/1 x 106 ppmv SO2)(64 lbs SO2/lb·mole SO2)

7CEMS = Boiler 7 SO2 CEMS reading (ppmv)

7EXH = Boiler 7 exhaust flowrate from Boiler 7 exhaust flowmeter (scfh)

7CONVF = Appropriate factors to convert concentration and exhaust to pounds per hour SO2 emissions = (1 lb·mole exh/385.6 scf exh)(1 lb·mole SO2/1 x 106 ppmv SO2)(64 lbs SO2/lb·mole SO2)

SO2-lbs/hr-2,3,4 = SO2 emissions in pounds per hour from Boilers 2, 3, and 4

H2 = Heat Input to Boiler 2, million Btu per hour = (Heat Output, Boiler 2 Steam lbs/hr)(Steam Heating Value Btu/lb)(1 million Btu/1 x 106 Btu) / (Boiler 2 Efficiency, as a function of boiler load, see attached graph of Boiler Efficiency vs Load)

Page 120: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 120 of 133

H3 = Heat Input to Boiler 3, million Btu per hour = (Heat Output, Boiler 3 Steam lbs/hr)(Steam Heating Value Btu/lb)(1 million Btu/1 x 106 Btu) / (Boiler 3 Efficiency, as a function of boiler load, see attached graph of Boiler Efficiency vs Load)

H4 = Heat Input to Boiler 4, million Btu per hour = (Heat Output, Boiler 4 Steam lbs/hr)(Steam Heating Value Btu/lb)(1 million Btu/1 x 106 Btu) / (Boiler 4 Efficiency, as a function of boiler load, see attached graph of Boiler Efficiency vs Load)

SO2-lbs/MMBtu-2,3,4 = SO2 emission in pounds per million Btu from Boilers 2, 3, and 4. St. Paul Cogeneration LLC wood-fired combined heating and power generation facility Boilers 2, 3, and 4 - Efficiency vs. Load

Boiler efficiency at 100% load 80 Boiler efficiency at 30% load 72

Minimum boiler load 20 Boiler efficiency is linear with respect to load

Slope of boiler efficiency line, M 1.14

Y-Intercept, B 68.57143 Equation of boiler efficiency line, Y=MX+B

68.00%

70.00%

72.00%

74.00%

76.00%

78.00%

80.00%

82.00%

0% 20% 40% 60% 80% 100%

Boile

r Effi

cien

cy

Boiler Load

Boiler Efficiency vs. LoadX Y

Boiler Load, %

Boiler Efficiency, %

0% 68.57% 10% 69.71% 20% 70.86% 30% 72.00% 40% 73.14% 50% 74.29% 60% 75.43% 70% 76.57% 80% 77.71% 90% 78.86%

100% 80.00%

Page 121: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 121 of 133

Appendix D. Environmental Wood Supply PM10 Modeling Parameters FS001

Parameter Value Units

Material Throughput 425000 ton/yr FS002 and FS003

Traffic Calculated by Activity Number of Vehicles Passes by Passes by Road Segment

(generally 1, N, or 2N)

Activity Percent

by Truck

Maximum Past Actual

Throughput

Amount per

Vehicle

Number of Vehicles (N)

Segment A

Segment B

Segment C

Segment D

Segment E

Notes --> A B C D D D D E

Wood In 100% 425,000 22 19,318 19,318 19,318 0 19,318 0

Wood Out 100% 425,000 22 19,318 19,318 0 19,318 19,318 0

Front End Loaders 100% 425,000 32,636

Totals 38,636 19,318 19,318 32,636 32,636

Average Daily Traffic 106 53 53 106 89

Fleet Loaded Status Mapped Out by Activity and Road Segment Percent of Vehicle Passes at Full Weight

Activity Empty Weight (tons) Full Weight (tons) Segment

A Segment

B Segment C Segment

D Segment

E

Notes --> F F G G G G E

Wood In 18 40 0% 50% 0% 100% 0%

Wood Out 18 40 100% 0% 50% 0% 0%

Front End Loaders 27.5 27.5 0% 0% 0% 0% 100%

Fleet Average Weight Claculated by Road Segment Fleet Weight (tons) for Emission Purposes

Activity Empty Weight (tons) Full Weight (tons) Segment

A Segment

B Segment

C Segment

D Segment

E Wood In 18 40 18 29 18 40 18

Wood Out 18 40 40 18 29 18 18 Front End Loaders 27.5 27.5 27.5 27.5 27.5 27.5 27.5

FS004 Parameter Value Units

Wood Pile Surface Area 1 ac

FS005 Parameter Value Units

Material Throughput 2125000 ton/yr Mean Wind Speed 10.6 mph

Material Moisture Content 40 %

Page 122: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 122 of 133

PM10 Modeled Emission Rates

Source Annual Emission Rate (g/s) 24-hour Emission Rate (g/s) FS001 - Wood Grinding 0.06724 0.06724

FS002 - Truck Traffic - Segment A 0.0034 0.0034 FS002 - Truck Traffic - Segment A 0.0065 0.0065 FS002 - Truck Traffic - Segment A 0.00394 0.00394 FS002 - Truck Traffic - Segment A 0.00286 0.00286

FS003 - FEL Traffic 0.03363 0.03363 FS004 - Wind Erosion 1 (with wind speed scalars) 1 (with wind speed scalars)

FS005 - Material Handling 0.00137 0.00137

PM10 Background Concentrations

Averaging Period Background Concentration Source 24-hour 56 2008 - 2010 average of H2H values from Red Rock Monitoring Station Annual 22 2008 - 2010 average of annual values from Red Rock Monitoring Station

Page 123: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 123 of 133

Appendix E. PM10 and NOx Modeling Parameters Results of 2001 PM10 and NO2 Modeling Summary of PM10 modeling results

Scenario Modeled

Aver-aging Time

Model Result

(µg/m³)

Back-ground (µg/m³)

Total (µg/m³)

NAAQS (µg/m³)

Location Easting

(m) Northing

(m) NAAQS 24-hr 96 44 140 150 492525 4976620

annual 14 22 36 50 492475 4976670 Summary of NO2 modeling results Scenario Modeled Aver-aging

Time Model Result

(µg/m³)

Back-ground (µg/m³)

Total (µg/m³)

NAAQS (µg/m³)

Location Easting

(m) Northing

(m) NAAQS annual 59 32 91 100 492475 4976670

Modeled Stack Parameters for 2001 PM10 Modeling

Source ID

delta id Description emission

rate g/s emission rate

(lb/hr) emission rate

(tons/yr) utm (x) utm (y) base elev (m)

SV1 SV001 boilers 2,3,4 & 7 11.224 89.0794 389.7222 492372.0 4976419.0 215 SV2 SV002 boiler 1 0.098 0.7778 3.4028 492383.0 4976419.0 215 SV3 SV003 boiler 5 & 6 0.275 2.1825 9.5486 492390.0 4976405.0 215 SV4 SV004 coal ash baghouse 0.006 0.0476 0.2083 492348.0 4976422.0 215 SV5 SV005 wood unloading 0.005 0.0397 0.1736 492338.0 4976377.0 215 SV6 SV006 wood ash capture 0.031 0.2460 1.0764 492338.0 4976377.0 215 SV7 SV007 wood storage silo #1 0.007 0.0556 0.2431 492331.0 4976415.0 215 SV8 SV008 wood storage silo #2 0.007 0.0556 0.2431 492341.0 4976421.0 215

Source

ID delta

id Description Height (m)

Height (ft)

Temp (K)

Temp (F)

exit velocity diameter (m/s) (acfm) (m) (ft)

SV1 SV001 boilers 2,3,4 & 7 78.73 258.3 479.61 404 13.57 542211 4.9 16.08 SV2 SV002 boiler 1 40.02 131.3 533 500 11.5 24872 1.14 3.74 SV3 SV003 boiler 5 & 6 39.41 129.3 533 500 23.09 72121 1.37 4.49 SV4 SV004 coal ash baghouse 0.61 2.00 311 100 0.01 560 5.8 19.03 SV5 SV005 wood unloading 18.29 60.01 283 50 11.88 198 0.1 0.33 SV6 SV006 wood ash capture 18.29 60.01 283 50 20.79 1384 0.2 0.66 SV7 SV007 wood storage silo #1 18.29 60.01 283 50 4.75 316 0.2 0.66 SV8 SV008 wood storage silo #2 18.29 60.01 283 50 4.75 316 0.2 0.66

Page 124: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 124 of 133

Appendix F. SO2 Modeling Parameters 1995 SO2 Modeling Results and Parameters District Energy ISCST2 Modeling Results

Year High 2nd High 1-hr concentration

(ug/m3)

Hight 2nd High 3-hr

concentration

High 2nd High 24-hr

concentration (ug/m3)

High Annual concentration

(ug/m3)

1973 1123.3 585.9 216.2 66.8 1974 1263.2 597.3 226.3 71.8 1975 1286.2 516.7 214 71 1976 1097.1 636.1 211.3 70.3 1977 1029.9 552.2 202.7 67.7

Standards: 1-hr

3-hr

24-hr

annual

Modeling Parameters

Stack 1 (Boilers 2, 3, and 4) Load (%) Heat Input

(MMBtu) Exit Gas Flow

(ACFM) Exit Velocity

(ft/min)

Exit Velocity

(m/s)

Exit Temp

(F)

Exit Temp

(K)

SO2 Emissions

(g/s)

SO2 Emissions

(lb/hr) 1.64 lb/MMBtu 100 584 305000 1517.0 7.71 450 505.2 120.678 957.8

75 438 228750 1137.8 5.78 450 505.2 90.508 718.3

50 292 152500 758.5 3.85 450 505.2 60.339 478.9

25 146 76250 379.3 1.93 450 505.2 30.169 239.4

Stack 2 (Boiler

1) Load (%) Heat Input (MMBtu)

Exit Gas Flow (ACFM)

Exit Velocity (ft/min)

Exit Velocity

(m/s)

Exit Temp

(F)

Exit Temp

(K)

SO2 Emissions

(g/s)

SO2 Emissions

(lb/hr) 0.05 lb/MMBtu 100 66 25000 2264.0 11.50 500 533.0 0.416 3.3

75 49.5 18750 1698.0 8.63 500 533.0 0.312 2.5

50 33 12500 1132.0 5.75 460 510.0 0.208 1.7

25 16.5 6250 566.0 2.88 420 488.6 0.104 0.8

Stack 3 (Boilers

5 and 6) Load (%) Heat Input (MMBtu)

Exit Gas Flow (ACFM)

Exit Velocity (ft/min)

Exit Velocity

(m/s)

Exit Temp

(F)

Exit Temp

(K)

SO2 Emissions

(g/s)

SO2 Emissions

(lb/hr) 0.05 lb/MMBtu 100 200 72300 4546.0 23.09 500 533.00 1.260 10.0

75 150 54225 3409.5 17.32 425 491.3 0.945 7.5

50 100 36150 2273.0 11.55 350 449.7 0.630 5.0

25 50 18075 1136.5 5.77 280 410.8 0.315 2.5

Page 125: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 125 of 133

Appendix G. Modeling Parameters used in Significant Impact Analysis for permit #12300063-101

Permit ID AERMOD ID Pollutant Averaging

Time Operating

Scenario (#) Release

Type Easting, X1 (m) Northing, Y1 (m)

Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec)

Height (m)

Exit Temp (K)

Exit Velocity

(m/s)

Diameter (m)

Flow Rate (ACFM)

STRU 5 STRU 5C NO2 1-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 (294.23) (37.07) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F NO2 1-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 255.23 32.16 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C NO2 annual 1 POINT 4,932,367.733 4,976,622.201 217.32 (105.23) (13.25) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F NO2 annual 1 POINT 4,932,367.733 4,976,622.201 217.32 148.16 18.67 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C SO2 1-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 (664.57) (83.73) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F SO2 1-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 222.75 28.07 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C SO2 3-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 (664.57) (83.73) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F SO2 3-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 222.75 28.07 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C SO2 24-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 (664.57) (83.73) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F SO2 24-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 222.75 28.07 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C SO2 annual 1 POINT 4,932,367.733 4,976,622.201 217.32 (76.36) (9.62) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F SO2 annual 1 POINT 4,932,367.733 4,976,622.201 217.32 13.71 1.73 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5C PM10 24-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 (176.09) (22.19) 78.73 479.817 13.56343 4.901 542,170.132 STRU 5 STRU 5F PM10 24-hr 1 POINT 4,932,367.733 4,976,622.201 217.32 26.5 3.34 78.73 479.817 13.56343 4.901 542,170.132

Page 126: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 126 of 133

Appendix H. Fugitive Emission Control Plan

FUGITIVE EMISSION CONTROL PLAN FOR Hans O. Nyman Energy Center District Energy St. Paul Inc

St. Paul Cogeneration LLC Environmental Wood Supply LLC

Distribution: Ever-Green Energy LLC

Date: March 28, 2016

Page 127: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 127 of 133

Fugitive Emission Control Plan March 28, 2016

Table of Contents

1.0 INTRODUCTION AND PURPOSE ...................................................................................................................... 1 2.0 FUGITIVE DUST OPERATIONS ......................................................................................................................... 2

2.1.1 Transfer of coal from truck to ground pile/hopper grate ...................................................................... 2 2.1.2 Transfer of fly and bottom ash from Boilers 2&3 ash silo into truck ..................................................... 2 2.1.3 Transfer of bottom ash from Boiler 7 conveyor to roll-off containers .................................................. 3 2.1.4 Transfer of fly ash from Boiler 7 ash silo into trucks ............................................................................. 3 2.1.5 Transfer of biomass from truck to hopper............................................................................................. 4 2.1.6 Truck traffic on paved surfaces .............................................................................................................. 4 2.1.7 Transfer of dust/debris from plant vacuum system into roll-off container ........................................... 4 2.1.8 Truck/unloader traffic on unpaved surfaces ......................................................................................... 5 2.1.9 Wind erosion of biomass storage piles .................................................................................................. 5 2.1.10 Transfer of wood chips (from delivery truck, grinder output, screener output, or from front end

loader) ................................................................................................................................................... 5 2.1.11 Wood grinding and screening ................................................................................................................ 5

Page 128: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 128 of 133

Fugitive Emission Control Plan 1 March 28, 2016

1.0 INTRODUCTION AND PURPOSE

District Energy St Paul Inc. (DESP), St. Paul Cogeneration LLC (SPC), and Environmental Wood Supply LLC (EWS) operate fugitive air emission sources under Minnesota Pollution Control Agency (MPCA) air permit number 12300063-004 (Permit). DESP and SPC operate fugitive air emission sources at the Energy Center located at 76 Kellogg Blvd West, St. Paul, MN and EWS operates fugitive air emission sources at the Wood Yard located at 2165 Pigs Eye Lake Rd, St. Paul, MN. Permit condition 5.1.22 requires that the permittee assemble a fugitive emission control plan that identifies all fugitive emission sources1, the primary and contingent control measures for each fugitive source, and recordkeeping associated with minimizing fugitive emissions. This Fugitive Dust Control Plan (Plan) satisfies Permit condition 5.1.22.

1 "Fugitive emissions" means pollutant discharges that could not reasonably pass through a stack, chimney, or other functionally equivalent opening. [MN. Rule 7005.0100]

Page 129: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 129 of 133

Fugitive Emission Control Plan 2 March 28, 2016

2.0 FUGITIVE DUST OPERATIONS

Table 1 identifies fugitive emission sources at the Energy Center and Wood Yard. Table 1: Fugitive Emission Sources

Fugitive Emission Description Pollutant Location

Transfer of coal from truck to ground pile/hopper grate PM/PM10/PM2.5 Energy Center Transfer of fly and bottom ash from Boilers 2&3 ash silo into truck PM/PM10/PM2.5 Energy Center Transfer of bottom ash from Boiler 7 conveyor to roll-off containers PM/PM10/PM2.5 Energy Center Transfer of fly ash from Boiler 7 ash silo into trucks PM/PM10/PM2.5 Energy Center Transfer of biomass from truck to hopper PM/PM10/PM2.5 Energy Center Truck traffic on paved surfaces PM/PM10/PM2.5 Energy Center Transfer of dust/debris from plant vacuum system into roll-off container PM/PM10/PM2.5 Energy Center Truck/loader traffic on unpaved surfaces PM/PM10/PM2.5 Wood Yard Wind erosion of biomass storage piles PM/PM10/PM2.5 Wood Yard Transfer of wood chips (from delivery truck, grinder output, screener output, or from front end loader)

PM/PM10/PM2.5 Wood Yard

Wood grinding and screening PM/PM10/PM2.5 Wood Yard

Notes: PM = particulate matter, PM10 = particulate matter less than 10 microns, PM2.5= particulate matter less than 2.5 microns

Each of the fugitive emission sources, control measures, and recordkeeping are discussed below. Appendix A contains process flow diagrams that indicate where some of these fugitive emissions are generated.

2.1.1 Transfer of coal from truck to ground pile/hopper grate

Coal is only used in Boilers 2 and 3 and is typically used during the coldest few months of the year. Boilers 2 and 3 have federally enforceable Permit conditions that limit operation to no more than 10% of total annual capacity so coal use is limited. Coal is stored at a third party storage yard and trucked in as needed. Coal is dumped in an area outside the building that has a grate leading to the coal hopper. The transfer of coal from a delivery truck to the grate can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Coal use is limited. ¢ The transfer point is adjacent to a building in an area somewhat protected from the wind which

aids in minimizing emissions. Recordkeeping requirements associated with this fugitive source is/are:

¢ Total amount of coal delivered is tracked on a monthly basis.

2.1.2 Transfer of fly and bottom ash from Boilers 2&3 ash silo into truck

Boilers 2 and 3 generate fly and bottom ash when coal is combusted. Ash remains in an enclosed system until it reaches the ash silo where it is stored prior to removal. Ash is transferred from the silo into trucks

Page 130: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 130 of 133

Fugitive Emission Control Plan 3 March 28, 2016

for removal from the Energy Center. The transfer of ash from silo to truck can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Ash is wetted with water and loaded using a dustless unloader before being deposited into the

truck. ¢ Ash is loaded into the truck in a partial enclosure.

Recordkeeping requirements associated with this fugitive source is/are:

¢ The watering system is inspected periodically to verify operation. This can be documented in the plant’s maintenance tracking system.

2.1.3 Transfer of bottom ash from Boiler 7 conveyor to roll-off containers

Boiler 7 generates bottom ash when biomass is combusted. Ash is transferred from the boiler on a conveyor through a water bath and into a roll-off container. The transfer of ash from the conveyor to the roll-off container can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Ash is completely submerged in a water bath not only to wet the ash to reduce emissions but to

quench any embers that remain. Water saturation results in emission reduction. Water level is automatically maintained using a float.

¢ Wetted ash is transferred to the roll-off in an enclosure. Recordkeeping requirements associated with this fugitive source is/are:

¢ The water bath is located in an area where it can be readily observed and action would be taken

in the event that the liquid level is too low. No written records or logs of these observations are maintained.

2.1.4 Transfer of fly ash from Boiler 7 ash silo into trucks

Boiler 7 generates fly ash when biomass is combusted. Ash stays in an enclosed system until it reaches the ash silo where it is stored prior to removal. Ash is transferred from the silo into trucks for removal from the Energy Center. The transfer of ash from silo to truck can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Ash is wetted with water before it is deposited into the truck. ¢ Ash is loaded into the truck in a partial enclosure.

Recordkeeping requirements associated with this fugitive source is/are:

¢ The watering system is inspected periodically to verify operation. This can be documented in the plant’s maintenance tracking system.

Page 131: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 131 of 133

Fugitive Emission Control Plan 4 March 28, 2016

2.1.5 Transfer of biomass from truck to hopper

Biomass is delivered to the Energy center via truck. Biomass is unloaded in a partial enclosure into a hopper where it enters an enclosed system. The transfer of biomass from truck to hopper can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Transfers occur in a partial enclosure ¢ Wood transferred is wet wood with a moisture content generally greater than 30%

Recordkeeping requirements associated with this fugitive source is/are:

¢ Wood is periodically tested for moisture content; these analysis are available upon request 2.1.6 Truck traffic on paved surfaces

Truck traffic exists due to the delivery of coal, wood, and fuel oil as well as from ash trucks removing ash at the Energy Center. Trucks travel on a paved surface while at the Energy Center. The paved surface is only large enough to allow a truck to travel approximately 250 feet (one way) while on site. Vehicle traffic on a paved surface can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ The maximum one way path on site is approximately 250 feet; this is a short enough distance

that trucks cannot operate at elevated speeds. Lower speeds result in lower emissions. ¢ The road surface is cleaned by an outside contractor periodically.

Recordkeeping requirements associated with this fugitive source is/are:

¢ Invoices from the sweeper contracted to clean the paved surface are kept in the accounting office. 2.1.7 Transfer of dust/debris from plant vacuum system into roll-off container

The Energy Center has a plant-wide vacuum system used to clean debris during maintenance activities. It is routed to a cyclone then to a bag filter. Most of the collected dust/debris collects in the cyclone and is transferred into a roll-off container. The transfer of dust/debris from the cyclone to the roll-off can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ The vacuum system is typically only used for maintenance activities. The plant estimates that

approximately 4 roll-off containers are filled annually. Emissions are minimized by the nature of its use.

Recordkeeping requirements associated with this fugitive source is/are:

¢ Due to the limited and insignificance of this activity, no written records are kept.

Page 132: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 132 of 133

Fugitive Emission Control Plan 5 March 28, 2016

2.1.8 Truck/unloader traffic on unpaved surfaces

Truck and front end loader traffic occurs at the Wood Yard due to wood chip haul trucks and front end loader movement on unpaved surfaces throughout the Wood Yard. Vehicle traffic on an unpaved surface can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Haul road surfaces are watered one per 12-hour period during operation from April 1 through

October 31 unless there is a 0.16 inch or greater rainfall that day. Conditions from November 1-March 31 are such that the ground is frozen and emissions are negligible.

¢ There is a posted speed limit of 5 miles per hour at the wood yard. Recordkeeping requirements associated with this fugitive source is/are:

¢ A log is kept each day indicating if the roads were watered or documenting the reason why they

were not watered as per the air permit requirements (see Appendix B for example form) 2.1.9 Wind erosion of biomass storage piles

Biomass fuel is stored in outside storage piles. The action of wind on a storage pile can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Piles are not disturbed any more than necessary to maintain operations and safety. Disturbing a

pile exposes more fines to wind erosion. ¢ Wood processed at the Wood Yard typically contains at least 30% moisture.

Recordkeeping requirements associated with this fugitive source is/are:

¢ Wood is periodically tested for moisture content; these analysis are available upon request 2.1.10 Transfer of wood chips (from delivery truck, grinder output, screener output, or from front end loader)

Biomass must be transferred at the Wood Yard. The transfer of material can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

¢ Wood is not handled more than is necessary to produce usable fuel. This not only reduces

emissions from material transfer but also increases the efficiency of the Wood Yard. ¢ Wood processed at the Wood Yard typically contains approximately 30% moisture.

Recordkeeping requirements associated with this fugitive source is/are:

¢ Wood is periodically tested for moisture content; these analysis are available upon request 2.1.11 Wood grinding and screening

Biomass is delivered to the Wood Yard as either whole trees/brush or wood chips. Depending on the form of wood delivery, it is either routed through a screener or wood grinder. The screening or grinding action can generate emissions of PM/PM10/PM2.5. Emissions are minimized using the following methods:

Page 133: Intent to Amend Air Emission Permit to District Energy St ... · The District Energy St Paul Inc-Hans O Nyman (Facility) is located at 76 Kellogg Boulevard W in Saint Paul, Ramsey

Permit Issued: [month day, year] 12300063-101 Permit Expires: [month day, year] Page 133 of 133

Fugitive Emission Control Plan 6 March 28, 2016

¢ When possible, incoming wood is screened rather than ground which reduces emission. ¢ Wood processed at the Wood Yard typically contains approximately 30% moisture. Recordkeeping

requirements associated with this fugitive source is/are:

¢ Wood is periodically tested for moisture content; these analysis are available upon request ¢ Wood throughput is tracked on a daily and monthly basis as per the Permit


Recommended