air individual permit part 70 reissuance no. 13700028-101

Air Individual Permit Part 70 Reissuance No. 13700028-101 for Virginia Department of Public Utilties Permittee: Virginia Department of Public Utilities
Copermittee name: Laurentian Energy Authority LLC
Facility name: Virginia Department of Public Utilities 618 2nd St S Virginia, MN 55792 St. Louis County
Expiration date: March 21, 2024 * All Title I Conditions do not expire Part 70 Reissuance: March 21, 2019 Permit characteristics: Federal; Part 70/ Major for NSR; Limits to avoid NSR
The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 13700028011 and authorizes the Permittee to modify and operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.
Signature: Carolina Espejel-Schutt This document has been electronically signed. for the Minnesota Pollution Control Agency

Page
1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 4. Summary of subject items ........................................................................................................................................... 6 5. Limits and other requirements .................................................................................................................................. 10 6. Submittal/action requirements ............................................................................................................................... 104 7. Appendices ............................................................................................................................................................... 132
Appendix A. Insignificant Activities and General Applicable Requirements .......................................................... 132 Appendix B: Modeled Stack Parameters ............................................................................................................... 133 Appendix C. 40 CFR pt. 60, subp. Da – Standards of Performance for Electric Utility Steam Generating Units ... 134 Appendix D. 40 CFR pt. 60, subp. A General Provisions ...................................................................................... 170 Appendix E. 40 CFR pt. 63, subp. DDDDD National Emission Standards for Hazardous Air Pollutants for Major
Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters............................................ 283 Appendix F. 40 CFR Pt. 63, subp. A General Provisions ....................................................................................... 381

Major Amendment 03/09/2017 13700028101
Part 70 Reissuance 07/15/2016 13700028101
Major Amendment 07/30/2015 13700028101
Administrative Amendment 06/15/2015 13700028101

2. Where to send submittals
Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604
Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.
Send submittals that are required by the Acid Rain Program to:
U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460
Send any application for a permit or permit amendment to:
Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 551554194
Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:
a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term
Unless another person is identified in the applicable Table, send all other submittals to:
AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 551554194

3. Facility description
The Virginia Department of Public Utilities (Facility) is located at 618 2nd St S in Virginia, St. Louis County, Minnesota. The facility is a citizenowned utility that provides steam to the heating distribution system for local businesses and residents of the Virginia, Minnesota area. In addition, the facility operates and maintains a 26 megawattmaximum electrical distribution system, a natural gas distribution system, and a water treatment plant that supplies drinking water to the city. The facility has the potential to operate four boilers, each burning specific fuel types: Boiler #7 (EQUI 2) and Boiler #9 (EQUI 3) each burn coal, Boiler #10 (EQUI 4) fires natural gas, and Boiler #11 (EQUI 16) burns wood cofired with natural gas, each used for district heating and electricity generation. Other emission sources at the facility include a makeup air heater, wood storage and handling systems for fuel delivery to EQUI 16, and fugitive dust emissions from truck traffic and ash handling. Major pollutants emitted include nitrogen oxides (NOx), sulfur dioxides (SO2), particulate matter (PM), particulate matter with an aerodynamic diameter less than 10 microns (PM10), particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5), hydrogen chloride (HCl), and carbon monoxide (CO). Addon pollution control equipment includes bag houses, cyclones, electrostatic precipitators (ESP), and selective noncatalytic reduction (SNCR), in combination with good combustion practices. Pollution controls intrinsic to the design of EQUI 4 (not addon controls) include lowexcess firing, flue gas recirculation, and oxygen trim/modified burner design. Description of Permit Actions

SI ID: Description
Relationshi p Type

ACTV 3: All IAs COMG 2: Boilers #7, #9, and #10 and Makeup Air Heater NOx Cap
has members
EQUI 2: Boiler #7 is monitored by
EQUI 32: Boiler #7 CO2 (bias adjustment)
EQUI 33: Boiler #7 SO2
EQUI 42: Boiler #7 Opacity
EQUI 44: Boiler #7 O2
EQUI 47: Boiler #7 CO
EQUI 2: Boiler #7 sends to STRU 17: Boiler #7
EQUI 2: Boiler #7 is controlled in series by
TREA 3: Centrifugal Collector Medium Efficiency (Boiler #7)
TREA 4: Electrostatic Precipitator High Efficiency (Boiler #7)
EQUI 35: Boiler #9 SO2
EQUI 3: Boiler #9 is monitored
EQUI 45: Boiler #9 O2
SI ID: Description
Relationshi p Type
monitored by
EQUI 3: Boiler #9 is controlled by
TREA 1: Electrostatic Precipitator High Efficiency (Boiler #9)
EQUI 23: Boiler #10 NOx
TREA 18: Low Excess Air Firing (Boiler #10)
TREA 19: Flue Gas Recirculation (Boiler #10)
TREA 2: Modified Furnace or Burner Design (Boiler #10)
EQUI 7: Enclosed Wood Unloading
sends to STRU 4: Enclosed Wood Unloading Area
EQUI 7: Enclosed Wood Unloading
is controlled by
TREA 7: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Enclosed Wood Unloading, Bucket Elevator, &

EQUI 9: Makeup Air Heater
is monitored by
EQUI 9: Makeup Air Heater
is monitored by
sends to STRU 6: Boiler #10
EQUI 11: Wood Transfer/Metering Bin
sends to STRU 8: Wood Transfer Metering Bin
EQUI 11: Wood Transfer/Metering Bin
is controlled by
TREA 11: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Conveyor #5)
EQUI 12: Bucket Elevator
EQUI 12: Bucket Elevator
is controlled by
TREA 7: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Enclosed Wood Unloading, Bucket Elevator, & Conveyor #2)
EQUI 13: Conveyor #2 sends to STRU 4: Enclosed Wood Unloading Area
EQUI 13: Conveyor #2 is controlled by
TREA 7: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Enclosed Wood Unloading, Bucket
SI ID: Description
Relationshi p Type
EQUI 14: Conveyor #3 sends to STRU 7: Wood Conveyor
TREA 10: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Conveyor #3 and Conveyor #4)
EQUI 15: Conveyor #5 sends to STRU 8: Wood Transfer Metering Bin
TREA 11: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Conveyor #5)
EQUI 25: Boiler #11 NOx
EQUI 30: Boiler #11 CO
EQUI 31: Boiler #11 O2 (bias adjustment)
TREA 16: Multiple Cyclone w/o Fly Ash Reinjection Most Multiclones (Boiler #11)
TREA 17: Electrostatic Precipitator High Efficiency

TREA 5: Selective Non Catalytic Reduction (Boiler #11)
EQUI 17: Conveyor #4 sends to STRU 7: Wood Conveyor
TREA 10: Fabric Filter Low Temperature, i.e., T<180 Degrees F (Conveyor #3 and Conveyor #4)
EQUI 18: Data Acquisition System (DAS)

EQUI 19: Boiler #10: 0.105 lbs NOx/mmBtu, EQUI 4, 30 DRA
sends to EQUI 18: Data Acquisition System (DAS)
sends to EQUI 22: Boiler #10 CO2 (bias adjustment)
sends to EQUI 23: Boiler #10 NOx
EQUI 20: Boiler #7: 20% Opacity, EQUI 2, 6min ave.
sends to EQUI 42: Boiler #7 Opacity
sends to EQUI 41: Boiler #9 Opacity

EQUI 23: Boiler #10 NOx EQUI 25: Boiler #11 NOx EQUI 26: Boiler #7: EQUI 2 SO2, 1hr ave.
EQUI 26: Boiler #7: EQUI sends to EQUI 32:
SI ID: Description
Relationshi p Type
2 SO2, 1hr ave. Boiler #7 CO2 (bias adjustment)
EQUI 26: Boiler #7: EQUI 2 SO2, 1hr ave.
sends to EQUI 33: Boiler #7 SO2
EQUI 28: Boiler #7 & #9: EQUI 2 & EQUI 3 SO2, 1 hr ave.

EQUI 44: Boiler #7 O2 EQUI 45: Boiler #9 O2 EQUI 46: Boiler #9 CO EQUI 47: Boiler #7 CO

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation
TFAC 2 13700028 Virginia Department of Public Utilities

5.1.1 The Permittee shall comply with the applicable requirements of Minn. R. 7007.0502. The Permittee submitted a plan on June 24, 2015 to avoid the requirement to submit a Mercury Reduction Plan by limiting mercury emissions though restricting fuel input. Enforceable requirements for compliance with this limit can be found under EQUI 3 later in this permit. This is a stateonly requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act. [Minn. R. 7007.0502]
5.1.2 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all applicable requirements contained in the following: Appendix A: Insignificant Activities and General Applicable Requirements; Appendix B: Modeled Stack Parameters; Appendix C: 40 CFR pt. 60, subp. Da; Appendix D: 40 CFR pt. 60, subp. A; Appendix E: 40 CFR pt. 63, subp. DDDDD; and Appendix F: 40 CFR pt. 63, subp. A. Modeling parameters in Appendix B: Modeled Stack Parameters are included for referenceonly as described elsewhere in this permit. [Minn. R. 7007.0800, subp. 2]
5.1.3 Operating Scenarios: The Permittee shall only operate EQUI 2 or EQUI 3 as described in the 1hr SO2 NAAQS modeling demonstration approved on December 5, 2018. The Permittee shall record and maintain operating hours for each boiler on each day of operation. [Minn. R. 7007.0100, subps. 7A, 7L, & 7M, Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.00107009.0090, Minn. Stat. 116.07, subds. 4a & 9]
5.1.4 Sulfur Dioxide: Modeled Parameters: The parameters used in SO2 modeling effective under Air Permit No. 13700028101 are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R. 7007.0100, subps. 7A, 7L, and 7M, Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.00100090, Minn. Stat. 116.07, subds. 4a and 9]

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Minn. R. 7007.0800, subps. 1, 2, and 4, Minn. R. 7009.0010 7009.0080, Minn. Stat. 116.07, subds. 4a & 9]
5.1.6 Any written approval regarding remodeling does not exempt the Permittee from obtaining any required permit or permit amendment for making such change(s), and any written approval does not take the place of any permit or permit amendment that may be required due to such change(s). [Minn. R. 7007.0100, subps. 7A, 7M, & 7L, Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.00107009.0090, Minn. Stat. 116.07, subds. 4a & 9]
5.1.7 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]
5.1.8 These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actualtoprojectedactual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 7007.1500. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.9 Preconstruction Documentation Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Prechange potential emissions of any affected existing emission unit, and the projected postchange potential emissions of any affected existing or new emission unit.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 45, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.10 The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R. 7007.0800, subps. 45, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.11 The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 45, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.12 Before beginning actual construction of any project which includes any electric utility steam generating unit (EUSGU), the Permittee shall submit a copy of the preconstruction documentation (items 1 4 under Preconstruction Documentation, above) to the Agency. [Minn. R. 7007.0800, subps. 45, Title I Condition: 40 CFR 52.21(r)(6)(ii) and Minn. R. 7007.3000]

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation
5.1.13 For any project which includes any EUSGU, the Permittee must submit an annual report to the Agency, within 60 days after the end of the calendar year. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person. b. The quantified annual emissions analyzed using the ATPA test, plus the potential emissions associated with the same project analyzed as part of a hybrid test. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection, if that is the case. [Minn. R. 7007.0800, subps. 45, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.14 For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual, plus potential used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain the following: a. The name and ID number of the facility, and the name and telephone number of the facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 45, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]
5.1.15 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0090. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 12, Minn. R. 7009.00107009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]
5.1.16 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]
5.1.17 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]
5.1.19 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]
5.1.20 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]
5.1.21 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.00107030.0080]
5.1.22 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]
5.1.23 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]
5.1.24 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]
5.1.25 Performance Test Notifications and Submittals: Performance Test Notification and Plan: due 30 days before each Performance Test Performance Test Pretest Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 14, Minn. R. 7017.2035, subps. 12]
5.1.26 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]
5.1.27 Monitoring Equipment Calibration The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]
5.1.28 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]
5.1.29 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]
5.1.30 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]
5.1.31 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]
5.1.32 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]
5.1.33 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than onehour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24 hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]
5.1.34 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]
5.1.35 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]
5.1.36 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 7007.1500]
5.1.37 Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]
5.1.38 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.30007019.3100]

5.2.1 The Permittee shall limit Nitrogen Oxides < 73.08 tons per month 12month rolling average. This limit applies to the combined NOx emissions from EQUI 2, EQUI 3, EQUI 4, and EQUI 9. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]
5.2.2 Nitrogen Oxides: Monthly Recordkeeping: By the 15th day of each month, the Permittee shall record the following information: 1) Total quantity of coal burned in EQUI 2 during the previous month, in tons (A); 2) Total quantity of coal burned in EQUI 3 during the previous month, in tons (B); 3) Total monthly NOx emissions from EQUI 4 and EQUI 9 as measured by NOx CEMS, in tons (y); and 4) Quantity of natural gas combusted in EQUI 4 and EQUI 9 during times of NOx CEMS malfunction (z). The Permittee shall use these fuel usage records, NOx emissions data, MPCAapproved emission factors, and Equation 1 to determine compliance with the NOx emission limit in COMG 2. [Minn. R. 7007.0800, subp. 5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]
5.2.3 Nitrogen Oxides: By the 15th day of each month, the Permittee shall calculate and record the monthly NOx emissions for the previous month using the following (Equation 1): NOx emissions = (EF1c x A) + (EF3c x B) + (EF4g x z) + y

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EF1c = The MPCAapproved emission factor for coal combustion at EQUI 2 (ton NOx/ton coal). At the time of permit issuance, the factor is 0.0033ton NOx/ton coal. EF3c = The MPCAapproved emission factor for coal combustion at EQUI 3 (ton NOx/ton coal). At the time of permit issuance, the factor is 0.0036ton NOx/ton coal. EF4g = The MPCAapproved emission factor for natural gas combustion at EQUI 4 and EQUI 9 (ton NOx/MMcf natural gas). At the time of permit issuance, the factor is 0.05ton NOx/MMcf natural gas. A, B, y, and z are as described above. [Minn. R. 7007.0800, subp. 4(B), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]
5.2.4 Nitrogen Oxides: By the 15th day of each month, the Permittee shall calculate and record the monthly 12month rolling average NOx emission rate. The "rolling average" shall be determined as defined in Minn. R. 7007.0100, subp. 21a using a 12month time period. [Minn. R. 7007.0800, subp. 4(B), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]
5.2.5 Nitrogen Oxides: Protocol for ReSetting the Emission Factor Used For Calculating NOx Emissions: The Permittee shall conduct performance testing under conditions that produce the maximum emission rate, using US EPA reference method 7 and 3A to measure the emission factor as required elsewhere in this permit. The Permittee shall report the test result in tons of NOx per ton of coal (ton NOx/ton coal) in the performance test report required by Minn. R. 7017.2035, subp. 1. The emission factor used for calculating emissions shall be reset to the 3hour average emission rate in tons of NOx per ton of coal (ton NOx/ton coal), measured during the most recent MPCA approved emission factor performance test. The new emission factor used for calculating emissions determined using this Protocol shall be effective upon receipt of the Notice of Compliance (NOC) letter that approves the test results and shall be incorporated into the permit during the next permit amendment. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]
5.2.6 Nitrogen Oxides: The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Resetting the Emission Factor Used for Calculating NOx Emissions established by this permit. [Minn. R. 7007.1500, subp. 1]
5.2.7 Nitrogen Oxides: Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements

EQUI 2 EU001 Boiler #7
5.3.1 The Permittee shall limit Sulfur Dioxide <= 0.813 pounds per million Btu 30day rolling average (boiler operating day). The Permittee shall not operate EQUI 2 and EQUI 3 simultaneously except during periods of startup and shutdown. [Minn. R. 7007.0100, subps. 7A, 7L, and 7M, Minn. R. 7007.0800, subps. 1, 2, and 4, Minn. R. 7009.00107009.0090, Minn. R. 7011.0510, subp. 1, Minn. Stat. 116.07, subds. 4a & 9]
5.3.2 The Permittee shall limit PM < 10 micron <= 0.30 pounds per million Btu heat input 3hour average. [Title I Condition: 40 CFR 52.21(k)(Modeling) & Minn. R. 7007.3000]
5.3.3 The Permittee shall limit Mercury <= 0.0000057 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD, Table 2, Minn. R. 7011.7050]
5.3.4 The Permittee shall limit Filterable Particulate Matter <= 0.040 pounds per million Btu heat input (fronthalf particulate matter). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD, Table 2, Minn. R. 7011.7050]
5.3.5 The Permittee shall limit Hydrogen Chloride <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD, Table 2, Minn. R. 7011.7050]
5.3.6 The Permittee shall limit Carbon Monoxide <= 340 parts per million 30day rolling average on a dry basis corrected to 3 percent oxygen. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD, Table 2, Minn. R. 7011.7050]
5.3.7 The Permittee shall limit Opacity <= 10 percent opacity 24hour block average or the highest hourly average opacity reading measured during the performance test run demonstrating compliance with the PM emission limitation. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD, Table 4, Minn. R. 7011.7050]
5.3.8 The Permittee shall limit Particulate Matter <= 0.60 pounds per million Btu heat input 3hour average. The potential to emit from the unit is 0.71 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]
5.3.9 The Permittee shall limit Sulfur Dioxide <= 4.0 pounds per million Btu heat input 3hour average. The potential to emit from the unit is 2.23 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0510, subp. 1]
5.3.10 The Permittee shall limit Opacity <= 20 percent opacity except for one sixminute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0510, subp. 2]

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation hour block average, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. Readings shall be taken every 15 minutes of operation and used to calculate the 8hour block average. This averaging time is more stringent than the 30day rolling average required by the Boiler MACT. The readings may be taken from the SO2 CEMS data, or may be independently taken. [Minn. R. 7017.2025, subp. 3, Minn. R. 7017.2025, subp. 3a]
5.3.12 The Permittee shall vent emissions from EQUI 2 to control equipment meeting the requirements of TREA 3 and TREA 4 whenever EQUI 2 operates. See TREA 3 for specific centrifugal collector operating requirements. See TREA 4 for specific electrostatic precipitator operating requirements. [Title I Condition: 40 CFR 52.21(k)(Modeling) and Minn. R. 7007.3000]
5.3.13 Sulfur Dioxide: Emissions Monitoring. The Permittee shall use a CEMS to measure SO2 emissions from EQUI 2. See EQUI 33 for specific CEMS requirements. [Minn. R. 7007.0800, subp. 2]
5.3.14 Sulfur Dioxide: Emission Rate Calculations: The Permittee shall calculate and record a 30boiler operating day rolling average SO2 emission rate in the units of the standard, updated after each new boileroperating day. Each 30boiler operating day rolling average emission rate is the average of all of the valid hourly SO2 emission rates in the 30boiler operating day period. [Minn. R. 7007.0100, subps. 7A, 7L, & 7M, Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.00107009.0090, Minn. Stat. 116.07, subds. 4a & 9]
5.3.15 Steam Flow: The Permittee shall calculate and record the three (3) 8hour block average steam flows each day for the previous day. A day may be defined as a calendar day, or as another 24hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R. 7007.0800, subp. 2]
5.3.16 Fuel Usage: The Permittee shall limit fuel usage to bituminous and subbituminous coal only. [Minn. R. 7007.0800, subp. 2]
5.3.17 Fuel Usage: Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record EQUI 2 fuel usage (for each permitted fuel) for the previous calendar month. The monthly values shall be used in the NOx emissions calculation equation (Equation 1) in COMG 2 of this permit. [Minn. R. 7007.0800, subp. 5, Title I Condition: Avoid major modification under 40 CFR

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 52.21(b)(2) & Minn. R. 7007.3000]
5.3.18 Opacity: Emission Monitoring. The Permittee shall use a COMS to measure opacity emissions from EQUI 2. See EQUI 42 for specific COMS requirements. [Minn. R. 7007.0800, subp. 2]
5.3.19 Mercury Emissions Reduction Plans Applicability. Based on actual emissions reported to the emissions inventory, EQUI 2 is not an existing mercury emissions source defined under Minn. R. 7007.0502 because mercury emissions from EQUI 2 have not exceeded three pounds per year for three consecutive years since 2014. Therefore, EQUI 2 is not required to be included in a mercury reduction plan and/or further limits to avoid mercury reduction plan requirements do not need to be imposed. [Minn. R. 7005.0100, subp. 23b, Minn. R. 7007.0502, subp. 2]
5.3.20 Boiler Alternative Operating Conditions for Performance Testing: Alternative Operating Conditions during testing are defined as 90 percent to 100 percent of the boiler's maximum normal (continuous) operating load or the maximum permitted operating rate, whichever is lower. The basis for this number must be included in the test plan. If testing is conducted at the alternative operating condition established, an operating limit will not be established as a result of performance testing. In no case will the new operating rate limit be higher than allowed by an existing permit condition. [Minn. R. 7017.2025, subp. 2(A), Minn. R. 7017.2025, subp. 3(B)]
5.3.21 Boiler Operating Conditions Not Meeting the Alternative Operating Conditions During Performance Testing: If performance testing is not conducted at or above the established alternative operating condition, the Permittee must then limit the boiler operating rate on an 8hour block average based on the following: 1) If the results of the performance test are greater than 80 percent of any applicable emission limit for which compliance is demonstrated, then boiler operation will be limited to the tested operating rate; and 2) If results are less than or equal to 80 percent of all applicable emission limits for which compliance is demonstrated, boiler operation will be limited to 110 percent of the tested operating rate. In no case will the new operating rate limit be higher than allowed by an existing permit condition. [Minn. R. 7017.2025, subp. 3(B)]
5.3.22 STET (Short Term Emergency and Testing) Operating hours limit: The Permittee may operate the boiler up to 40 hours per year to demonstrate the Uniform Rating of Generating Equipment (URGE) capacity and to meet emergency energy supply needs. The Permittee shall maintain documentation of all STET operation to demonstrate compliance with this limit. The boiler must meet emission limits during STET operation. [Minn. R. 7007.0800, subp. 2]
5.3.23 STET Operation Definition that Applies to Boilers that Meet or Do Not Meet the Alternative Operating Condition for Performance

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Testing. If performance test results demonstrate compliance at 80 percent or less of any applicable emission limits for any tested pollutant, STET operation is defined as operation beyond 110 percent of the average operating rate achieved during that performance test. If performance test results demonstrate compliance at greater than 80 percent of any applicable emission limit for any tested pollutant, STET operation is defined as operation beyond 100 percent of the average operating rate achieved during that performance test. In no case will STET operation be higher than allowed by an existing permit condition. [Minn. R. 7007.0800, subp. 2]
5.3.24 Coal Combustion Monitoring: The Permittee shall record the start and stop dates and times of all coal combustion periods for EQUI 2. The Permittee may use the data from the SO2 CEMS for EQUI 2 to meet this recordkeeping requirement provided that the CEMS data continuously specifies the time and date. However, if and when the CEMS malfunctions, the Permittee shall keep a written log of coal combustion in EQUI 2 in place of CEMS data during the CEMS malfunction. [Minn. R. 7007.0800, subp. 4]
5.3.25 The results of a performance test are not final until issuance of a review letter by MPCA, unless specified otherwise by Minn. R. 7017.20017017.2060. [Minn. R. 7017.2020, subp. 4]
5.3.26 The Permittee must comply with all applicable requirements of 40 CFR pt. 63, subp. DDDDD, as follows: 40 CFR 63.7485; 40 CFR 63.7490(a)(1); 40 CFR 63.7490(d); 40 CFR 63.7495(b); 40 CFR 63.7495(d); 40 CFR 63.7499(b); 40 CFR 63.7499(i); 40 CFR 63.7500(a)(1); 40 CFR 63.7500(a)(2); 40 CFR 63.7500(a)(3); 40 CFR 63.7500(f); 40 CFR 63.7505(a); 40 CFR 63.7505(c); 40 CFR 63.7505(d)(1); 40 CFR 63.7505(d)(2); 40 CFR 63.7505(d)(3); 40 CFR 63.7505(d)(4); 40 CFR 63.7515(a); 40 CFR 63.7515(d); 40 CFR 63.7515(f); 40 CFR 63.7515(g); 40 CFR 63.7520(b); 40 CFR 63.7520(f); 40 CFR 63.7521(a); 40 CFR

air individual permit part 70 reissuance no. 13700028-101

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