TECHNICAL SUPPORT DOCUMENT 1. 1.1 and€¦ · Great River Energy‐ Maple Lake was subject to CAIR...

Technical Support Document, Permit Action Number: 17100020‐003 of 9

TECHNICAL SUPPORT DOCUMENT

For DRAFT/PROPOSED AIR EMISSION PERMIT NO. 17100020‐003

This technical support document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set forth by the 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

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 4911)

Great River Energy 12300 Elm Creek Boulevard Maple Grove, MN 55369

Great River Energy ‐Maple Lake 800 2nd St West Maple Lake, Wright County, Minnesota 55358

Contact: Greg Archer Phone: 763‐445‐5206

1.2 Facility Description Great River Energy‐ Maple Lake operates a single simple‐cycle 29.3‐megawatt GE Combustion Turbine.

In addition, there are the following insignificant activities: one diesel‐starting engine, three 50,000‐

gallon aboveground No. 2 fuel oil storage tanks, fuel oil piping, substation circuit breakers, and unpaved

roads and parking lots.

The facility is a major source under the federal operation permits program (40 CFR pt. 70) and major

source under federal New Source Review (NSR). The facility is an area source under the National

Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63). This facility was subject to

the Clean Air Interstate Rule (CAIR) but is now subject to the Transport Rule (TR)/Cross‐State Air

Pollution Rule (CSAPR).

1.3 Description of the Activities Allowed by this Permit Action This permit action is a reissuance of the Part 70 operating permit. 1.4 Description of Notifications and Applications Included in this Action

Table 2. Notifications and Applications Included in this Action

Date Received DQ# Application/Notification Type and description

12/07/2012 4213 Part 70 Reissuance Application


1.5 Facility Emissions

Table 3. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

CO2e tpy

VOC tpy

SingleHAP tpy

AllHAPs tpy

Total Facility Limited Potential Emissions

19.10 19.10 17.62 80.36 1400 5.25 260,327 0.65 1.26 2.05

Total Facility Actual Emissions (2013)

0.0078 0.0070 0.0070 0.0026 1.51 0.0057 * 0.0070 *

*Not reported in MN emission inventory.

Table 4. Facility Classification Classification Major Synthetic Minor/Area Minor/Area

PSD X

Part 70 Permit Program X

Part 63 NESHAP X

1.6 Changes to Permit The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

The permit has been updated to reflect current MPCA templates and standard citation formatting.

PTE calculations were updated to include Greenhouse Gases (GHGs) and PM2.5 emissions.

Updated insignificant activities.

Appendix II was added to the permit. Appendix II contains the 40 CFR pt. 63, subp. ZZZZ requirements for black start diesel engine since the facility is an area source.

Fuel certification no longer necessary for compliance with Minn. R. 7011.2300; therefore, the requirement was removed from EU 001. The fuel type will meet the requirements of 40 CFR Section 80.510(c), of less than 15 parts per million (ppm).

On November 3, 2009, EPA promulgated a final rule entitled “Administrative Stay of Clean Air Interstate Rule (CAIR) for Minnesota; Administrative Stay of Federal Implementation Plan to Reduce Interstate Transport of Fine Particulate Matter and Ozone for Minnesota” (74 FR 56721). This rule became effective on December 3, 2009. The rule states that EPA is staying the application of CAIR and the CAIR FIP with respect to Minnesota and Minnesota sources, pending further rulemaking in response to the DC Circuit Court’s remand of CAIR to EPA. CAIR requirements were removed from the permit. The Cross‐State Air Pollution Rule (CSAPR) general requirements stating that the facility shall comply with 40 CFR pt. 97 have been added at the total facility level, as well as requirements stating that the facility shall submit information related to 40 CFR pt. 97 when requested by the MPCA after the sunset of CAIR.

The annual monitoring equipment calibration is required and the fuel flow meter has being calibrated consistent with 40 CFR Section 75.19, as incorporated into the facility operational procedures.


2. Regulatory and/or Statutory Basis New Source Review The facility is an existing major source under New Source Review regulations. No changes are authorized by this permit. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) The construction of this turbine commenced on July 1, 1977; therefore 40 CFR pt. 60, subp. GG (effective date is October 3, 1977) does not apply. The Permittee has stated that no New Source Performance Standards apply to the operations at this facility. National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility emits less than 10/25 tons per year for single and total HAPs, respectively. The facility is a natural minor source for HAPs. The applicable area source NESHAP is 40 CFR pt. 63, subp. ZZZZ for the emergency engines. A combustion turbine (EU001) is not subject to 40 CFR pt. 63 subp. YYYY, National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines because the turbines are not located at a major source of HAP emissions. Acid Rain Program This not an affected facility under the acid rain program, 40 CFR pt. 72.6(b)(1). Construction of this turbine commenced on July 1, 1977, before the January 01, 2000, effective date of the acid rain program. Clean Air Interstate Rule (CAIR) and the Transport Rule (TR)/Cross‐State Air Pollution Rule (CSAPR)

Great River Energy‐ Maple Lake was subject to CAIR when initially promulgated in 2005.

Great River Energy‐ Maple Lake submitted a CAIR application on June 30, 2008

CAIR was administratively stayed in Minnesota in December of 2009, so the application was returned.

CAIR was replaced by TR/CSAPR in 2011, but TR/CSAPR was stayed by the D.C. Circuit, and EPA was told to go back to CAIR.

The Supreme Court reversed the decision in 2014, and requested the D.C. Circuit to lift the stay.

The D.C. Circuit court did so, with an extension of the original compliance dates by three years.

Now, implementation of CSAPR will occur. Additional EPA guidance is expected in early 2015.

For now, general requirements stating that the facility shall comply with 40 CFR pt. 97 have been added at the total facility level, as well as requirements stating that the facility shall submit information related to 40 CFR pt. 97 when requested by the MPCA.

When EPA guidance is available on how to incorporate CAIR requirements in permits, we plan on sending letters to CSAPR facilities. This letter may include a request for an amendment application. Therefore, a requirement making it clear that an amendment application must be submitted for newly promulgated applicable requirements if there are 3 years remaining in the permit term has also been added at the total facility level.


Compliance Assurance Monitoring (CAM)

This permit action is a reissuance of a Part 70 permit; therefore, CAM applies to any emission units, which meet the CAM applicability requirements in 40 CFR pt. 64:

The unit is subject to an emission limitation or standard for the applicable regulated air pollutant,

The unit uses a control device to achieve compliance, and

The unit has potential pre‐control device emissions of the pollutant that are equal to or greater than 100 percent of the amount, in tons per year, required for the source to be classified as a major source.

The facility does not use a control device to achieve compliance; therefore, the requirements of 40 CFR pt. 64 are not applicable. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 5. Regulatory Overview of Facility Subject Item* Applicable Regulations Rationale

Total Facility (TF)

Minn. R. chs. 7002, 7007, 7009, 7017, 7019, 7030

Table A contains some requirements that apply to some facilities in Minnesota. Reporting and monitoring requirements are contained in Table B of this permit.

TF 40 CFR pt. 50; Minn. Stat. Section 116.07; Minn. R. 7007.0100; Minn. R. 7009‐0010‐0080

Modeling requirements to ensure that emissions do not cause violation of the National Ambient Air Quality Standards (NAAQS).

TF Minn. R. 7030.0010 through 7030.0080

The language 'This is a state‐only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are established only under state law and are not established under or required by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required only under state law. State law‐only requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

EU 001 (Combustion Turbine)

Minn. R. 7011.2300 40 CFR pt. 97

Standards of Performance for Stationary Internal Combustion Engines. The rule applies to opacity and SO2. Transport Rule/Cross‐State Air Pollution Rule (CSAPR). The rule applies to NOx and SO2.

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.).


3. Technical Information 3.1 Calculations of Potential to Emit Attachment 2 to this TSD contains Form GI‐07, which summarizes the PTE of the Facility, while Attachment 1 contains detailed spreadsheets and supporting information prepared by the Permittee and audited and approved by the MPCA staff. PTE emissions were calculated using the maximum heat input rating and emission factors from EPA’s AP‐42 for PM, PM10, SO2, NOx, VOC, CO and Lead. PM2.5 emissions were estimated based upon EPA’s Webfire emission factors. GRE’s Turbine manufacturer does not have PM2.5 emission estimates. The EPA test procedures (Method 5 and Method 202) have significant difficulties with the elevated temperatures of combustion turbine exhaust and the extremely low emissions. Carbon dioxide equivalent includes CO2 emissions as well as emissions of CH4 and N2O calculated using Global Warming Potential (GWP) emissions factors taken from EPA 40 CFR pt. 98, tables C‐1 and C‐2. 3.2 Dispersion Modeling Per MPCA policy, as permitted in the original Part 70 permit, the facility triggered the requirement to submit modeling information. The company was not required to complete dispersion modeling. So, the Tier language does not apply. This modeling information will be used if required by nearby sources. 3.3 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:

the likelihood of the facility violating the applicable requirements;

whether add‐on controls are necessary to meet the emission limits;

the variability of emissions over time;

the type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

the technical and economic feasibility of possible periodic monitoring methods; and

the kind of monitoring found on similar units elsewhere.


Table 6 summarizes the monitoring requirements.

Table 6. Monitoring Subject Item* Requirement (basis) Monitoring Discussion

EU 001 (Combustion Turbine)

SO2: 0.50 lb/mmBtu heat input Opacity: ≤ 20 % (Minn. R. 7011.2300) Fuel Type: No. 2 fuel oil/diesel fuel (Minn. R. 7005.0100) Fuel Monitoring (CSAPR)

Recordkeeping: Monthly records of fuel type and usage. CMS: Maintain and record the fuel used and calculate NOx and SO2 emissions for CSAPR allowances

Fuel certification is no longer necessary for compliance with Minn. R. 7011.2300. The fuel type will meet the requirements of 40 CFR Section 80.510(c), of less than 15 parts per million (ppm). The Permittee can demonstrate that the turbine will continue to operate such that emissions are well below the emission limits by using low‐sulfur fuel oil content of less than 0.050 percent by weight; therefore, no additional monitoring is required for SO2. In addition, EU 001 does have a calibrated and certified fuel flow monitor, consistent with EPA 40 CFR pt. 75, Low Mass Emissions (LME) requirements, which was installed to comply with CSAPR requirements.

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 3.4 Insignificant Activities Great River Energy ‐ Maple Lake has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix I to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities.

Table 7. Insignificant Activities

Insignificant Activity General Applicable

Emission limit Discussion

Individual units with potential emissions less than 1) 4,000 lbs/year of CO; 2) 2,000 lbs/year each of NOx, SO2, PM, PM10, VOCs and ozone; and 3) 1,000 tpy of CO2e. [Substation four circuit breakers]

PM, variable depending on airflow Opacity ≤ 20% (with exceptions) (Minn. R. 7011.0715 and Minn. R. 7011.0610)

There is a circuit breaker which is not expected to have any PM emissions or opacity. These units are estimated to have less than 1.7 lbs/yr of sulfur hexafluoride (SF6), which is well below the threshold for CO2e.


Insignificant Activity General Applicable

Emission limit Discussion

Fugitive Emissions [Fugitive Emissions from unpaved roads and parking lots]

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)

The Permittee will take reasonable precautions to prevent the discharge of visible fugitive dust emissions beyond the fence line of the property on which the emissions will be generated.

Emissions units with actual emissions of 1) 2 tpy CO; 2) 1 tpy each of NOx, SO2, PM. PM10, VOCs and ozone; 3) 1,000 tpy CO2e. [150,000 gals fuel oil storage

tank and associated piping]

Minn. R. 7011.1505

There are no standards of performance applicable for storage vessels/tanks.

Emissions units with actual emissions of 1) 2 tpy CO; 2) 1 tpy each of NOx, SO2, PM. PM10, VOCs and ozone; 3) 1,000 tpy CO2e.

[Diesel Black Start Engine]

SO2 ≤ 0.50 lb/MMBtuOpacity ≤ 20% (Minn. R. 7011.2300) 40 CFR pt. 63, subp. ZZZZ

Based on the diesel fuel used, the horsepower rating of the engine, and EPA published emission factors; it is highly unlikely that they could violate the applicable requirements. The area source requirements for subp. ZZZZ are included in the appendix II of the permit.

3.5 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. 3.6 Comments Received Public Notice Period: <start date> ‐ <end date> EPA 45‐day Review Period: <start date> ‐ <end date> This section will be completed after the referenced review periods above. 4. Permit Fee Assessment This permit action is the reissuance of an individual Part 70; therefore, no application or application additional points fees apply under Minn. R. 7002.0016, subp. 1. 5. Conclusion Based on the information provided by Great River Energy, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 17100020‐003


and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Amrill Okonkwo (permit engineer)

David Crowell (compliance and enforcement) Tarik Hanafy (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)

AQ File No. 147B; DQ 4213 Attachments:

1. PTE Summary Calculation Spreadsheets Points Calculator 2. Facility Description and CD‐01 Forms 3. Points Calculator


Attachment 1 – PTE Summary Calculation Spreadsheets (Available electronically in the Central File of Delta)

Attachment 2‐ Facility Description and CD‐01 Forms (Available electronically in the Central File of Delta)

Attachment 3‐ Points Calculator

(Available electronically in an excel spreadsheet in the Central File of Delta)

Attachment 1- PTE Summary Calculation Spreadsheets

PTE Calculations

Great River Energy - Maple Lake

EU001 Capacity(Heat input)

EmissionFactor Source

EmissionFactor

EmissionRate

Maximum Uncontrolled

Emissions

Pollution Control

Efficiency

Pollutant (mmBtu) AP-42 (lb/mmBtu) (lbs/hr) (tons/yr) (%)

PM 363.3 Table 3.1-2a 1.20E-02 4.3596 19.095PM10 363.3 Table 3.1-2a 1.20E-02 4.3596 19.095 PM2.5 363.3 EPA WebFire(1) 1.11E-02 4.0326 17.663

SO2 363.3 Table 3.1-2a 5.05E-02 18.35 80.36 NOX 363.3 Table 3.1-2a 8.80E-01 319.70 1400.30 CH4 363.3 EPA 40 CFR 98 2.20E-03 0.80 3.50NO2 363.3 EPA 40 CFR 98 2.20E-04 0.08 0.35

CO2e(2) 363.3 EPA 40 CFR 98 1.64E+02 59581 260966VOC 363.3 Table 3.1-2a 4.10E-04 0.1490 0.652 CO 363.3 Table 3.1-2a 3.30E-03 1.1989 5.251 Lead 363.3 Table 3.1-2a 1.40E-05 0.0051 0.022 Benzene 363.3 Table 3.1-4 5.50E-05 0.0200 0.0881,3-Butadiene 363.3 Table 3.1-4 1.60E-05 0.0058 0.025Formaldehyde 363.3 Table 3.1-4 2.80E-04 0.1017 0.446Naphthalene 363.3 Table 3.1-4 3.50E-05 0.0127 0.056Selenium 363.3 Table 3.1-5 2.50E-05 0.0091 0.040Arsenic 363.3 Table 3.1-5 1.10E-05 0.0040 0.018Beryllium 363.3 Table 3.1-5 3.10E-07 0.0001 0.000Cadmium 363.3 Table 3.1-5 4.80E-06 0.0017 0.008Chromium 363.3 Table 3.1-5 1.10E-05 0.0040 0.018Manganese 363.3 Table 3.1-5 7.90E-04 0.2870 1.257Mercury 363.3 Table 3.1-5 1.20E-06 0.0004 0.002Nickel 363.3 Table 3.1-5 4.60E-06 0.0017 0.007PAH 363.3 Table 3.1-4 4.00E-05 0.0145 0.064Total HAPs 363.3 na 1.29E-03 0.4679 2.049

References1. EPA Webfire provides PM2.5-PRI at 1.107E-02 for controlled sources. For other PM emission factors in AP-42the "uncontrolled" values matched the Webfire "controlled" values; therefore since WebFire does not provide a P"uncontrolled emission factor, we assume that the WebFire emission factor for PM2.5-PRI "controlled" is represeof "uncontrolled" PM2.5.2. Carbon dioxide equivalent includes CO2 emissions as well as CO2e emissions of CH4 and NO2 calculated usemission factors for CO2, CH4 and NO2 taken from EPA 40 CFR pt. 98, Tables C-1 and C-2., which is 25 and 2

Page 1

PTE Calculations

Maximum/Limited Controlled Emissions

(tons/yr)

19.10 19.10 17.66

80.36 1400.30

3.500.35

2609660.65 5.25 0.02 0.090.030.450.060.040.020.000.010.021.260.000.010.062.05

2,PM2.5entative

sing GWP98 respectively.

Page 2

Great River EnergyFacility Maple LakePermit No. 17100020-003Unit# IA-Diesel Black Start EngineDiesel Start Eng. Massaro Detroit Diesel AlisonModel 7123-7000 V12 #2 Fuel OilRated Output 500.00 hp Rated Input (5) 3.5 mmBtu/hr

Emission Factor (1)

Emission Rate

Potential to Emit (2)

Actual' Emissions (3)

lb/hp-hr lb/hr tpy tpy

PM 2.20E-03 1.100 4.818 0.039PM10 2.20E-03 1.100 4.818 0.039PM2.5 (a) 2.20E-03 1.100 4.818 0.039SOx 2.05E-03 1.025 4.490 0.036NOx 3.10E-02 15.50 67.89 0.543CO2e (b) 1.15E+00 577 2,527 20.20VOC 2.51E-03 1.257 5.506 0.044CO 6.68E-03 3.340 14.63 0.117Lead 0.00 0.00 0.00 0.000

Emission Factor (4)

Emission Factor

Emission Rate

Potential to Emit (2)

Restricted Emissions (3)

lb/MMBtu lb/hp-hr lb/hr tpy tpy

Benzene 9.33E-04 6.53E-06 3.27E-03 1.43E-02 1.14E-04 Toluene 4.09E-04 2.86E-06 1.43E-03 6.27E-03 5.01E-05 Xylenes 2.85E-04 2.00E-06 9.98E-04 4.37E-03 3.49E-05 1,3-Butadiene 3.91E-05 2.74E-07 1.37E-04 5.99E-04 4.79E-06 Formaldehyde 1.18E-03 8.26E-06 4.13E-03 1.81E-02 1.45E-04 Acetaldehyde 7.67E-04 5.37E-06 2.68E-03 1.18E-02 9.40E-05 Acrolein (a) 9.25E-05 6.48E-07 3.24E-04 1.42E-03 1.13E-05 Naphthalene 8.48E-05 5.94E-07 2.97E-04 1.30E-03 1.04E-05 Mercury (6) 3.01E-07 2.11E-09 1.05E-06 4.62E-06 3.69E-08Total PAH 1.68E-04 1.18E-06 5.88E-04 2.58E-03 2.06E-05

1) Emission factors are from MPCA Table EC-03.1 Reciprocating Engine <600 hp Diesel USEPA AP-42 Table 3.3-1: Emission Factors for Uncontrolled Gasoline and Diesel Industrual Engines (lb/MMBtu). http://www.epa.gov/ttn/chief/ap42/ch03/final/c03s03.pdf

a - No emission factor for PM2.5 is provided in AP-42 or EPA WebFire for Uncontrolled Gasoline and Diesel Engines It can be reasonably assumed that the emission factor will be the same as PM10 b - CO2e includes CO2 emissions as well as CO2e emissions of CH4 and N2O calculated using GWP. Emission Factors for CO2, CH4 and N2O taken from EPA 40 CFR 98 Tables C-1 and C-2 as no other GHG emission factors are provided for this type of engine. An average brake-specific fuel consumption (BSFC) of 7,000 Btu/hp-hr was used to convert from lb/MMBtu to lb/hp-hr.2) Potential to emit is calculated at 8760 since the EPA emergency generator memo does not apply to starting engines3) Esimtate actual emissions calcualted at 70 hours per year, as a worst case assumption. 4) USEPA AP-42 Table 3.3-2: Speciated Organic Compound Emission Factors for Uncontrolled Diesel Engines. http://www.epa.gov/ttn/chief/ap42/ch03/final/c03s03.pdf

An average brake-specific fuel consumption (BSFC) of 7,000 Btu/hp-hr was used to convert from lb/MMBtu to lb/hp-hr. a - less than 9.25E-05 lb/MMBtu5) An average brake-specific fuel consumption (BSFC) of 7,000 Btu/hp-hr was used to convert hp to mmBtu/hr6) Hg emission factor from WebFire for SIC 20200102

kg/hr tonnes/hr tonnes/year tonnes CO2e/year tons CO2e/yearCH4 0.0105 0.0000105 0.09198 2.2995 2.53473885N2O 0.0021 0.0000021 0.018396 5.482008 6.042817418

8.577556268Total tpy 2527.5776 5055155 lbs/year

577.0725 lbs/hr

1.154145 lbs/hp-hr

Attachment 2- Facility Description and CD-01 Forms

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MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

21 April, 2015 12:16

FACILITY DESCRIPTION: Potential-to-emit (by item)

Show: Active and Pending Records

AQD Facility ID:

Facility Name:

17100020

Great River Energy - Maple Lake

Item UnrestrictedPotential

(tons per yr)

LimitedPotential

(tons per yr)

ActualEmissions

(tons per yr)

Pollutant AddedBy

(Action)

RetiredBy

(Action)

HourlyPotential

(lbs per hr)

EU 001

Benzene PER 002 8.80E-022.00E-02 8.80E-02

Arsenic compounds PER 002 1.80E-024.00E-03 1.80E-02

1,3-Butadiene PER 002 2.50E-026.00E-03 2.50E-02

Carbon Dioxide Equivalent PER 003 2.59E+055.92E+04 2.59E+05

Cadmium compounds PER 002 8.00E-032.00E-03 8.00E-03

Methane PER 003 3.50E+008.00E-01 3.50E+00

Carbon Monoxide PER 002 5.25E+00 9.00E-031.20E+00 5.25E+00

Carbon Monoxide PER 003 5.25E+001.20E+00 5.25E+00

Carbon Dioxide PER 003 2.60E+055.94E+04 2.60E+05

Chromium compounds PER 002 1.80E-024.00E-03 1.80E-02

Formaldehyde PER 002 4.46E-011.02E-01 4.46E-01

Naphthalene PER 002 5.60E-021.30E-02 5.60E-02

HAPs - Total PER 002 4.83E+004.50E-01 4.83E+00

HAPs - Total PER 003 2.05E+004.50E-01 2.05E+00

Mercury Compounds PER 002 2.00E-034.00E-04 2.00E-03

Manganese compounds PER 002 1.26E+002.87E-01 1.26E+00

Nitrous Oxide PER 003 3.50E-018.00E-02 3.50E-01

Nickel compounds PER 002 7.00E-032.00E-03 7.00E-03

Nitrogen Oxides PER 002 1.40E+03 2.44E+003.20E+02 1.40E+03

Nitrogen Oxides PER 003 1.40E+033.20E+02 1.40E+03

PM < 2.5 micron PER 003 1.76E+014.02E+00 1.76E+01

Lead PER 002 2.30E-025.00E-03 2.30E-02

PM < 10 micron PER 002 1.80E+01 3.30E-024.12E+00 1.80E+01

PM < 10 micron PER 003 1.91E+014.36E+00 1.91E+01

Total Particulate Matter PER 002 1.91E+01 3.30E-024.36E+00 1.91E+01

Total Particulate Matter PER 003 1.91E+014.36E+00 1.91E+01

Selenium compounds PER 002 4.00E-029.00E-03 4.00E-02

Sulfur Dioxide PER 002 7.88E+02 1.40E-011.80E+02 7.88E+02

Sulfur Dioxide PER 003 8.04E+011.84E+01 8.04E+01

Volatile Organic Compounds PER 002 6.50E-01 1.00E-031.50E-01 6.50E-01

Volatile Organic Compounds PER 003 6.50E-011.50E-01 6.50E-01

Page 1 of 1

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Great River Energy - Maple Lake

Permit Number: 17100020 - 003

21 Apr, 2015 12:17Page 1 of 5

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr FACILITY SUBJECT TO TRANSPORT RULE(TR) /CROSS-STATE AIRPOLLUTION RULE (CSAPR)

1.0

CD 40 CFR pt. 97; 40 CFR 52.1240;40 CFR 52.38

The Permittee shall comply with all applicable requirements of 40 CFR pt. 97 forTransport Rule (TR) NOx Annual Units and a TR NOx Annual Source, described in40 CFR Section 97.404.

2.0

CD 40 CFR pt. 97; 40 CFR 52.1241;40 CFR 52.39

The Permittee shall comply with all applicable requirements of 40 CFR pt. 97 forTransport Rule (TR) SO2 Group 2 Units and a TR SO2 Group 2 Source, describedin 40 CFR Section 97.704.

3.0

CD 40 CFR pt. 97; Minn. R.7007.0800, subp. 2

The Permittee shall submit information to the MPCA that the MPCA deemsnecessary to evaluate the applicable requirements of 40 CFR pt. 97 within 60 daysof the date of a letter requesting such information.

4.0

CD Minn. R. 7007.0400, subp. 3 Upon adoption of a new or amended federal applicable requirement and if there aremore than 3 years remaining in the permit term, the Permittee shall file anapplication for an amendment within nine months of promulgation of the applicablerequirement.

5.0

CD hdr SOURCE-SPECIFIC REQUIREMENT6.0

CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

7.0

CD hdr DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCEREVIEW

8.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.0800, subp. 2

These requirements apply if a reasonable possibility (RP) as defined in 40 CFRSection 52.21(r)(6)(vi) exists that a proposed project, analyzed using theactual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test atSection 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, mayresult in a significant emissions increase (SEI). If the ATPA test is not used for theproject, or if there is no RP that the proposed project could result in a SEI, theserequirements do not apply to that project. The Permittee is only subject to thePreconstruction Documentation requirement for a project where a RP occurs onlywithin 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 permitamendment, recordkeeping, or notification may still be required by Minn. R.7007.1150 - 7007.1500.

9.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.1200, subp. 4;Minn. R. 7007.0800, subps. 4 & 5

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following:

1. Project description2. Identification of any emission unit (EU) whose emissions of an NSR pollutantcould be affected3. Pre-change potential emissions of any affected existing EU, and the projectedpost-change potential emissions of any affected existing or new EU.4. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excluded dueto increases not associated with the modification and that the EU could haveaccommodated during the baseline period, an explanation of why the amountswere excluded, and any creditable contemporaneous increases and decreases thatwere considered in the determination.

The Permittee shall maintain records of this documentation.

10.0




21 Apr, 2015 12:17Page 2 of 5

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potential emissionsin the hybrid test. The Permittee shall calculate and maintain a record of the sum ofthe actual and potential (if the hybrid test was used in the analysis) emissions of theregulated pollutant, in tons per year on a calendar year basis, for a period of 5years following resumption of regular operations after the change, or for a period of10 years following resumption of regular operations after the change if the projectincreases the design capacity of or potential to emit of any unit associated with theproject.

11.0

CD Title I Condition: 40 CFR Section52.21(r)(6); Minn. R. 7007.3000;Minn. R. 7007.0800, subps. 4 & 5

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 preconstructionprojection and exceed the baseline actual emissions by a significant amount aslisted at 40 CFR Section 52.21(b)(23). Such report shall be submitted to theAgency 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 ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.

12.0

CD hdr OPERATIONAL REQUIREMENTS13.0

CD 40 CFR pt. 50; Minn. Stat. Section116.07, subds. 4a & 9; Minn. R.7007.0100, subps. 7A, 7L & 7M;Minn. R. 7007.0800, subps. 1, 2 &4; Minn. R. 7009.0010-7009.0080

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

14.0

CD Minn. R. 7011.0020 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.

15.0

CD Minn. R. 7019.1000, subp. 4 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.

16.0

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

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated. At the timeof permit issuance of Permit No, 17100020-003, the facility does not have any airpollution control equipment.

17.0

CD Minn. R. 7007.0800, subps. 14and 16(J)

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 control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation. At the time of permit issuance of PermitNo, 17100020-003, the facility does not have any air pollution control equipment.

18.0

CD Minn. R. 7011.0150 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.

19.0

CD Minn. R. 7030.0010 - 7030.0080 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.

20.0

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

21.0




21 Apr, 2015 12:17Page 3 of 5

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

22.0

CD hdr MONITORING REQUIREMENTS23.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, includingthe date conducted, and any corrective action that resulted. The Permittee shallinclude the calibration frequencies, procedures, and manufacturer's specifications(if applicable) in the Operations and Maintenance Plan. Any requirements applyingto continuous emission monitors are listed separately in this permit.

24.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, and 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.

25.0

CD hdr RECORDKEEPING26.0

CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source or at Great River Energyheadquarters, 12300 Elm Creek Blvd., Maple Grove, Minnesota 55369, for a periodof five (5) years from the date of monitoring, sample, measurement, or report.Records which must be retained at this location include all calibration andmaintenance records, all original recordings for continuous monitoringinstrumentation, and copies of all reports required by the permit. Records mustconform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

27.0

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

28.0

CD Minn. R. 7007.1200, subp. 4 When the Permittee determines that no permit amendment or notification isrequired prior to making a change, the Permittee must retain records of allcalculations required under Minn. R. 7007.1200. These records shall be kept for aperiod 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 thecurrent calendar year of operation and may be kept at the stationary source oroffice of the stationary source for all other years. The records may be maintained ineither electronic or paper format.

29.0

CD hdr REPORTING/SUBMITTALS30.0

CD Minn. R. 7019.1000, subp. 3 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.

31.0

CD Minn. R. 7019.1000, subp. 2 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.

32.0




21 Apr, 2015 12:17Page 4 of 5

CD Minn. R. 7019.1000, subp. 1 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.

33.0

CD Minn. R. 7019.1000, subp. 1 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.

34.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearfollowing Permit Issuance. The first semiannual report submitted by the Permitteeshall cover the calendar half-year in which the permit is issued. The first report ofeach calendar year covers January 1 - June 30. The second report of eachcalendar year covers July 1 - December 31. If no deviations have occurred, thePermittee shall submit the report stating no deviations.

35.0

CD Minn. R. 7007.1150 - Minn. R.7007.1500

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.

36.0

S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit

37.0

CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment toextend 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).Performance testing deadlines from the General Provisions of 40 CFR pt. 60 andpt. 63 are examples of deadlines for which the MPCA does not have authority togrant extensions and therefore do not meet the requirements of Minn. R.7007.1400, subp. 1(H).

38.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year followingPermit Issuance (for the previous calendar year). The Permittee shall submit this tothe Commissioner on a form approved by the Commissioner. This report covers alldeviations experienced during the calendar year.

39.0

CD Minn. R. 7019.3000 -Minn. R.7019.3100

Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

40.0

CD Minn. R. 7002.0005 - Minn. R.7002.0095

Emission Fees: due 30 days after receipt of an MPCA bill.41.0




21 Apr, 2015 12:17Page 5 of 5

Subject Item: EU 001 Combustion Turbine

Associated Items: SV 001 Combustion Turbine

NC/CA

Type Citation Requirement

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

1.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input using 3-hourRolling Average . The potential to emit from the unit is 0.0505 lb/MMBtu due toequipment design and allowable fuels.

2.0

CD Minn. R. 7005.0100, subp. 35a Fuel Type: No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section80.510(c) only by design.

3.0

CD Minn. R. 7007.0800, subp. 5 Fuel Monthly Recordkeeping: The Permittee shall keep records of fuel type andusage on a monthly basis.

4.0

CD 40 CFR pt. 97; 40 CFR 75.19;Minn. R. 7007.0800, subps. 4 and5

The Permittee shall use the fuel flow meter as described under 40 CFR Section75.19 low mass emission methodology to record fuel use and calculate NOx andSO2 emissions for CSAPR allowances.

5.0

CD Minn. R. 7007.0800, subp. 4 The Permittee shall calibrate, operate and maintain a continuous monitoring system(CMS) for the fuel flow monitor consistent with 40 CFR Section 75.19.

6.0

CD Minn. R. 7007.0800, subp. 4 CMS QA/QC: The Permittee shall follow the manufacturer recommendation forpreventative maintenance and periodic monitoring to ensure CMS reliabilityincluding but not limited to annual calibrations for the fuel flow monitors.

7.0

Attachment 3- Points Calculator

Points Calculator

1) AQ Facility ID No.: 147B Total Points 02) Facility Name: Great River Energy-Maple Lake3) Small business? y/n? N 4) DQ Numbers (including all rolled) : 4213 5) Date of each Application Received: 12/7/20126) Final Permit No. 17100020-0037) Permit Staff Amrill Okonkwo8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)? NA

TotalApplication Type DQ No. Qty. Points Points DetailsAdministrative Amendment 1 0Minor Amendment 4 0Applicability Request 10 0Moderate Amendment 15 0Major Amendment 25 0Individual State Permit (not reissuance) 50 0Individual Part 70 Permit (not reissuance) 75 0

Additional PointsModeling Review 15 0

BACT Review 15 0LAER Review 15 0CAIR/Part 75 CEM analysis 10 0NSPS Review 10 0NESHAP Review 10 0Case-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 10 0Plantwide Applicability Limit (PAL) 20 0AERA review 15 0Variance request under 7000.7000 35 0Confidentiality request under 7000.1300 2 0EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0

Add'l Points 0

NOTES: This permit is a reissuance; therefore no additional points are required for this reissuance.

(DQ DQ 4213)

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