air emission permit no. 13100071-002 is issued to ...the permittee elected to install a general...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 13100071-002

IS ISSUED TO

Minnesota Municipal Power Agency

Faribault Energy Park Township 110N, Range 21W, Section 13

East of Interstate 35 & South of 170th Street Faribault, Rice County, MN 55021

The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Issue Date Action Number Total Facility Operating Permit 06/11/2003 and 02/20/2004 07/15/2004 001 Major Amendment 05/27/2004 and 10/25/2004 Administrative Amendment 06/23/2004 See below 002

This permit authorizes the permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Part 70/Incorporates Existing NSR Conditions from PER 001 Issue Date: January 13, 2005 Expiration: July 15, 2009 Title I Conditions do not expire. Richard J. Sandberg Air Permits Section Manager Industrial Division for Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency

Draft Permit No. 13100071-002 of 5

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule - not used in this permit Appendices: Insignificant Activities Stack Parameter used in Modeling Acid Rain Permit Application


NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.


FACILITY DESCRIPTION: The is a combustion turbine generator (CTG) with various support equipment scheduled to start operation in 2005. The CTG will be fueled primarily with pipeline natural gas (PNG), with very low sulfur distillate fuel oil for backup. The CTG is subject to the federal acid rain program. Initially the facility will be constructed as a simple cycle CTG, with a diesel-fired emergency generator, a diesel-fired fire pump, and two distillate fuel oil storage tanks. In simple cycle mode, the CTG will have a gross electric output of approximately 185 megawatts @ 44°F and operation will be limited to 2700 hours per year including 200 hours per year for startup and shutdown. The Permittee anticipates operating the simple cycle CTG as a peaking unit. Emissions will be controlled by dry-low NOx combustion, water injection, low sulfur fuels, and good combustion practices. Requirements for the simple cycle CTG operation are located in subject item EU 006. Construction for combined cycle operation will involve the addition of a heat recovery steam generator (HRSG) with a new stack for the CTG exhaust, along with an auxiliary boiler, and a cooling tower. In combined cycle mode, generating capacity will be approximately 280 megawatts gross and 250 megawatts net at 44°F. The CTG will produce approximately 180 megawatts gross, with the remainder generated by a steam turbine powered by the HRSG. The Permittee intends to operate the combined cycle facility as an intermediate load plant. Operation is anticipated to be 16 hours a day for five days a week (Monday through Friday). A duct burner will not be used in this combined cycle system. Emissions will be controlled by selective catalytic reduction, dry-low NOx combustion, water injection, low sulfur fuels, and good combustion practices. Requirements for the combined cycle CTG operation are located in subject item EU 001. ACTION 002: This major amendment adds applicable Title IV acid rain program requirements. In addition, the amendment authorizes installation of a GE Frame 7FA combustion turbine which is similar to the originally permitted Mitsubishi 501F that was not available. Permit No. 13100071-001 prohibited operation if a similar gas turbine was selected in place of the Mitsubishi turbine, until a major amendment was issued. This amendment (No. 13100071-002) revises that prohibition by allowing operation of the GE turbine in simple cycle mode only. This revision was made because the Permittee submitted a revised PSD air analysis and a revised Minnesota air emissions risk analysis for the GE turbine operating in simple cycle mode demonstrating equal or lesser impacts than for the Mitsubishi gas turbine operating in simple cycle mode. This permit amendment continues the prohibition on combined cycle operation of the GE turbine until another major amendment is issued incorporating any changes needed to accommodate combined cycle operation of the GE turbine. This amendment also includes a name change for the owner/operator of the facility from Faribault Energy Park, L.L.C. to Minnesota Municipal Power Agency, revises requirements for the gas turbine based on revisions to title 40 code of federal regulations part 60 subp. GG,


Standards of Performance for Stationary Gas Turbines effective July 8, 2004, and removes already-completed notification and submittal requirements regarding the manufacturer and model of gas turbine selected for this facility.

TABLE A: LIMITS AND OTHER REQUIREMENTS 01/13/05

Faribault Energy Park

13100071 - 002

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itOPERATIONAL REQUIREMENTS hdr

Permitted Installation and Operating Modes: Permit No. 13100071-001 allowedinstallation and operation of a Mitsubishi M501F (or equivalent) combustion turbinegenerator (CTG) in either simple cycle or combined cycle mode. For the purposesof Permit No. 13100071-001, 'equivalent' was any combustion turbine capable offiring the same fuels, with similar (approximately +/-5%) fuel-specific heat inputcapacity at a given ambient operating temperature and 60% relative humidity,similar gross electric output, and includes the Siemens-Westinghouse 501F andthe GE MS7001F series.

The Permittee elected to install a General Electric MS7001F series turbine (alsoknown as a GE Frame 7FA model 7241) in place of the Mitsubishi M501F CTG.

(continued below)

Minn. R. 7007.0800, subp. 2

Permitted Installation and Operating Modes (continued from above):

Permit No. 13100071-002 authorizes construction of the GE Frame 7FA CTG andoperation of the GE CTG in simple cycle mode. The Permittee shall not operatethe GE CTG in combined cycle mode until a major amendment is issuedauthorizing combined cycle operation.

CTG requirements for simple cycle operation are found in subject item EU 006, andCTG requirements for combined cycle operation are found in EU 001.

Once the Permittee commences combined cycle operation, the Permittee isprohibited from operating in simple cycle mode. EU 002 shall not be operatedduring EU 006 simple cycle operation.

Minn. R. 7007.0800, subp. 2

Sulfur Dioxide: less than or equal to 132 tons/year on a 12-month rolling sum basiswhen the CTG operates in combined cycle mode. This limit applies to the totalSO2 emissions for all fuels combusted in EU 001, EU 002, EU 003, and EU 004.

During the initial 12 months of EU 001 combined cycle operation, the limit frommonth 1 through month 'n' shall be as follows:

n = 1: 34 tonsn = 2: 68 tonsn = 3: 102 tonsn = 4 through 12: 132 tons

Title I Condition: 40 CFR Section 52.21 BACT limit forSO2 and to restrict H2SO4 emissions to less than thesignificant emission rate

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

This source is subject to the U.S. EPA Acid Rain Program codified at 40 CFR Parts72, 73, and 75. Some of the Acid Rain Program's requirements are included inTables A and B of this permit. All Acid Rain Program requirements are in thePermittee's acid rain permit application in the appendix to this permit.

EU 001/EU 006 is a utility unit and is also a new unit, an oil-fired unit, and agas-fired unit, as defined in 40 CFR Section 72.2.

40 CFR Parts 72, 73 and 75

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and shall include a preventativemaintenance program for that equipment, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipment toproper operation to meet applicable permit conditions, a description of theemployee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 16(J)

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13100071 - 002

Facility Name:

Permit Number:

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A and/or B.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

40 CFR Section 60.8(d); Minn. R. 7017.2030, subps.1-4, Minn. R. 7017.2018; and Minn. R. 7017.2035,subps. 1 and 2

Limits set as a result of a performance test apply until superseded as specified byMinn. R. 7017.2025 following formal review of a subsequent performance test onthe same emission unit.

Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Combined Cycle Operation Fuel Usage Records and Fuel Oil Source: After EU001 combined cycle operation commences, once each day the Permittee shallcalculate and record the total EU 001 and EU 002 natural gas usage in millioncubic feet, and the total EU 001, EU 002, EU 003, and EU 004 No. 2 distillate fueloil usage in gallons. By the 15th day of each month, the Permittee shall calculateand record the total monthly usage of each fuel type for the previous calendarmonth.

Distillate fuel oil for EU 001, EU 002, EU 003, and EU 004 shall be provided fromTK 001 and TK 002 (the two common storage tanks) so that the same fuel oil iscombusted in all four emission units.

Title I Condition: Monitoring for 40 CFR Section 52.21BACT Limit; Minn. R. 7007.0800, subps. 4 and 5

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13100071 - 002

Facility Name:

Permit Number:

Combined Cycle Operation Monthly SO2 Emissions: By the 15th day of eachmonth, the Permittee shall calculate and record the SO2 emissions for the previouscalendar month using the following equation:

SO2 = [(2.8571 * Sg * NG) + ( 0.02 * So * D * OIL)]/2000

where:

SO2 = tons per month of SO22.8571 = conversion factor (SO2 lb-lb-scf/S lb-gr-mmscf)Sg = grains of sulfur per 100 standard cubic feet of pipeline natural gasNG = millions of standard cubic feet of natural gas combusted during the previousmonth0.02 = conversion factor (SO2 lb/S lb; % to decimal)So = % sulfur content by weight in distillate oil (i.e., 0.02% = 0.02)D = density of distillate fuel oil in pounds per gallonOIL = gallons of distillate oil combusted during the previous month

Determine Sg, So, and D according to 40 CFR part 75, Appendix D.

Minn. R. 7007.0800, subp. 5

Combined Cycle 12-Month SO2 Emissions Calculations: By the 15th day of eachmonth, calculate and record the 12-month rolling sum total facility SO2 emissionsby summing the monthly SO2 emissions from the previous 12 months.

Minn. R. 7007.0800, subp. 5

Recordkeeping: Maintain records of the occurrence and duration of any startup,shutdown, or malfunction in the operation of EU 001, EU 002, and/or EU 006, orthe malfunction of any EU 001 or EU 006 control equipment.

40 CFR Section 60.7(b)

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

REPORTING/SUBMITTALS hdr

Obtain Major Amendment Permit Prior to Commencing Combined Cycle Operation:The Permittee shall submit a permit application for a major amendment to permitNo. 13100071-002. The application for the major amendment shall proposenecessary permit revisions meeting the requirements of 40 CFR Sections 52.21(j)and (k), and the MPCA Air Assessment Risk Analysis. The Permittee shall notcommence combined cycle operation of the GE combustion turbine generator untilthe major amendment is issued.

Minn. R. 7007.0800, subp. 2

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired 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 operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

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13100071 - 002

Facility Name:

Permit Number:

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). Submit the report on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

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13100071 - 002

Facility Name:

Permit Number:

Subject Item: EU 001 General Electric 7FA Combustion Turbine

Associated Items: CE 001 Selective Catalytic Reduction

CE 002 Dry Low NOx Combustion

CE 003 Water Injection

MR 001 NOx CEM

MR 002 CO CEM

SV 001 Combustion Turbine & HRSG Stack

What to do Why to do itEMISSION LIMITS AND OPERATING REQUIREMENTS - COMBINED CYCLEOPERATION

NOTE: These limits apply to the original Mitsubishi 501F gas turbine that will bereplaced by a GE Frame 7FA. Some of these limits will be revised through a majoramendment prior to construction of the additional equipment to convert from simplecycle operation to combined cycle operation of the GE gas turbine.

hdr

SV 001: The Permittee shall only use SV 001 to vent emissions to the atmospherefrom the combined cycle operation of the combustion turbine generator. ThePermittee shall not use SV 005 to vent emissions from EU 001.

Title I Condition: 40 CFR Section 52.21(k)

Phased Construction BACT Requirement: The initial construction of this facility asa simple cycle combustion turbine generator, with subsequent conversion to acombined cycle combustion turbine generator, is a phased construction projectsubject to the BACT requirement in 40 CFR Section 52.21(j)(4).

The determination of best available control technology shall be reviewed andmodified as appropriate at the latest reasonable time which occurs not more than18 months prior to commencement of construction of the additional equipment tooperate the combustion turbine generator in combined cycle mode. At such time,the Permittee may be required to demonstrate the adequacy of any previousdetermination of best available control technology for the facility.

Title I Condition: 40 CFR Section 52.21(j)(4) BACTRequirement

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Nitrogen Oxides: less than or equal to 3.0 parts per million using 3-hour Average byvolume on a dry basis corrected to 15% O2 when combusting natural gas. Thislimit applies at all times except during startup, shutdown, or malfunction.

Title I Condition: 40 CFR Section 52.21(j) BACT limit;meets 98.95 pmvd @15% O2 limit in 40 CFR Section60.332(a)(1)

Nitrogen Oxides: less than or equal to 6.0 parts per million by volume on a drybasis corrected to 15% O2 when combusting distillate fuel oil. This limit applies atall times except during startup, shutdown, or malfunction.

Title I Condition: 40 CFR Section 52.21(j) BACT limit;meets 108.105 ppmvd @15% O2 limit in 40 CFRSection 60.332(a)(1)

Sulfur Dioxide: less than or equal to 0.8 grains of sulfur/100 standard cubic feet ofnatural gas on a calendar year average. This limit applies at all times includingstartup, shutdown, and malfunction. This limit is equivalent to 0.00227 lbSO2/mmBtu @ 1005 Btu/scf.

Title I Condition: 40 CFR Section 52.21(j) SO2 BACTlimit and to limit H2SO4 to less than significantemission rate in 40 CFR Section 52.21(b)(23)(i); meetslimit in 40 CFR Section 60.333 and Minn. R.7011.2300, subp. 2

Sulfur Dioxide: less than or equal to 0.051 lbs/million Btu heat input whencombusting distillate fuel oil. This limit is equivalent to a sulfur content of 0.05% byweight and applies at all times including startup, shutdown, and malfunction.

Title I Condition: 40 CFR Section 52.21(j) SO2 BACTlimit and to limit H2SO4 to less than significantemission rate in 40 CFR Section 52.21(b)(23)(i); meetslimit in 40 CFR Section 60.333 and Minn. R.7011.2300, subp. 2

Carbon Monoxide: less than or equal to 10.0 parts per million using 3-hour Averageby volume on a dry basis corrected to 15% O2 when combusting natural gas ordistillate fuel oil. This limit applies at all times except during startup, shutdown, ormalfunction.

Title I Condition: 40 CFR Section 52.21(j) BACT limit

Particulate Matter < 10 micron: less than or equal to 0.01 lbs/million Btu heat inputusing 3-hour Average when combusting natural gas. This limit applies at all timesexcept during startup, shutdown, or malfunction.


Particulate Matter < 10 micron: less than or equal to 0.03 lbs/million Btu heat inputusing 3-hour Average when combusting distillate fuel oil. This limit applies at alltimes except during startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.01 lbs/million Btu heat input using3-hour Average when combusting natural gas. This limit applies at all times exceptduring startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.03 lbs/million Btu heat input using3-hour Average when combusting distillate fuel oil. This limit applies at all timesexcept during startup, shutdown, or malfunction.


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13100071 - 002

Facility Name:

Permit Number:

Volatile Organic Compounds: less than or equal to 1.0 parts per million using3-hour Average by volume on a dry basis corrected to 15% O2. This limit applieswhen combusting natural gas, and at all times except during startup, shutdown, ormalfunction.


Volatile Organic Compounds: less than or equal to 5.0 parts per million by volumeon a dry basis corrected to 15% O2. This limit applies when combusting fuel oil,and at all times except during startup, shutdown, or malfunction.


The Permittee shall operate EU 001 in a manner consistent with good combustionpractices to restrict emissions of PM, PM10, CO, and VOC.

Title I Condition: 40 CFR Section 52.21(j) BACToperating condition to limit PM, PM10, VOC, and CO

Permitted Fuel Types: Natural gas as defined in 40 CFR Section 72.2, except totalsulfur content shall not exceed 0.8 grains/100 scf and the natural gas shall beobtained from a supplier through a pipeline, and distillate fuel oil with a sulfurcontent not to exceed 0.05% by weight.

Title I Condition: To meet 40 CFR Section 52.21(j)BACT limits for SO2 and restrict H2SO4 emissions toless than the significant emission rate in 40 CFRSection 52.21(b)(23)(i); Minn. R. 7007.0800, subp. 2

EU 001 Operating Modes:

1. Startup and Shutdown Operating Mode is all EU 001 operation at 60% orgreater load for the specific compressor inlet ambient conditions.

2. Normal Operating Mode is all EU 001 operation at less than 60% load for thespecific compressor inlet ambient conditions.

Minn. R. 7007.0800, subp. 2

STARTUP AND SHUTDOWN REQUIREMENTS hdr

Startup and Shutdown While Combusting Pipeline Natural Gas: Not to exceed1255 hours per year on a 12-month rolling sum.


n = 1: 150 hoursn = 2: 280 hoursn = 3: 400 hoursn = 4: 515 hoursn = 5: 620 hoursn = 6: 720 hoursn = 7: 820 hoursn = 8: 910 hoursn = 9: 1000 hoursn = 10: 1085 hoursn = 11: 1170 hoursn = 12: 1255 hours

Title I Condition: 40 CFR Section 52.21(j) BACToperating condition to limit PM, PM10, NOx, VOC, andCO

Startup and Shutdown While Combusting Distillate Fuel Oil: Not to exceed 485hours per year on a 12-month rolling sum.


n = 1: 60 hoursn = 2: 108 hoursn = 3: 155 hoursn = 4: 200 hoursn = 5: 242 hoursn = 6: 282 hoursn = 7: 320 hoursn = 8: 355 hoursn = 9: 388 hoursn = 10: 421 hoursn = 11: 453 hoursn = 12: 485 hours

Title I Condition: 40 CFR Section 52.21(j) BACToperating condition to limit PM, PM10, NOx, VOC andCO

Control Equipment Operation During Startup and Shutdown: Operation of CE 001,CE 002, and CE 003 is not required during EU 001 startup or shutdown.

Minn. R. 7007.0800, subp. 2

MONITORING hdr

Emissions Monitoring: The Permittee shall use a Continuous Emissions MonitoringSystem (CEMS) to measure NOx emissions, and measure or calculate SO2 andCO2 in accordance with 40 CFR Part 75. The Permittee shall measure NOxemissions in ppmvd corrected to 15% oxygen and automatically calculate andrecord the 3-hour average NOx emission rate. NOx ppmvd emission data shallalso be converted to lb/mmBtu as required by part 75.

Title I Condition: monitoring for 40 CFR Section52.21(j) NOx and SO2 BACT limits; 40 CFR Section75.10 for SO2 and NOx; 40 CFR Sections 64.3(d)(1)and 60.334 for NOx CEMS

Emissions Monitoring: The owner or operator shall use a CEMS to measure COemissions in ppmvd corrected to 15% oxygen. The Permittee shall automaticallycalculate and record the 3-hour average CO emission rate.

Title I Condition: monitoring for 40 CFR Section52.21(j) CO BACT limit

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13100071 - 002

Facility Name:

Permit Number:

Fuel Monitoring: The Permittee shall follow the procedures in 40 CFR Sections60.334(h) and (i) to monitor sulfur and nitrogen content of the fuels combusted inEU 001, unless the Permittee develops a custom schedule according to 40 CFRSection 60.334(i)(3).

40 CFR Sections 60.334(h) and 60.334(i)

Emissions Monitoring: The Permittee shall measure or calculate SO2, NOx, andCO2 emission rates for each affected unit in accordance with 40 CFR Section 75.

40 CFR Section 75.10

CLEAN UNIT DESIGNATION REQUIREMENTS hdr

EU 001 Clean Unit Designation for NOx:

1. Use of CE 001 (selective catalytic reduction with ammonia injection) and CE 002(dry low NOx combustion) for NOx control qualifies EU 001 as a Clean Unit for NOxwhen combusting natural gas, provided the Permittee complies with the provisionsof 40 CFR Section 52.21(x); and

2. Use of CE 001 (selective catalytic reduction with ammonia injection) and CE 003(water injection) for NOx control qualifies EU 001 as a Clean Unit for NOx whencombusting distillate fuel oil, provided the Permittee complies with the provisions of40 CFR Section 52.21(x).

Title I Condition: 40 CFR Sections 52.21 (x)(3)(ii) and(x)(6)(i)

Clean Unit Designation for NOx Effective Date: The effective date is the earlier ofthree years after the issuance date of this permit or the date on which the controlequipment (CE 001, CE 002, and CE 003) is placed into service.

The Permittee shall indicate the date that CE 001, CE 002, and CE 003 are placedinto service in the 'Notification of Actual Date of Initial Startup' notificationrequirement for EU 001 in 'Table B: One Time Submittals Or Notifications'.

Title I Condition: 40 CFR Section 52.21(x)(4)(i)

Clean Unit Designation for NOx Expiration Date: The expiration date is the earlierof ten years after the effective date, or ten years after CE 001/CE 002/CE 003 wentinto service. In addition, the Clean Unit designation expires any time the Permitteefails to comply with the provisions for maintaining the Clean Unit designation in 40CFR Section 52.21(x)(7).

Title I Condition: 40 CFR Section 52.21(x)(5)(i)

Basis for Clean Unit Designation for NOx: In addition to the EU 001 NOx BACTlimits contained in this permit, the following parameters formed the basis for theclean unit designation:

1. Heat and Fuel Input Capacities:a. 1.867 mmcf natural gas/hour & 1876 mmBtu/hr heat input capacity @ 44F;b. 12,960 gallons distillate fuel oil/hour & 1801 mmBtu/hr heat input capacity @44F;

2. Startup and shutdown hours limits (CE 001 does not operate):a. 1255 hours per year when combusting natural gas;b. 485 hours per year when combusting distillate fuel oil;

3. Use of SCR with dry low NOx combustion when combusting natural gas;

4. Use of SCR with water injection when combusting fuel oil;

5. EU 001 Operating Modes definitions of startup/shutdown and normal operations.

Title I Condition: 40 CFR Section 52.21(x)(6)(iv)

Maintaining Clean Unit Designation for NOx: To maintain the Clean Unitdesignation for NOx, the Permittee must conform to all the restrictions listed in 40CFR Section 52.21(x)(7). Failure to do so results in EU 001 losing this Clean Unitdesignation.

Title I Condition: 40 CFR Section 52.21(x)(7)

ACID RAIN COMPLIANCE REQUIREMENTS

For additional requirement information, refer to the acid rain permit application inthe appendix of this permit.

hdr

The owner/operator shall operate the unit in compliance with all acid rain permitconditions in this permit and the acid rain permit application in the appendix of thispermit.

40 CFR Section 72.9(a)

Emissions from the stationary source cannot exceed any allowances that thesource lawfully holds under federal acid rain regulations, except as allowed byMinn. R. 7007.0800, subp. 7.

Minn. R. 7007.0800, subp. 7

If the unit has excess emissions, the designated representative shall submit aproposed offset plan in accordance with 40 CFR Section 72.9(e).

40 CFR Section 72.9(e)

Keep the certificate of representation, all emissions monitoring information, copiesof all reports, compliance certifications and related submissions, and all recordsmade or required under the Acid Rain Program on site for a period of 5 years fromthe date the document was created.

40 CFR Section 72.9(f)

Hold allowances after January 1, 2001, as of the allowance transfer deadline, in theunit's compliance subaccount. Allowances may not be less than the total annualemissions of sulfur dioxide from the previous calendar year from the unit.

40 CFR Section 72.9(c)

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13100071 - 002

Facility Name:

Permit Number:

RECORDKEEPING hdr

Recordkeeping - Gross Electric Power Output: The Permittee shall operate andmaintain instrumentation that instantaneously measures and electronically recordsEU 001 gross power output (in megawatts) at all times during operation of the EU001.

Title I Condition: Monitoring for 40 CFR Section52.21(j) BACT operating condition; Minn. R.7007.0800, subp. 5

Daily Startup and Shutdown Operating Hours Recordkeeping: Once each day thePermittee shall calculate and record EU 001 startup and shutdown operating hoursfor the previous calendar day. Seperate records shall be kept for each permittedfuel type.

Startup and shutdown operating hours shall be determined using the electronicdata produced by instrumentation that instantaneously measures EU 001 grosselectric power output.

Title I Condition: Monitoring for 40 CFR Section52.21(j) BACT operating condition; Minn. R.7007.0800, subp. 5

Monthly Startup and Shutdown Operating Hours Recordkeeping: By the 15th dayof each month, the Permittee shall calculate and record the total EU 001 startupand shutdown operating hours for the previous month and for the previous12-month period, for each permitted fuel.

Minn. R. 7007.0800, subps. 4 and 5

NOx and CO Emissions Recordkeeping: The Permittee shall automatically recordthe 3-hour average ppmvd @15% oxygen CO and NOx emissions data generatedby the CO and NOx CEMS.

Title I Condition: Recordkeeping for 40 CFR Section52.21(j) BACT limits

Recordkeeping - Fuel Sulfur Content: The Permittee shall record the results ofeach fuel sulfur analysis.

Title I Condition: Recordkeeping for 40 CFR Section52.21(j) BACT limits

CEMS REQUIREMENTS hdr

Installation Notification: due 60 days before installing the continuous emissionsmonitoring system.

Minn. R. 7017.1040, subp. 1

CO CEMS Certification Test: due within 90 days after the due date of the firstexcess emissions report required for the CO CEMS. Follow the PerformanceSpecifications listed in 40 CFR part 60, Appendix B.

Minn. R. 7017.1050, subp. 1

NOx CEMS Certification Test: due in accordance with 40 CFR Section 75.4(b).Certify all CEMS required by the Acid Rain Program in accordance with 40 CFRpart 75, Appendix A.

40 CFR Section 75.4(b)

NOx and CO CEMS Certification Test Plans: due 45 days before the correspondingCEMS Certification Test.

40 CFR Section 75.62; 40 CFR Section 75.20; Minn.R. 7017.1060, subps. 1 & 2

NOx and CO CEMS Certification Test Pretest Meeting: due 7 days thecorresponding CEMS Certification Test.

Minn. R. 7017.1060, subp. 3

NOx and CO CEMS Certification Test Reports: due 45 days after thecorresponding CEMS Certification Test.

40 CFR Section 75.63; Minn. R. 7017.1080, subp. 2

NOx and CO CEMS Certification Test Report - Microfiche Copy: due 105 days afterthe corresponding CEMS Certification Test.

Minn. R. 7017.1080, subp. 3

NOx CEMS Quality Assurance/Quality Control (QA/QC): The Permittee shalloperate, calibrate, and maintain the NOx CEMS according to the QA/QC procedurein 40 CFR part 75, Appendix B, as amended.


NOx CEMS and CO CEMS Continuous Operation: The NOx CEMS and CO CEMSmust be operated and data recorded during all periods of emission unit operationincluding periods of emission unit start-up, shutdown, or malfunction except forperiods of acceptable monitor downtime. This requirement applies whether or not anumerical emission limit applies during these periods. The CEMS must not bebypassed except in emergencies where failure to bypass would endanger humanhealth, safety, or plant equipment.

Acceptable CEM downtime includes reasonable periods as listed in items A, B, Cand D of Minn. R. 7017.1090, subp. 2.

Minn. R. 7017.1090, subp. 1

NOx CEMS Daily Calibration Error (CE) Test: Conduct daily CE testing on the NOxCEMS in accordance with 40 CFR part 75, Appendix B.

40 CFR part 75, Appendix B, section 2.1

CO CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified andrecorded at zero (low-level) and upscale (high-level) gas concentrations at leastonce daily. The CO CEMS shall be adjusted whenever the CD exceeds twice thespecification of 40 CFR part 60, Appendix B. 40 CFR part 60, Appendix F shall beused to determine out-of-control periods for the CO CEMS. Follow the proceduresin 40 CFR part 60, Appendix F.

Minn. R. 7017.1170, subp. 3

Linearity and Leak Check Test (Acid Rain Program): due before end of eachcalendar quarter following CEM Certification Test. Conduct a quarterly linearity teston the NOx CEMS in accordance with 40 CFR part 75, Appendix B.


NOx CEMS Linearity Test Results Summary: due 30 days after end of eachcalendar quarter following Linearity and Leak Check Test if performed.

Minn. R. 7017.1180, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each half-yearfollowing CEM Certification Test. Conduct a NOx CEMS RATA, in accordance with40 CFR part 75, Appendix B. If the RATA results indicate a relative accuracy of7.5% or less, the next RATA is not required for twelve months.


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13100071 - 002

Facility Name:

Permit Number:

CO CEMS Relative Accuracy Test Audit (RATA): due before end of each calendaryear following CO CEMS Certification Test. If the relative accuracy is 15% or lessthe next CO CEMS RATA is not due for 24 months. Follow the procedures in 40CFR part 60, Appendices B and F.

Minn. R. 7017.1170, subp. 5

NOx and CO CEMS Relative Accuracy Test Audit (RATA) Notification: due 30 daysbefore the corresponding CEMS RATA.

Minn. R. 7017.1180, subp. 2

NOx and CO CEMS Relative Accuracy Test Audit (RATA) Results Summary: due30 days after end of each calender quarter in which the corresponding CEMSRATA was conducted.

Minn. R. 7017.1180, subp. 3

CO CEMS Cylinder Gas Audit (CGA): due before end of each calendar half-yearfollowing CEMS Certification Test. Conduct CGA at least 3 months apart and notgreater than 8 months apart. Follow the procedures in 40 CFR part 60, AppendixF.

Minn. R. 7017.1170, subp. 4

CO CEMS Cylinder Gas Audit (CGA) Results Summary: due 30 days after end ofeach calendar half-year following CGA.

Minn. R. 7017.1180, subp. 1

Recordkeeping: The owner or operator must retain records of all CEMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

Minn. R 7017.1130; 40 CFR Section 75.50

PERFORMANCE TESTING REQUIREMENTS

(Refer to the Total Facility section of Table A for additional applicable performancetesting requirements)

hdr

Initial Performance Test: due 180 days after Initial Startup in combined cycle modebut no later than 60 days after achieving the maximum production rate, to measureNOx emissions. Separate tests shall be conducted for each permitted fuel type,and shall be conducted according to the requirements of 40 CFR Sections 60.8(b),60.8(c), and 60.335(c). Initial startup refers to startup of combined cycle operation.

Title I Condition: to measure NOx emissions subject toa 40 CFR Section 52.21(j) BACT limit; meetsrequirements of 40 CFR Sections 60.8(a) and60.335(c)

Initial Performance Test: due 180 days after Initial Startup in combined cycle modebut no later than 60 days after achieving the maximum production rate, to measureSO2 emissions. Separate tests shall be conducted for each permitted fuel type,and shall be conducted according to the requirements of 40 CFR Sections 60.8(b),60.8(c), and 60.335(d). Initial startup refers to startup of combined cycle operation.

Title I Condition: to measure SO2 emissions subject toa 40 CFR Section 52.21(j) BACT limit; meetsrequirements of 40 CFR Sections 60.8(a) and60.335(d)

Initial Performance Test: due 180 days after Initial Startup in combined cycle modebut no later than 60 days after achieving the maximum production rate, to measurePM, PM10, CO, and VOC emissions. Separate tests shall be conducted for eachpermitted fuel type. Initial startup refers to startup of combined cycle operation.

Title I Condition: to measure PM, PM10, and VOCemissions subject to a 40 CFR Section 52.21(j) BACTlimit

A-9



13100071 - 002

Facility Name:

Permit Number:

Subject Item: EU 002 Auxiliary Boiler

Associated Items: CE 004 Low NOx Burner

CE 005 Flue Gas Recirculation

SV 002 Auxiliary Boiler Stack

What to do Why to do itEMISSION AND OPERATING LIMITS hdr

Particulate Matter < 10 micron: less than or equal to 0.008 lbs/million Btu heat inputusing 3-hour Average when combusting natural gas. This standard applies at alltimes except during periods of startup, shutdown, or malfunction.

Title I Condition: 40 CFR Section 52.21(j) BACT Limit

Particulate Matter < 10 micron: less than or equal to 0.024 lbs/million Btu heat inputusing 3-hour Average when combusting distillate fuel oil. This standard applies atall times except during periods of startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.008 lbs/million Btu heat input using3-hour Average when combusting natural gas. This standard applies at all timesexcept during periods of startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.024 lbs/million Btu heat input using3-hour Rolling Average when combusting distillate fuel oil. This standard applies atall times except during periods of startup, shutdown, or malfunction.


Carbon Monoxide: less than or equal to 0.084 lbs/million Btu heat input using3-hour Average when combusting natural gas. This standard applies at all timesexcept during periods of startup, shutdown, or malfunction.


Carbon Monoxide: less than or equal to 0.036 lbs/million Btu heat input using3-hour Average when combusting distillate fuel oil. This standard applies at alltimes except during periods of startup, shutdown, or malfunction.


Nitrogen Oxides: less than or equal to 0.040 lbs/million Btu heat input using 3-hourAverage when combusting natural gas. This standard applies at all times exceptduring periods of startup, shutdown, or malfunction.


Nitrogen Oxides: less than or equal to 0.058 lbs/million Btu heat input using 3-hourAverage when combusting distillate fuel oil. This standard applies at all timesexcept during periods of startup, shutdown, or malfunction.


Sulfur Dioxide: less than or equal to 0.8 grains of sulfur/100 standard cubic feet ofnatural gas on a calendar year average. This limit applies at all times includingstartup, shutdown, and malfunction. This limit is equivalent to 0.00224 lbSO2/mmBtu @ 1020 Btu/scf.


Sulfur Dioxide: less than or equal to 0.051 lbs/million Btu heat input whencombusting distillate fuel oil. This limit applies at all times including startup,shutdown, or malfunction.

Title I Condition: 40 CFR Section 52.21(j) BACT Limit;meets requirements of 40 CFR Section 60.42c(d)

Volatile Organic Compounds: less than or equal to 0.006 lbs/million Btu heat inputusing 3-hour Average (as methane). This standard applies when combustingnatural gas, and at all times except during periods of startup, shutdown, ormalfunction.


Volatile Organic Compounds: less than or equal to 0.003 lbs/million Btu heat inputusing 3-hour Average (as methane). This standard applies when combustingdistillate fuel oil, and at all times except during periods of startup, shutdown, ormalfunction.


Opacity: less than or equal to 20 percent opacity except for one 6-minute period perhour of not more than 27% opacity, when combusting distillate fuel oil. Thisstandard applies at all times except during periods of startup, shutdown, ormalfunction.

40 CFR Section 60.43c(c)


Title I Condition: 40 CFR Section 52.21(j) BACToperating condition to limit PM, PM10, VOC, and CO


Title I Condition: 40 CFR Section 52.21(j) BACT Limitfor SO2; Minn. R. 7007.0800, subp. 2

MONITORING AND RECORDKEEPING hdr

Fuel Usage Recordkeeping: Record and maintain records of the amounts of eachfuel combusted on a monthly basis. These records may be in the form of fuel billsor meter readings.

40 CFR Section 60.13(i) and February 20, 1992, EPAmemorandum to meet the requirements of 40 CFRSection 60.48c(g)

Distillate Fuel Oil Supplier Certification: The Permittee shall obtain a certificationfrom the fuel oil supplier for each fuel oil delivery. The certification shall indicatethe supplier's name and contain a statement from the supplier that the oil complieswith the specifications under the definition of distillate oil in 40 CFR Section 60.41c.

40 CFR Section 60.48c(f)

PERFORMANCE TESTING REQUIREMENTS hdr

A-10



13100071 - 002

Facility Name:

Permit Number:

Initial Performance Test: due 180 days after Initial Startup, but no later than 60days after achieving the maximum production rate at which EU 002 will be operatedwhile combusting distillate fuel oil, to measure opacity while combusting distillatefuel oil. Testing shall meet the requirements of 40 CFR Section 60.8.


Initial Performance Test: due 180 days after Initial Startup but no later than 60 daysafter achieving the maximum production rate, to measure PM, PM10, NOx, CO,and VOC emissions. Seperate tests shall be conducted for each permitted fueltype.

Title I Condition: to measure PM, PM10, NOx, CO,and VOC emissions subject to a 40 CFR Section52.21(j) BACT limit

A-11



13100071 - 002

Facility Name:

Permit Number:

Subject Item: EU 003 Emergency Generator - 500 kW (670.5 hp)

Associated Items: SV 003 Emergency Generator Stack

What to do Why to do itOpacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Particulate Matter < 10 micron: less than or equal to 0.06 lbs/million Btu heat inputusing 3-hour Average


Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input using3-hour Average


Sulfur Dioxide: less than or equal to 0.051 lbs/million Btu heat input Title I Condition: 40 CFR Section 52.21(j) BACT Limit;meets requirements of Minn. R. 7011.2300, subp. 2

Carbon Monoxide: less than or equal to 0.76 lbs/million Btu heat input using 3-hourAverage


Volatile Organic Compounds: less than or equal to 0.1 lbs/million Btu heat inputusing 3-hour Average


Nitrogen Oxides: less than or equal to 3.28 lbs/million Btu heat input using 3-hourAverage


The Permittee shall operate EU 003 in a manner consistent with good combustionpractices to restrict emissions of PM, PM10, NOx, CO, and VOC.


Permitted Fuel: Distillate fuel oil with a sulfur content not to exceed 0.05% byweight.

Title I Condition: 40 CFR Section 52.21(j) BACT;meets requirements of Minn. R. 7011.2300, subp. 2

Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency diesel generator by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

Minn. R. 7007.0800, subps. 4 and 5

A-12



13100071 - 002

Facility Name:

Permit Number:

Subject Item: EU 004 Diesel Fire Pump

Associated Items: SV 004 Emergency Fire Pump Stack

What to do Why to do itOpacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Particulate Matter < 10 micron: less than or equal to 0.31 lbs/million Btu heat inputusing 3-hour Average


Total Particulate Matter: less than or equal to 0.31 lbs/million Btu heat input using3-hour Average


Sulfur Dioxide: less than or equal to 0.051 lbs/million Btu heat input Title I Conditions: 40 CFR Section 52.21(j) BACT Limitand 40 CFR Section 52.21(k)(1) to avoid violation of3-hour SO2 ambient air quality standard; meetsrequirements of Minn. R. 7011.2300, subp. 2

Nitrogen Oxides: less than or equal to 4.41 lbs/million Btu heat input using 3-hourAverage


Carbon Monoxide: less than or equal to 0.95 lbs/million Btu heat input using 3-hourAverage


Volatile Organic Compounds: less than or equal to 0.36 lbs/million Btu heat inputusing 3-hour Average


The Permittee shall operate EU 004 in a manner consistent with good combustionpractices to restrict emissions of PM, PM10, NOx, CO, and VOC.


Permitted Fuels: Distillate fuel oil with sulfur content not to exceed 0.05% byweight.

Title I Condition: 40 CFR Section 52.21(j) BACT;meets requirements of Minn. R. 7011.2300, subp. 2

Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency diesel engine by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

Minn. R. 7007.0800, subps. 4 and 5

A-13



13100071 - 002

Facility Name:

Permit Number:

Subject Item: EU 006 General Electric 7FA Combustion Turbine

Associated Items: CE 002 Dry Low NOx Combustion

CE 003 Water Injection

SV 005 GE Simple Cycle Combustion Turbine Stack

What to do Why to do itEMISSION LIMITS AND OPERATING REQUIREMENTS - SIMPLE CYCLEOPERATION

hdr

SV 005: The Permittee shall only use SV 005 for simple cycle operation of thecombustion turbine generator. The Permitee shall cease use of SV 005 uponcommencing combined cycle operation of the combustion turbine generator.

Minn. R. 7007.0800, subp. 2

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Simple Cycle Operating Life: The Permittee is allowed to operate the combustionturbine generator (CTG) in simple cycle mode during the thirty-six month periodfollowing initial startup of the combustion turbine generator. Any change in plannedoperation of the CTG in simple cycle mode beyond 36 months requires thePermittee to file an application to amend this permit in accordance withMinn. R. ch. 7007 and federal New Source Review permitting requirements.

Inital startup means the first time that any fuel is fired in the CTG, for any reason.


Nitrogen Oxides: less than or equal to 242.9 tons/year using 12-month Rolling Sumcalculated by the 15th day of each month. During the first 12 months of operation,the applicable NOx limit shall be determined as follows:

NOx = 48.83 + (n * 16.17)

where:

NOx = NOx limit in tons, as of month 'n'n = number of month(s) since EU 006 inital startup

For example, EU 006 inital startup occurs on June 10. In the first NOx calculation(required by July 15th), n = 1.


Nitrogen Oxides: less than or equal to 9.0 parts per million using 3-hour Average byvolume on a dry basis corrected to 15% O2 when combusting natural gas. Thislimit applies at all times except during startup, shutdown, or malfunction.


Nitrogen Oxides: less than or equal to 42.0 parts per million using 3-hour Averageby volume on a dry basis corrected to 15% O2 when combusting distillate fuel oil.This limit applies at all times except during startup, shutdown, or malfunction.


Sulfur Dioxide: less than or equal to 0.8 grains of sulfur/100 standard cubic feet ofnatural gas on a calendar year average. This limit applies at all times includingstartup, shutdown, and malfunction. This limit is equivalent to 0.00227 lbSO2/mmBtu heat input @ 1005 Btu/scf.

Title I Condition: To restrict emissions to less than thesignificant emissions rate in 40 CFR Section52.21(b)(23)(i); meets limit in 40 CFR Section 60.333and Minn. R. 7011.2300, subp. 2

Sulfur Dioxide: less than or equal to 0.051 lbs/million Btu heat input whencombusting distillate fuel oil. This limit is equivalent to a sulfur content of 0.05% byweight and applies at all times including startup, shutdown, and malfunction.

Title I Condition: To restrict emissions to less than themajor source level in 40 CFR Section 52.21(b)(1)(i)(b);meets limit in 40 CFR Section 60.333 and Minn. R.7011.2300, subp. 2

Carbon Monoxide: less than or equal to 9.0 parts per million by volume on a drybasis corrected to 15% O2 when combusting natural gas. This limit applies at alltimes except during startup, shutdown, or malfunction.


Carbon Monoxide: less than or equal to 20.0 parts per million using 3-hour Averageby volume on a dry basis corrected to 15% O2 when combusting distillate fuel oil.This limit applies at all times except during startup, shutdown, or malfunction.


Particulate Matter < 10 micron: less than or equal to 0.01 lbs/million Btu heat inputusing 3-hour Average when combusting natural gas. This limit applies at all timesexcept during startup, shutdown, or malfunction.


Particulate Matter < 10 micron: less than or equal to 0.03 lbs/million Btu heat inputusing 3-hour Average when combusting distillate fuel oil. This limit applies at alltimes except during startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.01 lbs/million Btu heat input using3-hour Average when combusting natural gas. This limit applies at all times exceptduring startup, shutdown, or malfunction.


Total Particulate Matter: less than or equal to 0.03 lbs/million Btu heat input using3-hour Average when combusting distillate fuel oil. This limit applies at all timesexcept during startup, shutdown, or malfunction.


A-14



13100071 - 002

Facility Name:

Permit Number:

Volatile Organic Compounds: less than or equal to 1.5 parts per million using3-hour Average by volume on a dry basis corrected to 15% O2 (as propane). Thislimit applies when combusting natural gas, and at all times except during startup,shutdown, or malfunction.

Title I Condition: To restrict emissions to less than thesignificant emissions rate in 40 CFR Section52.21(b)(23)(i)

Volatile Organic Compounds: less than or equal to 3.5 parts per million using3-hour Average by volume on a dry basis corrected to 15% O2 (as propane). Thislimit applies when combusting distillate fuel oil, and at all times except duringstartup, shutdown, or malfunction.

Title I Condition: To restrict emissions to less than thesignificant emissions rate in 40 CFR Section52.21(b)(23)(i)


Title I Condition: 40 CFR Section 52.21(j) BACT limitfor PM, PM10, and CO, and to restrict VOC emissionsto less than the significant emissions rate in 40 CFRSection 52.21(b)(23)(i)


Title I Condition: To restrict SO2 emissions to lessthan the major source level and to restrict H2SO4emissions to less than the significant emissions rate in40 CFR Section 52.21(b); Minn. R. 7007.0800, subp. 2

Operating Hours: EU 006 operation is subject to the following restrictions:

Annual operating hours: 2700 hours total for all loads and fuels including startupand shutdownAnnual distillate fuel oil operating hours: 500 hours excluding startup and shutdownAnnual startup and shutdown hours: 200 hours total for all fuelsAnnual distillate oil startup and shutdown hours: 32 hours

All annual limits are on a 12-month rolling sum basis.

Title I Condition: 40 CFR Section 52.21(j) BACTRequirement for NOx, PM, PM10, and CO and torestrict SO2, VOC, and H2SO4 emissions to less thanthe major source level or the significant emissions ratein 40 CFR Section 52.21(b)

EU 006 Operating Modes:

1. Startup and Shutdown Operating Mode is all EU 006 operation at 60% orgreater load for the specific compressor inlet ambient conditions.

2. Normal Operating Mode is all EU 006 operation at less than 60% load for thespecific compressor inlet ambient conditions.

Minn. R. 7007.0800, subp. 2

Control Equipment Operation During Startup and Shutdown: Operation of CE 002and CE 003 is not required during EU 006 startup or shutdown.

Minn. R. 7007.0800, subp. 2

ACID RAIN COMPLIANCE REQUIREMENTS

For additional requirement information, refer to the acid rain permit application inthe appendix of this permit.

hdr

The owner/operator shall operate the unit in compliance with all acid rain permitconditions in this permit and the acid rain permit application in the appendix of thispermit.


Emissions from the stationary source cannot exceed any allowances that thesource lawfully holds under federal acid rain regulations, except as allowed byMinn. R. 7007.0800, subp. 7.

Minn. R. 7007.0800, subp. 7

If the unit has excess emissions, the designated representative shall submit aproposed offset plan in accordance with 40 CFR Section 72.9(e).

40 CFR Section 72.9(e)

Keep the certificate of representation, all emissions monitoring information, copiesof all reports, compliance certifications and related submissions, and all recordsmade or required under the Acid Rain Program on site for a period of 5 years fromthe date the document was created.

40 CFR Section 72.9(f)

Hold allowances after January 1, 2001, as of the allowance transfer deadline, in theunit's compliance subaccount. Allowances may not be less than the total annualemissions of sulfur dioxide from the previous calendar year from the unit.

40 CFR Section 72.9(c)

MONITORING hdr

NOx Emissions Monitoring - lb/mmBtu: The Permittee shall determine NOxemissions in lb/mmBtu, according to part 75 Appendix E.

Appendix E requires the following, in part:

1. Initial performance test for each fuel, at four or more approximately equallyspaced operating loads ranging from minimum to maximum operating load;2. Measure fuel flow with automatic recording in-line flowmeters, and determineheat content of each fuel during initial performance testing and during each hourthat fuel is combusted in EU 006 after initial performance testing (refer to section2.4.1 for determining heat input when fuel is combusted for only a partial hour orwhen more than one fuel is combusted in an hour);3. Obtain from the manufacturer at least four operating parameters indicative ofNOx formation characteristics and recommended ranges of each parameter ateach load-heat input point (water injection when firing fuel oil is one parameter);

(cont.)


A-15



13100071 - 002

Facility Name:

Permit Number:

NOx Emissions Monitoring - lb/mmBtu (continued from above)

4. Tabulate results of each baseline correlation test for each fuel and convert ppmconcentrations to lb/mmBtu;5. Plot the tabulated baseline correlation test results for each fuel type and drawstraight line segments between each load point;6. Determine hourly NOx in lb/mmBtu using hourly load, fuel flow, heat input, andthe graph of baseline correlation results for the appropriate fuel and heat input rate;7. Use missing data procedures in Section 2.5 when appropriate;8. Use a computer program or other data reduction system to calculate and recordNOx emission rates in lb/mmBtu on an hourly basis.

Refer to Appendix E for additional details and requirements.


NOx Emissions Monitoring - ppmvd: The Permittee shall plot the NOxconcentration in parts per million on a dry basis corrected to 15% oxygen that weredetermined during the NOx performance testing required by part 75 Appendix E,Section 2.1.2. The ppmvd @ 15% O2 NOx values shall be plotted in the samemanner as described in Appendix E, Section 2.1.6.

The Permittee shall use a computer program or other data reduction system tocalculate and record NOx emission rates in ppmvd @15% O2 on a 3-hour averagebasis, in the same manner as described in Appendix E except ppmvd @ 15% O2values shall be used in place of lb/mmBtu. The emissions data shall be determinedand recorded for each hour that EU 006 combusts fuel.

These requirements are in addition to the requirements for determining pounds ofNOx/mmBtu described in part 75 Appendix E.

Title I Condition: Monitoring for 40 CFR Section52.21(j) NOx BACT limit; 40 CFR Section 64.3(d)(1)

NOx Emissions Monitoring - lb/hr: The Permittee shall convert the NOx lb/mmBtudata determined according to part 75 Appendix E, to lb/hr emissions data for eachhour that EU 006 combusts fuel. The conversion shall be made using thecorresponding hourly heat input rate determined according to Appendix E.

Once each day, the Permittee shall calculate and record the total pounds of NOxemitted by EU 006.

Title I Condition: Monitoring for 40 CFR Section52.21(j) NOx BACT limit

Emissions Monitoring: The Permittee shall measure or calculate SO2 and CO2 inaccordance with 40 CFR Part 75.

Title I Condition: Monitoring to restrict SO2 to lessthan the significant level in 40 CFR Section52.21(b)(23)(i); 40 CFR Section 75.10

Fuel Monitoring: The Permittee shall follow the procedures in 40 CFR Sections60.334(h) and (i) to monitor sulfur and nitrogen content of the fuels combusted inEU 006, unless the Permittee develops a custom schedule according to 40 CFRSection 60.334(i)(3).

40 CFR Sections 60.334(h) and 60.334(i)

Water Injection Monitoring: The Permittee shall install and operate a continuousmonitoring system to monitor and record the fuel consumption and the ratio ofwater to fuel being fired in EU 006. The Permittee shall follow the requirements ofSection 60.334(g) for the water injection to fuel fired ratio continuous monitoringsystem.

40 CFR Sections 60.334(a) and (g)

RECORDKEEPING hdr

Recordkeeping - Gross Electric Power Output: The Permittee shall operate andmaintain instrumentation that instantaneously measures and electronically recordsEU 006 gross power output (in megawatts) at all times during operation of the EU006.

Title I Condition: Recordkeeping for 40 CFR Section52.21(j) BACT operating condition; werhMinn. R.7007.0800, subp. 5

Recordkeeping - Fuel Type and Usage: The Permittee shall install automaticrecording in-line fuel flowmeters and measure and record fuel flow and heat inputrate on an hourly basis, as described in 40 CFR part 75, Appendix E, Section2.1.3.1. The recording system shall also indicate which type of fuel is beingcombusted.

Title I Condition: Recordkeeping for 40 CFR Section52.21(j) NOx BACT limit

Recordkeeping - NOx Emissions (ppmvd): The Permittee shall record the 3-houraverage NOx emissions in ppmvd @ 15% O2.


Recordkeeping - NOx Emissions (tons): By the 15th day of each month, thePermittee shall calculate and record the tons of NOx emitted during the previouscalendar month, and the tons of NOx emitted during the previous 12-month period.


Recordkeeping - Fuel Sulfur Content: The Permittee shall record the results ofeach fuel sulfur analysis.

Title I Condition: Recordkeeping to restrict SO2 to lessthan the significant emissions rate in 40 CFR Section52.21(b)(23)(i)

Daily Operating Hours Recordkeeping: Once each day the Permittee shallcalculate and record EU 006 normal operating hours, and startup/shutdownoperating hours for the previous calendar day. Seperate records shall be kept foreach permitted fuel type and operating mode.

Normal and startup/shutdown operating hours shall be determined using theelectronic data produced by instrumentation that instantaneously measures EU 006gross electric power output.

Title I Condition: Recordkeeping for 40 CFR Section52.21(j) BACT operating condition; Minn. R.7007.0800, subp. 5

A-16



13100071 - 002

Facility Name:

Permit Number:

Monthly Operating Hours Recordkeeping: By the 15th day of each month thePermittee shall calculate and record EU 006 normal operating hours, andstartup/shutdown operating hours for the previous month, and for the previous12-month period.

Seperate records shall be kept for each permitted fuel type and operating mode.

Minn. R. 7007.0800, subps. 4 and 5

PERFORMANCE TESTING REQUIREMENTS

(Refer to the Total Facility section of Table A for additional applicable performancetesting requirements)

hdr

Initial Performance Test: due 180 days after Initial Startup in simple cycle mode butno later than 60 days after achieving the maximum production rate, to measureNOx emissions. Separate tests shall be conducted for each permitted fuel type,and shall be conducted according to the requirements of 40 CFR Sections 60.8(b),60.8(c), and 60.335(c).

Title I Condition: to measure NOx emissions subject toa 40 CFR Section 52.21(j) BACT limit; meetsrequirements of 40 CFR Sections 60.8(a) and60.335(c)

Initial Performance Test: due 180 days after Initial Startup in simple cycle mode butno later than 60 days after achieving the maximum production rate, to measureSO2 emissions. Separate tests shall be conducted for each permitted fuel type,and shall be conducted according to the requirements of 40 CFR Sections 60.8(b),60.8(c), and 60.335(d).

Title I Condition: to measure SO2 emissions subject toa 40 CFR Section 52.21 limit to avoid the significantemission rate in 40 CFR Section 52.21(b)(23)(i); meetsrequirements of 40 CFR Sections 60.8(a) and60.335(d)

Initial Performance Test: due 180 days after Initial Startup in simple cycle mode butno later than 60 days after achieving the maximum production rate, to measure PM,PM10, CO, and VOC emissions. Separate tests shall be conducted for eachpermitted fuel type.

Title I Condition: to measure PM, PM10, and COemissions subject to a 40 CFR Section 52.21 BACTlimit and to measure VOC emissions subject to 40CFR Section 52.21 limits to avoid the significantemissions rate in 40 CFR Section 52.21(b)(23)(i)

A-17

TABLE B: SUBMITTALSFacility Name: Faribault Energy Park

Permit Number: 13100071 - 002

01/13/05

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Faribault Energy Park


01/13/05

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of EU 001combined cycle operation.

In addition this notification shall state theactual date the control equipment is placedinto service, the control equipment name, andthe control equipment 'CE' number (CE 001,CE 002, and CE 003). The notification shallalso state the effective date and the expirationdate for the EU 001 Clean Unit Designation.

EU001

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of EU 002. EU002

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of EU 006.

Inital startup means the first time that any fuelis fired in the CTG, for any reason.

EU006

Notification of the Date Construction Began due 30 days after Start Of Construction of EU002. The notification shall include the designheat input capacity, identification of the fuelsto be combusted, and the annual capacityfactor at which the Permittee anticipatesoperating the affected facility based on allfuels fired and based on each individual fuelfired.

EU002

Notification of the Date Construction Began due 30 days after Start Of Construction of EU006.

EU006

Notification of the Date Construction Began due 30 days after Start Of Construction of theadditional equipment needed to operate theCTG in combined cycle mode.

EU001

Testing Frequency Plan due 60 days after Initial Performance Test forPM, PM10, NOx, CO, and VOC emissions.The plan shall specify a testing frequencybased on the test results for each pollutantand fuel type, and MPCA guidance. Futureperformance tests at 12-month, 36-month,60-month, or another appropriate interval,shall be required upon written approval of theplan by the MPCA.

EU002

Testing Frequency Plan due 60 days after Initial Performance Test incombined cycle mode for PM, PM10, andVOC emissions. The plan shall specify atesting frequency based on the test results foreach pollutant and fuel type, and MPCAguidance. Future performance tests at12-month, 36-month, 60-month, or anotherappropriate interval, shall be required uponwritten approval of the plan by the MPCA.

EU001

Testing Frequency Plan due 60 days after Initial Performance Test insimple cycle mode for PM, PM10, NOx, CO,and VOC emissions. The plan shall specify atesting frequency based on the test results foreach pollutant and fuel type, and MPCAguidance. Future performance tests at12-month, 36-month, 60-month, or anotherappropriate interval, shall be required uponwritten approval of the plan by the MPCA.

EU006

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Faribault Energy Park


01/13/05

What to send When to send Portion of Facility AffectedExcess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar

quarter following Initial Startup of the Monitor(Submit Deviations Reporting Form DRF-1 asamended). The EER shall indicate all periodsof NOx and/or CO CEMS bypass and allperiods of exceedances of the NOx and/or COlimits including exceedances allowed by anapplicable standard, i.e. during startup,shutdown, and malfunctions.

EU001

Report due 30 days after end of each calendarhalf-year following Permit Issuance. Thereport shall include:

1. calendar dates in the reporting period;2. records of fuel supplier certification;3. certified statement signed by the Permitteeindicating that the certifications represent allfuel oil combusted during the reporting period.

EU002

Semiannual Deviations Report due 30 days after end of each calendarhalf-year following permit issuance . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations occured.

Total Facility

Compliance Certification Report (Acid RainProgram)

due 60 days after end of each calendar yearstarting 01/01/2004

EU001

Compliance Certification Report (Acid RainProgram)

due 60 days after end of each calendar yearstarting 01/01/2004

EU006

Compliance Certification due 31 days after end of each calendar yearfollowing permit issuance (for the previouscalendar year). Submit the certification on aform approved by the Commissioner, both tothe Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

B-3

APPENDIX MATERIAL Facility Name: Faribault Energy Park Permit Number: 13100071-002 A. Insignificant Activities Required To Be Listed

Space heaters fueled by kerosene, natural gas, or propane: Minn. R. 7007.1300, subp. 3.A.

Emissions from a laboratory: Minn. R. 7007.1300, subp. 3.G.

Brazing, soldering, or welding equipment: Minn. R. 7007.1300, subp. 3.H.(3)

Blueprint copiers and photographic processes: Minn. R. 7007.1300, subp. 3.H.(4)

Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities: Minn. R. 7007.1300, subp. 3.K.

Cooling Tower 0.08 lb PM/hr & 0.33 ton PM/yr; 0.01 lb PM10/hr & 0.05 ton PM10/yr: Minn. R. 7007.1300, subp. 3.I(2)

Two 384,000 gallon above ground fixed roof No. 2 distillate fuel oil storage tanks with limited potential VOC emissions less than 2.28 lb/hr and 1 tpy: Minn. R. 7007.1300, subp. 4

B. Stack Parameters Relied Upon For Modeling Stack Height (feet) Diameter (feet) Temperature (°F) Flow Rate (acfm) SV 001 (Mitsubishi)

170 19.0 245 1,097,969

SV 002 135 2.0 365 13,000SV 003 25 0.67 906 5,014SV 004 25 0.67 1025 1,636SV 005* (Mitsubishi)

100 22.5 x 22.5 1119 3,475,590

SV 005 (GE)

120 17 1068 2,541,103

* Mitsubishi turbine replaced by GE turbine; stack parameters revised to replect the change

STEP 1

Identify the source by plant name, State, and ORIS code

United States Environmental Protection Agency OMB No. 2060-0258 Acid Rain Program

Acid Rain Permit Application For more information, see instructions and refer to 40 CFR 72.30 and 72.31

This submission is: X New Revised

Plant Name: Faribault Energy Park State: MN ORIS Code: 56164

a

b

c

d

Unit ID#

Unit Will Hold Allowances

in Accordance with 40 CFR 72.9(c)(1)

New Units

Commence Operation Date

New Units

Monitor Certification Deadline

EU 006

Yes

May 1, 2005 July 29, 2005

EU 001

Yes

June 1, 2006 August 29, 2006

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

STEP 2 Enter the unit ID# for every affected unit at the affected source in column “a.” For new units, enter the requested information in columns “c” and “d.”

Yes

STEP 3 Read the standard requirements

Plant Name Faribault Energy Park Acid Rain - Page 2 Permit Requirements (1) The designated representative of each affected source and each affected unit at the source shall:

(i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit;

(2) The owners and operators of each affected source and each affected unit at the source shall:

(i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit.

Monitoring Requirements (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the unit with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements (1) The owners and operators of each source and each affected unit at the source shall:

(i) Hold allowances, as of the allowance transfer deadline, in the unit's compliance subaccount (after deductions under 40 CFR 73.34(c)), or in the compliance subaccount of another affected unit at the same source to the extent provided in 40 CFR 73.35(b)(3), not less than the total annual emissions of sulfur dioxide for the previous calendar year from the unit; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.

(2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows:

(i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3).

(4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Plant Name Faribault Energy Park Acid Rain - Page 3

STEP 3, Cont’d.

Nitrogen Oxides Requirements The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements (1) The designated representative of an affected unit that has excess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall:

(i) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77.

Recordkeeping and Reporting Requirements (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority:

(i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; (ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year period shall apply. (iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program.

(2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program.

Plant Name Faribault Energy Park Acid Rain - Page 4

Step 3, Cont’d. STEP 4 Read the certification statement, sign, and date

Liability, Cont’d. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. Except as provided under 40 CFR 72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NOx averaging plans), and except with regard to the requirements applicable to units with a common stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners and operators and the designated representative of one affected unit shall not be liable for any violation by any other affected unit of which they are not owners or operators or the designated representative and that is located at a source of which they are not owners or operators or the designated representative. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act. Effect on Other Authorities No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Act, including the provisions of title I of the Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold; provided, that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. Certification I am authorized to make this submission on behalf of the owners and operators of the affected source or affected units for which the submission is made. I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.

Name: James D. Larson Signature James D. Larson Date May 24, 2004

Technical Support Document, Permit Action Number: 13100071-002 Page 1 of 7 Date: 1/20/2005

TECHNICAL SUPPORT DOCUMENT For

DRAFT/PROPOSED AIR EMISSION PERMIT NO. 13100071-002 This technical support document is intended for all parties interested in the draft/proposed permit and to meet the requirements set forth by federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft/proposed permit. 1. General Information

1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 4911)

Minnesota Municipal Power Agency 200 South Sixth Street, Suite 300 Minneapolis, MN 55402 Contact: Randall Porter (612) 349-6868

Township 110N, Range 21W, Section 13 East of Interstate 35 & South of 170th Street Faribault, Rice County, MN 55021

1.2. Description of the Facility and Permit Action This facility is a combined cycle gas turbine electric power plant that is scheduled to commence operation in 2005 as a simple cycle gas turbine generator, with subsequent conversion to combined cycle operation. The turbine will combust natural gas and very low sulfur distillate fuel oil. Duct burners will not be used in the heat recovery steam generator. The simple cycle facility will not include an emergency generator or fire pump. This permit action is a major amendment to the New Source Review construction/part 70 operating permit issued July 15, 2004. 1.3 Description of the Activities Allowed by this Permit Action

This major amendment authorizes installation of a GE Frame 7FA combustion turbine which is similar to the originally permitted Mitsubishi 501F that was not available. Permit No. 13100071-001 prohibited operation if a different gas turbine was selected in place of the Mitsubishi turbine, until a major amendment was issued. This amendment (No. 13100071-002) revises that prohibition by allowing operation of the GE turbine in simple cycle mode only. This revision was made because the Permittee submitted a revised PSD air analysis and a revised Minnesota air emissions risk analysis for the GE turbine operating in simple cycle mode demonstrating equal or lesser impacts than for the Mitsubishi gas turbine operating in simple cycle mode. The Permittee requested the separation of the simple cycle and combined cycle


major amendments for the GE turbine because additional time was needed to prepare the information for the GE turbine combined cycle permit application, and the Permittee was concerned that this additional time may impact their desire to commence simple cycle operation in the spring of 2005. This permit amendment continues the prohibition on combined cycle operation of the GE turbine until another major amendment is issued incorporating any changes needed to accommodate combined cycle operation of the GE turbine. The GE turbine can employ evaporative inlet cooling to boost power output in warm weather. This amendment also includes a name change for the owner/operator of the facility from Faribault Energy Park, L.L.C. to Minnesota Municipal Power Agency, revises requirements for the gas turbine based on revisions to title 40 code of federal regulations part 60 subp. GG, Standards of Performance for Stationary Gas Turbines effective July 8, 2004, and removes already-completed notification and submittal requirements regarding the manufacturer and model of gas turbine selected for this facility. Also, the definition for the boundary between startup/shutdown and normal operation was revised from a finite electric output value (112 megawatts), to 60% load, because electric and power output vary with ambient conditions (mainly temperature). Finally, this amendment adds applicable Title IV acid rain program requirements. 1.4. Facility Emissions:

Permit No. 13100071-001 emissions were calculated based on a Mitsubishi 501 F gas turbine and applicable permit limits. The Permittee was not able to obtain this turbine and instead is permitted to install a GE Frame 7FA. Both turbines are similar in size and therefore emissions are similar, except for NOx emissions from natural gas combustion and CO emissions from fuel oil combustion. The GE turbine NG NOx emission rate is 9.0 ppmvd @ 15% O2 whereas the Mitsubishi rate was 25 ppmvd @15% O2. The GE turbine fuel oil CO emission rate is 20 ppmvd @ 15% O2 whereas the Mitsubishi rate was 10 ppmvd @15% O2. Also, (HAP and SO2) emissions based on fuel oil heat input are slightly higher for the GE turbine due to the higher heat input on fuel oil for the GE than for the Mitsubishi turbine.

Table 1a. Facility Emissions Changes - Simple Cycle PM

tpy PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

H2SO4 tpy

Formal-dehyde

tpy

All HAPs

tpy Mitsubishi 501F

Combustion Turbine

42.8 42.8 28.3 242.9 117.6 15.2 0.92 1.72 3.07

GE Frame 7FA Combustion

Turbine

32.0 32.0 30.0 154.4 169.2 17.3 1.05 1.64 3.01

Change* (10.8) (10.8) 1.7 (88.5) 51.6 2.1 0.06 (0.08) 0.06 *values in parentheses indicate a decrease in emissions


Table 1b. Facility Classification - Simple Cycle

Classification Major/Affected Source

Synthetic Minor Minor

PSD** PM, PM10, NOx, CO, SO2, VOC, H2SO4

Lead

Part 70 Permit Program NOx, CO PM10, SO2, VOC Single HAP, Total HAP Part 63 NESHAP Single HAP, Total HAP **Permittee has elected to meet PSD requirements for all pollutants that are major or significant in combined cycle mode


Table 1c. Facility Classification - Combined Cycle

Classification Major/Affected Source

Synthetic Minor

Minor

PSD PM, PM10, SO2, NOx, CO, VOC

H2SO4 Lead

Part 70 Permit Program PM10, SO2, NOx, CO, VOC

Single HAP, Total HAP

Part 63 NESHAP Single HAP, Total HAP 2. Regulatory and/or Statutory Basis

Table 2. Regulatory Overview of Units Affected by the Modification/Permit Amendment

EU, GP, or SV Applicable Regulations Comments: EU 001 and EU 006 Gas turbine generator initially operating in simple cycle mode and then converted to combined cycle mode

Acid Rain Requirements in 40 CFR Parts 72, 73, and 75

Hold SO2 allowances, monitor SO2, NOx, and CO2.

EU 001 and EU 006 Gas turbine generator initially operating in simple cycle mode and then converted to combined cycle mode

40 CFR part 60, subp. GG

Incorporate into the existing permit the applicable revised requirements in the federal standards of performance for stationary gas turbines. These revisions are revised NOx emissions monitoring and sulfur and nitrogen in contents fuel monitoring requirements.

This permitting action does not trigger any environmental review, risk analysis, or new requirements (other than the acid rain program requirements and revisions to part 60 subp. GG requirements). Refer to the technical support document for PER 001 for additional information. This major amendment is subject to the community involvement process. The initial information gathering phase revealed that no complaints have been received by the MPCA regarding the facility (because the facility is not yet constructed) and that there were no hot topic issues either. Also, there was no public comment during the recent public notice (April 9 - May 10, 2004) for the construction/operation permit issued July 15, 2004. As a result, it is apparent to permitting staff that the likelihood of adverse public comment regarding this permit action is very low and therefore, this project warrants no further community involvement. 3. Technical Information On October 19, 2004, the Permittee requested additional revisions to permit No. 13100071-001. Specifically, permit No. 13100071-001 contained a requirement for obtaining a major


amendment if the Mitsubishi turbine was not selected, and prohibition of turbine operation until the major amendment was issued. The Permittee was not able to obtain the Mitsubishi turbine, so as indicated in a September, 10, 2004, letter, a similar GE turbine (7FA Model 7241) was obtained. As a result, this triggered the permit No. 13100071-001 requirement to submit an application by November 12, 2004, to obtain a major amendment to update the permit requirements for the different turbine. Although the GE turbine NOx emissions are substantially lower than the Mitsubishi turbine, the Permittee again elected to meet PSD permitting requirements for BACT and the air analysis. The Permittee has determined that the same BACT requirements apply to simple cycle operation of the GE turbine as determined for simple cycle operation of the Mitsubishi turbine, and that simple cycle operation of the GE turbine will not cause ambient air concentrations greater than those determined for the Mitsubishi turbine in simple cycle mode. As shown below, most of the GE turbine emission rates for NOx, CO, VOC, and PM/PM10 are less than those for the Mitsubishi turbine.

Pollutant Turbine/fuel NOx ppmvd

@15% O2 CO ppmvd @15%

O2 VOC @15% O2 PM/PM10

Mitsubishi NG 25 10 1.0 ppmvd 19 lb/hr1

GE NG 9 9 1.4 ppmvw 7 lb/hr proposed emission limit 9 9 1.5 ppmvd 0.01 lb/mmBtu Mitsubishi Oil 42 10 5.0 ppmvd 54 lb/hr1

GE Oil 42 20 3.5 ppmvw 17 lb/hr proposed emission limit 42 20 3.5 ppmvd 0.03 lb/mmBtu

1based on 0.01 lb/mmBtu @ 1876 mmBtu/hr for NG and 0.03 lb/mmBtu @ 1801 mmBtu/hr for oil The Permittee has indicated the need for additional time to assemble the revised PSD and AERA permitting materials for combined cycle operation. The Permittee desires to commence simple cycle operation in spring 2005. As result, the Permittee requested revision of permit No. 13100071-001 so that permit amendments can be done separately for simple cycle operation and for combined cycle operation of the GE turbine. MPCA staff decided that the current draft major amendment (permit No. 13100071-002) would incorporate the changes necessary for GE turbine simple cycle operation and prohibit only combined cycle operation of the GE turbine until the major amendment authorizing combined cycle operation is issued. Permit No. 13100071-002 now allows operation of the GE Frame F7A gas turbine in simple cycle mode, and requires submittal of a major permit amendment application for combined cycle operation. This will avoid delay of the GE turbine simple cycle 2005 startup date. Permit No. 13100071-002 also includes revised simple cycle requirements (short term emission limits), as appropriate. Note that the Permittee has continued to elect to be subject to NSR in simple cycle mode (as was the case for the Mitsubishi in simple cycle mode), even though emissions from simple cycle operation of the GE gas turbine are less than the NSR major source threshold. Also, the NOx 12-month sum limit was not revised even though limited NOx should decrease due to lower NOx emissions from the GE turbine compared to the Mitsubishi turbine.


As part of this major amendment permitting action, the agency is re-opening the permit to revise requirements for the gas turbine due to the July 8, 2004, revisions to the federal standards for stationary gas turbines at 40 CFR part 60, subp. GG. The changes pertain to NOx emissions monitoring, and monitoring sulfur and nitrogen content of fuel combusted in the turbine. 3.1 Comments Received Public Notice Period #1: September 9, 2004 - October 11, 2004 EPA 45-day Review Period #1: September 9, 2004 - October 26, 2004 Public Notice Period #2: November 24, 2004 - December 23, 2004 EPA 45-day Review Period #2: November 24, 2004 - January 7, 2005 No comments were received from the public during public notice period #1 or from EPA during their 45-day review period #1. However, immediately prior to the start of the public notice, the permit was revised by adding a requirement to EU 001 and EU 006 from the acid rain permit program for monitoring or calculating emissions of SO2, NOx, and CO2 in accordance with 40 CFR Part 75. At the end of the public notice, an error in the VOC limits for EU 001/EU 006 was corrected. The VOC limits stated that the VOC was ‘as methane’, however, this is inappropriate for a limit expressed as a concentration by volume, and therefore was removed. This change does not require the MPCA to re-public notice this draft permit. On October 19, 2004, the Permittee requested additional revisions to permit No. 13100071-001. Specifically, permit No. 13100071-001 contained requirement for obtaining a major amendment if the Mitsubishi turbine was not selected, and prohibition of turbine operation until the major amendment was issued. See discussion above regarding the changes made to this permit. Due to the changes made after completion of public notice #1, the permit was put on public notice again, and was also sent to EPA for a second 45-day review. During the second public comment period on December 8, 2004, the GP 001 requirement from part 60 subpart Kb for maintaining records of tank volume and contents was removed by the permit writer, based on October 2003, revisions to subpart Kb. On December 9, 2004, the permit writer revised the EU 001 definition of the startup/shutdown and normal operation boundary, from 108.8 gross megawatts output to 60% load (measured gross in megawatts) based on specific compressor inlet conditions, as had been previously done for EU 006. No comments were received from the public during public notice period #2 or from EPA during their 45-day review period #2. 4. Conclusion Based on the information provided by Minnesota Municipal Power Agency, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 13100071-002 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.


Staff Members on Permit Team: Marshall Cole (permit writer/engineer) Greg Berg (enforcement; no input) Jenny Reinertsen (peer review) Attachments: Emission Calculation for simple cycle GE 7FA turbine

air emission permit no. 13100071-002 is issued to ...the permittee elected to install a general...

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