AIR POLLUTION CONTROL OPERATION PERMIT REVISION

AIR POLLUTION CONTROL CONSTRUCTION PERMIT REVISION

EI FACILITY NO: 737009020 OPERATION PERMIT REVISION NO.: 737009020-P13

737009020-P16 

CONSTRUCTION PERMIT REVISION NO.: 03-RV-248-R6

TYPE: Significant Revision of Part-70 Source Operation Permit

Revision of Construction Permit 03-RV-248-R5

In compliance with the provisions of Chapter 285, Wis. Stats., and Chapters NR 400 to NR 499, Wis. 

Adm. Code,

Name of Source: Wisconsin Public Service Corporation – Weston Plant

Street Address: 2501 Morrison Ave, Old Highway 51

Rothschild, Marathon County, Wisconsin

Responsible Official, & Title: Howard Giesler, General Manager - Weston

is authorized to operate an electricity generating facility in conformity with the conditions herein. 

This revised operation permit expires on August 27, 2018 [s. 285.66(2)(a), Wis. Stats., and s. NR 

407.09(1)(b)1., Wis. Adm. Code].

A Renewal application must be submitted at least 6 months, but not more than 18 months, prior to 

this expiration date. [ss. 285.66(3)(a), Wis. Stats. and NR 407.04(2), Wis. Adm. Code].

No permittee may continue operation of a source after the operation permit expires, unless the permittee 

submits a timely and complete application for renewal of the permit. If the permittee submits a timely 

and complete application for renewal, the existing operation permit will not expire until the renewal 

application has been finally acted upon by DNR. [ss. 227.51(2) and 285.62(8)(b), Wis. Stats., and NR 

407.04(2), Wis. Adm. Code]

This authorization requires compliance by the permit holder with the emission limitations, monitoring 

requirements and other terms and conditions set forth in Parts I, II, III, and IV hereof.

Dated at Eau Claire, Wisconsin September 23, 2014

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

For the Secretary

By /s/ Jeffery Johnson

Jeffery Johnson

Air Program Supervisor, WCR

FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page i

PREAMBLE TO OPERATION PERMIT

An Asterisk (*) throughout this document denotes legal authority, limitations and conditions which are not federally 

enforceable [Section NR 407.09(3)(b), Wis. Adm. Code.].

Historical Summary of Permits/Orders Issued to the Facility.

The construction permits, orders, etc. identified in the table below, are adopted, under ss. 285.65(3), Wis. 

Stats., and NR 407.09(2)(d), Wis. Adm. Code, by Permit 737009020-P16 which then becomes the primary 

enforceable document: 

Permit/Order Number Issuance Date Sources Covered & Description Permit Status

EPA-5-77-A-4 1977 EPA Approval to construct B03 Included in 737009020-P01

NS-78-37-39-DNR 1978 DNR Approval to construct B03 Included in 737009020-P01

AM-91-29 1991 Consent Order to burn PCB transformer oil Included in 737009020-P01

AM-01-601 2001 Consent Order to limit SO2 emissions Included in 737009020-P01

00-RLO-625-EXM 7/17/2000 Exemption - B03 (replace hot-side ESP w/ 

cold side baghouse)

Included in 737009020-P01

00-RLO-629-EXM 10/18/2000 Exemption – Temporary NG Rental Boiler 

01-MDW-701 2001 P51-P58 Incorporated into 02-JAJ-616

01-RV-095 11/13/2001 B22 Incorporated into 02-JAJ-616

02-JAJ-616 7/19/2002 B22, P51-P55 Revised by 02-JAJ-616-R1 

02-JAJ-616-R1 2/26/2004 B22, P51-P55 Incorporated into 04-RV-128 

02-RLO-RT1 12/11/2002 Research & Testing Exemption to burn 

partially burned coal (i.e. flyash) in B01, 

B02, B03

03-RLO-194-EXM 8/5/2003 Exemption –to burn partially burned coal 

(i.e. flyash) in B01, B02, B03

Included in 737009020-P01

04-RV-128 8/27/2004 B22 Included in 04-RV-128-OP 

04-RV-128-OP 10/15/2004 B22 Included in 737009020-P01 

737009020-P01 10/15/2004 B01, B02, B03, B11, B12, B13, B21, B22, 

P51-P55, P23, P31-P35, P36-P39, F24, 

T01

Revised by 737009020-P02 

737009020-P02 3/30/2007 Revision to B11, B12, B13 Revised by 06-SDD-102 (B03 only), 

Revised by 07-SDD-301 (B01 & B02 

only), Renewed by 737009020-P10 

03-RV-248 10/19/2004 B04, B25, B27-B29, P26, P30, P40, P41-P50, 

P56, P61-P66

Revised by 03-RV-248-R1, Included in 

737009020-P10

03-RV-248-OP Not issued Same as 03-RV-248 Noticed w/ 03-RV-248 – Not Issued

03-RV-248-R1 3/28/2007 B04, F26 Revised by 03-RV-248-R2 (for units 

listed), Included in 737009020-P10

03-RV-248-R2 6/1/2007 Modify B25, New B63 & B64 Revised by 03-RV-248-R3 (for units 

listed), Included in 737009020-P10

03-RV-248-R3 1/18/2008 B04, B25, B27, B28, P40, P44, P45, P49, P50, 

P56, B62, P65, P66

Revised by 03-RV-248-R4 (for units 

listed)

03-RV-248-R4 3/27/2009 B04, B25, B27-B29, P26, P30, P40, P41-P50, 

P56, P61-P66

Revised by 10-MHR-184 (F134 only), 

Revised by 03-RV-248-R5, (for units 

listed)

06-SDD-102 6/19/2007 Over fire air on B03 (expires 12/19/2009) Included in 737009020-P10 

06-SDD-193-EXM 7/17/2006 NSR Exemption – B03 Included in 737009020-P10

737009020-P03 Not issued Same as 06-SDD-102 Noticed w/ 06-SDD-102 – Not Issued

07-SDD-301 7/22/2008 Overfire air on B01 & B02 (expires 7/10/2008) Included in 737009020-P10 

737009020-P04 Not issued Same as 07-SDD-301 Noticed w/ 07-SDD-301 – Not Issued

737009020-P05 Not issued Acid Rain NOX Ave. Plan

B01-B03, B11-B13, B21, B22, P23, F24, P31-

P39, P61, P62, B67-B70, F134

Not Issued - Included in 737009020-

P10 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page ii

09-JGB-089-EXM 5/20/2009 Research & Testing Exemption - B03

10-MHR-184 4/20/2011 F71, F72, F72, F134 Included in 737009020-P10 

10-MHR-184-R1 6/15/2011 F71, F72, F72, F134 Included in 737009020-P10

11-MHR-086-EXM 6/30/2011 12 month Research & Testing Exemption – use 

of sorbent enhancement additive for mercury 

control in B03, B04

12-DCF-171 6/17/2013 B03, B71-B73, P77, P78, P80, P81, T90-

T92

NOT INCLUDED IN 737009020-P10, Revision 

request 12-DCF-171-R1 submitted

737009020-P12 Requested B03, B71-B73, P77, P78, P80, P81, T90-

T92 (Project not completed as of issuance date of 

this permit)

Not Issued – Noticed with 12-DCF171

12-DCF-171-R1 Requested

03-RV-248-R5 8/27/2013 B04 Included in 737009020-P10 

737009020-P10 8/27/2013 Entire Facility Revised by 737009020-P15

737009020-P15 6/9/2014 Minor Revision to Incorporate MATS 

Affirmative Defense Language for B04

Revised by 737009020-P16

03-RV-248-R7 Requested Removal of Hg BACT Limit

03-RV-248-R8 Requested VE BACT Limit for B04

14-XXX-041 Requested Dust collector at coal reclaim

Incorporation of US EPA Consent Decree

737009020-P14 Requested Incorporation of USEPA Consent Decree

03-RV-248-R6 9/23/2014 Revision of 03-RV-248-R5 for B04 Issued with and adopted by 

737009020-P16

737009020-P13 9/23/2014 MATS Extension (B01, B02, B03) Issued with and adopted by 

737009020-P16

737009020-P16 9/23/2014 Significant Revision Active

STACK AND PROCESS INDEX:1

MAIN BOILERS:

Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 

mmBtu/hr. (Babcock and Wilcox Radiant type water tube boiler) - Additional Fuels: Natural Gas, Distillate Fuel 

Oil, and Alternative Fuels. Controlled by ESP with SO3 Injection System – Installed 1954

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr. (Combustion Engineering Radiant type water tube boiler) - Additional Fuels: Natural Gas, Distillate 

Fuel Oil, and Alternative Fuels. Controlled by ESP with SO3 Injection System – Installed November 1960

Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr. (Combustion Engineering Radiant type water tube boiler) - Additional Fuels: Natural Gas, Distillate 

Fuel Oil, and Alternative Fuels. Controlled by Baghouse – Installed 12/1981

Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized 

Coal Boiler Rated at 5179.07 mmBtu/hr. Additional Fuels: Natural Gas. Controlled by Baghouse with FGD and 

SCR Systems – Installed 7/1/2008 

 1 This permit is based on information provided by the permittee in their permit application. The information describing the 

source contained in the Stack and Process Index is descriptive information and does not constitute enforceable conditions. 

However, the permittee should be aware that a physical change or a change in the method of operation that may render this 

descriptive information obsolete or inaccurate may trigger requirements for the permittee to obtain additional permits or seek 

modification of this permit pursuant to chs. NR 405, NR 406, and/or NR 407, Wis. Adm. Code, or change other applicable 

requirements presented in the permit application.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page iii

COMBUSTION TURBINES:

Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine W31 –

Peaking Unit - Rated at 395 mmBtu/hr – Westinghouse W-251-G – Installed 1/1969

Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine W32A –

Peaking Unit - Rated at 434 mmBtu/hr –Turbo Power & Marine Systems TP4-2 DF Twin Pac Pratt & Whitney 

Aircraft FT4C-1DF Gas Turbine – Installed 6/1973

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine W32B –

Peaking Unit - Rated at 434 mmBtu/hr – Turbo Power & Marine Systems TP4-2 DF Twin Pac Pratt & Whitney 

Aircraft FT4C-1DF Gas Turbine – Installed 6/1973

AUXILIARY BOILERS:

Stack S21, Boiler B21 – Weston Units 1& 2 Auxiliary Boiler – Natural Gas Fired Auxiliary Boiler Rated at 6.6 

mmBtu/hr – Johnston Bros. Inc. Catalog #16 Size 17 Type VDRE - Installed 10/1953

Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler - Natural Gas Fired Auxiliary Boiler Rated at 46.2 

mmBtu/hr – Installed 11/2001

Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler - Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – Installed 7/23/2007

STATIONARY RECIPROCATING INTERNAL COMBUSTION ENGINES:

Stack S11AL (Lower) and S11AU (Upper), Process B11A – B11 – Diesel Startup Engine with Dual Exhaust –

Rated at 5.8 mmBtu/hr (825 hp) – Installed 1/1969

Stack S11B, Process B11B - B11 – Emergency Black Start Diesel Engine – Rated at 3.0 mmBtu/hr (435 hp) –

Installed 1/1969

Stack S60, Process B60 – Weston Unit 3 Diesel Fire Pump Engine – Rated at 2.6 mmBtu/hr (380 hp) – Installed 

prior to 4/1981

Stack S27, Process B27 – Weston Unit 4 Diesel Booster Fire Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

Installed 9/20/2007

Stack S28, Process B28 – Weston Unit 4 Main Fire Pump Engine – Rated at 3 mmBtu/hr (430 hp) – Installed 

12/19/2006

HEATERS:

Stack S63, Process B63 – Natural Gas Heater Station #1 - Rated at 0.73 mmBtu/hr

Stack S64, Process B64 – Natural Gas Heater Station #2 – Rated at 0.73 mmBtu/hr

Stack S67, Process B67 – North Natural Gas Station Heater for Natural Gas Supply System – Rated at 1.5 

mmBtu/hr – Installed 1960

Stack S68, Process B68 – South Natural Gas Station Heater for Natural Gas Supply System – Rated at 1.5 

mmBtu/hr – Installed 1960

Stack S69, Process B69 – Rail Car Repair Station Heater – Rated at 0.23 mmBtu/hr - Installed 2005

Stack S70, Process B70 – Rail Car Repair Station Heater – Rated at 0.23 mmBtu/hr – Installed 2005
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page iv

COOLING TOWERS:

Stack S24, Process P24 – Weston Unit 3 Cooling Tower – Installed 1978

Stack S26, Process P26 – Weston Unit 4 Cooling Tower – Installed 9/24/2007

DUST COLLECTORS / BIN VENTS:

Stacks S31A, Process P31A, Control Device C31A – Weston Unit 3 Coal Unloading (Dumper House) – Rated at 

3200 tph – Enclosed Building with 2 Baghouses (C31A and C31B) and a third Junction House Baghouse (C31C) –

Installed 1978

Stacks S31B, Process P31B, Control Device C31B – Weston Unit 3 Coal Unloading (Dumper House) – Enclosed 

Building with 2 Baghouses (C31A and C31B) and a third Junction House Baghouse (C31C) – Installed 1978

Stacks S31C, Process P31C, Control Device C31C – Weston Unit 3 Junction House #1 – Enclosed Building with 

2 Baghouses (C31A and C31B) and a third Junction House Baghouse (C31C) – Installed 1978

Stacks S32A, Process P32A, Control Devices C32A – Weston Units 3 & 4 Crusher House – Rated at 1200 tph - 

Crusher house is enclosed and equipped with two baghouses (C32A and C32B), crusher house agglomerator is 

equipped with one baghouse (C32C), Coal Storage Silos and Cascade Conveyor are equipped with two baghouses 

(C32D and C32E) – Installed 1978 

Stacks S32B, Process P32B, Control Devices C32B – Weston Units 3 & 4 Crusher House – Enclosed – Equipped 

with Baghouse – Installed 1978

Stacks S32C, Process P32C, Control Devices C32C – Weston Units 3 & 4 Crusher House Agglomerator –

Enclosed – Equipped with Baghouse – Installed 1978

Stacks S32D, Process P32D, Control Device C32D – Weston Unit 3 Coal Storage Silos & Cascade Conveyor –

Dust Collector A – Enclosed – Equipped with Baghouse – Installed 1978

Stacks S32E, Process P32E, Control Devices C32E – Weston Unit 3 Coal Storage Silos & Cascade Conveyor –

Dust Collector B – Enclosed – Equipped with Baghouse – Installed 1978

Stack S34, Process P34, Control Device C34 – Weston Units 1&2 Transport Coal Conveyor #8 - Equipped with 

Baghouse– Installed 1992

Stacks S35A, Process P35, Control Devices C35A – Weston Units 1&2 Crusher House - Equipped with Baghouse 

– Installed/Last Modified 1995

Stacks S35B, Process P35, Control Devices C35B – Weston Units 1&2 Conveyor C and Coal Bunker - Equipped 

with Baghouse – Installed/Last Modified 1995

Stacks S36A, Process P36A, Control Device C36A – Weston Unit 3 Fly Ash Transfer & Handling – Installed/Last 

Modified 1995

Stacks S36B, Process P36B, Control Device C36B – Weston Unit 3 Fly Ash Silo – Installed/Last Modified 1995

Stack S37A, Process P37A, Control Device C37A – Weston Units 1 & 2 Fly Ash Transfer and Handling –

Installed 1962, Last Modified 1996

Stacks S37B, Process P37B, Control Device C37B – Weston Units 1 & 2 Fly Ash Silo – Installed 1962, Last 

Modified 1996

Stack S39, Process P39, Control Device C39 – Weston Unit 3 Flyash Storage Building Controlled with Baghouse–

Installed 1993

Stack S30, Process P30, Control Device C30 – Weston Unit 4 System 1, New Reclaim Tunnel Exit #34 – Installed 

2/14/2008
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page v

Stack S41, Process P41, Control Device C41 – Weston Unit 4 System 2, New Junction House 2, #31 – Installed 

3/19/2008

Stack S42, Process P42, Control Device C42 – Weston Unit 4 System 3, New Junction House 3, #32 – Installed 

3/19/2008

Stack S43, Process P43, Control Device C43 – Weston Unit 4 System 4, Unit 4 Silo Fill System, #7 - Installed 

3/19/2008

Stack S44, Process P44, Control Device C44 – Weston Unit 4 System 1, Lime Storage Silo Bin Vent #22 -

Installed 12/13/2007

Stack S45, Process P45, Control Device C45 – Weston Unit 4 System 2, Lime Storage Silo Bin Vent #27 –

Installed 12/17/2007

Stack S49, Process P49, Control Device C49 – Weston Unit 4 System 4, FGD Byproduct Recycle Bin Vent, #24 –

Installed 2/11/2008

Stack S50, Process P50, Control Device C50 – Weston Unit 4 System 5, FGD Waste Silo Bin Vent, #20 - Installed 

4/9/2008

Stack S65, Process P65, Control Device C65 – Weston Unit 4 PAC Storage Silo 4A - Installed 1/24/2008

Stack S66, Process P66, Control Device C66 – Weston Unit 4 PAC Storage Silo 4B - Installed 1/24/2008

FUGITIVE EMISSIONS UNITS:

Process F33 and F56 – Coal Storage and Pile Maintenance – Installed 1978

Process F38 – Bottom and Fly Ash Storage Site – Installed 1970, Last Modified 1993

Stack S40, Process P40 – Conveyor 11 Telescopic Chute #29 – Installed 10/19/2007

Process F134 – Facility Haul Roads

WELDING SHOPS:

Stack S61, Process P61 – Machine Shop Welding

Stack S62, Process P62 – Rail Car Facility Welding Shop

FUGITIVE EMISSIONS UNITS – ASH STORAGE AND PROCESSING:

Process F71 – Temporary Bottom Ash Storage Pile – Installed or last modified 2011

Process F72 – Temporary Fly Ash Storage Pile – Installed or last modified 2011

Process F73 – Bottom Ash Screening Plant – Installed or last modified 2011

Insignificant Emission Units:

Maintenance of Grounds, Equipment, and Buildings

Fuel Oil Storage Tanks (including one 385,000 fuel oil storage tank, two 12, 500 gallon turbine oil tanks, one 28,700 

gallon lube oil tank and one 14,800 gallon main lube oil tank, as well as tanks with capacities <10,000 

gallons)

Stockpiled Contaminated Soils

Demineralization and Oxygen Scavenging of Water for Boilers,
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page vi

Purging of Natural Gas Lines

Boiler, Turbine, and HVAC System Maintenance

Pollution Control Equipment Maintenance

Internal Combustion Engines Used for Warehouse and Material Transport

Fire Control Equipment

Janitorial Services

Office Activities

Convenience Space Heating (< 5 million BTU/hour )

Tank T01 – 3 Fuel Oil Storage Tanks

Gravel Parking Areas,

Unpaved Roads,

Tanks Associated with Insignificant Emissions,

Lubricating Oil Systems,

Plant Vacuum Systems,

Cold Solvent Parts Cleaning,

Non PCB Power Transformers,

Coal Dust Suppressant Equipment and Application,

Incineration of non-hazardous boiler chemical cleaners,

Combustion of Oil Soaked Adsorbents (<3 TPY),

Combustion of Petroleum Soaked Soil (<100 TPY), and

Sulfur Trioxide Storage Tank.

W31 Starting Diesel Engine (5.8 mmBtu/hr)

S60, P60 Ws Pumphouse Diesel Fire Pump

Loading of Coal for Off-Site Shipment

Two Convenience Space Heaters (less than 5 mmBtu/hr)

Transfer of Fly Ash via Rail Cars

Two Small Convenience Water Heaters

Process Safety Ventilation

Portable Vacuum Trucks

Intermittent Onsite Trucking of Coal

Maintenance Dredging and Dewatering of Bottom Ash Settling Pond

Handling and Reclaim of Small Amounts of Alternative Solid Fuels

Fill for Erosion and Roads

Permit Shield: Unless precluded by the Administrator of the US EPA, compliance with all emission limitations in 

this operation permit is considered to be compliance with all emission limitations established under ss. 285.01 to 

285.87, Wis. Stats., and emission limitations under the federal clean air act, that are applicable to the source if the 

permit includes the applicable limitation or if the Department determines that the emission limitations do not apply. 

On January 4, 2013, the U.S. Department of Justice (U.S. DOJ) lodged a proposed consent decree with the U.S. 

District Court for the Eastern District of Wisconsin in the lawsuit entitled U.S. v. Wisconsin Public Service 

Corporation, Civ. No. 13-C-10 (E.D. Wis.). The final consent decree was filed on March 7, 2013. The consent 

decree sets out conditions on the WPSC – Weston Generation Station, including emission limitations, control

requirements, and monitoring requirements for various pollutants. The conditions from the final consent decree will 

be incorporated into the Title V operation permit according to the schedule required by the final decree.

The final terms of this consent decree will affect, and may differ from, many of the current conditions in this permit. 

Operation in compliance with the terms of this operation permit does not shield the permitee from also complying 

with the terms of the final consent decree.

The following emission limitations were reviewed in the analysis and preliminary determination and were 

determined not to apply to this stationary source:

Processes F33 and F38: Not subject to particulate matter emission limitations of s. NR 415.05, Wis. Adm. 

Code, because units are fugitive dust sources.

US EPA did not identify combustion turbines B11, B12, and B13 as affected units under the Acid Rain 

Program, as such the requirements of ch. NR 409, Wis. Adm. Code would not apply to combustion turbines 

B11, B12, and B13.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit Preamble - page vii

Section NR 440.207, Wis. Adm. Code (40 CFR, Part 60, Subpart DC) does not apply to small industrialcommercial-institutional steam generating units at the facility with a maximum design heat input capacity of 

less than 2.9 megawatts (10 million Btu/hr).

Section NR 440.285, Wis. Adm. Code (40 CFR, Part 60, Subpart KB) does not apply to each volatile organic 

liquid storage vessel (including petroleum liquid storage vessels) with a capacity greater than or equal to 151 m3

storing a liquid with a maximum true vapor pressure less than 3.5 kilopascals (kPa). Section NR 440.285, Wis. 

Adm. Code (40 CFR, Part 60, Subpart KB) does not apply to each volatile organic liquid storage vessel 

(including petroleum liquid storage vessels) with a capacity greater than or equal to 75 m3

 but less than 151 m3

storing a liquid with a maximum true vapor pressure less than 15.0 kilopascals (kPa).

* Emissions of hazardous pollutants from the combustion of group 1 virgin fossil fuels are exempt from the 

requirements of s. NR 445.07(1), Wis. Adm. Code, pursuant to s. NR 445.07(5)(a), Wis. Adm. Code. 

Emissions of hazardous pollutants from the combustion of group 2 virgin fossil fuels vented from a stack that 

has downwash minimization stack height are exempt from the requirements of s. NR 445.07(1), Wis. Adm. 

Code, pursuant to s. NR 445.07(5)(b), Wis. Adm. Code.

Part I — The headings for the areas in the permit are defined below. The legal authority for these limitations or 

methods follows them in [brackets].

Pollutant – This area will note which pollutant is being regulated by the permit. 

Limitations – This area will list all applicable emission limitations that apply to the source, including case-bycase limitations such as Latest Available Control Techniques (LACT), Best Available Control Technology 

(BACT), or Lowest Achievable Emission Rate (LAER). It will also list any voluntary restrictions on hours of 

operation, raw material use, or production rate requested by the permittee to limit potential to emit.

Compliance Demonstration – The compliance demonstration methods outlined in this area may be used to 

demonstrate compliance with the associated emission limit or work practice standard listed under the 

corresponding Limitations column. The compliance demonstration area contains limits on parameters or other 

mechanisms that will be monitored periodically to ensure compliance with the limitations. The requirement to 

test as well as initial and periodic test schedules, if testing is required, will be stated here. Notwithstanding the 

compliance determination methods which the owner or operator of a sources is authorized to use under ch. NR 

439, Wis. Adm. Code, the Department may use any relevant information or appropriate method to determine a 

source’s compliance with applicable emission limitations.

Reference Test Methods, Recordkeeping, and Monitoring Requirements – Specific US EPA Reference test 

methods or other approved test methods will be contained in this area and are the methods that must be used 

whenever testing is required. A reference test method will be listed even if no testing is immediately required. 

Also included in this area are any recordkeeping requirements and their frequency and reporting requirements. 

Accuracy of monitoring equipment shall meet, at a minimum, the requirements of s. NR 439.055(3) and (4), 

Wis. Adm. Code, as specified in Part II of this permit.

Condition Type – This area will specify other conditions that are applicable to the entire facility that may not 

be tied to one specific pollutant.

Conditions – Specific conditions usually applicable to the entire facility or compliance requirements.

Acid Rain Portion of Operation Permit – This facility is an affected source under Phase I and Phase II of the 

Acid Rain Provisions (Title IV) of the Clean Air Act. Units 1 – 3 (boilers B01-B03) are Phase I and II units. 

The boilers are not considered new units under the acid rain requirements and the permittee has not submitted a 

repowering plan. To comply with Phase II Acid Rain requirements, the permittee will hold allowances in 

accordance with 40 CFR 72.9(c)(1) and use nitrogen oxide averaging. The acid rain requirements are included 

in the Acid Rain Portion of the Operation Permit included at the end of Part I of the permit.

PART II — This section contains the general limitations that the permittee must abide by. These requirements are 

standard for most sources of air pollutants so they are included in this section with every permit.

PART III - This section contains the requirements for 40 CFR 97 Clean Air Interstate Rule (CAIR) that the 

permittee must abide by.

PART IV - This section contains the requirements of 40 CFR 64 Compliance Assurance Monitoring (CAM) that the 

permittee must abide by.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 1

PART I

SPECIFIC PERMITS CONDITIONS

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 

mmBtu/hr. (Babcock and Wilcox Radiant type water tube boiler) – Installed 1954

Additional Fuels: Natural Gas, Distillate Fuel Oil, and Alternative Fuels 

Controlled by: ESP with SO3 Injection System

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr. (Combustion Engineering Radiant type water tube boiler) – Installed November 1960

Additional Fuels: Natural Gas, Distillate Fuel Oil, and Alternative Fuels 

Controlled by: ESP with SO3 Injection System

Pollutant: 1. Particulate Matter Emissions

a. Limitations:

(1) (a) Boiler B01:

(i) Emissions from boiler B01 may not exceed 0.10 pounds/mmBtu heat input.

(ii) Emissions from boiler B01 may not exceed 85.8 pounds per hour.

(b) Boiler B02: 

(i) Emissions from boiler B02 may not exceed 0.10 pounds/mmBtu heat input.

(ii) Emissions from boiler B02 may not exceed 100 pounds per hour.

[s. NR 415.06(2)(c), Wis. Adm. Code and 07-SDD-301]

(2) See also condition I.A.7.a.(1).

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire: 

(a) the following primary and backup fuels in boilers B01 and B02:

(i) coal;

(ii) natural gas; and

(iii) distillate fuel oil.

(b) the following alternate fuels2 in boilers B01 and B02:

(i) ash (partially burned coal);

(ii) wood waste;

(iii) waste water sludge;

(iv) refuse derived fuel; and 

(v) tire derived fuel.

(c) the following alternate fuels3 in boiler B02:

(i) transformer oil.

[s. NR 407.09(4)(a), Wis. Adm. Code, ss. 285.65(3) and 

285.63(1)(a), Wis. Stats. and 07-SDD-301]

(2) (a) The permittee shall operate an electrostatic precipitator 

whenever solid fuel is fired in boiler B01 in a manner that controls 

particulate matter emissions from boiler B01 so that the emission 

limitations in condition I.A.1.a.(1) are met. 

(b) The permittee shall operate an electrostatic precipitator 

whenever solid fuel is fired in boiler B02 in a manner that controls 

particulate matter emissions from boiler B02 so that the emission 

limitations in condition I.A.1.a.(1) are met. 

[ss. NR 407.09(4)(a) and NR 415.03, Wis. Adm. Code, s. 285.65(3), 

Wis. Stats. and 07-SDD-301]

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever particulate matter emission 

testing is required by the Department, the permittee 

shall use U.S. EPA Method 5, 5I, or 17, including 

backhalf (Method 202), or any other method approved 

by the Department in writing. [s. NR 439.06(1), and 

(1m), Wis. Adm. Code]

(2) The permittee shall retain copies of the results of 

the compliance emission tests specified in I.A.1.b.(4). 

[s. NR 439.04(1)(a), Wis. Adm. Code and 07-SDD301]

(3) The permittee shall keep records of the type and 

amount of fuel burned in each boiler on a monthly 

basis and the hours of operation of each ESP during the 

month. [s. NR 439.04(1)(d), Wis. Adm. Code and 07-

SDD-301]

 2

 See section I.A.6. of this permit for restrictions on the amount of alternate fuels that can be fired.

3

 Ibid. (Same as previous footnote.)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 2

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 1. Particulate Matter Emissions - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) The permittee shall operate an alarm system on each 

ESP to alert the operator if a section of the ESP is out of 

service. If an alarm occurs, the permittee shall take 

appropriate investigative and corrective action. [s. NR 

407.09(4)(a)1. and 3.b., Wis. Adm. Code]

(4) The permittee shall perform compliance emission 

testing of particulate matter emissions from each boiler 

to demonstrate compliance with the applicable 

particulate matter emission limit in I.A.1.a.(1), as 

follows:

(a) Testing shall be conducted every 24 months as long 

as the permit remains valid.

(b) Each biennial test of particulate matter emissions 

shall be performed within 90 days of the anniversary 

date of the issuance of this permit or within 90 days of 

an alternate date specified by the Department in writing.

(c) The permittee may request and the Department may 

approve a waiver from the required biennial testing 

provided the results of the most recently completed 

biennial test demonstrate that particulate matter 

emissions are 50 percent or less of the applicable 

limitation in condition I.A.1.a.(1)

(d) The permittee shall repeat the compliance emissions 

test while firing wood waste, transformer oil, waste 

water sludge, refuse waste, and/or tire derived fuels 

within 60 days of first firing wood waste, transformer 

oil, waste water sludge, refuse waste, and/or tire derived 

fuels. This testing shall be completed prior to firing the 

alternate fuel(s) on a regular basis.

(e) The tests shall be conducted in accordance with 

I.XXX.3.a.

[ss. NR 439.07, NR 439.075(2)(a) and NR 

439.075(3)(b), Wis. Adm. Code and 07-SDD-301]

(5) The permittee shall monitor the following 

operational parameters for each electrostatic precipitator 

(ESP):

(a) the primary voltage in volts;

(b) the secondary voltage in volts;

(c) the primary current in amps;

(d) the secondary current in amps; and

(e) the sparking rate in sparks per minute. 

[s. NR 439.055(1)(c), Wis. Adm. Code and 07-SDD301]

(6) The permittee shall use the parameters identified in 

I.A.1.b.(5) to evaluate the performance of each ESPs 

and perform maintenance as needed to maintain each 

ESPs in good working order. [s. NR 407.09(4)(a)3.b., 

Wis. Adm. Code and 07-SDD-301]

(4) (a) The permittee shall record the parameters listed in 

I.A.1.b.(5) once every 8 hours of operation or once per day, 

whichever yields the greater number of measurements. [s. NR 

439.055(2)(b), Wis. Adm. Code and 07-SDD-301]

(b) The permittee shall keep records of any maintenance performed 

on the ESPs as a result of the evaluations performed as required by 

I.A.1.b.(6). [s. NR 439.04(1)(d), Wis. Adm. Code]

(c) The permittee shall maintain records of any investigative and 

corrective action taken as a result of an alarm indicating visible 

emissions exceeded the respective opacity specified in conditions 

I.A.1.b.(11)(b) and (c) for each boiler, as required by condition 

I.A.1.b.(11)(f), that include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(d) The permittee shall maintain records of any investigative and 

corrective action taken as a result of an alarm indicating an ESP 

section is out of service, as required by I.A.1.b.(3), that include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(5) The permittee shall keep records of:

(a) the date, time, and initials of the person performing the 

inspections required by I.A.1.b.(7);

(b) a list of the items inspected; and

(c) any maintenance, repairs or adjustments performed as a result of 

these inspections. 

(d) the operating hours of each boiler since the last inspection; and

(e) the date, time and initials of the person performing the 

calibrations required by I.A.1.b.(8).

[s. NR 439.04(1)(d), Wis. Adm. Code and 07-SDD-301]

(6) The permittee shall keep records of:

(a) the date, time, and initials of the person performing the 

inspections required by I.A.1.b.(9);

(b) a list of the items inspected;

(c) any maintenance, repairs or adjustments performed as a result of 

these inspections;

[s. NR 439.04(1)(d), Wis. Adm. Code and 07-SDD-301]

(7) The permittee shall keep records of the amount in tons, of ash 

received for combustion from facilities FID #s 744009100 and 

737009570 monthly and in a calendar year. [s. NR 439.04(1)(d), 

Wis. Adm. Code and 07-SDD-301]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 3

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 1. Particulate Matter Emissions - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(7) The permittee shall perform periodic internal inspections of each electrostatic 

precipitator to ensure that the control equipment is operating properly. The time interval 

between inspections may not exceed 13,140 operating hours, unless an alternative 

schedule is approved by the department in writing. [s. NR 407.09(4)(a)3.b., Wis. Adm. 

Code and 07-SDD-301]

(8) The permittee shall calibrate instruments used for measuring the electrostatic 

precipitator operational parameters identified in I.A.1.b.(5) once every 13,140 hours of 

operation, unless an alternative schedule is approved by the department in writing. [s. 

NR 407.09(4)(a)3.b., Wis. Adm. Code]

(9) The permittee shall perform periodic inspections of each boiler to ensure optimum 

boiler performance using a qualified inspector. Specific items that should be inspected 

include, but are not limited to, firebox, boiler tubes, refractory, burner conditions, boiler 

backpass, boiler cleanliness and overall boiler condition. The time interval between 

inspections may not exceed 13,140 operating hours unless the department approves a 

request for an extension in writing. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code and 07-

SDD-301]

(10) Partially burned coal requirements:

(a) The amount of Rhinelander Paper Mill (RPM) (fid # 744008100) partially burned 

coal that is received for combustion in boilers B01, B02, and B03, in any calendar year

may not exceed 10,400 tons. 

(b) The amount of ash from Wausau-Mosinee Mill (fid # 737009570) received for 

combustion in B01, B02 and B03 in a calendar year may not exceed 10,000 tons.4

(c) The permittee shall obtain written approval from the department, prior to burning 

partially burned coal from other sources.

(d) The permittee shall perform an annual elemental metal analysis of the partially 

burned coal from facilities fid#s 744008100 and 737009570 (or other ash as approved 

under I.A.1.b.(9)(c)) prior to or within 90 days after the fuel is first burned in any of the 

boilers, in each calendar year. Elemental metal analysis is required once in any calendar 

year that partially burned coal is fired in any of the boilers.

[ss. 285.65(3) and (10), Stats. and s. NR 407.09(4)(a)3.b., Wis. Adm. Code and 07-SDD301]

(8) The permittee shall keep 

records to demonstrate compliance 

with I.A.1.b.(10)(d). [s. NR 

439.04(1)(d), Wis. Adm. Code]

 4

 The company names associated with these fid#s may be changed and still maintain compliance with this condition.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 4

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 1. Particulate Matter Emissions - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(11) Compliance Assurance Monitoring (CAM) Requirements: Boilers B01 and B02 

are each pollutant-specific emissions units for particulate matter emissions and are 

each subject to the CAM requirements of Part 64 CFR. As such each boiler is 

subject to the CAM requirements in Part IV and section I.XXX.9. of this permit, and 

as follows:

(a) Whenever either boiler is operating, the permittee shall monitor opacity as an 

indicator of ESP performance using a continuous opacity monitoring system 

(COMS) that meets the requirements I.A.2.b.(2) and I.A.2.c.(2);

(b) The indicator range for visible emissions from B01 is 20% opacity or less based 

on a one-hour average;5

 

(c) The indicator range for visible emissions from B02 is 10.5% or less based on a 

one-hour average;6

(d) The permittee shall use the data collected by the COMS to calculate one-hour 

average opacities for each boiler;

(e) An excursion is a one-hour average opacity reading that exceeds the indicator 

range in conditions I.A.1.b.(11)(b) or (c) for boilers B01 and B02, respectively;

(f) The permittee shall operate an alarm system to notify the operator if visible 

emissions exceed the respective opacity specified in conditions I.A.1.b.(11)(b) and 

(c) for each boiler. If an alarm occurs, the permittee shall take appropriate 

investigative and corrective action.

(g) The quality improvement plan (QIP) threshold is reached when excursions occur 

for more than 5% of an individual boiler’s operating time in a six month reporting 

period;

(h) The permittee shall operate the COMS in accordance with 40 CFR ss. 64.7 and 

64.8 as detailed in conditions I.XXX.a.(2) and (4).

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and s. NR 439.055(5), Wis. Adm. 

Code, and 40 CFR ss. 64.2, 64.3, 64.6, 64.7, and 64.8]

 5 The permittee established a correlation between particulate matter emissions and opacity using compliance emission test data. 

This correlation is described in the MONITORING APPROACH JUSTIFICATION FOR UNITS 1 AND 2 included in the CAM plan in Part 

IV of this permit. Based on this correlation, the indicator for boiler B01 is 20 percent or less.

6 The permittee established a correlation between particulate matter emissions and opacity using compliance emission test data. 

This correlation is described in the MONITORING APPROACH JUSTIFICATION FOR UNITS 1 AND 2 included in the CAM plan in Part 

IV of this permit. Based on this correlation, the indicator for boiler B02 is 10.52 percent or less.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 5

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.7

 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.05, Wis. Adm. Code and 07-SDD-301]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) To minimize visible emissions, the permittee shall start-up and shutdown each boiler according to the following:8

(a) Normal Start-up Sequence:

(i) Place ESP in service and ensure continuous opacity monitor is 

operational, or in accordance with an alternative monitoring method 

approved in writing by the Department.

(ii) Start the draft fan(s)

(iii) Preheat boiler firing natural gas and/or distillate fuel oil as a startup 

fuel.

(iv) Introduce coal to the combustion chamber while continuing to operate 

the startup fuel as the coal begins to ignite.9

 

(v) Continue the use of the startup fuel until stable fire is achieved.

(vi) Normal start-up is complete upon achieving a stable fire and B01 

reaches a minimum generator load of 12 MW or B02 reaches a minimum 

generator load of 18 MW.10

(b) Normal Shut-down Sequence:

(i) Reduce generator load to 12 MW for B01 or 18 MW for B02 with the 

intent of removing the unit from service.

(ii) Discontinue coal introduction to boiler and/or cease fuel firing.

(iii) Discontinue operation of the draft fans.

(iv) Discontinue operation of ESP.

(v) Normal shut-down is complete after item (iv) or a start-up of the boiler 

commences.

[s. NR 407.09(4)(a), Wis. Adm. Code and 07-SDD-301]

(2) The permittee shall calibrate, maintain and operate a continuous 

monitoring system for the measurement of opacity from each stack in 

accordance with the performance specifications in 40 CFR Part 75, 

Appendices A to I and Performance Specification 1 in 40 CFR Part 60, 

Appendix B. [ss. NR 439.09(1), and NR 439.095(1)(f) and (6), Wis. Adm. 

Code and 07-SDD-301]

(1) Reference Test Method for Visible 

Emissions: Whenever visible emission testing 

is required by the Department, the permittee 

shall use U.S. EPA Method 9 or any other 

method approved by the Department in writing. 

[s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) The continuous opacity monitors required 

by I.A.2.b.(2) shall complete one cycle of 

sampling and analyzing for each successive 

10-second period and one cycle of data 

recording for each successive 6-minute period, 

at a minimum. [s. NR 439.09(9)(a), Wis. Adm. 

Code and 07-SDD-301]

(3) The permittee shall submit quarterly excess 

emission reports to the Department by January 

30, April 30, July 30, and October 30 for the 

previous calendar quarter, in accordance with 

I.XXX.2.a. [s. NR 439.09(10), Wis. Adm. 

Code and 07-SDD-301]

(4) Unless otherwise specified by the 

Department, periods of excess visible 

emissions shall be any 6-minute period during 

which the average opacity exceeds the 

limitation in I.A.2.a.(1). [s. NR 439.09(10)(b), 

Wis. Adm. Code and 07-SDD-301]

 7

 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per hour may be 

exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of cleanings or the number of 

fires that may be started in any day, only the number of exemptions that are allowed in any one day.

8

 The normal start-up and shut-down sequences listed are a summary of steps to minimize visible emissions during start-up 

and shut-down operations. The normal start-up sequence listed here does not define the period of “new fire starting” 

allowed in the exceptions to the visible emission limitation in condition I.A.2.a.(1)(a).

9

 B02 is capable of operating at full load on natural gas.

10 All values are gross MW. The normal start-up sequence from first coal fire to stable coal fire is generally less than 12 

hours in duration.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 6

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 3. Nitrogen Oxides

a. Limitations:

(1) (a) Emissions from boiler B01 may not exceed 1079.5 pounds per hour.11

(b) Emissions from boiler B02 may not exceed 1258.0 pounds per hour.

[ss. 285.63(1)(b) and 285.65(3) and (7), Wis. Stats. and 07-SDD-301]

(2) Acid Rain Requirements: Boilers B01 and B02 are Affected Acid Rain Units subject to Acid Rain Requirements. As such 

the permittee shall comply with the applicable requirements included in the Acid Rain Portion of the Operation Permit in 

Section I.ZZZ.

(3) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boilers B01 and B02 are subject to 

the NOx - Annual and the NOx –Ozone Season CAIR requirements. As such, the permittee shall comply with the CAIR 

requirements as outlined in section I.XXX.8. and in the CAIR Permit Application (for sources subject to CAIR FIP) submitted 

by Wisconsin Public Service Corporation – Weston and dated May 23, 2007 incorporated as Part III of this Operation Permit 

and 40 CFR 97.121, 97.122, 97.221, 97.222, 97.321 and 97.322. OR alternately, when in effect, comply with the Cross-State 

Air Pollution Rule requirements, as applicable, as required in section I.XXX.8.

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate compliance with the 

applicable NOx hourly emission limit by using fuel 

consumption records and AP-42 emission factor. [s. 

285.65(3), Wis. Stats., s. 407.09(4), Wis. Adm. Code, and 07-

SDD-301]

(2) The permittee shall operate and maintain separated 

overfire air (SOFA) and low-NOx burner systems on boilers 

B01 and B02 when firing solid fuel as permitted under 07-

SDD-301. [ss. NR 407.09(1) and (4), Wis. Adm. Code]

(3) The permitte shall perform the boiler inspections required 

by I.A.1.b.(9). [s. NR 407.09(4)(a)3.b., Wis. Adm. Code]

(1) Reference Test Method for Nitrogen Oxide Emissions: 

Whenever nitrogen oxide emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 7 or 

other method approved by the Department in writing. [s. NR 

439.06(6), Wis. Adm. Code]

(2) The permittee shall keep monthly records of the type and 

amount of fuel fired in each boiler. [s. NR 439.04(1)(d), Wis. 

Adm. Code]

(3) The permittee shall maintain plans and specifications 

showing that separated overfire air and low-NOx burner 

systems are installed on boilers B01 and B02. [s. NR 

439.04(1)(d), Wis. Adm. Code and 07-SDD-301]

(4) The permittee shall keep records of boiler inspections as 

required by I.A.1.c.(6) [s. NR 439.04(1)(d), Wis. Adm. Code 

and 07-SDD-301]

 11 These limitations are established in the permit because the source was reviewed with this emission rate and it was 

determined that no ambient air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 7

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 4. Sulfur Dioxide

a. Limitations:

(1) Emissions may not exceed the following rates based on a 3-hour rolling average12:

(a) 1653.3 pounds per hour total from boilers B01 and B02 combined;

(b) 1029.6 pounds per hour from S01 with the emissions from B02 limited to 623.7 pound per hour, with combined emissions 

from B01 and B02 not to exceed 1653.3 pounds per hour; and

(c) 1200 pounds per hour from boiler B02 with the emissions from B01 limited to 453.6 pounds per hour, with combined 

emissions from B01 and B02 not to exceed 1653.3 pounds per hour.

[s. 285.65(7), Wis. Stats., s. 285.65(3), Wis. Stats. and s. NR 404.04(2)(b), Wis. Adm. Code and 07-SDD-301]

(2) Acid Rain Requirements: Boilers B01 and B02 are Affected Acid Rain Units subject to Acid Rain Requirements. As such 

the permittee shall comply with the applicable requirements included in the Acid Rain Portion of the Operation Permit in 

Section I.ZZZ.

(3) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boilers B01 and B02 are subject to 

the SO2 CAIR requirements. As such, the permittee shall comply with the CAIR requirements as outlined in section I.XXX.8. 

and in the CAIR Permit Application (for sources subject to CAIR FIP) submitted by Wisconsin Public Service Corporation –

Weston and dated May 23, 2007 incorporated as Part III of this Operation Permit and 40 CFR 97.121, 97.122, 97.221, 97.222, 

97.321 and 97.322. OR alternately, when in effect, comply with the Cross-State Air Pollution Rule requirements, as applicable, 

as required in section I.XXX.8.

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall calibrate, 

maintain and operate a continuous 

monitoring system for the 

measurement of sulfur dioxide 

emissions from each stack, in 

accordance with the performance 

specifications in 40 CFR Part 75, 

Appendices A to I.13 [ss. NR 

439.09(2), and NR 439.095(1)(f) and 

(6), Wis. Adm. Code and 07-SDD301]

(1) Reference Test Method for Sulfur Dioxide Emissions: Whenever sulfur dioxide 

emission testing is required by the Department, the permittee shall use U.S. EPA 

Method 6 or any other method approved by the Department in writing. 

[s. NR 439.06(2), Wis. Adm. Code]

(2) The continuous sulfur dioxide monitor required by I.A.4.b.(1) shall perform 

sampling, analyzing, and data recording as follows:

(a) complete one cycle of sampling, analyzing, and data recording for each successive 

15-minute period.

(b) the values recorded shall be averaged hourly.

(c) hourly averages shall be computed from 4 data points equally spaced over each 1 

hour period, except during periods when calibrations, quality assurance or 

maintenance activities are being performed. During these periods, a valid hour shall 

consist of at least 2 data points separated by a minimum of 15 minutes.

[s. NR 439.09(9)(b), Wis. Adm. Code and 07-SDD-301]

(3) The permittee shall submit quarterly excess emission reports to the Department by 

January 30, April 30, July 30, and October 30 for the previous calendar quarter. [s. 

NR 439.09(10), Wis. Adm. Code and 07-SDD-301]

(4) Excess emissions for sulfur dioxide are any 3-hour rolling average during which 

the average sulfur dioxide emissions exceed the emission limitation in I.A.4.a.(1). [s. 

NR 439.09(10)(b), Wis. Adm. Code and 07-SDD-301]

 12 These limits are established in the permit because the source was reviewed with these emission rates and it was determined 

that no 3-hour sulfur dioxide ambient air quality standards would be violated when operated as proposed. 13 The permittee is exempt from the biennial sulfur dioxide compliance tests required by ss. NR 439.075(2)(a)2., and (3)(b),

Wis. Adm. Code provided that they operate a continuous sulfur dioxide monitor that meets the performance specification 

requirements of s. NR 439.09, Wis. Adm. Code, pursuant to s. NR 439.075(4)(a)2., Wis. Adm. Code.

The permittee is exempt from the periodic fuel sampling and analysis requirements of s. NR 439.085(2), Wis. Adm. Code 

provided they operate a continuous sulfur dioxide emission monitor that meets the performance specification requirements of s. 

NR 439.09, Wis. Adm. Code, pursuant to s. NR 439.085(1)(c), Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 8

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 5. Carbon Monoxide

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions from boiler B01 may not exceed the following:

(i) 0.29 pounds/mmBTU heat input averaged over any 12-month period, excluding times when the unit is non-operational 

and periods of startup and shutdown; and

(ii) 4.8 tons in any calendar day, including all hours of operation or non-operation

(b) Emissions from boiler B02 may not exceed the following:

(i) 0.29 pounds/mmBTU heat input averaged over any 12-month period, excluding times when the unit is non-operational 

and periods of startup and shutdown; and

(ii) 5.6 tons in any calendar day, including all hours of operation or non-operation

[s. NR 405.08, Wis. Adm. Code and 07-SDD-301]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall calibrate, 

maintain and operate a continuous 

monitoring system for the 

measurement of carbon monoxide 

emissions from each stack, in 

accordance with the performance 

specifications in s. NR 439.09(4), 

Wis. Adm. Code. [ss. NR 405.08, 

NR 439.09(4) and NR 

439.095(1)(f), Wis. Adm. Code and 

07-SDD-301]

(1) Reference Test Method for Carbon Monoxide Emissions: Whenever carbon 

monoxide emission testing is required, the permittee shall use U.S. EPA Method 10 or 

any other method approved by the Department in writing. [s. NR 439.06(4)(a), Wis. 

Adm. Code]

(2) The continuous carbon monoxide monitor required by I.A.5.b.(1) shall perform 

sampling, analyzing, and data recording as follows:

(a) complete one cycle of sampling, analyzing, and data recording for each successive 

15-minute period.

(b) the values recorded shall be averaged hourly.

(c) hourly averages shall be computed from 4 data points equally spaced over each 1 

hour period, except during periods when calibrations, quality assurance or maintenance 

activities are being performed. During these periods, a valid hour shall consist of at 

least 2 data points separated by a minimum of 15 minutes. 

(d) When calculating hourly emissions in pounds per million Btu, a minimum 

concentration of 5.0 percent carbon dioxide or a maximum concentration of 14.0 

percent oxygen may be substituted for the measured diluent gas concentration value for 

any operating hour in which the hourly average carbon dioxide concentration is less 

than 5.0 percent carbon dioxide or the hourly average oxygen concentration is greater 

than 14.0 percent oxygen, as described in 40 CFR Part 75 Appendix F Section 3.3.4.1. 

[s. NR 439.09(9)(b), Wis. Adm. Code and 07-SDD-301]

(3) The permittee shall submit quarterly excess emission reports to the Department by 

January 30, April 30, July 30, and October 30 for the previous calendar quarter. [s. NR 

439.09(10), Wis. Adm. Code and 07-SDD-301]

(4) Excess emissions for carbon monoxide are defined as: 

(a) any calendar day during which the total mass emissions of carbon monoxide exceed 

the emission limitations in I.A.5.a.(1)(a)(ii) and I.A.5.a.(1)(b)(ii). 

(b) any month in which the calculated 12-month average carbon monoxide emission 

rate exceeds the emission limitations in I.A.5.a.(1)(a)(i) and I.A.5.a.(1)(b)(i).

[s. NR 439.06(4)(b), Wis. Adm. Code and 07-SDD-301]

(5) Unless otherwise required by the Department in writing, this permit grants the 

permittee approval to submit a summary excess emission report in lieu of the full excess 

emission reports. This summary report shall be submitted on a Department form or in a 

format approved by the Department.

[s. NR 439.09(10)(d), Wis. Adm. Code and 07-SDD-301]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 9

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 5. Carbon Monoxide – (Continued)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) The permittee shall keep records adequate to show:

(a) Periods of boiler startup14, including when boiler startup began and ended;

(b) Period of boiler shutdown15, including when boiler shutdown began and ended.

[s. NR 439.04(1)(d), Wis. Adm. Code]

 14 Section NR 400.02(152), Wis. Adm. Code defines “startup” as “the setting in operation of a facility or its emission control 

equipment for any purpose which produces emissions”.

15 Section NR 400.02(144), Wis. Adm. Code defines “shutdown” as “the cessation of operation of a direct or portable source 

or of emission control equipment”.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 10

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 6. * Hazardous Air Contaminants Regulated by ch. NR 445, Wis. Adm. Code

a. Limitations:

(1) * Except as provided in s. NR 445.07(5), Wis. Adm. Code, the following requirements apply16:

(a) * The permittee may not cause, allow or permit emissions of a hazardous air contaminant listed in Table A of s. NR 445.07, 

Wis. Adm. Code, in such quantity or concentration or for such duration as to cause an ambient air concentration of the 

contaminant off the source property that exceeds the concentration in column (g) of Table A for the contaminant. [s. NR 

445.07(1)(a), Wis. Adm. Code]

(b) * If a hazardous air contaminant for which a control requirement is identified in column (i) of Table A of s. NR 445.07, 

Wis. Adm. Code, is emitted in a quantity greater than the applicable amount listed in column (f)17 of Table A, the permittee 

shall control emissions of the contaminant to a level identified in column (i) of the table, according to the applicable 

compliance requirements of s. NR 445.08, Wis. Adm. Code. [s. NR 445.07(c), Wis. Adm. Code]

(2) * The permittee shall achieve compliance with the emission limitations and control requirements of I.A.6.a.(1) for each 

hazardous air contaminant by doing one or any combination of the following:

(a) * Limiting non-exempt, potential to emit emissions to less than the applicable thresholds in column (f) of Table A of s. NR 

445.07, Wis. Adm. Code.18 [s. NR 445.08(2)(a), Wis. Adm. Code]

(b) * Limiting the quantity, concentration or duration of non-exempt, potential to emit emissions of each hazardous air 

contaminant that has a standard expressed as an ambient air concentration in Table A of s. NR 445.07, Wis. Adm. Code so that 

the ambient air concentration off the source property is less than the concentration allowed under column (g) of Table A. [s.

NR 445.08(2)(b), Wis. Adm. Code]

(c) * Limiting the quantity, concentration or duration of non-exempt, potential to emit emissions of each hazardous air 

contaminant with a control requirement in column (i) of Table A of s. NR 445.07, Wis. Adm. Code having a unit risk factor 

established by either the EPA or the California air resources board, so as not to cause an ambient air concentration off the 

source property that results in an inhalation impact greater than 1 x 10-6 (as determined by the equation in s. NR 445.08(2)(c), 

Wis. Adm. Code). [s, BR 445.08(2)(c), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * To demonstrate compliance with conditions 

I.A.6.a.(1) and (2), the use of alternate fuels in 

boilers B01 and B02 may not exceed the 

following rates:

(a) Wood Waste Usage Limitations:

(i) Boiler B01: 1) 85.8 tons per hour; and

2) 284,090 tons during each 

12 consecutive month 

period.

(ii) Boiler B02: 1) 100 tons per hour; and 

2) 284,090 tons during each 

12 consecutive month 

period.

{continued on Next Page...}

(1) * The permittee shall keep the following records:

Wood Waste:

(a) The amount of wood waste combusted in each boiler in tons per hour;

(b) The amount of wood waste combusted in each boiler during each 

calendar month, in tons per month;

(c) The amount of wood waste combusted in each boiler totaled for each 

12 consecutive month period, in tons;

Waste Water Sludge:

(d) The amount of waste water sludge combusted in each boiler in tons 

per hour;

(e) The amount of waste water sludge combusted in each boiler during 

each calendar month, in tons per month;

(f) The amount of waste water sludge combusted in each boiler totaled for 

each 12 consecutive month period, in tons;

{continued on next page...}

 16 HAP emissions from natural gas and distillate fuel oil combustion are exempt since they are group 1 virgin fossil fuels, 

pursuant to s. NR 445.07(5)(a), Wis. Adm. Code. HAP emissions from coal combustion are exempt because coal is a group 2 

virgin fossil fuel and the boiler stacks meet the downwash minimization stack height criteria pursuant to s. NR 445. 07(5)(b), 

Wis. Adm. Code. The conditions in this section of the permit apply to hazardous air contaminant emissions generated by the 

combustion of alternate fuels in boilers B01 and B02.

17 The stacks (S01 and S02) exhausting boilers B01 and B02 are greater than 75 feet in height. The stacks are unobstructed 

discharge points, exhausting emissions within 10 degrees of vertical as required by s. NR 445.07(6)(a), Wis. Adm. Code. 

18 The boilers meet the requirements of s. NR 445.07(6)(a) and (b), Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 11

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 6. * Hazardous Air Contaminants Regulated by ch. NR 445, Wis. Adm. Code - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * {...continued from previous page...}

To demonstrate compliance with conditions I.A.6.a.(1) and (2), the 

use of alternate fuels in boilers B01 and B02 may not exceed the 

following rates:

(b) Waste Water Sludge Usage Limitations:

(i) Boiler B01: 1) 3.7 tons per hour; and

2) 8333 tons during each 12 consecutive month 

period.

(ii) Boiler B02: 1) 3.7 tons per hour; and

2) 8333 tons during each 12 consecutive month 

period.

(c) Refuse Derived Fuel Usage Limitations:

(i) Boiler B01: 1) 3.09 tons per hour; and

2) 13,889 tons during each 12 consecutive month 

period.

(ii) Boiler B02: 1) 3.09 tons per hour; and

2) 13,889 tons during each 12 consecutive month 

period.

(d) Tire Derived Fuel:

(i) Boiler B01: 1) 31.9 tons per hour; and

2) 279,444 tons during each 12 consecutive 

month period.

(ii) Boiler B02: 1) 37.2 tons per hour; and

2) 325,872 tons during each 12 consecutive 

month period.

(e) Transformer Oil:

(i) Boiler B01: None allowed.

(ii) Boiler B02: 1) 699 gallons per hour; and

2) 227,273 gallons during each 12 consecutive 

month period

[s. NR 445.08, Wis. Adm. Code]

(2) Partially burned coal requirements:

(a) The amount of Rhinelander Paper Mill (RPM) (fid # 744008100) 

partially burned coal that is received for combustion in boilers B01, 

B02, and B03, in any calendar year may not exceed 10,400 tons. 

(b) The amount of ash from Wausau-Mosinee Mill (fid # 737009570) 

received for combustion in B01, B02 and B03 in a calendar year may 

not exceed 10,000 tons.19

(c) The permittee shall obtain written approval from the department, 

prior to burning partially burned coal from other sources.

(d) The permittee shall perform an annual elemental metal analysis of 

the partially burned coal from facilities fid#s 744008100 and 

737009570 (or other ash as approved under I.A.6.b.(2)(c) prior to or 

within 90 days after the fuel is first burned in any of the boilers, in 

each calendar year. Elemental metal analysis is required once in any 

calendar year that partially burned coal is fired in any of the boilers.

[ss. 285.65(3) and (10), Stats. and s. NR 407.09(4)(a)3.b., Wis. Adm. 

Code and 07-SDD-301]

(1) * {...continued from previous page...}

The permittee shall keep the following records:

Refuse Derived Fuel:

(g) The amount of refuse derived fuel combusted in 

each boiler in tons per hour;

(h) The amount of refuse derived fuel combusted in 

each boiler during each calendar month, in tons per 

month;

(i) The amount of refuse derived fuel combusted in 

each boiler totaled for each 12 consecutive month 

period, in tons;

Tire Derived Fuel:

(j) The amount of tire derived fuel combusted in each 

boiler in tons per hour;

(k) The amount of tire derived fuel combusted in 

each boiler during each calendar month, in tons per 

month;

(l) The amount of tire derived fuel combusted in each 

boiler totaled for each 12 consecutive month period, 

in tons;

Transformer Oil:

(m) The amount of transformer oil combusted in 

boiler B02, in gallons per hour;

(n) The amount of transformer oil combusted in 

boiler B02 during each calendar month, in gallons per 

month;

(o) The amount of transformer oil combusted in 

boiler B02 totaled for each 12 consecutive month 

period, in gallons.

[s. NR 439.04(1)(d), Wis. Adm. Code]

(2) To demonstrate compliance with I.A.6.b.(2), the 

permittee shall keep records of the amount in tons, of 

ash received for combustion from facilities FID #s 

744009100 and 737009570 monthly and in a calendar 

year. [s. NR 439.04(1)(d), Wis. Adm. Code and 07-

SDD-301]

(3) The permittee shall keep records to demonstrate 

compliance with I.A.6.b.(2)(d). [s. NR 439.04(1)(d), 

Wis. Adm. Code]

 

19 The company names associated with these fid#s may be changed and still maintain compliance with this condition.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 12

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

a. Limitations:

(1) For each of boilers B01 and B02, the permittee shall comply with ONE of the following:

(a) Filterable particulate matter may not exceed: 0.03 lbs/mmBtu or 0.3 lbs/MWh gross electric output; OR

(b) Total non-Hg HAP metals may not exceed: 0.00005 lbs/mmBtu or 0.5 lbs/GWh; OR

(c) Individual Metal HAP metals may not exceed all of the following:

(i) Antimony (Sb): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(ii) Arsenic (As): 1.1 lbs/TBtu or 0.02 lbs/GWh;

(iii) Beryllium (Be): 0.2 lbs/TBtu or 0.002 lbs/GWh;

(iv) Cadmium (Cd): 0.3 lbs/TBtu or 0.003 lbs/GWh;

(v) Chromium (Cr): 2.8 lbs/TBtu or 0.03 lbs/GWh;

(vi) Cobalt (Co): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(vii) Lead (Pb): 1.2 lbs/TBtu or 0.02 lbs/GWh;

(viii) Manganese (Mn): 4.0 lbs/TBtu or 0.04 lbs/GWh;

(ix) Nickel (Ni): 3.5 lbs/TBtu or 0.04 lbs/GWh; and

(x) Selenium (Se): 5.0 lbs/TBtu or 0.06 lbs/GWh.

[40 CFR s. 63.9991(a)(1) and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.a., s. 285.65(13), Wis. Stats.]

(2) For each of boilers B01 and B02, the permittee shall comply with ONE of the following:

(a) Hydrogen chloride (HCl) emissions may not exceed: 0.002 lbs/mmBtu or 0.02 lbs/MWh; OR

(b) Sulfur dioxide (SO2) emissions may not exceed: 0.2 lbs/MMBtu or 1.5 lbs/MWh.

(c) The alternate SO2 limit in (b) shall only be used if the EGU:

(i) Has a system using wet or dry flue gas desulfurization technology and SO2 continuous emissions monitoring 

system (CEMS) installed on the unit; and

(ii) The wet or dry flue gas desulfurization technology installed on the unit is operated consistent with 40 CFR 

s. 63.10000(b), at all times.

[40 CFR ss. 63.9991(a)(1) and (c), and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.b., s. 285.65(13), Wis. Stats.]

(3) For each of boilers B01 and B02, mercury emissions may not exceed: 1.2 lbs/TBtu or 0.013 lbs/GWh. [40 CFR s. 

63.9991(a)(1) and 40 CFR, Part 63, Subpart UUUUU, Table 2, condition 1.c., s. 285.65(13), Wis. Stats.]

(4) The emission limits (I.A.7.a.(1) - (3)) and operating limits (I.A.7.b.(4)) in this section apply at all times except during 

periods of startup and shutdown; however, the permittee is required to meet the work practice requirements in conditions 

I.A.7.b. (3) during periods of startup or shutdown. [40 CFR s. 63.10000(a), s. 285.65(13), Wis. Stats.]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 13

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

a. Limitations:

{...continued from previous page...}

(5) The original compliance date for the requirements of this section is April 16, 2015. The department approved an extension 

of the compliance date to June 1, 2015 provided the following terms and conditions are met:20

(a) This extension covers the requirement to meet 40 CFR Part 63 Subpart UUUUU known as MATS for affected 

emissions units B01 and B02.

(b) Wisconsin Public Service Corporation submitted a proposed compliance schedule on May 28, 2013 indicating that 

they expect to retire or refuel these units by June 1, 2015, and additional time is needed to maintain electric reliability 

for the 2014-15 planning year. The anticipated compliance schedule is:

(i) March 7, 2013 – Wisconsin Public Service Corporation enters Consent Decree with USEPA and is required to 

repower, refuel or retire Weston units B01 and B02 by June 1, 2015.

(ii) June 1, 2015 – Final Compliance with 40 CFR Part 63 Subpart UUUUU.

(c) If Wisconsin Public Service Corporation is unable to meet these timelines proposed in its May 23, 2013 letter, the 

facility shall submit a revised timeline to the department that includes an explanation of the reasons for any delays. 

Under no circumstances may final compliance extend beyond April 16, 2016.

(d) To minimize emissions during the extension period (from April 16, 2015 until June 1, 2015) Wisconsin Public Service 

Corporation shall pursue the following guidelines:

(i) The boilers (B01 and B02), when firing coal, shall be operated according to current operation permit 

restrictions.

(ii) The boilers shall be dispatched in a manner consistent with current MISO requirements.

(iii) If the project extends past June 1, 2015, the facility shall complete the project as expeditiously as practicable.

(e) Within 30 days of achieving final compliance, submit to the Department, notification that final compliance has been 

achieved.

(f) This extension is limited to a maximum of one year in duration and expires no later than April 16, 2016.

(g) This extension is authorized under s. NR 460.05(7)(g), Wis. Adm. Code, s. 112(i)(3) of the Clean Air Act, and 40 

CFR 63.6(i)(9). Failure to satisfy any of the above terms and conditions may result in termination of the compliance 

extension, in part or whole, pursuant to s. NR 460.05(7)(L), Wis. Adm. Code, and 40 CFR 63.6(i)(14). 

(h) Any initial performance tests and other activities are also extended by this approval and shall be completed within 180 

days after the extended compliance date, as provided under ss. NR 460.05(7)(h)4. And 460.06(1)(b), Wis. Adm. Code 

and 40 CFR s. 63.6(i)(10)(iv) and 63.9984(f). 

[40 CFR, ss. 63.9982(a)(1), 63.9982(d), and 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), 

Wis. Stats.]

 20 See Approval of NESHAP Compliance Extension Request letter from K. Hart of the department to P. Spicer of Wisconsin 

Public Service Corporation dated August 13, 2013 and Addendum letter from K. Hart of the department to P Spicer of 

Wisconsin Public Service Corporation dated February 27, 2014.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 14

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate that compliance with 40 CFR, 

Part 63, Subpart UUUUU has been achieved, by conducting the 

required performance tests and other activities, no later than 180 

days after the compliance date in I.A.7.a.(5). [40 CFR s. 

63.9984(f), s. 285.63(13), Wis. Stats.]

(2) Periodic Tune-Up Requirements:

The permittee shall conduct a tune-up of the EGU burner and 

combustion controls at least each 36 calendar months, or each 48 

calendar months if neural network combustion optimization 

software is employed, as specified in 40 CFR s. 63.10021(e). [40 

CFR s. 63.9991(a)(1) and 40 CFR, Part 63, Subpart UUUUU, 

Table 3, condition 1.]

(a) Periodic tune-ups of the EGU(s) shall be performed as part of 

the demonstration of continuous compliance [40 CFR s. 

63.10000(e)]

(b) The permittee shall perform the first tune-up as part of the 

initial compliance demonstration. Notwithstanding this 

requirement, the permittee may delay the first burner inspection 

until the next scheduled unit outage provided the requirements of 

40 CFR s. 63.10005 are met. [40 CFR s. 63.10021(e)]

(c) Subsequently, an inspection of the burner shall be performed at 

least once every 36 calendar months unless the EGU employs 

neural network combustion optimization during normal operations 

in which case an inspection of the burner and combustion controls 

shall be performed at least once every 48 calendar months.

(d) Tune-ups shall consist of the following:

(i) As applicable, inspect the burner and combustion controls, 

and clean or replace any components of the burner or 

combustion controls as necessary upon initiation of the work 

practice program and at least once every required inspection 

period. Repair of a burner or combustion control component 

requiring special order parts may be scheduled as follows:

a) Burner or combustion control component parts needing 

replacement that affect the ability to optimize NOX and CO 

must be installed within 3 calendar months after the burner 

inspection,

b) Burner or combustion control component parts that do not 

affect the ability to optimize NOX and CO may be installed 

on a schedule determined by the operator;

(ii) As applicable, inspect the flame pattern and make any 

adjustments to the burner or combustion controls necessary to 

optimize the flame pattern. The adjustment should be 

consistent with the manufacturer's specifications, if available, 

or in accordance with best combustion engineering practice for 

that burner type;

{continued on next page...}

(1) Initial Performance Testing Requirements: Initial 

performance testing is required for all pollutants, to 

demonstrate compliance with the applicable emission 

limits in section I.A.7.a.

(a) The permittee may conduct the initial performance 

testing in accordance with 40 CFR s. 63.10005(h), to 

determine whether the unit(s) qualifies as a low emitting 

EGU (LEE) for one or more applicable emissions limits, 

except if the EGU is equipped with an acid gas scrubber 

and has a main stack and bypass stack exhaust 

configuration.

(b) For a qualifying LEE for Hg emissions limits, the 

permitee must conduct a 30-day performance test using 

Method 30B at least once every 12 calendar months to 

demonstrate continued LEE status.

(c) For a qualifying LEE of any other applicable 

emissions limits, the permittee must conduct a 

performance test at least once every 36 calendar months 

to demonstrate continued LEE status.

(d) If an EGU does not qualify as a LEE for total nonmercury HAP metals, individual non-mercury HAP 

metals, or filterable particulate matter (PM), the permitee 

shall demonstrate compliance through an initial 

performance test and shall monitor continuous 

performance through either use of a particulate matter 

continuous parametric monitoring system (PM CPMS), a 

PM CEMS, or, for an existing EGU, compliance 

performance testing repeated quarterly.

(i) If using PM CPMS, the permittee shall establish a 

site-specific operating limit corresponding to the 

results of the performance test demonstrating 

compliance with the pollutant with which you choose 

to comply: total non-mercury HAP metals, individual 

non-mercury HAP metals or filterable PM. The 

permittee shall use the PM CPMS to demonstrate 

continuous compliance with this operating limit. If 

electing to use a PM CPMS, the permittee shall repeat 

the performance test annually for the selected 

pollutant limit and reassess and adjust the site-specific 

operating limit in accordance with the results of the 

performance test.

(ii) The permittee may also opt to install and operate a 

particulate matter CEMS certified in accordance with 

Performance Specification 11 and Procedure 2 of 40 

CFR part 60, Appendices B and F, respectively, in 

accordance with 40 CFR s. 63.10010(i).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 15

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(iii) As applicable, observe the damper 

operations as a function of mill and/or cyclone 

loadings, cyclone and pulverizer coal feeder 

loadings, or other pulverizer and coal mill 

performance parameters, making adjustments 

and effecting repair to dampers, controls, 

mills, pulverizers, cyclones, and sensors;

(iv) As applicable, evaluate windbox pressures 

and air proportions, making adjustments and 

effecting repair to dampers, actuators, 

controls, and sensors;

(v) Inspect the system controlling the air-tofuel ratio and ensure that it is correctly 

calibrated and functioning properly. Such 

inspection may include calibrating excess O2

probes and/or sensors, adjusting overfire air 

systems, changing software parameters, and 

calibrating associated actuators and dampers 

to ensure that the systems are operated as 

designed. Any component out of calibration, 

in or near failure, or in a state that is likely to 

negate combustion optimization efforts prior 

to the next tune-up, should be corrected or 

repaired as necessary;

(vi) Optimize combustion to minimize 

generation of CO and NOX . This optimization 

should be consistent with the manufacturer's 

specifications, if available, or best combustion 

engineering practice for the applicable burner 

type. NOX optimization includes burners, 

overfire air controls, concentric firing system 

improvements, neural network or combustion 

efficiency software, control systems 

calibrations, adjusting combustion zone 

temperature profiles, and add-on controls such 

as SCR and SNCR; CO optimization includes 

burners, overfire air controls, concentric firing 

system improvements, neural network or 

combustion efficiency software, control 

systems calibrations, and adjusting 

combustion zone temperature profiles;

{continued on next page...}

(1) Initial Performance Testing Requirements: {...continued from previous page...]

(e) If an EGU does not qualify as a LEE for hydrogen chloride (HCl), the 

permittee may demonstrate initial and continuous compliance through use 

of an HCl CEMS, installed and operated in accordance with Appendix B 

to 40 CFR, Part 63, Subpart UUUUU. As an alternative to HCl CEMS, 

the permittee may demonstrate initial and continuous compliance by 

conducting an initial and periodic quarterly performance stack test for 

HCl. If an EGU uses wet or dry flue gas desulfurization technology (this 

includes limestone injection into a fluidized bed combustion unit), the 

permittee may apply a second alternative to HCl CEMS by installing and 

operating a sulfur dioxide (SO2 ) CEMS installed and operated in 

accordance with 40 CFR Part 75 to demonstrate compliance with the 

applicable SO2 emissions limit.

(f) If an EGU does not qualify as a LEE for Hg, the permittee shall 

demonstrate initial and continuous compliance through use of a Hg CEMS 

or a sorbent trap monitoring system, in accordance with Appendix A to 40 

CFR, Part 63, Subpart UUUUU.

[40 CFR s. 63.10000(c)(1), s. 285.65(13), Wis. Stats.]

(2) Subsequent Performance Tests and Tune-Ups:

(a) For EGUs using PM CPMS to monitor continuous performance with 

an applicable emission limit as provided for under 40 CFR s. 63.10000(c) 

(see condition I.A.7.c.(1)), you must conduct all applicable performance 

tests according to Table 5 to 40 CFR Part 63, Subpart UUUUU and 40 

CFR s. 63.10007 at least every year. [40 CFR s. 63.10006(a)]

(b) For EGUs meeting the LEE requirements of 40 CFR s. 63.10005(h) 

(see condition I.A.7.b.(4)(h)), the performance test shall be repeated once 

every 3 years (once every year for Hg) according to Table 5 and 40 CFR 

s. 63.10007. Should subsequent emissions testing results show the unit 

does not meet the LEE eligibility requirements, LEE status is lost. If this 

should occur:

(i) For all pollutant emission limits except for Hg, the permittee shall 

conduct emissions testing quarterly, except as otherwise provided in 40 

CFR s. 63.10021(d)(1).

(ii) For Hg, the permittee shall install, certify, maintain, and operate a 

Hg CEMS or a sorbent trap monitoring system in accordance with 

Appendix A to 40 CFR, Part 63, Subpart UUUUU, within 6 calendar 

months of losing LEE eligibility. Until the Hg CEMS or sorbent trap 

monitoring system is installed, certified, and operating, the permittee 

shall conduct Hg emissions testing quarterly, except as otherwise 

provided in 40 CFR s. 63.10021(d)(1). You must have 3 calendar years 

of testing and CEMS or sorbent trap monitoring system data that 

satisfy the LEE emissions criteria to reestablish LEE status.

[40 CFR s. 63.10006(b)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 16

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) , s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(vii) While operating at full load or the predominantly 

operated load, measure the concentration in the 

effluent stream of CO and NOX in ppm, by volume, 

and oxygen in volume percent, before and after the 

tune-up adjustments are made (measurements may be 

either on a dry or wet basis, as long as it is the same 

basis before and after the adjustments are made). You 

may use portable CO, NOX and O2 monitors for this 

measurement. EGU's employing neural network 

optimization systems need only provide a single preand post-tune-up value rather than continual values 

before and after each optimization adjustment made 

by the system;

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the 

information in paragraphs (d)(i) through (ix) of this 

condition, including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume 

percent, measured before and after an adjustment of 

the EGU combustion systems;

b) A description of any corrective actions taken as a 

part of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if 

the unit was physically and legally capable of using 

more than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tuneups as follows:

a) If the first required tune-up is performed as part of 

the initial compliance demonstration, report the date 

of the tune-up in hard copy (as specified in 40 CFR 

s. 63.10030) and electronically (as specified in 40 

CFR s. 63.10031). Report the date of each 

subsequent tune-up electronically (as specified in 40 

CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the 

initial compliance demonstration, but is postponed 

until the next unit outage, report the date of that tuneup and all subsequent tune-ups electronically, in 

accordance with 40 CFR s. 63.10031.

[40 CFR s. 63.10021(e), s. 285.65(13), Wis. Stats.]

(2) Subsequent Performance Tests and Tune-Ups:

{... continued from previous page...}

(c) Except where paragraphs (a) or (b) of this condition apply, or

where the permittee installs, certifies, and operates a PM CEMS to 

demonstrate compliance with a filterable PM emissions limit, the 

permittee shall conduct all applicable periodic emissions tests for 

filterable PM, individual, or total HAP metals emissions according 

to Table 5 to Subpart UUUUU, 40 CFR s. 63.10007, and s. 

63.10000(c), except as otherwise provided in s. 63.10021(d)(1).

(d) Except where paragraph (b) of this section applies, for coalfired EGUs that do not use either an HCl CEMS to monitor 

compliance with the HCl limit or an SO2 CEMS to monitor 

compliance with the alternate equivalent SO2 emission limit, the 

permittee shall conduct all applicable periodic HCl emissions tests 

according to Table 5 to Subpart UUUUU and 40 CFR s. 63.10007 

at least quarterly, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). [40 CFR s. 63.10006(d)]

(e) {reserved}

(f) Unless following the requirements listed in paragraphs (g) and 

(h) of this condition, subsequent performance tests shall be 

conducted as follows:

(i) performance tests required at least every 3 calendar years 

must be completed within 35 to 37 calendar months after the 

previous performance test; 

(ii) performance tests required at least every year must be 

completed within 11 to 13 calendar months after the previous 

performance test; and 

(iii) performance tests required at least quarterly must be 

completed within 80 to 100 calendar days after the previous 

performance test, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). 

[40 CFR s. 63.10006(f)]

(g) If electing to demonstrate compliance using emissions 

averaging under 40 CFR s. 63.10009, the permittee shall continue 

to conduct performance stack tests at the appropriate frequency 

given in section (c) through (f) of this section. [40 CFR s. 

63.10006(g)]

(h) If a performance test on a non-mercury LEE shows emissions 

in excess of 50 percent of the emission limit and if the permittee 

chooses to reapply for LEE status, the permittee shall conduct 

performance tests at the appropriate frequency given in paragraphs 

(c) through (e) of this condition for that pollutant until all 

performance tests over a consecutive 3-year period show 

compliance with the LEE criteria. [40 CFR s. 63.10006(h)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 17

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) , s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) Monitoring During Startup and Shutdown:

(a) The permittee shall operate all CMS during 

startup and shutdown. 

(b) Startup means either the first-ever firing of fuel 

in a boiler for the purpose of producing electricity, 

or the firing of fuel in a boiler after a shutdown 

event for any purpose. 

(i) Startup ends when any of the steam from the 

boiler is used to generate electricity for sale over 

the grid or for any other purpose (including on 

site use). 

(ii) For startup of a unit, clean fuels shall be used, 

either natural gas or distillate oil or a combination 

of clean fuels for ignition. 

(iii) Once the EGU is converted to firing coal, all 

of the applicable control technologies except dry 

scrubber and SCR shall be engaged. 

(iv) Any dry scrubber and SCR systems, if 

present, shall be started appropriately to comply 

with relevant standards applicable during normal 

operation. 

(c) Shutdown means the cessation of operation of a 

boiler for any purpose. 

(i) Shutdown begins either when none of the 

steam from the boiler is used to generate 

electricity for sale over the grid or for any other 

purpose (including on-site use) or at the point of 

no fuel being fired in the boiler. 

(ii) Shutdown ends when there is both no 

electricity being generated and no fuel being fired 

in the boiler.

(iii) During shutdown, all applicable control 

technologies shall be operated, while firing coal. 

(d) The EGU(s) shall comply with all applicable 

emissions limits at all times except for periods that 

meet the definitions of startup and shutdown in 40 

CFR Part 63, Subpart UUUUU. 

(e) The permittee shall keep records during periods 

of startup and shutdown. 

(f) The permittee shall provide reports concerning 

activities and periods of startup and shutdown, as 

specified in 40 CFR ss. 63.10011(g) and 

63.10021(h) and (i).

[40 CFR s. 63.9991(a)(1) and 40 CFR, Part 63, 

Subpart UUUUU, Table 3, conditions 3 and 4., s. 

285.65(13), Wis. Stats.]

(2) Subsequent Performance Tests and Tune-Ups:

{... continued from previous page...}

(i) The permittee shall conduct performance tune-ups according to 40 

CFR s. 63.10021(e), as follows:

(i) For EGUs not employing neural network combustion optimization 

during normal operation, each performance tune-up specified in 40 

CFR s. 63.10021(e) must be no more than 36 calendar months after 

the previous performance tune-up.

(ii) For EGUs employing neural network combustion optimization 

systems during normal operation, each performance tune-up specified 

in 40 CFR s. 63.10021(e) must be no more than 48 calendar months 

after the previous performance tune-up.

[40 CFR s. 63.10006(i)]

(j) The permittee shall report the results of performance tests and 

performance tune-ups within 60 days after the completion of the 

performance tests and performance tune-ups. The reports for all 

subsequent performance tests must include all applicable information 

required in 40 CFR s. 63.10031. [40 CFR s. 63.10006(j)]

[40 CFR s. 63.10006, s. 285.65(13), Wis. Stats.]

(3) Performance Tests – Methods and Other Procedures:

(a) Except as otherwise provided in this condition, the permittee shall 

conduct all required performance tests according to 40 CFR s. 63.7(d), 

(e), (f), and (h). The permittee shall also develop a site-specific test plan 

according to the requirements in 40 CFR s. 63.7(c).

(i) If using CEMS (Hg, HCl, SO2 , or other) to determine compliance 

with a 30-boiler operating day rolling average emission limit, you 

must collect data for all nonexempt unit operating conditions (see 40 

CFR s. 63.10011(g) and Table 3 to 40 CFR, Part 63, Subpart 

UUUUU).

(ii) If conducting performance testing with test methods in lieu of 

continuous monitoring, operate the unit at maximum normal 

operating load conditions during each periodic (e.g., quarterly) 

performance test. Maximum normal operating load will be generally 

between 90 and 110 percent of design capacity but should be 

representative of site specific normal operations during each test run.

(iii) For establishing operating limits with particulate matter 

continuous parametric monitoring system (PM CPMS) to 

demonstrate compliance with a PM or non Hg metals emissions 

limit, operate the unit at maximum normal operating load conditions 

during the performance test period. Maximum normal operating load 

will be generally between 90 and 110 percent of design capacity but 

should be representative of site specific normal operations during 

each test run.

[40 CFR s. 63.10007(a)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 18

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(4) Operating Limits: The permittee shall meet the 

applicable operating limit in Table 4 to Subpart 

UUUUU as follows:

(a) If demonstrating compliance using a PM CPMS, 

maintain the 30-boiler operating day rolling average 

PM CPMS output at or below the highest 1-hour 

average measured during the most recent performance 

test demonstrating compliance with the filterable PM, 

total non-mercury HAP metals (total HAP metals, for 

liquid oil-fired units), or individual non-mercury HAP 

metals (individual HAP metals including Hg, for 

liquid oil-fired units) emissions limitation(s).

(b) The operating limits apply at all times except 

during periods of startup and shutdown; however, the 

permittee is required to meet the work practice 

requirements in conditions I.A.7.b. (3) during periods 

of startup or shutdown. 

[40 CFR s. 63.9991(a)(2), s. 63.10000(a), and Table 4 

to 40 CFR, Part 63, Subpart UUUUU, s. 285.65(13), 

Wis. Stats.]

(5) At all times the permittee shall operate and 

maintain B01 and B02, including the associated air 

pollution control equipment and monitoring 

equipment, in a manner consistent with safety and 

good air pollution control practices for minimizing 

emissions. Determination of whether such operation 

and maintenance procedures are being used will be 

based on information which may include, but is not 

limited to, monitoring results, review of operation and 

maintenance procedures, review of operation and 

maintenance records, and inspection of the source. 

[40 CFR s. 63.10000(b), s. 285.65(13), Wis. Stats.]

(6) Initial Compliance Requirements: 

(a) General Requirements: For each affected EGU, 

initial compliance with each applicable emission limit 

in section I.A.7.a. shall be demonstrated with 

performance testing. Where two emissions limits are 

specified for a particular pollutant (e.g., a heat inputbased limit in lb/MMBtu and an electrical outputbased limit in lb/MWh), compliance may be 

demonstrated with either emission limit. 

{continued on next page...}

(3) Performance Tests – Methods and Other Procedures:

{...continued from previous page...}

(b) The permittee shall conduct each performance test (including 

traditional 3-run stack tests, 30-boiler operating day tests based on 

CEMS data (or sorbent trap monitoring system data), and 30-boiler 

operating day Hg emission tests for LEE qualification) according to 

the requirements in Table 5 to 40 CFR, Part 63, Subpart UUUUU. 

[40 CFR s. 63.10007(b)]

(c) If choosing the filterable PM method to comply with the PM

emission limit and demonstrate continuous performance using a PM

CPMS as provided for in 40 CFR s. 63.10000(c), the permittee shall 

also establish an operating limit according to 40 CFR s. 63.10011(b), 

s. 63.10023, and Tables 4 and 6 to Subpart UUUUU. Should the 

permittee desire to have operating limits that correspond to loads 

other than maximum normal operating load, the permittee shall 

conduct testing at those other loads to determine the additional 

operating limits. [40 CFR s. 63.10007(c)]

(d) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, where the concept of 

test runs does not apply, the permittee shall conduct a minimum of 

three separate test runs for each performance test, as specified in 40 

CFR s. 63.7(e)(3). Each test run shall comply with the minimum 

applicable sampling time or volume specified in Table 1 or 2 to 

Subpart UUUUU. Sections 63.10005(d) and (h) of 40 CFR (see 

conditions I.A.7.b.(6)(d) and (h)), respectively, provide special 

instructions for conducting performance tests based on CEMS or 

sorbent trap monitoring systems, and for conducting emission tests for 

LEE qualification. [40 CFR s. 63.10007(d)]

(e) To use the results of performance testing to determine compliance 

with the applicable emission limits in I.A.7.a., proceed as follows:

(i) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, if measurement 

results for any pollutant are reported as below the method 

detection level (e.g., laboratory analytical results for one or more 

sample components are below the method defined analytical 

detection level), the permittee shall use the method detection level 

as the measured emissions level for that pollutant in calculating 

compliance. The measured result for a multiple component 

analysis (e.g., analytical values for multiple Method 29 fractions 

both for individual HAP metals and for total HAP metals) may 

include a combination of method detection level data and 

analytical data reported above the method detection level.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 19

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(a) {...continued from previous page...}

One or more of the following activities may be 

required in conjunction with performance testing, as 

appropriate: collection of hourly electrical load data 

(megawatts); establishment of operating limits 

according to 40 CFR s. 63.10011 and 40 CFR Part 

63, Subpart UUUUU, Tables 4 and 7; and CMS 

performance evaluations. In all cases, you must 

demonstrate initial compliance no later than the 

applicable date in paragraph (f) of 40 CFR s. 

63.10005 for tune-up work practices for existing 

EGUs, in 40 CFR s. 63.9984. 

(i) To demonstrate initial compliance with an 

applicable emissions limit in section I.A.7.a. of this 

permit using stack testing, the initial performance 

test generally consists of three runs at specified 

process operating conditions using approved 

methods. If required to establish operating limits 

(see paragraph (d) of 40 CFR s. 63.10005 and 

Table 4 to 40 CFR Part 63, Subpart UUUUU), the 

permittee shall collect all applicable parametric 

data during the performance test period. Also, if 

you choose to comply with an electrical outputbased emission limit, you must collect hourly 

electrical load data during the test period.

(ii) To demonstrate initial compliance using either 

a CMS that measures HAP concentrations directly 

(i.e., an Hg, HCl, or HF CEMS, or a sorbent trap 

monitoring system) or an SO2 or PM CEMS, the 

initial performance test consists of 30 boiler 

operating days of data collected by the initial 

compliance demonstration date specified in 40 

CFR s. 63.10005 with the certified monitoring 

system.

a) The 30-boiler operating day CMS 

performance test must demonstrate compliance 

with the applicable Hg, HCl, HF, PM, or SO2

emissions limit in Table 1 or 2 to this subpart.

b) If you choose to comply with an electrical 

output-based emission limit, you must collect 

hourly electrical load data during the 

performance test period.

[40 CFR s. 63.10005(a)]

{continued on next page...}

(3) Performance Tests – Methods and Other Procedures:

(e) {...continued from previous page...}

(ii) If the limits are expressed in lb/MMBtu or lb/TBtu, the 

permittee shall use the F-factor methodology and equations in 

sections 12.2 and 12.3 of EPA Method 19 in Appendix A-7 to Part 

60 of 40 CFR. In cases where an appropriate F-factor is not listed in 

Table 19-2 of Method 19, you may use F-factors from Table 1 in 

section 3.3.5 of Appendix F to Part 75 of 40 CFR, or F-factors 

derived using the procedures in section 3.3.6 of Appendix to Part 75 

of 40 CFR. Use the following factors to convert the pollutant 

concentrations measured during the initial performance tests to 

units of lb/scf, for use in the applicable Method 19 equations:

a) Multiply SO2 ppm by 1.66 × 10−7 ;

b) Multiply HCl ppm by 9.43 × 10−8 ;

c) Multiply HF ppm by 5.18 × 10−8 ;

d) Multiply HAP metals concentrations (mg/dscm) by 6.24 × 10−8

; and

e) Multiply Hg concentrations (μg/scm) by 6.24 × 10−11.

(iii) To determine compliance with emission limits expressed in 

lb/MWh or lb/GWh, the permittee shall first calculate the pollutant 

mass emission rate during the performance test, in units of lb/h. For 

Hg, if a CEMS or sorbent trap monitoring system is used, use 

Equation A-2 or A-3 in Appendix A to 40 CFR, Part 63, Subpart 

UUUUU (as applicable). In all other cases, use an equation that has 

the general form of Equation A-2 or A-3, replacing the value of K 

with 1.66 × 10−7 lb/scf-ppm for SO2 , 9.43 × 10−8 lb/scf-ppm for 

HCl (if an HCl CEMS is used), or 6.24 × 10−8 lb-scm/mg-scf for 

HAP metals and for HCl (when performance stack testing is used), 

and defining Ch as the average SO2 or HCl concentration in ppm, or 

the average HAP metals concentration in mg/dscm. This calculation 

requires stack gas volumetric flow rate (scfh) and (in some cases) 

moisture content data (see 40 CFR ss. 63.10005(h)(3) and 

63.10010). Then, if the applicable emission limit is in units of 

lb/GWh, use Equation A-4 in Appendix A to Subpart UUUUU to 

calculate the pollutant emission rate in lb/GWh. In this calculation, 

define (M)h as the calculated pollutant mass emission rate for the 

performance test (lb/h), and define (MW)h as the average electrical 

load during the performance test (megawatts). If the applicable 

emission limit is in lb/MWh rather than lb/GWh, omit the 103 term 

from Equation A-4 to determine the pollutant emission rate in 

lb/MWh.

[40 CFR s. 63.10007(e)]

(f) Upon request, the permittee shall make available to the department 

such records as may be necessary to determine whether the 

performance tests have been done according to the requirements of this 

section. [40 CFR s. 63.10007(f)]

[40 CFR s. 63.10007, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 20

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) , s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(b) Performance testing requirements: If using 

performance testing to demonstrate initial 

compliance with the applicable emissions limits in 

section I.A.7.a. of this permit, the permittee shall 

conduct the tests according to 40 CFR s. 63.10007 

and Table 5 to 40 CFR Part 63, Subpart UUUUU. 

For the purposes of the initial compliance 

demonstration, test data and results from a 

performance test conducted prior to the compliance 

date in I.A.7.a.(5), may be used provided that the 

following conditions are fully met:

(i) For a performance test based on stack test data, 

the test was conducted no more than 12 calendar 

months prior to the compliance date in I.A.7.a.(5);

(ii) For a performance test based on data from a 

certified CEMS or sorbent trap monitoring system, 

the test consists of all valid CMS data recorded in 

the 30 boiler operating days immediately preceding 

the compliance date in I.A.7.a.(5);

(iii) The performance test was conducted in 

accordance with all applicable requirements in 40 

CFR s. 63.10007 and Table 5 to 40 CFR Part 63 

Subpart UUUUU;

(iv) A record of all parameters needed to convert 

pollutant concentrations to units of the emission 

standard (e.g., stack flow rate, diluent gas 

concentrations, hourly electrical loads) is available 

for the entire performance test period; and

(v) For each performance test based on stack test 

data, the permittee certifies, and keeps 

documentation demonstrating, that the EGU 

configuration, control devices, and fuel(s) have 

remained consistent with conditions since the prior 

performance test was conducted.

[40 CFR s. 63.10005(b)]

(c) Operating limits: In accordance with 40 CFR s. 

63.10010 and Table 4 to 40 CFR Part 63, Subpart 

UUUUU, the permitee may be required to establish 

operating limits using PM CPMS as part of the initial 

compliance demonstration. [40 CFR s. 63.10005(c)] 

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(a) If demonstrating compliance with any applicable emissions limit 

through use of a continuous monitoring system (CMS), where a CMS 

includes a continuous parameter monitoring system (CPMS) as well as 

a continuous emissions monitoring system (CEMS), the permitee shall 

develop a site-specific monitoring plan and submit this site-specific 

monitoring plan, if requested, at least 60 days before the initial 

performance evaluation (where applicable) of your CMS. The 

requirement to develop and submit a site-specific monitoring plan does 

not apply to affected sources with existing monitoring plans that apply 

to CEMS and CPMS prepared under Appendix B to 40 CFR Part 60 or 

Part 75, and that meet the requirements of 40 CFR s. 63.10010. (The 

permittee may use the process described in § 63.8(f)(4), to request 

approval of monitoring system quality assurance and quality control 

procedures alternative to those specified in this condition and, if 

approved, include those in the site-specific monitoring plan.) The 

monitoring plan shall address the provisions in (b) through (e) below.

(b) The site-specific monitoring plan shall include the information 

specified in condition (e), below. Alternatively, the requirements of 

condition (e) are considered to be met for a particular CMS or sorbent 

trap monitoring system if:

(i) The CMS or sorbent trap monitoring system is installed, 

certified, maintained, operated, and quality-assured either according 

to 40 CFR, Part 75, or Appendix A or B to 40 CFR, Part 63, 

Subpart UUUUU; and

(ii) The recordkeeping and reporting requirements of 40 CFR, Part 

75, or Appendix A or B to 40 CFR, Part 63, Subpart UUUUU, that 

pertain to the CMS are met.

(c) If requested by the department, the permittee shall submit the 

monitoring plan (or relevant portion of the plan) at least 60 days before 

the initial performance evaluation of a particular CMS, except where 

the CMS has already undergone a performance evaluation that meets 

the requirements of 40 CFR s. 63.10010 (e.g., if the CMS was 

previously certified under another program).

(d) The permittee shall operate and maintain the CMS according to the 

site-specific monitoring plan.

(e) The provisions of the site-specific monitoring plan shall address the 

following items:

(i) Installation of the CMS or sorbent trap monitoring system 

sampling probe or other interface at a measurement location relative 

to each affected process unit such that the measurement is 

representative of control of the exhaust emissions (e.g., on or 

downstream of the last control device). See 40 CFR s. 63.10010(a) 

for further details. For PM CPMS installations, follow the 

procedures in 40 CFR s. 63.10010(h).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 21

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) , s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(d) CMS requirement: If required to (or electing to) 

demonstrate initial compliance using a continuous 

monitoring system, the CMS must pass a performance 

evaluation prior to the initial compliance demonstration. If 

a CMS has been previously certified under another state or 

federal program and is continuing to meet the on-going 

quality-assurance (QA) requirements of that program, 

then, provided that the certification and QA provisions of 

that program meet the applicable requirements of 40 CFR 

ss. 63.10010(b) through (h), an additional performance 

evaluation of the CMS is not required.

(i) The permittee may demonstrate initial compliance 

with the applicable SO2 or HCl, emissions limit in 

condition I.A.7.a.(2) through use of an SO2 or HCl 

CEMS installed and operated in accordance with 40 

CFR, Part 75 or 40 CFR, Part 63, Subpart UUUUU, 

Appendix B, as applicable. The permittee may 

demonstrate compliance with a filterable PM emission 

limit in condition I.A.7.a.(1) (a) through use of a PM 

CEMS installed, certified, and operated in accordance 

with 40 CFR s. 63.10010(i). Initial compliance is 

achieved if the arithmetic average of 30-boiler operating 

days of quality-assured CEMS data, expressed in units 

of the standard (see 40 CFR s. 63.10007(e)), meets the 

applicable SO2, PM, or HCl emissions limit in section 

I.A.7.a. of this permit. Use Equation 19-19 of Method 

19 in Appendix A-7 to 40 CFR, Part 60 to calculate the 

30-boiler operating day average emissions rate. (NOTE:

For this calculation, the term Ehj in Equation 19-19 must 

be in the same units of measure as the applicable HCl 

emission limit in condition I.A.7.a.(2) (a).

(ii) When demonstrating compliance with the applicable 

emission limits for total non-mercury HAP metals, 

individual non-mercury HAP metals, total HAP metals, 

individual HAP metals, or filterable PM in section 

I.A.7.a. of this permit using initial performance testing 

and continuous monitoring with PM CPMS, the 

permittee shall:

a) Demonstrate initial compliance no later than 180 

days after the compliance date in I.A.7.a.(5);

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(e) {...continued from previous page...}

(ii) Performance and equipment specifications for the sample 

interface, the pollutant concentration or parametric signal 

analyzer, and the data collection and reduction systems.

(iii) Schedule for conducting initial and periodic performance 

evaluations.

(iv) Performance evaluation procedures and acceptance 

criteria (e.g., calibrations), including the quality control 

program in accordance with the general requirements of 40 

CFR s. 63.8(d).

(v) On-going operation and maintenance procedures, in 

accordance with the general requirements of 40 CFR 

ss. 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii).

(vi) Conditions that define a CMS that is out of control 

consistent with 40 CFR s. 63.8(c)(7)(i) and for responding to 

out of control periods consistent with 40 CFR 

ss. 63.8(c)(7)(ii) and (c)(8).

(vii) On-going recordkeeping and reporting procedures, in 

accordance with the general requirements of 40 CFR 

ss. 63.10(c), (e)(1), and (e)(2)(i), or as specifically required 

under 40 CFR, Part 63, Subpart UUUUU.

[40 CFR s. 63.10000(d), s. 285.65(13), Wis. Stats.]

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(a) For the CEMS, PM CPMS, and sorbent trap monitoring 

systems used to provide data under 40 CFR, Part 63, Subpart 

UUUUU, the permittee shall comply with the continuous 

monitoring system installation requirements for the appropriate 

exhaust configurations as required by 40 CFR s. 63.10010(a). 

(Exhaust configurations include but are not limited individual 

stacks, a common stack configuration or a main stack plus a 

bypass stack.) [40 CFR s. 63.10010(a)]

(b) If using an oxygen (O2 ) or carbon dioxide (CO2 ) CEMS to 

convert measured pollutant concentrations to the units of the 

applicable emissions limit, the O2 or CO2 concentrations shall be 

monitored at a location that represents emissions to the 

atmosphere, i.e., at the outlet of the EGU, downstream of all 

emission control devices. The permittee shall install, certify, 

maintain, and operate the CEMS according to Part 75 of 40 CFR. 

Use only quality-assured O2 or CO2 data in the emissions 

calculations; do not use Part 75 substitute data values. [40 CFR 

s. 63.10010(b)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 22

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) , s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats. ]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(d)(ii) {...continued from previous page...}

b) Demonstrate continuous compliance with the 

PM CPMS site-specific operating limit that 

corresponding to the results of the performance test 

demonstrating compliance with the emission limit 

with which the permittee has chosen to comply; 

and

c) Repeat the performance test annually for the 

selected pollutant emissions limit and reassess and 

adjust the site-specific operating limit in 

accordance with the results of the performance test.

(iii) When demonstrating compliance with the Hg 

emission limit in I.A.7.a.(3) using Hg CEMS or 

sorbent trap monitoring systems, initial compliance 

shall be demonstrated no later than 180 days after the 

compliance date in I.A.7.a.(5). Initial compliance is 

achieved if the arithmetic average of 30-boiler 

operating days of quality-assured CEMS (or sorbent 

trap monitoring system) data, expressed in units of 

the standard (see section 6.2 of Appendix A to 40 

CFR, Part 63, Subpart UUUUU), meets the 

applicable Hg emission limit in I.A.7.a.(3).

[40 CFR s. 63.10005(d)]

(e) Tune-ups: As part of the initial compliance 

demonstration, the permittee shall conduct a 

performance tune-up of each EGU according to 40 

CFR s. 63.10021(e). [40 CFR s. 63.10005(e)]

(f) For existing affected sources a tune-up may occur 

prior to April 16, 2012, so that existing sources without 

neural networks have up to 42 calendar months (3 

years from promulgation plus 180 days) or, in the case 

of units employing neural network combustion 

controls, up to 54 calendar months (48 months from 

promulgation plus 180 days) after the date that is 

specified for your source in 40 CFR s. 63.9984 and 

according to the applicable provisions in s. 63.7(a)(2) 

as cited in Table 9 to Subpart UUUUU to demonstrate 

compliance with this requirement. If a tune-up occurs 

prior to such date, the source must maintain adequate 

records to show that the tune-up met the requirements 

of this standard. [40 CFR s. 63.10005(f)]

(g) {reserved}

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

{...continued from previous page...}

(c) If required to use a stack gas flow rate monitor, either for routine 

operation of a sorbent trap monitoring system or to convert pollutant 

concentrations to units of an electrical output-based emission 

standard in Table 1 or 2 to Subpart UUUUU, the permittee shall 

install, certify, operate, and maintain the monitoring system and 

conduct on-going quality-assurance testing of the system according 

to Part 75 of 40 CFR. Use only unadjusted, quality-assured flow rate 

data in the emissions calculations. Do not apply bias adjustment 

factors to the flow rate data and do not use substitute flow rate data 

in the calculations. [40 CFR s.63.10010(c)]

(d) If required to make corrections for stack gas moisture content 

when converting pollutant concentrations to the units of an emission 

standard in Table 1 of 2 to Subpart UUUUU, the permittee shall 

install, certify, operate, and maintain a moisture monitoring system 

in accordance with Part 75 of 40 CFR. Alternatively, for coal-fired 

units, appropriate fuel-specific default moisture values from 40 CFR 

s. 75.11(b) may be used to estimate the moisture content of the stack 

gas. If a moisture monitoring system is installed and operated, do not 

use substitute moisture data in the emissions calculations. [40 CFR 

s. 63.1001(d)]

(e) If using an HCl CEMS, the permittee shall install, certify, 

operate, maintain, and quality-assure the data from the monitoring 

system in accordance with Appendix B to Subpart UUUUU. 

Calculate and record a 30-boiler operating day rolling average HCl 

emission rate in the units of the standard, updated after each new 

boiler operating day. Each 30-boiler operating day rolling average 

emission rate is the average of all the valid hourly HCl emission 

rates in the preceding 30 boiler operating days (see section 9.4 of 

Appendix B to Subpart UUUUU). [40 CFR s. 63.10010(e)]

(f)(i) If using an SO2 CEMS, the permittee shall install the monitor 

at the outlet of the EGU, downstream of all emission control 

devices, and shall certify, operate, and maintain the CEMS 

according to Part 75 of 40 CFR.

(ii) For on-going QA, the SO2 CEMS shall meet the applicable 

daily, quarterly, and semiannual or annual requirements in 

sections 2.1 through 2.3 of Appendix B to Part 75 of 40 CFR, 

with the following addition: The permittee shall perform the 

linearity checks required in section 2.2 of Appendix B to Part 75 

of 40 CFR if the SO2 CEMS has a span value of 30 ppm or less.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 23

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(h) Low emitting EGUs: The provisions of this 

paragraph (h) apply to all pollutants with 

emissions limits from existing EGUs. This 

compliance option may not be pursued, if for 

EGUs equipped with an acid gas scrubber and with 

a main stack and bypass stack exhaust 

configuration.

(i) An EGU may qualify for low emitting EGU 

(LEE) status for Hg, HCl, filterable PM, total 

non-Hg HAP metals, or individual non-Hg HAP 

metals if performance test data is collected that 

meets the requirements of this paragraph (h), and 

if those data demonstrate:

a) For all pollutants except Hg, performance 

test emissions results less than 50 percent of 

the applicable emissions limits in I.A.7.a. for 

all required testing for 3 consecutive years; or

b) For Hg emissions, either: 

1) Average emissions less than 10 percent 

of the applicable Hg emissions limit in 

I.A.7.a.(3) (expressed either in units of 

lb/TBtu or lb/GWh); or 

2) Potential Hg mass emissions of 29.0 or 

fewer pounds per year and compliance with 

the applicable Hg emission limit in 

I.A.7.a.(3) (expressed either in units of 

lb/TBtu or lb/GWh).

(ii) For all pollutants except Hg, the permittee 

shall conduct all required performance tests 

described in 40 CFR s. 63.10007 to demonstrate 

that a unit qualifies for LEE status.

a) When conducting emissions testing to 

demonstrate LEE status, the permittee shall 

increase the minimum sample volume 

specified in Table 1 or 2 to 40 CFR, Part 63, 

Subpart UUUUU nominally by a factor of 

two.

b) Follow the instructions in 40 CFR 

s. 63.10007(e) and Table 5 to Subpart 

UUUUU to convert the test data to the units of 

the applicable standard.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(f) {...continued from previous page...}

(iii) Calculate and record a 30-boiler operating day rolling average 

SO2 emission rate in the units of the standard, updated after each new 

boiler operating day. Each 30-boiler operating day rolling average 

emission rate is the average of all of the valid SO2 emission rates in 

the preceding 30 boiler operating days.

(iv) Use only unadjusted, quality-assured SO2 concentration values in 

the emissions calculations; do not apply bias adjustment factors to the 

Part 75 SO2 data and do not use Part 75 substitute data values.

[40 CFR s. 63.10010(f)]

(g) If using a Hg CEMS or a sorbent trap monitoring system, the 

permittee shall install, certify, operate, maintain and quality-assure the 

data from the monitoring system in accordance with Appendix A to 

Subpart UUUUU. The permittee shall calculate and record a 30- (or, if 

alternate emissions averaging is used, 90-) boiler operating day rolling 

average Hg emission rate, in units of the standard, updated after each 

new boiler operating day. Each 30- (or, if alternate emissions averaging 

is used, 90-) boiler operating day rolling average emission rate, 

calculated according to section 6.2 of Appendix A to Subpart UUUUU, 

is the average of all of the valid hourly Hg emission rates in the 

preceding 30- (or, if alternate emissions averaging is used, a 90-) boiler 

operating days. Section 7.1.4.3 of Appendix A to Subpart UUUUU 

explains how to reduce sorbent trap monitoring system data to an hourly 

basis. [40 CFR s. 63.10010(g)]

(h) If using a PM CPMS to demonstrate continuous compliance with an 

operating limit, the permittee shall install, calibrate, maintain, and 

operate the PM CPMS and record the output of the system as follows:

(i) Install, calibrate, operate, and maintain the PM CPMS according to 

the procedures in the approved site-specific monitoring plan 

developed in accordance with 40 CFR s. 63.10000(d), and meet the 

requirements the following:

a) The operating principle of the PM CPMS shall be based on instack or extractive light scatter, light scintillation, beta 

attenuation, or mass accumulation detection of the exhaust gas or 

representative sample. The reportable measurement output from 

the PM CPMS may be expressed as milliamps, stack 

concentration, or other raw data signal.

b) The PM CPMS shall have a cycle time ( i.e. , period required 

to complete sampling, measurement, and reporting for each 

measurement) no longer than 60 minutes.

c) The PM CPMS shall be capable, at a minimum, of detecting 

and responding to particulate matter concentrations of 0.5 

mg/acm.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 24

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h) {...continued from previous page...}

(iii) For Hg, the permittee shall conduct a 30-

boiler operating day performance test using 

Method 30B in Appendix A-8 to 40 CFR Part 60 

to determine whether a unit qualifies for LEE 

status. Locate the Method 30B sampling probe 

tip at a point within the 10 percent centroidal 

area of the duct at a location that meets Method 

1 in Appendix A-1 to 40 CFR Part 60 and 

conduct at least three nominally equal length test 

runs over the 30-boiler operating day test period. 

Collect Hg emissions data continuously over the 

entire test period (except when changing sorbent 

traps or performing required reference method 

QA procedures), under all process operating 

conditions. The permittee may use a pair of 

sorbent traps to sample the stack gas for no more 

than 10 days.

a) Depending on whether LEE status for Hg is 

assessed in terms of the lb/TBtu or lb/GWh 

emission limit in I.A.7.a.(3) or in terms of the 

annual Hg mass emissions limit of 29.0 lb/year, 

the permittee shall collect some or all of the 

following data during the 30-boiler operating 

day test period (see paragraph (h)(iii)c) of this 

condition):

1) Diluent gas (CO2 or O2 ) data, using either 

Method 3A in Appendix A-3 to Part 60 of 40 

CFR or a diluent gas monitor that has been 

certified according to Part 75 of 40 CFR.

2) Stack gas flow rate data, using either 

Method 2, 2F, or 2G in Appendices A-1 and 

A-2 to Part 60 of 40 CFR, or a flow rate 

monitor that has been certified according to 

Part 75 of 40 CFR.

3) Stack gas moisture content data, using 

either Method 4 in Appendix A-1 to Part 60 

of 40 CFR, or a moisture monitoring system 

that has been certified according to Part 75 of 

40 CFR. Alternatively, an appropriate fuelspecific default moisture value from 40 CFR 

s. 75.11(b) may be used in the calculations.

4) Hourly electrical load data (megawatts), 

from facility records.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(h) {...continued from previous page...}

(ii) Complete the initial performance evaluation no later than October 

13, 2015 or 180 days after the compliance date in I.A.7.a.(5), 

whichever is later.

(iii) Collect PM CPMS hourly average output data for all boiler 

operating hours except as indicated in paragraph (h)(v) of this 

condition. Express the PM CPMS output as milliamps, PM 

concentration, or other raw data signal value.

(iv) Calculate the arithmetic 30-boiler operating day rolling average of 

all of the hourly average PM CPMS output collected during all 

nonexempt boiler operating hours data (e.g., milliamps, PM 

concentration, raw data signal).

(v) The permittee shall collect data using the PM CPMS at all times the 

process unit is operating and at the intervals specified in paragraph 

(h)(i)b) of this condition, except for periods of monitoring system 

malfunctions, repairs associated with monitoring system malfunctions, 

required monitoring system quality assurance or quality control 

activities (including, as applicable, calibration checks and required zero 

and span adjustments), and any scheduled maintenance as defined in 

the site-specific monitoring plan.

(vi) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with your operating limit 

except:

a) Any data collected during monitoring system malfunctions, repairs 

associated with monitoring system malfunctions, or required 

monitoring system quality assurance or quality control activities 

conducted during monitoring system malfunctions are not used in 

calculations (report any such periods in your annual deviation report);

b) Any data collected during periods when the monitoring system is 

out of control as specified in the site-specific monitoring plan, repairs 

associated with periods when the monitoring system is out of control, 

or required monitoring system quality assurance or quality control 

activities conducted during out-of-control periods are not used in 

calculations (report emissions or operating levels and report any such 

periods in the annual deviation report);

c) Any data recorded during periods of startup or shutdown.

(vii) The permittee shall record and make available upon request 

results of PM CPMS system performance audits, as well as the dates 

and duration of periods from when the PM CPMS is out of control until 

completion of the corrective actions necessary to return the PM CPMS 

to operation consistent with the site-specific monitoring plan.

[40 CFR s.63.10010(h)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 25

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii) {...continued from previous page...}

b) If a CEMS is used to measure CO2 (or O2 )

concentration, and/or flow rate, and/or moisture, 

record hourly average values of each parameter 

throughout the 30-boiler operating day test period. If 

opting to use EPA reference methods rather than 

CEMS for any parameter, the permittee shall perform 

at least one representative test run on each operating 

day of the test period, using the applicable reference 

method.

c) Calculate the average Hg concentration, in μg/m3

(dry basis), for the 30-boiler operating day 

performance test, as the arithmetic average of all 

Method 30B sorbent trap results. Also calculate, as 

applicable, the average values of CO2 or O2

concentration, stack gas flow rate, stack gas moisture 

content, and electrical load for the test period. Then:

1) To express the test results in units of lb/TBtu, 

follow the procedures in 40 CFR s. 63.10007(e). 

Use the average Hg concentration and diluent gas 

values in the calculations.

2) To express the test results in units of lb/GWh, use 

Equations A-3 and A-4 in section 6.2.2 of Appendix 

A to Subpart UUUUU, replacing the hourly values 

“Ch ”, “Qh ”, “Bws ” and “(MW)h ” with the average 

values of these parameters from the performance 

test.

3) To calculate pounds of Hg per year, use one of 

the following methods:

A) Multiply the average lb/TBtu Hg emission rate 

(determined according to paragraph (h)(3)(iii)(A) 

of this section) by the maximum potential annual 

heat input to the unit (TBtu), which is equal to the 

maximum rated unit heat input (TBtu/hr) times 

8,760 hours. If the maximum rated heat input 

value is expressed in units of MMBtu/hr, multiply 

it by 10 −6 to convert it to TBtu/hr; or

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

{...continued from previous page...}

(i) If choosing to comply with the PM filterable emissions limit 

in lieu of metal HAP limits, the permittee may choose to install, 

certify, operate, and maintain a PM CEMS and record the output 

of the PM CEMS as specified in paragraphs (i)(i) through (v) of 

this condition, below. The compliance limit will be expressed as 

a 30-boiler operating day rolling average of the numerical 

emissions limit value applicable for the unit in tables 1 or 2 to 

Subpart UUUUU.

(i) Install and certify the PM CEMS according to the 

procedures and requirements in Performance Specification 

11—Specifications and Test Procedures for Particulate Matter 

Continuous Emission Monitoring Systems at Stationary 

Sources in Appendix B to Part 60 of 40 CFR, using Method 5 

at Appendix A-3 to Part 60 of 40 CFR and ensuring that the 

front half filter temperature shall be 160° ± 14 °C (320° ± 25 

°F). The reportable measurement output from the PM CEMS 

must be expressed in units of the applicable emissions limit 

(e.g., lb/MMBtu, lb/MWh).

(ii) Operate and maintain the PM CEMS according to the 

procedures and requirements in Procedure 2—Quality 

Assurance Requirements for Particulate Matter Continuous 

Emission Monitoring Systems at Stationary Sources in 

Appendix F to Part 60 of 40 CFR.

a) The permittee shall conduct the relative response audit 

(RRA) for the PM CEMS at least once annually.

b) The permittee shall conduct the relative correlation audit 

(RCA) for the PM CEMS at least once every 3 years.

(iii) Collect PM CEMS hourly average output data for all 

boiler operating hours except as indicated in paragraph (i) of 

this condition.

(iv) Calculate the arithmetic 30-boiler operating day rolling 

average of all of the hourly average PM CEMS output data 

collected during all nonexempt boiler operating hours.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 26

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii)c)3) {...continued from previous page...}

B) Multiply the average lb/GWh Hg emission rate 

(determined according to paragraph (h)(3)(iii)(B) of 

this section) by the maximum potential annual 

electricity generation (GWh), which is equal to the 

maximum rated electrical output of the unit (GW) 

times 8,760 hours. If the maximum rated electrical 

output value is expressed in units of MW, multiply it 

by 10 −3 to convert it to GW; or

C) If an EGU has a federally-enforceable permit limit 

on either the annual heat input or the number of 

annual operating hours, you may modify the 

calculations in paragraph (h)(3)(iii)(C)(1) of this 

section by replacing the maximum potential annual 

heat input or 8,760 unit operating hours with the 

permit limit on annual heat input or operating hours 

(as applicable).

[40 CFR s. 63.10005(h)]

(i) {reserved}

(j) Startup and shutdown: The permitee shall follow the 

requirements given in Table 3 to 40 CFR, Part 63, Subpart 

UUUUU . [40 CFR s. 63.10005(j)]

(k) The permittee shall submit a Notification of Compliance 

Status summarizing the results of the initial compliance 

demonstration, as provided in 40 CFR s. 63.10030. [40 CFR s. 

63.10005(k)]

[40 CFR s. 63.10005, s. 285.65(13), Wis. Stats.]

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

(a) The permittee shall demonstrate initial compliance with 

each emissions limit in I.A.7.a. by conducting performance 

testing. [40 CFR s. 63.10011(a)]

(b) If demonstrating initial compliance with HAP metals or 

filterable PM emission limit(s) through performance stack tests 

and electing to use a PM CPMS to demonstrate continuous 

performance, the permittee shall also establish a site-specific 

operating limit, in accordance with Table 4 to Subpart 

UUUUU, 40 CFR s. 63.10007, and Table 6 to Subpart 

UUUUU. The permittee may use only the parametric data 

recorded during successful performance tests ( i.e. , tests that 

demonstrate compliance with the applicable emissions limits) 

to establish an operating limit. [40 CFR s. 63.10011(b)]

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(i) {...continued from previous page...}

(v) The permittee shall collect data using the PM CEMS 

at all times the process unit is operating and at the 

intervals specified in paragraph (a) of this condition, 

except for periods of monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, 

and required monitoring system quality assurance or 

quality control activities.

a) The permittee shall use all the data collected during 

all boiler operating hours in assessing the compliance 

with the operating limit except:

1) Any data collected during monitoring system 

malfunctions, repairs associated with monitoring 

system malfunctions, or required monitoring system 

quality assurance or control activities conducted 

during monitoring system malfunctions in 

calculations and report any such periods in the annual 

deviation report;

2) Any data collected during periods when the 

monitoring system is out of control as specified in 

the site-specific monitoring plan, repairs associated 

with periods when the monitoring system is out of 

control, or required monitoring system quality 

assurance or control activities conducted during out 

of control periods in calculations used to report 

emissions or operating levels and report any such 

periods in the annual deviation report;

3) Any data recorded during periods of startup or 

shutdown.

b) The permittee shall record and make available upon 

request results of PM CEMS system performance 

audits, dates and duration of periods when the PM 

CEMS is out of control to completion of the corrective 

actions necessary to return the PM CEMS to operation 

consistent with the site-specific monitoring plan.

[40 CFR s. 63.10010(i)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 27

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with Emission Limitations and 

Work Practice Standards:

{...continued from previous page...}

(c)(i) If using CEMS or sorbent trap monitoring systems to measure 

a HAP (e.g., Hg or HCl) directly, the first 30-boiler operating day 

(or, if alternate emissions averaging is used for Hg, the 90-boiler 

operating day) rolling average emission rate obtained with 

certified CEMS after the compliance date in I.A.7.a.(5) (or, if 

applicable, prior to that date, as described in 40 CFR 

s. 63.10005(b)(2)), expressed in units of the standard, is the initial 

performance test. Initial compliance is demonstrated if the results 

of the performance test meet the applicable emission limit in 

I.A.7.a.

(ii) For a unit that uses a CEMS to measure SO2 or PM emissions 

for initial compliance, the first 30 boiler operating day average 

emission rate obtained with certified CEMS after the compliance 

date in I.A.7.a.(5) (or, if applicable, prior to that date, as 

described in 40 CFR s. 63.10005(b)(2)), expressed in units of the 

standard, is the initial performance test. Initial compliance is 

demonstrated if the results of the performance test meet the 

applicable SO2 or filterable PM emission limit in I.A.7.a.

[40 CFR s.10011(c)]

(d) For candidate LEE units, use the results of the performance 

testing described in 40 CFR s. 63.10005(h) to determine initial 

compliance with the applicable emission limit(s) in I.A.7.a. and to 

determine whether the unit qualifies for LEE status. [40 CFR s. 

63.10011(d)]

(e) The permittee shall submit a Notification of Compliance Status 

containing the results of the initial compliance demonstration, 

according to 40 CFR s. 63.10030(e). [40 CFR s. 63.10011(e)]

{continued on next page...}

(5) Monitoring, Installation, Operation and 

Maintenance Requirements:

{...continued from previous page...}

(j) The permittee may choose to comply with the metal 

HAP emissions limits using CEMS approved in 

accordance with 40 CFR s. 63.7(f) as an alternative to 

the performance test method specified in 40 CFR, Part 

63, Subpart UUUUU. If approved to use a HAP metals 

CEMS, the compliance limit will be expressed as a 30-

boiler operating day rolling average of the numerical 

emissions limit value in I.A.7.a.(1). If approved, the 

permittee may choose to install, certify, operate, and 

maintain a HAP metals CEMS and record the output of 

the HAP metals CEMS as specified below:

(i) a) Install and certify the HAP metals CEMS 

according to the procedures and requirements in 

the approved site-specific test plan as required in 

40 CFR s. 63.7(e). The reportable measurement 

output from the HAP metals CEMS shall be 

expressed in units of the applicable emissions 

limit (e.g., lb/MMBtu, lb/MWh) and in the form 

of a 30-boiler operating day rolling average.

b) Operate and maintain the HAP metals CEMS 

according to the procedures and criteria in the site 

specific performance evaluation and quality 

control program plan required in 40 CFR 

s. 63.8(d).

(ii) Collect HAP metals CEMS hourly average output 

data for all boiler operating hours except as indicated 

in section (j)(iv) of this condition.

(iii) Calculate the arithmetic 30-boiler operating day 

rolling average of all of the hourly average HAP 

metals CEMS output data collected during all 

nonexempt boiler operating hours data.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 28

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

{...continued from previous page...}

(f)(i) The permittee shall determine the fuel whose 

combustion produces the least uncontrolled 

emissions, i.e., the cleanest fuel, either natural 

gas or distillate oil, that is available on site or 

accessible nearby for use during periods of 

startup or shutdown.

(ii) The cleanest fuel available, either natural gas 

or distillate oil, for use during periods of startup 

or shutdown determination may take safety 

considerations into account.

[40 CFR 2. 63.10011(f)]

(g) The permittee shall follow the startup or 

shutdown requirements given in Table 3 to 40 CFR, 

Part 63, Subpart UUUUU for EGU. [40 CFR s. 

63.10011(g)]

[40 CFR s. 63.10011, s. 285.65(13), Wis. Stats.]

(8) Continuous Compliance Demonstration:

(a) The permittee shall demonstrate continuous 

compliance with each emissions limit in Table 2 to 

Subpart UUUUU (see condition I.A.7.a.), each 

operating limit in Table 4 to subpart UUUUU (see 

condition I.A.7.b.(4)), and each work practice 

standard in Tables 3 to Subpart UUUUU (see 

conditions I.A.7.a.(4) and I.A.7.b.(3)) that applies, 

according to the monitoring specified in Tables 6 

and 7 to Subpart UUUUU as outlined below and 

conditions I.A.7.b.(8)(b) through (g).

(i) If using CEMS to measure filterable PM, SO2, 

HCl, or Hg emissions, or using a sorbent trap 

monitoring system to measure Hg to demonstrate 

compliance with the applicable emission 

limitations in I.A.7.a., the permittee shall 

demonstrate continuous compliance by 

calculating the 30- (or 90-) boiler operating day 

rolling arithmetic average emissions rate in units 

of the applicable emissions standard basis at the 

end of each boiler operating day using all of the 

quality assured hourly average CEMS or sorbent 

trap data for the previous 30-boiler operating 

days, excluding data recorded during periods of 

startup or shutdown. [40 CFR s. 63.10021(a), 

item 1 of Table 7 to 40 CFR, Part 63, Subpart 

UUUUU]

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(j) {...continued from previous page...}

(iv) The permittee shall collect data using the HAP metals CEMS at all 

times the process unit is operating and at the intervals specified in 

paragraph (a) of this condition, except for periods of monitoring system 

malfunctions, repairs associated with monitoring system malfunctions, 

and required monitoring system quality assurance or quality control 

activities.

a) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with the emission limit 

except:

1) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or required 

monitoring system quality assurance or control activities conducted 

during monitoring system malfunctions in calculations and report 

any such periods in the annual deviation report;

2) Any data collected during periods when the monitoring system is 

out of control as specified in the site-specific monitoring plan, 

repairs associated with periods when the monitoring system is out of 

control, or required monitoring system quality assurance or control 

activities conducted during out of control periods in calculations 

used to report emissions or operating levels and report any such 

periods in the annual deviation report;

3) Any data recorded during periods of startup or shutdown.

b) The permittee shall record and make available upon request results 

of HAP metals CEMS system performance audits, dates and duration 

of periods when the HAP metals CEMS is out of control to 

completion of the corrective actions necessary to return the HAP 

metals CEMS to operation consistent with the site-specific 

performance evaluation and quality control program plan.

[40 CFR s. 63.10010(j)]

[40 CFR s. 63.10010, s. 285.65(13), Wis. Stats.]

(6) Continuous Compliance Demonstration – Monitoring and Data 

Collection:

(a) The permittee shall monitor and collect data according to this 

condition and the site-specific monitoring plan required by 40 CFR 

s. 63.10000(d).

(b) The permitee shall operate the monitoring system and collect data at 

all required intervals at all times that the affected EGU is operating, 

except for periods of monitoring system malfunctions or out-of-control 

periods (see 40 CFR s. 63.8(c)(7)), and required monitoring system 

quality assurance or quality control activities, including, as applicable, 

calibration checks and required zero and span adjustments. The 

permittee is required to affect monitoring system repairs in response to 

monitoring system malfunctions and to return the monitoring system to 

operation as expeditiously as practicable.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 29

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(ii) If choosing to establish PM CPMS operating limits as 

allowed by I.A.7.b.(4) to demonstrate compliance with the 

emission limitations in I.A.7.a.(1) (particulate matter (PM), total 

non-mercury HAP metals, individual non-mercury HAP metals), 

the permitee shall 

a) Install, certify, maintain, and operate a PM CPMS for 

monitoring emissions discharged to the atmosphere according to 

40 CFR s. 63.10010(g)(1) and 

b) Establish a site-specific operating limit in units of PM CPMS 

output signal (e.g., milliamps, mg/acm, or other raw signal) 

using data from the PM CPMS and the PM or HAP metals 

performance tests according to the following procedures:

1) Collect PM CPMS output data during the entire period of 

the performance tests.

2) Record the average hourly PM CPMS output for each test 

run in the three run performance test.

3) Determine the highest 1-hour average PM CPMS measured 

during the performance test demonstrating compliance with 

the filterable PM or HAP metals emissions limitations.

[40 CFR s. 63.10021(a) , Table 6 to 40 CFR, Part 63, Subpart 

UUUUU]

(iii) If using PM CPMS to measure compliance with a parametric 

operating limit, the permittee shall demonstrate continuous 

compliance by calculating the arithmetic 30-boiler operating day 

rolling average of all of the quality assured hourly average PM 

CPMS output data (e.g., milliamps, PM concentration, raw data 

signal) collected for all operating hours for the previous 30 boiler 

operating days, excluding data recorded during periods of startup 

or shutdown. [40 CFR s. 63.10021(a), item 2 of Table 7 to 40 

CFR, Part 63, Subpart UUUUU]

(iv) If using quarterly performance testing to measure compliance 

with one or more applicable emissions limits in condition 

I.A.7.a., the permitee shall demonstrate continuous compliance 

by calculating the results of the testing in units of the applicable 

emissions standard. [40 CFR s. 63.10021(a), item 4 of Table 7 to 

40 CFR, Part 63, Subpart UUUUU]

(v) When conducting periodic performance tune-ups of your 

EGU(s), the permittee shall demonstrate continuous compliance 

by conducting periodic performance tune-ups of the EGU(s), as 

specified in 40 CFR s. 63.10021(e). [40 CFR s. 63.10021(a), 

item 5 of Table 7 to 40 CFR, Part 63, Subpart UUUUU]

{continued on next page...}

(6) Continuous Compliance Demonstration –

Monitoring and Data Collection:

{...continued from previous page...}

(c) The permtitee may not use data recorded during 

EGU startup or shutdown or monitoring system 

malfunctions or monitoring system out-of-control 

periods, repairs associated with monitoring system 

malfunctions or monitoring system out-of-control 

periods, or required monitoring system quality assurance 

or control activities in calculations used to report 

emissions or operating levels. The permittee shall use all 

the data collected during all other periods in assessing 

the operation of the control device and associated 

control system.

(d) Except for periods of monitoring system 

malfunctions or monitoring system out-of-control 

periods, repairs associated with monitoring system 

malfunctions or monitoring system out-of-control 

periods, and required monitoring system quality 

assurance or quality control activities including, as 

applicable, calibration checks and required zero and 

span adjustments), failure to collect required data is a 

deviation from the monitoring requirements.

[40 CFR s. 63.10020, s. 285.65(13), Wis. Stats.]

(7) Notification Requirements:

(a) The permittee shall submit all of the notifications in 

40 CFR, ss. 63.7(b) and (c), 63.8 (e), (f)(4) and (6), and 

63.9 (b) through (h) that apply by the dates specified. 

[40 CFR ss. 63.9984(c) and 63.10030(a), s. 285.65(13), 

Wis. Stats.]

(b) As specified in 40 CFR s. 63.9(b)(2), the permittee 

shall submit an Initial Notification not later than 120 

days after April 16, 2012. [40 CFR ss. 63.9984(c) and 

63.10030(b), s. 285.65(13), Wis. Stats.]

(c) {reserved}

(d) When required to conduct a performance test, the 

permittee shall submit a Notification of Intent to 

conduct a performance test at least 30 days before the 

performance test is scheduled to begin. [40 CFR ss. 

63.9984(c) and 63.10030(d), s. 285.65(13), Wis. Stats.]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 30

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(vi) When complying with work practice 

standards during startup the permittee shall 

demonstrate continuous compliance by 

operating in accordance with Table 3 to 40 

CFR, Part 63, Subpart UUUUU. [40 CFR s. 

63.10021(a), item 6 of Table 7 to 40 CFR, 

Part 63, Subpart UUUUU]

(vii) When complying with work practice 

standards during shutdown, the permittee 

shall demonstrate continuous compliance by 

operating in accordance with Table 3 to 40 

CFR, Part 63, Subpart UUUUU. [40 CFR s. 

63.10021(a), item 7 of Table 7 to 40 CFR, 

Part 63, Subpart UUUUU]

[40 CFR s. 63.10021(a)]

(b) Except as otherwise provided in 40 CFR 

s. 63.10020(c), if using a CEMS to measure 

SO2 , PM, HCl, or Hg emissions, or using a 

sorbent trap monitoring system to measure Hg 

emissions, the permittee shall demonstrate 

continuous compliance by using all qualityassured hourly data recorded by the CEMS (or 

sorbent trap monitoring system) and the other 

required monitoring systems (e.g., flow rate, 

CO2 , O2 , or moisture systems) to calculate the 

arithmetic average emissions rate in units of the 

standard on a continuous 30-boiler operating 

day (or, if alternate emissions averaging is used 

for Hg, 90-boiler operating day) rolling average 

basis, updated at the end of each new boiler 

operating day. Use Equation 8 to determine the 

30- (or, if applicable, 90-) boiler operating day 

rolling average.

Where:

Heri is the hourly emissions rate for hour i and n is 

the number of hourly emissions rate values 

collected over 30- (or, if applicable, 90-) boiler 

operating days.

[40 CFR s. 63.10021(b)]

{continued on next page...}

(7) Notification Requirements:

{...continued from previous page...}

(e) When required to conduct an initial compliance demonstration as 

specified in 40 CFF s. 63.10011(a), the permittee shall submit a Notification 

of Compliance Status according to 40 CFR s. 63.9(h)(2)(ii). The Notification 

of Compliance Status report shall contain all the following information, as 

applicable:

(i) A description of the affected source(s) including identification of which 

subcategory the source is in, the design capacity of the source, a 

description of the add-on controls used on the source, description of the 

fuel(s) burned, including whether the fuel(s) were determined by the 

permittee or EPA through a petition process to be a non-waste under 40 

CFR s. 241.3, whether the fuel(s) were processed from discarded nonhazardous secondary materials within the meaning of 40 CFR s. 241.3, and 

justification for the selection of fuel(s) burned during the performance test.

(ii) Summary of the results of all performance tests and fuel analyses and 

calculations conducted to demonstrate initial compliance including all 

established operating limits.

(iii) Identification of whether compliance with each applicable emission 

limit will be demonstrated through performance testing; fuel moisture 

analyses; performance testing with operating limits (e.g., use of PM 

CPMS); CEMS; or a sorbent trap monitoring system.

(iv) Identification of whether compliance will be demonstrated by 

emissions averaging.

(v) A signed certification that all applicable emission limits and work 

practice standards have been met.

(vi) If a deviation from any emission limit, work practice standard, or 

operating limit occurred, submit a brief description of the deviation, the 

duration of the deviation, emissions point identification, and the cause of 

the deviation in the Notification of Compliance Status report.

(vii) In addition to the information required in 40 CFR s. 63.9(h)(2), your 

notification of compliance status must include the following:

a) A summary of the results of the annual performance tests and 

documentation of any operating limits that were reestablished during this 

test, if applicable. If stack tests are conducted once every 3 years 

consistent with 40 CFR s. 63.10006(b), the date of the last three stack 

tests, a comparison of the emission level achieved in the last three stack 

tests to the 50 percent emission limit threshold required in 40 CFR 

s. 63.10006(i), and a statement as to whether there have been any 

operational changes since the last stack test that could increase emissions.

b) Certifications of compliance, as applicable, signed by a responsible 

official stating: 

1. “This EGU complies with the requirements in 40 CFR, 

s. 63.10021(a) to demonstrate continuous compliance.” and

2. “No secondary materials that are solid waste were combusted in any 

affected unit.”

[40 CFR ss. 63.9984(c) and 63.10030(e), s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 31

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(c) If using a PM CPMS data to measure 

compliance with an operating limit in Table 4 to 

Subpart UUUUU, The permitee shall record the 

PM CPMS output data for all periods when the 

process is operating and the PM CPMS is not outof-control. The permittee shall demonstrate 

continuous compliance by using all qualityassured hourly average data collected by the PM 

CPMS for all operating hours to calculate the 

arithmetic average operating parameter in units of 

the operating limit (e.g., milliamps, PM 

concentration, raw data signal) on a 30 operating 

day rolling average basis, updated at the end of 

each new boiler operating day. Use Equation 9 to 

determine the 30 boiler operating day average.

Where:

Hpvi is the hourly parameter value for hour i and 

n is the number of valid hourly parameter values 

collected over 30 boiler operating days.

[40 CFR s. 63.10021(c)]

(d) If using quarterly performance testing to 

demonstrate compliance with one or more 

applicable emissions limits in 2 to Subpart 

UUUUU (see I.A.7.a.), the permittee:

(i) May skip performance testing in those 

quarters during which less than 168 boiler 

operating hours occur, except that a performance 

test must be conducted at least once every 

calendar year.

(ii) Shall conduct the performance test as defined 

in Table 5 to Subpart UUUUU and calculate the 

results of the testing in units of the applicable 

emissions standard; and

[40 CFR s. 63.10021(d)]

{continued on next page...}

(8) Reporting Requirements:

(a) The permittee shall submit each report in Table 8 to 40 CFR, Part 63, 

Subpart UUUUU that applies. If required to (or electing to) continuously 

monitor Hg and/or HCl emissions, The permittee shall also submit the 

electronic reports required under Appendix A and/or Appendix B to 

Subpart UUUUU, at the specified frequency. [40 CFR s. 63.10031(a)]

(b) Unless the department has approved a different schedule for 

submission of reports under 40 CFR s. 63.10(a), the permittee shall 

submit each report semiannually and according to the following:

(i) The first compliance report shall cover the period beginning on the 

compliance date in I.A.7.a.(5) (the compliance date specified in 40 

CFR s. 63.9984) and ending on either June 30 or December 31, 

whichever date is the first date that occurs at least 180 days after the 

specified compliance date.

(ii) The first compliance report shall be postmarked or submitted 

electronically no later than either July 31 or January 31, whichever date 

is the first date following the end of the first calendar half after the 

specified compliance date.

(iii) Each subsequent compliance report shall cover the semiannual 

reporting period from January 1 through June 30 or the semiannual 

reporting period from July 1 through December 31.

(iv) Each subsequent compliance report shall be postmarked or 

submitted electronically no later than July 31 or January 31, whichever 

date is the first date following the end of the semiannual reporting 

period.

(v) The permitte may submit the semiannual compliance reports along 

with the reports required by condition I.XXX.1.a., instead of according 

to the dates in paragraphs (i) through (iv), above.

[40 CFR s. 63.10031(b), Table 8 to 40 CFR, Part 63, Subpart UUUUU]

(c) The compliance report shall contain the following information: 

(i) The information required by the summary report located in 40 CFR 

s. 63.10(e)(3)(vi).

(ii) The total fuel use by each affected source subject to an emission 

limit, for each calendar month within the semiannual reporting period, 

including, but not limited to, a description of the fuel, whether the fuel 

has received a non-waste determination by EPA or your basis for 

concluding that the fuel is not a waste, and the total fuel usage amount 

with units of measure.

(iii) An indication of whether new types of fuel were burned during the 

reporting period. If new types of fuel were burned, the permittee shall 

include the date of the performance test where that fuel was in use.

(iv) The date of the most recent tune-up for each unit subject to the 

requirement to conduct a performance tune-up according to 40 CFR 

s. 63.10021(e), including the date of the most recent burner inspection 

if it was not done every 36 (or 48) months and was delayed until the 

next scheduled unit shutdown.

[40 CFR s. 63.10031(c)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 32

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats. ]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(e) When conducting periodic performance tune-ups 

of your EGU(s), as specified below, perform the first 

tune-up as part of the initial compliance 

demonstration. Notwithstanding this requirement, 

you the permittee may delay the first burner 

inspection until the next scheduled unit outage 

provided the requirements of 40 CFR s. 63.10005 are 

met. Subsequently, the permittee shall perform an 

inspection of the burner at least once every 36 

calendar months unless the EGU employs neural 

network combustion optimization during normal 

operations in which case the permittee shall perform 

an inspection of the burner and combustion controls at 

least once every 48 calendar months.

(i) As applicable, inspect the burner and combustion 

controls, and clean or replace any components of the 

burner or combustion controls as necessary upon 

initiation of the work practice program and at least 

once every required inspection period. Repair of a 

burner or combustion control component requiring 

special order parts may be scheduled as follows:

a) Burner or combustion control component 

parts needing replacement that affect the ability 

to optimize NOX and CO must be installed 

within 3 calendar months after the burner 

inspection,

b) Burner or combustion control component 

parts that do not affect the ability to optimize 

NOX and CO may be installed on a schedule 

determined by the operator;

(ii) As applicable, inspect the flame pattern and 

make any adjustments to the burner or combustion 

controls necessary to optimize the flame pattern. 

The adjustment should be consistent with the 

manufacturer's specifications, if available, or in 

accordance with best combustion engineering 

practice for that burner type;

(iii) As applicable, observe the damper operations as 

a function of mill and/or cyclone loadings, cyclone 

and pulverizer coal feeder loadings, or other 

pulverizer and coal mill performance parameters, 

making adjustments and effecting repair to dampers, 

controls, mills, pulverizers, cyclones, and sensors;

{continued on next page...}

(8) Reporting Requirements:

{...continued from previous page...}

(d) For each excess emissions occurring at an affected source where a 

CMS is used to comply with that emission limit or operating limit, the 

permittee shall include the information required in 40 CFR 

s. 63.10(e)(3)(v) in the compliance report specified in paragraph (c), 

above. [40 CFR s. 63.10031(d)]

(e) The permittee shall report all deviations as defined in 40 CFR, 

Part 63, Subpart UUUUU in the semiannual monitoring report 

required condition I.XXX.1.a. If an affected source submits a 

compliance report pursuant to Table 8 to to Subpart UUUUU along 

with, or as part of, the semiannual monitoring report required by 

condition I.XXX.1.a., and the compliance report includes all required 

information concerning deviations from any emission limit, operating 

limit, or work practice requirement in this subpart, submission of the 

compliance report satisfies any obligation to report the same 

deviations in the semiannual monitoring report. Submission of a 

compliance report does not otherwise affect any obligation the 

affected source may have to report deviations from permit 

requirements to the permit authority. [40 CFR s. 63.10031(e)]

(f) As of January 1, 2012, and within 60 days after the date of 

completing each performance test, the permittee shall submit the 

results of the performance tests required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's Central 

Data Exchange (CDX) ( www.epa.gov/cdx ). Performance test data 

shall be submitted in the file format generated through use of EPA's 

Electronic Reporting Tool (ERT) (see 

http://www.epa.gov/ttn/chief/ert/index.html ). Only data collected 

using those test methods on the ERT Web site are subject to this 

requirement for submitting reports electronically to WebFIRE. 

Owners or operators who claim that some of the information being 

submitted for performance tests is confidential business information 

(CBI) must submit a complete ERT file including information 

claimed to be CBI on a compact disk or other commonly used 

electronic storage media (including, but not limited to, flash drives) to 

EPA. The electronic media must be clearly marked as CBI and mailed 

to U.S. EPA/OAPQS/CORE CBI Office, Attention: WebFIRE 

Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 

27703. The same ERT file with the CBI omitted shall be submitted to 

EPA via CDX as described earlier in this paragraph. The permittee 

shall also submit these reports, including the confidential business 

information, to the department in the format specified by the 

department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 33

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b ), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(iv) As applicable, evaluate windbox pressures and 

air proportions, making adjustments and effecting 

repair to dampers, actuators, controls, and sensors;

(v) Inspect the system controlling the air-to-fuel 

ratio and ensure that it is correctly calibrated and 

functioning properly. Such inspection may include 

calibrating excess O2 probes and/or sensors, 

adjusting overfire air systems, changing software 

parameters, and calibrating associated actuators and 

dampers to ensure that the systems are operated as 

designed. Any component out of calibration, in or 

near failure, or in a state that is likely to negate 

combustion optimization efforts prior to the next 

tune-up, should be corrected or repaired as 

necessary;

(vi) Optimize combustion to minimize generation of 

CO and NOX . This optimization should be 

consistent with the manufacturer's specifications, if 

available, or best combustion engineering practice 

for the applicable burner type. NOX optimization 

includes burners, overfire air controls, concentric 

firing system improvements, neural network or 

combustion efficiency software, control systems 

calibrations, adjusting combustion zone temperature 

profiles, and add-on controls such as SCR and 

SNCR; CO optimization includes burners, overfire 

air controls, concentric firing system improvements, 

neural network or combustion efficiency software, 

control systems calibrations, and adjusting 

combustion zone temperature profiles;

(vii) While operating at full load or the 

predominantly operated load, measure the 

concentration in the effluent stream of CO and NOX

in ppm, by volume, and oxygen in volume percent, 

before and after the tune-up adjustments are made 

(measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the 

adjustments are made). You may use portable CO, 

NOX and O2 monitors for this measurement. EGU's 

employing neural network optimization systems 

need only provide a single pre- and post-tune-up 

value rather than continual values before and after 

each optimization adjustment made by the system;

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(i) Within 60 days after the date of completing each CEMS (SO2 , 

PM, HCl, and Hg) performance evaluation test, as defined in 40 

CFR s. 63.2 and required by Subpart UUUUU, the permittee shall 

submit the relative accuracy test audit (RATA) data (or, for PM 

CEMS, RCA and RRA data) required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The RATA 

data shall be submitted in the file format generated through use of 

EPA's Electronic Reporting Tool (ERT) ( 

http://www.epa.gov/ttn/chief/ert/index.html ). Only RATA data 

compounds listed on the ERT Web site are subject to this 

requirement. Owners or operators who claim that some of the 

information being submitted for RATAs is confidential business 

information (CBI) shall submit a complete ERT file including 

information claimed to be CBI on a compact disk or other 

commonly used electronic storage media (including, but not 

limited to, flash drives) by registered letter to EPA and the same 

ERT file with the CBI omitted to EPA via CDX as described 

earlier in this paragraph. The compact disk or other commonly 

used electronic storage media shall be clearly marked as CBI and 

mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: 

WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., 

Durham, NC 27703. The permittee shall also submit these RATAs 

to the department in the format specified by the department. The 

permittee shall submit calibration error testing, drift checks, and 

other information required in the performance evaluation as 

described in 40 CFR s. 63.2 and as required in 40 CFR.

(ii) For a PM CEMS, PM CPMS, or approved alternative 

monitoring using a HAP metals CEMS, within 60 days after the 

reporting periods ending on March 31st, June 30th, September 

30th, and December 31st, the permitee submit quarterly reports to 

EPA's WebFIRE database by using the Compliance and Emissions 

Data Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The permittee 

shall use the appropriate electronic reporting form in CEDRI or 

provide an alternate electronic file consistent with EPA's reporting 

form output format. For each reporting period, the quarterly 

reports must include all of the calculated 30-boiler operating day 

rolling average values derived from the CEMS and PM CPMS. 

The permittee shall also submit these quarterly reports to the 

department in the format specified by the department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 34

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats. ]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the information in 

paragraphs (e)(1) through (e)(9) of this section including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume percent, 

measured before and after an adjustment of the EGU 

combustion systems;

b) A description of any corrective actions taken as a part 

of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if the 

unit was physically and legally capable of using more 

than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tune-ups as 

follows:

a) If the first required tune-up is performed as part of the 

initial compliance demonstration, report the date of the 

tune-up in hard copy (as specified in 40 CFR s. 63.10030) 

and electronically (as specified in 40 CFR s. 63.10031). 

Report the date of each subsequent tune-up electronically 

(as specified in 40 CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the initial 

compliance demonstration, but is postponed until the next 

unit outage, report the date of that tune-up and all 

subsequent tune-ups electronically, in accordance with 40 

CFR s. 63.10031.

[40 CFR s. 63.10021(e)]

(f) The permittee shall submit the reports required under 40 

CFR s. 63.10031 and, if applicable, the reports required under 

Appendices A and B to Subpart UUUUU. The electronic 

reports required by Appendices A and B to Subpart UUUUU 

shall be sent to the EPA electronically, as provided in 40 CFR 

s. 63.10031. CEMS data (except for PM CEMS and any 

approved alternative monitoring using a HAP metals CEMS) 

shall be submitted using EPA's Emissions Collection and 

Monitoring Plan System (ECMPS) Client Tool. Other data, 

including PM CEMS data, HAP metals CEMS data, and 

CEMS performance test detail reports, shall be submitted in the

file format generated through use of EPA's Electronic 

Reporting Tool, the Compliance and Emissions Data Reporting 

Interface, or alternate electronic file format, all as provided for 

under 40 CFR s. 63.10031. These reports shall also be 

submitted to the department. [40 CFR s. 63.10021(f)]

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(iii) Reports for an SO2 CEMS, a Hg CEMS or sorbent 

trap monitoring system, an HCl CEMS, and any 

supporting monitors for such systems (such as a diluent 

or moisture monitor) shall be submitted using the 

ECMPS Client Tool, as provided for in Appendices A 

and B to Subpart UUUUU and 40 CFR s. 63.10021(f). 

The permittee shall also submit these to the department in 

the format specified by the department.

(iv) Submit the compliance reports required under 

paragraphs (c) and (d) of this condition and the 

notification of compliance status required under 40 CFR 

s. 63.10030(e) to EPA's WebFIRE database by using the 

Compliance and Emissions Data Reporting Interface 

(CEDRI) that is accessed through EPA's Central Data 

Exchange (CDX) ( www.epa.gov/cdx ). the permittee 

shall use the appropriate electronic reporting form in 

CEDRI or provide an alternate electronic file consistent 

with EPA's reporting form output format. The permittee 

shall also submit these compliance reports to the 

department in the format specified by the department.

(v) All reports required by 40 CFR, Part 63, Subpart 

UUUUU not subject to the requirements in paragraphs 

(f)(1) through (4) of this condition must be sent to the 

Administrator at the appropriate address listed in 40 CFR 

s. 63.13. If acceptable to both the Administrator and the 

owner or operator of a source, these reports may be 

submitted on electronic media. The Administrator retains 

the right to require submittal of reports subject to 

paragraphs (f)(1), (2), and (3) of this condition in paper 

format. The permittee shall also submit these compliance 

reports to the department in the format specified by the 

department.

[40 CFR s. 63.10031(f)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 35

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(g) The permittee shall report each instance in which 

an applicable emissions limit or operating limit in 

Tables 2 through 4 to Subpart UUUUU (I.A.7.a.) 

was not met or a required tune-up was not 

conducted. These instances are deviations from the 

requirements of Subpart UUUUU. These deviations 

shall be reported according to 40 CFR s. 63.10031. 

[40 CFR s. 63.10021(g)]

(h) The permittee shall keep records as specified in 

40 CFR s. 63.10032 during periods of startup and 

shutdown. [40 CFR s. 63.10021(h)]

(i) The permittee shall provide reports as specified in 

40 CFR s. 63.10031 concerning activities and 

periods of startup and shutdown. [40 CFR s. 

63.10021(i)]

[40 CFR s. 63.10021, s. 285.65(13), Wis. Stats.]

(9) Continuous Compliance Demonstration –

Emissions Averaging Provision:

(a) Following the compliance date, the permittee 

shall demonstrate compliance with Subpart UUUUU 

on a continuous basis by meeting the following:

(i) For each 30- (or 90-) day rolling average 

period, demonstrate compliance with the average 

weighted emissions limit for the existing units 

participating in the emissions averaging option as 

determined in 40 CFR s. 63.10009(f) and (g);

(ii) For each existing unit participating in the 

emissions averaging option that is equipped with 

PM CPMS, maintain the average parameter value 

at or below the operating limit established during 

the most recent performance test;

(iii) For each existing unit participating in the 

emissions averaging option venting to a common 

stack configuration containing affected units from 

other subcategories, maintain the appropriate 

operating limit for each unit as specified in Table 

4 to Subpart UUUUU that applies.

(b) Any instance where the permittee fails to comply 

with the continuous monitoring requirements in 

paragraphs (a) of this condition is a deviation.

[40 CFR s. 63.10022, s. 285.65(13), Wis. Stats.]

(8) Reporting Requirements:

{...continued from previous page...}

(g) If the permittee had a malfunction during the reporting period, the 

compliance report must include the number, duration, and a brief 

description for each type of malfunction which occurred during the 

reporting period and which caused or may have caused any applicable 

emission limitation to be exceeded. [40 CFR s. 63.10031(g)]

[40 CFR s. 63.10031, s. 285.65(13), Wis. Stats.]

(9) Recordkeeping Requirements:

(a) The permittee shall keep records according to the following. If 

required to (or electing to) continuously monitor Hg and/or HCl 

emissions, the permittee shall also keep the records required under 

Appendix A and/or Appendix B to 40 CFR, Part 63, Subpart UUUUU.

(i) A copy of each notification and report that you submitted to 

comply with this subpart, including all documentation supporting 

any Initial Notification or Notification of Compliance Status or 

semiannual compliance report that you submitted, according to the 

requirements in 40 CFR s. 63.10(b)(2)(xiv).

(ii) Records of performance stack tests, fuel analyses, or other 

compliance demonstrations and performance evaluations, as 

required in 40 CFR s. 63.10(b)(2)(viii).

[40 CFR s. 63.10032(a)]

(b) For each CEMS and CPMS, the permittee shall keep records 

according to the following:

(i) Records described in 40 CFR s. 63.10(b)(2)(vi) through (xi).

(ii) Previous (i.e., superseded) versions of the performance 

evaluation plan as required in 40 CFR s. 63.8(d)(3).

(iii) Request for alternatives to relative accuracy test for CEMS as 

required in 40 CFR s. 63.8(f)(6)(i).

(iv) Records of the date and time that each deviation started and 

stopped, and whether the deviation occurred during a period of 

startup, shutdown, or malfunction or during another period.

[40 CFR s. 63.10032(b)]

(c) The permittee shall keep the records required in Table 7 to 40 CFR, 

Part 63, Subpart UUUUU including records of all monitoring data and 

calculated averages for applicable PM CPMS operating limits to show 

continuous compliance with each emission limit and operating limit 

that applies to you. [40 CFR s. 63.10032(c)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 36

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(10) Establishing and Determining 

Compliance with a PM CPMS Operating 

Limit:

(a) During the initial performance test or any 

such subsequent performance test that 

demonstrates compliance with the filterable PM, 

individual non-mercury HAP metals, or total 

non-mercury HAP metals limit in I.A.7.a.(1), 

record all hourly average output values (e.g., 

milliamps, stack concentration, or other raw data 

signal) from the PM CPMS for the periods 

corresponding to the test runs (e.g., nine 1-hour 

average PM CPMS output values for three 3-

hour test runs).

(b) Determine the operating limit as the highest 

1-hour average PM CPMS output value recorded 

during the performance test. The permittee shall

verify an existing or establish a new operating 

limit after each repeated performance test.

(c) The permittee shall operate and maintain the 

process and control equipment such that the 30 

operating day average PM CPMS output does 

not exceed the operating limit determined in 

paragraphs (a) and (b) of this condition.

[40 CFR s. 63.10023, s. 285.65(13), Wis. Stats.]

(11) General Provisions: The permittee is 

subject to the General Provisions of 40 CFR 

ss. 63.1 through 63.15 as shown in Table 9 to 40 

CFR, Part 63, Subpart UUUUU. [40 CFR s. 

63.10040, s. 285.65(13), Wis. Stats.]

(12) Affirmative defense for exceedence of 

emission limit during malfunction: In 

response to an action to enforce the standards set 

forth in 40 CFR s. 63.9991 the permittee may 

assert an affirmative defense to a claim for civil 

penalties for exceedances of such standards that 

are caused by malfunction, as defined at 40 CFR 

s. 63.2. Appropriate penalties may be assessed, 

however, if the permittee fails to meet all burden 

of proving all of the requirements in the 

affirmative defense. The affirmative defense 

shall not be available for claims for injunctive 

relief.

{continued on next page...}

(9) Recordkeeping Requirements:

{...continued from previous page...}

(d) For each EGU subject to an emission limit, the permittee shall also keep 

the following records:

(i) The permittee shall keep records of monthly fuel use by each EGU, 

including the type(s) of fuel and amount(s) used.

(ii) If combusting non-hazardous secondary materials that have been 

determined not to be solid waste pursuant to 40 CFR 241.3(b)(1), the 

permittee shall keep a record which documents how the secondary 

material meets each of the legitimacy criteria. If combusting a fuel that 

has been processed from a discarded non-hazardous secondary material 

pursuant to 40 CFR 241.3(b)(2), the permittee shall keep records as to 

how the operations that produced the fuel satisfies the definition of 

processing in 40 CFR 241.2. If the fuel received a non-waste 

determination pursuant to the petition process submitted under 40 CFR 

241.3(c), the permittee shall keep a record which documents how the 

fuel satisfies the requirements of the petition process.

(iii) For an EGU that qualifies as an LEE under 40 CFR s. 63.10005(h), 

the permittee shall keep annual records that document that emissions in 

the previous stack test(s) continue to qualify the unit for LEE status for 

an applicable pollutant, and document that there was no change in 

source operations including fuel composition and operation of air 

pollution control equipment that would cause emissions of the pollutant 

to increase within the past year.

[40 CFR s. 63.10032(d)]

(e) If electing to average emissions consistent with 40 CFR s. 63.10009, the 

permittee must additionally keep a copy of the emissions averaging 

implementation plan required in 40 CFR s. 63.10009(g), all calculations 

required under 40 CFR s. 63.10009, including daily records of heat input or 

steam generation, as applicable, and monitoring records consistent with 40 

CFR s. 63.10022. [40 CFR s. 63.10032(e)]

(f) The permitee shall keep records of the occurrence and duration of each 

startup and/or shutdown. [40 CFR s. 63.10032(f)]

(g) The permittee shall keep records of the occurrence and duration of each 

malfunction of an operation ( i.e. , process equipment) or the air pollution 

control and monitoring equipment. [40 CFR s. 63.10032(g)]

(h) The permitee shall keep records of actions taken during periods of 

malfunction to minimize emissions in accordance with 40 CFR 

s. 63.10000(b), including corrective actions to restore malfunctioning 

process and air pollution control and monitoring equipment to its normal or 

usual manner of operation. [40 CFR s. 63.10032(h)]

(i) The permitee shall keep records of the type(s) and amount(s) of fuel 

used during each startup or shutdown. [40 CFR s. 63.10032(i)]

[40 CFR s. 63.10032, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 37

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: {...continued from previous page...}

(a) To establish the affirmative defense in any action to enforce such a 

limit, the permittee shall timely meet the notification requirements in 

paragraph (b) of this condition, and must prove by a preponderance of 

evidence that:

(i) The excess emissions:

a) Were caused by a sudden, infrequent, and unavoidable failure 

of air pollution control and monitoring equipment, process 

equipment, or a process to operate in a normal or usual manner, 

and

b) Could not have been prevented through careful planning, 

proper design or better operation and maintenance practices; and

c) Did not stem from any activity or event that could have been 

foreseen and avoided, or planned for; and

d) Were not part of a recurring pattern indicative of inadequate 

design, operation, or maintenance; and

(ii) Repairs were made as expeditiously as possible when the 

applicable emission limitations were being exceeded. Off-shift and 

overtime labor were used, to the extent practicable to make these 

repairs; and

(iii) The frequency, amount and duration of the excess emissions 

(including any bypass) were minimized to the maximum extent 

practicable during periods of such emissions; and

(iv) If the excess emissions resulted from a bypass of control 

equipment or a process, then the bypass was unavoidable to prevent 

loss of life, personal injury, or severe property damage; and

(v) All possible steps were taken to minimize the impact of the 

excess emissions on ambient air quality, the environment and 

human health; and

(vi) All emissions monitoring and control systems were kept in 

operation if at all possible, consistent with safety and good air 

pollution control practices; and

(vii) All of the actions in response to the excess emissions were 

documented by properly signed, contemporaneous operating logs; 

and

(viii) At all times, the affected source was operated in a manner 

consistent with good practices for minimizing emissions; and

(ix) A written root cause analysis has been prepared, the purpose of 

which is to determine, correct, and eliminate the primary causes of the 

malfunction and the excess emissions resulting from the malfunction 

event at issue. The analysis shall also specify, using best monitoring 

methods and engineering judgment, the amount of excess emissions 

that were the result of the malfunction.

{continued on next page...}

(10) Records (Form and Retention):

(a) Records must be in a form suitable and readily 

available for expeditious review, according to 40 CFR 

s. 63.10(b)(1).

(b) As specified in 40 CFR s. 63.10(b)(1), the 

permitee shall keep each record for 5 years following 

the date of each occurrence, measurement, 

maintenance, corrective action, report, or record.

(c) The permittee shall keep each record on site for at 

least 2 years after the date of each occurrence, 

measurement, maintenance, corrective action, report, 

or record, according to § 63.10(b)(1). The permittee 

may keep the records off site for the remaining 3 

years.

[40 CFR s. 63.10033, s. 285.65(13), Wis. Stats.]

(11) Emissions Averaging to Comply with 40 CFR, 

Part 63, Subpart UUUUU: The permittee may use 

the emission averaging described in 40 CFR s. 

63.10009 to comply with Subpart UUUUU, if all the 

criteria in that section are met. [40 CFR s. 63.10009, 

s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 38

A. Stack S01, Boiler B01, Control Device C01 – Weston Unit 1 - Coal Fired Dry-Bottom Boiler Rated at 858 mmBtu/hr 

- (CONTINUED)

Stack S02, Boiler B02, Control Device C02 – Weston Unit 2 - Coal Fired Dry-Bottom Boiler Rated at 1000 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.A.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b) s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: {...continued from previous page...}

(b) Notification. When experiencing an exceedance of its emission 

limit(s) during a malfunction, the permittee shall notify US EPA and 

the department by telephone or facsimile (FAX) transmission as soon 

as possible, but no later than two business days after the initial 

occurrence of the malfunction or, if it is not possible to determine 

within two business days whether the malfunction caused or 

contributed to an exceedance, no later than two business days after the 

permittee knew or should have known that the malfunction caused or 

contributed to an exceedance, but, in no event later than two business 

days after the end of the averaging period, if it wishes to avail itself of 

an affirmative defense to civil penalties for that malfunction. When 

seeking to assert an affirmative defense, the permittee shall also 

submit a written report to US EPA and the department within 45 days 

of the initial occurrence of the exceedance of the standard in 40 CFR 

s. 63.9991 to demonstrate, with all necessary supporting 

documentation, that it has met the requirements set forth in paragraph 

(a) of this condition. The permittee may seek an extension of this 

deadline for up to 30 additional days by submitting a written request 

to US EPA and the department before the expiration of the 45 day 

period. Until a request for an extension has been approved by US 

EPA and the department, the permittee is subject to the requirement to 

submit such report within 45 days of the initial occurrence of the 

exceedance.

[40 CFR s. 63.10001, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 39

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr (Combustion Engineering Radiant type water tube boiler) – Initially Operated 12/1981

Additional Fuels: Natural Gas, Distillate Fuel Oil, and Alternative Fuels. 

Controlled by: Baghouse 

Pollutant: 1. Particulate Matter Emissions

a. Limitations:

(1) (a) Emissions from Boiler B03 may not exceed 0.10 pounds per million BTU of heat input.

(b) Emissions from Boiler B03 may not exceed 342.3 pounds/hour in any hour.21 

[s. NR 440.19(3)(a)1., Wis. Adm. Code, s. 285.65(3), Wis. Stats., Permit EPA-5-77-A-4, condition 7a, 06-SDD-102, 40 CFR s. 60.42(a)(1)]

(2) See also condition I.B.7.a.(1).

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire:

(a) the following primary and backup fuels in boiler B03:

(i) coal, 

(ii) natural gas, and

(iii) distillate fuel oil.

(b) the following alternate fuels22 in boiler B03:

(i) ash (partially burned coal); and

(ii) refuse derived fuel (municipal).

[s, NR 407.09(4)(a), Wis. Adm. Code, ss. 285.65(3) and 

285.63(1)(a), Wis. Stats., 06-SDD-102]

(2) The permittee shall operate a baghouse to control particulate 

matter emissions from the boiler whenever the boiler is in 

operation and solid fuel is being fired, with the exception of 

periods of normal start-up and shut-down as defined in 

condition I.B.2.b.(1). [ss. NR 407.09(4)(a) and NR 415.03, Wis. 

Adm. Code, s. 285.65(3), Wis. Stats., 06-SDD-102]

(3) The permittee shall perform compliance emission testing of 

particulate matter emissions from this boiler to demonstrate 

compliance with the particulate matter emission limit in 

I.B.1.a.(1), as follows:

(a) Testing shall be conducted every 24 months as long as the 

permit remains valid.

(b) Each biennial test of particulate matter emissions shall be 

performed within 90 days of the anniversary date of the 

previous test or within 90 days of an alternate date specified by 

the Department in writing.

(c) The permittee may request and the Department may approve 

a waiver from the required biennial testing provided the results 

of the most recently completed biennial test demonstrate that 

particulate matter emissions are 50 percent or less of the 

applicable limitation in condition I.B.1.a.(1);

(d) The permittee shall repeat the compliance emissions test 

while firing refuse waste, within 60 days of first firing refuse 

waste. This testing shall be completed prior to firing the 

alternate fuel(s) on a regular basis.

(e) The tests shall be conducted in accordance with I.XXX.3.a.

[ss. NR 439.07, NR 439.075(2)(c) and NR 439.075(3)(b), Wis. 

Adm. Code, 06-SDD-102]

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever particulate matter emission testing is 

required by the Department, the permittee shall use U.S. 

EPA Method 5, 5I, or 17 including backhalf (Method 202), 

or any other method approved by the Department in 

writing. [s. NR 439.06(1), and (1m), Wis. Adm. Code]

(2) The permittee shall retain copies of the results of the 

compliance emission tests specified in I.B.1.b.(3). [s. NR 

439.04(1)(a), Wis. Adm. Code, 06-SDD-102]

(3) The permittee shall keep records of the type and amount 

of fuel burned in this boiler on a monthly basis. [s. NR 

439.04(1)(d), Wis. Adm. Code, 06-SDD-102]

(4) (a) The permittee shall record the parameters listed in 

I.B.1.b.(4) continuously whenever the boiler is operating. 

(b) In the event of a malfunction or failure of the 

continuous pressure differential monitoring system, the 

permittee shall record the pressure drop once every eight 

hours of source operation or once per day while the unit is 

operating, whichever yields the greater number of 

measurements, until the continuous monitor is returned to 

service. 

(c) The permittee shall maintain records of any 

investigative and corrective action taken as a result of an 

alarm indicating a differential pressure drop reading 

outside the indicator range in condition I.B.1.b.(10)(b), that 

include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(d) The permittee shall maintain records of any 

investigative and corrective action taken as a result of an 

alarm indicating a one-hour average opacity reading that 

exceeds the range in I.B.2.b.(10)(e), that include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken.

[s. NR 439.04(1)(d), Wis. Adm. Code]

[s. NR 439.055(5), Wis. Adm. Code, 06-SDD-102]

 21 This limit is also established in the permit because the source was reviewed with this emission rate and it was determined that 

no ambient air quality standards would be violated when operated as proposed. 

22 See section I.B.6. of this permit for restrictions on the amount of alternate fuels that can be fired.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 40

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 1. Particulate Matter Emissions - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and 

Monitoring:

(4) (a) The permittee shall continuously monitor the differential pressure 

drop across the baghouse. 

(b) In the event of a malfunction or failure of the continuous pressure 

differential monitoring system, the permittee shall monitor and record the 

pressure drop once every eight hours of source operation or once per day 

while the unit is operating, whichever yields the greater number of 

measurements, until the continuous monitor is returned to service. [ss. NR 

439.055(1)(a), (2)(b), and (5), Wis. Adm. Code and 06-SDD-102]

(6) The permittee shall perform periodic internal inspections of the baghouse 

to ensure that the control equipment is operating properly. The time interval 

between inspections may not exceed 13,140 operating hours unless written 

approval from the Department is granted allowing for a greater interval. 

Such a request may only be granted if the applicant demonstrates that such 

an interval is needed to maintain a stable electric power supply. [s. NR 

407.09(4)(a)3.b., Wis. Adm. Code and 06-SDD-102]

(7) The permittee shall calibrate instruments used for measuring the 

baghouse operational parameters identified in I.B.1.b.(4) once every 13,140 

hours of operation, unless an alternative schedule is approved by the 

department in writing. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code]

(8) The permittee shall perform periodic inspections of the boiler to ensure 

optimum boiler performance using a qualified inspector. Specific items that 

should be inspected include, but are not limited to, firebox, boiler tubes, 

refractory, burner conditions, boiler backpass, boiler cleanliness and overall 

boiler condition. The time interval between inspections may not exceed 

13,140 operating hours, unless the department approves a request for an 

extension in writing. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code and 06-

SDD-102]

(9) Partially burned coal requirements:

(a) The total amount of partially burned coal that is received from 

Rhinelander Paper Mill (RPM) (fid # 744008100) for combustion in boilers 

B01, B02 and B03 in any calendar year may not exceed 10,400 tons. 

(b) The total amount of partially burned coal that is received from WausauMosinee Mill (fid # 737009570) for combustion in B01, B02, and B03 in 

any calendar year may not exceed 10,000 tons.23

(c) The permittee shall obtain written approval from the department, prior to 

burning partially burned coal from other sources.

(d) The permittee shall perform an annual elemental metal analysis of the 

partially burned coal from facilities fid#s 744008100 and 737009570 (or 

other ash as approved under I.B.1.b.(9)(c) prior to or within 90 days after the 

fuel is first burned in any of the boilers, in each calendar year. Elemental 

metal analysis is required once in any calendar year that partially burned 

coal is fired in any of the boilers.

[ss. 285.65(3) and (10), Stats., s. NR 407.09(4)(a)3.b., Wis. Adm. Code and 

06-SDD-102]

(5) The permittee shall keep records of:

(a) the date, time, and initials of the person 

performing the inspections required by 

I.B.1.b.(6);

(b) a list of the items inspected;

(c) any maintenance or repairs performed as a 

result of these inspections;

(d) the operating hours of the boiler since the 

last inspection; and

(e) the date, time and initials of the person 

performing the calibrations required by 

I.B.1.b.(6).

[s. NR 439.04(1)(d), Wis. Adm. Code, 06-

SDD-102]

(6) The permittee shall keep records of:

(a) the date, time, and initials of the person 

performing the inspections required by 

I.B.1.b.(8);

(b) a list of the items inspected;

(c) any maintenance, repairs or adjustments 

performed as a result of these inspections. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 06-

SDD-102]

(7) The permittee shall keep records of the 

amount of ash received for combustion from 

facilities FID #s 744009100 and 737009570 

monthly and in a calendar year in tons. [s. NR 

439.04(1)(d), Wis. Adm. Code, 06-SDD-102]

(8) The permittee shall keep records to 

demonstrate compliance with I.B.1.b.(9)(d). [s. 

NR 439.04(1)(d), Wis. Adm. Code and 06-

SDD-102]

 23 The company names associated with these fid#s may be changed and still maintain compliance with this condition.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 41

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 1. Particulate Matter Emissions - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(10) Compliance Assurance Monitoring (CAM) Requirements: Boiler B03 is a pollutantspecific emissions unit for particulate matter emissions and is subject to the CAM 

requirements of Part 64 CFR. As such the boiler is subject to the CAM requirements in 

Part IV and section I.XXX.9. of this permit, and as follows:

(a) Whenever the boiler is operating, the permittee shall monitor differential pressure

drop across the fabric filter baghouse system as an indicator of control equipment 

performance, using electronic pressure transmitters located at the inlet and the outlet of 

the baghouse.;

(b) The indicator range for differential pressure drop across the baghouse controlling B03 

is 2.0 to 10.0 inches of water; 

(c) The permittee shall monitor opacity as a secondary indicator of baghouse performance 

using a continuous opacity monitoring system (COMS) that meets the requirements 

I.B.2.b.(2) and I.B.2.c.(2);

(d) The permittee shall use the data collected by the COMS to calculate one-hour average 

opacities for the boiler;

(e) The indicator range for visible emissions from B03 is 10% opacity or less based on a 

one-hour average; 

(f) An excursion is:

(i) a differential pressure drop reading outside the indicator range in condition 

I.B.1.b.(10)(b); OR

(ii) a one-hour average opacity reading that exceeds the range in I.B.2.b.(10)(e).

(g) The permittee shall operate an alarm system to notify the operator if the differential 

pressure drop across the baghouse is outside the range specified in conditions 

I.B.1.b.(10)(b). If an alarm occurs, the permittee shall take appropriate investigative and 

corrective action.

(h) The permittee shall operate an alarm system to notify the operator if visible emissions 

exceed the opacity specified in conditions I.B.1.b.(10)(e). If an alarm occurs, the 

permittee shall take appropriate investigative and corrective action.

(i) The quality improvement plan (QIP) threshold is reached when excursions occur for 

more than 5% of the boiler’s operating time in a six month reporting period;

(j) The permittee shall operate the COMS in accordance with 40 CFR ss. 64.7 and 64.8 as 

detailed in conditions I.XXX.a.(2) and (4).

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b. and s. NR 439.055(5), Wis. 

Adm. Code, and 40 CFR ss. 64.2, 64.3, 64.6, 64.7, and 64.8 and 06-SDD-102]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 42

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) The permittee may not cause to be discharged to the atmosphere any gases which exhibit greater than 20% opacity except 

for one-6 minute period per hour of not more than 27% opacity. This opacity standard applies at all times except periods of 

startup, shutdown, or malfunction. [ss. NR 440.11(3), NR 440.19(3)(a)2. and NR 431.05, Wis. Adm. Code, 06-SDD-102, 40 

CFR s. 60.42(a)(2)]

(2) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.24 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.05, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) To minimize visible emissions, the permittee shall start-up 

and shut-down the boiler according to the following:25

(a) Normal Start-up Sequence:

(i) Place the baghouse in service and ensure continuous opacity 

monitor is operational, or in accordance with an alternative 

monitoring method approved in writing by the Department.

(ii) Start the draft fan(s)

(iii) Preheat boiler firing natural gas.

(iv) Introduce coal to the combustion chamber while continuing 

to operate the gas burners as the coal begins to ignite.

(v) Continue the use of the gas burner during startup to achieve a 

stable coal fire.

(vi) Normal start-up is complete upon achieving a stable fire and 

a minimum generator load of 150 MW.26

(b) Normal Shut-down Sequence:

(i) Reduce generator load below 150 MW with the intent of 

removing the unit from service.

(ii) Discontinue coal introduction to boiler and cease fuel firing.

(iii) Discontinue operation of the draft fans.

(iv) Discontinue operation of baghouse.

(v) Normal shut-down is complete after item (iv) or a start-up of 

the boiler commences.

[s. NR 407.09(4)(a), Wis. Adm. Code and 06-SDD-102]

(2) The permittee shall calibrate, maintain and operate a 

continuous opacity monitoring system for the measurement of 

opacity from stack S03, in accordance with the performance 

specifications in 40 CFR Part 75, Appendices A to I. [ss. NR 

439.09(1), NR 439.095(1)(f) and (6) and 440.19(6)(a), Wis. 

Adm. Code, 06-SDD-102, 40 CFR s. 60.45(a)]

(1) Reference Test Method for Visible Emissions: 

Whenever visible emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 9 or 

other method approved by the Department. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The continuous opacity monitor required by I.B.2.b.(2) 

shall complete one cycle of sampling and analyzing for 

each successive 10-second period and one cycle of data 

recording for each successive 6-minute period. [ss. NR 

439.09(9)(a), Wis. Adm. Code and 06-SDD-102]

(3) The permittee shall submit quarterly excess emission 

reports to the Department within 30 days following the 

end of each calendar quarter in accordance with 

I.XXX.2.a. [ss. NR 439.09(10) and 440.19(6)(g), Wis. 

Adm. Code, 06-SDD-102, 40 CFR s. 60.45(g)]

(4) Unless otherwise specified by the Department, periods 

of excess visible emissions shall be any 6 minute period 

during which the average opacity exceeds the limitation in 

I.B.2.a.(1) except as allowed under s. NR 440.19(6)(g)1., 

Wis. Adm. Code. [ss. NR 439.09(10)(b) and NR 

440.19(6)(g)1., Wis. Adm. Code, 06-102-SDD, 40 CFR 

s.60.45(g)(1)]

 24 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

25 The following start-up and shut-down sequence contains a summary of steps to limit visible emissions.

26 All values are gross MW. The normal start-up sequence from first coal fire to stable coal fire is generally less than 12 hours 

in duration.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 43

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 3. Nitrogen Oxides

a. Limitations:

(1) Emissions may not exceed:

(a) 0.70 pound per million Btu averaged over any 3 hour period, and 

(b) 2,396.4 pounds/hour averaged over any 3 hour period.27

[ss. 285.63(1)(b), 285.65(3) and (7), Wis. Stats., s. NR 440.19(5)(a)3., Wis. Adm. Code, 06-SDD-102, 40 CFR s. 60.44(a)(3)]

(2) Acid Rain Requirements: Boiler B03 is an Affected Acid Rain Unit subject to Acid Rain Requirements. As such the 

permittee shall comply with the applicable requirements included in the Acid Rain Portion of the Operation Permit in Section 

I.ZZZ.

(3) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boiler B03 is subject to the NOx -

Annual and the NOx –Ozone Season CAIR requirements. As such, the permittee shall comply with the CAIR requirements as 

outlined in section I.XXX.8. and in the CAIR Permit Application (for sources subject to CAIR FIP) submitted by Wisconsin 

Public Service Corporation – Weston and dated May 23, 2007 incorporated as Part III of this Operation Permit and 40 CFR 

97.121, 97.122, 97.221, 97.222, 97.321 and 97.322. OR alternately, when in effect, comply with the Cross-State Air Pollution 

Rule requirements, as applicable, as required in section I.XXX.8.

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall 

calibrate, maintain and operate 

a continuous monitoring 

system for the measurement of 

nitrogen oxides from stack 

S03, in accordance with the 

performance specifications in 

40 CFR Part 75, Appendices 

A to I.28 [ss. NR 439.09(2), 

and NR 439.095(1)(f) and (6), 

Wis. Adm. Code and 06-SDD102]

(1) Reference Test Method for Nitrogen Oxide Emissions: Whenever nitrogen oxide emission 

testing is required by the Department, the permittee shall use U.S. EPA Method 7 or other 

method approved by the Department. [s. NR 439.06(6), Wis. Adm. Code]

(2) The continuous nitrogen oxides monitor required by I.B.3.b.(1) shall perform sampling, 

analyzing, and data recording as follows:

(a) complete one cycle of sampling, analyzing, and data recording for each successive 

15-minute period.

(b) the values recorded shall be averaged hourly.

(c) hourly averages shall be computed from 4 data points equally spaced over each 1 hour 

period, except during periods when calibrations, quality assurance or maintenance activities 

are being performed. During these periods, a valid hour shall consist of at least 2 data points 

separated by a minimum of 15 minutes. 

(d) When calculating hourly emissions in pounds per million Btu, a minimum concentration 

of 5.0 percent carbon dioxide or a maximum concentration of 14.0 percent oxygen may be 

substituted for the measured diluent gas concentration value for any operating hour in which 

the hourly average carbon dioxide concentration is less than 5.0 percent carbon dioxide or the 

hourly average oxygen concentration is greater than 14.0 percent oxygen, as described in 40 

CFR Part 75 Appendix F Section 3.3.4.1. 

[s. NR 439.09(9)(b), Wis. Adm. Code and 06-SDD-102]

(3) The permittee shall submit quarterly excess emission reports to the Department within 30 

days following the end of each calendar quarter. [s. NR 439.09(10), Wis. Adm. Code and 06-

SDD-102]

(4) Excess emissions for nitrogen oxides are any 3 hour rolling average during which the 

average nitrogen oxide emissions exceed the emission limitation in I.B.3.a.(1). For purposes 

of reporting exceedances on the basis of a 3-hour rolling average, any hourly average may be 

included in only one 3 hour period. [s. NR 440.19(6)(g)3., Wis. Adm. Code, 06-SDD-102, 

40 CFR s. 60.45(g)(3)]

 27 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

28 The permittee is exempt from the biennial nitrogen oxide compliance tests required by ss. NR 439.075(4) Wis. Adm. Code 

provided that they operate a continuous nitrogen oxide monitor that meets the performance specification requirements of s. NR 

439.09, Wis. Adm. Code. [s. NR 439.075(4)(a)2), Wis. Adm. Code and 06-SDD-102]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 44

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 4. Sulfur Dioxide

a. Limitations:

(1) Emissions may not exceed:

(a) 1.2 pounds per million Btu averaged over any 3 hour period; and 

(b) 4,108.2 pounds/hour averaged over any 3 hour period.29 

[ss. 285.63(10(b), 285.65(3) and (7), Wis. Stats., s. NR 440.19(4)(a)2., Wis. Adm. Code, Permit EPA-5-77-A-4, condition 7a, 

06-SDD-102, 40 CFR s. 60.43(a)(2)]

(2) Acid Rain Requirements: Boiler B03 is an Affected Acid Rain Unit subject to Acid Rain Requirements. As such the 

permittee shall comply with the applicable requirements included in the Acid Rain Portion of the Operation Permit in Section 

I.ZZZ.

(3) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boiler B03 is subject to the SO2 

CAIR requirements. As such, the permittee shall comply with the CAIR requirements as outlined in section I.XXX.8. and in the 

CAIR Permit Application (for sources subject to CAIR FIP) submitted by Wisconsin Public Service Corporation – Weston and 

dated May 23, 2007 incorporated as Part III of this Operation Permit and 40 CFR 97.121, 97.122, 97.221, 97.222, 97.321 and 

97.322. OR alternately, when in effect, comply with the Cross-State Air Pollution Rule requirements, as applicable, as required 

in section I.XXX.8.

b. Compliance 

Demonstration:

c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee 

shall calibrate, 

maintain and 

operate a 

continuous 

monitoring 

system for the 

measurement of 

sulfur dioxide 

from stack S03, 

in accordance 

with the 

performance 

specifications in 

40 CFR Part 75, 

Appendices A to 

I.30 [ss. NR 

439.09(2) and 

NR 

439.095(1)(f) 

and (6), Wis. 

Adm. Code and 

06-SDD-102]

(1) Reference Test Method for Sulfur Dioxide Emissions: Whenever sulfur dioxide emission testing is 

required by the Department, the permittee shall use U.S. EPA Method 6 or any other method approved by 

the Department in writing. [s. NR 439.06(2), Wis. Adm. Code]

(2) The continuous sulfur dioxide monitor required by I.B.4.b.(1) shall perform sampling, analyzing, and 

data recording as follows:

(a) complete one cycle of sampling, analyzing, and data recording for each successive 15-minute period.

(b) the values recorded shall be averaged hourly.

(c) hourly averages shall be computed from 4 data points equally spaced over each 1 hour period, except 

during periods when calibrations, quality assurance or maintenance activities are being performed. During 

these periods, a valid hour shall consist of at least 2 data points separated by a minimum of 15 minutes. 

(d) When calculating hourly emissions in pounds per million Btu, a minimum concentration of 5.0 percent 

carbon dioxide or a maximum concentration of 14.0 percent oxygen may be substituted for the measured 

diluent gas concentration value for any operating hour in which the hourly average carbon dioxide 

concentration is less than 5.0 percent carbon dioxide or the hourly average oxygen concentration is greater 

than 14.0 percent oxygen, as described in 40 CFR Part 75 Appendix F Section 3.3.4.1. 

[s. NR 439.09(9)(b), Wis. Adm. Code and 06-SDD-102]

(3) The permittee shall submit quarterly excess emission reports to the Department within 30 days 

following the end of each calendar quarter. [s. NR 439.09(10), Wis. Adm. Code and 06-SDD-102]

(4) Excess emissions for sulfur dioxide are any 3 hour rolling average during which the average sulfur 

dioxide emissions exceed the emission limitation in I.B.4.a.(1). For purposes of reporting exceedances on 

the basis of a 3-hour rolling average, any hourly average may be included in only one 3 hour period. [s. NR 

440.19(6)(g)2., Wis. Adm. Code, 06-SDD-102, 40 CFR s. 60.45(g)(2)]

 29 This limit is also established in the permit because the source was reviewed with this emission rate and it was determined that 

no ambient air quality standards would be violated when operated as proposed.

30 The permittee is exempt from the biennial sulfur dioxide compliance tests required by ss. NR 439.075(2)(a)2., and (3)(b), 

Wis. Adm. Code provided that they operate a continuous sulfur dioxide monitor that meets the performance specification 

requirements of s. NR 439.09, Wis. Adm. Code. [s. NR 439.075(4)(a)2., Wis. Adm. Code and 06-SDD-102] 

The permittee is exempt from the periodic fuel sampling and analysis requirements of s. NR 439.085(2), Wis. Adm. Code 

provided they operate a continuous sulfur dioxide emission monitor that meets the performance specification requirements of s. 

NR 439.09, Wis. Adm. Code. [s. NR 439.085(1)(c), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 45

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 5. Carbon Monoxide (CO)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 350 ppmvd corrected to 3% oxygen in any hour averaged over any 24-hour period

(b) 250 ppmvd corrected to 3% oxygen in any month averaged over any 12-month period [s. NR 405.08, Wis. Adm. Code and 

06-SDD-102]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall calibrate, maintain and operate a 

continuous monitoring system for the measurement of carbon 

monoxide emissions from stack S03, in accordance with the 

performance specifications in s. NR 439.09(4), Wis. Adm. 

Code. [ss. NR 405.08, NR 439.09(4), NR 439.095(1)(f), Wis. 

Adm. Code and 06-SDD-102]

(2) Compliance with the emission limitations in 

I.B.5.a.(1)(a)&(b) shall be determined using only CEM 

readings taken while the boiler is actually operating. Periods 

when the boiler is non-operational shall not be used to 

determine compliance with either of the emission limitations. 

[s. NR 405.08, Wis. Adm. Code and 06-SDD-102]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever carbon monoxide emission testing is required, the 

permittee shall use U.S. EPA Method 10 or any other method 

approved by the Department in writing. [s. NR 439.06(4)(a), 

Wis. Adm. Code]

(2) The continuous carbon monoxide monitor required by 

I.B.5.b.(1) shall perform sampling, analyzing, and data 

recording as follows:

(a) complete one cycle of sampling, analyzing, and data 

recording for each successive 15-minute period.

(b) the values recorded shall be averaged hourly.

(c) hourly averages shall be computed from 4 data points 

equally spaced over each 1 hour period, except during periods 

when calibrations, quality assurance or maintenance activities 

are being performed. During these periods, a valid hour shall 

consist of at least 2 data points separated by a minimum of 15 

minutes. 

(d) When calculating hourly emissions in ppmvd, a minimum 

concentration of 5.0 percent carbon dioxide or a maximum 

concentration of 14.0 percent oxygen may be substituted for 

the measured diluent gas concentration value for any 

operating hour in which the hourly average carbon dioxide 

concentration is less than 5.0 percent carbon dioxide or the 

hourly average oxygen concentration is greater than 14.0 

percent oxygen, as described in 40 CFR Part 75 Appendix F 

Section 3.3.4.1. 

[s. NR 439.09(9)(b), Wis. Adm. Code and 06-SDD-102]

(3) The permittee shall submit quarterly excess emission 

reports to the Department within 30 days following the end of 

each calendar quarter. [s. NR 439.09(10), Wis. Adm. Code 

and 06-SDD-102]

(4) Excess emissions for carbon monoxide are defined as: 

(a) any 24 hour rolling average during which the average 

carbon monoxide emissions exceed the emission limitation in 

I.B.5.a.(1)(a).

(b) any month in which the 12-month average carbon 

monoxide emissions exceed the emission limitation in 

I.B.5.a.(1)(b).

[s. NR 439.06(4)(b), Wis. Adm. Code and 06-SDD-102]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 46

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 6. * Hazardous Air Contaminants Regulated by ch. NR 445, Wis. Adm. Code

a. Limitations:

(1) * Except as provided in s. NR 445.07(5), Wis. Adm. Code, the following requirements apply31:

(a) * The permittee may not cause, allow or permit emissions of a hazardous air contaminant listed in Table A of s. NR 445.07, 

Wis. Adm. Code, in such quantity or concentration or for such duration as to cause an ambient air concentration of the 

contaminant off the source property that exceeds the concentration in column (g) of Table A for the contaminant. [s. NR 

445.07(1)(a), Wis. Adm. Code]

(b) * If a hazardous air contaminant for which a control requirement is identified in column (i) of Table A of s. NR 445.07, 

Wis. Adm. Code, is emitted in a quantity greater than the applicable amount listed in column (f)32 of Table A, the permittee 

shall control emissions of the contaminant to a level identified in column (i) of the table, according to the applicable 

compliance requirements of s. NR 445.08, Wis. Adm. Code. [s. NR 445.07(c), Wis. Adm. Code]

(2) * The permittee shall achieve compliance with the emission limitations and control requirements of I.B.6.a.(1) for each 

hazardous air contaminant by doing one or any combination of the following:

(a) * Limiting non-exempt, potential to emit emissions to less than the applicable thresholds in column (f) of Table A of s. NR 

445.07, Wis. Adm. Code.33 [s. NR 445.08(2)(a), Wis. Adm. Code]

(b) * Limiting the quantity, concentration or duration of non-exempt, potential to emit emissions of each hazardous air 

contaminant that has a standard expressed as an ambient air concentration in Table A of s. NR 445.07, Wis. Adm. Code so that 

the ambient air concentration off the source property is less than the concentration allowed under column (g) of Table A. [s. 

NR 445.08(2)(b), Wis. Adm. Code]

(c) * Limiting the quantity, concentration or duration of non-exempt, potential to emit emissions of each hazardous air 

contaminant with a control requirement in column (i) of Table A of s. NR 445.07, Wis. Adm. Code having a unit risk factor 

established by either the EPA or the California air resources board, so as not to cause an ambient air concentration off the 

source property that results in an inhalation impact greater than 1 x 10-6 (as determined by the equation in s. NR 445.08(2)(c), 

Wis. Adm. Code). [s, BR 445.08(2)(c), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * To demonstrate compliance with conditions I.B.6.a.(1) and 

(2), the use of alternate fuels in boiler B03 may not exceed the 

following rates:

(a) Refuse Derived Fuel Usage Limitations:

(i) 3.09 tons per hour; and

(ii) 13,889 tons during each 12 consecutive month period.

[s. NR 445.08, Wis. Adm. Code

(1) * The permittee shall keep the following records:

Refuse Derived Fuel:

(a) The amount of refuse derived fuel combusted in B03 in 

tons per hour;

(b) The amount of refuse derived fuel combusted in B03 

during each calendar month, in tons per month;

(c) The amount of refuse derived fuel combusted in B03 

totaled for each 12 consecutive month period, in tons.

 31 HAP emissions from natural gas and distillate fuel oil combustion are exempt since they are group 1 virgin fossil fuels, 

pursuant to s. NR 445.07(5)(a), Wis. Adm. Code. HAP emissions from coal combustion are exempt because coal is a group 2 

virgin fossil fuel and the boiler stacks meet the downwash minimization stack height criteria pursuant to s. NR 445. 07(5)(b), 

Wis. Adm. Code. The conditions in this section of the permit apply to hazardous air contaminant emissions generated by the 

combustion of alternate fuels in boiler B03.

32 The stack (S03) exhausting boiler B03 is greater than 75 feet in height. The stack is an unobstructed discharge point, 

exhausting emissions within 10 degrees of vertical as required by s. NR 445.07(6)(a), Wis. Adm. Code. 

33 The boiler meets the requirements of s. NR 445.07(6)(a) and (b), Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 47

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 6. * Hazardous Air Contaminants Regulated by ch. NR 445, Wis. Adm. Code - {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Partially burned coal requirements:

(a) The total amount of partially burned coal that is received 

from Rhinelander Paper Mill (RPM) (fid # 744008100) for 

combustion in boilers B01, B02 and B03 in any calendar year 

may not exceed 10,400 tons. 

(b) The total amount of partially burned coal that is received 

from Wausau-Mosinee Mill (fid # 737009570) for 

combustion in B01, B02, and B03 in any calendar year may 

not exceed 10,000 tons.34

(c) The permittee shall obtain written approval from the 

department, prior to burning partially burned coal from other 

sources.

(d) The permittee shall perform an annual elemental metal 

analysis of the partially burned coal from facilities fid#s 

744008100 and 737009570 (or other ash as approved under 

I.B.6.b.(2)(c) prior to or within 90 days after the fuel is first 

burned in any of the boilers, in each calendar year. Elemental 

metal analysis is required once in any calendar year that 

partially burned coal is fired in any of the boilers.

[ss. 285.65(3) and (10), Stats., s. NR 407.09(4)(a)3.b., Wis. 

Adm. Code and 06-SDD-102]

(2) To demonstrate compliance with I.B.6.b.(2), the permittee 

shall keep records of the amount of ash received for 

combustion from facilities FID #s 744009100 and 737009570 

monthly and in a calendar year in tons. [s. NR 439.04(1)(d), 

Wis. Adm. Code and 06-SDD-102]

(3) The permittee shall keep records to demonstrate 

compliance with I.B.6.b.(2)(d). [s. NR 439.04(1)(d), Wis. 

Adm. Code and 06-SDD-102]

 34 The company names associated with these fid#s may be changed and still maintain compliance with this condition.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 48

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5) [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

a. Limitations:

(1) For boiler B03, the permittee shall comply with ONE of the following:

(a) Filterable particulate matter may not exceed: 0.03 lbs/mmBtu or 0.3 lbs/MWh gross electric output; OR

(b) Total non-Hg HAP metals may not exceed: 0.00005 lbs/mmBtu or 0.5 lbs/GWh; OR

(c) Individual Metal HAP metals may not exceed all of the following:

(i) Antimony (Sb): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(ii) Arsenic (As): 1.1 lbs/TBtu or 0.02 lbs/GWh;

(iii) Beryllium (Be): 0.2 lbs/TBtu or 0.002 lbs/GWh;

(iv) Cadmium (Cd): 0.3 lbs/TBtu or 0.003 lbs/GWh;

(v) Chromium (Cr): 2.8 lbs/TBtu or 0.03 lbs/GWh;

(vi) Cobalt (Co): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(vii) Lead (Pb): 1.2 lbs/TBtu or 0.02 lbs/GWh;

(viii) Manganese (Mn): 4.0 lbs/TBtu or 0.04 lbs/GWh;

(ix) Nickel (Ni): 3.5 lbs/TBtu or 0.04 lbs/GWh; and

(x) Selenium (Se): 5.0 lbs/TBtu or 0.06 lbs/GWh.

[40 CFR s. 63.9991(a)(1) and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.a., s. 285.65(13), Wis. Stats.]

(2) For boiler B03, the permittee shall comply with ONE of the following:

(a) Hydrogen chloride (HCl) emissions may not exceed: 0.002 lbs/mmBtu or 0.02 lbs/MWh; OR

(b) Sulfur dioxide (SO2) emissions may not exceed: 0.2 lbs/MMBtu or 1.5 lbs/MWh.

(c) The alternate SO2 limit in (b) shall only be used if the EGU:

(i) Has a system using wet or dry flue gas desulfurization technology and SO2 continuous emissions monitoring 

system (CEMS) installed on the unit; and

(ii) The wet or dry flue gas desulfurization technology installed on the unit is operated consistent with 40 CFR 

s. 63.10000(b), at all times.

[40 CFR ss. 63.9991(a)(1) and (c), and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.b., s. 285.65(13), Wis. Stats.]

(3) For boiler B03, mercury emissions may not exceed: 1.2 lbs/TBtu or 0.013 lbs/GWh. [40 CFR s. 63.9991(a)(1) and 40 

CFR, Part 63, Subpart UUUUU, Table 2, condition 1.c., s. 285.65(13), Wis. Stats.]

(4) The emission limits (I.B.7.a.(1) - (3)) and operating limits (I.B.7.b.(4)) in this section apply at all times except during 

periods of startup and shutdown; however, the permittee is required to meet the work practice requirements in conditions 

I.B.7.b. (3) during periods of startup or shutdown. [40 CFR s. 63.10000(a), s. 285.65(13), Wis. Stats.]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 49

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

a. Limitations:

{...Continued from previous page...}

(5) The original compliance date for the requirements of this section is April 16, 2015. The department approved an extension 

of the compliance date to April 16, 2016 provided the following terms and conditions are met:35

(a) The extension to April 16, 2016 is allowed in order to install and achieve system design performance for a multipollutant control technology, Regenerative Activated Coke Technology (ReACT) for boiler B03.

(b) The department is granting extension of the compliance date until April 16, 2016. The request cites the following 

current project schedule:

(i) June 17, 2013 – Acquisition of construction permit from department.

(ii) October 3, 2013 – Groundbreaking for ReACT equipment installation.

(iii) April 22, 2016 – Hot commissioning of system to meet minimum performance standards.

(iv) June 1, 2016 – Commercial operation date.

(v) June 1 – December 31, 2016 – Continued activated coke conditioning to achieve design performance 

standards.

(vi) December 31, 2016 – Final compliance with 40 CFR Part 63, Subpart UUUUU.

(c) To minimize emissions during the extension period Wisconsin Public Service Corporation shall pursue the following 

guidelines:

(i) The boiler, when firing coal, shall fire only subbituminous coal to minimize emissions of hydrochlorid acid and 

other acid gas emissions.

(ii) The boiler, when firing coal, shall be operated according to current operation permit restrictions.

(iii) The boiler, when firing coal, shall optimize mercury reduction to the extent practicable taking into consideration 

other permit limitations (e.g., particulate matter) using the existing activated carbon injection system.

(iv) The boiler shall be dispatched in a manner consistent with current MISO requirements.

(d) Within 30 days of achieving final compliance, submit to the Department, notification that final compliance has been 

achieved.

(e) This extension is limited to a maximum of one year in duration and expires no later than April 16, 2016.

(f) This extension is authorized under s. NR 460.05(7)(g), Wis. Adm. Code, s. 112(i)(3) of the Clean Air Act, and 40 CFR 

63.6(i)(9). Failure to satisfy any of the above terms and conditions may result in termination of the compliance 

extension, in part or whole, pursuant to s. NR 460.05(7)(L), Wis. Adm. Code, and 40 CFR 63.6(i)(14). 

(g) Any initial performance tests and other activities are also extended by this approval and shall be completed within 180 

days after the extended compliance date, as provided under ss. NR 460.05(7)(h)4. And 460.06(1)(b), Wis. Adm. Code 

and 40 CFR s. 63.6(i)(10)(iv) and 63.9984(f).

[40 CFR, ss. 63.9982(a)(1), 63.9982(d), and 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), 

Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall 

demonstrate that compliance with 

40 CFR, Part 63, Subpart 

UUUUU has been achieved, by 

conducting the required 

performance tests and other 

activities, no later than 180 days 

after the compliance date in 

I.B.7.a.(5). [40 CFR s. 

63.9984(f), s. 285.65(13), Wis. 

Stats.]

(1) Initial Performance Testing Requirements: Initial performance testing is required for 

all pollutants, to demonstrate compliance with the applicable emission limits in section 

I.B.7.a.

(a) The permittee may conduct the initial performance testing in accordance with 40 CFR 

s. 63.10005(h), to determine whether the unit(s) qualifies as a low emitting EGU (LEE) 

for one or more applicable emissions limits, except if the EGU is equipped with an acid 

gas scrubber and has a main stack and bypass stack exhaust configuration.

(b) For a qualifying LEE for Hg emissions limits, the permitee must conduct a 30-day 

performance test using Method 30B at least once every 12 calendar months to 

demonstrate continued LEE status.

{continued on next page...}

 35 See Approval of NESHAP Compliance Extension Request letter from K. Hart of the department to P. Spicer of Wisconsin 

Public Service Corporation dated February 11, 2014 and Addendum letter from K. Hart of the department to P Spicer of 

Wisconsin Public Service Corporation dated February 27, 2014.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 50

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

The permittee shall conduct a tune-up of the EGU burner and 

combustion controls at least each 36 calendar months, or 

each 48 calendar months if neural network combustion 

optimization software is employed, as specified in 40 CFR 

s. 63.10021(e). [40 CFR s. 63.9991(a)(1) and 40 CFR, Part 

63, Subpart UUUUU, Table 3, condition 1.]

(a) Periodic tune-ups of the EGU(s) shall be performed as 

part of the demonstration of continuous compliance [40 CFR 

s. 63.10000(e)]

(b) The permittee shall perform the first tune-up as part of 

the initial compliance demonstration. Notwithstanding this 

requirement, the permittee may delay the first burner 

inspection until the next scheduled unit outage provided the 

requirements of 40 CFR s. 63.10005 are met. [40 CFR s. 

63.10021(e)]

(c) Subsequently, an inspection of the burner shall be 

performed at least once every 36 calendar months unless the 

EGU employs neural network combustion optimization 

during normal operations in which case an inspection of the 

burner and combustion controls shall be performed at least 

once every 48 calendar months.

(d) Tune-ups shall consist of the following:

(i) As applicable, inspect the burner and combustion 

controls, and clean or replace any components of the 

burner or combustion controls as necessary upon 

initiation of the work practice program and at least once 

every required inspection period. Repair of a burner or 

combustion control component requiring special order 

parts may be scheduled as follows:

a) Burner or combustion control component parts 

needing replacement that affect the ability to optimize 

NOX and CO must be installed within 3 calendar 

months after the burner inspection,

b) Burner or combustion control component parts that 

do not affect the ability to optimize NOX and CO may 

be installed on a schedule determined by the operator;

(ii) As applicable, inspect the flame pattern and make any 

adjustments to the burner or combustion controls 

necessary to optimize the flame pattern. The adjustment 

should be consistent with the manufacturer's 

specifications, if available, or in accordance with best 

combustion engineering practice for that burner type;

(iii) As applicable, observe the damper operations as a 

function of mill and/or cyclone loadings, cyclone and 

pulverizer coal feeder loadings, or other pulverizer and 

coal mill performance parameters, making adjustments 

and effecting repair to dampers, controls, mills, 

pulverizers, cyclones, and sensors;

{continued on next page...}

(1) Initial Performance Testing Requirements: {...continued from previous page...}

(c) For a qualifying LEE of any other applicable emissions 

limits, the permittee must conduct a performance test at least 

once every 36 calendar months to demonstrate continued LEE 

status.

(d) If an EGU does not qualify as a LEE for total non-mercury 

HAP metals, individual non-mercury HAP metals, or filterable 

particulate matter (PM), the permitee shall demonstrate 

compliance through an initial performance test and shall 

monitor continuous performance through either use of a 

particulate matter continuous parametric monitoring system 

(PM CPMS), a PM CEMS, or, for an existing EGU, 

compliance performance testing repeated quarterly.

(i) If using PM CPMS, the permittee shall establish a sitespecific operating limit corresponding to the results of the 

performance test demonstrating compliance with the 

pollutant with which you choose to comply: total nonmercury HAP metals, individual non-mercury HAP metals or 

filterable PM. The permittee shall use the PM CPMS to 

demonstrate continuous compliance with this operating limit. 

If electing to use a PM CPMS, the permittee shall repeat the 

performance test annually for the selected pollutant limit and 

reassess and adjust the site-specific operating limit in 

accordance with the results of the performance test.

(ii) The permittee may also opt to install and operate a 

particulate matter CEMS certified in accordance with 

Performance Specification 11 and Procedure 2 of 40 CFR 

part 60, Appendices B and F, respectively, in accordance 

with 40 CFR s. 63.10010(i).

(e) If an EGU does not qualify as a LEE for hydrogen chloride 

(HCl), the permittee may demonstrate initial and continuous 

compliance through use of an HCl CEMS, installed and 

operated in accordance with Appendix B to 40 CFR, Part 63, 

Subpart UUUUU. As an alternative to HCl CEMS, the 

permittee may demonstrate initial and continuous compliance 

by conducting an initial and periodic quarterly performance 

stack test for HCl. If an EGU uses wet or dry flue gas 

desulfurization technology (this includes limestone injection 

into a fluidized bed combustion unit), the permittee may apply 

a second alternative to HCl CEMS by installing and operating 

a sulfur dioxide (SO2) CEMS installed and operated in 

accordance with 40 CFR Part 75 to demonstrate compliance 

with the applicable SO2 emissions limit.

(f) If an EGU does not qualify as a LEE for Hg, the permittee 

shall demonstrate initial and continuous compliance through 

use of a Hg CEMS or a sorbent trap monitoring system, in 

accordance with Appendix A to 40 CFR, Part 63, Subpart 

UUUUU.

[40 CFR s. 63.10000(c)(1), s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 51

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(iv) As applicable, evaluate windbox pressures and 

air proportions, making adjustments and effecting 

repair to dampers, actuators, controls, and sensors;

(v) Inspect the system controlling the air-to-fuel ratio 

and ensure that it is correctly calibrated and 

functioning properly. Such inspection may include 

calibrating excess O2 probes and/or sensors, 

adjusting overfire air systems, changing software 

parameters, and calibrating associated actuators and 

dampers to ensure that the systems are operated as 

designed. Any component out of calibration, in or 

near failure, or in a state that is likely to negate 

combustion optimization efforts prior to the next 

tune-up, should be corrected or repaired as necessary;

(vi) Optimize combustion to minimize generation of 

CO and NOX . This optimization should be consistent 

with the manufacturer's specifications, if available, or 

best combustion engineering practice for the 

applicable burner type. NOX optimization includes 

burners, overfire air controls, concentric firing 

system improvements, neural network or combustion 

efficiency software, control systems calibrations, 

adjusting combustion zone temperature profiles, and 

add-on controls such as SCR and SNCR; CO 

optimization includes burners, overfire air controls, 

concentric firing system improvements, neural 

network or combustion efficiency software, control 

systems calibrations, and adjusting combustion zone 

temperature profiles;

(vii) While operating at full load or the 

predominantly operated load, measure the 

concentration in the effluent stream of CO and NOX

in ppm, by volume, and oxygen in volume percent, 

before and after the tune-up adjustments are made 

(measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the 

adjustments are made). You may use portable CO, 

NOX and O2 monitors for this measurement. EGU's 

employing neural network optimization systems need 

only provide a single pre- and post-tune-up value 

rather than continual values before and after each 

optimization adjustment made by the system;

{continued on next page...}

(2) Subsequent Performance Tests and Tune-Ups:

(a) For EGUs using PM CPMS to monitor continuous performance 

with an applicable emission limit as provided for under 40 CFR 

s. 63.10000(c) (see condition I.B.7.c.(1)), you must conduct all 

applicable performance tests according to Table 5 to 40 CFR Part 

63, Subpart UUUUU and 40 CFR s. 63.10007 at least every year. 

[40 CFR s. 63.10006(a)]

(b) For EGUs meeting the LEE requirements of 40 CFR 

s. 63.10005(h) (see condition I.B.7.b.(4)(h)), the performance test 

shall be repeated once every 3 years (once every year for Hg) 

according to Table 5 and 40 CFR s. 63.10007. Should subsequent 

emissions testing results show the unit does not meet the LEE 

eligibility requirements, LEE status is lost. If this should occur:

(i) For all pollutant emission limits except for Hg, the permittee 

shall conduct emissions testing quarterly, except as otherwise 

provided in 40 CFR s. 63.10021(d)(1).

(ii) For Hg, the permittee shall install, certify, maintain, and 

operate a Hg CEMS or a sorbent trap monitoring system in 

accordance with Appendix A to 40 CFR, Part 63, Subpart 

UUUUU, within 6 calendar months of losing LEE eligibility. 

Until the Hg CEMS or sorbent trap monitoring system is 

installed, certified, and operating, the permittee shall conduct Hg 

emissions testing quarterly, except as otherwise provided in 40 

CFR s. 63.10021(d)(1). You must have 3 calendar years of 

testing and CEMS or sorbent trap monitoring system data that 

satisfy the LEE emissions criteria to reestablish LEE status.

[40 CFR s. 63.10006(b)]

(c) Except where paragraphs (a) or (b) of this condition apply, or

where the permittee installs, certifies, and operates a PM CEMS to 

demonstrate compliance with a filterable PM emissions limit, the 

permittee shall conduct all applicable periodic emissions tests for 

filterable PM, individual, or total HAP metals emissions according 

to Table 5 to Subpart UUUUU, 40 CFR s. 63.10007, and s. 

63.10000(c), except as otherwise provided in s. 63.10021(d)(1).

(d) Except where paragraph (b) of this section applies, for coalfired EGUs that do not use either an HCl CEMS to monitor 

compliance with the HCl limit or an SO2 CEMS to monitor 

compliance with the alternate equivalent SO2 emission limit, the 

permittee shall conduct all applicable periodic HCl emissions tests 

according to Table 5 to Subpart UUUUU and 40 CFR s. 63.10007 

at least quarterly, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). [40 CFR s. 63.10006(d)]

(e) {reserved}

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 52

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the 

information in paragraphs (d)(i) through (ix) of this 

condition, including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume 

percent, measured before and after an adjustment of 

the EGU combustion systems;

b) A description of any corrective actions taken as a 

part of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if 

the unit was physically and legally capable of using 

more than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tuneups as follows:

a) If the first required tune-up is performed as part of 

the initial compliance demonstration, report the date 

of the tune-up in hard copy (as specified in 40 CFR 

s. 63.10030) and electronically (as specified in 40 

CFR s. 63.10031). Report the date of each 

subsequent tune-up electronically (as specified in 40 

CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the 

initial compliance demonstration, but is postponed 

until the next unit outage, report the date of that tuneup and all subsequent tune-ups electronically, in 

accordance with 40 CFR s. 63.10031.

[40 CFR s. 63.10021(e), s. 285.65(13), Wis. Stats.]

(3) Monitoring During Startup and Shutdown:

(a) The permittee shall operate all CMS during startup 

and shutdown. 

(b) Startup means either the first-ever firing of fuel in a 

boiler for the purpose of producing electricity, or the 

firing of fuel in a boiler after a shutdown event for any 

purpose. 

(i) Startup ends when any of the steam from the boiler 

is used to generate electricity for sale over the grid or 

for any other purpose (including on site use). 

(ii) For startup of a unit, clean fuels shall be used, 

either natural gas or distillate oil or a combination of 

clean fuels for ignition. 

(iii) Once the EGU is converted to firing coal, all of the 

applicable control technologies except dry scrubber and 

SCR shall be engaged. 

(2) Subsequent Performance Tests and Tune-Ups:

{... continued from previous page...}

(f) Unless following the requirements listed in paragraphs (g) and 

(h) of this condition, subsequent performance tests shall be 

conducted as follows:

(i) performance tests required at least every 3 calendar years 

must be completed within 35 to 37 calendar months after the 

previous performance test; 

(ii) performance tests required at least every year must be 

completed within 11 to 13 calendar months after the previous 

performance test; and 

(iii) performance tests required at least quarterly must be 

completed within 80 to 100 calendar days after the previous 

performance test, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). 

[40 CFR s. 63.10006(f)]

(g) If electing to demonstrate compliance using emissions 

averaging under 40 CFR s. 63.10009, the permittee shall continue 

to conduct performance stack tests at the appropriate frequency 

given in section (c) through (f) of this section. [40 CFR s. 

63.10006(g)]

(h) If a performance test on a non-mercury LEE shows emissions 

in excess of 50 percent of the emission limit and if the permittee 

chooses to reapply for LEE status, the permittee shall conduct 

performance tests at the appropriate frequency given in paragraphs 

(c) through (e) of this condition for that pollutant until all 

performance tests over a consecutive 3-year period show 

compliance with the LEE criteria. [40 CFR s. 63.10006(h)]

(i) The permittee shall conduct performance tune-ups according to 

40 CFR s. 63.10021(e), as follows:

(i) For EGUs not employing neural network combustion 

optimization during normal operation, each performance tune-up 

specified in 40 CFR s. 63.10021(e) must be no more than 36 

calendar months after the previous performance tune-up.

(ii) For EGUs employing neural network combustion 

optimization systems during normal operation, each 

performance tune-up specified in 40 CFR s. 63.10021(e) must 

be no more than 48 calendar months after the previous 

performance tune-up.

[40 CFR s. 63.10006(i)]

(j) The permittee shall report the results of performance tests and 

performance tune-ups within 60 days after the completion of the 

performance tests and performance tune-ups. The reports for all 

subsequent performance tests must include all applicable 

information required in 40 CFR s. 63.10031. [40 CFR s. 

63.10006(j)]

[40 CFR s. 63.10006, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 53

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) Monitoring During Startup and Shutdown:

(b) {...continued from previous page...}

(iv) Any dry scrubber and SCR systems, if present, shall 

be started appropriately to comply with relevant standards 

applicable during normal operation. 

(c) Shutdown means the cessation of operation of a boiler for 

any purpose. 

(i) Shutdown begins either when none of the steam from 

the boiler is used to generate electricity for sale over the 

grid or for any other purpose (including on-site use) or at 

the point of no fuel being fired in the boiler. 

(ii) Shutdown ends when there is both no electricity being 

generated and no fuel being fired in the boiler.

(iii) During shutdown, all applicable control technologies 

shall be operated, while firing coal. 

(d) The EGU(s) shall comply with all applicable emissions 

limits at all times except for periods that meet the definitions 

of startup and shutdown in 40 CFR Part 63, Subpart 

UUUUU. 

(e) The permittee shall keep records during periods of startup 

and shutdown. 

(f) The permittee shall provide reports concerning activities 

and periods of startup and shutdown, as specified in 40 CFR 

ss. 63.10011(g) and 63.10021(h) and (i).

[40 CFR s. 63.9991(a)(1) and 40 CFR, Part 63, Subpart 

UUUUU, Table 3, conditions 3 and 4., s. 285.65(13), Wis. 

Stats.]

(4) Operating Limits: The permittee shall meet the 

applicable operating limit in Table 4 to Subpart UUUUU as 

follows:

(a) If demonstrating compliance using a PM CPMS, 

maintain the 30-boiler operating day rolling average PM 

CPMS output at or below the highest 1-hour average 

measured during the most recent performance test 

demonstrating compliance with the filterable PM, total nonmercury HAP metals (total HAP metals, for liquid oil-fired 

units), or individual non-mercury HAP metals (individual 

HAP metals including Hg, for liquid oil-fired units) 

emissions limitation(s).

(b) The operating limits apply at all times except during 

periods of startup and shutdown; however, the permittee is 

required to meet the work practice requirements in 

conditions I.B.7.b. (3) during periods of startup or shutdown. 

[40 CFR s. 63.9991(a)(2), s. 63.10000(a), and Table 4 to 40 

CFR, Part 63, Subpart UUUUU, s. 285.65(13), Wis. Stats.]

(3) Performance Tests – Methods and Other Procedures:

(a) Except as otherwise provided in this condition, the 

permittee shall conduct all required performance tests 

according to 40 CFR s. 63.7(d), (e), (f), and (h). The permittee 

shall also develop a site-specific test plan according to the 

requirements in 40 CFR s. 63.7(c).

(i) If using CEMS (Hg, HCl, SO2 , or other) to determine 

compliance with a 30-boiler operating day rolling average 

emission limit, you must collect data for all nonexempt unit 

operating conditions (see 40 CFR s. 63.10011(g) and Table 

3 to 40 CFR, Part 63, Subpart UUUUU).

(ii) If conducting performance testing with test methods in 

lieu of continuous monitoring, operate the unit at maximum 

normal operating load conditions during each periodic (e.g., 

quarterly) performance test. Maximum normal operating 

load will be generally between 90 and 110 percent of design 

capacity but should be representative of site specific normal 

operations during each test run.

(iii) For establishing operating limits with particulate matter 

continuous parametric monitoring system (PM CPMS) to 

demonstrate compliance with a PM or non Hg metals 

emissions limit, operate the unit at maximum normal 

operating load conditions during the performance test 

period. Maximum normal operating load will be generally 

between 90 and 110 percent of design capacity but should 

be representative of site specific normal operations during 

each test run.

[40 CFR s. 63.10007(a)]

(b) The permittee shall conduct each performance test 

(including traditional 3-run stack tests, 30-boiler operating day 

tests based on CEMS data (or sorbent trap monitoring system 

data), and 30-boiler operating day Hg emission tests for LEE 

qualification) according to the requirements in Table 5 to 40 

CFR, Part 63, Subpart UUUUU. [40 CFR s. 63.10007(b)]

(c) If choosing the filterable PM method to comply with the 

PM

emission limit and demonstrate continuous performance using 

a PM

CPMS as provided for in 40 CFR s. 63.10000(c), the permittee 

shall also establish an operating limit according to 40 CFR s. 

63.10011(b), s. 63.10023, and Tables 4 and 6 to Subpart 

UUUUU. Should the permittee desire to have operating limits 

that correspond to loads other than maximum normal operating 

load, the permittee shall conduct testing at those other loads to 

determine the additional operating limits. [40 CFR s. 

63.10007(c)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 54

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(5) At all times the permittee shall operate and 

maintain B03, including the associated air pollution 

control equipment and monitoring equipment, in a 

manner consistent with safety and good air pollution 

control practices for minimizing emissions. 

Determination of whether such operation and 

maintenance procedures are being used will be based 

on information which may include, but is not limited 

to, monitoring results, review of operation and 

maintenance procedures, review of operation and 

maintenance records, and inspection of the source. 

[40 CFR s. 63.10000(b), s. 285.65(13), Wis. Stats.]

(6) Initial Compliance Requirements: 

(a) General Requirements: For each affected EGU, 

initial compliance with each applicable emission limit 

in section I.B.7.a. shall be demonstrated with 

performance testing. Where two emissions limits are 

specified for a particular pollutant (e.g., a heat inputbased limit in lb/MMBtu and an electrical outputbased limit in lb/MWh), compliance may be 

demonstrated with either emission limit. 

One or more of the following activities may be 

required in conjunction with performance testing, as 

appropriate: collection of hourly electrical load data 

(megawatts); establishment of operating limits 

according to 40 CFR s. 63.10011 and 40 CFR Part 63, 

Subpart UUUUU, Tables 4 and 7; and CMS 

performance evaluations. In all cases, you must 

demonstrate initial compliance no later than the 

applicable date in paragraph (f) of 40 CFR s. 

63.10005 for tune-up work practices for existing 

EGUs, in 40 CFR s. 63.9984. 

(i) To demonstrate initial compliance with an 

applicable emissions limit in section I.B.7.a. of this 

permit using stack testing, the initial performance 

test generally consists of three runs at specified 

process operating conditions using approved 

methods. If required to establish operating limits 

(see paragraph (d) of 40 CFR s. 63.10005 and Table 

4 to 40 CFR Part 63, Subpart UUUUU), the 

permittee shall collect all applicable parametric data 

during the performance test period. Also, if you 

choose to comply with an electrical output-based 

emission limit, you must collect hourly electrical 

load data during the test period.

{continued on next page...}

(3) Performance Tests – Methods and Other Procedures:

{...continued from previous page...}

(d) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, where the concept of 

test runs does not apply, the permittee shall conduct a minimum of 

three separate test runs for each performance test, as specified in 40 

CFR s. 63.7(e)(3). Each test run shall comply with the minimum 

applicable sampling time or volume specified in Table 1 or 2 to 

Subpart UUUUU. Sections 63.10005(d) and (h) of 40 CFR (see 

conditions I.B.7.b.(6)(d) and (h)), respectively, provide special 

instructions for conducting performance tests based on CEMS or 

sorbent trap monitoring systems, and for conducting emission tests for 

LEE qualification. [40 CFR s. 63.10007(d)]

(e) To use the results of performance testing to determine compliance 

with the applicable emission limits in I.B.7.a., proceed as follows:

(i) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, if measurement 

results for any pollutant are reported as below the method 

detection level (e.g., laboratory analytical results for one or more 

sample components are below the method defined analytical 

detection level), the permittee shall use the method detection level 

as the measured emissions level for that pollutant in calculating 

compliance. The measured result for a multiple component 

analysis (e.g., analytical values for multiple Method 29 fractions 

both for individual HAP metals and for total HAP metals) may 

include a combination of method detection level data and 

analytical data reported above the method detection level.

(ii) If the limits are expressed in lb/MMBtu or lb/TBtu, the 

permittee shall use the F-factor methodology and equations in 

sections 12.2 and 12.3 of EPA Method 19 in Appendix A-7 to Part 

60 of 40 CFR. In cases where an appropriate F-factor is not listed 

in Table 19-2 of Method 19, you may use F-factors from Table 1 

in section 3.3.5 of Appendix F to Part 75 of 40 CFR, or F-factors 

derived using the procedures in section 3.3.6 of Appendix to Part 

75 of 40 CFR. Use the following factors to convert the pollutant 

concentrations measured during the initial performance tests to 

units of lb/scf, for use in the applicable Method 19 equations:

a) Multiply SO2 ppm by 1.66 × 10−7 ;

b) Multiply HCl ppm by 9.43 × 10−8 ;

c) Multiply HF ppm by 5.18 × 10−8 ;

d) Multiply HAP metals concentrations (mg/dscm) by 6.24 × 

10−8 ; and

e) Multiply Hg concentrations (μg/scm) by 6.24 × 10−11 .

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 55

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(a) {...continued from previous page...}

(ii) To demonstrate initial compliance using either a CMS that 

measures HAP concentrations directly (i.e., an Hg, HCl, or HF 

CEMS, or a sorbent trap monitoring system) or an SO2 or PM 

CEMS, the initial performance test consists of 30 boiler operating 

days of data collected by the initial compliance demonstration date 

specified in 40 CFR s. 63.10005 with the certified monitoring 

system.

a) The 30-boiler operating day CMS performance test must 

demonstrate compliance with the applicable Hg, HCl, HF, PM, or 

SO2 emissions limit in Table 1 or 2 to this subpart.

b) If you choose to comply with an electrical output-based 

emission limit, you must collect hourly electrical load data during 

the performance test period.

[40 CFR s. 63.10005(a)]

(b) Performance testing requirements: If using performance testing to 

demonstrate initial compliance with the applicable emissions limits in 

section I.B.7.a. of this permit, the permittee shall conduct the tests 

according to 40 CFR s. 63.10007 and Table 5 to 40 CFR Part 63, 

Subpart UUUUU. For the purposes of the initial compliance 

demonstration, test data and results from a performance test conducted 

prior to the compliance date in I.B.7.a.(5), may be used provided that 

the following conditions are fully met:

(i) For a performance test based on stack test data, the test was 

conducted no more than 12 calendar months prior to the compliance 

date in I.B.7.a.(5);

(ii) For a performance test based on data from a certified CEMS or 

sorbent trap monitoring system, the test consists of all valid CMS 

data recorded in the 30 boiler operating days immediately preceding 

the compliance date in I.B.7.a.(5);

(iii) The performance test was conducted in accordance with all 

applicable requirements in 40 CFR s. 63.10007 and Table 5 to 40 

CFR Part 63 Subpart UUUUU;

(iv) A record of all parameters needed to convert pollutant 

concentrations to units of the emission standard (e.g., stack flow rate, 

diluent gas concentrations, hourly electrical loads) is available for 

the entire performance test period; and

(v) For each performance test based on stack test data, the permittee 

certifies, and keeps documentation demonstrating, that the EGU 

configuration, control devices, and fuel(s) have remained consistent 

with conditions since the prior performance test was conducted.

[40 CFR s. 63.10005(b)]

(c) Operating limits: In accordance with 40 CFR s. 63.10010 and 

Table 4 to 40 CFR Part 63, Subpart UUUUU, the permitee may be 

required to establish operating limits using PM CPMS as part of the 

initial compliance demonstration. [40 CFR s. 63.10005(c)]

(3) Performance Tests – Methods and Other Procedures:

(e) {...continued from previous page...}

(iii) To determine compliance with emission 

limits expressed in lb/MWh or lb/GWh, the 

permittee shall first calculate the pollutant mass 

emission rate during the performance test, in units 

of lb/h. For Hg, if a CEMS or sorbent trap 

monitoring system is used, use Equation A-2 or 

A-3 in Appendix A to 40 CFR, Part 63, Subpart 

UUUUU (as applicable). In all other cases, use an 

equation that has the general form of Equation A2 or A-3, replacing the value of K with 1.66 × 

10−7 lb/scf-ppm for SO2 , 9.43 × 10−8 lb/scf-ppm 

for HCl (if an HCl CEMS is used), or 6.24 × 10−8

lb-scm/mg-scf for HAP metals and for HCl (when 

performance stack testing is used), and defining 

Ch as the average SO2 or HCl concentration in 

ppm, or the average HAP metals concentration in 

mg/dscm. This calculation requires stack gas 

volumetric flow rate (scfh) and (in some cases) 

moisture content data (see 40 CFR 

ss. 63.10005(h)(3) and 63.10010). Then, if the 

applicable emission limit is in units of lb/GWh, 

use Equation A-4 in Appendix A to Subpart 

UUUUU to calculate the pollutant emission rate 

in lb/GWh. In this calculation, define (M)h as the 

calculated pollutant mass emission rate for the 

performance test (lb/h), and define (MW)h as the 

average electrical load during the performance 

test (megawatts). If the applicable emission limit 

is in lb/MWh rather than lb/GWh, omit the 103

term from Equation A-4 to determine the 

pollutant emission rate in lb/MWh.

[40 CFR s. 63.10007(e)]

(f) Upon request, the permittee shall make available 

to the department such records as may be necessary 

to determine whether the performance tests have 

been done according to the requirements of this 

section. [40 CFR s. 63.10007(f)]

[40 CFR s. 63.10007, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 56

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(d) CMS requirement: If required to (or electing to) 

demonstrate initial compliance using a continuous 

monitoring system, the CMS must pass a performance 

evaluation prior to the initial compliance 

demonstration. If a CMS has been previously certified 

under another state or federal program and is 

continuing to meet the on-going quality-assurance 

(QA) requirements of that program, then, provided 

that the certification and QA provisions of that 

program meet the applicable requirements of 40 CFR 

ss. 63.10010(b) through (h), an additional 

performance evaluation of the CMS is not required.

(i) The permittee may demonstrate initial 

compliance with the applicable SO2 or HCl, 

emissions limit in condition I.B.7.a.(2) through use 

of an SO2 or HCl CEMS installed and operated in 

accordance with 40 CFR, Part 75 or 40 CFR, Part 

63, Subpart UUUUU, Appendix B, as applicable. 

The permittee may demonstrate compliance with a 

filterable PM emission limit in condition I.B.7.a.(1)

(a) through use of a PM CEMS installed, certified, 

and operated in accordance with 40 CFR 

s. 63.10010(i). Initial compliance is achieved if the 

arithmetic average of 30-boiler operating days of 

quality-assured CEMS data, expressed in units of 

the standard (see 40 CFR s. 63.10007(e)), meets the 

applicable SO2, PM, or HCl emissions limit in 

section I.A.7.a. of this permit. Use Equation 19-19 

of Method 19 in Appendix A-7 to 40 CFR, Part 60 

to calculate the 30-boiler operating day average 

emissions rate. (NOTE: For this calculation, the term 

Ehj in Equation 19-19 must be in the same units of 

measure as the applicable HCl emission limit in 

condition I.B.7.a.(2) (a).

(ii) When demonstrating compliance with the 

applicable emission limits for total non-mercury 

HAP metals, individual non-mercury HAP metals, 

total HAP metals, individual HAP metals, or 

filterable PM in section I.B.7.a. of this permit using 

initial performance testing and continuous 

monitoring with PM CPMS, the permittee shall:

a) Demonstrate initial compliance no later than 

180 days after the compliance date in I.B.7.a.(5); 

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(a) If demonstrating compliance with any applicable emissions limit 

through use of a continuous monitoring system (CMS), where a CMS 

includes a continuous parameter monitoring system (CPMS) as well 

as a continuous emissions monitoring system (CEMS), the permitee 

shall develop a site-specific monitoring plan and submit this sitespecific monitoring plan, if requested, at least 60 days before the 

initial performance evaluation (where applicable) of your CMS. The 

requirement to develop and submit a site-specific monitoring plan 

does not apply to affected sources with existing monitoring plans that 

apply to CEMS and CPMS prepared under Appendix B to 40 CFR 

Part 60 or Part 75, and that meet the requirements of 40 CFR 

s. 63.10010. (The permittee may use the process described in 

§ 63.8(f)(4), to request approval of monitoring system quality 

assurance and quality control procedures alternative to those specified 

in this condition and, if approved, include those in the site-specific 

monitoring plan.) The monitoring plan shall address the provisions in 

(b) through (e) below.

(b) The site-specific monitoring plan shall include the information 

specified in condition (e), below. Alternatively, the requirements of 

condition (e) are considered to be met for a particular CMS or sorbent 

trap monitoring system if:

(i) The CMS or sorbent trap monitoring system is installed, 

certified, maintained, operated, and quality-assured either 

according to 40 CFR, Part 75, or Appendix A or B to 40 CFR, Part 

63, Subpart UUUUU; and

(ii) The recordkeeping and reporting requirements of 40 CFR, Part 

75, or Appendix A or B to 40 CFR, Part 63, Subpart UUUUU, that 

pertain to the CMS are met.

(c) If requested by the department, the permittee shall submit the 

monitoring plan (or relevant portion of the plan) at least 60 days 

before the initial performance evaluation of a particular CMS, except 

where the CMS has already undergone a performance evaluation that 

meets the requirements of 40 CFR s. 63.10010 (e.g., if the CMS was 

previously certified under another program).

(d) The permittee shall operate and maintain the CMS according to 

the site-specific monitoring plan.

(e) The provisions of the site-specific monitoring plan shall address 

the following items:

(i) Installation of the CMS or sorbent trap monitoring system 

sampling probe or other interface at a measurement location 

relative to each affected process unit such that the measurement is 

representative of control of the exhaust emissions (e.g., on or 

downstream of the last control device). See 40 CFR s. 63.10010(a) 

for further details. For PM CPMS installations, follow the 

procedures in 40 CFR s. 63.10010(h).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 57

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(d)(ii) {...continued from previous page...}

b) Demonstrate continuous compliance with the 

PM CPMS site-specific operating limit that 

corresponding to the results of the performance test 

demonstrating compliance with the emission limit 

with which the permittee has chosen to comply; 

and

c) Repeat the performance test annually for the 

selected pollutant emissions limit and reassess and 

adjust the site-specific operating limit in 

accordance with the results of the performance test.

(iii) When demonstrating compliance with the Hg 

emission limit in I.B.7.a.(3) using Hg CEMS or 

sorbent trap monitoring systems, initial compliance 

shall be demonstrated no later than 180 days after the 

compliance date in I.B.7.a.(5). Initial compliance is 

achieved if the arithmetic average of 30-boiler 

operating days of quality-assured CEMS (or sorbent 

trap monitoring system) data, expressed in units of 

the standard (see section 6.2 of Appendix A to 40 

CFR, Part 63, Subpart UUUUU), meets the 

applicable Hg emission limit in I.B.7.a.(3).

[40 CFR s. 63.10005(d)]

(e) Tune-ups: As part of the initial compliance 

demonstration, the permittee shall conduct a 

performance tune-up of each EGU according to 40 

CFR s. 63.10021(e). [40 CFR s. 63.10005(e)]

(f) For existing affected sources a tune-up may occur 

prior to April 16, 2012, so that existing sources without 

neural networks have up to 42 calendar months (3 

years from promulgation plus 180 days) or, in the case 

of units employing neural network combustion 

controls, up to 54 calendar months (48 months from 

promulgation plus 180 days) after the date that is 

specified for your source in 40 CFR s. 63.9984 and 

according to the applicable provisions in s. 63.7(a)(2) 

as cited in Table 9 to Subpart UUUUU to demonstrate 

compliance with this requirement. If a tune-up occurs 

prior to such date, the source must maintain adequate 

records to show that the tune-up met the requirements 

of this standard. [40 CFR s. 63.10005(f)]

(g) {reserved}

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(e) {...continued from previous page...}

(ii) Performance and equipment specifications for the sample 

interface, the pollutant concentration or parametric signal 

analyzer, and the data collection and reduction systems.

(iii) Schedule for conducting initial and periodic performance 

evaluations.

(iv) Performance evaluation procedures and acceptance criteria 

(e.g., calibrations), including the quality control program in 

accordance with the general requirements of 40 CFR s. 63.8(d).

(v) On-going operation and maintenance procedures, in 

accordance with the general requirements of 40 CFR 

ss. 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii).

(vi) Conditions that define a CMS that is out of control consistent 

with 40 CFR s. 63.8(c)(7)(i) and for responding to out of control 

periods consistent with 40 CFR ss. 63.8(c)(7)(ii) and (c)(8).

(vii) On-going recordkeeping and reporting procedures, in 

accordance with the general requirements of 40 CFR ss. 63.10(c), 

(e)(1), and (e)(2)(i), or as specifically required under 40 CFR, 

Part 63, Subpart UUUUU.

[40 CFR s. 63.10000(d), s. 285.65(13), Wis. Stats.]

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(a) For the CEMS, PM CPMS, and sorbent trap monitoring systems 

used to provide data under 40 CFR, Part 63, Subpart UUUUU, the 

permittee shall comply with the continuous monitoring system 

installation requirements for the appropriate exhaust configurations 

as required by 40 CFR s. 63.10010(a). (Exhaust configurations 

include but are not limited individual stacks, a common stack 

configuration or a main stack plus a bypass stack.) [40 CFR s. 

63.10010(a)]

(b) If using an oxygen (O2 ) or carbon dioxide (CO2 ) CEMS to 

convert measured pollutant concentrations to the units of the 

applicable emissions limit, the O2 or CO2 concentrations shall be 

monitored at a location that represents emissions to the atmosphere, 

i.e., at the outlet of the EGU, downstream of all emission control 

devices. The permittee shall install, certify, maintain, and operate the 

CEMS according to Part 75 of 40 CFR. Use only quality-assured O2

or CO2 data in the emissions calculations; do not use Part 75 

substitute data values. [40 CFR s. 63.10010(b)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 58

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(h) Low emitting EGUs: The provisions of this 

paragraph (h) apply to all pollutants with emissions 

limits from existing EGUs. This compliance option 

may not be pursued, if for EGUs equipped with an 

acid gas scrubber and with a main stack and bypass 

stack exhaust configuration.

(i) An EGU may qualify for low emitting EGU 

(LEE) status for Hg, HCl, filterable PM, total nonHg HAP metals, or individual non-Hg HAP metals 

if performance test data is collected that meets the 

requirements of this paragraph (h), and if those data 

demonstrate:

a) For all pollutants except Hg, performance test 

emissions results less than 50 percent of the 

applicable emissions limits in I.B.7.a. for all 

required testing for 3 consecutive years; or

b) For Hg emissions, either: 

1) Average emissions less than 10 percent of 

the applicable Hg emissions limit in I.B.7.a.(3)

(expressed either in units of lb/TBtu or 

lb/GWh); or 

2) Potential Hg mass emissions of 29.0 or fewer 

pounds per year and compliance with the 

applicable Hg emission limit in I.B.7.a.(3)

(expressed either in units of lb/TBtu or 

lb/GWh).

(ii) For all pollutants except Hg, the permittee shall 

conduct all required performance tests described in 

40 CFR s. 63.10007 to demonstrate that a unit 

qualifies for LEE status.

a) When conducting emissions testing to 

demonstrate LEE status, the permittee shall 

increase the minimum sample volume specified in 

Table 1 or 2 to 40 CFR, Part 63, Subpart UUUUU 

nominally by a factor of two.

b) Follow the instructions in 40 CFR 

s. 63.10007(e) and Table 5 to Subpart UUUUU to 

convert the test data to the units of the applicable 

standard.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

{...continued from previous page...}

(c) If required to use a stack gas flow rate monitor, either for routine 

operation of a sorbent trap monitoring system or to convert pollutant 

concentrations to units of an electrical output-based emission standard 

in Table 1 or 2 to Subpart UUUUU, the permittee shall install, certify, 

operate, and maintain the monitoring system and conduct on-going 

quality-assurance testing of the system according to Part 75 of 40 

CFR. Use only unadjusted, quality-assured flow rate data in the 

emissions calculations. Do not apply bias adjustment factors to the 

flow rate data and do not use substitute flow rate data in the 

calculations. [40 CFR s.63.10010(c)]

(d) If required to make corrections for stack gas moisture content 

when converting pollutant concentrations to the units of an emission 

standard in Table 1 of 2 to Subpart UUUUU, the permittee shall 

install, certify, operate, and maintain a moisture monitoring system in 

accordance with Part 75 of 40 CFR. Alternatively, for coal-fired units, 

appropriate fuel-specific default moisture values from 40 CFR 

s. 75.11(b) may be used to estimate the moisture content of the stack 

gas. If a moisture monitoring system is installed and operated, do not 

use substitute moisture data in the emissions calculations. [40 CFR s. 

63.1001(d)]

(e) If using an HCl CEMS, the permittee shall install, certify, operate, 

maintain, and quality-assure the data from the monitoring system in 

accordance with Appendix B to Subpart UUUUU. Calculate and 

record a 30-boiler operating day rolling average HCl emission rate in 

the units of the standard, updated after each new boiler operating day. 

Each 30-boiler operating day rolling average emission rate is the 

average of all the valid hourly HCl emission rates in the preceding 30 

boiler operating days (see section 9.4 of Appendix B to Subpart 

UUUUU). [40 CFR s. 63.10010(e)]

(f)(i) If using an SO2 CEMS, the permittee shall install the monitor at 

the outlet of the EGU, downstream of all emission control devices, 

and shall certify, operate, and maintain the CEMS according to 

Part 75 of 40 CFR.

(ii) For on-going QA, the SO2 CEMS shall meet the applicable 

daily, quarterly, and semiannual or annual requirements in sections 

2.1 through 2.3 of Appendix B to Part 75 of 40 CFR, with the 

following addition: The permittee shall perform the linearity 

checks required in section 2.2 of Appendix B to Part 75 of 40 CFR 

if the SO2 CEMS has a span value of 30 ppm or less.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 59

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h) {...continued from previous page...}

(iii) For Hg, the permittee shall conduct a 30-boiler 

operating day performance test using Method 30B 

in Appendix A-8 to 40 CFR Part 60 to determine 

whether a unit qualifies for LEE status. Locate the 

Method 30B sampling probe tip at a point within the 

10 percent centroidal area of the duct at a location 

that meets Method 1 in Appendix A-1 to 40 CFR 

Part 60 and conduct at least three nominally equal 

length test runs over the 30-boiler operating day test 

period. Collect Hg emissions data continuously over 

the entire test period (except when changing sorbent 

traps or performing required reference method QA 

procedures), under all process operating conditions. 

The permittee may use a pair of sorbent traps to 

sample the stack gas for no more than 10 days.

a) Depending on whether LEE status for Hg is 

assessed in terms of the lb/TBtu or lb/GWh 

emission limit in I.B.7.a.(3) or in terms of the 

annual Hg mass emissions limit of 29.0 lb/year, 

the permittee shall collect some or all of the 

following data during the 30-boiler operating day 

test period (see paragraph (h)(iii)c) of this 

condition):

1) Diluent gas (CO2 or O2 ) data, using either 

Method 3A in Appendix A-3 to Part 60 of 40 

CFR or a diluent gas monitor that has been 

certified according to Part 75 of 40 CFR.

2) Stack gas flow rate data, using either Method 

2, 2F, or 2G in Appendices A-1 and A-2 to Part 

60 of 40 CFR, or a flow rate monitor that has 

been certified according to Part 75 of 40 CFR.

3) Stack gas moisture content data, using either 

Method 4 in Appendix A-1 to Part 60 of 40 

CFR, or a moisture monitoring system that has 

been certified according to Part 75 of 40 CFR. 

Alternatively, an appropriate fuel-specific 

default moisture value from 40 CFR s. 75.11(b) 

may be used in the calculations.

4) Hourly electrical load data (megawatts), 

from facility records.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(f) {...continued from previous page...}

(iii) Calculate and record a 30-boiler operating day rolling average 

SO2 emission rate in the units of the standard, updated after each 

new boiler operating day. Each 30-boiler operating day rolling 

average emission rate is the average of all of the valid SO2

emission rates in the preceding 30 boiler operating days.

(iv) Use only unadjusted, quality-assured SO2 concentration values 

in the emissions calculations; do not apply bias adjustment factors 

to the Part 75 SO2 data and do not use Part 75 substitute data 

values.

[40 CFR s. 63.10010(f)]

(g) If using a Hg CEMS or a sorbent trap monitoring system, the 

permittee shall install, certify, operate, maintain and quality-assure 

the data from the monitoring system in accordance with Appendix A 

to Subpart UUUUU. The permittee shall calculate and record a 30-

(or, if alternate emissions averaging is used, 90-) boiler operating day 

rolling average Hg emission rate, in units of the standard, updated 

after each new boiler operating day. Each 30- (or, if alternate 

emissions averaging is used, 90-) boiler operating day rolling average 

emission rate, calculated according to section 6.2 of Appendix A to 

Subpart UUUUU, is the average of all of the valid hourly Hg 

emission rates in the preceding 30- (or, if alternate emissions 

averaging is used, a 90-) boiler operating days. Section 7.1.4.3 of 

Appendix A to Subpart UUUUU explains how to reduce sorbent trap 

monitoring system data to an hourly basis. [40 CFR s. 63.10010(g)]

(h) If using a PM CPMS to demonstrate continuous compliance with 

an operating limit, the permittee shall install, calibrate, maintain, and 

operate the PM CPMS and record the output of the system as follows:

(i) Install, calibrate, operate, and maintain the PM CPMS 

according to the procedures in the approved site-specific 

monitoring plan developed in accordance with 40 CFR s. 

63.10000(d), and meet the requirements the following:

a) The operating principle of the PM CPMS shall be based on 

in-stack or extractive light scatter, light scintillation, beta 

attenuation, or mass accumulation detection of the exhaust gas 

or representative sample. The reportable measurement output 

from the PM CPMS may be expressed as milliamps, stack 

concentration, or other raw data signal.

b) The PM CPMS shall have a cycle time ( i.e. , period 

required to complete sampling, measurement, and reporting 

for each measurement) no longer than 60 minutes.

c) The PM CPMS shall be capable, at a minimum, of 

detecting and responding to particulate matter concentrations 

of 0.5 mg/acm.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 60

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii) {...continued from previous page...}

b) If a CEMS is used to measure CO2 (or O2 ) 

concentration, and/or flow rate, and/or moisture, 

record hourly average values of each parameter 

throughout the 30-boiler operating day test 

period. If opting to use EPA reference methods 

rather than CEMS for any parameter, the 

permittee shall perform at least one 

representative test run on each operating day of 

the test period, using the applicable reference 

method.

c) Calculate the average Hg concentration, in 

μg/m3 (dry basis), for the 30-boiler operating 

day performance test, as the arithmetic average 

of all Method 30B sorbent trap results. Also 

calculate, as applicable, the average values of 

CO2 or O2 concentration, stack gas flow rate, 

stack gas moisture content, and electrical load 

for the test period. Then:

1) To express the test results in units of 

lb/TBtu, follow the procedures in 40 CFR 

s. 63.10007(e). Use the average Hg 

concentration and diluent gas values in the 

calculations.

2) To express the test results in units of 

lb/GWh, use Equations A-3 and A-4 in section 

6.2.2 of Appendix A to Subpart UUUUU, 

replacing the hourly values “Ch”, “Qh”, “Bws” 

and “(MW)h” with the average values of these 

parameters from the performance test.

3) To calculate pounds of Hg per year, use one 

of the following methods:

A) Multiply the average lb/TBtu Hg 

emission rate (determined according to 

paragraph (h)(3)(iii)(A) of this section) by 

the maximum potential annual heat input to 

the unit (TBtu), which is equal to the 

maximum rated unit heat input (TBtu/hr) 

times 8,760 hours. If the maximum rated 

heat input value is expressed in units of 

MMBtu/hr, multiply it by 10 −6 to convert it 

to TBtu/hr; or

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(h) {...continued from previous page...}

(ii) Complete the initial performance evaluation no later than 

October 13, 2015 or 180 days after the compliance date in 

I.B.7.a.(5), whichever is later.

(iii) Collect PM CPMS hourly average output data for all boiler 

operating hours except as indicated in paragraph (h)(v) of this 

condition. Express the PM CPMS output as milliamps, PM 

concentration, or other raw data signal value.

(iv) Calculate the arithmetic 30-boiler operating day rolling average 

of all of the hourly average PM CPMS output collected during all 

nonexempt boiler operating hours data (e.g., milliamps, PM 

concentration, raw data signal).

(v) The permittee shall collect data using the PM CPMS at all times 

the process unit is operating and at the intervals specified in 

paragraph (h)(i)b) of this condition, except for periods of 

monitoring system malfunctions, repairs associated with monitoring 

system malfunctions, required monitoring system quality assurance 

or quality control activities (including, as applicable, calibration 

checks and required zero and span adjustments), and any scheduled 

maintenance as defined in the site-specific monitoring plan.

(vi) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with your operating 

limit except:

a) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or 

required monitoring system quality assurance or quality control 

activities conducted during monitoring system malfunctions are 

not used in calculations (report any such periods in your annual 

deviation report);

b) Any data collected during periods when the monitoring system 

is out of control as specified in the site-specific monitoring plan, 

repairs associated with periods when the monitoring system is out 

of control, or required monitoring system quality assurance or 

quality control activities conducted during out-of-control periods 

are not used in calculations (report emissions or operating levels 

and report any such periods in the annual deviation report);

c) Any data recorded during periods of startup or shutdown.

(vii) The permittee shall record and make available upon request 

results of PM CPMS system performance audits, as well as the 

dates and duration of periods from when the PM CPMS is out of 

control until completion of the corrective actions necessary to 

return the PM CPMS to operation consistent with the site-specific 

monitoring plan.

[40 CFR s.63.10010(h)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 61

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii)c)3) {...continued from previous page...}

B) Multiply the average lb/GWh Hg emission rate 

(determined according to paragraph (h)(3)(iii)(B) of this 

section) by the maximum potential annual electricity 

generation (GWh), which is equal to the maximum rated 

electrical output of the unit (GW) times 8,760 hours. If 

the maximum rated electrical output value is expressed 

in units of MW, multiply it by 10 −3 to convert it to GW; 

or

C) If an EGU has a federally-enforceable permit limit on 

either the annual heat input or the number of annual 

operating hours, you may modify the calculations in 

paragraph (h)(3)(iii)(C)(1) of this section by replacing 

the maximum potential annual heat input or 8,760 unit 

operating hours with the permit limit on annual heat 

input or operating hours (as applicable).

[40 CFR s. 63.10005(h)]

(i) {reserved}

(j) Startup and shutdown: The permitee shall follow the 

requirements given in Table 3 to 40 CFR, Part 63, Subpart 

UUUUU . [40 CFR s. 63.10005(j)]

(k) The permittee shall submit a Notification of Compliance 

Status summarizing the results of the initial compliance 

demonstration, as provided in 40 CFR s. 63.10030. [40 CFR s. 

63.10005(k)]

[40 CFR s. 63.10005, s. 285.65(13), Wis. Stats.]

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

(a) The permittee shall demonstrate initial compliance with each 

emissions limit in I.B.7.a. by conducting performance testing. 

[40 CFR s. 63.10011(a)]

(b) If demonstrating initial compliance with HAP metals or 

filterable PM emission limit(s) through performance stack tests 

and electing to use a PM CPMS to demonstrate continuous 

performance, the permittee shall also establish a site-specific 

operating limit, in accordance with Table 4 to Subpart UUUUU, 

40 CFR s. 63.10007, and Table 6 to Subpart UUUUU. The 

permittee may use only the parametric data recorded during 

successful performance tests (i.e., tests that demonstrate 

compliance with the applicable emissions limits) to establish an 

operating limit. [40 CFR s. 63.10011(b)]

{continued on next page...}

(5) Monitoring, Installation, Operation and 

Maintenance Requirements:

{...continued from previous page...}

(i) If choosing to comply with the PM filterable emissions 

limit in lieu of metal HAP limits, the permittee may 

choose to install, certify, operate, and maintain a PM 

CEMS and record the output of the PM CEMS as specified 

in paragraphs (i)(i) through (v) of this condition, below. 

The compliance limit will be expressed as a 30-boiler 

operating day rolling average of the numerical emissions 

limit value applicable for the unit in tables 1 or 2 to 

Subpart UUUUU.

(i) Install and certify the PM CEMS according to the 

procedures and requirements in Performance 

Specification 11—Specifications and Test Procedures 

for Particulate Matter Continuous Emission Monitoring 

Systems at Stationary Sources in Appendix B to Part 60 

of 40 CFR, using Method 5 at Appendix A-3 to Part 60 

of 40 CFR and ensuring that the front half filter 

temperature shall be 160° ± 14 °C (320° ± 25 °F). The 

reportable measurement output from the PM CEMS 

must be expressed in units of the applicable emissions 

limit (e.g., lb/MMBtu, lb/MWh).

(ii) Operate and maintain the PM CEMS according to 

the procedures and requirements in Procedure 2—

Quality Assurance Requirements for Particulate Matter 

Continuous Emission Monitoring Systems at Stationary 

Sources in Appendix F to Part 60 of 40 CFR.

a) The permittee shall conduct the relative response 

audit (RRA) for the PM CEMS at least once 

annually.

b) The permittee shall conduct the relative 

correlation audit (RCA) for the PM CEMS at least 

once every 3 years.

(iii) Collect PM CEMS hourly average output data for 

all boiler operating hours except as indicated in 

paragraph (i) of this condition.

(iv) Calculate the arithmetic 30-boiler operating day 

rolling average of all of the hourly average PM CEMS 

output data collected during all nonexempt boiler 

operating hours.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 62

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with 

Emission Limitations and Work Practice Standards:

{...continued from previous page...}

(c)(i) If using CEMS or sorbent trap monitoring 

systems to measure a HAP (e.g., Hg or HCl) 

directly, the first 30-boiler operating day (or, 

if alternate emissions averaging is used for 

Hg, the 90-boiler operating day) rolling 

average emission rate obtained with certified 

CEMS after the compliance date in 

I.B.7.a.(5) (or, if applicable, prior to that 

date, as described in 40 CFR 

s. 63.10005(b)(2)), expressed in units of the 

standard, is the initial performance test. 

Initial compliance is demonstrated if the 

results of the performance test meet the 

applicable emission limit in I.B.7.a.

(ii) For a unit that uses a CEMS to measure 

SO2 or PM emissions for initial compliance, 

the first 30 boiler operating day average 

emission rate obtained with certified CEMS 

after the compliance date in I.B.7.a.(5) (or, if 

applicable, prior to that date, as described in 

40 CFR s. 63.10005(b)(2)), expressed in 

units of the standard, is the initial 

performance test. Initial compliance is 

demonstrated if the results of the 

performance test meet the applicable SO2 or 

filterable PM emission limit in I.B.7.a.

[40 CFR s.10011(c)]

(d) For candidate LEE units, use the results of 

the performance testing described in 40 CFR 

s. 63.10005(h) to determine initial compliance 

with the applicable emission limit(s) in I.B.7.a. 

and to determine whether the unit qualifies for 

LEE status. [40 CFR s. 63.10011(d)]

(e) The permittee shall submit a Notification of 

Compliance Status containing the results of the 

initial compliance demonstration, according to 

40 CFR s. 63.10030(e). [40 CFR s. 

63.10011(e)]

(5) Monitoring, Installation, Operation and Maintenance Requirements:

(i) {...continued from previous page...}

(v) The permittee shall collect data using the PM CEMS at all times the 

process unit is operating and at the intervals specified in paragraph (a) 

of this condition, except for periods of monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, and required 

monitoring system quality assurance or quality control activities.

a) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with the operating limit 

except:

1) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or required 

monitoring system quality assurance or control activities conducted 

during monitoring system malfunctions in calculations and report 

any such periods in the annual deviation report;

2) Any data collected during periods when the monitoring system is 

out of control as specified in the site-specific monitoring plan, 

repairs associated with periods when the monitoring system is out 

of control, or required monitoring system quality assurance or 

control activities conducted during out of control periods in 

calculations used to report emissions or operating levels and report 

any such periods in the annual deviation report;

3) Any data recorded during periods of startup or shutdown.

b) The permittee shall record and make available upon request results 

of PM CEMS system performance audits, dates and duration of 

periods when the PM CEMS is out of control to completion of the 

corrective actions necessary to return the PM CEMS to operation 

consistent with the site-specific monitoring plan.

[40 CFR s. 63.10010(i)]

(j) The permittee may choose to comply with the metal HAP emissions 

limits using CEMS approved in accordance with 40 CFR s. 63.7(f) as an 

alternative to the performance test method specified in 40 CFR, Part 63, 

Subpart UUUUU. If approved to use a HAP metals CEMS, the compliance 

limit will be expressed as a 30-boiler operating day rolling average of the 

numerical emissions limit value in I.B.7.a.(1). If approved, the permittee 

may choose to install, certify, operate, and maintain a HAP metals CEMS 

and record the output of the HAP metals CEMS as specified below:

(i) a) Install and certify the HAP metals CEMS according to the

procedures and requirements in the approved site-specific test plan as 

required in 40 CFR s. 63.7(e). The reportable measurement output

from the HAP metals CEMS shall be expressed in units of the

applicable emissions limit (e.g., lb/MMBtu, lb/MWh) and in the form 

of a 30-boiler operating day rolling average.

b) Operate and maintain the HAP metals CEMS according to the 

procedures and criteria in the site specific performance evaluation and 

quality control program plan required in 40 CFR s. 63.8(d).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 63

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

{...continued from previous page...}

(f)(i) The permittee shall determine the fuel whose 

combustion produces the least uncontrolled 

emissions, i.e., the cleanest fuel, either natural gas 

or distillate oil, that is available on site or 

accessible nearby for use during periods of startup 

or shutdown.

(ii) The cleanest fuel available, either natural gas 

or distillate oil, for use during periods of startup or 

shutdown determination may take safety 

considerations into account.

[40 CFR 2. 63.10011(f)]

(g) The permittee shall follow the startup or shutdown 

requirements given in Table 3 to 40 CFR, Part 63, 

Subpart UUUUU for EGU. [40 CFR s. 63.10011(g)]

[40 CFR s. 63.10011, s. 285.65(13), Wis. Stats.]

(8) Continuous Compliance Demonstration:

(a) The permittee shall demonstrate continuous 

compliance with each emissions limit in Table 2 to 

Subpart UUUUU (see condition I.B.7.a.), each 

operating limit in Table 4 to subpart UUUUU (see 

condition I.B.7.b.(4)), and each work practice 

standard in Tables 3 to Subpart UUUUU (see 

conditions I.B.7.a.(4) and I.B.7.b.(3)) that applies, 

according to the monitoring specified in Tables 6 and 

7 to Subpart UUUUU as outlined below and 

conditions I.B.7.b.(8)(b) through (g).

(i) If using CEMS to measure filterable PM, SO2, 

HCl, or Hg emissions, or using a sorbent trap 

monitoring system to measure Hg to demonstrate 

compliance with the applicable emission limitations 

in I.B.7.a., the permittee shall demonstrate 

continuous compliance by calculating the 30- (or 

90-) boiler operating day rolling arithmetic average 

emissions rate in units of the applicable emissions 

standard basis at the end of each boiler operating 

day using all of the quality assured hourly average 

CEMS or sorbent trap data for the previous 30-

boiler operating days, excluding data recorded 

during periods of startup or shutdown. [40 CFR s. 

63.10021(a), item 1 of Table 7 to 40 CFR, Part 63, 

Subpart UUUUU]

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(j) {...continued from previous page...}

(ii) Collect HAP metals CEMS hourly average output data for all 

boiler operating hours except as indicated in section (j)(iv) of this 

condition.

(iii) Calculate the arithmetic 30-boiler operating day rolling average 

of all of the hourly average HAP metals CEMS output data 

collected during all nonexempt boiler operating hours data.

(iv) The permittee shall collect data using the HAP metals CEMS at 

all times the process unit is operating and at the intervals specified 

in paragraph (a) of this condition, except for periods of monitoring 

system malfunctions, repairs associated with monitoring system 

malfunctions, and required monitoring system quality assurance or 

quality control activities.

a) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with the emission 

limit except:

1) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or 

required monitoring system quality assurance or control 

activities conducted during monitoring system malfunctions in 

calculations and report any such periods in the annual deviation 

report;

2) Any data collected during periods when the monitoring 

system is out of control as specified in the site-specific 

monitoring plan, repairs associated with periods when the 

monitoring system is out of control, or required monitoring 

system quality assurance or control activities conducted during 

out of control periods in calculations used to report emissions 

or operating levels and report any such periods in the annual 

deviation report;

3) Any data recorded during periods of startup or shutdown.

b) The permittee shall record and make available upon request 

results of HAP metals CEMS system performance audits, dates 

and duration of periods when the HAP metals CEMS is out of 

control to completion of the corrective actions necessary to return 

the HAP metals CEMS to operation consistent with the sitespecific performance evaluation and quality control program 

plan.

[40 CFR s. 63.10010(j)]

[40 CFR s. 63.10010, s. 285.65(13), Wis. Stats.]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 64

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(ii) If choosing to establish PM CPMS operating 

limits as allowed by I.B.7.b.(4) to demonstrate 

compliance with the emission limitations in 

I.B.7.a.(1) (particulate matter (PM), total nonmercury HAP metals, individual non-mercury HAP 

metals), the permitee shall 

a) Install, certify, maintain, and operate a PM 

CPMS for monitoring emissions discharged to the 

atmosphere according to 40 CFR s. 

63.10010(g)(1) and 

b) Establish a site-specific operating limit in units 

of PM CPMS output signal (e.g., milliamps, 

mg/acm, or other raw signal) using data from the 

PM CPMS and the PM or HAP metals 

performance tests according to the following 

procedures:

1) Collect PM CPMS output data during the 

entire period of the performance tests.

2) Record the average hourly PM CPMS output 

for each test run in the three run performance 

test.

3) Determine the highest 1-hour average PM 

CPMS measured during the performance test 

demonstrating compliance with the filterable 

PM or HAP metals emissions limitations.

[40 CFR s. 63.10021(a) , Table 6 to 40 CFR, Part 

63, Subpart UUUUU]

(iii) If using PM CPMS to measure compliance 

with a parametric operating limit, the permittee shall 

demonstrate continuous compliance by calculating 

the arithmetic 30-boiler operating day rolling 

average of all of the quality assured hourly average 

PM CPMS output data (e.g., milliamps, PM 

concentration, raw data signal) collected for all 

operating hours for the previous 30 boiler operating 

days, excluding data recorded during periods of 

startup or shutdown. [40 CFR s. 63.10021(a), item 

2 of Table 7 to 40 CFR, Part 63, Subpart UUUUU]

(iv) If using quarterly performance testing to 

measure compliance with one or more applicable 

emissions limits in condition I.B.7.a., the permitee 

shall demonstrate continuous compliance by 

calculating the results of the testing in units of the 

applicable emissions standard. [40 CFR s. 

63.10021(a), item 4 of Table 7 to 40 CFR, Part 63, 

Subpart UUUUU]

(6) Continuous Compliance Demonstration – Monitoring and Data 

Collection:

(a) The permittee shall monitor and collect data according to this 

condition and the site-specific monitoring plan required by 40 CFR 

s. 63.10000(d).

(b) The permitee shall operate the monitoring system and collect data 

at all required intervals at all times that the affected EGU is operating, 

except for periods of monitoring system malfunctions or out-ofcontrol periods (see 40 CFR s. 63.8(c)(7)), and required monitoring 

system quality assurance or quality control activities, including, as 

applicable, calibration checks and required zero and span adjustments. 

The permittee is required to affect monitoring system repairs in 

response to monitoring system malfunctions and to return the 

monitoring system to operation as expeditiously as practicable.

(c) The permtitee may not use data recorded during EGU startup or 

shutdown or monitoring system malfunctions or monitoring system 

out-of-control periods, repairs associated with monitoring system 

malfunctions or monitoring system out-of-control periods, or required 

monitoring system quality assurance or control activities in 

calculations used to report emissions or operating levels. The 

permittee shall use all the data collected during all other periods in 

assessing the operation of the control device and associated control 

system.

(d) Except for periods of monitoring system malfunctions or 

monitoring system out-of-control periods, repairs associated with 

monitoring system malfunctions or monitoring system out-of-control 

periods, and required monitoring system quality assurance or quality 

control activities including, as applicable, calibration checks and 

required zero and span adjustments), failure to collect required data is 

a deviation from the monitoring requirements.

[40 CFR s. 63.10020, s. 285.65(13), Wis. Stats.]

(7) Notification Requirements:

(a) The permittee shall submit all of the notifications in 40 CFR, ss. 

63.7(b) and (c), 63.8 (e), (f)(4) and (6), and 63.9 (b) through (h) that 

apply by the dates specified. [40 CFR ss. 63.9984(c) and 63.10030(a)]

(b) As specified in 40 CFR s. 63.9(b)(2), the permittee shall submit an 

Initial Notification not later than 120 days after April 16, 2012. [40 

CFR ss. 63.9984(c) and 63.10030(b)]

(c) {reserved}

(d) When required to conduct a performance test, the permittee shall 

submit a Notification of Intent to conduct a performance test at least 

30 days before the performance test is scheduled to begin. [40 CFR 

ss. 63.9984(c) and 63.10030(d)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 65

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(v) When conducting periodic performance 

tune-ups of your EGU(s), the permittee shall 

demonstrate continuous compliance by 

conducting periodic performance tune-ups of the 

EGU(s), as specified in 40 CFR s. 63.10021(e). 

[40 CFR s. 63.10021(a), item 5 of Table 7 to 40 

CFR, Part 63, Subpart UUUUU]

(vi) When complying with work practice 

standards during startup the permittee shall 

demonstrate continuous compliance by operating 

in accordance with Table 3 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10021(a), item 

6 of Table 7 to 40 CFR, Part 63, Subpart 

UUUUU]

(vii) When complying with work practice 

standards during shutdown, the permittee shall 

demonstrate continuous compliance by operating 

in accordance with Table 3 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10021(a), item 

7 of Table 7 to 40 CFR, Part 63, Subpart 

UUUUU]

[40 CFR s. 63.10021(a)]

(b) Except as otherwise provided in 40 CFR 

s. 63.10020(c), if using a CEMS to measure SO2 , 

PM, HCl, or Hg emissions, or using a sorbent trap 

monitoring system to measure Hg emissions, the 

permittee shall demonstrate continuous 

compliance by using all quality-assured hourly 

data recorded by the CEMS (or sorbent trap 

monitoring system) and the other required 

monitoring systems (e.g., flow rate, CO2 , O2 , or 

moisture systems) to calculate the arithmetic 

average emissions rate in units of the standard on a 

continuous 30-boiler operating day (or, if alternate 

emissions averaging is used for Hg, 90-boiler 

operating day) rolling average basis, updated at the 

end of each new boiler operating day. Use 

Equation 8 to determine the 30- (or, if applicable, 

90-) boiler operating day rolling average.

Where:

Heri is the hourly emissions rate for hour i and n is the 

number of hourly emissions rate values collected over 

30- (or, if applicable, 90-) boiler operating days.

[40 CFR s. 63.10021(b)]

(7) Notification Requirements:

{...continued from previous page...}

(e) When required to conduct an initial compliance demonstration as 

specified in 40 CFR s. 63.10011(a), the permittee shall submit a 

Notification of Compliance Status according to 40 CFR s. 63.9(h)(2)(ii). 

The Notification of Compliance Status report shall contain all the 

following information, as applicable:

(i) A description of the affected source(s) including identification of 

which subcategory the source is in, the design capacity of the source, a 

description of the add-on controls used on the source, description of the 

fuel(s) burned, including whether the fuel(s) were determined by the 

permittee or EPA through a petition process to be a non-waste under 40 

CFR s. 241.3, whether the fuel(s) were processed from discarded nonhazardous secondary materials within the meaning of 40 CFR s. 241.3, 

and justification for the selection of fuel(s) burned during the 

performance test.

(ii) Summary of the results of all performance tests and fuel analyses 

and calculations conducted to demonstrate initial compliance including 

all established operating limits.

(iii) Identification of whether compliance with each applicable 

emission limit will be demonstrated through performance testing; fuel 

moisture analyses; performance testing with operating limits (e.g., use 

of PM CPMS); CEMS; or a sorbent trap monitoring system.

(iv) Identification of whether compliance will be demonstrated by 

emissions averaging.

(v) A signed certification that all applicable emission limits and work 

practice standards have been met.

(vi) If a deviation from any emission limit, work practice standard, or 

operating limit occurred, submit a brief description of the deviation, the 

duration of the deviation, emissions point identification, and the cause 

of the deviation in the Notification of Compliance Status report.

(vii) In addition to the information required in 40 CFR s. 63.9(h)(2),

your notification of compliance status must include the following:

a) A summary of the results of the annual performance tests and 

documentation of any operating limits that were reestablished during 

this test, if applicable. If stack tests are conducted once every 3 

years consistent with 40 CFR s. 63.10006(b), the date of the last 

three stack tests, a comparison of the emission level achieved in the 

last three stack tests to the 50 percent emission limit threshold 

required in 40 CFR s. 63.10006(i), and a statement as to whether 

there have been any operational changes since the last stack test that 

could increase emissions.

b) Certifications of compliance, as applicable, signed by a 

responsible official stating: 

1. “This EGU complies with the requirements in 40 CFR, 

s. 63.10021(a) to demonstrate continuous compliance.” and

2. “No secondary materials that are solid waste were combusted in 

any affected unit.”

[40 CFR ss. 63.9984(c) and 63.10030(e), s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 66

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(c) If using a PM CPMS data to measure 

compliance with an operating limit in Table 4 to 

Subpart UUUUU, The permitee shall record the 

PM CPMS output data for all periods when the 

process is operating and the PM CPMS is not outof-control. The permittee shall demonstrate 

continuous compliance by using all qualityassured hourly average data collected by the PM 

CPMS for all operating hours to calculate the 

arithmetic average operating parameter in units of 

the operating limit (e.g., milliamps, PM 

concentration, raw data signal) on a 30 operating 

day rolling average basis, updated at the end of 

each new boiler operating day. Use Equation 9 to 

determine the 30 boiler operating day average.

Where:

Hpvi is the hourly parameter value for hour i and 

n is the number of valid hourly parameter values 

collected over 30 boiler operating days.

[40 CFR s. 63.10021(c)]

(d) If using quarterly performance testing to 

demonstrate compliance with one or more 

applicable emissions limits in 2 to Subpart 

UUUUU (see I.B.7.a.), the permittee:

(i) May skip performance testing in those 

quarters during which less than 168 boiler 

operating hours occur, except that a performance 

test must be conducted at least once every 

calendar year.

(ii) Shall conduct the performance test as defined 

in Table 5 to Subpart UUUUU and calculate the 

results of the testing in units of the applicable 

emissions standard; and

[40 CFR s. 63.10021(d)]

{continued on next page...}

(8) Reporting Requirements:

(a) The permittee shall submit each report in Table 8 to 40 CFR, Part 63, 

Subpart UUUUU that applies. If required to (or electing to) continuously 

monitor Hg and/or HCl emissions, The permittee shall also submit the 

electronic reports required under Appendix A and/or Appendix B to 

Subpart UUUUU, at the specified frequency. [40 CFR s. 63.10031(a)]

(b) Unless the department has approved a different schedule for 

submission of reports under 40 CFR s. 63.10(a), the permittee shall 

submit each report semiannually and according to the following:

(i) The first compliance report shall cover the period beginning on the 

compliance date in I.B.7.a.(5) (the compliance date specified in 40 

CFR s. 63.9984) and ending on either June 30 or December 31, 

whichever date is the first date that occurs at least 180 days after the 

specified compliance date.

(ii) The first compliance report shall be postmarked or submitted 

electronically no later than either July 31 or January 31, whichever date 

is the first date following the end of the first calendar half after the 

specified compliance date.

(iii) Each subsequent compliance report shall cover the semiannual 

reporting period from January 1 through June 30 or the semiannual 

reporting period from July 1 through December 31.

(iv) Each subsequent compliance report shall be postmarked or 

submitted electronically no later than July 31 or January 31, whichever 

date is the first date following the end of the semiannual reporting 

period.

(v) The permitte may submit the semiannual compliance reports along 

with the reports required by condition I.XXX.1.a., instead of according 

to the dates in paragraphs (i) through (iv), above.

[40 CFR s. 63.10031(b), Table 8 to 40 CFR, Part 63, Subpart UUUUU]

(c) The compliance report shall contain the following information: 

(i) The information required by the summary report located in 40 CFR 

s. 63.10(e)(3)(vi).

(ii) The total fuel use by each affected source subject to an emission 

limit, for each calendar month within the semiannual reporting period, 

including, but not limited to, a description of the fuel, whether the fuel 

has received a non-waste determination by EPA or your basis for 

concluding that the fuel is not a waste, and the total fuel usage amount 

with units of measure.

(iii) An indication of whether new types of fuel were burned during the 

reporting period. If new types of fuel were burned, the permittee shall 

include the date of the performance test where that fuel was in use.

(iv) The date of the most recent tune-up for each unit subject to the 

requirement to conduct a performance tune-up according to 40 CFR 

s. 63.10021(e), including the date of the most recent burner inspection 

if it was not done every 36 (or 48) months and was delayed until the 

next scheduled unit shutdown.

[40 CFR s. 63.10031(c)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 67

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(e) When conducting periodic performance tune-ups 

of your EGU(s), as specified below, perform the first 

tune-up as part of the initial compliance 

demonstration. Notwithstanding this requirement, 

you the permittee may delay the first burner 

inspection until the next scheduled unit outage 

provided the requirements of 40 CFR s. 63.10005 are 

met. Subsequently, the permittee shall perform an 

inspection of the burner at least once every 36 

calendar months unless the EGU employs neural 

network combustion optimization during normal 

operations in which case the permittee shall perform 

an inspection of the burner and combustion controls at 

least once every 48 calendar months.

(i) As applicable, inspect the burner and combustion 

controls, and clean or replace any components of the 

burner or combustion controls as necessary upon 

initiation of the work practice program and at least 

once every required inspection period. Repair of a 

burner or combustion control component requiring 

special order parts may be scheduled as follows:

a) Burner or combustion control component 

parts needing replacement that affect the ability 

to optimize NOX and CO must be installed 

within 3 calendar months after the burner 

inspection,

b) Burner or combustion control component 

parts that do not affect the ability to optimize 

NOX and CO may be installed on a schedule 

determined by the operator;

(ii) As applicable, inspect the flame pattern and 

make any adjustments to the burner or combustion 

controls necessary to optimize the flame pattern. 

The adjustment should be consistent with the 

manufacturer's specifications, if available, or in 

accordance with best combustion engineering 

practice for that burner type;

(iii) As applicable, observe the damper operations as 

a function of mill and/or cyclone loadings, cyclone 

and pulverizer coal feeder loadings, or other 

pulverizer and coal mill performance parameters, 

making adjustments and effecting repair to dampers, 

controls, mills, pulverizers, cyclones, and sensors;

{continued on next page...}

(8) Reporting Requirements:

{...continued from previous page...}

(d) For each excess emissions occurring at an affected source where a 

CMS is used to comply with that emission limit or operating limit, the 

permittee shall include the information required in 40 CFR 

s. 63.10(e)(3)(v) in the compliance report specified in paragraph (c), 

above. [40 CFR s. 63.10031(d)]

(e) The permittee shall report all deviations as defined in 40 CFR, 

Part 63, Subpart UUUUU in the semiannual monitoring report 

required condition I.XXX.1.a. If an affected source submits a 

compliance report pursuant to Table 8 to to Subpart UUUUU along 

with, or as part of, the semiannual monitoring report required by 

condition I.XXX.1.a., and the compliance report includes all required 

information concerning deviations from any emission limit, operating 

limit, or work practice requirement in this subpart, submission of the 

compliance report satisfies any obligation to report the same 

deviations in the semiannual monitoring report. Submission of a 

compliance report does not otherwise affect any obligation the 

affected source may have to report deviations from permit 

requirements to the permit authority. [40 CFR s. 63.10031(e)]

(f) As of January 1, 2012, and within 60 days after the date of 

completing each performance test, the permittee shall submit the 

results of the performance tests required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's Central 

Data Exchange (CDX) ( www.epa.gov/cdx ). Performance test data 

shall be submitted in the file format generated through use of EPA's 

Electronic Reporting Tool (ERT) (see 

http://www.epa.gov/ttn/chief/ert/index.html ). Only data collected 

using those test methods on the ERT Web site are subject to this 

requirement for submitting reports electronically to WebFIRE. 

Owners or operators who claim that some of the information being 

submitted for performance tests is confidential business information 

(CBI) must submit a complete ERT file including information 

claimed to be CBI on a compact disk or other commonly used 

electronic storage media (including, but not limited to, flash drives) to 

EPA. The electronic media must be clearly marked as CBI and mailed 

to U.S. EPA/OAPQS/CORE CBI Office, Attention: WebFIRE 

Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 

27703. The same ERT file with the CBI omitted shall be submitted to 

EPA via CDX as described earlier in this paragraph. The permittee 

shall also submit these reports, including the confidential business 

information, to the department in the format specified by the 

department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 68

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(iv) As applicable, evaluate windbox pressures and 

air proportions, making adjustments and effecting 

repair to dampers, actuators, controls, and sensors;

(v) Inspect the system controlling the air-to-fuel 

ratio and ensure that it is correctly calibrated and 

functioning properly. Such inspection may include 

calibrating excess O2 probes and/or sensors, 

adjusting overfire air systems, changing software 

parameters, and calibrating associated actuators and 

dampers to ensure that the systems are operated as 

designed. Any component out of calibration, in or 

near failure, or in a state that is likely to negate 

combustion optimization efforts prior to the next 

tune-up, should be corrected or repaired as 

necessary;

(vi) Optimize combustion to minimize generation of 

CO and NOX . This optimization should be 

consistent with the manufacturer's specifications, if 

available, or best combustion engineering practice 

for the applicable burner type. NOX optimization 

includes burners, overfire air controls, concentric 

firing system improvements, neural network or 

combustion efficiency software, control systems 

calibrations, adjusting combustion zone temperature 

profiles, and add-on controls such as SCR and 

SNCR; CO optimization includes burners, overfire 

air controls, concentric firing system improvements, 

neural network or combustion efficiency software, 

control systems calibrations, and adjusting 

combustion zone temperature profiles;

(vii) While operating at full load or the 

predominantly operated load, measure the 

concentration in the effluent stream of CO and NOX

in ppm, by volume, and oxygen in volume percent, 

before and after the tune-up adjustments are made 

(measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the 

adjustments are made). You may use portable CO, 

NOX and O2 monitors for this measurement. EGU's 

employing neural network optimization systems 

need only provide a single pre- and post-tune-up 

value rather than continual values before and after 

each optimization adjustment made by the system;

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(i) Within 60 days after the date of completing each CEMS (SO2 , 

PM, HCl, and Hg) performance evaluation test, as defined in 40 

CFR s. 63.2 and required by Subpart UUUUU, the permittee shall 

submit the relative accuracy test audit (RATA) data (or, for PM 

CEMS, RCA and RRA data) required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The RATA 

data shall be submitted in the file format generated through use of 

EPA's Electronic Reporting Tool (ERT) ( 

http://www.epa.gov/ttn/chief/ert/index.html ). Only RATA data 

compounds listed on the ERT Web site are subject to this 

requirement. Owners or operators who claim that some of the 

information being submitted for RATAs is confidential business 

information (CBI) shall submit a complete ERT file including 

information claimed to be CBI on a compact disk or other 

commonly used electronic storage media (including, but not 

limited to, flash drives) by registered letter to EPA and the same 

ERT file with the CBI omitted to EPA via CDX as described 

earlier in this paragraph. The compact disk or other commonly 

used electronic storage media shall be clearly marked as CBI and 

mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: 

WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., 

Durham, NC 27703. The permittee shall also submit these RATAs 

to the department in the format specified by the department. The 

permittee shall submit calibration error testing, drift checks, and 

other information required in the performance evaluation as 

described in 40 CFR s. 63.2 and as required in 40 CFR.

(ii) For a PM CEMS, PM CPMS, or approved alternative 

monitoring using a HAP metals CEMS, within 60 days after the 

reporting periods ending on March 31st, June 30th, September 

30th, and December 31st, the permitee submit quarterly reports to 

EPA's WebFIRE database by using the Compliance and Emissions 

Data Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The permittee 

shall use the appropriate electronic reporting form in CEDRI or 

provide an alternate electronic file consistent with EPA's reporting 

form output format. For each reporting period, the quarterly 

reports must include all of the calculated 30-boiler operating day 

rolling average values derived from the CEMS and PM CPMS. 

The permittee shall also submit these quarterly reports to the 

department in the format specified by the department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 69

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the information in 

paragraphs (e)(1) through (e)(9) of this section including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume percent, 

measured before and after an adjustment of the EGU 

combustion systems;

b) A description of any corrective actions taken as a part 

of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if the 

unit was physically and legally capable of using more 

than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tune-ups as 

follows:

a) If the first required tune-up is performed as part of the 

initial compliance demonstration, report the date of the 

tune-up in hard copy (as specified in 40 CFR s. 63.10030) 

and electronically (as specified in 40 CFR s. 63.10031). 

Report the date of each subsequent tune-up electronically 

(as specified in 40 CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the initial 

compliance demonstration, but is postponed until the next 

unit outage, report the date of that tune-up and all 

subsequent tune-ups electronically, in accordance with 40 

CFR s. 63.10031.

[40 CFR s. 63.10021(e)]

(f) The permittee shall submit the reports required under 40 

CFR s. 63.10031 and, if applicable, the reports required under 

Appendices A and B to Subpart UUUUU. The electronic 

reports required by Appendices A and B to Subpart UUUUU 

shall be sent to the EPA electronically, as provided in 40 CFR 

s. 63.10031. CEMS data (except for PM CEMS and any 

approved alternative monitoring using a HAP metals CEMS) 

shall be submitted using EPA's Emissions Collection and 

Monitoring Plan System (ECMPS) Client Tool. Other data, 

including PM CEMS data, HAP metals CEMS data, and 

CEMS performance test detail reports, shall be submitted in the 

file format generated through use of EPA's Electronic 

Reporting Tool, the Compliance and Emissions Data Reporting 

Interface, or alternate electronic file format, all as provided for 

under 40 CFR s. 63.10031. These reports shall also be 

submitted to the department. [40 CFR s. 63.10021(f)]

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(iii) Reports for an SO2 CEMS, a Hg CEMS or sorbent 

trap monitoring system, an HCl CEMS, and any 

supporting monitors for such systems (such as a diluent 

or moisture monitor) shall be submitted using the 

ECMPS Client Tool, as provided for in Appendices A 

and B to Subpart UUUUU and 40 CFR s. 63.10021(f). 

The permittee shall also submit these to the department in 

the format specified by the department.

(iv) Submit the compliance reports required under 

paragraphs (c) and (d) of this condition and the 

notification of compliance status required under 40 CFR 

s. 63.10030(e) to EPA's WebFIRE database by using the 

Compliance and Emissions Data Reporting Interface 

(CEDRI) that is accessed through EPA's Central Data 

Exchange (CDX) ( www.epa.gov/cdx ). the permittee 

shall use the appropriate electronic reporting form in 

CEDRI or provide an alternate electronic file consistent 

with EPA's reporting form output format. The permittee 

shall also submit these compliance reports to the 

department in the format specified by the department.

(v) All reports required by 40 CFR, Part 63, Subpart 

UUUUU not subject to the requirements in paragraphs 

(f)(1) through (4) of this condition must be sent to the 

Administrator at the appropriate address listed in 40 CFR 

s. 63.13. If acceptable to both the Administrator and the 

owner or operator of a source, these reports may be 

submitted on electronic media. The Administrator retains 

the right to require submittal of reports subject to 

paragraphs (f)(1), (2), and (3) of this condition in paper 

format. The permittee shall also submit these compliance 

reports to the department in the format specified by the 

department.

[40 CFR s. 63.10031(f)]

(g) If the permittee had a malfunction during the reporting 

period, the compliance report must include the number, 

duration, and a brief description for each type of malfunction 

which occurred during the reporting period and which 

caused or may have caused any applicable emission 

limitation to be exceeded. [40 CFR s. 63.10031(g)]

[40 CFR s. 63.10031, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 70

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(g) The permittee shall report each instance in which 

an applicable emissions limit or operating limit in 

Tables 2 through 4 to Subpart UUUUU (I.A.7.a.) 

was not met or a required tune-up was not 

conducted. These instances are deviations from the 

requirements of Subpart UUUUU. These deviations 

shall be reported according to 40 CFR s. 63.10031. 

[40 CFR s. 63.10021(g)]

(h) The permittee shall keep records as specified in 

40 CFR s. 63.10032 during periods of startup and 

shutdown. [40 CFR s. 63.10021(h)]

(i) The permittee shall provide reports as specified in 

40 CFR s. 63.10031 concerning activities and 

periods of startup and shutdown. [40 CFR s. 

63.10021(i)]

[40 CFR s. 63.10021, s. 285.65(13), Wis. Stats.]

(9) Continuous Compliance Demonstration –

Emissions Averaging Provision:

(a) Following the compliance date, the permittee 

shall demonstrate compliance with Subpart UUUUU 

on a continuous basis by meeting the following:

(i) For each 30- (or 90-) day rolling average 

period, demonstrate compliance with the average 

weighted emissions limit for the existing units 

participating in the emissions averaging option as 

determined in 40 CFR s. 63.10009(f) and (g);

(ii) For each existing unit participating in the 

emissions averaging option that is equipped with 

PM CPMS, maintain the average parameter value 

at or below the operating limit established during 

the most recent performance test;

(iii) For each existing unit participating in the 

emissions averaging option venting to a common 

stack configuration containing affected units from 

other subcategories, maintain the appropriate 

operating limit for each unit as specified in Table 

4 to Subpart UUUUU that applies.

(b) Any instance where the permittee fails to comply 

with the continuous monitoring requirements in 

paragraphs (a) of this condition is a deviation.

[40 CFR s. 63.10022, s. 285.65(13), Wis. Stats.]

(9) Recordkeeping Requirements:

(a) The permittee shall keep records according to the following. If 

required to (or electing to) continuously monitor Hg and/or HCl 

emissions, the permittee shall also keep the records required under 

Appendix A and/or Appendix B to 40 CFR, Part 63, Subpart UUUUU.

(i) A copy of each notification and report that you submitted to 

comply with this subpart, including all documentation supporting 

any Initial Notification or Notification of Compliance Status or 

semiannual compliance report that you submitted, according to the 

requirements in 40 CFR s. 63.10(b)(2)(xiv).

(ii) Records of performance stack tests, fuel analyses, or other 

compliance demonstrations and performance evaluations, as 

required in 40 CFR s. 63.10(b)(2)(viii).

[40 CFR s. 63.10032(a)]

(b) For each CEMS and CPMS, the permittee shall keep records 

according to the following:

(i) Records described in 40 CFR s. 63.10(b)(2)(vi) through (xi).

(ii) Previous (i.e., superseded) versions of the performance 

evaluation plan as required in 40 CFR s. 63.8(d)(3).

(iii) Request for alternatives to relative accuracy test for CEMS as 

required in 40 CFR s. 63.8(f)(6)(i).

(iv) Records of the date and time that each deviation started and 

stopped, and whether the deviation occurred during a period of 

startup, shutdown, or malfunction or during another period.

[40 CFR s. 63.10032(b)]

(c) The permittee shall keep the records required in Table 7 to 40 CFR, 

Part 63, Subpart UUUUU including records of all monitoring data and 

calculated averages for applicable PM CPMS operating limits to show 

continuous compliance with each emission limit and operating limit 

that applies to you. [40 CFR s. 63.10032(c)]

(d) For each EGU subject to an emission limit, the permittee shall also 

keep the following records:

(i) The permittee shall keep records of monthly fuel use by each 

EGU, including the type(s) of fuel and amount(s) used.

(ii) If combusting non-hazardous secondary materials that have 

been determined not to be solid waste pursuant to 40 CFR 

241.3(b)(1), the permittee shall keep a record which documents 

how the secondary material meets each of the legitimacy criteria. If 

combusting a fuel that has been processed from a discarded nonhazardous secondary material pursuant to 40 CFR 241.3(b)(2), the 

permittee shall keep records as to how the operations that produced 

the fuel satisfies the definition of processing in 40 CFR 241.2. If the 

fuel received a non-waste determination pursuant to the petition 

process submitted under 40 CFR 241.3(c), the permittee shall keep 

a record which documents how the fuel satisfies the requirements of 

the petition process.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 71

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(10) Establishing and Determining Compliance 

with a PM CPMS Operating Limit:

(a) During the initial performance test or any such 

subsequent performance test that demonstrates 

compliance with the filterable PM, individual nonmercury HAP metals, or total non-mercury HAP 

metals limit in I.B.7.a.(1), record all hourly average 

output values (e.g., milliamps, stack concentration, 

or other raw data signal) from the PM CPMS for the 

periods corresponding to the test runs (e.g., nine 1-

hour average PM CPMS output values for three 3-

hour test runs).

(b) Determine the operating limit as the highest 1-

hour average PM CPMS output value recorded 

during the performance test. The permittee shall

verify an existing or establish a new operating limit 

after each repeated performance test.

(c) The permittee shall operate and maintain the 

process and control equipment such that the 30 

operating day average PM CPMS output does not 

exceed the operating limit determined in paragraphs 

(a) and (b) of this condition.

[40 CFR s. 63.10023, s. 285.65(13), Wis. Stats.]

(11) General Provisions: The permittee is subject 

to the General Provisions of 40 CFR ss. 63.1 through 

63.15 as shown in Table 9 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10040, s. 

285.65(13), Wis. Stats.]

(12) Affirmative defense for exceedence of 

emission limit during malfunction: In response to 

an action to enforce the standards set forth in 40 CFR 

s. 63.9991 the permittee may assert an affirmative 

defense to a claim for civil penalties for exceedances 

of such standards that are caused by malfunction, as 

defined at 40 CFR s. 63.2. Appropriate penalties 

may be assessed, however, if the permittee fails to 

meet all burden of proving all of the requirements in 

the affirmative defense. The affirmative defense shall 

not be available for claims for injunctive relief.

{continued on next page...}

(9) Recordkeeping Requirements:

(d) {...continued from previous page...}

(iii) For an EGU that qualifies as an LEE under 40 CFR 

s. 63.10005(h), the permittee shall keep annual records that 

document that emissions in the previous stack test(s) continue to 

qualify the unit for LEE status for an applicable pollutant, and 

document that there was no change in source operations including 

fuel composition and operation of air pollution control equipment 

that would cause emissions of the pollutant to increase within the 

past year.

[40 CFR s. 63.10032(d)]

(e) If electing to average emissions consistent with 40 CFR 

s. 63.10009, the permittee must additionally keep a copy of the 

emissions averaging implementation plan required in 40 CFR 

s. 63.10009(g), all calculations required under 40 CFR s. 63.10009, 

including daily records of heat input or steam generation, as applicable, 

and monitoring records consistent with 40 CFR s. 63.10022. [40 CFR 

s. 63.10032(e)]

(f) The permitee shall keep records of the occurrence and duration of 

each startup and/or shutdown. [40 CFR s. 63.10032(f)]

(g) The permittee shall keep records of the occurrence and duration of 

each malfunction of an operation ( i.e. , process equipment) or the air 

pollution control and monitoring equipment. [40 CFR s. 63.10032(g)]

(h) The permitee shall keep records of actions taken during periods of 

malfunction to minimize emissions in accordance with 40 CFR 

s. 63.10000(b), including corrective actions to restore malfunctioning 

process and air pollution control and monitoring equipment to its 

normal or usual manner of operation. [40 CFR s. 63.10032(h)]

(i) The permitee shall keep records of the type(s) and amount(s) of fuel 

used during each startup or shutdown. [40 CFR s. 63.10032(i)]

[40 CFR s. 63.10032, s. 285.65(13), Wis. Stats.]

(10) Records (Form and Retention):

(a) Records must be in a form suitable and readily available for 

expeditious review, according to 40 CFR s. 63.10(b)(1).

(b) As specified in 40 CFR s. 63.10(b)(1), the permitee shall keep each 

record for 5 years following the date of each occurrence, measurement, 

maintenance, corrective action, report, or record.

(c) The permittee shall keep each record on site for at least 2 years 

after the date of each occurrence, measurement, maintenance, 

corrective action, report, or record, according to § 63.10(b)(1). The 

permittee may keep the records off site for the remaining 3 years.

[40 CFR s. 63.10033, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 72

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: 

{...continued from previous page...}

(a) To establish the affirmative defense in any action to enforce such 

a limit, the permittee shall timely meet the notification requirements 

in paragraph (b) of this condition, and must prove by a 

preponderance of evidence that:

(i) The excess emissions:

a) Were caused by a sudden, infrequent, and unavoidable failure 

of air pollution control and monitoring equipment, process 

equipment, or a process to operate in a normal or usual manner, 

and

b) Could not have been prevented through careful planning, 

proper design or better operation and maintenance practices; and

c) Did not stem from any activity or event that could have been 

foreseen and avoided, or planned for; and

d) Were not part of a recurring pattern indicative of inadequate 

design, operation, or maintenance; and

(ii) Repairs were made as expeditiously as possible when the 

applicable emission limitations were being exceeded. Off-shift and 

overtime labor were used, to the extent practicable to make these 

repairs; and

(iii) The frequency, amount and duration of the excess emissions 

(including any bypass) were minimized to the maximum extent 

practicable during periods of such emissions; and

(iv) If the excess emissions resulted from a bypass of control 

equipment or a process, then the bypass was unavoidable to 

prevent loss of life, personal injury, or severe property damage; 

and

(v) All possible steps were taken to minimize the impact of the 

excess emissions on ambient air quality, the environment and 

human health; and

(vi) All emissions monitoring and control systems were kept in 

operation if at all possible, consistent with safety and good air 

pollution control practices; and

(vii) All of the actions in response to the excess emissions were 

documented by properly signed, contemporaneous operating logs; 

and

(viii) At all times, the affected source was operated in a manner 

consistent with good practices for minimizing emissions; and

(ix) A written root cause analysis has been prepared, the purpose of 

which is to determine, correct, and eliminate the primary causes of 

the malfunction and the excess emissions resulting from the 

malfunction event at issue. The analysis shall also specify, using best 

monitoring methods and engineering judgment, the amount of excess 

emissions that were the result of the malfunction.

{continued on next page...}

(11) Emissions Averaging to Comply with 40 CFR, 

Part 63, Subpart UUUUU: The permittee may use the 

emission averaging described in 40 CFR s. 63.10009 to 

comply with Subpart UUUUU, if all the criteria in that 

section are met. [40 CFR s. 63.10009, s. 285.65(13), 

Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 73

B. Stack S03, Boiler B03, Control Device C03A – Weston Unit 3 - Coal Tangentially Fired Boiler Rated at 3423.48 

mmBtu/hr - (CONTINUED)

Pollutant: 7. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than the compliance date in I.B.7.a.(5). [40 CFR, 

ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b), s. 112(i)(3) CAA, s. NR 460.05(7), Wis. Adm. Code, s. 285.65(13), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: 

{...continued from previous page...}

(b) Notification. When experiencing an exceedance of its emission 

limit(s) during a malfunction, the permittee shall notify US EPA and 

the department by telephone or facsimile (FAX) transmission as 

soon as possible, but no later than two business days after the initial 

occurrence of the malfunction or, if it is not possible to determine 

within two business days whether the malfunction caused or 

contributed to an exceedance, no later than two business days after 

the permittee knew or should have known that the malfunction 

caused or contributed to an exceedance, but, in no event later than 

two business days after the end of the averaging period, if it wishes 

to avail itself of an affirmative defense to civil penalties for that 

malfunction. When seeking to assert an affirmative defense, the 

permittee shall also submit a written report to US EPA and the 

department within 45 days of the initial occurrence of the 

exceedance of the standard in 40 CFR s. 63.9991 to demonstrate, 

with all necessary supporting documentation, that it has met the 

requirements set forth in paragraph (a) of this condition. The 

permittee may seek an extension of this deadline for up to 30 

additional days by submitting a written request to US EPA and the 

department before the expiration of the 45 day period. Until a 

request for an extension has been approved by US EPA and the 

department, the permittee is subject to the requirement to submit 

such report within 45 days of the initial occurrence of the 

exceedance.

[40 CFR s. 63.10001, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 74

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – Installed 7/1/2008

Additional Fuels: Natural Gas. 

Controlled by: Baghouse with FGD and SCR systems 

Pollutant: 1. Particulate Matter Emissions (PM) and Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Particulate matter emissions (PM) may not exceed 0.02 pound per million Btu heat input (103.52 pounds per hour) 

averaged over any consecutive 3–hour period.36

(b) Particulate matter emissions less than 10 microns (PM10) may not exceed 0.018 pound per million Btu heat input averaged 

over any consecutive 3–hour period.

[s. NR 405.08(2), Wis. Adm. Code; s. NR 440.20(3), Wis. Adm. Code; s. 285.65(3), Wis. Stats., 03-RV-248-R4, 40 CFR s. 

60.42Da] 

(2) Particulate matter emissions may not exceed 0.10 pounds per million Btu heat input. [s. NR 415.06(2)(c), Wis. Adm. 

Code]

(3) See also condition I.C.15.a.(1).

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Particulate matter emissions shall be controlled using a 

fabric filter baghouse system to meet the BACT emission 

limit. [ s. NR 405.08(2), Wis. Adm. Code]

(2) The fabric filter baghouse system required by I.C.1.b.(1) 

shall be in line and shall be operated at all times when the 

boiler is in operation37 and coal is being fired. [ss. NR 

406.10 and NR 407.09(4)(a).1, Wis. Adm. Code and 03-RV248-R4]

(3) The permittee shall perform compliance emission tests 

to demonstrate compliance with the PM and PM10 emission 

limitations in condition I.C.1.a.(1) as follows: 

(a) Compliance emission tests shall be conducted every 24 

months within 90 days from the date of the last stack test as 

long as the permit remains valid.

(b) The tests shall be conducted in accordance with 

I.XXX.3.a.

(c) The permittee shall perform simultaneous monitoring of 

the parameters identified in I.C.1.c.(2).

[ss. NR 407.09(4)(a), NR 439.075(2)(c) and NR 

439.075(3)(b), Wis. Adm. Code, ss. 285.65(3) and (10), Wis. 

Stats. and 03-RV-248-R5]

(5) The total heat input capacity for all natural gas heaters 

on B04 may not exceed 500 mmBtu/hr when the baghouse is 

not on line. This condition is established to ensure the 

particulate matter limit is not exceeded when natural gas is 

fired in the boiler and the baghouse is not on line. [ss. 

285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever compliance emission testing is required, the following 

test methods and procedures shall be used to demonstrate 

compliance:

(a) The dry basis F factor (O2) procedures in Method 19 shall be 

used to compute the emission rate of particulate matter.

(b) For the particulate matter concentration, US EPA Method 5 

shall be used. For the PM-10 concentration, US EPA Method 201 

or 201A shall be used.

(c) The particulate matter concentration testing in (b) shall include 

condensible backhalf emissions determined using Method 202, or 

Method CTM 039, 

(d) As an alternative to Method 5, Method 17 may be used if the 

stack temperature at the sampling location does not exceed an 

average temperature of 320 degrees F.

(e) The Fc Factor (CO2) procedures in Method 19 may be used to 

compute the emission rate of particulate matter under the 

stipulations of s. NR 440.19(7)(d)1. The CO2 shall be determined 

in the same manner as the O2 concentration.

(f) Alternate methods may be use only if approved by the 

Department in writing. 

[s. NR 439.06(1) and (1m), Wis. Adm. Code; s. NR (8)(b), 

Wis. Adm. Code; s. 285.65(7), Wis. Stats., 03-RV-248-R4, 40 

CFR s. 60.50Da(b)] 

 36 The boiler is subject to New Source Performance Standards (NSPS) requirements for particulate matter under s. NR 

440.20(3), Wis. Adm. Code which limits particulate matter emissions to 0.03 pound per million Btu and 99% reduction when 

combusting solid fuel. The BACT limit for particulate matter is more restrictive then the particulate matter emission limits 

under NSPS, thus the boiler is expected to meet the NSPS particulate matter emission limits when meeting BACT.

37 Boiler operation (as it relates to baghouse operation) is any time the draft ID fan(s) are in operation. See normal start-up and 

shut-down sequence in condition I.C.9.b.(3).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 75

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 1. Particulate Matter Emissions (PM) and Particulate Matter Emissions less than 10 microns (PM10) -

{CONTINUED]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) The permittee shall perform 

periodic internal inspections of 

the baghouse to ensure that the 

control equipment is operating 

properly. The time interval 

between inspections may not 

exceed 13,140 operating hours 

unless written approval from the 

Department is granted allowing 

for a greater interval. Such a 

request may only be granted if the 

applicant demonstrates that such 

an interval is needed to maintain a 

stable electric power supply. [s. 

NR 407.09(4)(a)3.b., Wis. Adm. 

Code]

(7) The permittee shall calibrate 

instruments used for measuring 

the baghouse operational 

parameters identified in 

I.C.1.b.(4) once every 13,140 

hours of operation, unless an 

alternative schedule is approved 

by the department in writing. [s. 

NR 407.09(4)(a)3.b., Wis. Adm. 

Code]

(8) The permittee shall perform 

periodic inspections of the boiler 

to ensure optimum boiler 

performance using a qualified 

inspector. Specific items that 

should be inspected include, but 

are not limited to, firebox, boiler 

tubes, refractory, burner 

conditions, boiler backpass, boiler 

cleanliness and overall boiler 

condition. The time interval 

between inspections may not 

exceed 13,140 hours of operation, 

unless the department approves a 

request for an extension in 

writing. [s. NR 407.09(4)(a)3.b., 

Wis. Adm. Code]

(2) (a) The permittee shall continuously monitor the operating pressure drop across the 

fabric filter system and shall sound an audible alarm, whenever the operating pressure 

drop is below the minimum pressure drop identified in I.C.1.b.(9)(e). 

(b) The permittee shall continuously record the pressure drop across the fabric filter 

system, except as provided in I.C.1.c.(2)(c) below.

(c) In the event the continuous pressure drop recording equipment malfunctions, the 

permittee shall diligently work to return equipment to operation as soon as practicable and

manually record the pressure drop across the fabric filter system once every 8 hours of 

source operation or once per day while the unit is operating, whichever yields the greater 

number of measurements, until the continuous recorder is returned to service.

[s. NR 439.055(5), Wis. Adm. Code and 04-RV-248-R6]

(3)(a) The permittee shall maintain records of any investigative and corrective action 

taken as a result of an alarm indicating a differential pressure drop reading outside the 

indicator range in condition I.C.1.b.(9)(b), that include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(b) The permittee shall maintain records of any investigative and corrective action taken 

as a result of an alarm indicating an opacity reading, averaged over any consecutive 3-

hour period, that exceeds the range in I.C.2.b.(9)(e), that include:

(i) date and time of the alarm;

(ii) a description of the investigative actions taken; and 

(iii) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

[s. NR 439.055(5), Wis. Adm. Code, 06-SDD-102]

(4) Upon detecting an excursion or exceedance of the ranges specified in condition 

I.C.1.b.(9)(b) and (e), the permittee shall respond to every “out of range” alarm by 

restoring operation of the baghouse to its normal or usual manner of operation as 

expeditiously as practicable in accordance with good air pollution control practices for 

minimizing emissions. [40 CFR 64.7(d)(1), s. 285.65(3), Wis. Stats. and 04-RV-248-R4]

(5) The permittee shall maintain records of:

(a) The results of the compliance emission tests required by condition I.C.1.b.(3); and

(b) The parameter monitoring and associated operating ranges for the parameters 

identified in condition I.C.1.c.(2) as recorded during the compliance emission tests 

required by condition I.C.1.b.(3). 

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

(6) The permittee shall retain appropriate records on the manufacturer’s design 

specifications information for the natural gas burners to demonstrate compliance with 

permit condition I.C.1.b.(5). [s. 285.65(7), Wis. Stats., s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(7) The permittee shall maintain records of:

(a) the date, time, and initials of the person performing the inspections required by 

I.C.1.b.(6);

(b) a list of the items inspected;

(c) any maintenance or repairs performed as a result of these inspections;

(d) the operating hours of the boiler since the last inspection; and

(e) the date, time and initials of the person performing the calibrations required by 

I.B.1.b.(7).

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 76

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 1. Particulate Matter Emissions (PM) and Particulate Matter Emissions less than 10 microns (PM10) -

{CONTINUED]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and 

Monitoring:

(9) Compliance Assurance Monitoring (CAM) Requirements: Boiler B04 

is a pollutant-specific emissions unit for particulate matter emissions and 

is subject to the CAM requirements of Part 64 CFR. As such the boiler is 

subject to the CAM requirements in Part IV and section I.XXX.9. of this 

permit, and as follows:

(a) Whenever the boiler is operating, the permittee shall monitor 

differential pressure drop across the fabric filter baghouse system as an 

indicator of control equipment performance, using electronic pressure 

transmitters located at the inlet and the outlet of the baghouse.;

(b) The indicator range for differential pressure drop across the baghouse 

controlling B04 is 2.0 to 10.0 inches of water; 

(c) The permittee shall monitor opacity as a secondary indicator of 

baghouse performance using a continuous opacity monitoring system 

(COMS) that meets the requirements I.C.2.c.(2) through (4);

(d) The permittee shall use the data collected by the COMS to calculate 

opacities for the boiler, averaged over each consecutive 3-hour period;

(e) The indicator range for visible emissions from B04 is 10% opacity or 

less, averaged over each consecutive 3-hour period; 

(f) An excursion is:

(i) a differential pressure drop reading outside the indicator range in 

condition I.C.1.b.(9)(b); OR

(ii) any opacity reading that exceeds the range in I.C.2.b.(9)(e), as 

averaged over any consecutive 3-hour period.

(g) The permittee shall operate an alarm system to notify the operator if 

the differential pressure drop across the baghouse is outside the range 

specified in conditions I.C.1.b.(9)(b). If an alarm occurs, the permittee 

shall take appropriate investigative and corrective action.

(h) The permittee shall operate an alarm system to notify the operator if 

visible emissions exceed the opacity specified in conditions 

I.C.1.b.(9)(e). If an alarm occurs, the permittee shall take appropriate 

investigative and corrective action.

(i) The quality improvement plan (QIP) threshold is reached when 

excursions occur for more than 5% of the boiler’s operating time in a six 

month reporting period;

(j) The permittee shall operate the COMS in accordance with 40 CFR ss. 

64.7 and 64.8 as detailed in conditions I.XXX.a.(2) and (4).

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b. and NR s. 

439.055(5), Wis. Adm. Code, and 40 CFR ss. 64.2, 64.3, 64.6, 64.7, and 

64.8 and 06-SDD-102]

(8) The permittee shall maintain records of:

(a) the date, time, and initials of the person 

performing the inspections required by I.B.1.b.(8);

(b) a list of the items inspected;

(c) any maintenance, repairs or adjustments 

performed as a result of these inspections; and

(d) the operating hours of the boiler since the last 

inspection.

[s. NR 439.04(1)(d), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 77

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2)

a. Limitations:

(1) Best Available Control Technology (BACT):38

(a) Emissions may not exceed:39

(i) 0.10 pound per million Btu heat input for all periods, including startup, shut down and routine atomizer change out, 

averaged over any consecutive 30-day period, and

(ii) 0.09 pound per million Btu heat input for all periods, including startup, shut down and routine atomizer change out, 

averaged over any 12 consecutive months.

(b) Periods of Scheduled Maintenance of Sulfur Control System: Emissions may not exceed the following on days when 

scheduled maintenance of the sulfur control system is performed (e.g. atomizer change out).40 These limitations are applicable 

only during periods when this maintenance is performed.

(i) 3491.8 pounds per hour on a 3-hour average, and

(ii) 1508.9 pounds per hour on a 24-hour average.

(c) Emissions shall be controlled to a level that is 90% control for all periods when coal is fired, excluding periods of 

scheduled maintenance (e.g. atomizer change out) averaged over any consecutive 30-day period, measured using methods 

described by condition I.C.2.b.(5)(c).

(d) The uncontrolled sulfur dioxide emission content of the coal may not exceed 1.23 pounds per million Btu, averaged over 

any consecutive 30-day period.

(e) When determining compliance with the limits on an hourly and daily average, the permittee shall only include hours and 

days when the boiler operated. 

[ss. NR 405.08(2) and NR 440.20(4), Wis. Adm. Code, ss. 285.63(1)(b) and 285.65(3), Wis. Stats., 03-RV-248-R4, 40 CFR s. 

60.43Da]

(2) To ensure compliance with PSD increments and NAAQS, emissions may not exceed the following on days when no 

scheduled routine maintenance of the sulfur control system (i.e. atomizer change out) is performed:41

(a) 621 pounds per hour averaged over any consecutive 3-hour period, and

(b) 589 pounds per hour average over any consecutive 24-hour period.

[s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boiler B04 is subject to the SO2 

CAIR requirements. As such, the permittee shall comply with the CAIR requirements as outlined in section I.XXX.8. and in the 

CAIR Permit Application (for sources subject to CAIR FIP) submitted by Wisconsin Public Service Corporation – Weston and 

dated May 23, 2007 incorporated as Part III of this Operation Permit and 40 CFR 97.121, 97.122, 97.221, 97.222, 97.321 and 

97.322. OR alternately, when in effect, comply with the Cross-State Air Pollution Rule requirements, as applicable, as required 

in section I.XXX.8.

 38 The boiler is subject to NSPS requirement for sulfur dioxide under s. NR 440.20(4), Wis. Adm. Code. The NSPS limit for 

sulfur dioxide varies depending upon fuel sulfur content, with either a 90% reduction and 1.20 pound per million Btu 

limitations or a 70% reduction when emissions are below 0.60 pound per million Btu. The NSPS limits apply at all times 

except during periods of startup and shut down. The optional determination in s. NR 440.20(8)(c) may be used to demonstrate 

compliance with the NSPS sulfur dioxide standards if fuel pretreatment is utilized. The BACT limits for sulfur dioxide are 

more restrictive than the sulfur dioxide emission limits under NSPS, thus the boiler is expected to meet the NSPS sulfur dioxide 

emission limits while meeting BACT. 

39 Only hours when the boiler is operated shall be included in the averages in I.C.2.a.(1).

40 The permittee indicated in their application that the optimum time between routine atomizer changeouts would not be more 

frequent than 1000 hours.

41 These conditions are established to ensure compliance with PSD increments and NAAQS. At these emission rates the air 

quality standards are expected to be protected. These limits are applicable to days when no scheduled maintenance of the sulfur 

control system (e.g. atomizer change out) is required.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 78

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2) -- {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Sulfur dioxide emissions shall 

be controlled by the use of dry 

flue gas desulfurization (FGD) 

system to meet the BACT 

emission limits. [s. NR 

405.08(2), Wis. Adm. Code and 

03-RV-248-R4]

(2) When operating the boiler

during periods when the SO2

CEMs is not operating,

42 the 

permittee shall maintain the flow 

rate of the aqueous lime/recycled 

ash slurry to the FGD system at 

not less than 50 gallons per 

minute per side and not less than 

100 gallons per minute total,

averaged over each 24-hour 

period the boiler is operated43

or 

until the CEM is returned to 

service (excluding periods of 

flushes, startup, shutdown, and 

maintenance), or the value 

established during the most recent 

stack test that demonstrated 

compliance with the emission 

limitation in I.C.2.a.(1), if 

approved by the department in 

writing. [s. NR 407.09(4)(a), 

Wis. Adm. Code, s. 285.65(3), 

Wis. Stats. and 03-RV-248-R4]

(3) The boiler shall be fired on 

low sulfur powder river basin coal 

and natural gas only. [ss. NR 

405.08(2) and NR 406.10, Wis. 

Adm. Code; s. 285.65(3), Wis. 

Stats and 03-RV-248-R4]

(1) Reference Test Method for Sulfur Dioxide Emissions: Whenever compliance emission 

testing is required, US EPA Method 6, 6A or 6C or an alternate method approved in 

writing by the Department, shall be used to demonstrate compliance. [s. NR 439.06(2), 

Wis. Adm. Code]

(2) The permittee shall retain a copy of the department approved coal mine sampling and 

analysis protocol. The permittee shall submit any changes to this protocol for department 

approval. [s. NR 439.04(1)(d), Wis. Adm. Code]

(3) Continuous Emission Monitoring Requirements:

(a) The permittee shall calibrate, maintain and operate a continuous emission monitoring 

system, and record the output of the system, for measuring sulfur dioxide emissions.

(b) The permittee shall calibrate, maintain and operate a continuous emission monitoring 

system, and record the output of the system for measuring oxygen or carbon dioxide 

content of the flue gases at each location where sulfur dioxide emissions are monitored.

(c) The permittee shall calibrate, maintain and operate continuous SO2 emission monitors 

located at the inlet and outlet to the SO2 control device to measure the control efficiency 

of the SO2 control device. The permittee shall record the output of these systems. 

[s. NR 440.20(7)(b) and (d), Wis. Adm. Code, s. 285.65(10), Wis. Stats., 03-RV-248-R4, 

40 CFR s. 60.49Da(b) and (d)]

(d) Continuous emissions monitoring systems shall be installed and operated in 

accordance with 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code, s. NR 439.06(2), 

Wis. Adm. Code, and 40 CFR s. 60.49Da(b). 

(e) The continuous monitoring systems required by I.C.2.c.(3)(a), (b) and (c) shall be 

operated and data recorded during all periods of boiler operation including periods of 

startup, shutdown, malfunction or emergency conditions except for continuous monitoring 

system breakdowns, repairs, calibration checks and zero and span adjustments. [s. NR 

440.20(7)(e), Wis. Adm. Code and 40 CFR s. 60.49Da(e)]

(f) The permittee shall obtain emission data for at least 18 hours in at least 22 out of 30 

successive boiler operating days. If this minimum data requirement cannot be met with a 

continuous monitoring system, the permittee shall supplement emission data with other 

monitoring systems approved by the department. [s. NR 440.20(7)(f), Wis. Adm. Code

and 40 CFR s. 60.49Da(f)]

(g) One hour averages shall be computed from 4 or more data points equally spaced over 

each one-hour period and shall be expressed in lbs/mmBtu heat input and used to calculate 

the average emission rates in I.C.2.b.(6). At least 2 data points shall be used to calculate 

the one-hour averages. [ss. NR 440.13(8) and NR 44.20(7)(g), Wis. Adm. Code]

(h) When it becomes necessary to supplement continuous monitoring system data to meet 

the minimum data requirements in I.C.2.c.(3)(f), the permittee shall use the reference 

methods and procedures specified in s. NR 440.20(7)(h) (40 CFR s. 60.49Da(h)) or the 

acceptable alternative methods and procedures given in s. NR 440.20(7)(j), Wis. Adm. 

Code (40 CFR s. 60.49Da(j)). [s. NR 440.20(7)(h), Wis. Adm. Code and 40 CFR s. 

60.49Da(h)]

(i) When calculating hourly emissions in pounds per million Btu, a minimum 

concentration of 5.0 percent carbon dioxide or a maximum concentration of 14.0 percent 

oxygen may be substituted for the measured diluent gas concentration value for any 

operating hour in which the hourly average carbon dioxide concentration is less than 5.0 

percent carbon dioxide or the hourly average oxygen concentration is greater than 14.0 

percent oxygen, as described in 40 CFR Part 75 Appendix F Section 3.3.4.1. [03-RV248-R4]

 42 This approach is utilized during periods when the SO2 CEMS is not operating, to demonstrate continuous compliance, 

provided the CEMS meets the requirements of 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code, s. NR 439.06(2), Wis. 

Adm. Code, and 40 CFR s. 60.49Da(b).

43 Only hours when the boiler is operated shall be included in the average in I.C.2.b.(2).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 79

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2) -- {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(4) Compliance Demonstration for Coal Sulfur Dioxide 

Content:

(a) The permittee shall demonstrate compliance with the coal

sulfur dioxide content limit in I.C.2.a.(1)(d) by utilizing coal 

sampling and analysis of the coal as it is shipped from the 

mine. 

(b) In the event that mine sampling and analysis is 

unavailable, the permittee shall use as received fuel sampling 

and analysis procedures in accordance with s. NR 439.08, 

Wis. Adm. Code or other analysis procedures approved in 

writing by the department to demonstrate compliance with 

this limit. 

(d) In lieu of fuel sampling and analysis, the permittee may 

demonstrate compliance with the coal sulfur dioxide content 

limit in I.C.2.a.(1)(d) by using emissions data measured by 

the continuous emission monitoring system at the inlet to the 

FGD system required by I.C.2.c.(3)(c). 

[s. 285.65(3), Wis. Stats., ss. NR 407.09(4)(a) and NR 439.08, 

Wis. Adm. Code, and 03-RV-248-R4]

(5) The permittee shall demonstrate compliance with the 

sulfur dioxide emission limits contained in I.C.2.a.(1)(a), 

I.C.2.a.(1)(b)(i) and (ii), and I.C.2.a.(2) using emissions data 

measured by the continuous emission monitoring system 

required by I.C.2.c.(3) as follows44

:

(a) Daily average concentration shall be calculated each 

calendar day by combining the sulfur dioxide concentration 

and diluent concentration (in % O2 or % CO2) measurement 

consistent with the procedures specified in 40 CFR Part 75 

Appendix F. 12 consecutive months concentrations shall be 

calculated based on the calculations of the daily 

concentrations. 

(b) The permittee shall use CEMs data for B04 to demonstrate 

compliance with emission limits in I.C.2.a.(1)(b)(i) and (ii).

(c) Continuous SO2 emission monitors located at the inlet and 

outlet to the SO2 control device shall be used in accordance 

with 40 CFR Part 75 to demonstrate compliance with 

I.C.2.a.(1)(c), whenever coal is fired. 

[ss. 285.65(3) and (10), Wis. Stats. and 03-RV-248-R4]

(4) During operation the permittee shall monitor and record 

the flow rate of the aqueous lime/recycled ash slurry to the 

dry flue gas desulfurization (FGD) system once every 8 hours 

of operation or once per day, whichever yields the greater 

number of measurements. [ss. NR 439.04(1)(d) and NR 

439.055(1)(a), Wis. Adm. Code and 03-RV-248-R4]

(5) The permittee shall submit quarterly reports to the 

Department on the information required under condition 

I.C.2.b.(4) for each train load of coal received during the 

calendar quarter. These reports shall include the mine of 

origin of each train load of coal. [ss. 285.65(3) and (10), Wis. 

Stats. and 03-RV-248-R4]

(6) The permittee shall maintain records of:

(a) Daily average SO2 emission rates as determined in 

I.C.2.b.(6)(a), in lbs/mmBtu;

(b) 30-day average SO2 emission rates for each 30 successive 

boiler operating day period as determined in I.C.2.b.(6)(b), in 

lbs/mmBtu;

(c) 12-month average SO2 emission rates for each 12 

consecutive month period as determined in I.C.2.b.(6)(c), in 

lbs/mmBtu; 

(d) 30-day average SO2 control level for each 30 consecutive 

day period as determined in I.C.2.b.(9), in percent

(e) hourly average SO2 emission rates as determined in 

I.C.2.b.(6)(e), in pounds per hour;

(f) 3-hour average SO2 emission rates as determined in 

I.C.2.b.(6)(e), in pounds per hour;

(g) 24-hour average S02 emission rates as determined in 

I.C.2.b.(6)(f), in pounds per hour

[s. 285.65(3), Wis. Stats, s. NR 439.04(1)(d), Wis. Adm. 

Code and 03-RV-248-R4]

 44 The boiler is exempt from periodic compliance emission tests required by ss. NR 439.075(2)(a)2., and (3)(b), Wis. Adm. 

Code provided they operate a continuous sulfur dioxide emission monitor that meets the performance specification 

requirements of s. NR 439.09, Wis. Adm. Code, pursuant to s. NR 439.075(4)(a)2., Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 80

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2) -- {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Compliance Provisions:

(a) Compliance with the sulfur dioxide emission limitations 

in I.C.2.a.(1)(a)(i) and (c) shall be based on the average 

emission rate for 30 successive boiler operating days. 

(b) Compliance with the emission limitations in 

I.C.2.a.(1)(a)(i) and (c) shall be determined by calculating the 

arithmetic average of all hourly emission rates for sulfur 

dioxide for the 30 successive boiler operating days.

(c) Compliance with the emission limitation in 

I.C.2.a.(1)(a)(ii) shall be determined by calculating the

arithmetic average of all hourly sulfur dioxide emission rates 

for each 12 consecutive month period that the boiler has 

operated. 

(d) Only hours when the boiler is operated shall be included 

in the averages in (a) through (c).

(e) To demonstrate compliance with the sulfur dioxide 

emission limitation in I.C.2.a.(2)(a), the permittee shall 

calculate the arithmetic average of all hourly sulfur dioxide 

emission rates for each three consecutive hour period, 

whenever the boiler is operated.

(f) To demonstrate compliance with the sulfur dioxide 

emission limitations in I.C.2.a.(2)(b), the permittee shall 

calculate the arithmetic average of all hourly sulfur dioxide 

emission rates for each 24 consecutive hour period whenever 

the boiler is operated. 

(g) The permittee shall demonstrate compliance during 

periods of routine maintenance (e.g. atomizer change out) as 

follows:

(i) To demonstrate compliance with the sulfur dioxide 

emission limitations in I.C.2.(1)(b)(i), the permittee shall 

calculate the arithmetic average of all hourly sulfur 

dioxide emission rates for each three consecutive hour 

period while routine maintenance is being performed.

(ii) To demonstrate compliance with the sulfur dioxide 

emission limitation in I.C.2.(1)(b)(ii), the permittee shall 

calculate the arithmetic average of all hourly sulfur 

dioxide emission rates for S04 for each 24 consecutive 

hour period while routine maintenance is being 

performed.

[ss. NR 407.09(4)(a), NR 405.08(2) and NR 440.20(6)(e) and 

(g), Wis. Adm. Code, s. 285.65(3), Wis. Stats., 03-RV-248-

R4, 40 CFR s. 60.48Da(e)]

(7) For Periods of Scheduled Maintenance of the Sulfur 

Control System the permittee shall maintain records of:

(a) The date the maintenance was performed (e.g. the date the 

atomizers were changed);

(b) The hours boiler B04 operated since the last atomizer was 

changed;

(c) The start and end time of the scheduled routine 

maintenance;

(d) The average hourly SO2 emission rate for S04 during the 

period of routine maintenance as determined in I.C.2.b.(6)(g), 

in pounds per hour;

(e) The 3-hour average SO2 emission rate for S04 for each 

consecutive 3 hour period during the period of routine 

maintenance as determined in I.C.2.b.(6)(g), in pounds per 

hour; and 

(f) The 24-hour average SO2 emission rate for S04 for each 

24 consecutive hour period during the period of routine 

maintenance, in pounds per hour.

[s. 285.65(3), Wis. Stats., s. NR 439.04(1)(d), Wis. Adm. 

Code and 03-RV-248-R4]

(8) Reporting Requirements: For sulfur dioxide the 

following information shall be reported to the department for 

each 24-hour period:

(a) Calendar date.

(b) The average sulfur dioxide emission rates (lbs/mmBtu) 

for each 30 successive boiler operating days, ending with the 

last 30-day period in the quarter; reasons for noncompliance 

with the emission standards, and description of the corrective 

actions taken.

(c) Percent reduction of the potential combustion 

concentration of sulfur dioxide for each 30 successive boiler 

operating days, ending with the last 30-day period in the 

quarter; reasons for noncompliance with the standards; and 

description of corrective action taken.

(d) Identification of the boiler operating days for which 

pollutant or diluent data have not been obtained by an 

approved method for at least 18 hours of operation of the 

facility; justification for not obtaining sufficient data; and 

description of corrective actions taken.

{...Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 81

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2) -- {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Reporting Requirements: {...Continued from Previous Page...}

(e) Identification of the times when emissions data have been excluded from the 

calculation of average emission rates because of startup, shutdown, maintenance of the 

sulfur dioxide control system (e.g. atomizer changeout) or other reasons, and justification 

for excluding data for reasons other than startup, shutdown, and maintenance of the sulfur 

dioxide control system (e.g. atomizer changeout).

(f) Identification of “F” factor used for calculations, method of determination and type of 

fuel combusted.

(g) Identification of times when hourly averages have been obtained based on manual 

sampling methods.

(h) Identification of times when the pollutant concentration exceeded full span of the 

continuous monitoring system.

(i) Description of any modification s to the continuous monitoring system which could 

affect the ability of the continuous monitoring system to comply with Performance 

Specification 2 or 3 of 40 CFR part 60, Appendix B.

(j) If the minimum quantity of emissions data as required by s. NR 440.20(7) (40 CFR s. 

60.49Da) is not obtained for any 30 successive boiler operating days, the information 

obtained under s. NR 440.20(6)(h) (40 CFR s. 60.48Da(h)) and listed in s. NR 

440.20(9)(c) (40 CFR s. 60.51Da(c)) shall be reported to the department for that 30-day 

period.

(k) If fuel pretreatment credit toward the sulfur dioxide emission standards in I.C.2.a. is 

claimed, the permittee shall submit a signed statement:

(i) Indicating what percentage cleaning credit was taken for the calendar quarter, and 

whether the credit was determined in accordance with the provisions of I.C.2.b.(9) and 

Method 19 of 40 CFR part 60, Appendix A.

(ii) Listing the quantity, heat content, and date each pretreated fuel shipment was 

received during the previous quarter; the name and location of the fuel pretreatment 

facility; and the total quantity and total heat content of all fuels received at the facility 

during the previous quarter.

(l) For any periods for which sulfur dioxide emissions data are not available, the 

permittee shall submit a signed statement indicating if any changes were made in 

operation of the emission control system during the period of data unavailability. 

Operations of the control system and boiler during periods of data unavailability are to be 

compared with operation of the control system and boiler before and following the period 

of data unavailability.

(m) The permittee shall submit a signed statement indicating whether:

(i) The required continuous monitoring system calibration, span, and drift checks or 

other periodic audits have or have not been performed as specified.

(ii) The data used to show compliance was or was not obtained in accordance with the 

approved methods and procedures of ch. NR 440, Wis. Adm. Code and is 

representative of plant performance.

(iii) The minimum data requirements have or have not been met; or, the minimum data 

requirements have not been met for errors that were unavoidable.

(iv) Compliance with the standards in I.C.2.a. has or has not been achieved during the 

reporting period.

[s. NR 440.20(9), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.51Da]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 82

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2) -- {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(9) Report Submittal: 

(a) The permittee shall submit a written report containing the information in 

I.C.2.c.(8), or other information approved by the department in writing, to the 

department semiannually for each 6-month period. All semiannual reports shall be 

postmarked by the 30th day following the end of each 6-month period.

(b) The permittee may submit electronic quarterly reports for sulfur dioxide in lieu of 

the written reports required in (a). The format of each quarterly electronic report shall 

be coordinated with the department. The electronic report shall be submitted no later 

than 30 days after the end of the calendar quarter and shall be accompanied by a 

certification statement from the permittee indicating whether compliance with the 

applicable emission standards and minimum data requirements was achieved during 

the reporting period. Before submitting the reports in the electronic format, the 

permittee shall coordinate with the department to obtain agreement to submit reports in 

this alternative format.

[s. NR 440.20(9)(i) and (j), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.51Da(j) 

and (k)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 83

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx)

a. Limitations:

(1) Best Available Control Technology (BACT):45 Emissions may not exceed:46

(a) 0.06 pound per million Btu heat input, averaged over any consecutive 30-day period during normal operations, not 

including startup and shutdown47; and

(b) 0.06 pound per million Btu heat input for all periods including startup and shut down, averaged over any consecutive 12-

month period. 

(c) When determining compliance with these limits, the permittee shall only account for the hours and days when the boiler 

operated. 

[ss. NR 405.08(2) and NR 440.20(5)(a)1. and (6)(e), Wis. Adm. Code, s. 285.65(3), Wis. Stats., 03-RV-248-R4, 40 CFR s. 

60.44Da(a)(1)] 

(2) Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR) Requirements: Boiler B04 is subject to the NOx -

Annual and the NOx –Ozone Season CAIR requirements. As such, the permittee shall comply with the CAIR requirements as 

outlined in section I.XXX.8. and in the CAIR Permit Application (for sources subject to CAIR FIP) submitted by Wisconsin 

Public Service Corporation – Weston and dated May 23, 2007 incorporated as Part III of this Operation Permit and 40 CFR 

97.121, 97.122, 97.221, 97.222, 97.321 and 97.322. OR alternately, when in effect, comply with the Cross-State Air Pollution 

Rule requirements, as applicable, as required in section I.XXX.8.

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and 

Monitoring:

(1) Nitrogen Oxide Emissions shall be controlled using low NOx burners, good 

combustion practices and a Selective Catalytic Reduction (SCR) System to meet the 

BACT emission limits. [s. NR 405.08(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats., 

and 03-RV-248-R4]

(2) Compliance Provisions

(a) Compliance with the nitrogen oxides emissions limitations in I.C.3.a.(1) shall be 

based on the average emission rate for 30 successive boiler operating days48.

(b) Compliance with the emission limitations in I.C.3.a.(1) shall be determined by 

calculating the arithmetic average of all hourly emission rates for nitrogen oxides for 

the 30 successive boiler operating days49, except for the periods of startup and 

shutdown.

(c) 24 hour emissions shall be calculated by combining the NOx concentration and 

diluent concentration (in % O2 or % CO2) measurement consistent with the procedures 

specified in 40 CFR Part 75 Appendix F. 

(d) Compliance with the emission limitation in I.C.3.a.(1)(b) shall be determined by 

calculating the arithmetic average of all hourly nitrogen oxides emission rates for each 

12 consecutive month period that the boiler has operated.

[ss. NR 440.20(6)(e) and (g), Wis. Adm. Code, s. 285.65(3), Wis. Stats., 03-RV-248-

R4, 40 CFR s. 60.48Da(e) and (g)]

(1) Reference Test Method for 

Nitrogen Oxide Emissions:

Whenever compliance emission 

testing is required, US EPA Method 

7, 7E or an alternate method 

approved in writing by the 

Department shall be used to 

demonstrate compliance. [s. NR 

439.06(6), Wis. Adm. Code]

 45 The boiler is subject to NSPS requirements under s. NR 440.20(5)(a)1., Wis. Adm. Code for nitrogen oxides. The NSPS 

limit is 0.50 pound per million Btu. The NSPS nitrogen oxides emission limits apply at all times except during periods of 

startup, shut down or malfunction. The compliance determination in s. NR 440.20(8)(d) is used to demonstrate compliance 

with NSPS NOx standard. The BACT nitrogen oxides limit under I.A.4.a.(1), is more restrictive than the NSPS nitrogen oxides 

emission limits, thus the boiler is expected to meet the NSPS nitrogen oxides emission limit while complying with the BACT 

nitrogen oxides limit.

46 Only hours when the boiler is operated shall be included in the averages in I.C.3.a.(1).

47 Startup begins with flame on and ends when the ammonia injection starts and the SCR inlet gas temperature is greater than 

580 degrees F. Shutdown begins when the ammonia injection stops and the SCR inlet flue gas temperature drops below 580 

degrees F. Shutdown ends with flame out.

48 “Boiler operating day” means a 24-hour period during which fossil fuel is combusted in a steam generating unit for the entire 

24 hours. [s. NR 440.20(2)(e), Wis. Adm. Code]

49 Ibid. (Same as previous footnote.)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 84

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx) - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) When operating the boiler

during periods when the NOx

CEMS is not operating,

50 the 

permittee shall maintain the 

parameters identified in condition 

I.C.3.c.(4), within the following 

normal operating ranges or normal 

operating ranges approved by the 

department in writing, averaged 

over each 24-hour period the boiler 

is operated:

(a) Either:

(i) Carbon monoxide emissions 

in compliance with the emission 

limitations in I.C.4.a.(1), or

(ii) Percent excess O2: 1.8% to 

5.1%.

(b) SCR inlet temperature: 580 to 

820 degrees Fahrenheit 

(c) SCR differential pressure: 2 to 

10 inches WC.

[s. 285.65(3), Wis. Stats. and 03-

RV-248-R4]

(2) Continuous Emission Monitoring Requirements:

(a) The permittee shall calibrate, maintain, and operate continuous emissions 

monitoring systems (CEMs)51, and record the output of the system for measuring 

nitrogen oxides emissions discharged to the atmosphere. 

(b) The permittee shall calibrate, maintain, and operate a continuous monitoring system 

and record the output of the system for measuring the oxygen or carbon dioxide content 

of the flue gases at each location where nitrogen oxides are monitored.

(c) Continuous emissions monitoring systems shall be installed, certified, and operated 

in accordance with 40 CFR Part 75, s. NR 440.20(7)(c), Wis. Adm. Code, s. NR 

439.06(2), Wis. Adm. Code, and 40 CFR s. 60.49Da(c). 

(d) The continuous monitoring systems required by (a) and (b) shall be operated and 

data recorded during all periods of operation of the affected facility including periods of 

startup, shutdown, malfunction or emergency conditions, except for continuous 

monitoring system breakdowns, repairs, calibration checks and zero and span 

adjustments.

(e) The permittee shall obtain emission data for at least 18 hours in at least 22 out of 30 

successive boiler operating days. If this minimum data requirement cannot be met with 

a continuous monitoring system, the permittee shall supplement emission data with 

other monitoring systems approved by the department or the reference methods and 

procedures described in s. NR 440.20(7)(h) (40 CFR s. 60.49Da(h)).

(f) The continuous monitoring systems required by (a) and (b) shall complete a 

minimum of one cycle of operation (sampling, analyzing and data recording for each 

successive 15 minute period.

(g) One-hour averages shall be computed from 4 or more data points equally spaced 

over each one-hour period. Data recorded during periods of continuous monitoring 

system breakdowns, repairs, calibration checks, and zero and span adjustments may not 

be included in the data averages.

(h) The one-hour averages shall be expressed in lbs/million Btu heat input and used to 

calculate the average daily, 30-day and 12 consecutive month emission rates. The one 

hour averages shall be calculated using the data points required by s. NR 440.13(2). At 

least 2 data points shall be used to calculate the one-hour averages.

(i) The span value for nitrogen oxides is 1000 ppm or the NOx span values determined 

according to section 2.1.2 in Appendix A to 40 CFR 75.52 [s. NR 440.20(7)(i)3., Wis. 

Adm. Code, 40 CFR s. 60.49Da(i)(3) and 40 CFR 60.486(e)(2)(ii)]

(j) Continuous emissions monitoring systems shall be installed and operated in 

accordance with 40 CFR Part 75, s. NR 440.20(7)(d), Wis. Adm. Code, 40 CFR s. 

60.49Da(d), and s. NR 439.06(6)(b), Wis. Adm. Code requirements. 

(k) When calculating hourly emissions in pounds per million Btu, a minimum 

concentration of 5.0 percent carbon dioxide or a maximum concentration of 14.0 

percent oxygen may be substituted for the measured diluent gas concentration value for 

any operating hour in which the hourly average carbon dioxide concentration is less 

than 5.0 percent carbon dioxide or the hourly average oxygen concentration is greater 

than 14.0 percent oxygen, as described in 40 CFR Part 75 Appendix F Section 3.3.4.1. 

[ss. 285.65(3) and (10), Wis. Stats.; ss. NR 439.06, NR 440.13(8), and NR 440.20(7)(c) 

- (i), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.49Da(c)-(i)]

 50 This approach is utilized during periods when the NOx CEMS is not operating, to demonstrate continuous compliance, 

provided the CEMS meets the requirements of 40 CFR Part 75, s. NR 440.20(7)(c), Wis. Adm. Code, s. NR 439.06(2), Wis. 

Adm. Code, and 40 CFR s. 60.49Da(c).

51 The boiler is exempt from periodic compliance emission tests required by ss. NR 439.075(2)(a)2., and (3)(b), Wis. Adm. 

Code provided they operate a continuous nitrogen oxides emission monitor that meets the performance specification 

requirements of s. NR 439.09, Wis. Adm. Code, pursuant to s. NR 439.075(4)(a)2., Wis. Adm. Code.

52 See letter from Andy Seeber of DNR to Randy Oswald of WPSC dated December 5, 2007.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 85

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx) - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) The permittee shall keep appropriate records of the strip chart, round chart or data 

acquisition (DAS) system/electronic data storage continuously. [ss. 285.65(3) and (10), 

Wis. Stats. and 03-RV-248-R4]

(4) When operating the boiler during periods when the NOx CEMS is not operating, the 

permittee shall, either continuously or on a hourly basis: 

(a) To demonstrate good combustion practices, the permittee shall either:

(i) monitor and record CO emissions using the CEMS required by I.C.4.c.(2), or

(ii) monitor and record percent excess O2.

(b) Monitor and record the SCR inlet temperature.

(c) Monitor and record the SCR differential pressure.

[s. 285.65(10), Wis. Stats. and 03-RV-248-R4]

(5) The permittee shall calibrate, maintain and operate instrumentation to monitor the 

parameters identified by condition I.C.3.c.(4) [s. 285.65(3) and (10), Wis. Stats. and 03-

RV-248-R4]

(6) The permittee shall retain plans and specifications to show that the boiler is equipped 

with low NOx burners. [s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(7) For nitrogen oxides the following information shall be reported to the department for 

each 24-hour period:

(a) Calendar date.

(b) The average nitrogen oxides emission rates (lbs/mmBtu) for each 30 successive boiler 

operating days, ending with the last 30-day period in the quarter; reasons for 

noncompliance with the emission standards, and description of the corrective actions 

taken.

(c) Identification of the boiler operating days for which pollutant or diluent data have not 

been obtained by an approved method for at least 18 hours of operation of the facility; 

justification for not obtaining sufficient data; and description of corrective actions taken.

(d) Identification of the times when emissions data have been excluded from the 

calculation of average emission rates because of startup, shutdown, malfunction or other 

reasons, and justification for excluding data for reasons other than startup, shutdown, or 

malfunction.

(e) Identification of “F” factor used for calculations, method of determination and type of 

fuel combusted.

(f) Identification of times when hourly averages have been obtained based on manual 

sampling methods.

(g) Identification of times when the pollutant concentration exceeded full span of the 

continuous monitoring system.

(h) Description of any modifications to the continuous monitoring system which could 

affect the ability of the continuous monitoring system to comply with Performance 

Specification 2 or 3 of 40 CFR part 60, Appendix B.

(i) If the minimum quantity of emissions data as required by s. NR 440.20(7) (40 CFR s. 

60.49Da) is not obtained for any 30 successive boiler operating days, the information 

obtained under s. NR 440.20(6)(h) (40 CFR s. 60.48Da(h)) and listed in s. NR 

440.20(9)(c) (40 CFR s. 60.51Da(c)) shall be reported to the department for that 30-day 

period.

{Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 86

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx) - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) {... Continued from previous page...}

(j) For any periods for which nitrogen oxides emissions data are not available, the 

permittee shall submit a signed statement indicating if any changes were made in 

operation of the emission control system during the period of data unavailability. 

Operations of the control system and boiler during periods of data unavailability are to be 

compared with operation of the control system and boiler before and following the period 

of data unavailability.

(k) The permittee shall submit a signed statement indicating whether:

(i) The required continuous monitoring system calibration, span, and drift checks or 

other periodic audits have or have not been performed as specified.

(ii) The data used to show compliance was or was not obtained in accordance with the 

approved methods and procedures of ch. NR 440, Wis. Adm. Code and is 

representative of plant performance.

(iii) The minimum data requirements have or have not been met; or, the minimum data 

requirements have not been met for errors that were unavoidable.

(iv) Compliance with the standards in I.C.2.a. has or has not been achieved during the 

reporting period.

[s. NR 440.20(9), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.51Da]

(8) Report Submittal: 

(a) The permittee shall submit a written report containing the information in I.C.3.c.(7) or 

other information approved by the department in writing, to the department semiannually 

for each 6-month period. All semiannual reports shall be postmarked by the 30th day 

following the end of each 6-month period.

(b) The permittee may submit electronic quarterly reports for nitrogen oxides in lieu of 

the written reports required in (a). The format of each quarterly electronic report shall be 

coordinated with the department. The electronic report shall be submitted no later than 30 

days after the end of the calendar quarter and shall be accompanied by a certification 

statement from the permittee indicating whether compliance with the applicable emission 

standards and minimum data requirements was achieved during the reporting period. 

Before submitting the reports in the electronic format, the permittee shall coordinate with 

the department to obtain agreement to submit reports in this alternative format.

[s. NR 440.20(9)(i) and (j), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.51Da(j) and 

(k)]

(9) The permittee shall keep records adequate to show:

(a) Periods of boiler startup, including when boiler startup began and ended;

(b) Period of boiler shutdown, including when boiler shutdown began and ended.

[s. NR 439.04(1)(d), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 87

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 4. Carbon Monoxide (CO)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.15 pound per million Btu heat input averaged over any calendar day (excluding startup and/or shut down53). 

(b) 3399 tons in any 12 consecutive months for all periods, including startup and shut down.54 (BACT) 

(c) When determining compliance with these limits, the permittee shall only count the hours, and days when the boiler 

operated.

[s. NR 405.08(2), Wis. Adm. Code, s. 285.65(3) and (7), Wis. Stats., and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Carbon Monoxide Emissions shall be controlled 

using low NOx burners and good combustion practices to 

meet BACT limits. [ss. NR 405.08(2) and NR 

407.09(4)(a), Wis. Adm. Code; s. 285.65(3), Wis. Stats., 

and 03-RV-248-R4]

(2) The permittee shall demonstrate compliance with the 

carbon monoxide emission limits as follows:

(a) Daily average shall be determined by calculating the 

arithmetic average of all applicable hourly emission rates 

for a calendar day. 

(b) The hourly emission rate shall be calculated by 

combining the CO concentration and diluent 

concentration (in % O2 or % CO2) measurement 

consistent with the procedures specified in 40 CFR Part 

75 Appendix F. The conversion factor, (K), shall be 

0.7266 x 10E-7 lb CO/ft3 – ppm. 

(c) To demonstrate compliance with I.C.4.a.(1)(b), the

permittee shall calculate annual emissions by totaling the 

hourly calculated emission rate for each 12-consecutive 

month period. [s. 285.65(3), Wis. Stats. and 03-RV-248-

R4] 

(3) When operating the boiler during periods when the 

carbon monoxide CEMS is not operating, 55 the permittee 

shall maintain the percent excess O2 within the normal 

operating range of 1.8% to 5.1 % or a normal operating 

ranges approved by the department in writing, averaged 

over each 24-hour period the boiler is operated. [s. NR 

407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(1) Reference Test Method for Carbon Monoxide Emissions:

Whenever compliance emission testing is required, US EPA 

Method 10, 10B, or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. NR 

439.06(4), Wis. Adm. Code]

(2) Continuous Monitoring Requirements:

(a) The permittee shall calibrate, maintain and operate a 

continuous emissions monitoring systems (CEMS) for measuring 

carbon monoxide.56

(b) The continuous emissions monitoring system for measuring 

carbon monoxide shall comply with all the provisions and 

requirements in Performance Specification 4 in 40 CFR part 60, 

Appendix B.

(c) The permittee shall calibrate, maintain and operate a 

continuous emissions monitoring systems (CEMS) for measuring 

oxygen or CO2. 

(d) The continuous emissions monitoring system for measuring 

carbon monoxide shall comply with all the provisions and 

requirements in Performance Specification 4 in 40 CFR part 60, 

Appendix B or, for affected units the performance specifications 

in 40 CFR part 75, Appendices A to I.

(e) When calculating hourly emissions, a minimum concentration 

of 5.0 percent carbon dioxide or a maximum concentration of 14.0 

percent oxygen may be substituted for the measured diluent gas 

concentration value for any operating hour in which the hourly 

average carbon dioxide concentration is less than 5.0 percent 

carbon dioxide or the hourly average oxygen concentration is 

greater than 14.0 percent oxygen, as described in 40 CFR Part 75 

Appendix F Section 3.3.4.1.

{...Continued on Next Page...}

 53 Startup period begins with flame on and ends when the ammonia injection starts and the SCR inlet gas temperature is greater 

than 580 degrees F. Shutdown begins when the ammonia injection stops and the SCR inlet flue gas temperature drops below 

580 degrees F. Shutdown ends with flame out.

54 This limit is based on a BACT limit, 0.15 pound per million Btu heat input x heat input of the boiler x 5179.07 mmBtu/hr x 

8,760 hours/year operation x ton/2000 lbs.

55 This approach is utilized during periods when the carbon monoxide CEMS is not operating, to demonstrate continuous 

compliance, provided the CEMS meets the requirements of Performance Specification 4 in 40 CFR part 60, Appendix B or, for 

affected units the performance specifications in 40 CFR part 75, Appendices A to I.

56 The boiler is exempt from periodic compliance emission tests required by ss. NR 439.075(2)(a)2., and (3)(b), Wis. Adm. 

Code provided they operate a continuous carbon monoxide emission monitor that meets the performance specification 

requirements of s. NR 439.09, Wis. Adm. Code, pursuant to s. NR 439.075(4)(a)2., Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 88

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 4. Carbon Monoxide (CO) - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Continuous Monitoring Requirements: {...Continued from Previous 

Page...}

(f) The CEMSs shall, at a minimum, complete one cycle of sampling, analyzing 

and data recording for each successive 15 minute period. The values recorded 

shall be averaged hourly. Hourly averages shall be computed from 4 data points 

equally spaced over each 1 hour period, except during periods when calibration, 

quality assurance or maintenance activities are being performed. During these 

periods, a valid hour shall consist of at least 2 data points separated by a 

minimum of 15 minutes.

(g) Periods of excess emissions shall be reported as any calendar day or 12 

consecutive month period during which the average carbon monoxide emissions 

exceeded the emission limitation in I.C.4.1.a.(1). An exceedance shall be based 

on at least 18 and not more than 24 valid recordings of hourly average emission 

rates in any 24 hour period.

(h) The permittee shall submit quarterly excess emission reports in accordance 

with I.XXX.2.a.

[s. 285.65(3), Wis. Stats.; ss. NR 407.09(4)(a) and NR 439.09, Wis. Adm. Code 

and 03-RV-248-R4]

(3) When operating the boiler during periods when the carbon monoxide 

CEMS is not operating, the permittee shall, either continuously or on a hourly 

basis, monitor and record percent excess O2. [s. NR 439.04(1)(d), Wis. Adm. 

Code, s. 285.65(10), Wis. Stats. and 03-RV-248-R4]

(4) The permittee shall calibrate, maintain and operate instrumentation to 

monitor the parameter(s) identified by condition I.C.4.c.(3). [s. NR 

407.09(4)(a), Wis. Adm. Code, ss. 285.65(3) and (10), Wis. Stats. and 03-RV248-R4] 

(5) The permittee shall retain plans and specifications to show that the boiler is 

equipped with low NOx burners. [s. NR 439.04(1)(d), Wis. Adm. Code, s. 

285.65(3), Wis. Stats. and 03-RV-248-R4] 

(6) The permittee shall maintain the following records:

(a) The hourly average carbon monoxide emission rate, as determined in 

I.C.4.b.(2), in lbs/mmBtu and lbs/hr;

(b) The daily average carbon monoxide emission rate, as determined in 

I.C.4.b.(2), in lbs/mmBtu;

(c) The total carbon monoxide emissions for each 12 consecutive month period, 

as determined in I.C.4.b.(2), in tons.

[s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 03-RV-248-

R4]

(7) The permittee shall keep records adequate to show:

(a) Periods of boiler startup, including when boiler startup began and ended;

(b) Period of boiler shutdown, including when boiler shutdown began and 

ended.

[s. NR 439.04(1)(d), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 89

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 5. Volatile Organic Compounds (VOC)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.0036 pound per million Btu heat input averaged over any calendar day.

(b) 81.60 tons57 in any 12 consecutive months for all periods, including startup and shut down.58

(c) When determining compliance with these limits, the permittee shall only account for the hours, and days when the boiler 

operated.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) VOC Emissions shall be controlled using low NOx 

burners and good combustion practices to meet BACT 

limits. [s. NR 419.03, Wis. Adm. Code; s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) To ensure good combustion practices are utilized 

when the boiler is burning coal:

(a) the permittee shall maintain the carbon monoxide 

emissions in compliance with the emission limitations in 

I.C.4.a.(1);

(b) When operating the boiler during periods when the 

carbon monoxide CEMS is not operating,

59 the permittee 

shall maintain the percent excess O2 within the normal 

operating range of 1.8% to 5.1 % or a normal operating 

range approved by the department in writing, averaged 

over each 24-hour period the boiler is operated.

[s. NR 407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(3) The permittee shall demonstrate compliance with the 

volatile organic compound emission limit contained in 

I.C.5.a. as follows:

(a) VOC emissions shall be calculated based on each 

calendar day. 

(b) The permittee shall calculate an hourly average 

emission rate based on measured data using CO CEMs 

required in I.C.4.b.(1) by combining the CO concentration 

and diluent concentration (in %O2 or % CO2) 

measurement, consistent with the procedures specified in 

40 CFR Part 75 Appendix F, in the following equation:

VOC actual = VOC limit X (CO actual/CO limit);

(c) To demonstrate compliance with I.C.5.a.(1)(b), the 

permittee shall calculate annual emissions by totaling the 

hourly calculated emission rate for each 12-consecutive 

month period. 

[s. NR 407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4] 

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, US EPA Method 25A 

and/or 18 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(3), Wis. Adm. Code]

(2) (a) During operation, the permittee shall continuously 

monitor and record carbon monoxide emissions using the CEMS 

required by I.C.4.c.(2), to demonstrate good combustion practices 

are utilized. 

(b) When operating the boiler during periods when carbon 

monoxide CEMS is not operating, the permittee shall, either 

continuously or on an hourly basis, monitor and record percent 

excess O2, to demonstrate good combustion practices are 

utilized. 

[s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(10), Wis. Stats., 

03-RV-248-R4]

(3) The permittee shall calibrate, maintain and operate 

instrumentation to monitor the parameters identified by condition 

I.C.5.c.(2). [s. NR 407.09(4)(a), Wis. Adm. Code, ss. 285.65(3) 

and (10), Wis. Stats. and 03-RV-248-R4]

(4) The permittee shall retain plans and specifications to show 

that the boiler is equipped with low NOx burners. [s. NR 

439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 03-

RV-248-R4] 

(5) The permittee shall maintain the following records to 

document when periods of startup and shutdown occur:

(a) Date and time when startup begins with flame on;

(b) The temperature of the flue gas entering the SCR to 

document when periods of startup end and periods of shutdown 

begin. 

(c) Date and time when shutdown ends with flame out.

[s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. Stats., 

03-RV-248-R4]

 57 This limit is based on a BACT limit, 0.0036 pound per million Btu heat input x heat input of the boiler, 5173X07mmBtu/hr 

x 8,760 hours/year operation x ton/2000 lbs.

58 Startup period begins with flame on and ends when the ammonia injection starts and the SCR inlet gas temperature is greater 

than 580 degrees F. Shutdown begins when the ammonia injection stops and the SCR inlet flue gas temperature drops below 

580 degrees F. Shutdown ends with flame out

59 This approach is utilized during periods when the carbon monoxide CEMS is not operating, to demonstrate continuous 

compliance, provided the CEMS meets the requirements of Performance Specification 4 in 40 CFR part 60, Appendix B or, for 

affected units the performance specifications in 40 CFR part 75, Appendices A to I.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 90

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 6. Lead Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed 0.13 pound per hour. [s. NR 405.08(2), Wis. 

Adm. Code; s. 285.65(3) and (7), Wis. Stats., and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall perform compliance emission test to 

demonstrate compliance with the lead emission limitation in 

condition I.C.6.a.(1) as follows:

(a) A compliance emission test shall be conducted every 60 

months within 90 days from the date of the last stack test as 

long as the permit remains valid.

(b) The test shall be conducted in accordance with 

I.XXX.3.a.(1).

(c) The permittee shall perform simultaneous monitoring of 

the parameters identified in I.C.6.c.(2) to establish normal 

operational ranges. [ss. NR 407.09(4)(a) and NR 

439.075(1)(b), Wis. Adm. Code, s. 285.65(3) and (10), Wis. 

Stats. and 03-RV-248-R4]

(2) Lead emissions shall be controlled using a fabric filter 

baghouse system to meet the BACT limit. [s. NR 

407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(3) The fabric filter baghouse system shall be in line and shall 

be operated at all times when the boiler is in operation60 and 

coal is being fired. [ss. NR 406.10 and NR 407.09(4)(a)1., 

Wis. Adm. Code and 03-RV-248-R4]

(4) The pressure drop across the fabric filter baghouse system 

shall be maintained as required by condition I.C.1.b.(9). [s. 

NR 407.09(4)(a)1., Wis. Adm. Code, s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(1) Reference Test Method for Lead Emissions: Whenever 

compliance emission testing is required, US EPA Method 12 

or Method 29 or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall continuously monitor the operating 

pressure drop across the fabric filter system and shall sound 

an audible alarm, whenever the operating pressure drop is 

below the minimum pressure drop identified in I.C.6.b.(4). [s. 

NR 439.055(5), Wis. Adm. Code and 04-RV-248-R4]

(3) The permittee shall record the pressure drop across the 

fabric filter baghouse system a minimum of once for every 8 

hours of source operation or once per day, whichever yields 

the greater number of measurements. [s. NR 439.055(2)(b)1., 

Wis. Adm. Code and 03-RV-248-R4]

(4) The permittee shall maintain records of all inspections, 

checks and any maintenance or repairs performed on the 

fabric filter baghouse system, containing the date of the 

action, initials of inspector, and the results. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(5) Upon detecting an excursion or exceedance of the range 

specified in condition I.C.6.b.(4), the permittee shall respond 

to every “out of range” pressure drop alarm by restoring 

operation of the baghouse to its normal or usual manner of 

operation as expeditiously as practicable in accordance with 

good air pollution control practices for minimizing emissions. 

[s. NR 407.09(4)(a), Wis. Adm. Code, 40 CFR 64.7(d)(1), s. 

285.65(3), Wis. Stats. and 04-RV-248-R4]

(6) The permittee shall maintain records of:

(a) The results of the compliance emission tests required by 

condition I.C.6.b.(1); and

(b) The parameter monitoring and associated operating 

ranges for the parameters identified in condition I.C.6.c.(2) as 

recorded during the compliance emission tests required by 

condition I.C.6.b.(1).

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

 

60 Boiler operation (as it relates to baghouse operation) is any time the draft ID fan(s) are in operation. See normal start-up and 

shut-down sequence in condition I.C.9.b.(3).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 91

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 7. Mercury Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed: 

(i) 1.7 pound per trillion Btu heat input in any 12 consecutive months; AND

(ii) 0.8 pounds per trillion Btu heat input in any 12 consecutive months.61 

(b) Compliance shall be demonstrated using an Hg CEMS installed, certified, operated, maintained, and the data quality 

assured in accordance with 40 CFR s. 63.10010 and Appendix A of 40 CFR, Part 63, Subpart UUUUU, or as approved by the 

department in writing. [ss. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.; 03-RV-248-R6]

(2) Case-by-case Maximum Achievable Control Technology (MACT):

(a) Emissions may not exceed 1.7 pound per trillion Btu heat input in any 12 consecutive months.

(b) Compliance shall be demonstrated as required by condition I.C.7.a.(1)(b).

(c) The permittee shall comply with the emission limitation in I.C.7.a.(2)(a) until April 16, 2015, the compliance date for 

existing sources subject to National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam 

Generating Units, 40 CFR Part 63 Subpart UUUUU. The permitte shall comply with the requirements of section I.C.15., in 

lieu of this section, starting on April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b)]

[40 CFR s. 63.43, 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Mercury emissions shall be 

controlled using a fabric filter 

baghouse system coupled with the 

sorbent injection system to meet 

the BACT limits of I.C.7.a.(1)(a)(i) 

and (ii) and the MACT limit of 

I.C.7.a.(2), whenever coal is fired 

in boiler B04. [ss. 285.65(3) and 

(7), Wis. Stats., s. NR 407.09(1)(c) 

and (4), Wis. Adm. Code, and 03-

RV-248-R4]

(1) Reference Test Method for Mercury Emissions: Whenever compliance emission 

testing is required, US EPA Methods 29, 30A and 30B or an alternative method 

approved in writing by the department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The monitoring, recording and recordkeeping requirements for the baghouse system 

identified in conditions I.C.1.c.(2) through (8) shall be used as monitoring, recording and 

recordkeeping requirements for the mercury emission limitations in I.C.7.a. [s. NR 

439.055(2)(b)1., Wis. Adm. Code, and 03-RV-248-R4]

 61 The emission limitation of 0.8 pounds per trillion Btu heat input is the rate shown to be reflective of the actual achievable

mercury reductions as determined by the optimizations study and compliance emission tests required by permit 03-RV-248-

R4. Condition I.A.8.b.(2) of construction permit 03-RV-248-R4 required the permittee to perform an optimization study 

within 18 months of initial operation, to determine the minimum sorbent feed rate, evaluate the effect of increased sorbent 

injection, evaluate the effect of increase slurry in the spray dryer, optimize the SCR unit, determine actual operating 

conditions, and determine the achievable mercury reductions. The results of the optimization study are summarized in a 

report submitted by the permittee dated November 19, 2009. Condition I.A.8.b.(4) of construction permit 03-RV-248-R4 

required the permittee to perform 4 mercury compliance emission tests within 18 months of initial operation. Condition 

I.A.8.b.(6) of construction permit 03-RV-248-R4 required the permittee to submit the results of the compliance emission tests 

and required the department to review the test results and adjust the emission limit to more accurate reduction levels for 

mercury when the operation permit is issued. Establishing a mercury emission limitation based on the achievable mercury 

reductions demonstrated through compliance emission testing and the mercury optimization study is not being done as a Title 

V action, but is a requirement of the Title I construction permit for boiler B04. (See construction permit 03-RV-248 and its 

subsequent revisions.) Because Title V operation permits are required to contain all applicable requirements, the limit 

established through the Title I construction permit requirement is being placed in the facility’s renewed Title V operation 

permit.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 92

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 7. Mercury Emissions - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping and 

Monitoring:

(2) To demonstrate compliance with the BACT & MACT emission limitations

in I.C.7.a., the permittee shall 

(a) Operate a mercury continuous emission monitoring system (Hg CEMS) 

according to the requirements of I.C.7.c.(5). The Hg CEMS shall be installed, 

certified, operated, maintained, and the data quality assured in accordance with 

40 CFR s. 63.10010 and Appendix A of 40 CFR, Part 63, Subpart UUUUU, or 

as approved by the department in writing. (See sections I.XXX.12. and 13. for 

additional requirements.) 

(b) When operating the boiler during periods when the Hg CEMS is not 

operating,62 the permittee shall maintain the minimum sorbent feed rate, 

averaged over each 24-hour period the boiler is operated63 or until the CEMS is 

returned to service (excluding periods of flushes, startup, shutdown, and 

maintenance), as follows:

(i) not less than 3.0 pounds of sorbent per MMacf of exhaust gas;

or

(ii) an alternate minimum sorbent feed rate approved by the department in 

writing, which meets the following criteria: 

a)The alternate minimum sorbent feed rate has been shown to 

demonstrate compliance with the mercury emission limitations of 

conditions I.C.7.a.(1) and (2), through either compliance emission testing 

or data collected from a certified Hg CEMS that is operating in 

accordance with the requirements of I.C.7.b.(2)(a);

b) If the permittee elects to utilize mercury control enhancing 

chemical(s) in addition to or without the sorbent under (ii)(a), the 

addition of such chemical(s) and the addition of any sorbent(s) is 

maintained at the rate(s) used during the testing which demonstrated 

compliance with the mercury emission limitations in I.C.7.a.(1) and (2); 

and

c) The alternate minimum sorbent feed rates from (ii)a) and (ii)b) shall 

be based on compliance emission testing or periods using data collected 

from a certified Hg CEMS, when the boiler was operating at capacity or 

as close to capacity as practicable. 

[40 CFR s. 63.43, ss. NR 405.08 and NR 407.09(1)(c) and (4), Wis. Adm. 

Code, s. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R6]

(3) The permittee shall maintain records of:

(a) the date, time, and initials of the person 

performing the inspections required by 

I.C.7.b.(4);

(b) a list of the items inspected;

(c) any maintenance, repairs, or adjustments 

performed as a result of these inspections; 

(d) the operating hours of the boiler since 

the last inspection;

(e) the monthly average mercury content of 

the coal fired in boiler B04; and

(f) the monthly average higher heating 

value of the coal fired in boiler B04.

[s. NR 439.04(1)(d), Wis. Adm. Code and 

03-RV-248-R4]

 62 This approach is utilized during periods when the mercury CEMS is not operating to demonstrate continuous compliance, 

provided the CEMS is installed and certified and being operated, maintained and the data quality assured in accordance with 40 

CFR s. 63.10010 and Appendix A of 40 CFR, Part 63, Subpart UUUUU, or as approved by the department in writing.

63 Only hours when the boiler is operated shall be included in the average in I.C.7.b.(2).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 93

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 7. Mercury Emissions - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) The compliance demonstration methods 

for the baghouse system identified in 

conditions I.C.1.b.(2) through (9), shall be 

used as compliance demonstration methods 

for the mercury emission limitations in 

I.C.7.a., in addition to those included under 

section I.C.7.b . [s. 285.65(3), Wis. Stats., s. 

NR 407.09(1)(c) and (4), Wis. Adm. Code and 

03-RV-248-R4]

(4) Continuous Emission Monitoring Requirements:

(a) The Hg CEMS shall be installed, certified, operated, maintained, and 

quality assured in accordance with 40 CFR s. 63.10010 and Appendix A of 40 

CFR, Part 63, Subpart UUUUU, or as approved by the department in writing. 

[ss. NR 407.09(1)(c) and (4) and NR 439.095(6), Wis. Adm. Code]

(b) The Hg CEMS shall, at a minimum, complete one cycle of sampling, 

analyzing and data recording for each successive 15-minute period. The 

values recorded shall be averaged hourly. Hourly averages shall be computed 

from a minimum of 4 data points equally spaced over each 1 hour period, 

except during periods when calibration, quality assurance or maintenance 

activities are being performed. During these periods a valid hour shall consist 

of at least 2 data points separated by a minimum of 15 minutes. [ss. NR 

407.09(1)(c) and (4) and NR 439.09(9)(b), Wis. Adm. Code]

(c) (i) The hourly average mercury emission rates shall be used to calculate a 

monthly average mercury emission rate for the periods during each 

calendar month that the boiler is operated, in pounds per trillion Btu heat 

input to the boiler. 

(ii) The 12-month rolling average mercury emission rate shall be 

calculated monthly for the previous 12 consecutive month period, in 

pounds per trillion Btu heat input to the boiler.

(iii) The permittee shall keep monthly records of the monthly average 

mercury emission rate and the 12-month rolling average mercury 

emission rate.

[ss. NR 407.09(1)(c) and (4), and s. NR 439.04(1)(d), Wis. Adm. Code]

(d) Quarterly Excess Emission Reports: The permittee shall submit quarterly 

excess emission reports to the department in accordance with I.XXX.2.a.(1) 

and (2). [s. NR 439.09(10), Wis. Adm. Code]

(e) Periods of excess emissions shall be reported as any 12-month rolling 

average during which mercury emissions exceed the applicable emission 

limitations in I.C.7.a.(1). [s. NR 439.09(10), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 94

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 7. Mercury Emissions - {Continued}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(4) The permittee shall perform periodic inspections of the sorbent 

injection system to ensure that the control equipment is operating 

properly. The time interval between inspections may not exceed 13,140 

operating hours, unless written approval from the Department is granted 

allowing for a greater interval. Such a request may only be granted if the 

applicant demonstrates that such an interval is needed to maintain a 

stable electric power supply. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code]

(5) During periods when the Hg CEMS is not 

operating the permittee shall:

(a) Continuously monitor the following:

(i) Sorbent feed rate in pounds per MMacf of 

exhaust gas;

(ii) Amount or feed rate of any mercury control 

enhancing chemical(s) used;

(b) Keep records of:

(i) The type of sorbent used during the period in 

question;

(ii) The feed rate of sorbent used, averaged over 

each 24-hour period that the boiler is operated 

during the period in question, or averaged over the 

period in question if less than 24 hours in duration; 

(iii) The type of any mercury control enhancing 

chemical(s) used during the period in question;

(iv) The feed rate of any mercury control enhancing 

chemical(s) used, averaged over each 24-hour 

period that the boiler is operated during the period 

in question, or averaged over the period in question 

if less than 24 hours in duration;

(v) The start and end time of the period in question;

(vi) The duration of the period in question;

[ss. NR 407.09(1)(c) and (4) and NR 439.04(1)(d), 

Wis. Adm. Code, 03-RV-248-R6]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 95

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 8. Emissions of Fluorides

a. Limitations:

(1) 0.000217 pound per million Btu heat input (1.12 pounds per hour). (BACT) [s. NR 405.08(2), Wis. Adm. Code; s. 

285.65(3), Wis. Stats.; s. 285.65 (7) Wis. Stats.] 

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Emissions of fluorides shall be controlled by a fabric 

filter baghouse system and a dry FGD system. [s. NR 

407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(2) Compliance demonstration requirements of I.C.1.b.(2), 

(4), (6), and (7) shall be used as compliance demonstration 

methods for fluoride emissions. [s. NR 407.09(4)(a), Wis. 

Adm. Code, s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Emissions of Fluorides: 

Whenever compliance emission testing is required, US EPA 

Method 13B or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The monitoring and recordkeeping requirements of 

I.C.1.c.(2)-(5), (7) and (8) shall be used as monitoring and 

recordkeeping requirements for fluoride emissions. [s. NR 

439.04(1)(d), Wis. Adm. Code, 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 96

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 9. Visible Emissions

a. Limitations:

(1) (a) The permittee may not cause to be discharged into the atmosphere any gases which exhibit greater than 20% opacity (6-

minute average), except for one 6-minute period per hour of not more than 27% opacity. 

(b) The emission standard in (a) applies at all times except periods of startup, shutdown, and malfunction.

[ss. NR 431.05, NR 440.20(3)(b) and NR 440.20(6)(c), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.42Da(b) and s. 

60.48Da(c)]

(2) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.64 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.05, Wis. Adm. Code]

(3) Best Available Control Technology (BACT)65 [s. NR 405.08, Wis. Adm. Code and Court of Appeals Decision Dated and 

Filed May 13, 2010, Appeal No. 2009AP648, Cir Ct. No. 2007CV1455]

b. Compliance 

Demonstration:

c. Test Methods, Recordkeeping, and Monitoring:

(1) Opacity shall be controlled 

using a fabric filter baghouse 

system. [s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(2) The fabric filter baghouse 

system shall be in line and shall 

be operated at all times when the 

boiler is in operation66 and coal 

is being fired. [ss. NR 406.10 

and NR 407.09(4)(a)1., Wis. 

Adm. Code and 03-RV-248-R4]

(1) Reference Test Method for Visible Emissions: Whenever compliance emission testing 

is required, US EPA Method 9 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [ss. NR 439.06(9)(a)1., NR 

440.20(8)(b)3., Wis. Adm. Code, 40 CFR s. 60.50Da(b)(3)]

(2) The permittee shall calibrate, maintain and operate a continuous monitoring system, 

and record the output of the system, for measuring the opacity of emissions discharged to 

the atmosphere. [s. NR 440.20(7)(a), Wis. Adm. Code, s. 285.65(10), Wis. Stats., 03-RV248-R4, 40 CFR s. 60.49Da(a)]

(3) The continuous opacity monitor (COM) may be located after the baghouse. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(4) The continuous opacity monitors required by I.C.9.c.(2) shall complete one cycle of 

sampling and analyzing for each successive 10-second period and one cycle of data 

recording for each successive 6-minute period. [s. NR 439.09(9)(a), Wis. Adm. Code]

(5) Unless otherwise specified by the Department, periods of excess visible emissions shall 

be any 6-minute period during which the average opacity exceeds the limitation in 

I.C.9.a.(1). [ss. NR 439.09(10)(b) and NR 440.20(9)(h), Wis. Adm. Code, 40 CFR s. 

60.51Da(i)]

 64 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

65 The District IV COURT OF APPEALS DECISION DATED AND FILED May 13, 2010, Appeal No. 2009AP648, SIERRA 

CLUB v. WISCONSIN DEPARTMENT OF NATURAL RESOURCES, WISCONSIN PUBLIC SERVICE CORPORATION AND DAIRYLAND 

POWER COOPERATIVE (Cir. Ct. No. 2007CV1455) concluded that boiler B04 is subject to a BACT visible emission limitation. 

The BACT visible emission limitation may not be established in this Title V operation permit renewal, but must be established 

in a Title I, new source review action. The compliance plan and schedule in condition I.XXX.13.(1)(b), lays out the procedure 

that shall be followed to establish the specific visible emission BACT limitation for boiler B04.

66 Boiler operation (as it relates to baghouse operation) is any time the draft ID fan(s) are in operation. See normal start-up and 

shut-down sequence in condition I.C.9.b.(3).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 97

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 9. Visible Emissions {CONTINUED}

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) To minimize visible emissions, the 

permittee shall start-up and shut-down each 

boiler according to the following:67

(a) Normal Start-up Sequence:

(i) Place the baghouse in service and ensure 

continuous opacity monitor is operational, 

or in accordance with an alternative 

monitoring method approved in writing by 

the Department.

(ii) Start the draft fan(s)

(iii) Preheat boiler firing natural gas.

(iv) Introduce coal to the combustion 

chamber while continuing to operate the gas 

burners as the coal begins to ignite.

(v) Continue the use of the gas burner 

during startup to achieve a stable coal fire.

(vi) Normal start-up is complete when: 1. 

A stable coal fire is achieved; 2. A 

minimum SCR operating temperature of 

580 degrees Fahrenheit is achieved; and 3. 

Ammonia injection starts.68

(b) Normal Shut-down Sequence:

(i) Reduce generator load below 350 MW 

with the intent of removing the unit from 

service.69

(ii) Discontinue coal introduction to boiler 

and cease fuel firing.

(iii) Discontinue operation of the draft fans.

(iv) Discontinue operation of baghouse.

(v) Normal shut-down is complete after 

item (iv) or a start-up of the boiler 

commences.

[s. NR 407.09(4)(a), Wis. Adm. Code]

(6) The permittee shall submit quarterly excess emission reports to the 

Department by January 30, April 30, July 30, and October 30 for the previous 

calendar quarter, in accordance with I.XXX.2.a. These reports shall include, 

but not be limited to:

(a) For any periods for which opacity emissions data are not available, the 

permittee shall submit a signed statement indicating if any changes were made 

in operation of the emissions control system during the period of data 

unavailability. Operations of the control system and affected facility during 

periods of data unavailability are to be compared with operation of the control 

system and affected facility before and following the period of data 

unavailability.

(b) The report shall include a signed statement indicating whether:

(i) The required continuous monitoring system calibration , span, and drift 

checks or other periodic audits have or have not been performed as 

specified.

(ii) The data used to show compliance was or was not obtained in 

accordance with approved methods and procedures of ch. NR 440 and is 

representative of plant performance.

(iii) The minimum data requirements have or have not been met; or, the 

minimum data requirements have not been met for errors that were 

unavoidable.

(iv) Compliance with the standards has or has not been achieved during the 

reporting period.

(c) Identification of opacity levels in excess of the opacity standard in 

I.C.9.a.(1) and the date of such excesses shall be submitted to the department 

each calendar quarter.

[ss. NR 439.09(10) and NR 440.20(9), Wis. Adm. Code, 40 CFR s. 60.51Da]

(7) The permittee may submit electronic quarterly reports in lieu of submitting 

the written report required by I.C.9.c.(6). The format shall be coordinated with 

the department. The electronic report shall be submitted no later than 30 days 

after the end of the calendar quarter and accompanied by a certification 

statement indicating whether compliance with the applicable emission standards 

and minimum data requirements of this section was achieved during the 

reporting period. Before submitting reports in the electronic format, the 

permittee shall coordinate with the department to obtain approval. [s. NR 

440.20(9)(j), Wis. Adm. Code, 40 CFR s. 60.51Da(k)]

 67 The following start-up and shut-down sequence contains a summary of steps to limit visible emissions.

68 The normal start-up sequence from first coal fire to stable coal fire is generally less than 12 hours in duration.

69 All values are gross MW.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 98

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 10. Beryllium

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed 1.3 pound per trillion Btu heat input. [s. NR 

405.08(2), Wis. Adm. Code; ss. 285.65(3) and (7), Wis. Stats., and 03-RV-248-R4

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall perform compliance 

emission test to demonstrate compliance with the 

beryllium emission limitation in condition 

I.C.10.a.(1) as follows:

(a) A compliance emission test shall be conducted 

every 60 months within 90 days from the date of the 

last stack test as long as the permit remains valid.

(b) The test shall be conducted in accordance with 

I.XXX.3.a.(1).

(c) The permittee shall perform simultaneous 

monitoring of the parameters identified in 

I.C.10.c.(2). [ss. NR 407.09(4)(a) and NR 

439.075(1)(b), Wis. Adm. Code, s. 285.65(3) and 

(10), Wis. Stats. and 03-RV-248-R4]

(2) Beryllium emissions shall be controlled by a 

fabric filter baghouse system to meet the BACT 

limit. [s. NR 407.09(4)(a), Wis. Adm. Code; s. 

285.65(3), Wis. Stats., and 03-RV-248-R4]

(3) The fabric filter baghouse system shall be in line 

and shall be operated at all times when the boiler is 

in operation70 and coal is being fired. [ss. NR 

406.10 and NR 407.09(4)(a)1., Wis. Adm. Code and 

03-RV-248-R4]

(4) The pressure drop across the fabric filter 

baghouse system shall be maintained as required by 

condition I.C.1.b.(9). [s. NR 407.09(4)(a)1., Wis. 

Adm. Code, s. 285.65(3), Wis. Stats. and 03-RV248-R4]

(5) The permittee shall monitor beryllium emissions 

through coal sampling and analysis done in 

accordance with the methods and procedures 

outlined in I.XXX.4.a. and s. NR 439.08(1), Wis. 

Adm. Code. The permittee shall monitor monthly 

average beryllium content and higher heating value 

in the coal. The data obtained from the coal sampling 

and analysis shall be correlated with the results of the 

latest compliance emission test for the purpose of 

calculating the beryllium emission rate. [s. NR 

407.09(4)(a)1., Wis. Adm. Code and 03-RV-248-R4]

(1) Reference Test Method for Emissions of Beryllium: Whenever 

compliance emission testing is required, US EPA Method 29 or an 

alternate method approved in writing by the Department, shall be used 

to demonstrate compliance. [s. NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall continuously monitor the operating pressure 

drop across the fabric filter system and shall sound an audible alarm, 

whenever the operating pressure drop is below the minimum pressure 

drop identified in I.C.10.b.(4). [s. NR 439.055(5), Wis. Adm. Code and 

04-RV-248-R4]

(3) The permittee shall record the pressure drop across the fabric filter 

baghouse system a minimum of once for every 8 hours of source 

operation or once per day, whichever yields the greater number of 

measurements. [s. NR 439.055(2)(b)1., Wis. Adm. Code and 03-RV248-R4]

(4) The permittee shall maintain records of all inspections, checks and 

any maintenance or repairs performed on the fabric filter baghouse 

system, including the date of the action, initials of inspector, and the 

results. [s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(5) Upon detecting an excursion or exceedance of the range specified 

in condition I.C.10.b.(4), the permittee shall respond to every “out of 

range” pressure drop alarm by restoring operation of the baghouse to 

its normal or usual manner of operation as expeditiously as practicable 

in accordance with good air pollution control practices for minimizing 

emissions. [s. 285.65(3), Wis. Stats. and 04-RV-248-R4]

(6) The permittee shall maintain records of:

(a) The results of the compliance emission tests required by condition 

I.C.10.b.(1); and

(b) The parameter monitoring and associated operating ranges for the 

parameters identified in condition I.C.10.c.(2) as recorded during the 

compliance emission tests required by condition I.C.10.b.(1).

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

(7) The permittee shall maintain monthly records of:

(a) the average beryllium content of the coal as determined in 

I.C.10.b.(5);

(b) the average higher heating value of the coal as determined in 

I.C.10.b.(5);

(c) The calculated beryllium emission rate in pounds per trillion Btu 

heat input as determined in I.C.10.b.(5).

[s. NR 439.04(1)(d), Wis. Adm. Code]

 

70 Boiler operation (as it relates to baghouse operation) is any time the draft ID fan(s) are in operation. See normal start-up and 

shut-down sequence in condition I.C.9.b.(3).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 99

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 11. Hazardous air pollutants (inorganic solid HAPs, inorganic acid HAPs, Organic HAPs) regulated under sec. 112 

of the Clean Air Act.

a. Limitations:

(1) The permittee shall use fabric filter baghouse and comply with the PM/PM10 limits in I.C.1.a(1) to meet case-by-case 

MACT for inorganic solid HAPs; 

(2) The permittee shall use a dry flue gas desulfurization system (FGD) and comply with the emission limitation of condition 

I.C.2.a.(1) to meet case-by-case MACT limits for inorganic acid HAPs; 

(3) The permittee shall comply with and meet the VOC emission limits in I.C.5.a.(1) to comply with case-by-case MACT for 

organic HAPs 

[40 CFR s. 63.43; s. 285.65(13), Wis. Stats; and 03-RV-248-R4]

The permittee shall comply with the requirements of this section until April 16, 2015, the compliance date for existing 

sources subject to National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam 

Generating Units, 40 CFR Part 63 Subpart UUUUU. The permitte shall comply with the requirements of section I.C.15., in 

lieu of this section, starting on April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Inorganic HAP emissions shall be controlled using a fabric 

filter baghouse system. [40 CFR s. 63.43, s. NR 407.09(4)(a)1., 

Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The fabric filter baghouse system shall be in line and shall 

be operated at all times when the boiler is in operation71 and 

coal is being fired. [ss. NR 406.10 and NR 407.09(4)(a)1., 

Wis. Adm. Code and 03-RV-248-R4]

(3) The compliance demonstration methods identified in 

conditions I.C.1.b. (4), (6) and (7) shall be used as compliance 

demonstration methods for inorganic HAP emission limitations 

in I.C.11.a.(1). [s. NR 407.09(4)(a)1., Wis. Adm. Code, s. 

285.65(3), Wis. Stats. and 03-248-R4]

(4) Inorganic acid HAPs emission shall be controlled using a 

dry flue gas desulfurization system (FGD) [40 CFR s. 63.43, s. 

NR 407.09(4)(a)1., Wis. Adm. Code, s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(5) The compliance demonstration method identified in 

condition I.C.2.b.(1) through (3) shall be used as compliance 

demonstration methods for inorganic acid HAPs emission 

limitations in I.C.11.a. (2). [s. 285.65(3), Wis. Stats. and 03-

RV-248-R4]

(6) Organic HAPs emission shall be controlled using good 

combustion practices. [40 CFR s. 63.43, s. NR 407.09(4)(a)1., 

Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(7) The compliance demonstration method identified in 

section I.C.5.b. shall be used as compliance demonstration 

methods for organic HAPs emission limitations in I.C.11.a.(3). 

[s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for organic HAPs Emissions; 

inorganic solid HAPs, and inorganic acid HAPs: Whenever 

compliance testing is required, a compliance test protocol 

approved in writing by the Department, shall be used to 

demonstrate compliance. [s. NR 439.06(8), Wis. Adm. 

Code]

(2) The recordkeeping, recording and monitoring 

requirements of conditions I.C.1.c.(2) through (5), (7), and 

(8) shall be used as recordkeeping, recording and monitoring 

requirements for the inorganic solid HAP emission limitation 

in I.C.11.a.(1). [s. NR 439.04(1)(d), Wis. Adm. Code]

(3) The recordkeeping, recording and monitoring 

requirements of condition I.C.2.c.(4) and (5) shall be used as 

recordkeeping, recording and monitoring requirements for 

the inorganic acid HAP emission limitation in I.C.11.a.(2). 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(4) The recordkeeping, recording and monitoring 

requirements of conditions I.C.5.c.(2) through (5) shall be 

used as recordkeeping, recording and monitoring 

requirements for the organic HAP emission limitation in 

I.C.11.a.(3). [s. NR 439.04(1)(d), Wis. Adm. Code]

 

71 Boiler operation (as it relates to baghouse operation) is any time the draft ID fan(s) are in operation. See normal start-up and 

shut-down sequence in condition I.C.9.b.(3).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 100

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 12 Ammonia Emissions

a. Limitations:

(1) 3 ppm volume dry corrected to 3% percent oxygen and 55.52 pounds per hour72 [ s. NR 445.04(1), Wis. Adm. Code and 

03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall perform compliance emission tests to 

demonstrate compliance with the hourly ammonia emission 

limitation in condition I.C.12.a.(1) as follows:

(a) A compliance emission test shall be conducted every 60 

months within 90 day from the date of the last stack test as 

long as the permit remains valid.

(b) The tests shall be conducted in accordance with 

I.XXX.3.a.(1).

[ss. NR 407.09(4)(a) and NR 439.075(1)(b), Wis. Adm. Code, 

ss. 285.65(3) and (10), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Ammonia: Whenever 

compliance testing for ammonia is required, USEPA Method 

027, or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall retain records of the results of the 

compliance emission tests required by condition I.C.12.b.(1). 

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

 72 These emissions do not result from combustion. Aqueous ammonia is used as the reagent for the SCR. Ammonia that does 

not react is exhausted out of the stack.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 101

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 13. Sulfuric Acid Mist (H2SO4)

a. Limitations:

(1) Best Available Control Technology (BACT): 0.005 pound per million Btu heat input, based upon a 24-hour average. [s. 

NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Sulfuric acid mist emissions shall be controlled by a FGD 

system to meet the BACT limits. [s. NR 405.08(2), Wis. 

Adm. Code and 03-RV-248-R4]

(2) The boiler may only be fired on coal and natural gas. [ss. 

NR 405.08(2) and NR 406.10, Wis. Adm. Code; s. 285.65(3), 

Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall perform compliance emission tests to 

demonstrate compliance with the sulfuric acid mist emission 

limitation in condition I.C.13.a.(1) as follows:

(a) A compliance emission test shall be conducted every 60 

months within 90 days from the date of the last stack test as 

long as the permit remains valid. 

(b) The test shall be conducted in accordance with 

I.XXX.3.a.(1).

(c) The permittee shall perform simultaneous monitoring of 

the parameters identified in I.C.13.c.(2)(b) and (3).

[ss. NR 407.09(4)(a) and NR 439.075(1)(b) Wis. Adm. Code, 

s. 285.65(10), Wis. Stats., and 03-RV-248-R4]

(4) The permittee shall maintain the flow rate of the aqueous 

lime/recycled ash slurry to the FGD system at not less than 

50 gallons per minute per side and not less than 100 gallons 

per minute total, averaged over each day the boiler is 

operated73 (excluding flushes, startup, shutdown, and 

maintenance), or the value established during the most recent 

stack test that demonstrated compliance with the emission 

limitation in I.C.13.a.(1), if approved by the department in 

writing. [s. NR 407.09(4)(a), Wis. Adm. Code, s. 285.65(3), 

Wis. Stats. and 03-RV-248-R4]

(5) To ensure good combustion practices are utilized when 

the boiler is burning coal:

(a) the permittee shall maintain the carbon monoxide 

emissions in compliance with the emission limitations in 

I.C.4.a.(1);

(b) When operating the boiler during periods when the

carbon monoxide CEMS is not operating, 74 the permittee 

shall maintain the percent excess O2 within the normal 

operating range of 1.8% to 5.1 % or a normal operating range 

approved by the department in writing, averaged over each 

24-hour period the boiler is operated.

[s. NR 407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(1) Reference Test Method for Sulfur Acid Mist Emissions:

Whenever compliance emission testing is required, US EPA 

Method 8 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) (a) During operation, the permittee shall continuously 

monitor and record carbon monoxide emissions using the 

CEMS required by I.C.4.c.(2), to demonstrate good 

combustion practices are utilized. 

(b) When operating the boiler during periods when the

carbon monoxide CEMS is not operating, the permittee shall, 

either continuously or on an hourly basis, monitor and record 

percent excess O2, to demonstrate good combustion practices 

are utilized. 

[s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(10), Wis. 

Stats. and 03-RV-248-R4]

(3) During operation, the permittee shall monitor and record 

the flow rate of the aqueous lime/recycled ash slurry to the 

dry flue gas desulfurization (FGD) system once every 8 hours 

of operation or once per day, whichever yields the greater 

number of measurements. [ss. NR 439.04(1)(d) and NR 

439.055(1)(a), Wis. Adm. Code and 03-RV-248-R4]

(4) The permittee shall maintain records of: 

(a) The results of the compliance emission tests required by 

condition I.C.13.b.(3); and 

(b) The parameter monitoring and associated operating 

ranges for the parameters identified in condition 

I.C.13.c.(2)(b) and (3) as recorded during the compliance 

emission tests required by condition I.C.13.b.(3).

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

 73 Only hours when the boiler is operated shall be included in the average in I.C.2.b.(2).

74 This approach is utilized during periods when the carbon monoxide CEMS is not operating, to demonstrate continuous 

compliance, provided the CEMS meets the requirements of Performance Specification 4 in 40 CFR part 60, Appendix B or, for 

affected units the performance specifications in 40 CFR part 75, Appendices A to I .
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 102

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 14. Hydrogen Chloride

a. Limitations:

(1) 10.94 pounds per hour, based upon a 24-hour average (MACT), regulated under sec. 112 of the Clean Air Act. [40 CFR s. 

63.43, s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

The permittee shall comply with the requirements of this section until April 16, 2015, the compliance date for existing 

sources subject to National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam 

Generating Units, 40 CFR Part 63 Subpart UUUUU. The permitte shall comply with the requirements of section I.C.15., in 

lieu of this section, starting on April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Hydrogen Chloride emissions shall be controlled by the use of 

dry flue gas desulfurization (FGD) Systems to meet the MACT 

limits. [40 CFR s. 63.43, s. NR 405.08(2), Wis. Adm. Code and 

03-RV-248-R4]

(2) The boiler may only be fired on coal and natural gas. [s. NR 

405.08(2) , Wis. Adm. Code; s. NR 406.10, Wis. Adm. Code; s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall perform compliance emission tests to 

demonstrate compliance with the hydrogen chloride emission 

limitation in condition I.C.14.a.(1) as follows:

(a) A compliance emission test shall be conducted every 60 

months within 90 days from the date of the last stack test as long 

as the permit remains valid. 

(b) The test shall be conducted in accordance with I.XXX.3.a.(1).

(c) The permittee shall perform simultaneous monitoring of the 

parameter(s) identified in I.C.14.c.(2)

[ss. NR 407.09(4)(a) and NR 439.075(1)(b) Wis. Adm. Code and 

03-RV-248-R4]

(4) The permittee shall maintain the flow rate of the aqueous 

lime/recycled ash slurry to the FGD system at not less than 50

gallons per minute per side and not less than 100 gallons per 

minute total, averaged over each day the boiler is operated75

(excluding flushes, startup, shutdown, and maintenance), or the 

value established during the most recent stack test that 

demonstrated compliance with the emission limitation in 

I.C.2.a.(1), if approved by the department in writing. [s. NR 

407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 03-

RV-248-R4]

(1) Reference Test Method for Hydrogen Chloride 

Emissions: Whenever compliance emission testing is 

required, US EPA Method 26A or an alternate method 

approved in writing by the Department, shall be used to 

demonstrate compliance. [s. NR 439.06(8), Wis. Adm. 

Code]

(2) During operation, the permittee shall monitor and 

record the flow rate of the aqueous lime/recycled ash 

slurry to the dry flue gas desulfurization (FGD) system 

once every 8 hours of operation or once per day, 

whichever yields the greater number of measurements. 

[ss. NR 439.04(1)(d) and NR 439.055(1)(a), Wis. Adm. 

Code and 03-RV-248-R4]

(3) The permittee shall maintain records of: 

(a) The results of the compliance emission tests required 

by condition I.C.14.b.(3); and 

(b) The parameter monitoring and associated operating 

ranges for the parameter(s) identified in condition 

I.C.14.c.(2) as recorded during the compliance emission 

tests required by condition I.C.14.b.(3).

[ss. NR 439.04(1)(d) and NR 439.11, Wis. Adm. Code]

 75 Only hours when the boiler is operated shall be included in the average in I.C.2.b.(2).
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 103

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) For boiler B04, the permittee shall comply with ONE of the following:

(a) Filterable particulate matter may not exceed: 0.03 lbs/mmBtu or 0.3 lbs/MWh gross electric output; OR

(b) Total non-Hg HAP metals may not exceed: 0.00005 lbs/mmBtu or 0.5 lbs/GWh; OR

(c) Individual Metal HAP metals may not exceed all of the following:

(i) Antimony (Sb): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(ii) Arsenic (As): 1.1 lbs/TBtu or 0.02 lbs/GWh;

(iii) Beryllium (Be): 0.2 lbs/TBtu or 0.002 lbs/GWh;

(iv) Cadmium (Cd): 0.3 lbs/TBtu or 0.003 lbs/GWh;

(v) Chromium (Cr): 2.8 lbs/TBtu or 0.03 lbs/GWh;

(vi) Cobalt (Co): 0.8 lbs/TBtu or 0.008 lbs/GWh;

(vii) Lead (Pb): 1.2 lbs/TBtu or 0.02 lbs/GWh;

(viii) Manganese (Mn): 4.0 lbs/TBtu or 0.04 lbs/GWh;

(ix) Nickel (Ni): 3.5 lbs/TBtu or 0.04 lbs/GWh; and

(x) Selenium (Se): 5.0 lbs/TBtu or 0.06 lbs/GWh.

[40 CFR s. 63.9991(a)(1) and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.a., s. 285.65(13), Wis. Stats.]

(2) For boiler B04, the permittee shall comply with ONE of the following:

(a) Hydrogen chloride (HCl) emissions may not exceed: 0.002 lbs/mmBtu or 0.02 lbs/MWh; OR

(b) Sulfur dioxide (SO2) emissions may not exceed: 0.2 lbs/MMBtu or 1.5 lbs/MWh.

(c) The alternate SO2 limit in (b) shall only be used if the EGU:

(i) Has a system using wet or dry flue gas desulfurization technology and SO2 continuous emissions monitoring 

system (CEMS) installed on the unit; and

(ii) The wet or dry flue gas desulfurization technology installed on the unit is operated consistent with 40 CFR 

s. 63.10000(b), at all times.

[40 CFR ss. 63.9991(a)(1) and (c), and 40 CFR Part 63, Subpart UUUUU, Table 2, condition 1.b., s. 285.65(13), Wis. Stats.]

(3) For boiler B04, mercury emissions may not exceed: 1.2 lbs/TBtu or 0.013 lbs/GWh. [40 CFR s. 63.9991(a)(1) and 40 

CFR, Part 63, Subpart UUUUU, Table 2, condition 1.c., s. 285.65(13), Wis. Stats.]

(4) The emission limits (I.C.15.a.(1) - (3)) and operating limits (I.C.15.b.(4)) in this section apply at all times except during 

periods of startup and shutdown; however, the permittee is required to meet the work practice requirements in conditions 

I.C.15.b. (3) during periods of startup or shutdown. [40 CFR s. 63.10000(a), s. 285.65(13), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate that 

compliance with 40 CFR, Part 63, Subpart 

UUUUU has been achieved, by conducting 

the required performance tests and other 

activities, no later than 180 days after April 

16, 2015. [40 CFR s. 63.9984(f), s. 

285.65(13), Wis. Stats.]

(1) Initial Performance Testing Requirements: Initial performance testing is 

required for all pollutants, to demonstrate compliance with the applicable

emission limits in section I.C.15.a.

(a) The permittee may conduct the initial performance testing in accordance 

with 40 CFR s. 63.10005(h), to determine whether the unit(s) qualifies as a 

low emitting EGU (LEE) for one or more applicable emissions limits, except 

if the EGU is equipped with an acid gas scrubber and has a main stack and 

bypass stack exhaust configuration.

(b) For a qualifying LEE for Hg emissions limits, the permitee must conduct 

a 30-day performance test using Method 30B at least once every 12 calendar 

months to demonstrate continued LEE status.

(c) For a qualifying LEE of any other applicable emissions limits, the 

permittee must conduct a performance test at least once every 36 calendar 

months to demonstrate continued LEE status.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 104

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

The permittee shall conduct a tune-up of the EGU burner and 

combustion controls at least each 36 calendar months, or each 

48 calendar months if neural network combustion optimization 

software is employed, as specified in 40 CFR s. 63.10021(e). 

[40 CFR s. 63.9991(a)(1) and 40 CFR, Part 63, Subpart 

UUUUU, Table 3, condition 1.]

(a) Periodic tune-ups of the EGU(s) shall be performed as part 

of the demonstration of continuous compliance [40 CFR s. 

63.10000(e)]

(b) The permittee shall perform the first tune-up as part of the 

initial compliance demonstration. Notwithstanding this 

requirement, the permittee may delay the first burner inspection 

until the next scheduled unit outage provided the requirements 

of 40 CFR s. 63.10005 are met. [40 CFR s. 63.10021(e)]

(c) Subsequently, an inspection of the burner shall be performed 

at least once every 36 calendar months unless the EGU employs 

neural network combustion optimization during normal 

operations in which case an inspection of the burner and 

combustion controls shall be performed at least once every 48 

calendar months.

(d) Tune-ups shall consist of the following:

(i) As applicable, inspect the burner and combustion 

controls, and clean or replace any components of the burner 

or combustion controls as necessary upon initiation of the 

work practice program and at least once every required 

inspection period. Repair of a burner or combustion control 

component requiring special order parts may be scheduled as 

follows:

a) Burner or combustion control component parts needing 

replacement that affect the ability to optimize NOX and CO 

must be installed within 3 calendar months after the burner 

inspection,

b) Burner or combustion control component parts that do 

not affect the ability to optimize NOX and CO may be 

installed on a schedule determined by the operator;

(ii) As applicable, inspect the flame pattern and make any 

adjustments to the burner or combustion controls necessary 

to optimize the flame pattern. The adjustment should be 

consistent with the manufacturer's specifications, if available, 

or in accordance with best combustion engineering practice 

for that burner type;

(iii) As applicable, observe the damper operations as a 

function of mill and/or cyclone loadings, cyclone and 

pulverizer coal feeder loadings, or other pulverizer and coal 

mill performance parameters, making adjustments and 

effecting repair to dampers, controls, mills, pulverizers, 

cyclones, and sensors;

{continued on next page...}

(1) Initial Performance Testing Requirements: {...continued from previous page...}

(d) If an EGU does not qualify as a LEE for total nonmercury HAP metals, individual non-mercury HAP metals, 

or filterable particulate matter (PM), the permitee shall 

demonstrate compliance through an initial performance test 

and shall monitor continuous performance through either 

use of a particulate matter continuous parametric 

monitoring system (PM CPMS), a PM CEMS, or, for an 

existing EGU, compliance performance testing repeated 

quarterly.

(i) If using PM CPMS, the permittee shall establish a 

site-specific operating limit corresponding to the results 

of the performance test demonstrating compliance with 

the pollutant with which you choose to comply: total 

non-mercury HAP metals, individual non-mercury HAP 

metals or filterable PM. The permittee shall use the PM 

CPMS to demonstrate continuous compliance with this 

operating limit. If electing to use a PM CPMS, the 

permittee shall repeat the performance test annually for 

the selected pollutant limit and reassess and adjust the 

site-specific operating limit in accordance with the 

results of the performance test.

(ii) The permittee may also opt to install and operate a 

particulate matter CEMS certified in accordance with 

Performance Specification 11 and Procedure 2 of 40 

CFR part 60, Appendices B and F, respectively, in 

accordance with 40 CFR s. 63.10010(i).

(e) If an EGU does not qualify as a LEE for hydrogen 

chloride (HCl), the permittee may demonstrate initial and 

continuous compliance through use of an HCl CEMS, 

installed and operated in accordance with Appendix B to 40 

CFR, Part 63, Subpart UUUUU. As an alternative to HCl 

CEMS, the permittee may demonstrate initial and 

continuous compliance by conducting an initial and 

periodic quarterly performance stack test for HCl. If an 

EGU uses wet or dry flue gas desulfurization technology 

(this includes limestone injection into a fluidized bed 

combustion unit), the permittee may apply a second 

alternative to HCl CEMS by installing and operating a 

sulfur dioxide (SO2) CEMS installed and operated in 

accordance with 40 CFR Part 75 to demonstrate compliance 

with the applicable SO2 emissions limit.

(f) If an EGU does not qualify as a LEE for Hg, the 

permittee shall demonstrate initial and continuous 

compliance through use of a Hg CEMS or a sorbent trap 

monitoring system, in accordance with Appendix A to 40 

CFR, Part 63, Subpart UUUUU.

[40 CFR s. 63.10000(c)(1), s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 105

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(iv) As applicable, evaluate windbox pressures and 

air proportions, making adjustments and effecting 

repair to dampers, actuators, controls, and sensors;

(v) Inspect the system controlling the air-to-fuel ratio 

and ensure that it is correctly calibrated and 

functioning properly. Such inspection may include 

calibrating excess O2 probes and/or sensors, 

adjusting overfire air systems, changing software 

parameters, and calibrating associated actuators and 

dampers to ensure that the systems are operated as 

designed. Any component out of calibration, in or 

near failure, or in a state that is likely to negate 

combustion optimization efforts prior to the next 

tune-up, should be corrected or repaired as necessary;

(vi) Optimize combustion to minimize generation of 

CO and NOX . This optimization should be consistent 

with the manufacturer's specifications, if available, or 

best combustion engineering practice for the 

applicable burner type. NOX optimization includes 

burners, overfire air controls, concentric firing 

system improvements, neural network or combustion 

efficiency software, control systems calibrations, 

adjusting combustion zone temperature profiles, and 

add-on controls such as SCR and SNCR; CO 

optimization includes burners, overfire air controls, 

concentric firing system improvements, neural 

network or combustion efficiency software, control 

systems calibrations, and adjusting combustion zone 

temperature profiles;

(vii) While operating at full load or the 

predominantly operated load, measure the 

concentration in the effluent stream of CO and NOX

in ppm, by volume, and oxygen in volume percent, 

before and after the tune-up adjustments are made 

(measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the 

adjustments are made). You may use portable CO, 

NOX and O2 monitors for this measurement. EGU's 

employing neural network optimization systems need 

only provide a single pre- and post-tune-up value 

rather than continual values before and after each 

optimization adjustment made by the system;

{continued on next page...}

(2) Subsequent Performance Tests and Tune-Ups:

(a) For EGUs using PM CPMS to monitor continuous performance 

with an applicable emission limit as provided for under 40 CFR 

s. 63.10000(c) (see condition I.C.15.c.(1)), you must conduct all 

applicable performance tests according to Table 5 to 40 CFR Part 

63, Subpart UUUUU and 40 CFR s. 63.10007 at least every year. 

[40 CFR s. 63.10006(a)]

(b) For EGUs meeting the LEE requirements of 40 CFR 

s. 63.10005(h) (see condition I.C.15.b.(4)(h)), the performance test 

shall be repeated once every 3 years (once every year for Hg) 

according to Table 5 and 40 CFR s. 63.10007. Should subsequent 

emissions testing results show the unit does not meet the LEE 

eligibility requirements, LEE status is lost. If this should occur:

(i) For all pollutant emission limits except for Hg, the permittee 

shall conduct emissions testing quarterly, except as otherwise 

provided in 40 CFR s. 63.10021(d)(1).

(ii) For Hg, the permittee shall install, certify, maintain, and 

operate a Hg CEMS or a sorbent trap monitoring system in 

accordance with Appendix A to 40 CFR, Part 63, Subpart 

UUUUU, within 6 calendar months of losing LEE eligibility. 

Until the Hg CEMS or sorbent trap monitoring system is 

installed, certified, and operating, the permittee shall conduct Hg 

emissions testing quarterly, except as otherwise provided in 40 

CFR s. 63.10021(d)(1). You must have 3 calendar years of 

testing and CEMS or sorbent trap monitoring system data that 

satisfy the LEE emissions criteria to reestablish LEE status.

[40 CFR s. 63.10006(b)]

(c) Except where paragraphs (a) or (b) of this condition apply, or

where the permittee installs, certifies, and operates a PM CEMS to 

demonstrate compliance with a filterable PM emissions limit, the 

permittee shall conduct all applicable periodic emissions tests for 

filterable PM, individual, or total HAP metals emissions according 

to Table 5 to Subpart UUUUU, 40 CFR s. 63.10007, and s. 

63.10000(c), except as otherwise provided in s. 63.10021(d)(1).

(d) Except where paragraph (b) of this section applies, for coalfired EGUs that do not use either an HCl CEMS to monitor 

compliance with the HCl limit or an SO2 CEMS to monitor 

compliance with the alternate equivalent SO2 emission limit, the 

permittee shall conduct all applicable periodic HCl emissions tests 

according to Table 5 to Subpart UUUUU and 40 CFR s. 63.10007 

at least quarterly, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). [40 CFR s. 63.10006(d)]

(e) {reserved}

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 106

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(2) Periodic Tune-Up Requirements:

(d) {...continued from previous page...}

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the 

information in paragraphs (d)(i) through (ix) of this 

condition, including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume 

percent, measured before and after an adjustment of 

the EGU combustion systems;

b) A description of any corrective actions taken as a 

part of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if 

the unit was physically and legally capable of using 

more than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tuneups as follows:

a) If the first required tune-up is performed as part of 

the initial compliance demonstration, report the date 

of the tune-up in hard copy (as specified in 40 CFR 

s. 63.10030) and electronically (as specified in 40 

CFR s. 63.10031). Report the date of each 

subsequent tune-up electronically (as specified in 40 

CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the 

initial compliance demonstration, but is postponed 

until the next unit outage, report the date of that tuneup and all subsequent tune-ups electronically, in 

accordance with 40 CFR s. 63.10031.

[40 CFR s. 63.10021(e), s. 285.65(13), Wis. Stats.]

(3) Monitoring During Startup and Shutdown:

(a) The permittee shall operate all CMS during startup 

and shutdown. 

(b) Startup means either the first-ever firing of fuel in a 

boiler for the purpose of producing electricity, or the 

firing of fuel in a boiler after a shutdown event for any 

purpose. 

(i) Startup ends when any of the steam from the boiler 

is used to generate electricity for sale over the grid or 

for any other purpose (including on site use). 

(ii) For startup of a unit, clean fuels shall be used, 

either natural gas or distillate oil or a combination of 

clean fuels for ignition. 

(iii) Once the EGU is converted to firing coal, all of the 

applicable control technologies except dry scrubber and 

SCR shall be engaged. 

(2) Subsequent Performance Tests and Tune-Ups:

{... continued from previous page...}

(f) Unless following the requirements listed in paragraphs (g) and 

(h) of this condition, subsequent performance tests shall be 

conducted as follows:

(i) performance tests required at least every 3 calendar years 

must be completed within 35 to 37 calendar months after the 

previous performance test; 

(ii) performance tests required at least every year must be 

completed within 11 to 13 calendar months after the previous 

performance test; and 

(iii) performance tests required at least quarterly must be 

completed within 80 to 100 calendar days after the previous 

performance test, except as otherwise provided in 40 CFR 

s. 63.10021(d)(1). 

[40 CFR s. 63.10006(f)]

(g) If electing to demonstrate compliance using emissions 

averaging under 40 CFR s. 63.10009, the permittee shall continue 

to conduct performance stack tests at the appropriate frequency 

given in section (c) through (f) of this section. [40 CFR s. 

63.10006(g)]

(h) If a performance test on a non-mercury LEE shows emissions 

in excess of 50 percent of the emission limit and if the permittee 

chooses to reapply for LEE status, the permittee shall conduct 

performance tests at the appropriate frequency given in paragraphs 

(c) through (e) of this condition for that pollutant until all 

performance tests over a consecutive 3-year period show 

compliance with the LEE criteria. [40 CFR s. 63.10006(h)]

(i) The permittee shall conduct performance tune-ups according to 

40 CFR s. 63.10021(e), as follows:

(i) For EGUs not employing neural network combustion 

optimization during normal operation, each performance tune-up 

specified in 40 CFR s. 63.10021(e) must be no more than 36 

calendar months after the previous performance tune-up.

(ii) For EGUs employing neural network combustion 

optimization systems during normal operation, each 

performance tune-up specified in 40 CFR s. 63.10021(e) must 

be no more than 48 calendar months after the previous 

performance tune-up.

[40 CFR s. 63.10006(i)]

(j) The permittee shall report the results of performance tests and 

performance tune-ups within 60 days after the completion of the 

performance tests and performance tune-ups. The reports for all 

subsequent performance tests must include all applicable 

information required in 40 CFR s. 63.10031. [40 CFR s. 

63.10006(j)]

[40 CFR s. 63.10006, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 107

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) Monitoring During Startup and Shutdown:

(b) {...continued from previous page...}

(iv) Any dry scrubber and SCR systems, if present, 

shall be started appropriately to comply with relevant 

standards applicable during normal operation. 

(c) Shutdown means the cessation of operation of a boiler 

for any purpose. 

(i) Shutdown begins either when none of the steam 

from the boiler is used to generate electricity for sale 

over the grid or for any other purpose (including on-site 

use) or at the point of no fuel being fired in the boiler. 

(ii) Shutdown ends when there is both no electricity 

being generated and no fuel being fired in the boiler.

(iii) During shutdown, all applicable control 

technologies shall be operated, while firing coal. 

(d) The EGU(s) shall comply with all applicable 

emissions limits at all times except for periods that meet 

the definitions of startup and shutdown in 40 CFR Part 

63, Subpart UUUUU. 

(e) The permittee shall keep records during periods of 

startup and shutdown. 

(f) The permittee shall provide reports concerning 

activities and periods of startup and shutdown, as 

specified in 40 CFR ss. 63.10011(g) and 63.10021(h) and 

(i).

[40 CFR s. 63.9991(a)(1) and 40 CFR, Part 63, Subpart 

UUUUU, Table 3, conditions 3 and 4., s. 285.65(13), 

Wis. Stats.]

(4) Operating Limits: The permittee shall meet the 

applicable operating limit in Table 4 to Subpart UUUUU 

as follows:

(a) If demonstrating compliance using a PM CPMS, 

maintain the 30-boiler operating day rolling average PM 

CPMS output at or below the highest 1-hour average 

measured during the most recent performance test 

demonstrating compliance with the filterable PM, total 

non-mercury HAP metals (total HAP metals, for liquid 

oil-fired units), or individual non-mercury HAP metals 

(individual HAP metals including Hg, for liquid oil-fired 

units) emissions limitation(s).

(b) The operating limits apply at all times except during 

periods of startup and shutdown; however, the permittee 

is required to meet the work practice requirements in 

conditions I.C.15.b. (3) during periods of startup or 

shutdown. 

[40 CFR s. 63.9991(a)(2), s. 63.10000(a), and Table 4 to 

40 CFR, Part 63, Subpart UUUUU, s. 285.65(13), Wis. 

Stats.]

(3) Performance Tests – Methods and Other Procedures:

(a) Except as otherwise provided in this condition, the permittee 

shall conduct all required performance tests according to 40 CFR 

s. 63.7(d), (e), (f), and (h). The permittee shall also develop a sitespecific test plan according to the requirements in 40 CFR 

s. 63.7(c).

(i) If using CEMS (Hg, HCl, SO2 , or other) to determine 

compliance with a 30-boiler operating day rolling average 

emission limit, you must collect data for all nonexempt unit 

operating conditions (see 40 CFR s. 63.10011(g) and Table 3 to 

40 CFR, Part 63, Subpart UUUUU).

(ii) If conducting performance testing with test methods in lieu 

of continuous monitoring, operate the unit at maximum normal 

operating load conditions during each periodic (e.g., quarterly) 

performance test. Maximum normal operating load will be 

generally between 90 and 110 percent of design capacity but 

should be representative of site specific normal operations 

during each test run.

(iii) For establishing operating limits with particulate matter 

continuous parametric monitoring system (PM CPMS) to 

demonstrate compliance with a PM or non Hg metals emissions 

limit, operate the unit at maximum normal operating load 

conditions during the performance test period. Maximum 

normal operating load will be generally between 90 and 110 

percent of design capacity but should be representative of site 

specific normal operations during each test run.

[40 CFR s. 63.10007(a)]

(b) The permittee shall conduct each performance test (including 

traditional 3-run stack tests, 30-boiler operating day tests based on 

CEMS data (or sorbent trap monitoring system data), and 30-

boiler operating day Hg emission tests for LEE qualification) 

according to the requirements in Table 5 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10007(b)]

(c) If choosing the filterable PM method to comply with the PM

emission limit and demonstrate continuous performance using a 

PM

CPMS as provided for in 40 CFR s. 63.10000(c), the permittee 

shall also establish an operating limit according to 40 CFR s. 

63.10011(b), s. 63.10023, and Tables 4 and 6 to Subpart UUUUU. 

Should the permittee desire to have operating limits that 

correspond to loads other than maximum normal operating load, 

the permittee shall conduct testing at those other loads to 

determine the additional operating limits. [40 CFR s. 

63.10007(c)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 108

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(5) At all times the permittee shall operate and 

maintain B04, including the associated air pollution 

control equipment and monitoring equipment, in a 

manner consistent with safety and good air pollution 

control practices for minimizing emissions. 

Determination of whether such operation and 

maintenance procedures are being used will be based 

on information which may include, but is not limited 

to, monitoring results, review of operation and 

maintenance procedures, review of operation and 

maintenance records, and inspection of the source. 

[40 CFR s. 63.10000(b), s. 285.65(13), Wis. Stats.]

(6) Initial Compliance Requirements: 

(a) General Requirements: For each affected EGU, 

initial compliance with each applicable emission limit 

in section I.C.15.a. shall be demonstrated with 

performance testing. Where two emissions limits are 

specified for a particular pollutant (e.g., a heat inputbased limit in lb/MMBtu and an electrical outputbased limit in lb/MWh), compliance may be 

demonstrated with either emission limit. 

One or more of the following activities may be 

required in conjunction with performance testing, as 

appropriate: collection of hourly electrical load data 

(megawatts); establishment of operating limits 

according to 40 CFR s. 63.10011 and 40 CFR Part 63, 

Subpart UUUUU, Tables 4 and 7; and CMS 

performance evaluations. In all cases, you must 

demonstrate initial compliance no later than the 

applicable date in paragraph (f) of 40 CFR s. 

63.10005 for tune-up work practices for existing 

EGUs, in 40 CFR s. 63.9984. 

(i) To demonstrate initial compliance with an 

applicable emissions limit in section I.C.15.a. of this 

permit using stack testing, the initial performance 

test generally consists of three runs at specified 

process operating conditions using approved 

methods. If required to establish operating limits 

(see paragraph (d) of 40 CFR s. 63.10005 and Table 

4 to 40 CFR Part 63, Subpart UUUUU), the 

permittee shall collect all applicable parametric data 

during the performance test period. Also, if you 

choose to comply with an electrical output-based 

emission limit, you must collect hourly electrical 

load data during the test period.

{continued on next page...}

(3) Performance Tests – Methods and Other Procedures:

{...continued from previous page...}

(d) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, where the concept of 

test runs does not apply, the permittee shall conduct a minimum of 

three separate test runs for each performance test, as specified in 40 

CFR s. 63.7(e)(3). Each test run shall comply with the minimum 

applicable sampling time or volume specified in Table 1 or 2 to 

Subpart UUUUU. Sections 63.10005(d) and (h) of 40 CFR (see 

conditions I.C.15.b.(6)(d) and (h)), respectively, provide special 

instructions for conducting performance tests based on CEMS or 

sorbent trap monitoring systems, and for conducting emission tests for 

LEE qualification. [40 CFR s. 63.10007(d)]

(e) To use the results of performance testing to determine compliance 

with the applicable emission limits in I.C.15.a., proceed as follows:

(i) Except for a 30-boiler operating day performance test based on 

CEMS (or sorbent trap monitoring system) data, if measurement 

results for any pollutant are reported as below the method 

detection level (e.g., laboratory analytical results for one or more 

sample components are below the method defined analytical 

detection level), the permittee shall use the method detection level 

as the measured emissions level for that pollutant in calculating 

compliance. The measured result for a multiple component 

analysis (e.g., analytical values for multiple Method 29 fractions 

both for individual HAP metals and for total HAP metals) may 

include a combination of method detection level data and 

analytical data reported above the method detection level.

(ii) If the limits are expressed in lb/MMBtu or lb/TBtu, the 

permittee shall use the F-factor methodology and equations in 

sections 12.2 and 12.3 of EPA Method 19 in Appendix A-7 to Part 

60 of 40 CFR. In cases where an appropriate F-factor is not listed 

in Table 19-2 of Method 19, you may use F-factors from Table 1 

in section 3.3.5 of Appendix F to Part 75 of 40 CFR, or F-factors 

derived using the procedures in section 3.3.6 of Appendix to Part 

75 of 40 CFR. Use the following factors to convert the pollutant 

concentrations measured during the initial performance tests to 

units of lb/scf, for use in the applicable Method 19 equations:

a) Multiply SO2 ppm by 1.66 × 10−7 ;

b) Multiply HCl ppm by 9.43 × 10−8 ;

c) Multiply HF ppm by 5.18 × 10−8 ;

d) Multiply HAP metals concentrations (mg/dscm) by 6.24 × 

10−8 ; and

e) Multiply Hg concentrations (μg/scm) by 6.24 × 10−11 .

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 109

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(a) {...continued from previous page...}

(ii) To demonstrate initial compliance using either a CMS that 

measures HAP concentrations directly (i.e., an Hg, HCl, or HF 

CEMS, or a sorbent trap monitoring system) or an SO2 or PM 

CEMS, the initial performance test consists of 30 boiler operating 

days of data collected by the initial compliance demonstration date 

specified in 40 CFR s. 63.10005 with the certified monitoring 

system.

a) The 30-boiler operating day CMS performance test must 

demonstrate compliance with the applicable Hg, HCl, HF, PM, or 

SO2 emissions limit in Table 1 or 2 to this subpart.

b) If you choose to comply with an electrical output-based 

emission limit, you must collect hourly electrical load data during 

the performance test period.

[40 CFR s. 63.10005(a)]

(b) Performance testing requirements: If using performance testing to 

demonstrate initial compliance with the applicable emissions limits in 

section I.C.15.a. of this permit, the permittee shall conduct the tests 

according to 40 CFR s. 63.10007 and Table 5 to 40 CFR Part 63, 

Subpart UUUUU. For the purposes of the initial compliance 

demonstration, test data and results from a performance test conducted 

prior to April 16, 2015, may be used provided that the following 

conditions are fully met:

(i) For a performance test based on stack test data, the test was 

conducted no more than 12 calendar months prior to April 16, 2015;

(ii) For a performance test based on data from a certified CEMS or 

sorbent trap monitoring system, the test consists of all valid CMS 

data recorded in the 30 boiler operating days immediately preceding 

April 16, 2015;

(iii) The performance test was conducted in accordance with all 

applicable requirements in 40 CFR s. 63.10007 and Table 5 to 40 

CFR Part 63 Subpart UUUUU;

(iv) A record of all parameters needed to convert pollutant 

concentrations to units of the emission standard (e.g., stack flow rate, 

diluent gas concentrations, hourly electrical loads) is available for 

the entire performance test period; and

(v) For each performance test based on stack test data, the permittee 

certifies, and keeps documentation demonstrating, that the EGU 

configuration, control devices, and fuel(s) have remained consistent 

with conditions since the prior performance test was conducted.

[40 CFR s. 63.10005(b)]

(c) Operating limits: In accordance with 40 CFR s. 63.10010 and 

Table 4 to 40 CFR Part 63, Subpart UUUUU, the permitee may be 

required to establish operating limits using PM CPMS as part of the 

initial compliance demonstration. [40 CFR s. 63.10005(c)]

(3) Performance Tests – Methods and Other Procedures:

(e) {...continued from previous page...}

(iii) To determine compliance with emission 

limits expressed in lb/MWh or lb/GWh, the 

permittee shall first calculate the pollutant mass 

emission rate during the performance test, in units 

of lb/h. For Hg, if a CEMS or sorbent trap 

monitoring system is used, use Equation A-2 or 

A-3 in Appendix A to 40 CFR, Part 63, Subpart 

UUUUU (as applicable). In all other cases, use an 

equation that has the general form of Equation A2 or A-3, replacing the value of K with 1.66 × 

10−7 lb/scf-ppm for SO2 , 9.43 × 10−8 lb/scf-ppm 

for HCl (if an HCl CEMS is used), or 6.24 × 10−8

lb-scm/mg-scf for HAP metals and for HCl (when 

performance stack testing is used), and defining 

Ch as the average SO2 or HCl concentration in 

ppm, or the average HAP metals concentration in 

mg/dscm. This calculation requires stack gas 

volumetric flow rate (scfh) and (in some cases) 

moisture content data (see 40 CFR 

ss. 63.10005(h)(3) and 63.10010). Then, if the 

applicable emission limit is in units of lb/GWh, 

use Equation A-4 in Appendix A to Subpart 

UUUUU to calculate the pollutant emission rate 

in lb/GWh. In this calculation, define (M)h as the 

calculated pollutant mass emission rate for the 

performance test (lb/h), and define (MW)h as the 

average electrical load during the performance 

test (megawatts). If the applicable emission limit 

is in lb/MWh rather than lb/GWh, omit the 103

term from Equation A-4 to determine the 

pollutant emission rate in lb/MWh.

[40 CFR s. 63.10007(e)]

(f) Upon request, the permittee shall make available 

to the department such records as may be necessary 

to determine whether the performance tests have 

been done according to the requirements of this 

section. [40 CFR s. 63.10007(f)]

[40 CFR s. 63.10007, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 110

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(d) CMS requirement: If required to (or electing to) 

demonstrate initial compliance using a continuous 

monitoring system, the CMS must pass a performance 

evaluation prior to the initial compliance 

demonstration. If a CMS has been previously certified 

under another state or federal program and is 

continuing to meet the on-going quality-assurance 

(QA) requirements of that program, then, provided 

that the certification and QA provisions of that 

program meet the applicable requirements of 40 CFR 

ss. 63.10010(b) through (h), an additional 

performance evaluation of the CMS is not required.

(i) The permittee may demonstrate initial 

compliance with the applicable SO2 or HCl, 

emissions limit in condition I.C.15.a.(2) through use 

of an SO2 or HCl CEMS installed and operated in 

accordance with 40 CFR, Part 75 or 40 CFR, Part 

63, Subpart UUUUU, Appendix B, as applicable. 

The permittee may demonstrate compliance with a 

filterable PM emission limit in condition 

I.C.15.a.(1) (a) through use of a PM CEMS 

installed, certified, and operated in accordance with 

40 CFR s. 63.10010(i). Initial compliance is 

achieved if the arithmetic average of 30-boiler 

operating days of quality-assured CEMS data, 

expressed in units of the standard (see 40 CFR 

s. 63.10007(e)), meets the applicable SO2, PM, or 

HCl emissions limit in section I.A.7.a. of this 

permit. Use Equation 19-19 of Method 19 in 

Appendix A-7 to 40 CFR, Part 60 to calculate the 

30-boiler operating day average emissions rate. 

(NOTE: For this calculation, the term Ehj in Equation 

19-19 must be in the same units of measure as the 

applicable HCl emission limit in condition 

I.C.15.a.(2) (a).

(ii) When demonstrating compliance with the 

applicable emission limits for total non-mercury 

HAP metals, individual non-mercury HAP metals, 

total HAP metals, individual HAP metals, or 

filterable PM in section I.C.15.a. of this permit 

using initial performance testing and continuous 

monitoring with PM CPMS, the permittee shall:

a) Demonstrate initial compliance no later than 

180 days after April 16, 2015; 

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(a) If demonstrating compliance with any applicable emissions limit 

through use of a continuous monitoring system (CMS), where a CMS 

includes a continuous parameter monitoring system (CPMS) as well 

as a continuous emissions monitoring system (CEMS), the permitee 

shall develop a site-specific monitoring plan and submit this sitespecific monitoring plan, if requested, at least 60 days before the 

initial performance evaluation (where applicable) of your CMS. The 

requirement to develop and submit a site-specific monitoring plan 

does not apply to affected sources with existing monitoring plans that 

apply to CEMS and CPMS prepared under Appendix B to 40 CFR 

Part 60 or Part 75, and that meet the requirements of 40 CFR 

s. 63.10010. (The permittee may use the process described in 

§ 63.8(f)(4), to request approval of monitoring system quality 

assurance and quality control procedures alternative to those specified 

in this condition and, if approved, include those in the site-specific 

monitoring plan.) The monitoring plan shall address the provisions in 

(b) through (e) below.

(b) The site-specific monitoring plan shall include the information 

specified in condition (e), below. Alternatively, the requirements of 

condition (e) are considered to be met for a particular CMS or sorbent 

trap monitoring system if:

(i) The CMS or sorbent trap monitoring system is installed, 

certified, maintained, operated, and quality-assured either 

according to 40 CFR, Part 75, or Appendix A or B to 40 CFR, Part 

63, Subpart UUUUU; and

(ii) The recordkeeping and reporting requirements of 40 CFR, Part 

75, or Appendix A or B to 40 CFR, Part 63, Subpart UUUUU, that 

pertain to the CMS are met.

(c) If requested by the department, the permittee shall submit the 

monitoring plan (or relevant portion of the plan) at least 60 days 

before the initial performance evaluation of a particular CMS, except 

where the CMS has already undergone a performance evaluation that 

meets the requirements of 40 CFR s. 63.10010 (e.g., if the CMS was 

previously certified under another program).

(d) The permittee shall operate and maintain the CMS according to 

the site-specific monitoring plan.

(e) The provisions of the site-specific monitoring plan shall address 

the following items:

(i) Installation of the CMS or sorbent trap monitoring system 

sampling probe or other interface at a measurement location 

relative to each affected process unit such that the measurement is 

representative of control of the exhaust emissions (e.g., on or 

downstream of the last control device). See 40 CFR s. 63.10010(a) 

for further details. For PM CPMS installations, follow the 

procedures in 40 CFR s. 63.10010(h).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 111

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(d)(ii) {...continued from previous page...}

b) Demonstrate continuous compliance with the 

PM CPMS site-specific operating limit that 

corresponding to the results of the performance test 

demonstrating compliance with the emission limit 

with which the permittee has chosen to comply; 

and

c) Repeat the performance test annually for the 

selected pollutant emissions limit and reassess and 

adjust the site-specific operating limit in 

accordance with the results of the performance test.

(iii) When demonstrating compliance with the Hg 

emission limit in I.C.15.a.(3) using Hg CEMS or 

sorbent trap monitoring systems, initial compliance 

shall be demonstrated no later than 180 days after 

April 16, 2015. Initial compliance is achieved if the 

arithmetic average of 30-boiler operating days of 

quality-assured CEMS (or sorbent trap monitoring 

system) data, expressed in units of the standard (see 

section 6.2 of Appendix A to 40 CFR, Part 63, 

Subpart UUUUU), meets the applicable Hg emission 

limit in I.C.15.a.(3).

[40 CFR s. 63.10005(d)]

(e) Tune-ups: As part of the initial compliance 

demonstration, the permittee shall conduct a 

performance tune-up of each EGU according to 40 

CFR s. 63.10021(e). [40 CFR s. 63.10005(e)]

(f) For existing affected sources a tune-up may occur 

prior to April 16, 2012, so that existing sources without 

neural networks have up to 42 calendar months (3 

years from promulgation plus 180 days) or, in the case 

of units employing neural network combustion 

controls, up to 54 calendar months (48 months from 

promulgation plus 180 days) after the date that is 

specified for your source in 40 CFR s. 63.9984 and 

according to the applicable provisions in s. 63.7(a)(2) 

as cited in Table 9 to Subpart UUUUU to demonstrate 

compliance with this requirement. If a tune-up occurs 

prior to such date, the source must maintain adequate 

records to show that the tune-up met the requirements 

of this standard. [40 CFR s. 63.10005(f)]

(g) {reserved}

{continued on next page...}

(4) Continuous Monitoring System Requirements:

(e) {...continued from previous page...}

(ii) Performance and equipment specifications for the sample 

interface, the pollutant concentration or parametric signal 

analyzer, and the data collection and reduction systems.

(iii) Schedule for conducting initial and periodic performance 

evaluations.

(iv) Performance evaluation procedures and acceptance criteria 

(e.g., calibrations), including the quality control program in 

accordance with the general requirements of 40 CFR s. 63.8(d).

(v) On-going operation and maintenance procedures, in 

accordance with the general requirements of 40 CFR 

ss. 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii).

(vi) Conditions that define a CMS that is out of control consistent 

with 40 CFR s. 63.8(c)(7)(i) and for responding to out of control 

periods consistent with 40 CFR ss. 63.8(c)(7)(ii) and (c)(8).

(vii) On-going recordkeeping and reporting procedures, in 

accordance with the general requirements of 40 CFR ss. 63.10(c), 

(e)(1), and (e)(2)(i), or as specifically required under 40 CFR, 

Part 63, Subpart UUUUU.

[40 CFR s. 63.10000(d), s. 285.65(13), Wis. Stats.]

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(a) For the CEMS, PM CPMS, and sorbent trap monitoring systems 

used to provide data under 40 CFR, Part 63, Subpart UUUUU, the 

permittee shall comply with the continuous monitoring system 

installation requirements for the appropriate exhaust configurations 

as required by 40 CFR s. 63.10010(a). (Exhaust configurations 

include but are not limited individual stacks, a common stack 

configuration or a main stack plus a bypass stack.) [40 CFR s. 

63.10010(a)]

(b) If using an oxygen (O2 ) or carbon dioxide (CO2 ) CEMS to 

convert measured pollutant concentrations to the units of the 

applicable emissions limit, the O2 or CO2 concentrations shall be 

monitored at a location that represents emissions to the atmosphere, 

i.e., at the outlet of the EGU, downstream of all emission control 

devices. The permittee shall install, certify, maintain, and operate the 

CEMS according to Part 75 of 40 CFR. Use only quality-assured O2

or CO2 data in the emissions calculations; do not use Part 75 

substitute data values. [40 CFR s. 63.10010(b)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 112

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

{...continued from previous page...}

(h) Low emitting EGUs: The provisions of this 

paragraph (h) apply to all pollutants with emissions 

limits from existing EGUs. This compliance option 

may not be pursued, if for EGUs equipped with an 

acid gas scrubber and with a main stack and bypass 

stack exhaust configuration.

(i) An EGU may qualify for low emitting EGU 

(LEE) status for Hg, HCl, filterable PM, total nonHg HAP metals, or individual non-Hg HAP metals 

if performance test data is collected that meets the 

requirements of this paragraph (h), and if those data 

demonstrate:

a) For all pollutants except Hg, performance test 

emissions results less than 50 percent of the 

applicable emissions limits in I.C.15.a. for all 

required testing for 3 consecutive years; or

b) For Hg emissions, either: 

1) Average emissions less than 10 percent of 

the applicable Hg emissions limit in 

I.C.15.a.(3) (expressed either in units of 

lb/TBtu or lb/GWh); or 

2) Potential Hg mass emissions of 29.0 or fewer 

pounds per year and compliance with the 

applicable Hg emission limit in I.C.15.a.(3)

(expressed either in units of lb/TBtu or 

lb/GWh).

(ii) For all pollutants except Hg, the permittee shall 

conduct all required performance tests described in 

40 CFR s. 63.10007 to demonstrate that a unit 

qualifies for LEE status.

a) When conducting emissions testing to 

demonstrate LEE status, the permittee shall 

increase the minimum sample volume specified in 

Table 1 or 2 to 40 CFR, Part 63, Subpart UUUUU 

nominally by a factor of two.

b) Follow the instructions in 40 CFR 

s. 63.10007(e) and Table 5 to Subpart UUUUU to 

convert the test data to the units of the applicable 

standard.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

{...continued from previous page...}

(c) If required to use a stack gas flow rate monitor, either for routine 

operation of a sorbent trap monitoring system or to convert pollutant 

concentrations to units of an electrical output-based emission standard 

in Table 1 or 2 to Subpart UUUUU, the permittee shall install, certify, 

operate, and maintain the monitoring system and conduct on-going 

quality-assurance testing of the system according to Part 75 of 40 

CFR. Use only unadjusted, quality-assured flow rate data in the 

emissions calculations. Do not apply bias adjustment factors to the 

flow rate data and do not use substitute flow rate data in the 

calculations. [40 CFR s.63.10010(c)]

(d) If required to make corrections for stack gas moisture content 

when converting pollutant concentrations to the units of an emission 

standard in Table 1 of 2 to Subpart UUUUU, the permittee shall 

install, certify, operate, and maintain a moisture monitoring system in 

accordance with Part 75 of 40 CFR. Alternatively, for coal-fired units, 

appropriate fuel-specific default moisture values from 40 CFR 

s. 75.11(b) may be used to estimate the moisture content of the stack 

gas. If a moisture monitoring system is installed and operated, do not 

use substitute moisture data in the emissions calculations. [40 CFR s. 

63.1001(d)]

(e) If using an HCl CEMS, the permittee shall install, certify, operate, 

maintain, and quality-assure the data from the monitoring system in 

accordance with Appendix B to Subpart UUUUU. Calculate and 

record a 30-boiler operating day rolling average HCl emission rate in 

the units of the standard, updated after each new boiler operating day. 

Each 30-boiler operating day rolling average emission rate is the 

average of all the valid hourly HCl emission rates in the preceding 30 

boiler operating days (see section 9.4 of Appendix B to Subpart 

UUUUU). [40 CFR s. 63.10010(e)]

(f)(i) If using an SO2 CEMS, the permittee shall install the monitor at 

the outlet of the EGU, downstream of all emission control devices, 

and shall certify, operate, and maintain the CEMS according to 

Part 75 of 40 CFR.

(ii) For on-going QA, the SO2 CEMS shall meet the applicable 

daily, quarterly, and semiannual or annual requirements in sections 

2.1 through 2.3 of Appendix B to Part 75 of 40 CFR, with the 

following addition: The permittee shall perform the linearity 

checks required in section 2.2 of Appendix B to Part 75 of 40 CFR 

if the SO2 CEMS has a span value of 30 ppm or less.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 113

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h) {...continued from previous page...}

(iii) For Hg, the permittee shall conduct a 30-boiler 

operating day performance test using Method 30B 

in Appendix A-8 to 40 CFR Part 60 to determine 

whether a unit qualifies for LEE status. Locate the 

Method 30B sampling probe tip at a point within the 

10 percent centroidal area of the duct at a location 

that meets Method 1 in Appendix A-1 to 40 CFR 

Part 60 and conduct at least three nominally equal 

length test runs over the 30-boiler operating day test 

period. Collect Hg emissions data continuously over 

the entire test period (except when changing sorbent 

traps or performing required reference method QA 

procedures), under all process operating conditions. 

The permittee may use a pair of sorbent traps to 

sample the stack gas for no more than 10 days.

a) Depending on whether LEE status for Hg is 

assessed in terms of the lb/TBtu or lb/GWh 

emission limit in I.C.15.a.(3) or in terms of the 

annual Hg mass emissions limit of 29.0 lb/year, 

the permittee shall collect some or all of the 

following data during the 30-boiler operating day 

test period (see paragraph (h)(iii)c) of this 

condition):

1) Diluent gas (CO2 or O2 ) data, using either 

Method 3A in Appendix A-3 to Part 60 of 40 

CFR or a diluent gas monitor that has been 

certified according to Part 75 of 40 CFR.

2) Stack gas flow rate data, using either Method 

2, 2F, or 2G in Appendices A-1 and A-2 to Part 

60 of 40 CFR, or a flow rate monitor that has 

been certified according to Part 75 of 40 CFR.

3) Stack gas moisture content data, using either 

Method 4 in Appendix A-1 to Part 60 of 40 

CFR, or a moisture monitoring system that has 

been certified according to Part 75 of 40 CFR. 

Alternatively, an appropriate fuel-specific 

default moisture value from 40 CFR s. 75.11(b) 

may be used in the calculations.

4) Hourly electrical load data (megawatts), 

from facility records.

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(f) {...continued from previous page...}

(iii) Calculate and record a 30-boiler operating day rolling average 

SO2 emission rate in the units of the standard, updated after each 

new boiler operating day. Each 30-boiler operating day rolling 

average emission rate is the average of all of the valid SO2

emission rates in the preceding 30 boiler operating days.

(iv) Use only unadjusted, quality-assured SO2 concentration values 

in the emissions calculations; do not apply bias adjustment factors 

to the Part 75 SO2 data and do not use Part 75 substitute data 

values.

[40 CFR s. 63.10010(f)]

(g) If using a Hg CEMS or a sorbent trap monitoring system, the 

permittee shall install, certify, operate, maintain and quality-assure 

the data from the monitoring system in accordance with Appendix A 

to Subpart UUUUU. The permittee shall calculate and record a 30-

(or, if alternate emissions averaging is used, 90-) boiler operating day 

rolling average Hg emission rate, in units of the standard, updated 

after each new boiler operating day. Each 30- (or, if alternate 

emissions averaging is used, 90-) boiler operating day rolling average 

emission rate, calculated according to section 6.2 of Appendix A to 

Subpart UUUUU, is the average of all of the valid hourly Hg 

emission rates in the preceding 30- (or, if alternate emissions 

averaging is used, a 90-) boiler operating days. Section 7.1.4.3 of 

Appendix A to Subpart UUUUU explains how to reduce sorbent trap 

monitoring system data to an hourly basis. [40 CFR s. 63.10010(g)]

(h) If using a PM CPMS to demonstrate continuous compliance with 

an operating limit, the permittee shall install, calibrate, maintain, and 

operate the PM CPMS and record the output of the system as follows:

(i) Install, calibrate, operate, and maintain the PM CPMS 

according to the procedures in the approved site-specific 

monitoring plan developed in accordance with 40 CFR s. 

63.10000(d), and meet the requirements the following:

a) The operating principle of the PM CPMS shall be based on 

in-stack or extractive light scatter, light scintillation, beta 

attenuation, or mass accumulation detection of the exhaust gas 

or representative sample. The reportable measurement output 

from the PM CPMS may be expressed as milliamps, stack 

concentration, or other raw data signal.

b) The PM CPMS shall have a cycle time ( i.e. , period 

required to complete sampling, measurement, and reporting 

for each measurement) no longer than 60 minutes.

c) The PM CPMS shall be capable, at a minimum, of 

detecting and responding to particulate matter concentrations 

of 0.5 mg/acm.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 114

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii) {...continued from previous page...}

b) If a CEMS is used to measure CO2 (or O2 ) 

concentration, and/or flow rate, and/or moisture, 

record hourly average values of each parameter 

throughout the 30-boiler operating day test 

period. If opting to use EPA reference methods 

rather than CEMS for any parameter, the 

permittee shall perform at least one 

representative test run on each operating day of 

the test period, using the applicable reference 

method.

c) Calculate the average Hg concentration, in 

μg/m3 (dry basis), for the 30-boiler operating 

day performance test, as the arithmetic average 

of all Method 30B sorbent trap results. Also 

calculate, as applicable, the average values of 

CO2 or O2 concentration, stack gas flow rate, 

stack gas moisture content, and electrical load 

for the test period. Then:

1) To express the test results in units of 

lb/TBtu, follow the procedures in 40 CFR 

s. 63.10007(e). Use the average Hg 

concentration and diluent gas values in the 

calculations.

2) To express the test results in units of 

lb/GWh, use Equations A-3 and A-4 in section 

6.2.2 of Appendix A to Subpart UUUUU, 

replacing the hourly values “Ch”, “Qh”, “Bws” 

and “(MW)h” with the average values of these 

parameters from the performance test.

3) To calculate pounds of Hg per year, use one 

of the following methods:

A) Multiply the average lb/TBtu Hg 

emission rate (determined according to 

paragraph (h)(3)(iii)(A) of this section) by 

the maximum potential annual heat input to 

the unit (TBtu), which is equal to the 

maximum rated unit heat input (TBtu/hr) 

times 8,760 hours. If the maximum rated 

heat input value is expressed in units of 

MMBtu/hr, multiply it by 10 −6 to convert it 

to TBtu/hr; or

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(h) {...continued from previous page...}

(ii) Complete the initial performance evaluation no later than 

October 13, 2015.

(iii) Collect PM CPMS hourly average output data for all boiler 

operating hours except as indicated in paragraph (h)(v) of this 

condition. Express the PM CPMS output as milliamps, PM 

concentration, or other raw data signal value.

(iv) Calculate the arithmetic 30-boiler operating day rolling average 

of all of the hourly average PM CPMS output collected during all 

nonexempt boiler operating hours data (e.g., milliamps, PM 

concentration, raw data signal).

(v) The permittee shall collect data using the PM CPMS at all times 

the process unit is operating and at the intervals specified in 

paragraph (h)(i)b) of this condition, except for periods of 

monitoring system malfunctions, repairs associated with monitoring 

system malfunctions, required monitoring system quality assurance 

or quality control activities (including, as applicable, calibration 

checks and required zero and span adjustments), and any scheduled 

maintenance as defined in the site-specific monitoring plan.

(vi) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with your operating 

limit except:

a) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or 

required monitoring system quality assurance or quality control 

activities conducted during monitoring system malfunctions are 

not used in calculations (report any such periods in your annual 

deviation report);

b) Any data collected during periods when the monitoring system 

is out of control as specified in the site-specific monitoring plan, 

repairs associated with periods when the monitoring system is out 

of control, or required monitoring system quality assurance or 

quality control activities conducted during out-of-control periods 

are not used in calculations (report emissions or operating levels 

and report any such periods in the annual deviation report);

c) Any data recorded during periods of startup or shutdown.

(vii) The permittee shall record and make available upon request 

results of PM CPMS system performance audits, as well as the 

dates and duration of periods from when the PM CPMS is out of 

control until completion of the corrective actions necessary to 

return the PM CPMS to operation consistent with the site-specific 

monitoring plan.

[40 CFR s.63.10010(h)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 115

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Initial Compliance Requirements:

(h)(iii)c)3) {...continued from previous page...}

B) Multiply the average lb/GWh Hg emission rate 

(determined according to paragraph (h)(3)(iii)(B) of this 

section) by the maximum potential annual electricity 

generation (GWh), which is equal to the maximum rated 

electrical output of the unit (GW) times 8,760 hours. If 

the maximum rated electrical output value is expressed 

in units of MW, multiply it by 10 −3 to convert it to GW; 

or

C) If an EGU has a federally-enforceable permit limit on 

either the annual heat input or the number of annual 

operating hours, you may modify the calculations in 

paragraph (h)(3)(iii)(C)(1) of this section by replacing 

the maximum potential annual heat input or 8,760 unit 

operating hours with the permit limit on annual heat 

input or operating hours (as applicable).

[40 CFR s. 63.10005(h)]

(i) {reserved}

(j) Startup and shutdown: The permitee shall follow the 

requirements given in Table 3 to 40 CFR, Part 63, Subpart 

UUUUU. [40 CFR s. 63.10005(j)]

(k) The permittee shall submit a Notification of Compliance 

Status summarizing the results of the initial compliance 

demonstration, as provided in 40 CFR s. 63.10030. [40 CFR s. 

63.10005(k)]

[40 CFR s. 63.10005, s. 285.65(13), Wis. Stats.]

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

(a) The permittee shall demonstrate initial compliance with each 

emissions limit in I.C.15.a. by conducting performance testing. 

[40 CFR s. 63.10011(a)]

(b) If demonstrating initial compliance with HAP metals or 

filterable PM emission limit(s) through performance stack tests 

and electing to use a PM CPMS to demonstrate continuous 

performance, the permittee shall also establish a site-specific 

operating limit, in accordance with Table 4 to Subpart UUUUU, 

40 CFR s. 63.10007, and Table 6 to Subpart UUUUU. The 

permittee may use only the parametric data recorded during 

successful performance tests (i.e., tests that demonstrate 

compliance with the applicable emissions limits) to establish an 

operating limit. [40 CFR s. 63.10011(b)]

{continued on next page...}

(5) Monitoring, Installation, Operation and 

Maintenance Requirements:

{...continued from previous page...}

(i) If choosing to comply with the PM filterable emissions 

limit in lieu of metal HAP limits, the permittee may 

choose to install, certify, operate, and maintain a PM 

CEMS and record the output of the PM CEMS as specified 

in paragraphs (i)(i) through (v) of this condition, below. 

The compliance limit will be expressed as a 30-boiler 

operating day rolling average of the numerical emissions 

limit value applicable for the unit in tables 1 or 2 to 

Subpart UUUUU.

(i) Install and certify the PM CEMS according to the 

procedures and requirements in Performance 

Specification 11—Specifications and Test Procedures 

for Particulate Matter Continuous Emission Monitoring 

Systems at Stationary Sources in Appendix B to Part 60 

of 40 CFR, using Method 5 at Appendix A-3 to Part 60

of 40 CFR and ensuring that the front half filter 

temperature shall be 160° ± 14 °C (320° ± 25 °F). The 

reportable measurement output from the PM CEMS 

must be expressed in units of the applicable emissions 

limit (e.g., lb/MMBtu, lb/MWh).

(ii) Operate and maintain the PM CEMS according to 

the procedures and requirements in Procedure 2—

Quality Assurance Requirements for Particulate Matter 

Continuous Emission Monitoring Systems at Stationary 

Sources in Appendix F to Part 60 of 40 CFR.

a) The permittee shall conduct the relative response 

audit (RRA) for the PM CEMS at least once 

annually.

b) The permittee shall conduct the relative 

correlation audit (RCA) for the PM CEMS at least 

once every 3 years.

(iii) Collect PM CEMS hourly average output data for 

all boiler operating hours except as indicated in 

paragraph (i) of this condition.

(iv) Calculate the arithmetic 30-boiler operating day 

rolling average of all of the hourly average PM CEMS 

output data collected during all nonexempt boiler 

operating hours.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 116

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with 

Emission Limitations and Work Practice Standards:

{...continued from previous page...}

(c)(i) If using CEMS or sorbent trap monitoring 

systems to measure a HAP (e.g., Hg or HCl) 

directly, the first 30-boiler operating day (or, 

if alternate emissions averaging is used for 

Hg, the 90-boiler operating day) rolling 

average emission rate obtained with certified 

CEMS after April 16, 2015 (or, if applicable, 

prior to that date, as described in 40 CFR 

s. 63.10005(b)(2)), expressed in units of the 

standard, is the initial performance test. 

Initial compliance is demonstrated if the 

results of the performance test meet the 

applicable emission limit in I.C.15.a.

(ii) For a unit that uses a CEMS to measure 

SO2 or PM emissions for initial compliance, 

the first 30 boiler operating day average 

emission rate obtained with certified CEMS 

after April 16, 2015 (or, if applicable, prior to 

that date, as described in 40 CFR 

s. 63.10005(b)(2)), expressed in units of the 

standard, is the initial performance test. 

Initial compliance is demonstrated if the 

results of the performance test meet the 

applicable SO2 or filterable PM emission 

limit in I.C.15.a.

[40 CFR s.10011(c)]

(d) For candidate LEE units, use the results of 

the performance testing described in 40 CFR 

s. 63.10005(h) to determine initial compliance 

with the applicable emission limit(s) in I.C.15.a. 

and to determine whether the unit qualifies for 

LEE status. [40 CFR s. 63.10011(d)]

(e) The permittee shall submit a Notification of 

Compliance Status containing the results of the 

initial compliance demonstration, according to 

40 CFR s. 63.10030(e). [40 CFR s. 

63.10011(e)]

(5) Monitoring, Installation, Operation and Maintenance Requirements:

(i) {...continued from previous page...}

(v) The permittee shall collect data using the PM CEMS at all times the 

process unit is operating and at the intervals specified in paragraph (a) 

of this condition, except for periods of monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, and required 

monitoring system quality assurance or quality control activities.

a) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with the operating limit 

except:

1) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or required 

monitoring system quality assurance or control activities conducted 

during monitoring system malfunctions in calculations and report 

any such periods in the annual deviation report;

2) Any data collected during periods when the monitoring system is 

out of control as specified in the site-specific monitoring plan, 

repairs associated with periods when the monitoring system is out 

of control, or required monitoring system quality assurance or 

control activities conducted during out of control periods in 

calculations used to report emissions or operating levels and report 

any such periods in the annual deviation report;

3) Any data recorded during periods of startup or shutdown.

b) The permittee shall record and make available upon request results 

of PM CEMS system performance audits, dates and duration of 

periods when the PM CEMS is out of control to completion of the 

corrective actions necessary to return the PM CEMS to operation 

consistent with the site-specific monitoring plan.

[40 CFR s. 63.10010(i)]

(j) The permittee may choose to comply with the metal HAP emissions 

limits using CEMS approved in accordance with 40 CFR s. 63.7(f) as an 

alternative to the performance test method specified in 40 CFR, Part 63, 

Subpart UUUUU. If approved to use a HAP metals CEMS, the compliance 

limit will be expressed as a 30-boiler operating day rolling average of the 

numerical emissions limit value in I.C.15.a.(1). If approved, the permittee 

may choose to install, certify, operate, and maintain a HAP metals CEMS

and record the output of the HAP metals CEMS as specified below:

(i) a) Install and certify the HAP metals CEMS according to the

procedures and requirements in the approved site-specific test plan as 

required in 40 CFR s. 63.7(e). The reportable measurement output

from the HAP metals CEMS shall be expressed in units of the

applicable emissions limit (e.g., lb/MMBtu, lb/MWh) and in the form 

of a 30-boiler operating day rolling average.

b) Operate and maintain the HAP metals CEMS according to the 

procedures and criteria in the site specific performance evaluation and 

quality control program plan required in 40 CFR s. 63.8(d).

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 117

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Initial Demonstration of Compliance with Emission 

Limitations and Work Practice Standards:

{...continued from previous page...}

(f)(i) The permittee shall determine the fuel whose 

combustion produces the least uncontrolled 

emissions, i.e., the cleanest fuel, either natural gas 

or distillate oil, that is available on site or 

accessible nearby for use during periods of startup 

or shutdown.

(ii) The cleanest fuel available, either natural gas 

or distillate oil, for use during periods of startup or 

shutdown determination may take safety 

considerations into account.

[40 CFR 2. 63.10011(f)]

(g) The permittee shall follow the startup or shutdown 

requirements given in Table 3 to 40 CFR, Part 63, 

Subpart UUUUU for EGU. [40 CFR s. 63.10011(g)]

[40 CFR s. 63.10011, s. 285.65(13), Wis. Stats.]

(8) Continuous Compliance Demonstration:

(a) The permittee shall demonstrate continuous 

compliance with each emissions limit in Table 2 to 

Subpart UUUUU (see condition I.C.15.a.), each 

operating limit in Table 4 to subpart UUUUU (see 

condition I.C.15.b.(4)), and each work practice 

standard in Tables 3 to Subpart UUUUU (see 

conditions I.C.15.a.(4) and I.C.15.b.(3)) that applies, 

according to the monitoring specified in Tables 6 and 

7 to Subpart UUUUU as outlined below and 

conditions I.C.15.b.(8)(b) through (g).

(i) If using CEMS to measure filterable PM, SO2, 

HCl, or Hg emissions, or using a sorbent trap 

monitoring system to measure Hg to demonstrate 

compliance with the applicable emission limitations 

in I.C.15.a., the permittee shall demonstrate 

continuous compliance by calculating the 30- (or 

90-) boiler operating day rolling arithmetic average 

emissions rate in units of the applicable emissions 

standard basis at the end of each boiler operating 

day using all of the quality assured hourly average 

CEMS or sorbent trap data for the previous 30-

boiler operating days, excluding data recorded 

during periods of startup or shutdown. [40 CFR s. 

63.10021(a), item 1 of Table 7 to 40 CFR, Part 63, 

Subpart UUUUU]

{continued on next page...}

(5) Monitoring, Installation, Operation and Maintenance 

Requirements:

(j) {...continued from previous page...}

(ii) Collect HAP metals CEMS hourly average output data for all 

boiler operating hours except as indicated in section (j)(iv) of this 

condition.

(iii) Calculate the arithmetic 30-boiler operating day rolling average 

of all of the hourly average HAP metals CEMS output data 

collected during all nonexempt boiler operating hours data.

(iv) The permittee shall collect data using the HAP metals CEMS at 

all times the process unit is operating and at the intervals specified 

in paragraph (a) of this condition, except for periods of monitoring 

system malfunctions, repairs associated with monitoring system 

malfunctions, and required monitoring system quality assurance or 

quality control activities.

a) The permittee shall use all the data collected during all boiler 

operating hours in assessing the compliance with the emission 

limit except:

1) Any data collected during monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, or 

required monitoring system quality assurance or control 

activities conducted during monitoring system malfunctions in 

calculations and report any such periods in the annual deviation

report;

2) Any data collected during periods when the monitoring 

system is out of control as specified in the site-specific 

monitoring plan, repairs associated with periods when the 

monitoring system is out of control, or required monitoring 

system quality assurance or control activities conducted during 

out of control periods in calculations used to report emissions 

or operating levels and report any such periods in the annual 

deviation report;

3) Any data recorded during periods of startup or shutdown.

b) The permittee shall record and make available upon request 

results of HAP metals CEMS system performance audits, dates 

and duration of periods when the HAP metals CEMS is out of 

control to completion of the corrective actions necessary to return 

the HAP metals CEMS to operation consistent with the sitespecific performance evaluation and quality control program 

plan.

[40 CFR s. 63.10010(j)]

[40 CFR s. 63.10010, s. 285.65(13), Wis. Stats.]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 118

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(ii) If choosing to establish PM CPMS operating 

limits as allowed by I.C.15.b.(4) to demonstrate 

compliance with the emission limitations in 

I.C.15.a.(1) (particulate matter (PM), total nonmercury HAP metals, individual non-mercury HAP 

metals), the permitee shall 

a) Install, certify, maintain, and operate a PM 

CPMS for monitoring emissions discharged to the 

atmosphere according to 40 CFR s. 

63.10010(g)(1) and 

b) Establish a site-specific operating limit in units 

of PM CPMS output signal (e.g., milliamps, 

mg/acm, or other raw signal) using data from the 

PM CPMS and the PM or HAP metals 

performance tests according to the following 

procedures:

1) Collect PM CPMS output data during the 

entire period of the performance tests.

2) Record the average hourly PM CPMS output 

for each test run in the three run performance 

test.

3) Determine the highest 1-hour average PM 

CPMS measured during the performance test 

demonstrating compliance with the filterable 

PM or HAP metals emissions limitations.

[40 CFR s. 63.10021(a) , Table 6 to 40 CFR, Part 

63, Subpart UUUUU]

(iii) If using PM CPMS to measure compliance 

with a parametric operating limit, the permittee shall 

demonstrate continuous compliance by calculating 

the arithmetic 30-boiler operating day rolling 

average of all of the quality assured hourly average 

PM CPMS output data (e.g., milliamps, PM 

concentration, raw data signal) collected for all 

operating hours for the previous 30 boiler operating 

days, excluding data recorded during periods of 

startup or shutdown. [40 CFR s. 63.10021(a), item 

2 of Table 7 to 40 CFR, Part 63, Subpart UUUUU]

(iv) If using quarterly performance testing to 

measure compliance with one or more applicable 

emissions limits in condition I.C.15.a., the permitee 

shall demonstrate continuous compliance by 

calculating the results of the testing in units of the 

applicable emissions standard. [40 CFR s. 

63.10021(a), item 4 of Table 7 to 40 CFR, Part 63, 

Subpart UUUUU]

(6) Continuous Compliance Demonstration – Monitoring and Data 

Collection:

(a) The permittee shall monitor and collect data according to this 

condition and the site-specific monitoring plan required by 40 CFR 

s. 63.10000(d).

(b) The permitee shall operate the monitoring system and collect data 

at all required intervals at all times that the affected EGU is operating, 

except for periods of monitoring system malfunctions or out-ofcontrol periods (see 40 CFR s. 63.8(c)(7)), and required monitoring 

system quality assurance or quality control activities, including, as 

applicable, calibration checks and required zero and span adjustments. 

The permittee is required to affect monitoring system repairs in 

response to monitoring system malfunctions and to return the 

monitoring system to operation as expeditiously as practicable.

(c) The permtitee may not use data recorded during EGU startup or 

shutdown or monitoring system malfunctions or monitoring system 

out-of-control periods, repairs associated with monitoring system 

malfunctions or monitoring system out-of-control periods, or required 

monitoring system quality assurance or control activities in 

calculations used to report emissions or operating levels. The 

permittee shall use all the data collected during all other periods in 

assessing the operation of the control device and associated control 

system.

(d) Except for periods of monitoring system malfunctions or 

monitoring system out-of-control periods, repairs associated with 

monitoring system malfunctions or monitoring system out-of-control 

periods, and required monitoring system quality assurance or quality 

control activities including, as applicable, calibration checks and 

required zero and span adjustments), failure to collect required data is 

a deviation from the monitoring requirements.

[40 CFR s. 63.10020, s. 285.65(13), Wis. Stats.]

(7) Notification Requirements:

(a) The permittee shall submit all of the notifications in 40 CFR, ss. 

63.7(b) and (c), 63.8 (e), (f)(4) and (6), and 63.9 (b) through (h) that 

apply by the dates specified. [40 CFR ss. 63.9984(c) and 63.10030(a)]

(b) As specified in 40 CFR s. 63.9(b)(2), the permittee shall submit an 

Initial Notification not later than 120 days after April 16, 2012. [40 

CFR ss. 63.9984(c) and 63.10030(b)]

(c) {reserved}

(d) When required to conduct a performance test, the permittee shall 

submit a Notification of Intent to conduct a performance test at least 

30 days before the performance test is scheduled to begin. [40 CFR 

ss. 63.9984(c) and 63.10030(d)]

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 119

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(a) {...continued from previous page...}

(v) When conducting periodic performance 

tune-ups of your EGU(s), the permittee shall 

demonstrate continuous compliance by 

conducting periodic performance tune-ups of the 

EGU(s), as specified in 40 CFR s. 63.10021(e). 

[40 CFR s. 63.10021(a), item 5 of Table 7 to 40 

CFR, Part 63, Subpart UUUUU]

(vi) When complying with work practice 

standards during startup the permittee shall 

demonstrate continuous compliance by operating 

in accordance with Table 3 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10021(a), item 

6 of Table 7 to 40 CFR, Part 63, Subpart 

UUUUU]

(vii) When complying with work practice 

standards during shutdown, the permittee shall 

demonstrate continuous compliance by operating 

in accordance with Table 3 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10021(a), item 

7 of Table 7 to 40 CFR, Part 63, Subpart 

UUUUU]

[40 CFR s. 63.10021(a)]

(b) Except as otherwise provided in 40 CFR 

s. 63.10020(c), if using a CEMS to measure SO2 , 

PM, HCl, or Hg emissions, or using a sorbent trap 

monitoring system to measure Hg emissions, the 

permittee shall demonstrate continuous 

compliance by using all quality-assured hourly 

data recorded by the CEMS (or sorbent trap 

monitoring system) and the other required 

monitoring systems (e.g., flow rate, CO2 , O2 , or 

moisture systems) to calculate the arithmetic 

average emissions rate in units of the standard on a 

continuous 30-boiler operating day (or, if alternate 

emissions averaging is used for Hg, 90-boiler 

operating day) rolling average basis, updated at the 

end of each new boiler operating day. Use 

Equation 8 to determine the 30- (or, if applicable, 

90-) boiler operating day rolling average.

Where:

Heri is the hourly emissions rate for hour i and n is the 

number of hourly emissions rate values collected over 

30- (or, if applicable, 90-) boiler operating days.

[40 CFR s. 63.10021(b)]

(7) Notification Requirements:

{...continued from previous page...}

(e) When required to conduct an initial compliance demonstration as 

specified in 40 CFR s. 63.10011(a), the permittee shall submit a 

Notification of Compliance Status according to 40 CFR s. 63.9(h)(2)(ii). 

The Notification of Compliance Status report shall contain all the 

following information, as applicable:

(i) A description of the affected source(s) including identification of 

which subcategory the source is in, the design capacity of the source, a 

description of the add-on controls used on the source, description of the 

fuel(s) burned, including whether the fuel(s) were determined by the 

permittee or EPA through a petition process to be a non-waste under 40 

CFR s. 241.3, whether the fuel(s) were processed from discarded nonhazardous secondary materials within the meaning of 40 CFR s. 241.3, 

and justification for the selection of fuel(s) burned during the 

performance test.

(ii) Summary of the results of all performance tests and fuel analyses 

and calculations conducted to demonstrate initial compliance including 

all established operating limits.

(iii) Identification of whether compliance with each applicable 

emission limit will be demonstrated through performance testing; fuel 

moisture analyses; performance testing with operating limits (e.g., use 

of PM CPMS); CEMS; or a sorbent trap monitoring system.

(iv) Identification of whether compliance will be demonstrated by 

emissions averaging.

(v) A signed certification that all applicable emission limits and work 

practice standards have been met.

(vi) If a deviation from any emission limit, work practice standard, or 

operating limit occurred, submit a brief description of the deviation, the 

duration of the deviation, emissions point identification, and the cause 

of the deviation in the Notification of Compliance Status report.

(vii) In addition to the information required in 40 CFR s. 63.9(h)(2),

your notification of compliance status must include the following:

a) A summary of the results of the annual performance tests and 

documentation of any operating limits that were reestablished during 

this test, if applicable. If stack tests are conducted once every 3 

years consistent with 40 CFR s. 63.10006(b), the date of the last 

three stack tests, a comparison of the emission level achieved in the 

last three stack tests to the 50 percent emission limit threshold 

required in 40 CFR s. 63.10006(i), and a statement as to whether 

there have been any operational changes since the last stack test that 

could increase emissions.

b) Certifications of compliance, as applicable, signed by a 

responsible official stating: 

1. “This EGU complies with the requirements in 40 CFR, 

s. 63.10021(a) to demonstrate continuous compliance.” and

2. “No secondary materials that are solid waste were combusted in 

any affected unit.”

[40 CFR ss. 63.9984(c) and 63.10030(e), s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 120

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(c) If using a PM CPMS data to measure 

compliance with an operating limit in Table 4 to 

Subpart UUUUU, The permitee shall record the 

PM CPMS output data for all periods when the 

process is operating and the PM CPMS is not outof-control. The permittee shall demonstrate 

continuous compliance by using all qualityassured hourly average data collected by the PM 

CPMS for all operating hours to calculate the 

arithmetic average operating parameter in units of 

the operating limit (e.g., milliamps, PM 

concentration, raw data signal) on a 30 operating 

day rolling average basis, updated at the end of 

each new boiler operating day. Use Equation 9 to 

determine the 30 boiler operating day average.

Where:

Hpvi is the hourly parameter value for hour i and 

n is the number of valid hourly parameter values 

collected over 30 boiler operating days.

[40 CFR s. 63.10021(c)]

(d) If using quarterly performance testing to 

demonstrate compliance with one or more 

applicable emissions limits in 2 to Subpart 

UUUUU (see I.C.15.a.), the permittee:

(i) May skip performance testing in those 

quarters during which less than 168 boiler 

operating hours occur, except that a performance 

test must be conducted at least once every 

calendar year.

(ii) Shall conduct the performance test as defined 

in Table 5 to Subpart UUUUU and calculate the 

results of the testing in units of the applicable 

emissions standard; and

[40 CFR s. 63.10021(d)]

{continued on next page...}

(8) Reporting Requirements:

(a) The permittee shall submit each report in Table 8 to 40 CFR, Part 63, 

Subpart UUUUU that applies. If required to (or electing to) continuously 

monitor Hg and/or HCl emissions, The permittee shall also submit the 

electronic reports required under Appendix A and/or Appendix B to 

Subpart UUUUU, at the specified frequency. [40 CFR s. 63.10031(a)]

(b) Unless the department has approved a different schedule for 

submission of reports under 40 CFR s. 63.10(a), the permittee shall 

submit each report semiannually and according to the following:

(i) The first compliance report shall cover the period beginning on 

April 16, 2015 (the compliance date specified in 40 CFR s. 63.9984) 

and ending on June 30, 2015 (either June 30 or December 31, 

whichever date is the first date that occurs at least 180 days after the 

specified compliance date).

(ii) The first compliance report shall be postmarked or submitted 

electronically no later than July 31, 2015 (either July 31 or January 31, 

whichever date is the first date following the end of the first calendar 

half after the specified compliance date).

(iii) Each subsequent compliance report shall cover the semiannual 

reporting period from January 1 through June 30 or the semiannual 

reporting period from July 1 through December 31.

(iv) Each subsequent compliance report shall be postmarked or 

submitted electronically no later than July 31 or January 31, whichever 

date is the first date following the end of the semiannual reporting 

period.

(v) The permitte may submit the semiannual compliance reports along 

with the reports required by condition I.XXX.1.a., instead of according 

to the dates in paragraphs (i) through (iv), above.

[40 CFR s. 63.10031(b), Table 8 to 40 CFR, Part 63, Subpart UUUUU]

(c) The compliance report shall contain the following information: 

(i) The information required by the summary report located in 40 CFR 

s. 63.10(e)(3)(vi).

(ii) The total fuel use by each affected source subject to an emission 

limit, for each calendar month within the semiannual reporting period, 

including, but not limited to, a description of the fuel, whether the fuel 

has received a non-waste determination by EPA or your basis for 

concluding that the fuel is not a waste, and the total fuel usage amount 

with units of measure.

(iii) An indication of whether new types of fuel were burned during the 

reporting period. If new types of fuel were burned, the permittee shall 

include the date of the performance test where that fuel was in use.

(iv) The date of the most recent tune-up for each unit subject to the 

requirement to conduct a performance tune-up according to 40 CFR 

s. 63.10021(e), including the date of the most recent burner inspection 

if it was not done every 36 (or 48) months and was delayed until the 

next scheduled unit shutdown.

[40 CFR s. 63.10031(c)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 121

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(e) When conducting periodic performance tune-ups 

of your EGU(s), as specified below, perform the first 

tune-up as part of the initial compliance 

demonstration. Notwithstanding this requirement, 

you the permittee may delay the first burner 

inspection until the next scheduled unit outage 

provided the requirements of 40 CFR s. 63.10005 are 

met. Subsequently, the permittee shall perform an 

inspection of the burner at least once every 36 

calendar months unless the EGU employs neural 

network combustion optimization during normal 

operations in which case the permittee shall perform 

an inspection of the burner and combustion controls at 

least once every 48 calendar months.

(i) As applicable, inspect the burner and combustion 

controls, and clean or replace any components of the 

burner or combustion controls as necessary upon 

initiation of the work practice program and at least 

once every required inspection period. Repair of a 

burner or combustion control component requiring 

special order parts may be scheduled as follows:

a) Burner or combustion control component 

parts needing replacement that affect the ability 

to optimize NOX and CO must be installed 

within 3 calendar months after the burner 

inspection,

b) Burner or combustion control component 

parts that do not affect the ability to optimize 

NOX and CO may be installed on a schedule 

determined by the operator;

(ii) As applicable, inspect the flame pattern and 

make any adjustments to the burner or combustion 

controls necessary to optimize the flame pattern. 

The adjustment should be consistent with the 

manufacturer's specifications, if available, or in 

accordance with best combustion engineering 

practice for that burner type;

(iii) As applicable, observe the damper operations as 

a function of mill and/or cyclone loadings, cyclone 

and pulverizer coal feeder loadings, or other 

pulverizer and coal mill performance parameters, 

making adjustments and effecting repair to dampers, 

controls, mills, pulverizers, cyclones, and sensors;

{continued on next page...}

(8) Reporting Requirements:

{...continued from previous page...}

(d) For each excess emissions occurring at an affected source where a 

CMS is used to comply with that emission limit or operating limit, the 

permittee shall include the information required in 40 CFR 

s. 63.10(e)(3)(v) in the compliance report specified in paragraph (c), 

above. [40 CFR s. 63.10031(d)]

(e) The permittee shall report all deviations as defined in 40 CFR, 

Part 63, Subpart UUUUU in the semiannual monitoring report 

required condition I.XXX.1.a. If an affected source submits a 

compliance report pursuant to Table 8 to to Subpart UUUUU along 

with, or as part of, the semiannual monitoring report required by 

condition I.XXX.1.a., and the compliance report includes all required 

information concerning deviations from any emission limit, operating 

limit, or work practice requirement in this subpart, submission of the 

compliance report satisfies any obligation to report the same 

deviations in the semiannual monitoring report. Submission of a 

compliance report does not otherwise affect any obligation the 

affected source may have to report deviations from permit 

requirements to the permit authority. [40 CFR s. 63.10031(e)]

(f) As of January 1, 2012, and within 60 days after the date of 

completing each performance test, the permittee shall submit the 

results of the performance tests required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's Central 

Data Exchange (CDX) ( www.epa.gov/cdx ). Performance test data 

shall be submitted in the file format generated through use of EPA's 

Electronic Reporting Tool (ERT) (see 

http://www.epa.gov/ttn/chief/ert/index.html ). Only data collected 

using those test methods on the ERT Web site are subject to this 

requirement for submitting reports electronically to WebFIRE. 

Owners or operators who claim that some of the information being 

submitted for performance tests is confidential business information 

(CBI) must submit a complete ERT file including information 

claimed to be CBI on a compact disk or other commonly used 

electronic storage media (including, but not limited to, flash drives) to 

EPA. The electronic media must be clearly marked as CBI and mailed 

to U.S. EPA/OAPQS/CORE CBI Office, Attention: WebFIRE 

Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 

27703. The same ERT file with the CBI omitted shall be submitted to 

EPA via CDX as described earlier in this paragraph. The permittee 

shall also submit these reports, including the confidential business 

information, to the department in the format specified by the 

department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 122

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(iv) As applicable, evaluate windbox pressures and 

air proportions, making adjustments and effecting 

repair to dampers, actuators, controls, and sensors;

(v) Inspect the system controlling the air-to-fuel 

ratio and ensure that it is correctly calibrated and 

functioning properly. Such inspection may include 

calibrating excess O2 probes and/or sensors, 

adjusting overfire air systems, changing software 

parameters, and calibrating associated actuators and 

dampers to ensure that the systems are operated as 

designed. Any component out of calibration, in or 

near failure, or in a state that is likely to negate 

combustion optimization efforts prior to the next 

tune-up, should be corrected or repaired as 

necessary;

(vi) Optimize combustion to minimize generation of 

CO and NOX . This optimization should be 

consistent with the manufacturer's specifications, if 

available, or best combustion engineering practice 

for the applicable burner type. NOX optimization 

includes burners, overfire air controls, concentric 

firing system improvements, neural network or 

combustion efficiency software, control systems 

calibrations, adjusting combustion zone temperature 

profiles, and add-on controls such as SCR and 

SNCR; CO optimization includes burners, overfire 

air controls, concentric firing system improvements, 

neural network or combustion efficiency software, 

control systems calibrations, and adjusting 

combustion zone temperature profiles;

(vii) While operating at full load or the 

predominantly operated load, measure the 

concentration in the effluent stream of CO and NOX

in ppm, by volume, and oxygen in volume percent, 

before and after the tune-up adjustments are made 

(measurements may be either on a dry or wet basis, 

as long as it is the same basis before and after the 

adjustments are made). You may use portable CO, 

NOX and O2 monitors for this measurement. EGU's 

employing neural network optimization systems 

need only provide a single pre- and post-tune-up 

value rather than continual values before and after 

each optimization adjustment made by the system;

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(i) Within 60 days after the date of completing each CEMS (SO2 , 

PM, HCl, and Hg) performance evaluation test, as defined in 40 

CFR s. 63.2 and required by Subpart UUUUU, the permittee shall 

submit the relative accuracy test audit (RATA) data (or, for PM 

CEMS, RCA and RRA data) required by this subpart to EPA's 

WebFIRE database by using the Compliance and Emissions Data 

Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The RATA 

data shall be submitted in the file format generated through use of 

EPA's Electronic Reporting Tool (ERT) ( 

http://www.epa.gov/ttn/chief/ert/index.html ). Only RATA data 

compounds listed on the ERT Web site are subject to this 

requirement. Owners or operators who claim that some of the 

information being submitted for RATAs is confidential business 

information (CBI) shall submit a complete ERT file including 

information claimed to be CBI on a compact disk or other 

commonly used electronic storage media (including, but not 

limited to, flash drives) by registered letter to EPA and the same 

ERT file with the CBI omitted to EPA via CDX as described 

earlier in this paragraph. The compact disk or other commonly 

used electronic storage media shall be clearly marked as CBI and 

mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: 

WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., 

Durham, NC 27703. The permittee shall also submit these RATAs 

to the department in the format specified by the department. The 

permittee shall submit calibration error testing, drift checks, and 

other information required in the performance evaluation as 

described in 40 CFR s. 63.2 and as required in 40 CFR.

(ii) For a PM CEMS, PM CPMS, or approved alternative 

monitoring using a HAP metals CEMS, within 60 days after the 

reporting periods ending on March 31st, June 30th, September 

30th, and December 31st, the permitee submit quarterly reports to 

EPA's WebFIRE database by using the Compliance and Emissions 

Data Reporting Interface (CEDRI) that is accessed through EPA's 

Central Data Exchange (CDX) ( www.epa.gov/cdx ). The permittee 

shall use the appropriate electronic reporting form in CEDRI or 

provide an alternate electronic file consistent with EPA's reporting 

form output format. For each reporting period, the quarterly 

reports must include all of the calculated 30-boiler operating day 

rolling average values derived from the CEMS and PM CPMS. 

The permittee shall also submit these quarterly reports to the 

department in the format specified by the department.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 123

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

(e) {...continued from previous page...}

(viii) Maintain on-site and submit, if requested by the 

Administrator, an annual report containing the information in 

paragraphs (e)(1) through (e)(9) of this section including:

a) The concentrations of CO and NOX in the effluent 

stream in ppm by volume, and oxygen in volume percent, 

measured before and after an adjustment of the EGU 

combustion systems;

b) A description of any corrective actions taken as a part 

of the combustion adjustment; and

c) The type(s) and amount(s) of fuel used over the 12 

calendar months prior to an adjustment, but only if the 

unit was physically and legally capable of using more 

than one type of fuel during that period; and

(ix) Report the dates of the initial and subsequent tune-ups as 

follows:

a) If the first required tune-up is performed as part of the 

initial compliance demonstration, report the date of the 

tune-up in hard copy (as specified in 40 CFR s. 63.10030) 

and electronically (as specified in 40 CFR s. 63.10031). 

Report the date of each subsequent tune-up electronically 

(as specified in 40 CFR s. 63.10031).

b) If the first tune-up is not conducted as part of the initial 

compliance demonstration, but is postponed until the next 

unit outage, report the date of that tune-up and all 

subsequent tune-ups electronically, in accordance with 40 

CFR s. 63.10031.

[40 CFR s. 63.10021(e)]

(f) The permittee shall submit the reports required under 40 

CFR s. 63.10031 and, if applicable, the reports required under 

Appendices A and B to Subpart UUUUU. The electronic

reports required by Appendices A and B to Subpart UUUUU 

shall be sent to the EPA electronically, as provided in 40 CFR 

s. 63.10031. CEMS data (except for PM CEMS and any 

approved alternative monitoring using a HAP metals CEMS) 

shall be submitted using EPA's Emissions Collection and 

Monitoring Plan System (ECMPS) Client Tool. Other data, 

including PM CEMS data, HAP metals CEMS data, and 

CEMS performance test detail reports, shall be submitted in the 

file format generated through use of EPA's Electronic 

Reporting Tool, the Compliance and Emissions Data Reporting 

Interface, or alternate electronic file format, all as provided for 

under 40 CFR s. 63.10031. These reports shall also be 

submitted to the department. [40 CFR s. 63.10021(f)]

{continued on next page...}

(8) Reporting Requirements:

(f) {...continued from previous page...}

(iii) Reports for an SO2 CEMS, a Hg CEMS or sorbent 

trap monitoring system, an HCl CEMS, and any 

supporting monitors for such systems (such as a diluent 

or moisture monitor) shall be submitted using the 

ECMPS Client Tool, as provided for in Appendices A 

and B to Subpart UUUUU and 40 CFR s. 63.10021(f). 

The permittee shall also submit these to the department in 

the format specified by the department.

(iv) Submit the compliance reports required under 

paragraphs (c) and (d) of this condition and the 

notification of compliance status required under 40 CFR 

s. 63.10030(e) to EPA's WebFIRE database by using the 

Compliance and Emissions Data Reporting Interface 

(CEDRI) that is accessed through EPA's Central Data 

Exchange (CDX) ( www.epa.gov/cdx ). the permittee 

shall use the appropriate electronic reporting form in 

CEDRI or provide an alternate electronic file consistent 

with EPA's reporting form output format. The permittee 

shall also submit these compliance reports to the 

department in the format specified by the department.

(v) All reports required by 40 CFR, Part 63, Subpart 

UUUUU not subject to the requirements in paragraphs 

(f)(1) through (4) of this condition must be sent to the 

Administrator at the appropriate address listed in 40 CFR 

s. 63.13. If acceptable to both the Administrator and the 

owner or operator of a source, these reports may be 

submitted on electronic media. The Administrator retains 

the right to require submittal of reports subject to 

paragraphs (f)(1), (2), and (3) of this condition in paper 

format. The permittee shall also submit these compliance 

reports to the department in the format specified by the 

department.

[40 CFR s. 63.10031(f)]

(g) If the permittee had a malfunction during the reporting 

period, the compliance report must include the number, 

duration, and a brief description for each type of malfunction 

which occurred during the reporting period and which 

caused or may have caused any applicable emission 

limitation to be exceeded. [40 CFR s. 63.10031(g)]

[40 CFR s. 63.10031, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 124

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(8) Continuous Compliance Demonstration:

{...continued from previous page...}

(g) The permittee shall report each instance in which 

an applicable emissions limit or operating limit in 

Tables 2 through 4 to Subpart UUUUU (I.A.7.a.) 

was not met or a required tune-up was not 

conducted. These instances are deviations from the 

requirements of Subpart UUUUU. These deviations 

shall be reported according to 40 CFR s. 63.10031. 

[40 CFR s. 63.10021(g)]

(h) The permittee shall keep records as specified in 

40 CFR s. 63.10032 during periods of startup and 

shutdown. [40 CFR s. 63.10021(h)]

(i) The permittee shall provide reports as specified in 

40 CFR s. 63.10031 concerning activities and 

periods of startup and shutdown. [40 CFR s. 

63.10021(i)]

[40 CFR s. 63.10021, s. 285.65(13), Wis. Stats.]

(9) Continuous Compliance Demonstration –

Emissions Averaging Provision:

(a) Following the compliance date, the permittee 

shall demonstrate compliance with Subpart UUUUU 

on a continuous basis by meeting the following:

(i) For each 30- (or 90-) day rolling average 

period, demonstrate compliance with the average 

weighted emissions limit for the existing units 

participating in the emissions averaging option as 

determined in 40 CFR s. 63.10009(f) and (g);

(ii) For each existing unit participating in the 

emissions averaging option that is equipped with 

PM CPMS, maintain the average parameter value 

at or below the operating limit established during 

the most recent performance test;

(iii) For each existing unit participating in the 

emissions averaging option venting to a common 

stack configuration containing affected units from 

other subcategories, maintain the appropriate 

operating limit for each unit as specified in Table 

4 to Subpart UUUUU that applies.

(b) Any instance where the permittee fails to comply 

with the continuous monitoring requirements in 

paragraphs (a) of this condition is a deviation.

[40 CFR s. 63.10022, s. 285.65(13), Wis. Stats.]

(9) Recordkeeping Requirements:

(a) The permittee shall keep records according to the following. If 

required to (or electing to) continuously monitor Hg and/or HCl 

emissions, the permittee shall also keep the records required under 

Appendix A and/or Appendix B to 40 CFR, Part 63, Subpart UUUUU.

(i) A copy of each notification and report that you submitted to 

comply with this subpart, including all documentation supporting 

any Initial Notification or Notification of Compliance Status or 

semiannual compliance report that you submitted, according to the 

requirements in 40 CFR s. 63.10(b)(2)(xiv).

(ii) Records of performance stack tests, fuel analyses, or other 

compliance demonstrations and performance evaluations, as 

required in 40 CFR s. 63.10(b)(2)(viii).

[40 CFR s. 63.10032(a)]

(b) For each CEMS and CPMS, the permittee shall keep records 

according to the following:

(i) Records described in 40 CFR s. 63.10(b)(2)(vi) through (xi).

(ii) Previous (i.e., superseded) versions of the performance 

evaluation plan as required in 40 CFR s. 63.8(d)(3).

(iii) Request for alternatives to relative accuracy test for CEMS as 

required in 40 CFR s. 63.8(f)(6)(i).

(iv) Records of the date and time that each deviation started and 

stopped, and whether the deviation occurred during a period of 

startup, shutdown, or malfunction or during another period.

[40 CFR s. 63.10032(b)]

(c) The permittee shall keep the records required in Table 7 to 40 CFR, 

Part 63, Subpart UUUUU including records of all monitoring data and 

calculated averages for applicable PM CPMS operating limits to show 

continuous compliance with each emission limit and operating limit 

that applies to you. [40 CFR s. 63.10032(c)]

(d) For each EGU subject to an emission limit, the permittee shall also 

keep the following records:

(i) The permittee shall keep records of monthly fuel use by each 

EGU, including the type(s) of fuel and amount(s) used.

(ii) If combusting non-hazardous secondary materials that have 

been determined not to be solid waste pursuant to 40 CFR 

241.3(b)(1), the permittee shall keep a record which documents 

how the secondary material meets each of the legitimacy criteria. If 

combusting a fuel that has been processed from a discarded nonhazardous secondary material pursuant to 40 CFR 241.3(b)(2), the 

permittee shall keep records as to how the operations that produced 

the fuel satisfies the definition of processing in 40 CFR 241.2. If the 

fuel received a non-waste determination pursuant to the petition 

process submitted under 40 CFR 241.3(c), the permittee shall keep 

a record which documents how the fuel satisfies the requirements of 

the petition process.

{continued on next page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 125

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(10) Establishing and Determining Compliance with 

a PM CPMS Operating Limit:

(a) During the initial performance test or any such 

subsequent performance test that demonstrates 

compliance with the filterable PM, individual nonmercury HAP metals, or total non-mercury HAP 

metals limit in I.C.15.a.(1), record all hourly average 

output values (e.g., milliamps, stack concentration, or 

other raw data signal) from the PM CPMS for the 

periods corresponding to the test runs (e.g., nine 1-

hour average PM CPMS output values for three 3-

hour test runs).

(b) Determine the operating limit as the highest 1-

hour average PM CPMS output value recorded during 

the performance test. The permittee shall verify an 

existing or establish a new operating limit after each 

repeated performance test.

(c) The permittee shall operate and maintain the 

process and control equipment such that the 30 

operating day average PM CPMS output does not 

exceed the operating limit determined in paragraphs 

(a) and (b) of this condition.

[40 CFR s. 63.10023, s. 285.65(13), Wis. Stats.]

(11) General Provisions: The permittee is subject to 

the General Provisions of 40 CFR ss. 63.1 through 

63.15 as shown in Table 9 to 40 CFR, Part 63, 

Subpart UUUUU. [40 CFR s. 63.10040, s. 

285.65(13), Wis. Stats.]

(12) Affirmative defense for exceedence of emission 

limit during malfunction: In response to an action 

to enforce the standards set forth in 40 CFR s. 

63.9991 the permittee may assert an affirmative 

defense to a claim for civil penalties for exceedances 

of such standards that are caused by malfunction, as 

defined at 40 CFR s. 63.2. Appropriate penalties may 

be assessed, however, if the permittee fails to meet all 

burden of proving all of the requirements in the 

affirmative defense. The affirmative defense shall not 

be available for claims for injunctive relief.

{continued on next page...}

(9) Recordkeeping Requirements:

(d) {...continued from previous page...}

(iii) For an EGU that qualifies as an LEE under 40 CFR 

s. 63.10005(h), the permittee shall keep annual records that 

document that emissions in the previous stack test(s) continue to 

qualify the unit for LEE status for an applicable pollutant, and 

document that there was no change in source operations including 

fuel composition and operation of air pollution control equipment 

that would cause emissions of the pollutant to increase within the 

past year.

[40 CFR s. 63.10032(d)]

(e) If electing to average emissions consistent with 40 CFR 

s. 63.10009, the permittee must additionally keep a copy of the 

emissions averaging implementation plan required in 40 CFR 

s. 63.10009(g), all calculations required under 40 CFR s. 63.10009, 

including daily records of heat input or steam generation, as 

applicable, and monitoring records consistent with 40 CFR 

s. 63.10022. [40 CFR s. 63.10032(e)]

(f) The permitee shall keep records of the occurrence and duration of 

each startup and/or shutdown. [40 CFR s. 63.10032(f)]

(g) The permittee shall keep records of the occurrence and duration of 

each malfunction of an operation ( i.e. , process equipment) or the air 

pollution control and monitoring equipment. [40 CFR s. 63.10032(g)]

(h) The permitee shall keep records of actions taken during periods of 

malfunction to minimize emissions in accordance with 40 CFR 

s. 63.10000(b), including corrective actions to restore malfunctioning 

process and air pollution control and monitoring equipment to its 

normal or usual manner of operation. [40 CFR s. 63.10032(h)]

(i) The permitee shall keep records of the type(s) and amount(s) of 

fuel used during each startup or shutdown. [40 CFR s. 63.10032(i)]

[40 CFR s. 63.10032, s. 285.65(13), Wis. Stats.]

(10) Records (Form and Retention):

(a) Records must be in a form suitable and readily available for 

expeditious review, according to 40 CFR s. 63.10(b)(1).

(b) As specified in 40 CFR s. 63.10(b)(1), the permitee shall keep 

each record for 5 years following the date of each occurrence, 

measurement, maintenance, corrective action, report, or record.

(c) The permittee shall keep each record on site for at least 2 years 

after the date of each occurrence, measurement, maintenance, 

corrective action, report, or record, according to § 63.10(b)(1). The 

permittee may keep the records off site for the remaining 3 years.

[40 CFR s. 63.10033]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 126

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: 

{continued from previous page...}

(a) To establish the affirmative defense in any action to enforce such 

a limit, the permittee shall timely meet the notification requirements 

in paragraph (b) of this condition, and must prove by a 

preponderance of evidence that:

(i) The excess emissions:

a) Were caused by a sudden, infrequent, and unavoidable failure 

of air pollution control and monitoring equipment, process 

equipment, or a process to operate in a normal or usual manner, 

and

b) Could not have been prevented through careful planning, 

proper design or better operation and maintenance practices; and

c) Did not stem from any activity or event that could have been 

foreseen and avoided, or planned for; and

d) Were not part of a recurring pattern indicative of inadequate 

design, operation, or maintenance; and

(ii) Repairs were made as expeditiously as possible when the 

applicable emission limitations were being exceeded. Off-shift and 

overtime labor were used, to the extent practicable to make these 

repairs; and

(iii) The frequency, amount and duration of the excess emissions 

(including any bypass) were minimized to the maximum extent 

practicable during periods of such emissions; and

(iv) If the excess emissions resulted from a bypass of control 

equipment or a process, then the bypass was unavoidable to 

prevent loss of life, personal injury, or severe property damage; 

and

(v) All possible steps were taken to minimize the impact of the 

excess emissions on ambient air quality, the environment and 

human health; and

(vi) All emissions monitoring and control systems were kept in 

operation if at all possible, consistent with safety and good air 

pollution control practices; and

(vii) All of the actions in response to the excess emissions were 

documented by properly signed, contemporaneous operating logs; 

and

(viii) At all times, the affected source was operated in a manner 

consistent with good practices for minimizing emissions; and

(ix) A written root cause analysis has been prepared, the purpose of 

which is to determine, correct, and eliminate the primary causes of 

the malfunction and the excess emissions resulting from the 

malfunction event at issue. The analysis shall also specify, using best 

monitoring methods and engineering judgment, the amount of excess 

emissions that were the result of the malfunction.

{continued on next page...}

(11) Emissions Averaging to Comply with 40 CFR, 

Part 63, Subpart UUUUU: The permittee may use the 

emission averaging described in 40 CFR s. 63.10009 to 

comply with Subpart UUUUU, if all the criteria in that 

section are met. [40 CFR s. 63.10009, s. 285.65(13), 

Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 127

C. Stack S04, Boiler B04, Control Device C04A, C04B, C04C, C04D – Weston Unit 4 – Super Critical Pulverized Coal 

Boiler Rated at 5179.07 mmBtu/hr – (CONTINUED)

Pollutant: 15. Hazardous Air Pollutants Regulated by the Clean Air Act: {CONTINUED}

National Emission Standards for HAPs (NESHAP): Coal- and Oil-Fired Electric Utility Steam Generating Units, 40 CFR, Part 

63, Subpart UUUUU.

The permittee shall comply with the requirements of this section no later than April 16, 2015. [40 CFR, ss. 63.9982(a)(1), 

63.9982(d), and s. 63.9984(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(12) Affirmative defense for exceedence of emission limit during 

malfunction: 

{continued from previous page...}

(b) Notification. When experiencing an exceedance of its emission 

limit(s) during a malfunction, the permittee shall notify US EPA and 

the department by telephone or facsimile (FAX) transmission as 

soon as possible, but no later than two business days after the initial 

occurrence of the malfunction or, if it is not possible to determine 

within two business days whether the malfunction caused or 

contributed to an exceedance, no later than two business days after 

the permittee knew or should have known that the malfunction 

caused or contributed to an exceedance, but, in no event later than 

two business days after the end of the averaging period, if it wishes 

to avail itself of an affirmative defense to civil penalties for that 

malfunction. When seeking to assert an affirmative defense, the 

permittee shall also submit a written report to US EPA and the 

department within 45 days of the initial occurrence of the 

exceedance of the standard in 40 CFR s. 63.9991 to demonstrate, 

with all necessary supporting documentation, that it has met the 

requirements set forth in paragraph (a) of this condition. The 

permittee may seek an extension of this deadline for up to 30 

additional days by submitting a written request to US EPA and the 

department before the expiration of the 45 day period. Until a 

request for an extension has been approved by US EPA and the 

department, the permittee is subject to the requirement to submit 

such report within 45 days of the initial occurrence of the 

exceedance.

[40 CFR s. 63.10001, s. 285.65(13), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 128

D. Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

395 MMBTU/hr – Peaking Unit – Installed 1/1969

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations: 

(1) 0.60 pound per million Btu of heat input and 25.0 pounds per hour when firing natural gas and/or distillate fuel oil.76 [s. 

NR 415.06(1)(a) Wis. Adm. Code, s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas and/or distillate 

fuel oil having a sulfur content of no more than 0.05% in the 

CT. [ss.285.65(3) and 285.65(10), Wis. Stats.] 

(2) The permittee shall demonstrate compliance with the 

applicable PM/PM10 hourly emission limit by using fuel 

consumption records and emission factors of 0.0066 

lb/MMBTU of natural gas and 0.012 lb/MMBTU of distillate 

fuel oil or alternative Department approved emission factors.

[s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever particulate matter emission testing is required by 

the Department, the permittee shall use U.S. EPA Method 5, 

including backhalf draft Dry Impinger (Method 202), U.S. 

EPA Method 201 or 201A for PM10, or any other method 

approved by the Department in writing. [s. NR 439.06(1), and 

(1m) Wis. Adm. Code]

(2) The permittee shall retain the CT’s fuel burner design 

specifications to demonstrate that the burners are solely 

designed to burn natural gas/distillate fuel oil. [s. 285.65(3), 

Wis. Stats.]

 76 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no ambient 

air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 129

D. Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

395 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) 40% opacity or number 2 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 40% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.77 

(b) Visible emissions may exceed number 2 of the Ringlemann chart or 40% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.04(1), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas or distillate fuel 

oil in the CT. [s. 407.09(4)(a)3.b., Wis. Adm. Code]

(2) To demonstrate compliance with the visible emission 

limitation in I.D.2.a.(1), the permittee shall perform U.S. EPA 

Method 9 visible emission testing on Stack S11 as follows:

(a) Testing shall be conducted every 12 months as long as the 

permit remains valid. The permittee shall perform an annual

Method 9 test for each fuel used in the turbine during the

previous 12-month period prior to the scheduled test date, 

with the exception noted under (b).

(b) The department may grant a written waiver of a scheduled 

test for a particular fuel, if the turbine was not operated firing 

that fuel, more than 360 hours in the previous 12 month 

period prior to the scheduled test date.

(c) Each annual visible emission test shall be performed 

within 90 days of the anniversary date of the issuance of this 

permit or within 90 days of an alternate date specified by the 

Department in writing. [40 CFR 70.6(a)(3)(i)(B), ss. 

285.65(3) and (13), Wis. Stats., s. NR 439.075(4)(a)1.c., Wis. 

Adm. Code]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or any other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1., 

Wis. Adm. Code]

(2) The permittee shall retain fuel burner design specifications 

to demonstrate that the burners are solely designed to burn 

natural gas/distillate fuel oil. [s. NR 439.04(1)(d), Wis. Adm. 

Code and s. 285.65(3), Wis. Stats.] 

(3) The permittee shall retain copies of the results of the 

annual visible emission testing required by I.D.2.b.(2). [s. NR 

439.04(1)(d), Wis. Adm. Code]

 77 When combustion equipment is being cleaned or a new fire started and opacity exceeds 40%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 130

D. Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

395 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 3. Sulfur Dioxide (SO2)

a. Limitations:

(1)(a) 19.95 pounds per hour when firing natural gas and/or distillate fuel oil. 78

(b) The sulfur content of the fuel oil fired in B11 may not exceed 0.05% by weight.

[ss. 285.65(3) and (7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall use one of the following options to 

demonstrate compliance with condition I.D.3.a.(1):

(a) The permittee shall take a representative sample from 

each batch of distillate fuel oil received and have the sample 

analyzed for sulfur content;

(b) The permittee shall take a representative sample from the 

distillate fuel oil in the fuel tank after each new shipment of 

oil is received, added to the tank and adequately blended with 

existing oil. This sample shall be analyzed for sulfur content 

before any oil from the refilled fuel tank is combusted;

(c) The permittee shall retain copies of the fuel supplier’s 

sulfur content analysis for each shipment of distillate fuel oil 

received; or

(d) The permittee shall retain copies of the fuel supplier’s 

sulfur content analysis of a representative sample of the batch 

of distillate fuel oil from which the shipment was taken.

[ss. NR 439.04(1)(d) and NR 439.085(4), Wis. Adm. Code]

(2) The permittee shall demonstrate compliance with the 

applicable SO2 hourly emission limit by using fuel 

consumption records and emission factors of 0.0034 

lb/MMBTU for natural gas and 0.051 lb/MMBTU for 

distillate fuel oil or alternative Department approved emission 

factors. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever sulfur dioxide emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 6, 6A 

or 6C or any other method approved by the Department in 

writing. [s. NR 439.06(2), Wis. Adm. Code]

(2) The permittee shall maintain the following records:

(a) sulfur content of the distillate fuel oil as determined in 

condition I.D.3.b.(1);

(b) the name of the oil supplier;

(c) the quantity of distillate fuel oil received in each shipment;

(d) operating hours of the turbine on a monthly basis;

(e) amount of fuel used in the turbine on a monthly basis.

[s. NR 439.04(1)(d), Wis. Adm. Code]

 78 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 131

D. Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

395 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 4. Nitrogen Oxides (NOX)

a. Limitations:

(1) 347.6 pounds per hour when firing natural gas and/or distillate fuel.79 [ss.285.65(3) and 285.65(7), Wis. Stats.]

(2) The combustion turbine (B11) may not operate more than 455 hours per month averaged over any consecutive 12-month 

period.80 [ss. 285.63(1)(b) and 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate compliance with the 

applicable NOx hourly emission limit by using fuel 

consumption records and emission factors of 0.32 lb/MMBTU 

of natural gas and 0.88 lb/MMBTU gallons of distillate fuel 

oil or alternative Department approved emission factors. [s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Nitrogen Oxides Emissions: 

Whenever Nitrogen oxides emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 7, 7E, 

or any other method approved by the Department in writing. 

[s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall maintain monthly records of 

(a) the number of hours of operation of B11; and 

(b) the monthly fuel usage of B11 averaged over any 

consecutive 12-month period. 

[s. NR 439.04, Wis. Adm. Code]

D. Stack S11, Combustion Turbine B11 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

395 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 5. Carbon Monoxide (CO)

a. Limitations:

(1) 216.25 pounds per hour when firing natural gas and/or distillate fuel oil. [ss.285.65(3) and 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate compliance with the 

applicable CO hourly emission limit by using fuel 

consumption records and emission factors of 0.082 

lb/MMBTU for natural gas and 0.0033 lb/ MMBTU of 

distillate fuel oil or alternative Department approved emission 

factors. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever carbon monoxide emission testing is required by 

the Department, the permittee shall use U.S. EPA Method 10 

or any other method approved by the Department in writing. 

[s. NR 439.06(4), Wis. Adm. Code]

 79 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

80 This limitation is necessary to ensure that the annual National Ambient Air Quality Standard for NOx is attained and 

maintained. Note: Air quality dispersion modeling performed for this permit took this operating hour limitation into account 

when determining whether the annual SO2 and the annual PM10 National Ambient Air Quality Standards are attained and 

maintained.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 132

E. Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – Installed 6/1973 

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – Installed 6/1973

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations: 

(1) Particulate Matter Emissions from EACH combustion turbine (B12 and B13) may not exceed: 0.10 pound per million Btu 

of heat input and 26.91 pounds per hour when firing natural gas and/or distillate fuel oil.81 [s. NR 415.06(2)(c) Wis. Adm. 

Code, s.285.65(3), Wis. Stats, s. 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall only fire natural gas and/or 

distillate fuel oil having a sulfur content of no more 

than 0.05% in the CT. [ss.285.65(3) and 285.65(10), 

Wis. Stats.]

(2) The permittee shall demonstrate compliance 

with the applicable PM/PM10 hourly emission limit 

by using fuel consumption records and emission 

factors of 0.023 lb/MMBTU of natural gas and 

0.062 lb/MMBTU of distillate fuel oil or alternative 

Department approved emission factors(the 

Department approval must be in writing). [s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Particulate Matter Emissions: Whenever 

particulate matter emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 5, including backhalf draft Dry 

Impinger (Method 202), U.S. EPA Method 201 or 201A for PM10, or 

any other method approved by the Department in writing. [s. NR 

439.06(1), and (1m) Wis. Adm. Code]

(2) The permittee shall retain fuel burner design specifications for each 

turbine to demonstrate that the burners are solely designed to burn 

natural gas/distillate fuel oil. [s. 285.65(3), Wis. Stats.]

 81 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 133

E. Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED) 

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.82 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises.

[s. NR 431.05, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas or distillate fuel 

oil in each turbine. [s. 407.09(4)(a)3.b., Wis. Adm. Code]

(2) To demonstrate compliance with the visible emission

limitation in I.E.2.a.(1), the permittee shall perform U.S. EPA 

Method 9 visible emission testing on each of Stack S12 and 

S13 as follows:

(a) Testing shall be conducted every 12 months as long as the 

permit remains valid. The permittee shall perform an annual 

Method 9 test for each turbine, for each fuel used during the 

previous 12-month period prior to the scheduled test date, 

with the exception noted under (b). 

(b) The department may grant a written waiver of a scheduled 

test for a particular fuel, if the turbine was not operated firing 

that fuel, more than 360 hours in the previous 12 month 

period prior to the scheduled test date.

(c) Each annual visible emission test shall be performed 

within 90 days of the anniversary date of the issuance of this 

permit or within 90 days of an alternate date specified by the 

Department in writing. 

[40 CFR 70.6(a)(3)(i)(B), ss. 285.65(3) and (13), Wis. Stats., 

s. NR 439.075(4)(a)1.c., Wis. Adm. Code]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or any other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1, 

and (1m) Wis. Adm. Code]

(2) The permittee shall retain fuel burner design specifications 

for each turbine to demonstrate that the burners are solely 

designed to burn natural gas/distillate fuel oil. [s. 285.65(3), 

Wis. Stats.]

(3) The permittee shall retain copies of the results of the 

annual visible emission testing required by I.E.2.b.(2). [s. NR 

439.04(1)(d), Wis. Adm. Code]

 82 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance 

per hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one 

day.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 134

E. Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED) 

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 3. Sulfur Dioxide (SO2)

a. Limitations:

(1)(a) Emissions from EACH combustion turbine (B12 and B13) may not exceed 21.92 pounds per hour when firing natural 

gas and/or distillate fuel oil. 83

(b) The sulfur content of the fuel oil fired in B12 and B13 may not exceed 0.05% by weight.

[s. 285.65(3), Wis. Stats., and s. 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall use one of the following options to 

demonstrate compliance with condition I.E.3.a.(1):

(a) The permittee shall take a representative sample from 

each batch of distillate fuel oil received and have the sample 

analyzed for sulfur content;

(b) The permittee shall take a representative sample from the 

distillate fuel oil in the fuel tank after each new shipment of 

oil is received, added to the tank and adequately blended with 

existing oil. This sample shall be analyzed for sulfur content 

before any oil from the refilled fuel tank is combusted;

(c) The permittee shall retain copies of the fuel supplier’s 

sulfur content analysis for each shipment of distillate fuel oil 

received; or

(d) The permittee shall retain copies of the fuel supplier’s 

sulfur content analysis of a representative sample of the batch 

of distillate fuel oil from which the shipment was taken.

[ss. NR 439.04(1)(d) and NR 439.085(4), Wis. Adm. Code]

(2) The permittee shall demonstrate compliance with the 

applicable SO2 hourly emission limit by using fuel 

consumption records and emission factors of 0.0034 

lb/MMBTU for natural gas and 0.048 lb/MMBTU for 

distillate fuel oil or alternative Department approved emission 

factors. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever sulfur dioxide emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 6, 6A 

or 6C or any other method approved by the Department in 

writing. [s. NR 439.06(2), Wis. Adm. Code]

(2) The permittee shall maintain the following records:

(a) sulfur content of the distillate fuel oil as determined in 

condition I.E.3.b.(1);

(b) the name of the oil supplier;

(c) the quantity of distillate fuel oil received in each shipment;

(d) operating hours of each turbine on a monthly basis;

(e) amount of fuel used in each turbine on a monthly basis.

[s. NR 439.04(1)(d), Wis. Adm. Code]

 83 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 135

E. Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED) 

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 4. Nitrogen Oxides (NOX)

a. Limitations:

(1) Emissions from EACH combustion turbine (B12 and B13) may not exceed 212.7 pounds per hour when firing natural gas 

and 411.0 pounds per hour when firing distillate fuel oil. 

(2) EACH combustion turbine (B12 and B13) may not operate more than 603 hours per month averaged over any 12 

consecutive month period on natural gas and 73 hours per month averaged over 12 consecutive month period on distillate fuel 

oil.84 [ss.285.63(1)(b) and 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall 

demonstrate compliance with the 

applicable NOx hourly emission 

limit by using fuel consumption 

records and emission factors of 

0.476 lb/MMBTU of natural gas 

and 0.947 lb/MMBTU of 

distillate fuel oil or alternative 

Department approved emission 

factors. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Nitrogen Oxides Emissions: Whenever nitrogen oxides 

emission testing is required by the Department, the permittee shall use U.S. EPA Method 

7, 7E, or any other method approved by the Department in writing. [s. NR 439.06(6), Wis. 

Adm. Code]

(2) The permittee shall maintain the following records:

(a) Records of the number of hours each turbine is operated on distillate fuel oil and/or 

natural gas for each day that B12 and/or B13 is operated;

(b) Records of the number of hours each turbine is operated on distillate fuel oil and/or 

natural gas each month that B12 and/or B13 is operated; and

(c) Records of the hours each turbine is operated on distillate fuel oil and/or natural gas 

averaged over each 12 consecutive month period. This calculation of the 12-month 

rolling operating hour total shall occur within 15 business days after the end of each 

calendar month. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

E. Stack S12, Combustion Turbine B12 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED) 

Stack S13, Combustion Turbine B13 – Simple Cycle Natural Gas/Distillate Fuel Oil Combustion Turbine Rated at 

434 MMBTU/hr – Peaking Unit – (CONTINUED)

Pollutant: 5. Carbon Monoxide (CO)

a. Limitations:

(1) Emissions from EACH combustion turbine (B12 and B13) may not exceed 175.6 pounds per hour when firing natural gas 

and/or distillate fuel oil.85 [ss.285.65(3) and 285.65(7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall demonstrate compliance with the 

applicable CO hourly emission limit by using fuel 

consumption records and emission factors of 0.392 

lb/MMBTU of natural gas and 0.043 lb/MMBTU of 

distillate fuel oil or alternative Department approved 

emission factors. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever carbon monoxide emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 10 or any 

other method approved by the Department in writing. [s. NR 

439.06(4), Wis. Adm. Code]

 84 This limitation is necessary to ensure that the annual National Ambient Air Quality Standard for NOx is attained and 

maintained. Note: Air quality dispersion modeling performed for this permit took this operating hour limitation into account 

when determining whether the annual SO2 and the annual PM10 National Ambient Air Quality Standards are attained and 

maintained.

85 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 136

F. Stack S21, Boiler B21 – Weston Units 1 & 2 Auxiliary Boiler – Natural Gas Fired Auxiliary Boiler Rated 

at 6.6 MMBTU/hr – Installed 10/1953

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations:

(1)(a) 0.60 pound per million Btu heat input and

(b) 0.16 pound per hour.86

[s. NR 415.06(1)(a), Wis. Adm. Code and ss. 285.63(1)(b) and 285.65(3), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in the boiler.

87 

[s. NR 407.09(4)(a), Wis. Adm. Code and s. 285.65(3), Wis. 

Stats.]

(2) The permittee shall demonstrate compliance with the 

applicable PM/PM10 hourly emission limit by using fuel 

consumption records and an emission factor of 0.0076

lbs/mmBtu or an alternative Department approved emission 

factor. [s. NR 407.09(4)(a), Wis. Adm. Code and s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever particulate matter emission testing is required, the 

permittee shall use US EPA Method 5, 5A, 5B, 5D, 5E, 5F, 

5G, 5H, 5I or 17 including condensable backhalf emissions 

(U.S. EPA Method 202) or any other method approved by the 

Department in writing. [s. NR 439.06(1), and (1m) Wis. Adm. 

Code]

(2) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.40(1)(d), Wis. Adm. Code and s. 285.65(3), 

Wis. Stats.]

 86 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

87 Because the emission limitation listed in I.F.1.a.(1)(b) is greater than the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the particulate matter emission limit. Maximum 

theoretical particulate matter emissions were calculated using an emission factor of 0.0076 pounds per mmBtu from AP-42, 5th 

edition, ch. 1.3.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 137

F. Stack S21, Boiler B21 – Natural Gas Fired Auxiliary Boiler Rated at 6.6 MMBTU/hr – (CONTINUED)

Pollutant: 2. Nitrogen Oxides Emissions (NOX)

a. Limitations:

(1) 0.96 pound per hour.88 [ss. 285.63(1)(b) and s. 285.65(3) and (7), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler.89 [s. 

NR 407.09(4)(a), Wis. Adm. Code and ss. 285.63(1)(a) and 

285.65(3), Wis. Stats.]

(2) The permittee shall demonstrate compliance with the 

applicable NOx hourly emission limit by using fuel consumption 

records and an emission factor of 0.097 lbs/mmBtu or an 

alternative Department approved emission factor. [s. NR 

407.09(4)(a), Wis. Adm. Code and s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Nitrogen Oxide 

Emissions: Whenever nitrogen oxide emission testing is 

required, the permittee shall use U.S. EPA Method 7, 7A, 

7B, 7C, 7D, or 7E or any other method approved by the 

Department in writing. [s. NR 439.06(6)(a), Wis. Adm. 

Code]

(2) The permittee shall retain boiler design specifications 

to demonstrate that the boiler is solely designed to burn 

natural gas. [s. NR 439.04(1)(d), Wis. Adm. Code]

F. Stack S21, Boiler B21 – Natural Gas Fired Auxiliary Boiler Rated at 6.6 MMBTU/hr – (CONTINUED)

Pollutant: 3. Visible Emissions

a. Limitations:

(1) 40% opacity or number 2 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 40% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.90 

(b) Visible emissions may exceed number 2 of the Ringlemann chart or 40% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.04(1), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in 

this boiler.91 [s. NR 407.09(4)(a), Wis. Adm. 

Code and ss. 285.63(1)(a) and 285.65(3), Wis. 

Stats.]

(1) Reference Test Method for Visible Emissions: Whenever visible 

emission testing is required, the permittee shall use U.S. EPA Method 9 or 

any other method approved by the Department in writing. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain boiler design specifications to demonstrate 

that the boiler is solely designed to burn natural gas. [s. NR 439.04(1)(d), 

Wis. Adm. Code and s. 285.65(3), Wis. Adm. Code]

 88 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

89 Because the emission limitation listed in I.F.2.a.(1) is greater than the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the nitrogen oxide emission limit. Maximum 

theoretical nitrogen oxide emissions were calculated using an emission factor of 0.097 pounds per mmBtu from the burner 

vendor (Cleaver Brooks) for burner model VG-84.

90 When combustion equipment is being cleaned or a new fire started and opacity exceeds 40%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

91 It is not expected that the visible emission limitation of 40% opacity would be exceeded while firing this fuel. Therefore 

restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 138

F. Stack S21, Boiler B21 – Natural Gas Fired Auxiliary Boiler Rated at 6.6 MMBTU/hr – (CONTINUED)

Pollutant: 4. Sulfur Dioxide (SO2)

a. Limitations:

(1)(a) 0.35 pound per hour. 92 [s. 285.65(7), Wis. Stats., and s. 285.65(3), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler.93

[s. NR 407.09(4)(a), Wis. Adm. Code and ss. 285.63(1)(a) 

and 285.65(3), Wis. Stats.]

(2) The permittee shall demonstrate compliance with the 

applicable sulfur dioxide hourly emission limit by using fuel 

consumption records and an emission factor of 0.0017 

lbs/mmBtu or an alternative Department approved emission 

factor. [s. NR 407.09(4)(a), Wis. Adm. Code and s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever sulfur dioxide emission testing is required, the 

permittee shall use U.S. EPA Method 6, 6A, 6B, 6C, or 8 or 

any other method approved by the Department in writing. [s. 

NR 439.06(2)(a), Wis. Adm. Code]

(2) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code and s. 285.65(3), 

Wis. Stats.]

 92 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

93 Because the emission limitation listed in I.F.3.a.(1) is greater than the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the sulfur dioxide emission limit. Maximum 

theoretical sulfur dioxide emissions were calculated using an emission factor of 0.0017 pounds per mmBtu from the burner 

vendor (Cleaver Brooks) for burner model VG-84.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 139

F. Stack S21, Boiler B21 – Natural Gas Fired Auxiliary Boiler Rated at 6.6 MMBTU/hr – (CONTINUED)

Pollutant: 5. Carbon Monoxide (CO)

a. Limitations:

(1) 0.24 pound per hour.94 [s. 285.65(7), Wis. Stats., and s. 285.65(3), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler.95 

[s. NR 407.09(4)(a), Wis. Adm. Code and ss. 285.63(1)(a) 

and 285.65(3), Wis. Stats.]

(2) The permittee shall demonstrate compliance with the 

applicable CO hourly emission limit by using fuel 

consumption records and an emission factor of 0.036 

lbs/mmBtu or an alternative Department approved emission 

factor. [s. NR 407.09(4)(a), Wis. Adm. Code and s. 285.65(3), 

Wis. Stats.]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever carbon monoxide emission testing is required, the 

permittee shall use U.S. EPA Method 10 or any other method 

approved by the Department in writing. [s. NR 439.06(4)(a), 

Wis. Adm. Code]

(2) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code and s. 285.65(3), 

Wis. Stats.]

 94 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

95 Because the emission limitation listed in I.F.5.a.(1) is equal to the maximum theoretical emissions while firing natural gas, 

limiting the type of fuel used is adequate to demonstrate compliance with the carbon monoxide emission limit. Maximum 

theoretical carbon monoxide emissions were calculated using an emission factor of 0.036 pounds per mmBtu from the burner 

vendor (Cleaver Brooks) for burner model VG-84.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 140

F. Stack S21, Boiler B21 – Natural Gas Fired Auxiliary Boiler Rated at 6.6 MMBTU/hr – (CONTINUED)

Pollutant: 6. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers 

and Process Heaters (40 CFR, Part 63, Subpart DDDDD)

The permittee shall comply with the requirements of this section at such time as judicial review is no longer pending or US 

EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR s. 63.7495(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) The permittee shall comply with the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, as applicable.96 [40 

CFR, Part 63, Subpart DDDDD, s. 285.65(13), Wis. Stats.]

 96 On March 21, 2011, an amended version of EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) for 

Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, was published as a final rule in the 

Federal Register (40 CFR Part 63, subpart DDDDD). Under the amended rule, auxilliary boiler B21 is an industrial boiler per 

the definition in 40 CFR s. 63.7575. Because the boiler was constructed prior to June 4, 2010 (B21 constructed 1953), it is 

considered an existing affected source, pursuant to 40 CFR s. 63.7490(d). Boiler B21 fires natural gas and is included in the 

boiler and process heater subcategory “units designed to burn natural gas, refinery gas or other gas fuels” in 40 CFR s. 

63.74999(l). As an existing affected source the permittee was required to comply with the requirements of 40 CFR Part 63, 

subpart DDDDD of the amended rule no later than March 21,2014, pursuant to 40 CFR s. 63.7495(b).

However, on May 16, 2011 US EPA “stayed” this amended rule and will be seeking additional public feedback and gathering 

more information on the final standards. The US EPA will accept additional data and information on the standard until July 15, 

2011. This reconsideration delays the effective dates of the rule until such time as judicial review is no longer pending or until 

US EPA completes its reconsideration of the rules, whichever is earlier. It is uncertain at this time what changes will be made. 

Therefore specific NESHAP requirements are not included in this permit. When US EPA’s reconsideration of this NESHAP is 

complete or judicial review is no longer pending, whichever is earlier, the permittee will be required to comply with all 

applicable requirements by the established compliance dates and this operation permit will be revised to incorporate the 

applicable emission limitations, work practice and other requirements.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 141

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – Installed 11/2001

Pollutant: 1. Particulate Matter (PM/PM10)

a. Limitations:

(1) Emissions may not exceed:

(a) 0.15 pound per million Btu heat input; and

(b) 0.80 pound per hour.97

[s. NR 415.06(2)(a), Wis. Adm. Code, ss. 285.63(1)(b) and 285.65(3) and (7), Wis. Stats., and 04-RV-128]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this aux 

boiler.98 [s. NR 407.09(4)(a), Wis. Adm. Code and ss. 

285.65(3) and 285.63(1)(a), Wis. Stats. and 04-RV-128]

(2) The permittee shall demonstrate compliance with the 

applicable PM/PM10 hourly emission limit by using fuel 

consumption records and an emission factor 3.3 lbs/mmcuft 

or an alternative department approved emission factor. [s. NR 

407.09(4)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

04-RV-128]

(1) Reference Test Method for Particulate Matter: Whenever 

particulate matter emission testing is required, the permittee 

shall use US EPA Method 5, 5A, 5B, 5D, 5E, 5F, 5G, 5H, 5I 

or 17 including condensable backhalf emissions (U.S. EPA 

Method 202) or any other method approved by the 

Department in writing. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall record and maintain records of the 

type and amount of each fuel combusted during each calendar 

month.99 [s. NR 440.13(9), Wis. Adm. Code and 04-RV-128]

(3) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code. and 04-RV-128]

 97 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no 

ambient air quality standards would be violated when operated as proposed.

98 Because the emission limitation listed in I.G.1.a.(1)(b) is greater than the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the particulate matter emission limit. Maximum 

theoretical particulate matter emissions were calculated using an emission factor of 3.3 pounds per million cubic feet of natural 

gas fired from a stack test conducted on January 9, 2002.

99 Since the boiler will only burn natural gas, the daily record keeping requirements of s. NR 440.207(9)(g), Wis. Adm. Code, 

are unnecessary, because the unit is not subject to any of the emission related requirements of the New Source Performance 

Standard. Thus, the daily record keeping requirements are waived per US EPA guidance and replaced with requirements to 

record monthly fuel use
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 142

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 2. Nitrogen Oxides Emissions (NOx)

a. Limitations:

(1) 1.67 pounds per hour.100 [ss. 285.63(1)(b) and s. 285.65(3) and (7), Wis. Stats. and 04-RV-128]

(2) The permittee may not fire more than 152 million cubic feet of natural gas in the aux boiler in any 12 consecutive 

months.101 [ss. 285.65(3) and (7), Wis. Stats. and 04-RV-128]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this aux 

boiler.102 [s. NR 407.09(4)(a), Wis. Adm. Code and s. 

285.65(3), Wis. Stats. and 04-RV-128]

(2) To demonstrate compliance status with condition 

I.G.2.a.(2) the permittee shall keep the records required 

by I.G.2.c.(2). [s. NR 407.09(4)(a), Wis. Adm. Code 

and s. 285.65(3), Wis. Stats. and 04-RV-128]

(3) The permittee shall demonstrate compliance with 

the applicable NOx hourly emission limit by using fuel 

consumption records and an emission factor of 27.4 

lbs/mmcuft or an alternative department approved 

emission factor AP-42 emission factor. [s. NR 

407.09(4)(a), Wis. Adm. Code and s. 285.65(3), Wis. 

Stats. and 04-RV-128]

(4) The permittee shall perform annual inspections of 

the boiler to ensure optimum performance. Items to be 

inspected include, but are not limited to:

(a) Firebox for signs of leakage,

(b) Boiler tubes for indications of fouling,

(c) Water drum for corrosive/scale and metal fatigue,

(d) Burner for corrosion/erosion,

(e) Refractory throat and throat gasket,

(f) Windbox for cleanliness and damper movement,

(g) Gas supply strainer,

(h) Gas pilot electrode,

(i) Flame scanner.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and 

(10), Wis. Stats. and 04-RV-128]

(1) Reference Test Methods for Nitrogen Oxides Emissions: 

Whenever nitrogen oxide emission testing is required, the permittee 

shall use U.S. EPA Method 7, 7A, 7B, 7C, 7D, or 7E or any other 

method approved by the Department in writing.[s. NR 439.06(6)(a), 

Wis. Adm. Code]

(2) The permittee shall maintain monthly records of the following:

(a) The amount of natural gas fired in boiler B22 in mmcuft per 

month;

(b) The total amount of natural gas fired in boiler B22 in each 12 

consecutive month period (in mmcuft). The 12-month rolling fuel 

use total shall be calculated within 10 business days after the end of 

each calendar month. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 04-RV-128]

(3) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural gas. [s. 

NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 04-

RV-128]

(4) The permittee shall retain copies of the equipment manufacturer 

information for the boiler. [s. NR 439.04(1)(d), Wis. Adm. Code]

(5) The permittee shall keep records of:

(a) the date, time, and initials of the person(s) performing the 

inspections required by I.G.2.b.(4);

(b) a list of the items inspected;

(c) observations/descriptions for each item inspected;

(d) any maintenance or repairs performed as a result of these 

inspections;

(e) the date, time, and initials of the person(s) performing the 

reviews required by I.G.2.b.(5);

(f) a list of the items reviewed;

(g) observations/conclusions for each item reviewed;

(h) any maintenance, repairs or adjustments made as a result of the 

review.

[s. NR 439.04(1)(d), Wis. Adm. Code]

 100 This limit is established in the permit because the source was reviewed with this emission rate and it was determined that no ambient air 

quality standards would be violated when operated as proposed.

101 This restriction is established so that the NOx emissions are not subject to PSD BACT emission limits under s. NR 405.08, Wis. Adm. 

Code.

102 Because the emission limitation listed in I.G.2.a.(1)(b) is greater than the maximum theoretical emissions while firing natural gas, limiting 

the type of fuel used is adequate to demonstrate compliance with the nitrogen oxides emission limit. Maximum theoretical nitrogen oxides 

emissions were calculated using an emission factor of 27.4 pounds per million cubic feet of natural gas fired from a stack test conducted on 

January 9, 2002.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 143

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 2. Nitrogen Oxides Emissions (NOx) – (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(5) The permittee shall perform boiler performance reviews to 

ensure optimum performance. Each performance review shall 

be conducted within 90 days of when the unit combusts 152 

million cubic feet of natural gas following the previous 

performance review. Items to be reviewed include, but are not 

limited to:

(a) Flame pattern: adjust burner as necessary to optimize the 

flame pattern consistent with the manufacturer’s specifications;

(b) Inspect the system controlling the air-to-fuel ratio and 

ensure it is calibrated correctly;

(c) Optimize total emissions of carbon monoxide consistent 

with the manufacturer’s specifications; and

(d) Measure carbon monoxide concentration in the effluent 

stream before and after the adjustments are made.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and (10), Wis. 

Stats. and 04-RV-128]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 144

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 3. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.103 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.05, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this aux 

boiler.104 [s. NR 407.09(4)(a), Wis. Adm. Code and ss. 

285.65(3) and 285.63(1)(a), Wis. Stats. and 04-RV-128]

(1) Whenever visible emission testing is required, the 

permittee shall use U.S. EPA Method 9 or any other method 

approved by the Department in writing. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 04-RV-128]

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 4. Sulfur dioxide (SO2)

a. Limitations:

(1) 0.05 pound per hour.105 [ss. 285.63(1)(b) and 285.65(3) and (7), Wis. Stats. and 04-RV-128]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler.106 

[s. NR 407.09(4)(a), Wis. Adm. Code and ss. 285.65(3) and 

285.63(1)(a), Wis. Stats. and 04-RV-128]

(2) The permittee will demonstrate compliance with the 

applicable sulfur dioxide hourly emission limit by using fuel 

consumption records and an AP-42 emission factor of 0.6

lbs/mmcuft or an alternative department approved emission 

factor. [s. 285.65(3), Wis. Stats. and 04-RV-128]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever sulfur dioxide emission testing is required, the 

permittee shall use U.S. EPA Method 6, 6A, 6B, 6C, or 8 or 

any other method approved by the Department in writing.

[s. NR 439.06(2)(a), Wis. Adm. Code]

(2) The permittee shall retain boiler design specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 04-RV-128]

 103 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

104 It is not expected that the visible emission limitation of 20% opacity would be exceeded while firing this fuel. Therefore 

restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.

105 This restrictions is established so that the sulfur dioxide emissions are not subject to PSD BACT emission limits under s. 

NR 405.08, Wis. Adm. Code. Additionally, this limit is established in the permit because the source was reviewed with this 

emission rate and it was determined that no ambient air quality standards would be violated when operated as proposed.

106 Because the emission limitation listed in I.G.4.a.(1) is greater than the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the sulfur dioxide emission limit. Maximum 

theoretical sulfur dioxide emissions were calculated using an emission factor of 0.6 pounds per million cubic feet of natural gas 

fired from AP-42, 5th edition, ch. 1.4.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 145

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 5. Carbon Monoxide (CO)

a. Limitations:

(1) Emissions may not exceed 1.67 pounds per hour.107 [ss. 285.63(1)(b) and s. 285.65(3) and (7), Wis. Stats. and 04-RV-128]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler.108 

[s. NR 407.09(4)(a), Wis. Adm. Code and ss. 285.65(3) and 

285.63(1)(a), Wis. Stats. and 04-RV-128]

(2) The permittee shall demonstrate compliance with the 

applicable CO hourly emission limit by using fuel 

consumption records and an emission factor of 36.1

lbs/mmcuft or an alternative department approved emission 

factor AP-42 emission factor. [s. 285.65(3), Wis. Stats.] 

Permit # 04-RV-128]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever carbon monoxide emission testing is required, the 

permittee shall use U.S. EPA Method 10 or any other method 

approved by the Department in writing. [s. NR 439.06(4), 

Wis. Adm. Code]

(2) The permittee shall retain boiler specifications to 

demonstrate that the boiler is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 04-RV-128]

 107 This restrictions is established so that the carbon monoxide emissions are not subject to PSD BACT emission limits under s. 

NR 405.08, Wis. Adm. Code. Additionally, this limit is established in the permit because the source was reviewed with this 

emission rate and it was determined that no ambient air quality standards would be violated when operated as proposed.

108 Because the emission limitation listed in I.G.5.a.(1) is equal to the maximum theoretical emissions while firing natural gas, 

limiting the type of fuel used is adequate to demonstrate compliance with the carbon monoxide emission limit. Maximum 

theoretical carbon monoxide emissions were calculated using an emission factor of 36.1 pounds per million cubic feet of natural 

gas fired from emission performance date supplied by the boiler manufacturer.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 146

G. Stack S22, Boiler B22 – Weston Unit 3 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler 

Rated at 46.2 mmBtu/hr – (CONTINUED)

Pollutant: 9. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers 

and Process Heaters (40 CFR, Part 63, Subpart DDDDD)

The permittee shall comply with the requirements of this section at such time as judicial review is no longer pending or US 

EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR s. 63.7495(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) The permittee shall comply with the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, as applicable.109 [40 

CFR, Part 63, Subpart DDDDD, s. 285.65(13), Wis. Stats.]

 109 On March 21, 2011, an amended version of EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) 

for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, was published as a final rule in the 

Federal Register (40 CFR Part 63, subpart DDDDD). Under the amended rule, auxilliary boiler B22 is an industrial boiler per 

the definition in 40 CFR s. 63.7575. Because the boiler was constructed prior to June 4, 2010 (B22 constructed 2001), it is 

considered an existing affected source, pursuant to 40 CFR s. 63.7490(d). Boiler B22 burns natural gas and is included in the 

boiler and process heater subcategory “units designed to burn natural gas, refinery gas or other gas 1 fuels” in 40 CFR s. 

63.74999(l). As existing affected source the permittee was required to comply with the requirements of 40 CFR Part 63, 

subpart DDDDD of the amended rule no later than March 21,2014, pursuant to 40 CFR s. 63.7495(b).

However, on May 16, 2011 US EPA “stayed” this amended rule and will be seeking additional public feedback and gathering 

more information on the final standards. The US EPA will accept additional data and information on the standard until July 15, 

2011. This reconsideration delays the effective dates of the rule until such time as judicial review is no longer pending or until 

US EPA completes its reconsideration of the rules, whichever is earlier. It is uncertain at this time what changes will be made. 

Therefore specific NESHAP requirements are not included in this permit. When US EPA’s reconsideration of this NESHAP is 

complete or judicial review is no longer pending, whichever is earlier, the permittee will be required to comply with all 

applicable requirements by the established compliance dates and this operation permit will be revised to incorporate the 

applicable emission limitations, work practice and other requirements.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 147

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – Installed 7/23/2007

Pollutant: 1. Particulate Matter (PM)

a. Limitations:

(1) Emissions may not exceed the Best Available Control Technology (BACT) limitations of:

(a) Emissions may not exceed 0.0075 pound per million Btu when firing natural gas; 

(b) Emissions may not exceed 1.712 pounds per hour when firing natural gas; and

(c) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler. [s. 

NR 407.09(4)(a), Wis. Adm. Code and ss. 285.65(3) and 

285.63(1)(a), Wis. Stats.]

(2) The permittee shall determine the hourly emissions using 

fuel consumption records and emissions factor determined by 

stack testing. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall perform annual inspections of the 

boiler to ensure optimum performance. Items to be inspected 

include, but are not limited to:

(a) Firebox for signs of leakage,

(b) Boiler tubes for indications of fouling,

(c) Water drum for corrosive/scale and metal fatigue,

(d) Burner for corrosion/erosion,

(e) Refractory throat and throat gasket,

(f) Windbox for cleanliness and damper movement,

(g) Gas supply strainer,

(h) Gas pilot electrode,

(i) Flame scanner.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and (10), 

Wis. Stats. and 03-RV-248-R4]

(4) The permittee shall perform annual boiler performance 

reviews to ensure optimum performance. Items to be 

reviewed include, but are not limited to:

(a) Boiler flue gas temperatures,

(b) Boiler outlet steam temperatures,

(c) Furnace pressure,

(d) Air flow,

(e) Fuel flow,

(f) Air preheater performance.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and (10), 

Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions:

Whenever compliance emission testing is required, test 

procedures in 40 CFR 60 and US EPA Method 5, including 

backhalf (Method 202) or an alternate method approved in 

writing by the Department, shall be used to demonstrate 

compliance. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall maintain records of total amount of 

fuel used as required in condition I.H.1.b.(4). [s. 439.04(1)(d), 

Wis. Adm. Code, ss. 285.65(3) and (10), Wis. Stats. and 03-

RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The permittee shall retain copies of the equipment 

manufacturer information for the boiler. [s. NR 439.04(1)(d), 

Wis. Adm. Code]

(5) The permittee shall keep records of:

(a) the date, time, and initials of the person(s) performing the 

inspections required by I.H.1.b.(3);

(b) a list of the items inspected;

(c) observations/descriptions for each item inspected;

(d) any maintenance or repairs performed as a result of these 

inspections;

(e) the date, time, and initials of the person(s) performing the 

reviews required by I.H.1.b.(4);

(f) a list of the items reviewed;

(g) observations/conclusions for each item reviewed;

(h) any maintenance, repairs or adjustments made as a result 

of the review.

[s. NR 439.04(1)(d), Wis. Adm. Code]

(6) The permittee shall maintain the following records:

(a) Daily records of fuel used by the boiler; and

(b) Records of total amount of fuel used by the boiler in any 

12 consecutive months. 

[s. 285.65(3), Wis. Stats. and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 148

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 2. Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Emissions may not exceed the Best Available Control Technology (BACT) limitations of:

(a) Emissions may not exceed 0.0075 pound per million Btu when firing natural gas; 

(b) Emissions may not exceed 1.712 pounds per hour when firing natural gas; and

(c) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4] 

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in this boiler. [s. 

NR 407.09(4)(a), Wis. Adm. Code and ss. 285.65(3) and 

285.63(1)(a), Wis. Stats.]

(2) The permittee shall determine the hourly emissions using 

fuel consumption records and emissions factor determined by 

stack testing. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 5, including backhalf (Method 202) or an alternate 

method approved in writing by the Department, shall be used 

to demonstrate compliance. [s. NR 439.06(1), Wis. Adm. 

Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4) (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 149

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 3. Sulfur Dioxide (SO2)

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions may not exceed 6.0 E-4 pound per million Btu when firing natural gas; 

(b) Emissions may not exceed 0.14 pound per hour when firing natural gas; and

(c) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records an emission factor of 0.6 pound per 

million standard cubic feet, or other emission factor as 

approved in writing by the Department. [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) The permittee shall only fire natural gas in this boiler.110 

[ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 6, 6A or 6C or an alternate method approved in 

writing by the Department, shall be used to demonstrate 

compliance. [s. NR 439.06(2), Wis. Adm. Code]

(2) The permittee shall keep retain plans and specifications 

that indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 110 This condition is established to meet the BACT emission limit. Because the emission limitations listed in I.H.3.a.(1) are 

equal to the maximum theoretical emissions while firing natural gas, limiting the type of fuel used is adequate to demonstrate 

compliance with the sulfur dioxide emission limit. Maximum theoretical sulfur dioxide emissions were calculated using an 

emission factor of 0.6 pounds per million cubic feet of natural gas fired from AP-42, 5th edition, ch. 1.4.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 150

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 4. Oxides of Nitrogen (NOx)

a. Limitations:

(1) Best Available Control Technology (BACT):111 

(a) Emissions may not exceed 0.10 pound per million Btu (22.9 pounds per hour) when firing natural gas; 

(b) Emissions may not exceed 22.9 pounds per hour when firing natural gas; and

(c) The use of good combustion practices and use of low NOx burners. 

[s. NR 405.08(2), Wis. Adm. Code; s. NR 440.205(5)(a), Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.44b(a)]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only 

fire natural gas in the boiler.112 

[ss. NR 405.08(2) and NR 

407.09(4)(a), Wis. Adm. Code 

and 03-RV-248-R4]

(2) The permittee shall use 

data from the continuous 

monitoring system required by 

I.H.4.c.(6) to demonstrate 

compliance with the emission 

limitations in I.H.4.a.(1). [s. 

NR 407.09(4)(a)1., Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with 

I.H.1.b.(3) and (4) shall also 

be used as compliance 

demonstration requirements 

for this section. [s. NR 

407.09(4)(a), Wis. Adm. 

Code]

(1) Reference Test Method for Nitrogen Oxide Emissions: Whenever compliance emission 

testing is required, test procedures in 40 CFR 60, US EPA Method 7, 7A, 7B, 7C, 7D, or 7E 

or an alternate method approved in writing by the Department shall be used to demonstrate 

compliance. [s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that indicate the boiler’s fuel design 

capabilities. [s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also be used to met the 

requirements of this section. [s. NR 439.04(1), Wis. Adm. Code]

(4) The permittee shall keep manufacturer’s information that shows that low NOx burners 

were installed. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4] 

(5) Continuous Monitoring System Requirements: The permittee shall comply with the 

NSPS emission monitoring requirements per s. NR 440.205(9), Wis. Adm. Code as follows: 

(a) The permittee shall install, calibrate, maintain and operate a continuous monitoring 

system, and record the output of the system for measuring nitrogen oxides emissions to the 

atmosphere. [s. NR 440.205(9)(b), s. 285.65(3), Wis. Stats., 03-RV-248-R4, 40 CFR s. 

60.48b(b)]

(b) The continuous monitoring system shall be operated and data recorded during all periods 

of operation of B25 except for continuous monitoring system breakdowns and repairs. Data 

shall be recorded during calibration checks, and zero and span adjustments. [s. NR 

440.205(9)(c), Wis. Adm. Code, 40 CFR s. 60.48b(c)]

(c) The 1-hour average nitrogen oxides emission rates shall be expressed in pounds per 

mmBtu heat input. The 1-hour average emission rates shall be calculated using the data 

points required under s. NR 440.13, Wis. Adm. Code. At least 2 data points shall be used to 

calculate each 1-hour average. [ss. NR 405.08(2), NR 440.205(5) (i) and NR 440.205(9)(d), 

Wis. Adm. Code, 40 CFR ss. 60.44b(i) and 60.48b(c)] 

(d) The procedures under s. NR 440.13 shall be followed for installation, evaluation, and 

operation of the continuous monitoring system. [s. NR 440.205(9)(e), Wis. Adm. Code, 40 

CFR s. 60.48b(e)]

(e) The span value for nitrogen oxides is 500 ppm or the NOx span values determined 

according to section 2.1.2 in Appendix A to 40 CFR 75.113 [s. NR 440.205(9)(e)2., Wis. 

Adm. Code and 40 CFR 60.486(e)(2)(ii)]

{Continued on Next Page...}

 111 The auxiliary boiler is subject to NSPS for NOx under s. NR 440.205(5)(a), Wis. Adm. Code. For a high heat release rate 

the NSPS limit is 0.20 lb/mmBtu. The proposed BACT limit is more restrictive then the NSPS limit for nitrogen oxides, thus 

the auxiliary boiler is expected to meet the NSPS limit for nitrogen oxides.

112 This condition is established to meet the BACT emission limit.

113 See letter from Andy Seeber of DNR to Randy Oswald of WPSC dated December 5, 2007.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 151

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 4. Oxides of Nitrogen (NOx) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(5) Continuous Monitoring System Requirements: {...Continued from Previous Page...}

(f) When nitrogen oxides emission data are not obtained because of continuous monitoring 

system breakdowns, repairs, calibration checks and zero and span adjustments, emission data 

will be obtained by using standby monitoring systems, Method 7 or 7A of Appendix A, 40 

CFR part 60, or other approved reference methods to provide emission date for a minimum of 

75% of the operating hours in each steam generating unit operating day, in at least 22 out of 

30 successive steam generating unit operating days. [s. NR 440.205(9)(f), Wis. Adm. Code, 

40 CFR s. 60.48b(f)]

(g) When calculating hourly emissions in pounds per million Btu, a minimum concentration 

of 5.0 percent carbon dioxide or a maximum concentration of 14.0 percent oxygen may be 

substituted for the measured diluent gas concentration value for any operating hour in which 

the hourly average carbon dioxide concentration is less than 5.0 percent carbon dioxide or the 

hourly average oxygen concentration is greater than 14.0 percent oxygen, as described in 40 

CFR Part 75 Appendix F Section 3.3.4.1. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(h) The continuous emissions monitoring system shall meet the following minimum 

frequency operating requirements:

(i) Complete a minimum of one cycle of sampling, analyzing and data recording for each 

successive 15-minute period. 

(ii) The values shall be averaged hourly. Hourly averages shall be computed from 4 or 

more data points equally spaced over each 1 hour period, except during periods when 

calibration, quality assurance or maintenance activities are being performed. During 

these periods, a valid hour shall consist of at least 2 data points separated by a minimum 

of 15 minutes.

(iii) Data recorded during periods of continuous monitoring system breakdowns, repairs, 

calibration checks, and zero and span adjustments may not be included in the data 

averages. 

[ss. NR 439.09(9)(b) and NR 440.13(5)(b) and (8), Wis. Adm. Code]

(6) Recordkeeping Requirements: The permittee shall comply with the NSPS 

recordkeeping requirements per s. NR 440.205(10), Wis. Adm. Code, as follows. The 

permittee shall maintain records of the following information for each steam generating unit 

operating day:

(a) Calendar date;

(b)The average hourly nitrogen oxides emission rates (expressed as NO2) (lb/mmBtu heat 

input) measured by the continuous monitoring system;

(c) Identification of the steam generating unit operating hours when the 1-hour average 

nitrogen oxides emission rates are in excess of the nitrogen oxides emissions limitations in 

I.H.4.a.(1);

(d) Identification of the steam generating unit operating hours for which pollutant data have 

not been obtained, including reasons for not obtaining sufficient data and a description of 

corrective actions taken;

(e) Identification of times when emission data have been excluded from the calculation of 

average emission rates and the reason for excluding the data;

(f) Identification of “F” factor used for calculations and the method of determination;

(g) Identification of the times when the pollutant concentration exceeded full span of the 

continuous monitoring system;

(h) Description of any modification to the continuous monitoring system that could affect the 

ability of the continuous monitoring system to comply with Performance Specification 2 or 3 

of Appendix B, 40 CFR part 60; 

(i) Results of daily CEMS drift tests and quarterly accuracy assessments as required under 40 

CFR part 60, Appendix F, Procedure 1; and

(j) The amount of fuel combusted during each day.

[s. NR 440.205(10)(d) and (g) Wis. Adm. Code, 03-RV-248-R4, 40 CFR s. 60.49b(g)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 152

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 4. Oxides of Nitrogen (NOx) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) Records Retention: All records required by I.H.4.c.(6) shall be maintained by the 

permittee for a period of 2 years following the date of the record. [s. NR 440.205(10)(o), 

Wis. Adm. Code, 40 CFR s. 60.49b(o)]

(8) Excess Emission Reporting Requirements: The permittee shall comply with the 

NSPS reporting requirements per s. NR 440.205(10), Wis. Adm. Code, as follows.

(a) The permittee shall submit excess emission reports to the department for any excess 

emissions which occurred during the reporting period.

(b) Excess emissions are defined as any calculated 1 hour average nitrogen oxides 

emissions rate which exceeds the emission limitations in I.H.4.a.(1).

(c) The permittee shall submit reports to the department containing the information 

required under I.H.4.c.(6) or information required by the Department in writing.

(d) The reporting period for the reports required under this section is each 6-month period.

(e) All reports shall be submitted to the department and shall be postmarked by the 30th

day following the end of the calendar quarter.

(f) Electronic Reports: The permittee may submit electronic quarterly reports in lieu of 

submitting written reports as follows:

(i) The format of each quarterly electronic report shall be coordinated with the 

department. 

(ii) The electronic report shall be submitted no later than 30 days after the end of the 

calendar quarter; 

(iii) The electronic report shall be accompanied by a certification statement from the 

permittee, indicating whether compliance with the applicable emission limitations and 

minimum data requirement was achieved during the reporting period. 

(iv) Before submitting reports in electronic format, the permittee shall coordinate with 

the department to obtain agreement to submit reports in this alternative format.

[s. NR 440.205(10)(h), (i), (s), (t), Wis. Adm. Code, 03-RV-248-R4, 40 CFR ss.60.49b(h), 

(i), (s), (t)]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 153

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 5. Carbon Monoxide

a. Limitations:

(1) Emissions may not exceed the Best Available Control Technology (BACT) limitations of:

(a) Emissions may not exceed 0.08 pound per million Btu when firing natural gas; 

(b) Emissions may not exceed 18.4 pounds per hour when firing natural gas; and

(c) Use of good combustion practices and use of low NOx burners.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records and an emission factor of 7.42E-02 

pound per million Btu, or other emission factor as approved in 

writing by the Department [s. 285.65(3), Wis. Stats. and 03-

RV-248-R4]

(2) The permittee shall only fire natural gas in the boiler.114 [ 

ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Carbon Monoxide Emissions:

Whenever compliance emission testing is required, test 

procedures in 40 CFR Part 60, Appendix A, US EPA Method 

10, or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. NR 

439.06(4), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 114 This condition is established to meet the BACT emission limit. Because the emission limitations listed in I.H.5.a.(1) are 

equal to the maximum theoretical emissions while firing natural gas, limiting the type of fuel used is adequate to demonstrate 

compliance with the carbon monoxide emission limit. Maximum theoretical carbon monoxide emissions were calculated using 

an emission factor of 0.0742 pounds per million Btu from emission performance date supplied by the boiler manufacturer.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 154

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 6. Volatile Organic Compounds (VOC)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed 5.4 E-3 pound per million Btu when firing natural gas; 

(b) Emissions may not exceed 1.24 pounds per hour when firing natural gas; and

(c) Use of good combustion practices and use of low NOx burners.

[s. NR 405.08, Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records and an emission factor of 5.5 pound 

per million standard cubic feet, or other emission factor as 

approved in writing by the Department [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) The permittee shall only fire natural gas in the boiler.115 

[ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, test procedures in 40 

CFR Part 60, US EPA Method 25 or 18, or an alternate 

method approved in writing by the Department shall be used 

to demonstrate compliance. [s. NR 439.06(3), Wis. Adm. 

Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 115 This condition is established to meet BACT emission limit. Because the emission limitations listed in I.H.6.a.(1) are equal 

to the maximum theoretical emissions while firing natural gas, limiting the type of fuel used is adequate to demonstrate 

compliance with the volatile organic compound emission limit. Maximum theoretical volatile organic compound emissions 

were calculated using an emission factor of 5.5 pounds per million cubic feet of natural gas fired from AP-42, 5th edition, ch. 

1.4.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 155

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 7. Lead Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed 1.13 E-04 pound per hour when firing natural gas; and

(b) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records and an emission factor of 5.0 E-04 

pound per million standard cubic feet, or other emission factor 

as approved in writing by the Department [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) The permittee shall only fire natural gas in the boiler.116 

[ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Lead Emissions: Whenever 

compliance emission testing is required, US EPA Method 12 

or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 116 This condition is established to meet the BACT emission limit. Because the emission limitation listed in I.H.7.a.(1) is equal 

to the maximum theoretical emissions while firing natural gas, limiting the type of fuel used is adequate to demonstrate 

compliance with the lead emission limit. Maximum theoretical lead emissions were calculated using an emission factor of 

0.0005 pounds per million cubic feet of natural gas fired from AP-42, 5th edition, ch. 1.4
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 156

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 8. Mercury Emissions

a. Limitations:

(1) Emissions may not exceed the Best Available Control Technology (BACT) limitations of:

(a) Emissions may not exceed 5.9 E-5 pound per hour when firing natural gas; and

(b) Use of good combustion practices and firing clean fuel (natural gas). 

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records and an emission factor of 2.6 E-04 

pound per million standard cubic feet, or other emission factor 

as approved in writing by the Department.[s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) The permittee shall only fire natural gas in the boiler.117 

[ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Mercury Emissions:

Whenever compliance emission testing is required, US EPA 

Method 29 or an alternative method approved in writing by 

the department shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 117 This condition is established to meet the BACT emission limit. Because the emission limitation listed in I.H.8.a.(1) is equal 

to the maximum theoretical emissions while firing natural gas, limiting the type of fuel used is adequate to demonstrate 

compliance with the mercury emission limit. Maximum theoretical mercury emissions were calculated using an emission factor 

of 2.6 E-4 pounds per million cubic feet of natural gas fired from AP-42, 5th edition, ch. 1.4
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 157

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 9. Emissions of Fluorides

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed 2.7 E-4 pound per million Btu (6.2 E-2 pound per hour) when firing natural gas; and

(b) Use of good combustion practices and firing clean fuel (natural gas).

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [s. NR 405.08(2), Wis. Adm. Code; ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

fuel consumption records and an emission factor of 0.275 

pound per million standard cubic feet, or other emission factor 

as approved in writing by the Department. [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(2) The permittee shall only fire natural gas in the boiler.118 

[ss. NR 405.08(2) and NR 407.09(4)(a) Wis. Adm. Code and 

03-RV-248-R4]

(3) Compliance with I.H.1.b.(3) and (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Emissions of Fluorides:

Whenever compliance emission testing is required, US EPA 

Method 13B or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2), (4), (5) and (6) shall also 

be used to met the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]

 118 This condition is established to meet the BACT emission limit.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 158

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 10. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.119 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises.

[ss. NR 405.08(2) and NR 431.05, Wis. Adm. Code and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in the boiler.120

[ss. NR 405.08(2) and NR 407.09(4)(a), Wis. Adm. Code and 

03-RV-248-R4]

(1) Reference Test Method for Visible Emissions: Whenever 

compliance emission testing is required, US EPA Method 9 or 

an alternate method approved in writing by the Department, 

shall be used to demonstrate compliance. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

 119 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

120 This condition is established to meet BACT emission limit. It is not expected that the visible emission limitation of 20% 

opacity would be exceeded while firing this fuel. Therefore restricting the type of fuel used is adequate to demonstrate 

compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 159

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 11. Sulfuric Acid Mist (H2SO4)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed 2.1 E-2 pound per hour when firing natural gas; and

(b) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in the boiler.121 

[ss. NR 405.08(2) NR 407.09(4)(a) Wis. Adm. Code and 03-

RV-248-R4]

(2) The permittee shall determine the hourly emissions using 

fuel consumption records, and an emission factor of 0.06 

pound per million standard cubic feet, or other emission factor 

as approved in writing by the Department. [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(3) Compliance with I.H.1.b. (4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(1)(c)1.b., Wis. Adm. Code]

(1) Reference Test Method for Sulfur Acid Mist Emissions:

Whenever compliance emission testing is required, US EPA 

Method 8 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the boiler’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The requirements of I.H.1.c.(2) shall also be used to met 

the requirements of this section. [s. NR 439.04(1), Wis. Adm. 

Code]

 121 This condition is established to meet BACT emission limit.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 160

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 12. Hazardous air pollutants regulated under sec. 112 of the Clean Air Act.

a. Limitations:

(1) 400 ppm Carbon Monoxide by volume on a dry basis corrected to 3% O2, based on a 30-day rolling average, excluding 

periods of monitoring malfunctions, associated repairs, out-of-control periods, required QA/QC activities, or when the boiler is 

operating at less than 50% of its rated capacity.122 [s. 285.65(13), Wis. Stats. and 03-RV-248-R4] 

(2) Total natural gas combusted by the auxiliary boiler may not exceed 450 million standard cubic feet in any 12 consecutive 

months. [s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

The permittee shall comply with the requirements of this section until such time as judicial review is no longer pending or 

US EPA completes its reconsideration of the National Emission Standards for Hazardous Air Pollutants for Industrial, 

Commercial and Institutional Boilers and Process Heaters at Major Sources (40 CFR, Part 63, Subpart DDDDD), 

whichever is earlier. The permitte shall comply with the requirements of section I.H.13., in lieu of this section, at such time 

as judicial review is no longer pending or US EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR 

s. 63.7495(b)]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall operate and maintain a 

continuous emission monitoring system (CEMS) for 

carbon monoxide according to the following 

procedures:

(a) each CEMS shall be operated, and maintained 

according to Performance Specification (PS) 4A of 40 

CFR part 60, appendix B;

(b) the permittee shall conduct a performance 

evaluation of each CEMS according to the 

requirements in §63.8 and according to PS 4A of 40 

CFR part 60, appendix B;

(c) the CEMS must complete a minimum of one cycle 

of operation (sampling, analyzing, and data recording) 

for each successive 15-minute period;

(d) the CEMs data must be reduced as specified in 

§63.8(g)(2);

(e) the permittee shall calculate and record a 30-day 

rolling average emission rate on a daily basis;

(f) the permittee shall not use data recorded during 

periods of monitoring malfunctions, associated repairs, 

out-of-control periods, required QA/QC activities , or 

when the boiler is operating at less than 50% of its 

rated capacity in the calculation for condition 

I.H.12.b.(1)(e). Periods for which the monitoring 

system is out of control and data are not available for 

required calculations, constitutes a deviation from the 

monitoring requirements.

[ s. 285.65(13), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for organic HAPs Emissions; inorganic 

solid HAPs, and inorganic acid HAPs: Whenever compliance 

emission testing is required a method approved in writing by the 

Department shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall maintain the following records:

(a) Daily records of the amount of fuel used in the boiler;

(b) Records of total amount of fuel used in the boiler in any 12 

consecutive months. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall report each instance in which the emission 

limit in H.14.a.(1) was not met. This includes reporting instances 

during startup, shutdown, or malfunction when the applicable 

emission limit was not met. These instances are deviations from the 

emission limits and work practice standards. [s. 285.65(13), Wis. 

Stats. and 03-RV-248-R4] 

(4) The administrator will determine whether deviations that occur 

during a period of startup, shutdown, or malfunction are violations 

according to the provisions in § 63.6(e). [s. 285.65(13), Wis. Stats. 

and 03-RV-248-R4]

(5) The permittee shall submit a Notification of Intent to conduct a 

performance test or evaluation at least 30 days before the 

performance test is scheduled to begin. [s. 285.65(13), Wis. Stats. 

and 03-RV-248-R4]

(6) The permittee shall submit a Notification of Compliance Status 

including all performance evaluation results before the close of 

business on the 60th day following the completion of the 

performance evaluation required under I.H.12.b.(1)(b). [s. 

285.65(13), Wis. Stats. and 03-RV-24-R4]

 122 These case-by-case boiler MACT requirements were established in construction permit 03-RV-248. These case-by-case 

boiler MACT requirements are identical to the MACT for Industrial, Commercial and Institutional Boilers that was signed June 

24, 2004 and later vacated. Removal of the vacated MACT requirements could result in an increase in emissions that may 

require a construction permit.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 161

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 12. Hazardous air pollutants regulated under sec. 112 of the Clean Air Act. - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(7) The semiannual compliance reports required by I.XXX.1.a.(1) shall contain the 

following information as related to hazardous air pollutant emissions from boiler B25:

(a) Company name and address;

(b) Statement by responsible official certifying the truth, accuracy, and completeness of 

the report content;

(c) Date of report and beginning and ending dates of the reporting period;

(d) Type and amount of the total fuel usage;

(e) a summary of the results of performance tests and documentation of any operating 

limits that were reestablished during this test, if applicable;

(f) a signed statement indicating that you burned no new types of fuel;

(g) whether there were any startup, shutdown, or malfunction periods during the reporting 

period and whether the actions taken were consistent with your SSMP. If there were 

startup, shutdown, or malfunctions, the compliance report must include the information in 

§63.10(d)(5)(i);

(h) If there were no deviations from any emission limits, operating limits, or work 

practice standards during the reporting period, a statement that to that affect shall be 

included in the report;

(i) If there were no periods during which the CEM was out of control as specified in 

§63.8(c)(7) during the reporting period, a statement that to that affect shall be included in 

the report. 

[s. 285.65(13), Wis. Stats. and 03RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 162

H. Stack S25, Boiler B25 – Weston Unit 4 Auxiliary Heating Boiler – Natural Gas Fired Auxiliary Boiler Rated at 

229.8 mmBtu/hr – (CONTINUED)

Pollutant: 13. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for Hazardous Air Pollutants for Majors Sources: Industrial, Commercial and Institutional 

Boilers and Process Heaters (40 CFR, Part 63, Subpart DDDDD)

The permittee shall comply with the requirements of this section at such time as judicial review is no longer pending or US 

EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR s. 63.7495(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) The permittee shall comply with the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, as applicable.123 [40 

CFR, Part 63, Subpart DDDDD, s. 285.65(13), Wis. Stats.]

 123 On March 21, 2011, an amended version of EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) 

for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, was published as a final rule in the 

Federal Register (40 CFR Part 63, subpart DDDDD). Under the amended rule, auxilliary boiler B25 is an industrial boiler per 

the definition in 40 CFR s. 63.7575. Because the boiler was constructed prior to June 4, 2010 (B25 constructed 2007), it is 

considered an existing affected source, pursuant to 40 CFR s. 63.7490(d). Boiler B25 burns natural gas and is included in the 

boiler and process heater subcategory “units designed to burn natural gas, refinery gas or other gas 1 fuels” in 40 CFR s. 

63.74999(l). As an existing affected source the permittee was required to comply with the requirements of 40 CFR Part 63, 

subpart DDDDD of the amended rule no later than March 21,2014, pursuant to 40 CFR s. 63.7495(b).

However, on May 16, 2011 US EPA “stayed” this amended rule and will be seeking additional public feedback and gathering 

more information on the final standards. The US EPA will accept additional data and information on the standard until July 15, 

2011. This reconsideration delays the effective dates of the rule until such time as judicial review is no longer pending or until 

US EPA completes its reconsideration of the rules, whichever is earlier. It is uncertain at this time what changes will be made. 

Therefore specific NESHAP requirements are not included in this permit. When US EPA’s reconsideration of this NESHAP is 

complete or judicial review is no longer pending, whichever is earlier, the permittee will be required to comply with all 

applicable requirements by the established compliance dates and this operation permit will be revised to incorporate the 

applicable emission limitations, work practice and other requirements. Until the requirements of the NESHAP for industrial, 

commercial, and institutional boilers and process heaters at major source become affective, the permittee shall comply with the 

case-by-case MACT requirements for hazardous air pollutants regulated by the Clean Air Act established in construction permit 

03-RV-248-R3 and included in section I.H.12. of this permit.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 163

I. Stacks S11AL (lower) and S11AU (upper), Process B11A – B11 – Diesel Startup Engine with Dual Exhaust – Rated 

at 5.8 mmBtu/hr (825 hp) – Installed 1/1969

Stack S11B, Process B11B- B11 – Emergency Black Start Diesel Engine – Rated at 3.0 mmBtu/hr (435 hp) –

Installed 1/1969

Stack S60, Process B60 – Weston Unit 3 Diesel Fire Pump Engine – Rated at 2.6 mmBtu/hr (380 hp) – Installed 

prior to 4/1981

Pollutant: 1. Particulate Matter Emissions (PM) or Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Emissions may not exceed the most restrictive of:

(a) 0.50 pounds per mmBtu heat input; or

(b) (i) 0.40 pounds PM per hour for B11A,

(ii) 0.33 pounds PM10 per hour for B11A,

(ii) 0.71 pounds PM or PM10 per hour for B11B, 

(iii) 0.44 pounds PM or PM10 per hour for B60.124

[s. NR 485.055, Wis. Adm. Code and s. 285.63(1)(b), Wis. Adm. Code]

(2) Each engine shall meet the following operating hour restrictions:

(a) Engine B11A may not be operated more than 100 hours averaged over each 12 consecutive month period.125 

(b) Engine B11B may not be operating more than 200 hours averaged over each 12 consecutive month period.126 

(c) Engine B60 may not be operated more than 200 hours averaged over each 12 consecutive month period.127 

[s. 285.63(1)(b), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire low sulfur 

content distillate fuel oil, with a sulfur content not 

greater than 0.05 percent by weight, in each of the 

engines.128 [ss. NR 407.09(1)(c)1.b., Wis. Adm. 

Code and 285.65(3) and 285.63(1)(a), Wis. Stats.]

(2) To demonstrate compliance with I.I.1.a.(2) the 

permittee shall maintain the records required by 

I.I.1.c.(3). [s. NR 407.09(1)(c)1.b., Wis. Adm.

Code and s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Particulate Matter Emissions: Whenever 

particulate matter emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 5, including backhalf (Method 

202) or any other method approved by the Department in writing. [s. NR 

439.06(1), and (1m) Wis. Adm. Code]

 124 The more restrictive emission limitations in I.I.1.a.(1)(b) are necessary to ensure that the NAAQSs are protected. The 

limitations of 0.40 pounds PM per hour and 0.33 pounds PM10 per hour for B11A are equivalent to the maximum theoretical 

emissions based on emission factors of 0.0697 pounds PM per mmBtu heat input and 0.0573 pounds PM10 per mmBtu heat 

input from AP-42 section 3.4. The limitation of 0.71 pounds per hour for B11B is equivalent to the maximum theoretical 

emissions based on an emission factor of 0.74 g/hp-hr from CARB database. The limitation of 0.44 pounds per hour for B60 is 

equivalent to the maximum theoretical emissions based on an emission factor of 0.53 g/hp-hr from CARB database.

125 The operating hour restriction is necessary to ensure that the annual NAAQSs are protected. This operating hour 

restriction was taken into account when modeling emissions of PM10, SO2, and NOx. Because the operating hours of B11A 

are restricted to less than 100 hours per year, this engine is considered a “limited use stationary RICE”, pursuant to 40 CFR, s. 

63.6675. 

126 The operating hour restriction is necessary to ensure that the annual NAAQSs are protected. This operating hour 

restriction was taken into account when modeling emissions of PM10, SO2, and NOx. 

127 Ibid. (Same as previous footnote.)

128 Because the emission limitations listed in I.I.1.a.(1)(b) are equal to the maximum theoretical emissions while firing 

distillate fuel oil, limiting the type of fuel used is adequate to demonstrate compliance with the particulate matter emission 

limit. Maximum theoretical particulate matter emissions were calculated using the emission factors referenced in footnote 

122.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 164

I. Stacks S11AL (lower) and S11AU (upper), Process B11A – B11 – Diesel Startup Engine with Dual Exhaust – Rated 

at 5.8 mmBtu/hr (825 hp) – Installed 1/1969

Stack S11B, Process B11B- B11 – Emergency Black Start Diesel Engine – Rated at 3.0 mmBtu/hr (435 hp) –

Installed 1/1969

Stack S60, Process B60 – Weston Unit 3 Diesel Fire Pump Engine – Rated at 2.6 mmBtu/hr (380 hp) – Installed 

prior to 4/1981

Pollutant: 1. Particulate Matter Emissions (PM) or Particulate Matter Emissions less than 10 microns (PM10) - 

{CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(3) The compliance demonstration methods of 

condition I.D.3.b.(1) shall also be used as to 

demonstrate compliance with the distillate fuel oil 

sulfur content limitation in I.I.1.b.(1) [s. NR 

407.09(4)(a), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that indicate each 

engine’s fuel usage design capabilities.129 [s. NR 439.04(1)(d), Wis. 

Adm. Code]

(3) The permittee shall maintain monthly records of:

(a) The number of hours of operation for EACH engine; and 

(b) The monthly hours of operation of EACH engine averaged over each 

12 consecutive month period. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(4) The requirements of I.D.3.c.(2) shall also be used to meet the 

recordkeeping requirements to demonstrate compliance with the distillate 

fuel oil sulfur content limitation in I.I.1.b.(1). [s. NR 439.04(1), Wis. 

Adm. Code]

 129 These plans and specifications are sufficient because each engine is designed to only burn distillate fuel oil.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 165

I. Stacks S11AL (lower) and S11AU (upper), Process B11A – B11 – Diesel Startup Engine - (CONTINUED)

Stack S11B, Process B11B- B11 – Emergency Black Start Diesel Engine - (CONTINUED)

Stack S60, Process B60 – Weston Unit 3 Diesel Fire Pump Engine - (CONTINUED)

Pollutant: 2. Visible Emissions (VEs)

a. Limitations:

(1) Visible emissions from B11A and B11B may not exceed 40% opacity or number 2 on the Ringlemann chart, with the 

following exceptions: 

(a) Visible emissions may exceed 40% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.130 

(b) Visible emissions may exceed number 2 of the Ringlemann chart or 40% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.04(1), Wis. Adm. Code]

(2) Visible emissions from B60 may not exceed 20% opacity or number 1 on the Ringlemann chart, with the following 

exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.131 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.05, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire low sulfur content distillate 

fuel oil, with a sulfur content not greater than 0.05 percent by 

weight, in each of the engines.132 [s. NR 407.09(4), Wis. 

Adm. Code and s. 285.65(3), Wis. Stats.]

(2) The compliance demonstration methods of condition 

I.D.3.b.(1) shall also be used as to demonstrate compliance 

with the distillate fuel oil sulfur content limitation in 

I.I.2.b.(1) [s. NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or any other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1., 

Wis. Adm. Code]

(2) The permittee shall retain fuel burner design specifications 

to demonstrate that each engine is solely designed to burn 

distillate fuel oil. [s. 285.65(3), Wis. Stats.]

(3) The requirements of I.D.3.c.(2) shall also be used to meet 

the recordkeeping requirements to demonstrate compliance 

with the distillate fuel oil sulfur content limitation in 

I.I.2.b.(1). [s. NR 439.04(1), Wis. Adm. Code]

 130 When combustion equipment is being cleaned or a new fire started and opacity exceeds 40%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

131 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

132 It is not expected that the visible emission limitations of 20% and 40% opacity would be exceeded while firing this fuel. 

Therefore restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 166

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) – Installed 

9/20/2007

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) – Installed 

12/19/2006

Pollutant: 1. Particulate Matter Emissions (PM) or Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Best Available Control Technology (BACT):133

(a) Emissions from B27 may not exceed 0.42 pound per hour;

(b) Emissions from B28 may not exceed 0.89 pounds per hour;

(c) Use of distillate fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Emissions from B28 may not exceed 0.50 pounds per hour.

134 [s. 285.65(7), Wis. Stats., s. NR 404.08, Wis. Adm. Code]

(3) Hour of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire distillate fuel oil with a maximum 

sulfur content of 0.003% by weight, in each of the engines. [ss. NR 

407.09(1)(c)1.b., Wis. Adm. Code and 285.65(3) and 285.63(1)(a), 

Wis. Stats.]

(2) The permittee shall determine the hourly emissions from each of 

B27 and B28 using fuel consumption and certified test data as 

required by 40 CFR Part 60. [s. 285.65(3), Wis. Stats. and 03-RV248-R4]

(3) The permittee shall fire fuel oil having a maximum sulfur content 

of 0.003% by weight. This condition is established to meet BACT 

emission limit. [s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-

R4]

(4) The permittee shall perform 

(a) Inspections of each engine to ensure optimum performance every 

12 months. Items to be inspected include, but are not limited to:

(i) General condition of the engine,

(ii) Air filter,

(iii) Coolant level,

(iii) Oil (replace/filter/oil level)

(b) Inspections of each engine every 24 months. Items to be 

inspected include, but are not limited to:

(i) Valve Lash,

(ii) Crankcase Breather,

(iii) Fuel system primary and secondary filters,

(c) Inspections of each engines’ fuel injection nozzles every 48 

months.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and (10), Wis. 

Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required, test procedures in 40 CFR 60 and US EPA 

Method 5, including backhalf (Method 202) or an 

alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. 

[s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of 

operation for each of B27 and B28, to demonstrate 

compliance with condition I.J.1.a.(3). [ss. 285.65(3) 

and (10), Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall retain plans and specifications 

that indicate the fuel design capabilities of each of B27 

and B28. [s. NR 439.04(1)(d), Wis. Adm. Code and 

03-RV-248-R4]

(4) The permittee shall retain copies of the equipment 

manufacturer information for each engine. [s. NR 

439.04(1)(d), Wis. Adm. Code]

(5) The permittee shall keep records of:

(a) the date, time, and initials of the person(s) 

performing the inspections required by I.J.1.b.(4);

(b) a list of the items inspected;

(c) observations/descriptions for each item inspected;

(d) any maintenance, repairs or adjustments performed 

as a result of these inspections.

[s. NR 439.04(1)(d), Wis. Adm. Code]

 133 The pound per hour BACT emission limitations also ensure that the NAAQSs are protected. The limitations in 

I.J.1.a.(1)(a) and (b) are equivalent to the maximum theoretical emissions based on an emission factor of 0.31 pounds per 

mmBtu heat input from AP-42 section 3.3.

134 The permittee elected an emission limitation of 0.50 pounds per hour, which is more stringent than the BACT limitation of 

0.89 pounds per hour established in construction permit 03-RV-248-R4. The more stringent limitation was used in dispersion 

modeling to demonstrate that the NAAQSs will be attained and maintained. The decrease in the emission rate is not a 

modification and is not subject to construction permit requirements pursuant to chs. NR 405, 406 and 408, Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 167

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2)

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 0.39 pound per hour;

(b) Emissions from B28 may not exceed 0.83 pounds per hour; 

(c) Use of distillate fuel oil having a maximum sulfur content of 0.003% by weight; and 

(d) Use of good combustion practices. (BACT)

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(1) The permittee shall determine the hourly emissions from each of B27 and B28 using 

fuel consumption records, fuel sulfur content and an emission factor of 0.29 pound per 

million Btu, or other emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee shall fire distillate fuel oil having a maximum sulfur content of 

0.003% by weight. This condition is established to meet BACT emission limit. [s. NR 

405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as compliance demonstration 

requirements for this section. [s. NR 407.09(4)(a), Wis. Adm. Code]

(4) The permittee shall use one of the following options to demonstrate compliance with 

condition I.J.2.a.(1)(c): 

(a) A representative sample shall be taken from each fuel lot of fuel oil received. The 

sample shall be analyzed by the permittee for the sulfur content by weight using 

procedures outline in s. NR 439.08(2), Wis. Adm. Code and the analysis shall be 

retained by the permittee for a period of at least five years. 

(b) The Department will accept, in lieu of an analysis on each fuel lot under (a) above, 

an analysis of a representative sample of the fuel lot of distillate fuel oil from which the 

fuel lot was taken. 

[ss. NR 439.04(1)(d) and NR 439.085(4), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(5) The permittee shall retain copies of its distillate fuel oil supplier’s fuel sulfur and 

heat content analyses at the facility for each fuel lot of distillate fuel oil received 

pursuant to 40 CFR 60.334 for a period of five years. 

(6) The permittee shall further obtain certification from the fuel supplier that the 

applicable methods in s. NR 439.08(2), Wis. Adm. Code, were followed, if applicable, 

by the supplier in the preparation of said sulfur and heat content analyses. The fuel lot’s 

quantity of fuel oil shall be included with the copies of these analyses. 

[ss. NR 439.04(1)(d) and NR 439.085(4), Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(1) Reference Test Method for 

Sulfur Dioxide Emissions:

Whenever compliance emission 

testing is required, US EPA Method 

6, 6A or 6C or an alternate method 

approved in writing by the 

Department, shall be used to 

demonstrate compliance. [s. NR 

439.06(2), Wis. Adm. Code]

(2) The permittee shall record the 

monthly hours of operation of each 

of B27 and B28, to demonstrate 

compliance with condition 

I.J.2.a.(2). [ss. 285.65(3) and (10), 

Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall retain plans 

and specifications that indicate the 

fuel design capabilities of each of 

B27 and B28. [s. NR 439.04(1)(d), 

Wis. Adm. Code and 03-RV-248-

R4]

(4) The requirements of I.J.1.c.(4) 

and (5) shall also be used to meet 

the requirements of this section. [s. 

NR 439.04(1), Wis. Adm. Code]

(5) The permittee shall maintain 

records required under condition 

I.J.2.b.(4) – (6). [s. NR 

439.04(1)(d), Wis. Adm. Code and 

03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 168

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx)

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 5.96 pounds per hour (0.60 tpy); 

(b) Emissions from B28 may not exceed 12.66 pounds per hour (1.27 tpy);

(c) Use of distillate fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices and ignition timing retard.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions of 

each of B27 and B28 using fuel consumption records and an 

emission factor of 4.41 pounds per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats.]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code and 03-RV-248-R4]

(1) Reference Test Method for Nitrogen Oxide Emissions:

Whenever compliance emission testing is required, test 

procedures in 40 CFR 60, US EPA Method 7 or an alternate 

method approved in writing by the Department shall be used 

to demonstrate compliance. 

[s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

for each of B27 and B28, to demonstrate compliance with 

condition I.J.3.a.(2). [s. 285.65(10), Wis. Stats.; s. 285.65(3), 

Wis. Stats.]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 169

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 4. Carbon Monoxide (CO)

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 1.28 pounds per hour;

(b) Emissions from B28 may not exceed 2.73 pounds per hour;

(c) Use of fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records and an 

emission factor of 0.95 pound per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03RV-248-R4]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Carbon Monoxide Emissions:

Whenever compliance emission testing is required, US EPA 

Method 10, or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. NR 

439.06(4), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

for each of B27 and B28, to demonstrate compliance with 

condition I.J.4.a.(2). [ss. 285.65(3) and (10), Wis. Stats. and 

03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities for each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 170

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 5. Volatile Organic Compounds (VOC)

a. Limitations:

(1) Best Available Control Technology:

(a) Emissions from B27 may not exceed 0.47 pound per hour;

(b) Emissions from B28 may not exceed 1.00 pounds per hour;

(c) Use of fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices.

[s. NR 405.08, Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records and an 

emission factor of 0.35 pound per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight . [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, test procedures in 40 

CFR Part 60, Appendix A, US EPA Method 25 or 18, or an 

alternate method approved in writing by the Department shall 

be used to demonstrate compliance. [s. NR 439.06(3), Wis. 

Adm. Code]

(2) The permittee shall record the monthly hours of operation 

for each of B27 and B28, to demonstrate compliance with 

condition I.J.5.a.(2). [ss. 285.65(3) and (10), Wis. Stats. and 

03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 171

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 6. Lead Emissions

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 1.22 E -05 pound per hour;

(b) Emissions from B28 may not exceed 2.58 E -05 pounds per hour;

(c) The use of fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) The use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records and an 

emission factor of 9.0 E-06 pound per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Lead Emissions: Whenever 

compliance emission testing is required, US EPA Method 12 

or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(5), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

of each of B27 and B28, to demonstrate compliance with 

condition I.J.6.a.(2). [s. 285.65(10), Wis. Stats.; s. 285.65(3), 

Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities for each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 172

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 7. Mercury Emissions

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 4.06 E-06 pound per hour;

(b) Emissions from B28 may not exceed 8.61 E-06 pounds per hour;

(c) Use of fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records and an 

emission factor of 3.0 E-06 pound per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Mercury Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 29 or an alternative method approved in writing by 

the department shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

of each of B27 and B28, to demonstrate compliance with 

condition I.J.7.a.(2). [ss. 285.65(3) and (10), Wis. Stats. and 

03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 173

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 8. Emissions of Fluorides

a. Limitations:

(1) Best Available Control Technology (BACT):

(a) Emissions from B27 may not exceed 3.66 E-04 pound per hour; 

(b) Emissions from B28 may not exceed 7.76 E-04 pounds per hour;

(c) Use of fuel oil having a maximum sulfur content of 0.003% by weight; and 

(d) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records and an 

emission factor of 3.73 E-05 pound per gallon, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(3) Compliance with I.J.1.b.(4) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Emissions of Fluorides: 

Whenever compliance emission testing is required, US EPA 

Method 13B or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

for each of B27 and B28, to demonstrate compliance with 

condition I.J.8.a.(2). [ss. 285.65(3) and (10), Wis. Stats. and 

03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(4) The requirements of I.J.1.c.(4) and (5) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 174

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 9. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion

equipment may not be cleaned nor a fire started more than 3 times per day.135 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[ss. NR 405.08(2) and NR 431.05, Wis. Adm. Code and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(2) The permittee shall only fire ultra low sulfur content 

distillate fuel oil in each of the engines.136 [s. NR 407.09(4), 

Wis. Adm. Code and s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

compliance emission testing is required, US EPA Method 9 or 

an alternate method approved in writing by the Department, 

shall be used to demonstrate compliance. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

 135 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

136 It is not expected that the visible emission limitation of 20% opacity would be exceeded while firing this fuel. Therefore 

restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 175

J. Stack S27, Process B27 – Weston Unit 4 Diesel Booster Pump Engine – Rated at 1.4 mmBtu/hr (200 hp) –

(CONTINUED)

Stack S28, Process B28 – Weston Unit 4 Main Booster Pump Engine – Rated at 3 mmBtu/hr (430 hp) –

(CONTINUED)

Pollutant: 10. Sulfuric Acid Mist (H2SO4)

a. Limitations:

(1) Best Available Control Technology:

(a) Emissions from B27 may not exceed 6.01E-02 pound per hour;

(b) Emissions from B28 may not exceed 0.127 pounds per hour;

(c) Use of fuel oil having a maximum sulfur content of 0.003% by weight; and

(d) Use of good combustion practices.

[s. NR 405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(2) Hours of operation may not exceed the following in any 12 consecutive month period:

(a) B27: 200 hours; and

(b) B28: 200 hours.

[ss. 285.65(3) and (7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall fire fuel oil having a maximum sulfur 

content of 0.003% by weight. This condition is established to 

meet BACT emission limit. [s. NR 405.08(2), Wis. Adm. 

Code and 03-RV-248-R4]

(2) The permittee shall determine the hourly emissions from 

each of B27 and B28 using fuel consumption records, and an 

emission factor of 2.90 E-02 pound per million Btu, or other 

emission factor as approved in writing by the Department. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Sulfur Acid Mist Emissions:

Whenever compliance emission testing is required, US EPA 

Method 8 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall record the monthly hours of operation 

of each of boilers B27 and B28, to demonstrate compliance 

with condition I.J.10.a.(2). [ss. 285.65(3) and (10), Wis. Stats. 

and 03-RV-248-R4]

(3) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each of B27 and B28. 

[s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(4) The permittee shall maintain the records required under 

condition I.J.2.b.(4) – (6) to demonstrate compliance with the 

sulfur content in the fuel. [s. NR 439.04(1)(d), Wis. Adm. 

Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 176

K. Stack S63, Process B63 – Natural Gas Heater Station #1

Stack S64, Process B64 – Natural Gas Heater Station #2

Stack S69, Process B69 – Rail Car Repair Station Heater – Installed 2005

Stack S70, Process B70 – Rail Car Repair Station Heater – Installed 2005

Pollutant: 1. Particulate Matter Emissions (PM) and Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 1.0 E-02 pounds PM per hour for B63;

(ii) 6.0 E-03 pounds PM10 per hour for B63;

(iii) 1.0 E-02 pounds PM per hour for B64;

(iv) 6.0 E-03 pounds PM10 per hour for B64;

(v) 1.71 E-03 pound PM and PM10 per hour for B69;

(vi) 1.71 E-03 pound PM and PM10 per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 7.6 lbs/mmcuft or alternate data approved 

in writing by the Department to determine the hourly 

emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(3) The permittee shall perform annual inspections of each 

heater to ensure optimum performance. Items to be inspected 

include, but are not limited to:

(a) Burner for proper physical condition and operation,

(b) Air flow (windbox and damper) physical condition,

(c) Flue gas path physical condition.

[s. NR 407.09(1), Wis. Adm. Code, ss. 285.65(3) and (10), 

Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever compliance emission testing is required, test 

procedures in 40 CFR 60 and US EPA Method 5, including 

backhalf (Method 202) or an alternate method approved in 

writing by the Department, shall be used to demonstrate 

compliance. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the fuel design capabilities of each heater. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

(3) The permittee shall retain copies of the equipment 

manufacturer information for the boiler. [s. NR 439.04(1)(d), 

Wis. Adm. Code]

(4) The permittee shall keep records of:

(a) the date, time, and initials of the person(s) performing the 

inspections required by I.K.1.b.(3);

(b) a list of the items inspected;

(c) observations/descriptions for each item inspected;

(d) any maintenance, repairs or adjustments performed as a 

result of these inspections.

[s. NR 439.04(1)(d), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 177

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 2. Sulfur Dioxide (SO2)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 4.0 E-04 pound per hour for B63;

(ii) 4.0 E-04 pounds per hour for B64;

(iii) 1.35 E-04 pound per hour for B69;

(iv) 1.35E-04 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 0.6 lbs/mmcuft or alternate data approved 

in writing by the Department to determine the hourly 

emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(1) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 6, 6A or 6C or an alternate method approved in 

writing by the Department, shall be used to demonstrate 

compliance. [s. NR 439.06(2), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 178

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 3. Oxides of Nitrogen (NOx)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 7.3 E-02 pound per hour for B63;

(ii) 7.3 E-02 pounds per hour for B64;

(iii) 2.25 E-02 pound per hour for B69;

(iv) 2.25 E-02 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 100 lbs/mmcuft or alternate data approved 

in writing by the Department to determine the hourly 

emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(3) Compliance with I.K.1.b.(3) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Nitrogen Oxide Emissions: 

Whenever compliance emission testing is required, test 

procedures in 40 CFR 60, US EPA Method 7 or an alternate 

method approved in writing by the Department shall be used 

to demonstrate compliance. 

[s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 179

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 4. Carbon Monoxide (CO)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 6.0 E-02 pound per hour for B63;

(ii) 6.0 E-02 pounds per hour for B64;

(ii) 1.89 E-02 pound per hour for B69;

(iii) 1.89 E-02 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet the BACT emission limit. 

[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design fuel rate use and an 

emission factor of 84 lbs/mmcuft or alternate data approved in 

writing by the Department to determine the hourly emissions. 

[s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-RV-248-

R4]

(3) Compliance with I.K.1.b.(3) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Carbon Monoxide Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 10, or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. NR 

439.06(4), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 180

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 5. Volatile Organic Compounds (VOC)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 4.0 E-03 pound per hour for B63;

(ii) 4.0 E-03 pounds per hour for B64;

(iii) 1.24 E-03 pound per hour for B69;

(iv) 1.24 E-03 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet the BACT emission limit. 

[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 5.5 lbs/mmcuft or alternate data approved 

in writing by the Department to determine the hourly 

emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(3) Compliance with I.K.1.b.(3) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, test procedures in 40 

CFR Part 60, Appendix A, US EPA Method 25 or 18, or an 

alternate method approved in writing by the Department shall 

be used to demonstrate compliance. [s. NR 439.06(3), Wis. 

Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 181

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 6. Lead Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 3.68E-07 pound per hour for B63;

(ii) 3.68E-07 pounds per hour for B64;

(iii) 1.13 E-07 pound per hour for B69;

(iv) 1.13 E-07 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. 

Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 5 E-04 lbs/mmcuft or alternate data approved 

in writing by the Department to determine the hourly emissions. 

[s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-RV-248-R4]

(3) Compliance with I.K.1.b.(3) shall also be used as 

compliance demonstration requirements for this section. [s. NR 

407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Lead Emissions: Whenever 

compliance emission testing is required, US EPA Method 

12 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. 

NR 439.06(5), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be 

used to meet the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 182

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 7. Mercury Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 1.91E-07 pound per hour for B63;

(ii) 1.91E-07 pounds per hour for B64;

(iii) 5.86 E-08 pound per hour for B69;

(iv) 5.86 E-08 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. 

Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 2.6 E-04 lbs/mmcuft or alternate data 

approved in writing by the Department to determine the hourly 

emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. and 03-

RV-248-R4]

(3) Compliance with I.K.1.b.(3) shall also be used as compliance 

demonstration requirements for this section. [s. NR 407.09(4)(a), 

Wis. Adm. Code]

(1) Reference Test Method for Mercury Emissions: 

Whenever compliance emission testing is required, US 

EPA Method 29 or an alternative method approved in 

writing by the department shall be used to demonstrate 

compliance. [s. NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be 

used to meet the requirements of this section. [s. NR 

439.04(1), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 183

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 8. Emissions of Fluorides

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 2.04E-04 pound per hour for B63;

(ii) 2.04E-04 pounds per hour for B64;

(iii) 6.3 E-05 pound per hour for B69;

(iv) 6.3 E-05 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 0.291 lbs/mmcuft or alternate data 

approved in writing by the Department to determine the 

hourly emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. 

and 03-RV-248-R4]

(3) Compliance with I.K.1.b.(3) shall also be used as 

compliance demonstration requirements for this section. [s. 

NR 407.09(4)(a), Wis. Adm. Code]

(1) Reference Test Method for Emissions of Fluorides: 

Whenever compliance emission testing is required, US EPA 

Method 13B or an alternate method approved in writing by 

the Department, shall be used to demonstrate compliance. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4] 

(3) The requirements of I.K.1.c.(3) and (4) shall also be used 

to meet the requirements of this section. [s. NR 439.04(1), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 184

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 9. Visible Emissions

a. Limitations:

(1) 20% opacity or number 1 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 20% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.137 

(b) Visible emissions may exceed number 1 of the Ringlemann chart or 20% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[ss. NR 405.08(2) and NR 431.05, Wis. Adm. Code and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall fire natural gas. This condition is 

established to meet BACT emission limit.

138 [s. NR 

405.08(2), Wis. Adm. Code and 03-RV-248-R4]

(1) Reference Test Method for Visible Emissions: Whenever 

compliance emission testing is required, US EPA Method 9 or 

an alternate method approved in writing by the Department, 

shall be used to demonstrate compliance. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate the process’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]

 137 When combustion equipment is being cleaned or a new fire started and opacity exceeds 20%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

138 It is not expected that the visible emission limitation of 20% opacity would be exceeded while firing this fuel. Therefore 

restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 185

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 10. Sulfuric Acid Mist (H2SO4)

a. Limitations:

(1) Best Available Control Technology (BACT): 

(a) Emissions may not exceed:

(i) 6.75 E-05 pound per hour for B63;

(ii) 6.75 E-05 pounds per hour for B64;

(iii) 2.07 E-05 pound per hour for B69;

(iv) 2.07 E-05 pound per hour for B70.

(b) The permittee shall only fire natural gas in processes B63, B64, B69, and B70.

[s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The facility shall fire natural gas in these heaters. This 

condition is established to meet BACT emission limit. [ss. 

285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4] 

(2) The permittee shall use the design rate for fuel use and an 

emission factor of 9.64 E-02 lbs/mmcuft or alternate data 

approved in writing by the Department to determine the 

hourly emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats. 

and 03-RV-248-R4]

(1) Reference Test Method for Sulfur Acid Mist Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 8 or an alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. [s. NR 

439.06(8), Wis. Adm. Code]

(2) The permittee shall retain plans and specifications that 

indicate these heater’s fuel design capabilities. [s. NR 

439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 186

K. Stack S63, Process B63 – Natural Gas Heater Station #1 - (CONTINUED)

Stack S64, Process B64 – Natural Gas Heater Station #2 – (CONTINUED)

Stack S69, Process B69 – Rail Car Repair Station Heater – (CONTINUED)

Stack S70, Process B70 – Rail Car Repair Station Heater – (CONTINUED)

Pollutant: 11. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers and Process 

Heaters at Major Sources (40 CFR, Part 63, Subpart DDDDD)

The permittee shall comply with the requirements of this section at such time as judicial review is no longer pending or US 

EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR s. 63.7495(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) The permittee shall comply with the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, as applicable.139 [40 

CFR, Part 63, Subpart DDDDD, s. 285.65(13), Wis. Stats.]

 139 On March 21, 2011, an amended version of EPA’s National Emission Standard for Hazardous Air Pollutants 

(NESHAP) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, was 

published as a final rule in the Federal Register (40 CFR Part 63, subpart DDDDD). Under the amended rule, 

natural gas heaters B69 and B70 were not considered “process heaters” pursuant to the definition in 40 CFR s. 

63.7575, because the units are used for comfort heat and/or space heat.

Under the amended rule, natural gas heaters B63 and B64 are “process heaters” per the definition in 40 CFR s. 

63.7575. Because each of these process heaters were constructed prior to June 4, 2010, they are considered existing 

affected sources, pursuant to 40 CFR s. 63.7490(d). Each heater burns natural gas and is included in the boiler and 

process heater subcategory “units designed to burn natural gas, refinery gas or other gas 1 fuels” in 40 CFR s. 

63.74999(l). Each of process heaters B63 and B64 have a heat input capacity less than 10 million Btu per hour 

(each rated at 0.73 million Btu per hour), As existing affected sources they were required to comply with the 

requirements of 40 CFR Part 63, subpart DDDDD of the amended rule no later than March 21,2014, pursuant to 40 

CFR s. 63.7495(b).

However, on May 16, 2011 US EPA “stayed” this amended rule and will be seeking additional public feedback and 

gathering more information on the final standards. The US EPA will accept additional data and information on the 

standard until July 15, 2011. This reconsideration delays the effective dates of the rule until such time as judicial 

review is no longer pending or until US EPA completes its reconsideration of the rules, whichever is earlier. 

Because the NESHAP requirements for industrial, commercial, and institutional boilers and process heaters at major 

sources may change significantly, they are not included in the draft permit. When US EPA’s reconsideration of this 

NESHAP is complete or judicial review is no longer pending, whichever is earlier, the permittee will be required to 

comply with all applicable requirements by the established compliance dates and this operation permit would be 

revised to incorporate the applicable emission limitations, work practice and other requirements.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 187

L. Stack S67, Process B67 – North Natural Gas Station Heater for Natural Gas Supply System – Rated at 1.5 

mmBtu/hr – Installed 1960

Stack S68, Process B68 – South Natural Gas Station Heater for Natural Gas Supply System – Rated at 1.5 

mmBtu/hr – Installed 1960

Pollutant: 1. Particulate Matter Emissions

a. Limitations:

(1) Emissions from EACH heater may not exceed the most restrictive of the following:140

(a) 0.60 pounds per mmBtu; or

(b) 0.01 pounds per hour.

[s. NR 415.06(1)(a), Wis. Adm. Code, s. 285.63(1)(b), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in these 

heaters.141 [ss. NR 407.09(1)(c)1.b., Wis. Adm. Code and ss. 

285.65(3) and 285.63(1)(a), Wis. Stats.]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever particulate matter emission testing is required, the 

permittee shall use US EPA Method 5, 5A, 5B, 5D, 5E, 5F, 

5G, 5H, 5I or 17 including condensable backhalf emissions 

(U.S. EPA Method 202) or any other method approved by the 

Department in writing. [s. NR 439.06(1), and (1m) Wis. Adm. 

Code]

(2) The permittee shall retain design specifications to 

demonstrate that each heater is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code]

 140 The more restrictive limitation of 0.01 pounds per hour is necessary to ensure that the NAAQSs are attained and 

maintained.

141 Because the emission limitation listed in I.L.1.a.(1)(b) is equal to the maximum theoretical emissions while firing natural 

gas, limiting the type of fuel used is adequate to demonstrate compliance with the particulate matter emission limit. Maximum 

theoretical particulate matter emissions were calculated using an emission factor of 7.6 pounds per million cubic feet of natural 

gas fired from AP-42, 5th edition, ch. 1.4.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 188

L. Stack S67, Process B67 – North Natural Gas Station Heater for Natural Gas Supply System – (CONTINUED)

Stack S68, Process B68 – South Natural Gas Station Heater for Natural Gas Supply System – (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) 40% opacity or number 2 on the Ringlemann chart, with the following exceptions: 

(a) Visible emissions may exceed 40% opacity when combustion equipment is being cleaned or a new fire started, emissions 

may not exceed number 4 of the Ringlemann chart or 80% opacity for more than 6 minutes in any one hour. Combustion 

equipment may not be cleaned nor a fire started more than 3 times per day.142 

(b) Visible emissions may exceed number 2 of the Ringlemann chart or 40% opacity for stated periods of time, as permitted by 

the department, for such purpose as an operating test, use of emergency equipment or other good cause, provided no hazard 

or unsafe condition arises. 

[s. NR 431.04(1), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall only fire natural gas in these 

heaters.143 [ss. NR 407.09(1)(c)1.b., Wis. Adm. Code and ss. 

285.65(3) and 285.63(1)(a), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required, the permittee shall use 

U.S. EPA Method 9 or any other method approved by the 

Department in writing. [s. NR 439.06(9)(a)1., Wis. Adm. 

Code] 

(2) The permittee shall retain design specifications to 

demonstrate that each heater is solely designed to burn natural 

gas. [s. NR 439.04(1)(d), Wis. Adm. Code]

 142 When combustion equipment is being cleaned or a new fire started and opacity exceeds 40%, one 6-minute exceedance per 

hour may be exempt, but no more than 3 exemptions per day are allowed. This provision does not restrict the number of 

cleanings or the number of fires that may be started in any day, only the number of exemptions that are allowed in any one day.

143 It is not expected that the visible emission limitation of 40% opacity would be exceeded while firing this fuel. Therefore 

restricting the type of fuel used is adequate to demonstrate compliance with the visible emission limitation.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 189

L. Stack S67, Process B67 – North Natural Gas Station Heater for Natural Gas Supply System – (CONTINUED)

Stack S68, Process B68 – South Natural Gas Station Heater for Natural Gas Supply System – (CONTINUED)

Pollutant: 3. Hazardous Air Pollutants Regulated by the Clean Air Act:

National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers and Process 

Heaters at Major Sources (40 CFR, Part 63, Subpart DDDDD)

The permittee shall comply with the requirements of this section at such time as judicial review is no longer pending or US 

EPA completes its reconsideration of the rules, whichever is earlier. [40 CFR s. 63.7495(b), s. 285.65(13), Wis. Stats.]

a. Limitations:

(1) The permittee shall comply with the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, as applicable.144 [40 

CFR, Part 63, Subpart DDDDD, s. 285.65(13), Wis. Stats.]

 144 On March 21, 2011, an amended version of EPA’s National Emission Standard for Hazardous Air Pollutants 

(NESHAP) for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources, was 

published as a final rule in the Federal Register (40 CFR Part 63, subpart DDDDD). Under the amended rule, 

natural gas heaters B67, and B68 are “process heaters” per the definition in 40 CFR s. 63.7575. Because each of 

these process heaters were constructed prior to June 4, 2010, they are considered existing affected sources, pursuant 

to 40 CFR s. 63.7490(d). Each heater burns natural gas and is included in the boiler and process heater subcategory 

“units designed to burn natural gas, refinery gas or other gas 1 fuels” in 40 CFR s. 63.74999(l). Each of process 

heaters B67, and B68 have a heat input capacity less than 10 million Btu per hour (each rated at 1.5 million Btus per 

hour). As existing affected sources they were required to comply with the requirements of 40 CFR Part 63, subpart 

DDDDD of the amended rule no later than March 21,2014, pursuant to 40 CFR s. 63.7495(b).

However, on May 16, 2011 US EPA “stayed” this amended rule and will be seeking additional public feedback and 

gathering more information on the final standards. The US EPA will accept additional data and information on the 

standard until July 15, 2011. This reconsideration delays the effective dates of the rule until such time as judicial 

review is no longer pending or until US EPA completes its reconsideration of the rules, whichever is earlier. 

Because the NESHAP requirements for industrial, commercial, and institutional boilers and process heaters at major 

sources may change significantly, they are not included in the draft permit. When US EPA’s reconsideration of this 

NESHAP is complete or judicial review is no longer pending, whichever is earlier, the permittee will be required to 

comply with all applicable requirements by the established compliance dates and this operation permit would be 

revised to incorporate the applicable emission limitations, work practice and other requirements.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 190

M. Stack S24, Process P24 – Weston Unit 3 Cooling Tower – Installed 1978

Pollutant: 1. Chromium

a. Limitations:

(1) No owner or operator of an exiting industrial process cooling tower may use chromium based water treatment chemicals in 

industrial process cooling tower on or after March 8, 1996. [s. NR 468.30(3)(a), Wis. Adm. Code, s. 285.65(3), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall retain copies of the material safety 

data sheets (MSDS) of all the chemical used to treat water in 

the cooling tower. These records shall be used to show 

compliance with the limit in I.M.1.a.(1). [ss. NR 

407.09(1)(c)1.b., Wis. Adm. Code and ss. 285.65(3) and 

285.63(1)(a), Wis. Stats.]

(1) Reference Test Method for Chromium Emissions: 

Whenever chromium emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 0013 

or other method approved by the Department in writing. [s. 

NR 439.06(8), Wis. Adm. Code]

(2) The permittee shall retain copies of all the MSDS of the 

treatment chemicals used at the facility. [s. NR 439.04(1)(d), 

Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 191

N. Stack S26, Process P26 – Weston Unit 4 Cooling Tower – Installed 9/24/2007

Pollutant: 1. Particulate Matter Emissions (PM)

a. Limitations:

(1) The permittee shall apply Best Available Control Technology (BACT) as follows:

(a) The use of high efficiency drift eliminators that will control drift to 0.0005%; and 

(b) Total hourly emissions may not exceed 1.14 pounds per hour. 

[s. NR 405.08(2), Wis. Adm. Code and ss. 285.65(3) and (7), Wis. Stats., 03-RV-248-R4]

(2) No owner or operator of a new industrial process cooling tower may use chromium-based water treatment chemicals in 

industrial process cooling tower on or after September 8, 1994. [s. NR 468.30(3)(b), Wis. Adm. Code, s. 285.65(3), Wis. 

Stats., 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall monitor and record the water usage 

and the hours the cooling tower is operated on a daily basis. 

[ss. 285.65(3) and 285.65(10), Wis. Stats. and 03-RV-248-

R4]

(2) The permittee shall demonstrate compliance with the 

BACT for PM/PM10 emission rate by operating the cooling 

tower and drift eliminators in accordance with the 

manufacturer’s specifications. [s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(3) The permittee shall retain copies of the material safety 

data sheets (MSDS) of all chemicals used to treat water in the 

cooling tower. These records shall be used to show 

compliance of the limit in I.N.1.a.(c). [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(1) The records required under I.N.1.b.(1) shall be 

maintained for a period of at least five years and shall be 

made available to the Department upon request. [s. NR 

439.04(1)(d) and (2), Wis. Adm. Code and 03-RV-248-R4]

(2) The permittee shall retain copies of all the MSDS of the 

treatment chemicals used at the facility. [s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(3) The permittee shall retain copies of the notification 

required under s. NR 468.30(4)(a) and (b), Wis. Adm. Code at 

the facility for a minimum of 5 years. The notification shall be 

made available to Department staff on request during normal 

business hours. [s. NR 468.30(4)(d), Wis. Adm. Code and 

03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 192

O. Processes P31A, P31B, P31C - Stacks S31A, S31B, S31C - Control Devices C31A, C31B, C31C – Weston Unit 3 

Coal Unloading – Installed 1978 

Enclosed Building (Dumper House) with 2 Baghouses (C31A and C31B)

Junction House Baghouse (C31C)

Processes P32A, P32B, P32C, P32D, P32E - Stacks S32A, S32B, S32C, S32D, S32E - Control Devices C32A, C32B, 

C32C, C32D, C32E – Weston Units 3 & 4 Crusher House – Installed 1978 

Crusher house enclosed and equipped with two baghouses (C32A and C32B), 

Crusher House Agglomerator - Equipped with Baghouse (C32C) 

Coal Storage Silos and Cascade Conveyor - Equipped with Baghouses (C32D and C32E)

Process P34 – Stack S34 - Control Device C34 – Weston Units 1&2 Transport Coal Conveyor #8 - Equipped with 

Baghouse– Installed 1992

Processes P35A, P35B - Stacks S35A, S35B - Control Devices C35A, S35B – Weston Units 1&2: 

Crusher House - Equipped with Baghouse (C35A) – Installed/Last Modified 1995

Conveyor C and Coal Bunker - Equipped with Baghouse (C35B) – Installed/Last Modified 1995

Process P36A, P36B - Stacks S36A, S36B - Control Devices C36A, C36B – Weston Unit 3: 

Fly Ash Transfer & Handling (Baghouse C36A) – Installed/Last Modified 1995

Fly Ash Silo (Baghouse C36B) – Installed/Last Modified 1995

Process P37S, P37B - Stacks S37A, S37B - Control Device C37A, C37B – Weston Units 1 & 2:

Fly Ash Transfer and Handling (Baghouse C37A) – Installed 1962, Last Modified 1996 

Fly Ash Silo (Baghouse C37B) – Installed 1962, Last Modified 1996

Stack S39, Process P39, Control Device C39 – Weston Unit 3 Flyash Storage Building Controlled with Baghouse–

Installed 1993

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations:

(1) Emissions may not exceed the most restrictive of:145

(a) 0.20 pounds per 1000 pounds gas;

(b) E = 17.13 P0.16

where E is the emission limitation in pounds per hour and P is the process weight rate in tons per hour; or

(c) The following rates for each stack:

(i) S31A: 1.75 pounds per hour;

(ii) S31B: 1.75 pounds per hour;

(iii) S31C: 0.49 pounds per hour;

(iv) S32A: 1.09 pounds per hour;

(v) S32B: 1.51 pounds per hour;

(vi) S32C: 0.04 pounds per hour;

(vii) S32D: 1.76 pounds per hour;

(viii) S32E: 2.21 pounds per hour;

(ix) S34: 0.52 pounds per hour;

(x) S35A: 0.53 pounds per hour;

(xi) S35B: 1.03 pounds per hour;

(xii) S36A: 0.38 pounds per hour;

(xiii) S36B: 0.23 pounds per hour;

(xiv) S37A: 0.58 pounds per hour;

(xv) S37B: 0.13 pounds per hour;

(xvi) S39: 0.21 pounds per hour.

[ss. NR 415.05(1)(m) and NR 415.05(2), Wis. Adm. Code, ss. 285.63(1)(b) and 285.65(3), Wis. Stats., 737009020-P10, and 

Stipulation and Order for Judgement, Marathon County Case No. 08-CX-3]

(2) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be 

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code]

 145 The emission limitations listed in I.O.1.a.(1)(c)are necessary to ensure the National Ambient Air Quality Standards for particulate matter

are attained and maintained.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 193

O. Processes P31A, P31B, P31C - Stacks S31A, S31B, S31C - Control Devices C31A, C31B, C31C – Weston Unit 3 Coal 

Unloading – (CONTINUED)

Process P32A, P32B, P32C, P32D, P32E - Stacks S32A, S32B, S32C, S32D, S32E - Control Devices C32A, C32B, 

C32C, C32D, C32E – Weston Units 3 & 4 Crusher House – (CONTINUED) 

Process P34 – Stack S34 - Control Device C34 – Weston Units 1&2 Transport Coal Conveyor #8 - Equipped with 

Baghouse– (CONTINUED)

Process P35A, P35B - Stacks S35A, S35B - Control Devices C35A, S35B – Weston Units 1&2 Crusher House, 

Conveyor C and Coal Bunker – (CONTINUED) 

Process P36A, P36B - Stacks S36A, S36B - Control Devices C36A, C36B – Weston Unit 3 Fly Ash Transfer, 

Handling, and Silo – (CONTINUED)

Process P37A, P37B - Stacks S37A, S37B - Control Device C37A, C37B – Weston Units 1 & 2 Fly Ash Transfer, 

Handling, and Silo

Stack S39, Process P39, Control Device C39 – Weston Unit 3 Flyash Storage Building Controlled with Baghouse–

Installed 1993

Pollutant: 1. Particulate Matter Emissions (PM/PM10) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(1) The permittee shall operate baghouse(s) in a manner that controls particulate 

matter emissions from each process whenever each process is operating, so that the 

emission limitations in condition I.O.1.a.(1) are met. [s. NR 415.04(1)(c), Wis. 

Adm. Code]

(2) The permittee shall perform daily visible inspections of each exhaust stack to 

detect visible emissions. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code]

(3) The permittee shall install and operate a pressure drop monitoring device to 

measure the pressure drop across each baghouse (in water column) [ss. NR 

439.055(1)(a), and (2)(b), Wis. Adm. Code]

(4) The permittee shall operate an alarm system on each baghouse to monitor the 

differential pressure created by each fan, which exhausts emissions from the 

baghouse. An alarm shall be set to alert the operator if the pressure drop is outside 

the associated range specified in condition I.O.1.b.(6)(b). If an alarm occurs, the 

permittee shall take appropriate investigative and corrective action. [s. NR 

407.09(4)(a)3.b., Wis. Adm. Code]

(5) The permittee shall instruct a designated staff person(s) to monitor each process 

for fugitive emissions. Upon detecting any fugitive emissions, the permittee shall 

initiate appropriate investigative and/or corrective actions necessary to prevent 

fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats.]

(6) Compliance Assurance Monitoring (CAM) Requirements: 

Processes P31A, P31B, P31C, P32A, P32B, P32D, P32E, P34, P35A, P35B, P36A, 

P36B, and P37A are each pollutant-specific emissions units for particulate matter 

emissions and are each subject to the CAM requirements of Part 64 CFR. Processes 

P32C, P37B, and P39 are not subject to the CAM requirements of Part 64, CFR, 

however the permittee has elected to comply with these CAM requires for these 

additional processes.146 As such each process is subject to the CAM requirements in 

Part IV and section I.XXX.9. of this permit, and as follows:

{Continued on Next Page...}

(1) Reference Test Method for 

Particulate Matter Emissions: 

Whenever particulate matter emission 

testing is required by the Department, 

the permittee shall use U.S. EPA 

Method 5, including backhalf (Method 

202) or other method approved by the 

Department in writing. [s. NR 

439.06(1), Wis. Adm. Code]

(2) The permittee shall measure and 

record the pressure drop across each 

baghouse (in water column) once every 

8 hours that the associated process is in 

operation, or once per day, whichever 

yields the greater number of 

measurements. [ss. NR 439.055(1)(a), 

and (2)(b), Wis. Adm. Code]

(3) The permittee shall maintain daily 

records of the visual inspections of 

each exhaust stack required by 

I.O.1.b.(2) that include:

(a) the date and time of the inspection;

(b) the initials of the person performing 

the inspection;

(c) the results of the inspection; and

(d) a description of any maintenance or 

repairs performed as a result of the 

inspection. 

[s. NR 439.04(1)(d), Wis. Adm. Code]

 146 Note: Processes P32C, P37B and P39, do not have potential pre-control device particulate matter emissions that are greater than 100 tons 

per year and therefore are not subject to CAM requirements, pursuant to Part 64, CFR. However, the permittee has elected to include these 

emissions units in the CAM Plan for consistency.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 194

O. Processes P31A, P31B, P31C - Stacks S31A, S31B, S31C - Control Devices C31A, C31B, C31C – Weston Unit 3 Coal 

Unloading – (CONTINUED)

Process P32A, P32B, P32C, P32D, P32E - Stacks S32A, S32B, S32C, S32D, S32E - Control Devices C32A, C32B, 

C32C, C32D, C32E – Weston Units 3 & 4 Crusher House – (CONTINUED) 

Process P34 – Stack S34 - Control Device C34 – Weston Units 1&2 Transport Coal Conveyor #8 - Equipped with 

Baghouse– (CONTINUED)

Process P35A, P35B - Stacks S35A, S35B - Control Devices C35A, S35B – Weston Units 1&2 Crusher House, 

Conveyor C and Coal Bunker – (CONTINUED) 

Process P36A, P36B - Stacks S36A, S36B - Control Devices C36A, C36B – Weston Unit 3 Fly Ash Transfer, 

Handling, and Silo – (CONTINUED)

Process P37A, P37B - Stacks S37A, S37B - Control Device C37A, C37B – Weston Units 1 & 2 Fly Ash Transfer, 

Handling, and Silo

Stack S39, Process P39, Control Device C39 – Weston Unit 3 Flyash Storage Building Controlled with Baghouse–

Installed 1993

Pollutant: 1. Particulate Matter Emissions (PM/PM10) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, 

and Monitoring:

(6) Compliance Assurance Monitoring (CAM) Requirements:

{... Continued from Previous Page...}

(a) Whenever a process is operating, the permittee shall monitor differential pressure drop 

across the fabric filter baghouse system as an indicator of control equipment performance;

(b) The indicator range for differential pressure drop across each baghouse controlling a 

process is as follows:

(i) P31A, P31B: 0.5 to 8.5 inches of water

(ii) P31C: 0.5 to 7.0 inches of water

(iii) P32A, B32B, P32C: 0.5 to 7.0 inches of water

(iv) P32D, P32E: 0.5 to 8.5 inches of water

(v) P34: 0.5 to 7.0 inches of water

(vi) P35A, P35B: 0.5 to 7.0 inches of water

(vii) P36A: 1.0 to 35.0 inches of water

(viii) P36B: -1.0 to 7.0 inches of water

(ix) P37A: 0.5 to 25.0 inches of water

(x) P37B: -1.0 to 7.0 inches of water

(xi) P39: 0.5 to 8.0 inches of water

(c) A differential pressure drop reading outside of the applicable indicator range specified in 

condition I.O.1.b.(6)(b) shall trigger a visual inspection of the exhaust stack for any visible 

emissions, as a secondary indicator of compliance.

(d) An excursion is a differential pressure drop reading outside the indicator range in 

condition I.O.1.b.(6)(b) and any visible emissions are noted as a result of the visual 

inspection of the exhaust stack following an alarm;

(e) The permittee shall operate an alarm system on each baghouse to alert the operator if the 

differential pressure drop across any baghouse is outside the applicable range specified in 

condition I.O.1.b.(6)(b). If an alarm occurs, the permittee shall visually inspect the exhaust 

stack for any visible emissions and take appropriate investigative and corrective action.

(f) The quality improvement plan (QIP) threshold is reached when excursions occur for 

more than 5% of each individual process’s operating time in a six month reporting period.

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b. and s. NR 439.055(5), Wis. Adm. 

Code, and 40 CFR ss. 64.2, 64.3, 64.6, 64.7, and 64.8 (except for processes P32C, P37B, 

and P39: s. 285.65(7), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b, Wis. Adm. Code ]

(4) The permittee shall 

maintain records of any 

investigative and corrective 

action taken as a result of a 

differential pressure alarm that 

include:

(a) date and time of the alarm;

(b) date, time, and results of the 

visual inspection of the exhaust 

stack for visible emissions 

required by condition 

I.O.1.b.(6)(c);

(c) a description of the 

investigative actions taken; and 

(d) the type of corrective action 

taken. 

[s. NR 439.04(1)(d), Wis. Adm. 

Code]

(5) The permittee shall 

maintain records of all 

inspections, checks and any 

maintenance or repairs 

performed on the fabric filter 

baghouse systems, including 

the date of the action, initials of 

inspector, and the results. [s. 

NR 439.04(1)(d), Wis. Adm. 

Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 195

O. Processes P31A, P31B, P31C - Stacks S31A, S31B, S31C - Control Devices C31A, C31B, C31C – Weston Unit 3 Coal 

Unloading – (CONTINUED)

Process P32A, P32B, P32C, P32D, P32E - Stacks S32A, S32B, S32C, S32D, S32E - Control Devices C32A, C32B, 

C32C, C32D, C32E – Weston Units 3 & 4 Crusher House – (CONTINUED) 

Process P34 – Stack S34 - Control Device C34 – Weston Units 1&2 Transport Coal Conveyor #8 - Equipped with 

Baghouse– (CONTINUED)

Process P35A, P35B - Stacks S35A, S35B - Control Devices C35A, S35B – Weston Units 1&2 Crusher House, 

Conveyor C and Coal Bunker – (CONTINUED) 

Process P36A, P36B - Stacks S36A, S36B - Control Devices C36A, C36B – Weston Unit 3 Fly Ash Transfer, 

Handling, and Silo – (CONTINUED)

Process P37A, P37B - Stacks S37A, S37B - Control Device C37A, C37B – Weston Units 1 & 2 Fly Ash Transfer, 

Handling, and Silo

Stack S39, Process P39, Control Device C39 – Weston Unit 3 Flyash Storage Building Controlled with Baghouse–

Installed 1993

Pollutant: 2. Visible Emissions

a. Limitations:

(1) 20% opacity number 1 on the Ringlemann chart. [s. NR 431.05, Wis. Adm. Code and for P32A, P32B, P32C, P32D and 

P32E: s. NR 440.42(3)(c), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Same as particulate matter. See I.O.1.b.(1) to (5) above. [s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1., 

Wis. Adm. Code and for P32A, P32B, P32C, P32D, and 

P32E: ss. NR 439.07(8)(f), NR 440.42(5), and NR 

440.42(5)(b)2., Wis, Adm. Code]

(2) Same as particulate matter. See I.O.1.b.(2) to (5) above. [s. 

285.65(3), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 196

P. Process P30 - Stack S30 - Control Device C30 – Weston Unit 4 System 1, New Reclaim Tunnel Exit #34 – Installed 

2/14/2008

Process P41 - Stack S41 – Control Device C41 – Weston Unit 4 System 2, New Junction House 2, #31 – Installed 

3/19/2008

Process P42 - Stack S42 – Control Device C42 – Weston Unit 4 System 3, New Junction House 3, #32 – Installed 

3/19/2008

Process P43 - Stack S43 – Control Device C43 – Weston Unit 4 System 4, Unit 4 Silo Fill System, #7 - Installed 

3/19/2008

Process P44 - Stack S44 – Control Device C44 – Weston Unit 4 System 1, Lime Storage Silo Bin Vent #22 -

Installed 12/13/2007

Process P45 - Stack S45 – Control Device C45 – Weston Unit 4 System 2, Lime Storage Silo Bin Vent #27 -

Installed 12/13/2007 

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.01 grains per dry standard cubic foot of exhaust gas; and 

(b) The following rates for each stack:147

(i) S30: 0.79 pounds per hour;

(ii) S41: 2.59 pounds per hour;

(iii) S42: 0.79 pounds per hour;

(iv) S43: 3.84 pounds per hour;

(v) S44: 0.10 pounds per hour;

(vi) S45: 0.26 pounds per hour

[ss. NR 405.08, NR 415.05(1)(m) and NR 415.05(2), Wis. Adm. Code; ss. 285.63(1)(b) and 285.65(3), Wis. Stats., 03-RV-248-

R4]

(2) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be 

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code, 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall operate baghouse(s) in a manner 

that controls particulate matter emissions from each 

process whenever each process is operating, so that the 

emission limitations in condition I.P.1.a.(1) are met. [s. 

NR 415.04(1)(c), Wis. Adm. Code, 03-RV-248-R4]

(2) The permittee shall perform daily visible inspections 

of each exhaust stack to detect visible emissions. [s. NR 

407.09(4)(a)3.b., Wis. Adm. Code, 03-RV-248-R4]

(3) The permittee shall install and operate a pressure 

drop monitoring device to measure the pressure drop 

across each baghouse (in water column) [ss. NR 

439.055(1)(a), and (2)(b), Wis. Adm. Code, 03-RV-248-

R4]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever particulate matter emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 5, including 

backhalf (Method 202) or other method approved by the 

Department in writing. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall measure and record the pressure drop across 

each baghouse (in water column) once every 8 hours that the 

associated process is in operation, or once per day, whichever 

yields the greater number of measurements. [ss. NR 439.055(1)(a), 

and (2)(b), Wis. Adm. Code, 03-RV-248-R4]

(3) The permittee shall maintain daily records of the visual 

inspections of each exhaust stack required by I.P.1.b.(2) that 

include:

(a) the date and time of the inspection;

(b) the initials of the person performing the inspection;

(c) the results of the inspection; and

(d) a description of any maintenance or repairs performed as a 

result of the inspection. 

[s. NR 439.04(1)(d), Wis. Adm. Code, ] 03-RV-248-R4

 147 The emission limitations listed in I.P.1.a.(1)(b)are necessary to ensure the National Ambient Air Quality Standards for 

particulate matter are attained and maintained.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 197

P. Process P30 - Stack S30 - Control Device C30 – Weston Unit 4 System 1, New Reclaim Tunnel Exit #34 – (CONT’D)

Process P41 - Stack S41 – Control Device C41 – Weston Unit 4 System 2, New Junction House 2, #31 – (CONT’D)

Process P42 - Stack S42 – Control Device C42 – Weston Unit 4 System 3, New Junction House 3, #32 – (CONT’D)

Process P43 - Stack S43 – Control Device C43 – Weston Unit 4 System 4, Unit 4 Silo Fill System, #7 – (CONT’D)

Process P44 - Stack S44 – Control Device C44 – Weston Unit 4 System 1, Lime Storage Silo Bin Vent #22 –

(CONT’D)

Process P45 - Stack S45 – Control Device C45 – Weston Unit 4 System 2, Lime Storage Silo Bin Vent #27 –

(CONT’D) 

Pollutant: 1. Particulate Matter Emissions (PM/PM10) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(4) The permittee shall operate an alarm system on each 

baghouse to monitor the differential pressure created by each 

fan, which exhausts emissions from the baghouse. An alarm 

shall be set to alert the operator if the pressure drop is outside 

the associated range specified in condition I.P.1.b.(6)(b). If 

an alarm occurs, the permittee shall take appropriate 

investigative and corrective action. [s. NR 407.09(4)(a)3.b., 

Wis. Adm. Code, 03-RV-248-R4]

(5) The permittee shall instruct a designated staff person(s) to 

monitor each process for fugitive emissions. Upon detecting 

any fugitive emissions, the permittee shall initiate appropriate 

investigative and/or corrective actions necessary to prevent 

fugitive dust from becoming airborne. [s. 285.65(3), Wis. 

Stats., 03-RV-248-R4]

(6) Compliance Assurance Monitoring (CAM) Requirements: 

Processes P30, P41, P42, P43, and P45 are each pollutantspecific emissions units for particulate matter emissions and 

are each subject to the CAM requirements of Part 64 CFR. 

Process P44 is are not subject to the CAM requirements of 

Part 64, CFR, however the permittee has elected to comply 

with these CAM requires for this additional process.148 As 

such each process is subject to the CAM requirements in Part 

IV and section I.XXX.9. of this permit, and as follows:

(a) Whenever a process is operating, the permittee shall 

monitor differential pressure drop across the fabric filter 

baghouse system as an indicator of control equipment 

performance;

(b) The indicator range for differential pressure drop across 

each baghouse controlling a process is as follows:

(i) P30: 2.0 to 8.0 inches of water

(ii) P41: 2.0 to 8.0 inches of water

(iii) P42: 2.0 to 8.0 inches of water

(iv) P43: 2.0 to 8.0 inches of water

(v) P44: -1.0 to 8.0 inches of water

(vi) P45: -1.0 to 5.5 inches of water

{...Continued on Next Page...}

(4) The permittee shall maintain records of any investigative 

and corrective action taken as a result of a differential 

pressure alarm or fugitive emission observations that include:

(a) date and time of the alarm;

(b) date, time, and results of the visual inspection of the 

exhaust stack for visible emissions required by condition 

I.P.1.b.(6)(c);

(c) a description of the investigative actions taken; and 

(d) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 03-RV-248-R4]

(5) The permittee shall maintain records of all inspections, 

checks and any maintenance or repairs performed on the 

fabric filter baghouse systems, including: 

(a) the date of the action, 

(b) initials of inspector, and 

(c) the results. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 03-RV-248-R4]

 148 Note: Process P44 does not have potential pre-control device particulate matter emissions that are greater than 100 tons per year and 

therefore is not subject to CAM requirements, pursuant to Part 64, CFR. However, the permittee has elected to include this emissions units in 

the CAM Plan for consistency.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 198

P. Process P30 - Stack S30 - Control Device C30 – Weston Unit 4 System 1, New Reclaim Tunnel Exit #34 – (CONT’D)

Process P41 - Stack S41 – Control Device C41 – Weston Unit 4 System 2, New Junction House 2, #31 – (CONT’D)

Process P42 - Stack S42 – Control Device C42 – Weston Unit 4 System 3, New Junction House 3, #32 – (CONT’D)

Process P43 - Stack S43 – Control Device C43 – Weston Unit 4 System 4, Unit 4 Silo Fill System, #7 – (CONT’D)

Process P44 - Stack S44 – Control Device C44 – Weston Unit 4 System 1, Lime Storage Silo Bin Vent #22 –

(CONT’D)

Process P45 - Stack S45 – Control Device C45 – Weston Unit 4 System 2, Lime Storage Silo Bin Vent #27 –

(CONT’D) 

Pollutant: 1. Particulate Matter Emissions (PM/PM10) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(6) Compliance Assurance Monitoring (CAM) Requirements: 

{...Continued from Previous Page...}

(c) A differential pressure drop reading outside of the 

applicable indicator range specified in condition I.P.1.b.(6)(b) 

shall trigger a visual inspection of the exhaust stack for any 

visible emissions, as a secondary indicator of compliance.

(d) An excursion is a differential pressure drop reading 

outside the indicator range in condition I.P.1.b.(6)(b) and any 

visible emissions are noted as a result of the visual inspection 

of the exhaust stack following an alarm;

(e) The permittee shall operate an alarm system on each 

baghouse to alert the operator if the differential pressure drop 

across any baghouse is outside the range applicable range 

specified in conditions I.P.1.b.(6)(b). If an alarm occurs, the 

permittee shall visually inspect the exhaust stack for any 

visible emissions and take appropriate investigative and 

corrective action.

(f) The quality improvement plan (QIP) threshold is reached 

when excursions occur for more than 5% of each individual 

process’s operating time in a six month reporting period.

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b. and 

ss. NR 439.055(1) and (5), Wis. Adm. Code, and 40 CFR ss. 

64.2, 64.3, 64.6, 64.7, and 64.8 (except for process P44: s. 

285.65(7), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b, Wis. 

Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 199

P. Process P30 - Stack S30 - Control Device C30 – Weston Unit 4 System 1, New Reclaim Tunnel Exit #34 – (CONT’D)

Process P41 - Stack S41 – Control Device C41 – Weston Unit 4 System 2, New Junction House 2, #31 – (CONT’D)

Process P42 - Stack S42 – Control Device C42 – Weston Unit 4 System 3, New Junction House 3, #32 – (CONT’D)

Process P43 - Stack S43 – Control Device C43 – Weston Unit 4 System 4, Unit 4 Silo Fill System, #7 – (CONT’D)

Process P44 - Stack S44 – Control Device C44 – Weston Unit 4 System 1, Lime Storage Silo Bin Vent #22 –

(CONT’D)

Process P45 - Stack S45 – Control Device C45 – Weston Unit 4 System 2, Lime Storage Silo Bin Vent #27 –

(CONT’D)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 10% opacity.

[s. NR 431.05, Wis. Adm. Code; s. NR 405.09, Wis. Adm. Code; s. 285.65(3), Wis. Stats., 03-RV-248-R4, and for P30 and 

P43: s. NR 440.42(3)(c), Wis. Adm. Code149]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Same as particulate matter. See I.P.1.b.(1) to (6) above. [s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1., 

Wis. Adm. Code and for P30 and P43: ss. NR 439.07(8)(f), 

NR 440.42(3)(c), and NR 440.42(5)(b)2., Wis. Adm. Code]

(2) Same as particulate matter. See I.P.1.b.(2) to (5) above. [s. 

285.65(3), Wis. Stats.]

 149 Processes P30 and P43 are subject to the New Source Performance Standard for Coal Preparation Plants outlined in s. NR 

440.42, Wis. Adm. Code. Section NR 440.42(3)(c), Wis. Adm. Code prohibits the discharge into the atmosphere from any 

affected coal processing and conveying equipment, coal storage system or coal transfer and loading system processing coal 

gases which exhibit 20% opacity or greater. Because the BACT limitation of 10% opacity is more restrictive than the NSPS 

limitation of 20% opacity, compliance with BACT ensures compliance with the NSPS requirement.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 200

Q. Process P49, Stack S49, Control Device C49 – Weston Unit 4 System 4, FGD Byproduct Recycle Bin Vent, #24 -

Installed 2/11/2008

Process P50, Stack S50, Control Device C50 – Weston Unit 4 System 5, FGD Waste Silo Bin Vent, #20 - Installed 

4/9/2008

Process P65, Stack S65, Control Device C65 – Weston Unit 4 PAC Storage Silo 4A - Installed 1/24/2008

Process P66, Stack S66, Control Device C66 – Weston Unit 4 PAC Storage Silo 4B - Installed 1/24/2008

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.02 grains per dry standard cubic foot of exhaust gas; and 

(b) The following rates for each stack of:150

(i) S49: 0.83 pounds per hour;

(ii) S50: 0.362 pounds per hour;

(iii) S65: 0.21 pounds per hour;

(iv) S66: 0.21 pounds per hour

[ss. NR 405.08, NR 415.05(1)(m) and NR 415.05(2), Wis. Adm. Code; ss. 285.63(1)(b) and 285.65(3), Wis. Stats., 03-RV248-R4]

(2) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code, 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall operate baghouse(s) in a

manner that controls particulate matter emissions 

from each process whenever each process is

operating, so that the emissions limitations in 

condition I.Q.1.a.(1) are met. [s. NR 415.04(1)(c), 

Wis. Adm. Code, 03-RV-248-R4]

(2) The permittee shall perform daily visible 

inspections of each exhaust stack to detect visible 

emissions. [s. NR 407.09(4)(a)3.b., Wis. Adm. Code, 

03-RV-248-R4]

(3) The permittee shall install and operate a pressure 

drop monitoring device to measure the pressure drop 

across each baghouse (in water column) [ss. NR 

439.055(1)(a), and (2)(b), Wis. Adm. Code, 03-RV248-R4]

(4) The permittee shall operate an alarm system on 

each baghouse to monitor the differential pressure 

created by each fan, which exhausts emissions from 

the baghouse. An alarm shall be set to alert the 

operator if the pressure drop is outside the range 

specified in condition I.Q.1.b.(6)(b). If an alarm 

occurs, the permittee shall take appropriate 

investigative and corrective action. [s. NR 

407.09(4)(a)3.b., Wis. Adm. Code, 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever particulate matter emission testing is required by the 

Department, the permittee shall use U.S. EPA Method 5, including 

backhalf (Method 202) or other method approved by the Department 

in writing. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall measure and record the pressure drop across 

each baghouse (in water column) once every 8 hours that the 

associated process is in operation, or once per day, whichever yields 

the greater number of measurements. [ss. NR 439.055(1)(a), and 

(2)(b), Wis. Adm. Code, 03-RV-248-R4]

(3) The permittee shall maintain daily records of the visual 

inspections of each exhaust stack required by I.O.1.b.(2) that include:

(a) the date and time of the inspection;

(b) the initials of the person performing the inspection;

(c) the results of the inspection; and

(d) a description of any maintenance or repairs performed as a result 

of the inspection. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 03-RV-248-R4]

(4) The permittee shall maintain records of any investigative and 

corrective action taken as a result of a differential pressure alarm or 

fugitive emission observations that include:

(a) date and time of the alarm;

(b) date, time, and results of the visual inspection of the exhaust stack 

for visible emissions required by condition I.Q.1.b.(6)(c);

(c) a description of the investigative actions taken; and 

(d) the type of corrective action taken. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 03-RV-248-R4]

 150 The emission limitations listed in I.Q.1.a.(1)(b)are necessary to ensure the National Ambient Air Quality Standards for 

particulate matter are attained and maintained.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 201

Q. Process P49, Stack S49, Control Device C49 – Weston Unit 4 System 4, FGD Byproduct Recycle Bin Vent, #24 -

Installed 2/11/2008

Process P50, Stack S50, Control Device C50 – Weston Unit 4 System 5, FGD Waste Silo Bin Vent, #20 - Installed 

4/9/2008

Process P65, Stack S65, Control Device C65 – Weston Unit 4 PAC Storage Silo 4A - Installed 1/24/2008

Process P66, Stack S66, Control Device C66 – Weston Unit 4 PAC Storage Silo 4B - Installed 1/24/2008

Pollutant: 1. Particulate Matter Emissions (PM/PM10) - (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and 

Monitoring:

(5) The permittee shall instruct a designated staff person(s) to monitor each 

process for fugitive emissions. Upon detecting any fugitive emissions, the 

permittee shall initiate appropriate investigative and/or corrective actions 

necessary to prevent fugitive dust from becoming airborne. [s. 285.65(3), 

Wis. Stats., 03-RV-248-R4]

(6) Compliance Assurance Monitoring (CAM) Requirements: 

Processes P49 and P50 are each pollutant-specific emissions units for 

particulate matter emissions and are each subject to the CAM requirements of 

Part 64 CFR. Processes P65 and P66 are not subject to the CAM 

requirements of Part 64, CFR, however the permittee has elected to comply 

with these CAM requires for these additional processes.151 As such each 

process is subject to the CAM requirements in Part IV and section I.XXX.9. 

of this permit, and as follows:

(a) Whenever a process is operating, the permittee shall monitor differential 

pressure drop across the fabric filter baghouse system as an indicator of 

control equipment performance;

(b) The indicator range for differential pressure drop across each baghouse 

controlling a process is as follows:

(i) P49: -1.0 to 5.5 inches of water

(ii) P59: -1.0 to 8.0 inches of water

(iii) P65: -1.0 to 5.0 inches of water

(iv) P66: -1.0 to 5.0 inches of water

(c) A differential pressure drop reading outside of the applicable indicator 

range specified in condition I.Q.1.b.(6)(b) shall trigger a visual inspection of 

the exhaust stack for any visible emissions, as a secondary indicator of 

compliance.

(d) An excursion is a differential pressure drop reading outside the indicator 

range in condition I.Q.1.b.(6)(b) and any visible emissions are noted as a 

result of the visual inspection of the exhaust stack following an alarm;

(e) The permittee shall operate an alarm system on each baghouse to alert the 

operator if the differential pressure drop across any baghouse is outside the 

range applicable range specified in conditions I.Q.1.b.(6)(b). If an alarm 

occurs, the permittee shall visually inspect the exhaust stack for any visible 

emissions and take appropriate investigative and corrective action.

(f) The quality improvement plan (QIP) threshold is reached when excursions 

occur for more than 5% of each individual process’s operating time in a six 

month reporting period.

[s. 285.65(13), Wis. Stats., ss. NR 407.09(4)(a)1. and 3.b. and s. NR 

439.055(5), Wis. Adm. Code, and 40 CFR ss. 64.2, 64.3, 64.6, 64.7, and 64.8 

(except for processes P32C, P37B, P39, P44, P65, P66: s. 285.65(7), Wis. 

Stats., ss. NR 407.09(4)(a)1. and 3.b, Wis. Adm. Code ]

(5) The permittee shall maintain records of all 

inspections, checks and any maintenance or 

repairs performed on the fabric filter baghouse 

systems, including:

(a) the date of the action, 

(b) initials of inspector, and 

(c) the results. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 03-

RV-248-R4]

 151 Note: Processes P65 and P66 do not have potential pre-control device particulate matter emissions that are greater than 100 tons per year 

and therefore are not subject to CAM requirements, pursuant to Part 64, CFR. However, the permittee has elected to include these emissions 

units in the CAM Plan for consistency.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 202

Q. Process P49, Stack S49, Control Device C49 – Weston Unit 4 System 4, FGD Byproduct Recycle Bin Vent, #24 –

(CONTINUED)

Process P50, Stack S50, Control Device C50 – Weston Unit 4 System 5, FGD Waste Silo Bin Vent, #20 –

(CONTINUED)

Process P65, Stack S65, Control Device C65 – Weston Unit 4 PAC Storage Silo 4A – (CONTINUED)

Process P66, Stack S66, Control Device C66 – Weston Unit 4 PAC Storage Silo 4B – (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) Best Available Control Technology (BACT): 10% opacity.

[s. NR 431.05, Wis. Adm. Code; s. NR 405.09, Wis. Adm. Code; s. 285.65(3), Wis. Stats., 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Same as particulate matter. See I.Q.1.b.(1) to (6) above. [s. 

285.65(3), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or other method 

approved by the Department in writing. [ss. NR 

439.06(9)(a)1. and NR 439.07(8)(f), Wis. Adm. Code]

(2) Same as particulate matter. See I.Q.1.b.(2) to (5) above. [s. 

285.65(3), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 203

R. Process F33 and F56 – Coal Storage and Pile Maintenance

Pollutant: 1. Fugitive Dust (PM/PM10)

a. Limitations:

(1) The permittee may not cause or allow emissions greater than 10% opacity from the coal pile storage area. [ss. NR 405.09 

(F56 only), and NR 415.04, Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) (a) The long term coal storage pile shall be adequately compacted 

to minimize air and water infiltration.

(b) Once compacted, the bulk of the pile shall be left undisturbed 

(inactive). 

(c) All coal slides, loose coal, or other storage pile disturbances shall 

be cleaned up and recompacted as soon as practical.

(d) All peaks, windrows, and edges shall be knocked down, smoothed 

out and recompacted as soon as practical.

[ss. NR 405.08 (F56 only), NR 406.10, NR 415.04(1)(b), Wis. Adm. 

Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) When trained staff observe visible emissions of 10% or more at 

the process, or 5% opacity or more at the property fence line, the 

permittee shall take appropriate actions to control fugitive emissions. 

(e.g. increased watering, increased application of dust suppressants, 

increased street sweeping) [s. NR 407.09(1)(c)1.b., Wis. Adm. Code, 

s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) A surfactant (wet suppression spray and/or surface stabilizing 

agent) or cover material(s), shall be applied to the pile as follows: 

(a) To the active area of the pile at the beginning and end of each 

shift, at stack out and reclaim activity152. (Except when weather 

conditions exist such that precipitation and/or ambient temperature 

would control fugitive emissions); 

(b) To the active area during reclaim activities whenever any visible 

emissions are seen beyond the coal pile boundary; 

(c) To the inactive area of the coal storage pile whenever any visible 

emissions are seen beyond the coal pile boundary; or 

(c) Whenever the Trained Person identified in I.R.1.b.(5) determines 

additional surfactant is needed. 

[ss. NR 405.08 (F56 only), NR 406.10, and NR 415.04(1)(b), Wis. 

Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(4) The permittee shall designate at least one Trained Person to 

monitor compliance with the emission limitation, the requirements of 

this section of the permit, and the measures for preventing particulate 

matter from becoming airborne. [s. NR 407.09(1)(c)1.b., Wis. Adm. 

Code, s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required, the appropriate US EPA Method 9 or an 

alternate method approved in writing by the 

Department, shall be used to demonstrate compliance. 

[s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) For each day of operation the permittee shall 

maintain records of the specific measures taken to 

control fugitive particulate matter emissions. These 

records shall include:

(a) the date;

(b) the signature of the Trained Person identified in 

I.R.1.b.(4); and

(c) a description of the specific measure(s) taken (i.e. 

area to which surfactant (wet suppression spray and/or 

surface stabilizing agent) or cover material was 

applied, and the amount applied).

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV248-R4]

(3) The permittee shall maintain records of the 

inspections required by I.R.1.b.(6). [s. NR 

439.04(1)(d), Wis. Adm. Code]

(4) The permittee shall retain copies of the Method 9 

certification, other training or qualifications, or 

written Department approval of the Trained Person 

identified in I.R.1.b.(4). [s. NR 439.04(1)(d), Wis. 

Adm. Code and 03-RV-248-R4]

 152 When the beginning of a shift and the end of a shift coincide with each other, the permittee need only apply surfactant one 

time.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 204

R. Process F33 and F56 – Coal Storage and Pile Maintenance – (CONTINUED)

Pollutant: 1. Fugitive Dust (PM/PM10) – (CONTINUED)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(5) The permittee shall ensure that the Trained Person identified in 

I.R.1.b.(5) has:

(a) Received training to evaluate compliance with the requirements 

of this section of the permit and the measures for preventing 

particulate matter from becoming airborne, or

(b) Obtained certification as a Method 9 opacity observer in the last 2 

years , or

(c) Attended appropriate training or has other reasonable 

qualifications and has written Department approval to act as the 

Trained Person for the purpose of this permit.

[s. NR 407.09(1)(c)1.b., Wis. Adm. Code, s. 285.65(3), Wis. Stats. 

and 03-RV-248-R4]

(6) The Trained Person identified in I.R.1.b.(5) shall conduct 

inspections of the coal storage pile as follows:

(a) Weekly inspections of the inactive coal storage pile; 

(b) Daily inspections of the active coal pile area, to determine the 

continued effectiveness of the surfactant, whenever coal is reclaimed 

from the pile. [ss. NR 405.08 (F56 only), NR 406.10, NR 

415.04(1)(b), Wis. Adm. Code; s. 285.65(3), Wis. Stats. and 03-RV248-R4]

R. Process F33 and F56 – Coal Storage and Pile Maintenance – (CONTINUED)

Pollutant: 2. * Hazardous Pollutants

a. Limitations:

(1) * The permittee shall comply with the Control and Compliance Requirements for the Handling and Storage of Coal in 

conditions I.XXX.6.a. [s. NR 445.10, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * The permittee shall comply with the Control and Compliance 

Requirements for the Handling and Storage of Coal in conditions 

I.XXX.6.a. [s. NR 445.10, Wis. Adm. Code]

(1) * The permittee shall comply with the Control and 

Compliance Requirements for the Handling and Storage 

of Coal in conditions I.XXX.6.a. [s. NR 445.10, Wis. 

Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 205

S. Process F38 – Bottom and Fly Ash Storage Site

Pollutant: 1. Particulate Matter – Fugitive Dust Emissions

a. Limitations:

(1) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall apply water, wet suppression spray, 

surface stabilizing agent and/or cover material(s) as needed to 

prevent particulate matter from becoming airborne. [s. NR 

415.04(1)(b), Wis. Adm. Code]

(2) Ash shall be hauled offsite in enclosed tanker(s) or in 

trucks. The ash within any open bed of a truck shall be tarped 

when leaving the facility to prevent material from falling off 

and becoming airborne. [s. NR 415.04(1)(b), Wis. Adm. 

Code]

(1) When applying suppressant for dust control, the permittee 

shall record:

(a) the date and time of the application; and

(b) the area(s) at the facility where suppressant is applied. [s. 

NR 439.04(1)(d), Wis. Adm. Code]

S. Process F38 – Bottom and Fly Ash Storage Site – (CONTINUED)

Pollutant: 2. Visible Emissions

a. Limitations:

(1) Fugitive emissions from any outdoor source and building or structure egress other than a stack shall be controlled such that 

visible emissions do not exceed 20% opacity except for 3 minutes in any hour when fugitive emissions may equal 50% opacity. 

[s. NR 415.04(2)(6)1. and (c)2., Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Same as particulate matter. See I.S.1.b.(1) and (2) above. 

[s. NR 407.09(1)(c)1.b., Wis. Adm. Code and s. 285.65(3), 

Wis. Stats.]

(1) Reference Test Method for Visible Emissions: Whenever 

visible emission testing is required by the Department, the 

permittee shall use U.S. EPA Method 9 or other method 

approved by the Department in writing. [s. NR 439.06(9)(a)1., 

Wis. Adm. Code]

(2) Same as particulate matter. See I.S.1.c.(1) above. [s. NR 

439.04(1)(d), Wis. Adm. Code and s. 285.65(3), Wis. Stats.]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 206

T. Stack S40, Process P40 – Conveyor 11 Telescopic Chute #29

Pollutant: 1. Particulate Matter Emissions (PM/PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.484 Pound PM per hour; and 

(b) 0.23 pound PM10 per hour.

[ss. NR 405.08 and NR 415.06(2)(c), Wis. Adm. Code, s. 285.65(3), Wis. Stats., and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall utilize a telescopic chute to meet the 

BACT limits. [s. NR 405.08, Wis. Adm. Code and 03-RV-248-

R4]

(2) The permittee shall determine the hourly emissions using the 

daily throughput and an emission factor of 1.61 E-04 pound per 

ton of coal for PM and 7.63 E-05 pound per ton of coal for PM10 

or other emission factors approved in writing by the 

Department.153. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(3) The permittee shall designate at least one Trained Person to 

monitor compliance with the emission limitation, the requirements 

of this section of the permit, and the measures for preventing 

particulate matter from becoming airborne. [s. NR 

407.09(1)(c)1.b., Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(4) The permittee shall ensure that the Trained Person identified in 

I.T.1.b.(4) meets the training requirements of I.R.1.b.(5). [s. NR 

407.09(1)(c)1.b., Wis. Adm. Code, s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required, the appropriate US EPA Method 9 or an 

alternate method approved in writing by the Department, 

shall be used to demonstrate compliance. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]

(2) For each day of operation the permittee shall 

maintain records of the specific measures taken to control 

fugitive particulate matter emissions. These records shall 

include:

(a) the date;

(b) the signature of the Trained Person identified in 

I.T.1.b.(3)

(c) a description of the specific measure(s) taken (e.g. 

area to which dust suppressant was applied, amount of 

amount of dust suppressant applied)

[s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-

R4]

(3) The permittee shall retain copies of the Method 9 

certification, other training or qualifications, or written 

Department approval of the Trained Person identified in 

I.T.1.b.(3). [s. NR 439.04(1)(d), Wis. Adm. Code and 

03-RV-248-R4]

T. Stack S40, Process P40 – Conveyor 11 Telescopic Chute #29 – (CONTINUED)

Pollutant: 2. * Hazardous Pollutants

a. Limitations:

(1) * The permittee shall comply with the Control and Compliance Requirements for the Handling and Storage of Coal in 

conditions I.XXX.6.a. [s. NR 445.10, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * The permittee shall comply with the Control and Compliance 

Requirements for the Handling and Storage of Coal in conditions 

I.XXX.6.a. [s. NR 445.10, Wis. Adm. Code]

(1) * The permittee shall comply with the Control and 

Compliance Requirements for the Handling and Storage of 

Coal in conditions I.XXX.6.a. [s. NR 445.10, Wis. Adm. 

Code]

 153 Emissions were calculated for P40 based upon a capacity of 3000 tons of coal handled per hour.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 207

U. Process F134 – Facility Haul Roads 

Pollutant: 1. Fugitive Dust (PM/PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): The permittee shall:

(a) Pave haul roads where possible;

(b) Water roadways;

(c) Sweep roadways.

[ss. NR 405.08 and NR 431.05, Wis. Adm. Code; s. 285.65(3), Wis. Stats., and 03-RV-248-R4]

(2) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking 

precautions to prevent particulate matter from becoming airborne. Those precautions shall include, but not be limited to, the 

following:

(a) The measures specified in 1.a.(1) above, and

(b) Covering, securing, or wetting materials transported by truck(s) to prevent material from falling off and from becoming 

airborne.

[s. NR 415.04, Wis. Adm. Code, Permit # 10-MHR-184-R1]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) All facility haul roads that lead to active piles shall be 

paved. [s. NR 405.08, Wis. Adm. Code, Permit #s 03-RV248-R4, and 10-MHR-184]

(2) All other facility haul roads that do not lead to active piles 

shall be paved where possible to meet the BACT limits. [s. 

NR 405.08, Wis. Adm. Code and Permit #s 03-RV-248-R4 

and 10-MHR-184]

(3) All facility haul roads shall be swept, at minimum, daily 

(except when weather conditions exist such that precipitation 

and/or ambient temperature would control fugitive emissions 

or prevent vacuum sweeping’s effectiveness). If, in the 

opinion of the Trained Person additional roadways sweeping 

is necessary to prevent inappropriate fugitive dust emissions it 

will be conducted as soon as practical. [s. NR 405.08, Wis. 

Adm. Code and 03-RV-248-R4]

(4) Water the roadways to minimize fugitive emissions as 

soon as practicable whenever – in the opinion of the Trained 

Person [see (5)-(6) below] – applying wet suppression to the 

roadways is needed to minimize fugitive emissions. [s. NR 

405.08, Wis. Adm. Code and Permits # 03-RV-248-R4 and 

10-MHR-184-R1]

(5) The permittee shall designate at least one Trained Person 

to monitor compliance with the emission limitation, the 

requirements of this section of the permit, and the measures 

for preventing particulate matter from becoming airborne. [s. 

NR 407.09(1)(c)1.b., Wis. Adm. Code, s. 285.65(3), Wis. 

Stats. and 03-RV-248-R4]

(6) The permittee shall ensure that the Trained Person 

identified in I.U.1.b.(5) meets the training requirements of 

I.R.1.b.(5). [s. NR 407.09(1)(c)1.b., Wis. Adm. Code, s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions: 

Whenever compliance emission testing is required, the 

appropriate US EPA Method 9 or an alternate method 

approved in writing by the Department, shall be used to 

demonstrate compliance. [s. NR 439.06(9)(a)1., Wis. Adm. 

Code]

(2) The permittee shall maintain daily records of:

(a) the date and time roadway sweeping and/or roadway 

watering occurred; OR

(b) the date and reasons why roadway sweeping and/or 

watering did not occur.

[s. 285.65(3), Wis. Stats.; s. NR 415.04(1)(b), Wis. Adm. 

Code and 03-RV-248-R4]

(3) The permittee shall retain copies of the Method 9 

certification, other training or qualifications, or written 

Department approval of the Trained Person identified in 

I.U.1.b.(4). [s. NR 439.04(1)(d), Wis. Adm. Code and 03-

RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 208

V. Stack S61, Process P61 – Machine Shop Welding

Stack S62, Process P62 – Rail Car Facility Welding Shop

Pollutant: 1 Particulate Matter Emissions (PM) and Particulate Matter Emissions less than 10 microns (PM10)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions may not exceed:

(a) 0.065 pounds PM per hour for P61

(b) 0.065 pounds PM10 per hour for P61

(c) 0.065 pounds PM per hour for P62

(d) 0.065 pounds PM10 per hour for P62

[s. NR 405.08(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

(2) The electrode use for EACH welding shop may not exceed the following:

(a) The total amount of electrodes used may not exceed 35,148 pounds in any 12 consecutive months.

(b) The total amount of electrodes may not exceed 96 pounds per day on a monthly average.

[s. NR 405.08(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

electrodes consumption records and an emission factor of 

16.32 lbs/1000 lbs of electrode consumed154 or an alternate 

emission factor approved by the Department in writing. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) Monthly welding records generated from the inventory 

system shall be used to determine the average daily weld 

emissions to demonstrate compliance with the particulate 

emission limits in I.V.1.a.(1). [s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(1) Reference Test Method for Particulate Matter Emissions:

Whenever compliance emission testing is required, test 

procedures in 40 CFR 60 and US EPA Method 5, including 

backhalf (Method 202) or an alternate method approved in 

writing by the Department, shall be used to demonstrate 

compliance [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall maintain the following records:

(a) Monthly records of the amount of electrodes used, in 

pounds; 

(b) Records of the calculated monthly average, daily 

electrode use, in pounds per day, to show compliance with 

I.V.1.a.(2)(b);

(b) Records of the total amount of electrodes used in any 12 

consecutive month period, in pounds, to show compliance 

with I.V.1.a. (2)(a). [s. NR 439.04(1)(d), Wis. Adm. Code, ss. 

285.65(3) and (10) and 03-RV-248-R4]

 154 This emission factor is based on the worst case PM10 emission factor of 81.6 lbs/1000 lbs of electrode consumed from AP42 Table 12.19-1, and a release factor of 20%.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 209

V. Stack S61, Process P61 – Machine Shop Welding – (CONTINUED)

Stack S62, Process P62 – Rail Car Facility Welding Shop - (CONTINUED)

Pollutant: 2. Volatile Organic Compounds (VOC)

a. Limitations:

(1) Best Available Control Technology (BACT): Emissions from EACH process may not exceed 0.23 pounds per hour. [s. NR 

405.08(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

(2) The electrode use for EACH welding shop may not exceed the following:

(a) The total amount of electrodes used may not exceed 35,148 pounds in any 12 consecutive months.

(b) The total amount of electrodes may not exceed 96 pounds per day on a monthly average.

[s. NR 405.08(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats. and 03-RV-248-R4]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall determine the hourly emissions using 

electrodes consumption records and an emission factor of 

57.5 pounds per 1000 pounds of electrodes consumed or an 

alternate emission factor approved by the Department in 

writing. [s. 285.65(3), Wis. Stats. and 03-RV-248-R4]

(2) Monthly welding records generated from the inventory 

system will be used to determine the average daily welding 

emissions to demonstrate compliance with the particulate 

emission limits in I.V.2.a.(1). [s. 285.65(3), Wis. Stats. and 

03-RV-248-R4]

(1) Reference test Method for Volatile Organic Compound 

Emissions: Whenever compliance emission testing is 

required, the appropriate US EPA Method 25 or 18 or an 

alternate method approved in writing by the Department, shall 

be used to demonstrate compliance. [s. NR 439.06(3)., Wis. 

Adm. Code]

(2) The permittee shall maintain the following records:

(a) Monthly records of the amount of electrodes used, in 

pounds; 

(b) Records of the calculated monthly average, daily 

electrode use, in pounds per day, to show compliance with 

I.V.2.a.(2)(b);

(b) Records of the total amount of electrodes used in any 12 

consecutive month period, in pounds, to show compliance 

with I.V.2.a. (2)(a). [s. NR 439.04(1)(d), Wis. Adm. Code, ss. 

285.65(3) and (10) and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 210

V. Stack S61, Process P61 – Machine Shop Welding – (CONTINUED)

Stack S62, Process P62 – Rail Car Facility Welding Shop - (CONTINUED)

Pollutant: 3. Visible Emissions

a. Limitations:

(1) 20% opacity. [s. NR 431.05, Wis. Adm. Code; s. NR 405.09, Wis. Adm. Code; s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. 

Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Complying with conditions I.V.1.b.(1) and (2) will also 

serve as compliance with the visible emission limits. [s. 

285.65(3), Wis. Stats. and 03-RV-248-R4]

(1) Reference Test Method for Visible Emissions: Whenever 

compliance emission testing is required, US EPA Method 9 or

an alternate method approved in writing by the Department, 

shall be used to demonstrate compliance. [ss. NR 

439.06(9)(a)1. and NR 439.07(8)(f), Wis. Adm. Code]

(2) Compliance with conditions I.V.1.c.(2), will serve as 

demonstrating compliance with the recordkeeping and 

monitoring requirements for visible emissions. [s. 285.65(3), 

Wis. Stats.; s. 285.65(10), Wis. Stats. and 03-RV-248-R4]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 211

V. Stack S61, Process P61 – Machine Shop Welding – (CONTINUED)

Stack S62, Process P62 – Rail Car Facility Welding Shop - (CONTINUED)

Pollutant: 4. Hexavalent Chromium

a. Limitations:

(1) * Emissions of hexavalent chromium from the Rail Car Facility Welding Shop (P62) may not exceed 0.088 pounds in any 

12 consecutive month period. [s. NR 445.08(2)(c), Wis. Adm. Code]

(2) * Emissions of hexavalent chromium from the Machine Shop Welding Process (P61) may not exceed 1.23 pounds in any 

12 consecutive month period. [s. NR 445.08(2)(c), Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) * The permittee shall determine 

hourly emissions using monthly electrode 

consumption records for the Rail Car 

Facility Welding Shop (P62) and an 

emission factor of 0.176 lbs/1000 lbs of 

electrodes consumed155 or and alternative 

department approved emission factor. [s. 

285.65(3), Wis. Stats.]

(2) * For the Rail Car Facility Welding 

Shop P62, the permittee may not use more 

than 2500 pounds of electrodes containing 

chromium VI during any 12-consecutive 

month period. [s. 285.65(3), Wis. Stats]

(1) Reference Test Method for Hexavalent Chromium Emissions: Whenever 

compliance emission testing is required, US EPA Method 0013 or an alternate 

method approved in writing by the Department, shall be used to demonstrate 

compliance. [s. NR 439.06(8) Wis. Adm. Code]

(2) * The permittee shall maintain monthly records of the 

(a) Amount of each type of electrodes used, in the Rail Car Facility Welding 

Shop (P62), in pounds per month, as required by condition I.V.1.c.(2);

(b) Amount of each type of electrodes used in the Machine Shop Welding (P61), 

in pounds per month, as required by condition I.V.1.c.(2);

(c) The total amount of hexavalent chromium containing electrodes that are used 

in the Machine Shop Welding (P61) each month, in pounds per month;

(d) The total amount of hexavalent chromium containing electrodes that are used 

in the Rail Car Facility Welding Shop (P62) each month, in pounds per month;

(e) The total amount of hexavalent chromium containing electrodes used in the 

Machine Shop Welding P61, during the previous 12-consecutive month period, 

in pounds.

(f) The total amount of hexavalent chromium containing electrodes used in the 

Rail Car Facility Welding Shop (P62) during the previous 12-consecutive month 

period, in pounds.

(g) The amount of hexavalent chromium emitted from the Machine Shop 

Welding (P61), each month, calculated using the electrode consumption records 

and emission factor identified in condition I.V.4.b.(1), in pounds per month;

(h) The amount of hexavalent chromium emitted from the Rail Car Facility 

Welding Shop (P62), each month, calculated using the electrode consumption 

records and emission factor identified in condition I.V.4.b.(1), in pounds;

(i) The total amount of hexavalent chromium emitted from the Machine Shop 

Welding (P61), during the previous 12 consecutive month period, in pounds; and

(j) The total amount of hexavalent chromium emitted from the Rail Car Facility 

Welding Shop (P62), during the previous 12 consecutive month period, in 

pounds.

[s. NR 439.04(1)(d) and ss. 285.65(3) and (10), Wis. Stats.]

 155 Worst case hexavalent chromium emission factor from U.S. EPA Memo dated February 7, 2005, Regarding January 25, 

2005 Meeting with the Shipbuilding Industry, Attachment 5. Summary of Welding Emission Factors.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 212

W. Process F71 – Temporary Bottom Ash Storage Pile 

X. Process F72 – Temporary Fly Ash Storage Pile

Y. Process F73 – Bottom Ash Screening Plant

Pollutant: 1. Particulate Matter – Fugitive Dust Emissions

a. Limitations:

(1) The permittee may not cause, allow, or permit any materials to be handled, transported, or stored without taking precautions 

to prevent particulate matter from becoming airborne. Nor may the permittee allow a structure, a parking lot, or a road to be 

used, constructed, altered, repaired, sand blasted, or demolished without taking such precautions. [s. NR 415.04, Wis. Adm. 

Code, Permit # 10-MHR-184-R1]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall apply water, wet suppression spray, 

surface stabilizing agent and/or cover material(s) as needed to 

prevent particulate matter from becoming airborne. [s. NR 

415.04(1)(b), Wis. Adm. Code, Permit # 10-MHR-184-R1]

(2) Ash shall be hauled offsite in enclosed tanker(s) or in 

trucks. The ash within any open bed of a truck shall be tarped 

when leaving the facility to prevent material from falling off 

and becoming airborne. [s. NR 415.04(1)(b), Wis. Adm. 

Code, Permit # 10-MHR-184-R1]

(1) When applying suppressant for dust control, the permittee 

shall record:

(a) the date and time of the application, and

(b) the area(s) at the facility where suppressant is applied. 

[s. NR 439.04(1)(d), Wis. Adm. Code, Permit # 10-MHR184-R1]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 213

XXX. Conditions Applicable to the Entire Facility

Condition Type: 1. Reporting

a. Conditions:

(1) The permittee shall submit the results of monitoring required by this permit to the Department every 6 months. In lieu of 

submission of all monitoring results, a summary of the monitoring results may be submitted to the Department. The summary 

shall include sufficient data for the Department to determine whether the source is in compliance with the applicable 

requirements to which the monitoring relates. The semiannual monitoring report may be consolidated with the quarterly excess 

emission report required under s. NR 439.09 when submission of both these reports is required.

(a) The time periods to be addressed by the submittal are: January 1 to June 30 and July 1 to December 31

(b) The report shall be submitted to the West Central Region Air Management Program, Wausau Service Center, 5301 Rib 

Mountain Drive, Wausau, WI 54401, and to Compliance Data - Wisconsin, Air and Radiation Division, U.S. EPA, 77 West 

Jackson, Chicago, IL 60604 within 60 days after the end of each reporting period.

(c) All deviations from and violations of applicable requirements shall be clearly identified in the submittal. (d) Each submittal 

shall be certified by a responsible official as to the truth, accuracy, and completeness of the report. [s. NR 439.03(1)(b), Wis. 

Adm. Code and 03-RV-248-R4]

(2) The permittee shall submit certification of compliance with the requirements of this permit to the Department and U.S. EPA 

annually.

(a) The time period to be addressed by the report is the January 1 to December 31 period which precedes the report.

(b) The report shall be submitted to the West Central Region Air Management Program, Wausau Service Center, 5301 Rib 

Mountain Drive, Wausau, WI 54401, and to Compliance Data - Wisconsin, Air and Radiation Division, U.S. EPA, 77 West 

Jackson, Chicago, IL 60604 within 60 days after the end of each reporting period.

(c) The information included in the report shall comply with the requirements of Part II, Section N of this permit.

(d) Each report shall be certified by a responsible official as to the truth, accuracy, and completeness of the report. [s. NR 

439.03(1)(c), Wis. Adm. Code and 03-RV-248-R4]

Condition Type: 2. Quarterly Excess Emission Reports

a. Conditions:

(1) The quarterly excess emission reports required by this permit shall:

(a) Be submitted to the West Central Region Air Management Program, Wausau Service Center, 5301 Rib Mountain Drive, 

Wausau, WI 54401, within 30 days of the end of each calendar quarter,

(b) Contain the following information:

(i) The date and starting and ending times or duration of each period of excess emissions and the magnitude of the 

emissions;

(ii) The periods of excess emissions that occur during startups, shutdowns, sootblowing, control equipment malfunction, 

process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any 

malfunction and the measures taken to reduce excess emissions.

(iii) The date and starting and ending times of any period during which the monitoring system was inoperative for any 

reason or causes, including monitor malfunction or calibration, except zero and span checks. The report shall identify the 

repairs or adjustments made to the system.

(iv) The date and starting and ending time of a period during which the process being monitored was inoperative.

(v) When no period of excess emissions occurred during the quarter and the monitoring system had no period of 

downtime, an excess emission report shall be filed stating such information. 

[ss. NR 439.09(10) and NR 439.09(10)(a), Wis. Adm. Code]

(2) Unless otherwise required by the department in writing, the permittee may submit a summary excess emission report in 

lieu of the full excess emission reports required by this permit. The summary report shall be submitted on a form provided by 

the Department or in a format approved by the Department. [s. NR 439.09(10)(d), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 214

XXX. Conditions Applicable to the Entire Facility

Condition Type: 3. Compliance Emission Testing

a. Conditions:

(1) Whenever compliance emission testing is required by the Department:

(a) Unless the department requires or approves the performance of a test at less than capacity, all compliance emission tests 

shall be performed with the equipment operating at capacity or as close to capacity as practicable.

(b) The reference test methods outlined in this permit shall be used unless an alternate, U.S. EPA approved, test method is 

approved by the Department in writing.

(c) The Department shall be notified in writing at least 20 business days in advance of a compliance emission test, to provide 

the department an opportunity to have a representative present to witness the testing procedures.

(d) The notice required by (c) shall provide a test plan which includes, but need not be limited to, the following:

(i) A description of the sampling equipment and the test methods and procedures to be used.

(ii) A description of the process to be tested.

(iii) A description of the process or operation variables which affect the air contaminant source’s emissions.

(iv) The date and starting time of the test.

(v) A description of the number and location of the sampling ports and sampling points including a sketch showing the 

distance of the sampling ports from the nearest upstream and downstream flow disturbances and the stack dimensions.

(vi) A statement indicating the production rate and the operating conditions at which the test will be conducted.

(e) The permittee shall notify the department of any modifications to the test plan at least 5 business days prior to the test. 

(f) In the event the permittee is unable to conduct the compliance emission test on the date specified in the test plan, due to 

unforeseeable circumstances beyond the permittee’s control, the permittee shall notify the department at least 5 business days 

prior to the scheduled compliance emission test date and specify the date when the test is rescheduled.

(e) Two copies of the emission test report shall be submitted to the West Central Region Air Management Program, Wausau 

Service Center, 5301 Rib Mountain Drive, Wausau, WI 54401 for evaluation within 60 days after completion of a compliance 

emission test. If requested the department may grant an extension of up to 30 days for test report submittal. The emission test 

report shall include, but need not be limited to the information outlined in s. NR 439.07(9), Wis. Adm. Code.

(f) Compliance emission tests shall be conducted according to the procedures in s. NR 439.07(8), Wis. Adm. Code.

[ss. NR 439.07(1), (2), (4), (8) and (9), Wis. Adm. Code]

(2) The following exceptions apply to compliance emission testing required under s. NR 439.075(2)(a) or (c):

(a) The department may grant a written waiver of a scheduled test if any of the following applies:

(i) The direct stationary source associated with the emission point subject to the testing requirement will be ceasing 

operation within one year of a scheduled test.

(ii) The most recently completed test results from a test conducted according to the methods and procedures specified in s. 

NR 439.07 for the direct stationary source demonstrate that the emissions of the air contaminant for which compliance 

emission testing is required are 50% or less of the applicable emission limitation.

(iii) The direct stationary source associated with the emission point subject to the testing requirement has not operated 

more than 360 hours in the previous 12 month period prior to the scheduled test date.

(b) The department may grant an extension of up to 180 days for compliance emission testing if the permittee requests an 

extension, in writing, and can demonstrate that a representative emissions test cannot be performed within the time frames 

specified in this permit. 

(c) All requests for waivers under paragraph (b) shall be submitted in writing for department review and approval at least 60 

days prior to the required date.

[s. NR 439.075(4), Wis. Stats]

(3) Nothing in this permit or in s. NR 439.075, Wis. Adm. Code may be construed as preventing the department from 

requiring the performance of additional compliance emission tests on affected sources or requiring tests for pollutants and 

sources other than those listed in s. NR 439.075, Wis. Adm. Code. [s. NR 439.075(1)(b), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 215

XXX. Conditions Applicable to the Entire Facility

Condition Type: 4. Additional Reference Test Methods

a. Conditions:

(1) Reference Test Method for Coal Sampling: Whenever coal sampling is required, it shall be performed according to ASTM 

D2234-02, Standard Practice for Collection of a Gross Sample of Coal. [s. NR 439.08(1)(a), Wis. Adm. Code]

(2) Reference Test Method for Preparing Coal for Analysis: Whenever preparation of a coal sample for analysis is required, it 

shall be performed according to ASTM D2013-01, Standard Method of Preparing Coal Samples for Analysis. [s. NR 

439.08(1)(b), Wis. Adm. Code]

(3) Reference Test Method for the Sulfur Content in Coal: Whenever the sulfur content of a coal sample is required, it shall be 

determined according to ASTM D3177-02, Standard Test Methods for Total Sulfur in the Analysis Sample of Coal and Coke, 

or ASTM D4239-04a, Standard Test Methods for Sulfur in the Analysis Sample of Coal and Coke using High Temperature 

Tube Furnace Combustion Methods. [s. NR 439.08(1)(c), Wis. Adm. Code]

(4) Reference Test Method for the Heat Content in Coal: Whenever the heat content of a coal sample is required, it shall be 

determined according to ASTM D5865-04, Standard Test Methods for Gross Calorific Value of Coal and Coke. [s. NR 

439.08(1)(d), Wis. Adm. Code]

(5) Reference Test Method for Ash Content in Coal: Whenever the ash content of a coal sample is required, it shall be 

determined according to ASTM D3174-04, Standard Test Method for Ash in the Analysis Sample of Coal and Coke from Coal. 

[s. NR 439.08(1)(e), Wis. Adm. Code]

(6) Reference Test Method for Moisture Content in Coal: Whenever the moisture content of a coal sample is required, it shall 

be determined according to ASTM D3173-02, Standard Test Method for Moisture in the Analysis Sample of Coal and Coke. 

[s. NR 439.08(1)(f), Wis. Adm. Code]

(7) Reference Test Method for Ultimate Analysis in Coal: Whenever the ultimate analysis of a coal sample is required, it shall 

be determined according to ASTM D3176-89, Standard Practice for the Ultimate Analysis of Coal and Coke. [s. NR 

439.08(1)(g), Wis. Adm. Code]

(8) Reference Test Method for Liquid Fossil Fuel Sampling: Whenever liquid fossil fuel sampling is required it shall be 

performed according to ASTM D4057-95, Standard Practice for Manual Sampling of Petroleum and Petroleum Products, or 

ASTM D4177-95, Standard Practice for Automatic Sampling of Petroleum and Petroleum Products.

(9) Reference Test Method for Sulfur Content in Liquid Fossil Fuel: Whenever the sulfur content of a liquid fossil fuel sample 

is required, it shall be determined according to ASTM D129-00, Standard Test Method for Sulfur in Petroleum Products 

(General Bomb Method), ASTM D1552-03, Standard Test Method for Sulfur in Petroleum Products (High-Temperature 

Method), or ASTM D4294-03, Standard Test Method for Sulfur in Petroleum Products by Energy-Dispersive X-ray 

Fluorescence Spectroscopy.

(10) Reference Test Method for Heat Content in Liquid Fossil Fuel: Whenever the heat content of a liquid fossil fuel sample 

is required, it shall be determined according to ASTM D240-02, Standard Test Method for Heat of Combustion of Liquid 

Hydrocarbon Fuels by a Bomb Calorimeter.

(11) Reference Test Method for Sampling and Analysis of Fuels Other Than Coal and Liquid Fossil Fuel: Whenever sampling 

and analysis of a fuel other than coal and liquid fossil fuel is required, it shall be determined by methods and procedures 

approved, in writing, by the Department. [s. NR 439.08(3), Wis. Adm. Code]

(12) Alternative methods than those listed in (1) through (11) above, may be used if approved, in writing, by the department. 

[s. NR 439.08, Wis. Adm. Code]

Condition Type: 5. Fugitive Dust Control Plan

a. Conditions:

(1) The permittee shall maintain and follow a fugitive dust control plan for all potential sources of fugitive dust emissions. 

This plan shall be submitted to the Department upon request. A copy of the plan shall be kept at the facility. The department 

may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with applicable 

emission limits. The plan shall identify the specific measures to be taken, when each measure is needed, and the frequency 

with which each measure will be taken.156 [s. NR 415.03, Wis. Adm. Code]

 156 For example, specific dust control measures could include: watering all roads hourly and amount of water used, use of spray 

bars including amount and rate of water applied, or use of other approved dust suppressants.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 216

XXX. Conditions Applicable to the Entire Facility

Condition Type: 6. Control and Compliance Requirements for the Handling and Storage of Coal

a. Conditions:

(1) Requirements for Outdoor Fugitive Coal Dust Emissions: The permittee shall achieve compliance by doing all of the 

following:

(a) Have the ability to control, in a timely manner, outdoor fugitive coal dust emissions in an effort to prevent emissions off 

the source property.157

(b) Develop and implement a plan to control outdoor fugitive coal dust emissions in an effort to prevent emissions off the 

source property. The plan shall include all of the following:

(i) Identification of all sources of outdoor fugitive coal dust emissions from coal handling and coal storage piles on the 

source property;

(ii) A description of the measures that can be taken to control, in a timely manner, outdoor fugitive coal dust emissions 

from all sources identified under (i) under the following conditions: a) routine operation, b) periods of high activity158, c) 

periods of increased probability of outdoor fugitive dust emissions159, and d) when equipment used to control outdoor 

fugitive coal dust emissions malfunctions.

(c) Keep records of actions taken to control outdoor fugitive coal dust emissions in accordance with s. NR 439.04(2), Wis. 

Adm. Code.

(d) Keep a copy of the plan and records of all actions taken at the facility for inspection upon request.

[s. NR 445.10(2), Wis. Adm. Code]

(2) Requirements for Non-fugitive Coal Dust Emissions to the Ambient Air: For any non-fugitive source of coal dust 

emissions exhausted through a fabric filter to the ambient air, the permittee shall do one of the following:

(a) Limit visible emissions from each source to 10% opacity,

(b) Limit the quantity, concentration or duration of potential-to-emit emissions of respirable coal dust from all sources so that 

the ambient air concentration off the source property is less than 21.6 ug/m3 for any 24 hour period. (The permittee may rely 

on information generated by either the EPA screening or refined dispersion model to demonstrate meeting this concentration 

requirement.)

[s. NR 445.10(3), Wis. Adm. Code]

 157 Examples of measures that would meet the ability to control requirement include active measures such as the application of 

water or chemical dust suppressants, passive measures such as the use of enclosed delivery or handling systems or solid 

fencing, or access to third-parties to provide dust suppression, as appropriate. The intent of this section is to allow facilities that 

suppress dust using water to manage the amount of water applied to avoid potential boiler, handling, or other operational 

problems, as long as there is sufficient dust control so as not to cause excessive outdoor fugitive coal dust emissions.

158 Examples of periods of high activity include periods when the daily handling of coal is much greater than usual, such as 

unloading a large number of coal shipments at the close of the shipping season

159 . Examples of periods of increased probability of fugitive coal dust emissions include periods or a combination of periods of 

drought, freezing weather, or forecasts of high winds exceeding 25 miles per hour.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 217

XXX. Conditions Applicable to the Entire Facility

Condition Type: 7. Recordkeeping Requirements

a. Conditions:

(1) Copies of all records required by this permit shall be retained by the permittee for a period of 5 years. [s, NR 439.04(2), 

Wis. Adm. Code]

(2) No person may deny information or access to records relating to emissions or any other records required to be kept to an 

authorized representative of the department. [s. NR 439.05(1), Wis. Adm. Code]

Condition Type: 8. Clean Air Interstate Rule (CAIR) / Cross-State Air Pollution Rule (CSAPR)

a. Conditions:

(1) The permittee shall comply with the requirements of the Clean Air Interstate Rule (CAIR) as applicable. See Part III.160 

[40 CFR part 97]; OR

(2) When in effect, the permittee shall comply with the requirements of the Cross-State Interstate Rule (CSAPR) as applicable. 

 160 On July 11, 2008, the U.S. Circuit Court of Appeals for the District of Columbia Circuit made a decision to vacate CAIR “in 

its entirety” and remanded U.S. EPA to promulgate a new rule consistent with the Court’s decision. On December 23, 2008, the

U.S. Court of Appeals for the District of Columbia Circuit made a decision to remand the case without vacatur so that U.S. EPA 

may remedy CAIR’s flaws in accordance with their July 11, 2008 opinion in this case. As a result CAIR remains in effect until 

it is replaced by a rule consistent with the U.S. Circuit Court of Appeals’ July 11, 2008 opinion. On July 6, 2011, the US EPA 

finalized the Cross-State Air Pollution Rule (CSAPR), effective January 1, 2012, to replace the 2005 Clean Air Interstate Rule 

(CAIR). The CSAPR was scheduled to takes affect January 1, 2012, with CAIR being implemented through the 2011 

compliance periods and then replaced by CSAPR. However, the US Court of Appeals for the District of Columbia Circuit 

issued a ruling filed on December 30, 2011 to stay CSAPR pending judicial review. In the interim CAIR continues to apply. 

U.S. EPA finalized a supplemental rulemaking on December 15, 2011 requiring five states, including Wisconsin to make 

summertime NOx reductions under the CSAPR ozone season control program. On January 26, 2012, US EPA signed a notice to 

be published in the Federal Register, indicating that the Agency will not require compliance with the supplemental CSAPR rule 

while the stay is in affect. On August 21, 2012 the U.S. Court of Appeals for the District of Columbia Circuit made a decision to 

vacate CSAPR and the CSAPR FIP and remanded the case to U.S. EPA for action consistent with the decision. The court 

directed U.S. EPA to continue administering CAIR pending the promulgation of a valid replacement.

It is uncertain at this time what changes, if any, might be made to CSAPR and when the rule will go into affect. In the interim, 

Wisconsin Public Service Corporation – Weston (ORIS/Facility Code 4078) would be subject to the requirements of CAIR, as 

applicable, as currently promulgated by U.S. EPA. Under the current CAIR requirements, boilers B01, B02, B03 and B04 

(identified by the facility as Units 1, 2, 3, and 4 respectively) and processes P32A and P32 (identified by the facility as Units 

32A and 32B respectively) at the Wisconsin Public Service Corporation Weston Site (FID #: 737009020, ORIS/Facility Code: 

4078) is subject to: the CAIR Nitrogen Oxide – Annual Program, the CAIR Sulfur Dioxide Program and the CAIR Nitrogen 

Oxide – Ozone Season Program. Under the rule as currently written, the permittee is required to comply with the CAIR 

requirements as outlined in the CAIR Permit Application (for sources subject to CAIR FIP – See Part III of this permit) and 40 

CFR 97.121, 97.122, 97.221, 97.222, 97.321 and 97.322.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 218

XXX. Conditions Applicable to the Entire Facility

Condition Type: 9. Compliance Assurance Monitoring (CAM) Requirements

a. Conditions:

(1) Compliance Assurance Monitoring (CAM) Requirements: Boilers B01, B02, B03, and B04 and processes P31A, P31B, 

P31C, P32A, P32B, P32D, P32E, P34, P35A, P35B, P36A, P36B, P37A, P30, P41, P42, P43, P45, P49, and P50 are each 

pollutant-specific emissions unit for particulate matter emissions subject to the CAM requirements of Part 64 CFR. As such 

the permittee shall comply with the provisions of the associated CAM plans for the pollutant-specific emissions from boilers 

B01, B02, B03, and B04 and processes P31A, P31B, P31C, P32A, P32B, P32D, P32E, P34, P35A, P35B, P36A, P36B, P37A, 

P30, P41, P42, P43, P45, P49, and P50, included in this permit as Part IV and these processes are subject to the CAM 

requirements of 40 CFT Part 64 as follows: [s. 285.65(13), Wis. Stats. 40 CFR Parts 64.2, 64.3, and 64.6(c)(3)]

(a) The permittee shall monitor the indicators identified in each CAM plan in Part IV of this permit as indicators of emission 

control equipment performance for each associated control device controlling the pollutant-specific emissions from each 

respective process, whenever the process is operating. [40 CFR parts 64.3(a)(1) and (3), 64.6(c)(1)(i), and 64.7(a)]

(b) The permittee shall use the means or devices to measure the above indicators as identified in each CAM plan in Part IV, 

whenever the identified process is operating. [40 CFR parts 64.6(c)(1)(ii) and 64.7(c)]

(c) The permittee shall operate the indicator monitoring devices as identified in each CAM plan in Part IV. [40 CFR parts 

64.3(b), 64.6(c)(1)(iii), and 64.7(b)]

(d) An exceedance or excursion shall be defined for each of the indicators as identified in each CAM plan in Part IV. The 

permittee shall notify the Department in writing prior to reestablishing the exceedance or excursion value for any of the 

indicators. [40 CFR parts 64.6(c)(2)]

(e) The permittee shall establish that the indicator ranges identified in each of the CAM plans in Part IV are representative of a 

level where the associated control equipment is operating in compliance with the respective pollutant-specific emission 

limitations in Part I of this permit. [40 CFR Parts 64.4(d) and 64.6(c)(2)]

(f) The indicator ranges or the procedures for establishing indicator ranges identified in each of the CAM plans in Part IV may 

rely on engineering assessments and other data, provided that the permittee demonstrates that factors specific to the type of 

monitoring, control device, or pollutant-specific emissions unit make compliance or performance testing unnecessary to 

establish indicator ranges at levels that satisfy the criteria in 40 CFR Part 64.3. [40 CFR Part 64.4(d)(2)]

(g) Each of the CAM plans in Part IV shall specify the level at which an excursion or exceedance will be deemed to occur, 

including the appropriate averaging period associated with such exceedance or excursion. [40 CFR Part 64.6(c)(2)]

(h) For defining an excursion from an indicator range or designated condition, each of the CAM plans in Part IV may either 

include the specific value(s) or condition(s) at which an excursion shall occur, or the specific procedures that will be used to 

establish that value or condition. If the latter, the permittee shall notify the department in writing prior to any establishment or

reestablishment of the value. [40 CFR Part 64.6(c)(2)]

(i) Any performance test(s) necessary under I.XXX.9.a.(1)(e) shall be conducted in accordance with I.XXX.3.a. Such data 

may be supplemented, if desired, by engineering assessments and manufacturer’s recommendations, to justify the indicator 

ranges (or, if applicable, the procedures for establishing such indicator ranges). Emission testing is not required to be 

conducted over the entire indicator range or range of potential emissions. [40 CFR Part 64.4(c)]

{Continued On Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 219

XXX. Conditions Applicable to the Entire Facility

Condition Type: 9. Compliance Assurance Monitoring (CAM) Requirements {CONTINUED...}

a. Conditions:

{...Continued from Previous Page...}

(2) CAM – Monitoring Operation: 

(a) Commencement of Operation: The permittee shall commence operation of the monitoring identified as CAM in each 

CAM plan in Part IV upon issuance of this permit. [40 CFR Part 64.7(a)]

(b) Proper Maintenance: At all times the permittee shall maintain the monitoring equipment required by I.XXX.9.a.(1), 

including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment.

(c) Continued Operation: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality 

assurance or control activities (including calibration checks and required zero and span adjustments), the permittee shall 

conduct all monitoring collecting data at the required intervals, at all times the process is operating. Data recorded during 

monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes 

of this requirement, including data averages and calculations, or fulfilling a minimum data availability requirement. The 

permittee shall use all data collected during all other periods in assessing the operation of the control device and associated 

control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to 

provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.

(d) Response to Excursions or Exceedances: (i) Upon detecting an excursion or exceedance, the permittee shall restore 

operation of the associated process (including the control device and associated capture system) to its normal or usual manner 

of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. 

The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective 

actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than 

those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, 

recording that operations returned to normal without operator action, or any necessary follow-up actions to return operation to 

within the indicator range, designated condition, or below the applicable emission limitation or standard as applicable. (ii) 

Determination of whether the permittee has used acceptable procedures in response to an excursion or exceedance will be 

based on information available, which may include but is not limited to, monitoring results, review of operation and 

maintenance procedures and records, and inspection of the control device, associated capture system, and the process.

(e) Documentation of Need for Improved Monitoring: If the permittee identifies a failure to achieve compliance with the 

associated pollutant specific emission limitations outlined in Part I for which the CAM requirements outlined in I.XXX.9.a.(1) 

did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or 

performance testing document a need to modify the existing indicator ranges, the permittee shall promptly notify the 

Department, and if necessary, submit a proposed revision to this operation permit to address the necessary monitoring changes. 

Such a revision may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the 

frequency of conducting monitoring and collecting data, or the monitoring of additional parameters.

[40 CFR Part 64.7]

(3) CAM - Reporting and Recordkeeping Requirements:

(a) General Reporting Requirements:

(i) The permittee shall include the CAM information in the compliance and monitoring reports required by I.XXX.1.a. 

(ii) The compliance and monitoring reports shall include, at a minimum, the information required by conditions I.XXX.1.a.(1) 

and (2) and the following, as applicable: 1) summary information on the number, duration and cause (including unknown 

cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken; 2) summary information on 

the number, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime 

associated with zero and span or other daily calibration checks, if applicable); and 3) a description of the actions taken to 

implement a QIP during the reporting period as specified in I.XXX.9.a.(1). Upon completion of a QIP, the permittee shall 

include in the next summary report documentation that the implementation of the plan has been completed and reduced the 

likelihood of similar levels of excursions or exceedances occurring.

(b) General Recordkeeping Requirements:

(i) The permittee shall maintain records of monitoring data, monitoring performance data, corrective actions taken, any written 

QIP required by I.XXX.9.a.(1) and any activities undertaken to implement a QIP, and other supporting information.

(ii) Instead of paper records, the permittee may maintain records on alternative media, such as microfilm, computer files, 

magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and 

review, and does not conflict with other applicable recordkeeping requirements. [40 CFR §64.9]

{...Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 220

XXX. Conditions Applicable to the Entire Facility

Condition Type: 9. Compliance Assurance Monitoring (CAM) Requirements {CONTINUED...}

a. Conditions:

{...Continued from Previous Page...}

(4) CAM - Quality Improvement Plan (QIP) Requirements:

(a) Based on the results of a determination made under I.XXX.9.a.(2)(d)(ii), the permittee shall develop and implement a QIP if 

the required monitoring shows an accumulations of exceedances or excursions of the value (or range) established pursuant to 

I.XXX.9.a.(1)(d) exceeding 5 percent duration of the associated process’s operating time in any calendar quarter. 

(b) Elements of a QIP: (i) The permittee shall maintain the QIP in writing and have it available for inspection. (ii) The plan 

initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation 

procedures, the permittee shall modify the plan to include procedures for conducting one or of the following actions , as 

appropriate: (1) improved preventive maintenance practices, (2) process operation changes, (3) appropriate improvements to 

control methods, (4) other steps appropriate to correct control performance, (5) more frequent or improved monitoring (only in 

conjunction with one or more of steps (1) through (4)). 

(c) If a QIP is required, the permittee shall develop and implement a QIP as expeditiously as practicable and shall notify the 

Department if the period of completing the improvements contained in the QIP exceeds 180 days from the date on which the 

need to implement the QIP was determined.

(d) Following implementation of a QIP, upon any subsequent determination pursuant to I.XXX.9.a.(2)(d)(ii) the Department 

may require that the permittee make reasonable changes to the QIP, if the QIP is found to have: (i) failed to address the cause 

of the control device performance problems; or (ii) failed to provide adequate procedures for correcting control device 

performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing 

emissions.

(e) Implementation of a QIP shall not excuse the permittee from compliance with any existing emission limitation or standard, 

or any existing monitoring, testing, reporting or recordkeeping requirement that applies under federal, state, or local law, or any 

other applicable requirement of the Clean Air Act.

[40 CFR Part 64.8]

Condition Type: 10. Control of Mercury Emissions from Major Utilities *

a. Conditions:

(1A) The permittee is exempt from the emissions limitations and other requirements in ss. NR 446, Wis. Adm. Code, 

Subchapters II and III, as outlined in sections I.XXX.10. and I.XXX.11. of this permit, if the source is regulated161 for 

mercury emissions under 40 CFR Part 63 Subpart UUUUU. [s. 285.27(2)(d), Wis. Stats.]

(1) * Mercury Emission Limitations for Major Utilities: 

(a) Beginning January 1, 2010, no owner or operator of a major utility may (Wisconsin Public Service Corporation)162 cause, 

allow or permit mercury emissions that exceed 60% of the mercury emissions baseline (584 pounds per year)163 determined by 

the department under s. NR 446.06, Wis. Adm. Code. [s. NR 446.05, Wis. Adm. Code]

(b) Baseline mercury emissions are as follows:

(i) Weston 1 (B01): 43 pounds per year

(ii) Weston 2 (B02): 67 pounds per year

(iii) Weston 3 (B03): 246 pounds per year

(iv) Pulliam 3: 14 pounds per year

(v) Pulliam 4: 16 pounds per year

(vi) Pulliam 5: 29 pounds per year

(vii) Pulliam 6: 42 pounds per year

(viii) Pulliam 7: 48 pounds per year

(ix) Pulliam 8: 80 pounds per year

(x) Total for Wisconsin Public Service Corporation: 584 pounds per year

[s. NR 446.06(4), Wis. Adm. Code]

{...Continued on Next Page...}

 161 Sources are considered regulated by 40 CFR Part 63 Subpart UUUUU as of the date that the source must comply with the 

applicable requirements. For existing sources, this date is April 16, 2015 (see 40 CFR s.63.9984(b)).

162 Wisconsin Public Service Corporation is the owner and operator of a major utility as defined in s. NR 446.02(6m). The 

utility’s coal-fired units covered by s. NR 446.05 include Pulliam Units 3 through 8 and Weston Units 1 through 3.

163 The department provided written notification of the baseline mercury emissions for Wisconsin Public Service Corporation in 

a letter from Kevin Kessler, Air Management Bureau Director, dated 12/13/2006.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 221

XXX. Conditions Applicable to the Entire Facility

Condition Type: 10. Control of Mercury Emissions from Major Utilities * - {CONTINUED}

a. Conditions:

{...Continued from Previous Page...}

(2) * Annual Mercury Emissions Determination and Reporting:

(a) For calendar years 2010 through 2014, the permittee shall determine and report to the department by March 1, annual 

mercury emissions for each unit using the following formula:

Annual Mercury Emissions = Fuel Use x Mercury Content of Fuel x Reduction of Mercury Prior to its Release to the Atmosphere

Where:

(i) Fuel use is the amount of fuel combusted in the combustion unit, as measured by the procedures in Appendices A, B, C and 

F of 40 CFR part 75. The total amount of fuel combusted in mmBtus may be apportioned to individual fuels, using 

consumption and delivery records for the fuels.

(ii) Mercury content of the fuel is determined according to ASTM D3984-01 or an equivalent method approved by the 

department, following the procedures in s. NR 446.07(1), (2), and (3).

(iii) Reduction of mercury is calculated through source performance tests which follow the procedures listed below. A value

of one is assumed for natural gas fired combustion units that are exempt from performance testing under paragraph (f) below.

a) The source performance test shall be conducted according to Method 101A in Appendix B of 40 CFR part 61, Method 

29 in Appendix A of 40 CFR part 60, Method 30A or 30B in Appendix A of 40 CFR part 60, or ASTM D6784-02.

b) A sample of fuel burned during the test shall be analyzed for mercury content, using ASTM D3684-01, or an equivalent 

method approved by the department. During each of the 3 runs of the performance test, a separate sample of fuel being 

burned during the run shall be collected and analyzed.

c) During the source performance testing, the consumption of fuel shall be monitored and recorded.

d) The permittee shall submit to the department the information obtained in a) through c) above, and the calculations for 

the percent removal efficiency of mercury.

(iv) The department may require that more than one source performance test be conducted if a single test is determined not to 

be representative of conditions at the combustion unit.

(b) The department may require the permittee to use other methods of determining the annual mercury emissions.

(c) The permittee may request that alternative methods for determining annual mercury emissions be approved by the 

department.

(d) All units with an electrical generating capacity equal to or greater than200 MW, and all units that undergo process changes 

or change control equipment after January 1, 2006, shall have source performance tests conducted during calendar years 2010 

and 2013.

(e) The permittee shall use the results of the most recently conducted source performance test for calculating the reduction

efficiency under paragraph (a)(iii) above.

(f) Combustion units that exclusively combust natural gas are not subject to the source performance testing requirements of 

this condition.

[s. NR 446.08, Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 222

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units *

a. Conditions:

(1A) The permittee is exempt from the emissions limitations and other requirements in ss. NR 446, Wis. Adm. Code, 

Subchapters II and III, as outlined in sections I.XXX.10. and I.XXX.11. of this permit, if the source is regulated164 for 

mercury emissions under 40 CFR Part 63 Subpart UUUUU. [s. 285.27(2)(d), Wis. Stats.]

(1) * Mercury Emission Limitations for Large Coal-fired Electric Generating Units (EGUs):165

(a) Beginning January 1, 2015 the permittee shall comply with one of the following emission limitations:

(i) Achieve a minimum of 90% mercury emissions reduction as measured from the mercury content of the fuel 

combusted; OR

(ii) Limit mercury emissions annually to 0.0080 pounds per gigawatt-hour (lbs/GWh) of electricity produced.

(b) The permittee shall achieve compliance with these limitations by either of the following methods:

(i) Unit-by-unit compliance: Demonstrate that the mercury emissions from each coal-fired EGU meet either of the 

mercury emission limits in paragraph (a) using the measurement methods and calculation procedures in condition 

I.XXX.11.a.(4); OR

(ii) Unit Averaging: Demonstrate that the sum of the mercury emissions from all coal-fired EGUs subject to the mercury 

emission limits in paragraph (a) does not exceed the sum of the annual allowable mercury emissions for the coal-fired 

EGUs using the measurement methods and calculation procedures in condition I.XXX.11.a.(4).

[s. NR 446.13, Wis. Adm. Code]

(2) * Multipollutant Reduction Alternative for Coal-fired Electrical Generating Units (EGUs):

(a) The permittee may elect to meet the emission limitations below instead of the emission limitations in condition (1) above. 

The following annual emission limitations for NOx, SO2, and mercury apply to each unit for which the owner or operator 

makes an election under this condition. 

(i) For NOx, beginning January 1, 2015: 0.07 pounds per mmBtu of heat input.

(ii) For SO2, beginning January 1, 2015: 0.10 pounds per mmBtu of heat input.

(iii) For mercury emissions, all of the following:

a) Beginning January 1, 2015 and to December 31, 2017, a 70% mercury emission reduction as measured from the 

mercury content of the fuel combusted or 0.0190 pounds per gigawatt-hour (lbs/GWh)

b) Beginning January 1, 2018 and to December 31, 2020, an 80% mercury emission reduction as measured from the 

mercury content of the fuel combusted or 0.0130 pounds per gigawatt-hour (lbs/GWh)

c) Beginning January 1, 2021, a 90% mercury emission reduction as measured from the mercury content of fuel 

combusted or 0.0080 pounds per gigawatt-hour (lbs/GWh)

(b) The permittee shall achieve compliance with these limitations by either of the following methods:

(i) Unit-by-unit compliance: Demonstrating that the mercury, NOx and SO2 emissions from each coal-fired EGU meet the 

applicable emission limitations using the measurement methods and calculation procedures in condition I.XXX.11.a.(4).

(ii) Unit averaging: Demonstrating for each pollutant, the sum of the emissions from all coal-fired EGUs subject to these 

emission limitations do not exceed the sum of the annual allowable mercury, NOx or SO2 emissions for the coal-fired EGUs 

using the measurement methods and calculation procedures in condition I.XXX.11.a.(4).

(c) The permittee shall identify each EGU for which they are electing this alternative in the submittal required by paragraph 

(3) below.

[ss. NR 446.14 and NR 446.17(2), Wis. Adm. Code]

(3) * Emission Limitation Election: 

(a) No later than December 31, 2010 the permittee shall identify for each affected EGU, the applicable mercury emission 

limitations in this section including an elections made under condition (2) above. This identification shall be submitted to the 

department in writing.

(b) Within 90 days after the receipt of the submittal required by (a), the department shall notify the permittee in writing of the 

emission limitation designations for each affected coal-fired EGU.

(c) Designations by the department under paragraph (b) shall establish the mercury emission limitation requirements.

[s. NR 446.17(2), Wis. Adm. Code]

 164 Sources are considered regulated by 40 CFR Part 63 Subpart UUUUU as of the date that the source must comply with the 

applicable requirements. For existing sources, this date is April 16, 2015 (see 40 CFR s.63.9984(b)).

165 A large coal-fired EGU means an electric generating unit serving a generator with nameplate capacity 150 megawatts and 

greater, pursuant to s. NR 446.10(7), Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 223

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(4) * Emission Determination and Compliance Demonstration: 

(a) Monitoring Requirements: For each affected coal-fired EGU, the permittee shall monitor emissions, heat input, electricity 

generation and process thermal energy, as required to demonstrate compliance, according to the following methods and 

specifications: [s. NR 446.18(1), Wis. Adm. Code]

(i) For NOx and SO2, hourly mass emissions according to 40 CFR part 75 and 40 CFR part 75, Appendices A to I, 

incorporated by reference in ss. NR 484.03(7) and 484.04 (27) respectively. 

(ii) For mercury, hourly mass emissions using continuous emission monitoring. By December 31, 2013, the department 

shall promulgate rules that specify the requirements for continuous emission monitoring for purposes of this paragraph. 

(Note: On February 8, 2008, the U.S. District Court of Appeals for the D.C. Circuit vacated rules the department had 

intended to rely on related to continuous emission monitoring for mercury emissions. (See New Jersey, et. al. v. 

Environmental Protection Agency, D.C. Ct. App. No 05-1097, February 8, 2008.).) 

(iii) For heat input flow rate and hourly heat input, according to 40 CFR part 75 and 40 CFR part 75, Appendices A to I, 

incorporated by reference in ss. NR 484.03(7) and 484.04(27) respectively. 

(iv) For gross electric output, hourly megawatt-hours using continuous monitoring. 

(v) For process thermal energy input, hourly mmBtus delivered to the process using continuous monitoring. 

(b) Determining Annual Actual Emissions: For each affected coal-fired EGU, the permittee shall determine annual mass of 

actual emissions for each pollutant as the sum of monitored emissions according to Equation 1. 

 ∑

=

=

n

i 1

Pactual Pmonitored Equation 1 

where: 

Pactual is the mass of mercury, NOx or SO2 emitted during the compliance year 

Pmonitored is the mass of mercury, NOx or SO2 emissions monitored and determined for each hour i the EGU is operated during 

the compliance year 

n is the number of hours the EGU is operating during the compliance year 

[s. NR 446.18(2), Wis. Adm. Code]

(c) Determining Annual Fuel Mercury Content: For each affected coal-fired EGU, the permittee shall determine the annual 

mass of mercury contained in all combusted fuels, as required to demonstrate compliance, according to the following 

procedures: [s. NR 446.18(3), Wis. Adm. Code]

(i) Calculate the mass of mercury contained in each fuel for each month, according to Equation 2, as the mercury 

concentration in fuel combusted each month as determined following the procedures in s. NR 446.07 (1), (2) and (3) 

according to solid and non-solid types of fuel, multiplied by the amount of fuel, in mmBtu, combusted each month as 

determined following the procedures in s. NR 446.07(4).

 Fuel Hgfm = HIfm × Hg Cfm Equation 2 

where: 

Fuel Hgfm is the mass of mercury contained in fuel f, in month m 

HIfm is the heat input of the combusted fuel f, in month m 

Hg Cfm is the mercury concentration for fuel f, in month m 

(ii) Calculate the annual mass of mercury, according to Equation 3, as the sum of mercury contained in all fuels 

combusted for all months during the compliance year. 

 

m

12

m 1

f

i 1

annual Fuel Hgi Fuel Hg ∑ ∑= = 













 = Equation 3 

where: 

Fuel Hgannual is the mass amount of mercury contained in all fuels combusted during the compliance year 

Fuel Hgi is the mercury mass content for fuel i, combusted in month m, during the compliance year determined in par. (i) 

f is number of fuels combusted during the compliance month 

{...Continued On Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 224

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(4) * Emission Determination and Compliance Demonstration: {... Continued from Previous Page...}

(d) Determining Annual Gross Output: For each affected coal-fired EGU, the permittee shall determine the annual gross 

energy output in gigawatt-hours, as required to demonstrate compliance, according to the following procedures: 

(i) Calculate the annual gross electric output in gigawatt-hours, according to Equation 4, as the sum of gross electric 

output measured in megawatt-hours for each hour the EGU is operating. 

 1,000

MWh

E 

n

i 1

i

GWh

∑

= = Equation 4 

where: 

EGWh is the total annual gross electric output in GWh 

MWhi is the gross electric output in MWh for each hour i the EGU operated during the compliance year 

1,000 is the factor to convert MWh to GWh

n is the number of hours the EGU operated during the compliance year 

(ii) Calculate the annual amount of useful thermal energy in mmBtu, according to Equation 5, as the sum of the process 

thermal energy input for each hour the EGU is operated multiplied by the process energy efficiency. 

 ∑

=





 



 = ×

n

i 1

annual i 100

PEE UTE PTEI Equation 5 

where: 

UTEannual is the annual amount of thermal energy, in mmBtu, utilized in the cogeneration process 

PTEIi is the amount of thermal energy input, in mmBtu, made available to the cogeneration process for each hour i the 

EGU operated during the compliance year 

PEE is the process energy efficiency, expressed as a percent, measured for the EGU. A value of 50% may be assumed. 

n is the number of hours the unit operated during the year of compliance 

(iii) Calculate the annual gross energy output in mmBtu, according to Equation 6, as the sum of the annual gross 

electric output and the annual applied thermal energy converted to electric output. 

 3,413

UTE GEO E annual

GWh = GWh + Equation 6 

where: 

GEOGWh is the total annual gross energy output in GWh 

EGWh is the total annual gross electric output in GWh determined in par. (a) 

UTEannual is the total annual useful thermal energy in mmBtu determined in par. (b) 

3,413 is the factor to convert thermal energy in mmBtu to GWh 

[s. NR 446.18(4), Wis. Adm. Code]

{...Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 225

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(4) * Emission Determination and Compliance Demonstration: {... Continued from Previous Page...}

(e) Determining Annual Allowable Emissions: . Except as provided in s. NR 446.185, for each affected coal-fired EGU, the 

permittee shall, determine annual allowable emissions, as required to demonstrate compliance, according to the following 

procedures: 

(i) When achieving compliance on a unit-by-unit basis, use one of the following equations as applicable: 

a) For a percent reduction mercury emission limitation, Equation 7. 

 Hg Fuel Hg (1- Hg CE) allowable = annual × Equation 7 

where: 

Hgallowable is the mass of mercury emissions allowed for the compliance year 

Fuel Hgannual is the mass of mercury in fuel combusted during the compliance year as determined in par. (c)(ii).

Hg CE is the applicable requirement for percent mercury emission reduction divided by 100. 

b) For a mercury output emission limitation, Equation 8. 

 allowable GWh ELoutput Hg = GEO × Equation 8 

where: 

Hgallowable is the mass of mercury emissions in pounds allowed for the compliance year 

GEOGWh is the annual gross energy output during the compliance year as determined in sub. (4)(c) 

ELoutput is the applicable mercury output based emission limitation in pounds per GWh 

c) For a NOx or SO2 emission limitation, Equation 9. 

 p

h

i 1

Pallowable = ∑HIi × EL

=

 Equation 9 

where: 

Pallowable is the mass of NOx or SO2 emissions allowed for the compliance year 

HI is the amount of fuel, in mmBtu combusted each hour i, during the compliance year 

h is the number of hours fuel is combusted during the compliance year 

ELp is the applicable emission limitation of s. NR 446.14(1) for NOx or SO2 

(ii) When achieving compliance using unit averaging as allowed under s. NR 446.13(2)(b) or 446.14(2)(b), according to 

Equation 10: 

 ∑=

=

n

u 1

Unit Averaging Pallowable Pu Equation 10 

where: 

Unit Averaging Pallowable is the mass of mercury, NOx, or SO2 emissions allowed for each pollutant determined in par. (i) 

for each EGU participating in emissions averaging during the compliance year 

Pu is the lowest annual allowable mass of mercury, NOx or SO2 emissions allowed for the compliance year for each 

EGU as determined under par. (i) or applicable under any other enforceable state or federal requirement for each EGU 

participating in emissions averaging during the compliance year 

n is the number of EGUs participating in emissions averaging 

[s. NR 446.18(5), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 226

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(5) * Annual Compliance Report: Beginning March 1, 2015 and on or before March 1 of every year thereafter, the permittee 

shall prepare and submit a compliance report for the affected EGUs, for the previous year. The report shall include all of the 

following: [s. NR 446.17(1), Wis. Adm. Code]

(a) The actual mercury emissions and, if subject to NOx and SO2 emission limitations under condition (2), the actual NOx and 

SO2 emissions from each affected coal-fired EGU for the previous year following the methodology in condition 

I.XXX.11.a.(4).

(b) The designated emission limitations for each affected coal-fire EGU as identified in condition (3)(c).

(c) The amount of any early reduction emission credits certified under condition I.XXX.11.a.(6) and currently held by the 

permittee in pounds, and the amount of certified early reduction emissions being surrendered.

(d) A comparison of annual actual emissions (par. (a)) minus any surrendered early emission reduction credits (par (c)), to the 

designated annual allowable emission limitations identified in paragraph (b), for each affected coal-fired EGU.

(6) * Early Mercury Emission Reduction Credits: [s. NR 446.15, Wis. Adm. Code]

(a) The permittee may request that the department certify excess mercury emission reductions by affected coal-fired EGUs, as 

early emission reduction credits.

(b) The department may only certify emission reductions that meet either of the following criteria as early emission reduction 

credits:

(i) The department may only certify emission reductions achieved by major utilities in calendar years 2010 to 2014 in 

excess of the emission limitations in condition I.XXX.10.a.(1).

(ii) Emission reductions achieved in calendar years 2015 to 2020 from coal-fired EGUs subject to the emission 

limitations in condition I.XXX.11.a.(2) in excess of the applicable emission limitation in I.XXX.11.a.(2)(a)(iii)a) or b).

(c) Beginning March 1, 2011, and on or before March 1, 2021, the permittee may request in the annual compliance required by 

condition (5), that the department certify excess mercury reductions from the previous calendar year as early emission 

reduction credits. The department shall provide written notice within 60 days of the receipt of a request approving or denying 

the early emission reduction credit request.

(d) The department shall certify the emission reductions, in terms of pounds of mercury emissions reduced, as early emission 

reduction credits if the permittee demonstrate to the department that the reductions are actual mercury emission reductions that 

are not required under any stat or federal law, court order or air permit condition.

(e) Certified mercury emission reduction credits may be used by the permittee of a coal-fired EGU to meet the annual mercury 

emission limitations in I.XXX.11.a.(2)(a)(iii) provided the amount of certified mercury emission reduction credits surrendered 

does not exceed 10% of the applicable emission limitation, in pounds.

(f) The department will maintain an ongoing record of the early mercury emission reduction credits certified and surrendered

to achieve compliance with the emission limitations in condition I.XXX.11.a.(2)

(7) * Electric Reliability Compliance Extension: [s. NR 446.16, Wis. Adm. Code]

(a) The permittee may request an extension to achieve compliance with the applicable mercury, NOx or SO2 emission 

limitations in conditions I.XXX.11.a.(1) and (2).

(b) The department may grant an extension if, in consultation with the public service commission, the department determines 

that the information submitted by the permittee supports a conclusion that without the extension a major electrical supply 

disruption is likely to occur. 

(c) An extension may not be granted beyond January 1, 2017.

(d) The permittee shall submit a written request for extension to the department at the time the emission limitation election 

required by condition I.XXX.11.a.(3) is provided.

(e) The request shall provide sufficient information concerning the conditions on which the request is based to demonstrate to 

the department’s satisfaction that an extension is warranted. In addition, the request shall include all of the following:

(i) The proposed control equipment installation schedule for all affected coal-fired EGUs.

(ii) The additional period of time being requested.

(iii) The alternative annual emission limitations for mercury, NOx or SO2 that will be achieved during the period of the 

requested extension.

(iv) The reasons why the permittee is unable to meet the January 1, 2015 compliance schedule and emission limitations 

in conditions I.XXX.11.a.(1) or (2).

(f) Within 180 days after the receipt of a complete request the department shall notify the applicant in writing of the reasons 

for denying, approving, or conditionally approving the request.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 227

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(8) * Large Coal-fired Electric Generating Unit Variance:

(a) The permittee may request a variance from the emission reduction requirements of conditions I.XXX.11.a.(1) and (2) by 

submitting a written request to the department and commission. The request shall provide sufficient information concerning 

the conditions or special circumstances on which the variance request is based to demonstrate to the department’s satisfaction 

that a variance from the applicable requirements is necessary. In addition the request shall include the following:

(i) Where an alternative compliance schedule is sought, the permittee shall submit a proposed schedule which demonstrates 

reasonable further progress and contains a date for final compliance as soon as practicable.

(ii) Where an alternative reduction requirement is sought, the permittee shall submit a proposed reduction requirement.

(iii) Requests for variances shall contain relevant information on the costs and technological feasibility of meeting the 

reduction requirements as required by the department.

(b) Requests for a variance shall be received 12 months in advance of an emission reduction requirement is conditions 

I.XXX.11.a.(1) or (2) or as established under I.XXX.11.a.(7).

(c) The department may grant a variance that sets an alternative reduction requirement or schedule, or both.

(d) The department may grant a variance if the permittee demonstrates to the department’s satisfaction that the reduction 

requirements are technologically or economically infeasible.

(e) The department may grant a variance that sets an alternative schedule if the permittee demonstrates to the department’s 

satisfaction that the delay is needed to complete installation and place into operation control technology to achieve compliance 

with a reduction requirement.

(f) Within 90 days of the receipt of a complete request, the department shall publish a public notice on each variance request 

and the department’s preliminary determination to grant or deny the request, to provide opportunity for public comments 

including, where requested, a public hearing on the variance request. Following the public comment period, the department 

shall notify the permittee in writing of the reasons for denying, granting or for granting in a modified form any request for a 

variance.

(g) The department may, after notice and opportunity for hearing, revoke or modify any variance when any term or condition 

of the variance has been violated.

[s. NR 446.165, Wis. Adm. Code]

(9) * Compliance Alternatives: 

(a) Alternative Annual Allowable Mercury Emissions: [s. NR 446.185(1), Wis. Adm. Code] 

(i) The permittee may use baseline mercury emissions approved by the department as an alternative to procedures in 

condition I.XXX.11.a.4.(e)(i) in determining annual allowable mercury emissions. 

(ii) Baseline mercury emissions shall be determined and used for calculating annual allowable mercury emissions for 5-

year periods beginning with the period of 2015 to 2019. Baseline mercury emissions shall be determined every 5 years 

and used to calculate annual allowable mercury emissions for the subsequent 5-year period. 

(iii) Baseline mercury emissions for each 5-year period shall be determined using fuel mercury content data measured 

for the calendar year which is 2 years prior to the first year of the applicable 5-year period. The year designated for 

measuring fuel mercury content is the baseline determination year. 

Note: Baseline emissions are measured for 2013 for determining the annual allowable emissions for compliance years 

2015 to 2019, measured for 2018 for determining allowable emissions for compliance years 2020 through 2024, etc. 

(iv) No later than May 1 of the calendar year after the baseline determination year, the permittee shall submit a report to 

the department that includes information necessary to determine the baseline mercury emissions for that 5-year period. 

(v) In the report required under par. (d), the permittee may request alternative data be used for determining baseline 

emissions if the data for the specified year is not representative of the EGU's normal operations or maintenance 

schedule. 

{...Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 228

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(9) * Compliance Alternatives: 

(a) Alternative Annual Allowable Mercury Emissions: {...Continued from Previous Page...}

(vi) Baseline mercury emissions for each EGU shall be determined according to the following procedures: 

a) Measure and determine the fuel mercury content according to requirements of condition I.XXX.11.a.(4)(c) for all 

fuels combusted in the EGU for the baseline determination year. 

b) Calculate the baseline mercury concentration, on a mmBtu-basis, for the baseline determination year according to 

Equation 11. 

 

HI

Fuel Hg BMC h

i 1

i

annual

∑

=

=

 Equation 11 

where: 

BMC is the average baseline mercury concentration of fuel, in pounds per mmBtu, contained in the fuels combusted 

in the EGU during the baseline determination year 

Fuel Hgannual is the total mass of mercury contained in the fuel determined in subd. a). 

HI is the total amount of fuel, in mmBtu, consumed each hour i, during the baseline determination year 

h is the total number of hours fuel is consumed during the baseline determination year 

c) Calculate the baseline mercury emissions according to Equation 12 as the baseline mercury concentration times the 

3-year average of annual fuel consumption, in mmBtu, for the baseline determination year and 2 years prior to the 

baseline determination year. 

 

3

HI

BME BMC

3

y 1 y

h

i 1

i

 

∑ ∑= = 















= × Equation 12 

where: 

BME is the baseline mercury emissions for the EGU in pounds 

BMC is the baseline mercury concentration for the EGU determined in subd. b)., in pounds per mmBtu. 

HI is the amount of fuel, in mmBtu combusted in the EGU for each hour i during each year y 

h is the total number of hours fuel is combusted in the EGU during each year 

(vii) When determining annual allowable mercury emissions for achieving compliance on a unit-by-unit basis, use one of 

the following equations as applicable: 

a) For a percent reduction mercury emission limitation, Equation 13. 

 Hg BME (1- Hg CE) allowable = × Equation 13 

where: 

Hgallowable is the mass of mercury emissions allowed for the EGU for the compliance year 

BME is the baseline emissions for the EGU as determined in par. (vi)c). 

Hg CE is the applicable requirement for percent mercury emission reduction divided by 100. 

b) For a mercury output emission limitation, Equation 14. 

 





























= × × ×

∑

=

GWh

h

i 1

i

allowable GWh E

HI

Hg GEO BMC (1- Hg CE)

 Equation 14 

where: 

Hgallowable is the mass of mercury emissions allowed for the compliance year 

GEOGWh is the annual gross energy output of the EGU, in GWh, as determined in s. NR 446.18(4) for the compliance 

year 

BMC is the baseline mercury concentration determined in par. (vi)c). for the EGU in pounds per mmBtu 

Hg CE is the applicable requirement for percent mercury control removal divided by 100 

HI is the amount of fuel, in mmBtu combusted each hour i, in the baseline determination year 

h is the total number of hours fuel is combusted during the calendar year designated for measuring baseline emissions 

data under par. (iii) 

EGWh is the annual gross electric output, in GWh, for the baseline determination year calculated according to s. NR 

446.18(4)(a)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 229

XXX. Conditions Applicable to the Entire Facility

Condition Type: 11. Control of Mercury Emissions from Coal-Fired Electric Generating Units * {CONTINUED}

a. Conditions:

(9) * Compliance Alternatives: {...Continued from Previous Page...}

(b) Alternative SO2 Compliance Determination: 

(i) The permittee may demonstrate compliance with the SO2 emission limitation in condition I.XXX.11.a.(2)(a) by 

demonstrating a minimum SO2 control efficiency equal to or greater than 90% removal of sulfur from fuels combusted in the 

affected EGU each year, excluding startup and shutdown, using a method approved by the department.

(ii) If electing to demonstrate compliance according to paragraph (i), the permittee shall submit an SO2 compliance 

demonstration procedure for department approval no later than October 1, 2013. The compliance procedure shall include test 

methods to determine sulfur removal from fuel and operating and parametric monitoring procedures to ensure continuous 

operation of control equipment consistent with maintaining the required control efficiency.

[s. NR 446.185(2), Wis. Stats.]

(c) Alternative Methods and Procedures: The permittee may use methods and procedures in determining annual allowable 

emissions as approved by the department to account for any of the following:

(i) The contribution to mercury emissions by non-fuel materials inherent to pollution control processes. The contribution to 

the annual allowable emissions may not exceed the amount calculated when substituting annual mercury content of non-fuel 

materials for annual fuel mercury content in Equation 7 in this permit section.

(b) When monitoring or implementing control equipment for a stack serving multiple EGUs.

[s. NR 446.185(3), Wis. Stats.]

(10) * Mercury Emission Limits for Small Coal-Fired Electric Generating Units (EGUs):166

(a) Beginning January 1, 2015, an owner or operator of a small coal-fired EGU shall limit mercury emissions to a level that is 

determined by the department to be the best available control technology. 

(b) Notwithstanding (a), an owner or operator may elect to have a small coal-fired EGU comply with the mercury emission 

limits in I.ZZZ.11.(1) or (2) in accordance with I.ZZZ.11.(3)(b).

(c) BACT Determination for Small Coal-Fired Electric Generating Units:

(i) No later than June 30, 2011, owners or operators of small coal-fired EGUs shall provide the department with a 

preliminary BACT determination.

(ii) Notwithstanding (i), a small coal-fired EGU designated by the department under I.ZZZ.11.(3)(b) to meet the emission 

limitations in I.ZZZ.11.(1) or (2) are not required to provide a preliminary BACT determination.

(iii) The owner or operator shall submit the information required in (i) on the application form required for an operation 

permit, an amendment to an application, or renewal of the operation permit, as applicable.

(iv) Within 180 days after the receipt of the information in (iii), the department shall approve, conditionally approve, or 

disapprove the owner’s or operator’s preliminary BACT determination.

[ss. NR 446.12 and 446.17(3), Wis. Adm. Code]

Condition Type: 12. Continuous Monitoring Systems (CMS)

a. Conditions:

(1) For all Continuous Emission Monitoring Systems (CEMS) required by this permit:

(a) The permittee shall submit a quality control and quality assurance plan for approval by the department. The monitor shall 

follow the plan, as approved by the department. [s. NR 439.095(6), Wis. Adm. Code]

(b) The permittee shall comply with the quality control and quality assurance plan submitted by the owner or operator of the

source and approved by the department. [s. NR 439.09(8), Wis. Adm. Code and permits 06-SDD-102, 07-SDD-301, 03-RV248-R4]

 166 A small coal-fired EGU means an electric generating unit serving a generator with a nameplate capacity greater than 25 

megawatts but less than 150 megawatts, pursuant to s. NR 446.10(10), Wis. Adm. Code.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 230

XXX. Conditions Applicable to the Entire Facility

Condition Type: 13. 

a. Conditions:

This section intentionally left blank.

Condition Type: 14. Stack Parameters

a. Conditions:

(1) Each stack at the facility shall meet the respective requirements identified in Table 1 below.167

(a) The height of each stack above ground level shall be at least the height listed in column (a) of the table below;

(b) The inside diameter of each stack at its outlet may not exceed the diameter listed in column (b) of the table below; and

(c) The stacks identified with a “No” in column (c) of the table below may not be equipped with a rainhat or other device 

which impedes the upward flow of exhaust gas and shall exhaust upward.

[ss. 285.63(1)(b) and 285.65(3), Wis. Stats. and 03-RV-248-R4, 04-RV-128]

(2) Compliance Demonstration: The permittee shall keep and maintain on site technical drawings, blueprints or equivalent 

records of the physical stack parameters. [s. NR 439.04(1)(d), Wis. Adm. Code and 03-RV-248-R4, 04-RV-128]

Table 1 – Stack Parameter Requirements

(a) (b) (c)

Stack ID

Minimum Stack Height

(feet)

Maximum Inside Diameter 

(or equivalent diameter) 

(feet)

Obstruction or Non-vertical 

Flow Allowed? (yes/no)

Main Boilers:

S01 242.97 11.92 no

S02 242.6 11.92 no

S03 496.2 16.00 no

S04 500.0 20.00 no

Combustion Turbines:

S11 30.0 8.43 no

168

S12 23.0 8.10 no

169

S13 23.0 8.10 no

170

Auxiliary Boilers:

S21 126.17 1.42 yes

S22 230.0 4.00 no

S25 255.0 4.00 no

Stationary Reciprocating Internal Combustion Engines:

S11AL 14.5 0.50 yes

S11AU 15.7 0.50 yes

S11B 15.3 0.42 yes

S60 26.0 0.50 no

S27 34.5 0.67 no

S28 26.0 0.83 no

Heaters:

S63 14.5 0.83 yes

 167 These requirements are included because the source was reviewed with these stack parameters and it was determined that no ambient 

quality standards would be violated when operated as proposed. 

168 This stack has baffles at the stack exit, but the diameter and exhaust gas exit velocity were calculated taking into consideration 

these baffles. For the purposes of this requirement, these baffles do not constitute a “device that impedes the upward flow of the 

exhaust gases”.

169 Ibid. (Same as previous footnote.)

170 Ibid. (Same as previous footnote.)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 231

Table 1 – Stack Parameter Requirements

(a) (b) (c)

Stack ID

Minimum Stack Height

(feet)

Maximum Inside Diameter 

(or equivalent diameter) 

(feet)

Obstruction or Non-vertical 

Flow Allowed? (yes/no)

S64 17.0 0.83 yes

S67 20.9 1.35 yes

S68 20.4 1.35 yes

S69 49.78 0.33 yes

S70 49.78 0.33 yes

Cooling Towers:

S24A 56.1 30.0 no

S24B 56.1 30.0 no

S24C 56.1 30.0 no

S24D 56.1 30.0 no

S24E 56.1 30.0 no

S24F 56.1 30.0 no

S24G 56.1 30.0 no

S24H 56.1 30.0 no

S26A 62.8 34.20 no

S26B 62.8 34.20 no

S26C 62.8 34.20 no

S26D 62.8 34.20 no

S26E 62.8 34.20 no

S26F 62.8 34.20 no

S26G 62.8 34.20 no

S26H 62.8 34.20 no

S26I 62.8 34.20 no

S26J 62.8 34.20 no

S26K 62.8 34.20 no

S26L 62.8 34.20 no

Dust Collectors / Bin Vents:

S31A 60.0 5.16 no

S31B 60.0 5.16 no

S31C 42.5 2.12 yes

S32A 71.8 2.69 yes

S32B 74.7 2.67 yes

S32C 35.8 0.67 yes

S32D 227.7 4.02 yes

S32E 227.7 4.02 yes

S34 65.0 2.17 no

S35A 40.0 1.50 no

S35B 147.0 2.63 no

S36A 31.1 1.00 yes

S36B 89.9 1.25 yes

S37A 46.69 0.67 no

S37B 105.2 1.70 yes

S39 31.4 0.93 no

S30 35.0 2.17 no

S41 75.0 3.83 no

S42 95.0 2.17 no

S43 250.0 4.83 no

S44 69.5 1.46 yes

S45 82.0 1.46 yes

S49 123.0 1.50 yes

S50 120.0 2.01 yes

S65 72.5 0.67 no
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 232

Table 1 – Stack Parameter Requirements

(a) (b) (c)

Stack ID

Minimum Stack Height

(feet)

Maximum Inside Diameter 

(or equivalent diameter) 

(feet)

Obstruction or Non-vertical 

Flow Allowed? (yes/no)

S66 72.5 0.67 no

Welding Shops:

S61 38.46 2.0 no

S62 37.0 2.0 no
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 233

YYY. Specific Conditions Applicable to all WPSC Facilities

1. Pollutant: Sulfur Dioxide (SO2)*

a. Limitations:

(1) Corporate Emission Limitation: The average number of pounds of sulfur dioxide emissions per million BTU of heat input 

from all boilers under the ownership or control of the permittee for any year may not exceed 1.20.

[WPSC is considered a major utility as defined in s. 285.41(1)(f), Wis. Stats. The total sulfur dioxide emissions from all 

stationary sources in Wisconsin that are owned or controlled by WPSC have exceeded 5000 tons per year after 1979. As a 

result, WPSC is subject to s. 285.41(2), Wis. Stats. Which sets a corporate emission limit on the average pounds of sulfur 

dioxide emissions per million BTU of heat input from all boilers under the ownership or control of WPSC. The corporate 

emission limit is 1.20 pounds per million BTU of heat input. The corporate emission limit does not affect the emission limits of 

individual emission units under control of WPSC and is enforced separately from the emission limits on individual emission 

units.] [s. 285.41(2), Wis. Stats.]*

(2) WPSC shall prepare an annual sulfur dioxide emission summary that outlines compliance status with the corporate 

emission limit in condition I.YYY.1.a.(1) for each calendar year. [s. 285.41(6), Wis. Stats.]*

(3) Alternate Scenario - Trading to Comply with Condition I.YYY.1.a.(1):

(a) Two major utilities (as defined in s. 285.41(1)(f), Wis. Stats.) may enter into an agreement for trading emissions unless the 

sum of the proposed traded emissions and the projected annual emissions of the grantor major utility for the year to which the 

agreement will apply would exceed the actual annual emissions for the grantor major utility in 1985.

(b) To determine whether the major utility that is the grantor in an agreement is in compliance with the emission rate in 

condition I.YYY.1.a.(1) in a given year, the Department shall add the traded emissions and the grantor's annual emissions and

divide the sum by the annual heat input of the grantor.

(c) To determine whether the major utility that is the grantee in an agreement is in compliance with the emission rate in 

condition I.YYY.1.a.(1) in a given year, the Department shall subtract the traded emissions from the grantee's annual emissions 

and divide the difference by the annual heat input of the grantee. [s. 285.41(2)(b), Wis. Stats.]*

(4) Alternate Scenario – Variance: WPSC may request a variance from the emission rate in condition I.YYY.1.a.(1) according 

to the following conditions:

(a) WPSC may request a variance from the emission rate in condition I.YYY.1.a.(1) if the Department has not served WPSC 

with written notice under s. 285.83, Wis. Stats., that WPSC has violated condition I.YYY.1.a.(1); and

(b) if any of the following variance conditions exist:

1. A major electrical supply emergency within or outside this state.

2. A major fuel supply disruption.

3. An extended and unplanned disruption in the operation of a nuclear plant or low sulfur coal-fired boiler under the ownership 

or control if the major utility.

4. The occurrence of an uncontrollable event not anticipated in the plan submitted under conditions I.YYY.1.b.(1) and 

I.YYY.1.c.(1).

5. A plan by WPSC to install and place into operation new technological devices that will enable it to achieve compliance with 

condition I.YYY.1.a.(1).

(c) With the request for a variance, WPSC shall submit its plan for achieving compliance with condition I.YYY.1.a.(1).

(d) If the request is based on the variance conditions specified under condition I.YYY.1.a.1.b.(1) through (5)., the request shall 

include an explanation of why the major utility cannot achieve or remain in compliance by using fuel with a lower sulfur 

content or by environmental dispatching. [s. 285.41(4), Wis. Stats.]*

{Continued on Next Page...}
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 234

YYY. Specific Conditions Applicable to all WPSC Facilities

1. Pollutant: Sulfur Dioxide (SO2)* - {Continued)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Annual Compliance Plan – Each year WPSC shall prepare 

an annual plan for achieving compliance with the emission 

rate under condition I.YYY.1.a.(1) that includes, at a 

minimum:

(a) WPSC's expected electricity demand;

(b) WPSC's annual operation plan;

(c) The expected operation characteristics of each boiler 

operated by WPSC, including:

1. The order to be used in placing boilers into operational 

production,

2. The planned maintenance schedule for each boiler,

3. How any maintenance is expected to affect the methods of 

meeting electricity demands,

4. The amount of coal and other fossil fuels or other materials 

to be used for each boiler in operational production,

5. The sulfur content (in pounds of sulfur dioxide per million 

BTU of heat input) of coal and other fossil fuels or other 

materials to be used for each boiler in operational production,

6. The anticipated sulfur dioxide emissions from each boiler,

7. Contingency plans for unexpected events or increased 

demand including a summary of generation costs and the 

anticipated additional costs for reducing sulfur dioxide 

emissions under those circumstances,

8. The methods that will be used to achieve compliance with 

condition I.YYY.1.a.(1) in the following year including, if 

applicable, the provisions of any trading agreement under s. 

285.41(2)(b)1), Wis. Stats.,

9. The total anticipated annual sulfur dioxide emissions from 

all boilers under the ownership or control of the permittee for 

each of the next three (3) years. [s. 285.41(3)(a), Wis. Stats.]*

(1) WPSC shall submit a copy of the Annual Compliance Plan 

required by condition I.YYY.1.b.(1) on or before October 1 of 

each year for the following calendar year to:

(a) The Wisconsin Department of Natural Resources, Bureau 

of Air Management, 101 South Webster Street, P.O. Box 

7921 (AM/7), Madison, WI 53707-7921; and

(b) The Wisconsin Public Service Commission, 610 North 

Whitney Way, Madison, WI 53705. [s. 285.41(3)(a), Wis. 

Stats.]*

(2) The annual sulfur dioxide emission summary required by 

condition W(1)(b)2) shall be submitted by March 1 for the 

preceding calendar year to:

(a) The Wisconsin Department of Natural Resources, Bureau 

of Air Management, 101 South Webster Street, P.O. Box 

7921 (AM/7), Madison, WI 53707 - 7921; and

(b) The Wisconsin Public Service Commission, 610 North 

Whitney Way, Madison, WI 53705. [s. 285.41(6), Wis. 

Stats.]*

(3) Any requests for variance described in condition 

I.YYY.1.a.(4) shall be submitted to:

(a) The Wisconsin Department of Natural Resources, Bureau 

of Air Management, 101 South Webster Street, P.O. Box 

7921 (AM/7), Madison, WI 53707- 7921; and

(b) The Wisconsin Public Service Commission, 610 North 

Whitney Way, Madison, WI 53705. [s. 285.41(4), Wis. 

Stats.]*
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 235

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

Issued to: Weston Plant

ORIS Code: 4078

Unit ID# [Provided by the National 

Allowance Database for the Federal 

Acid Rain Program.]

OWNED AND OPERATED BY: NEW UNIT - Commence 

Operation Date

[NA = Not Applicable]

NEW UNIT - Monitor 

Certification Deadline

1 Wisconsin Public Service Corporation NA NA

2 Wisconsin Public Service Corporation NA NA

3 Wisconsin Public Service Corporation NA NA

Duty to Reapply: The designated representative shall submit a complete acid rain portion of an operation permit application at 

least 12 months, but not more than 18 months, before this permit expires. [s. NR 409.08(1)(c), Wis. Adm. Code]

Permit Shield: Operation in accordance with the acid rain portion of this operation permit shall be deemed to be operation in 

compliance with the acid rain program, except as provided in s. NR 409.06(7)(f), Wis. Adm. Code. [s. NR 409.10(2), Wis. 

Adm. Code]

Contents:

1. Statement of Basis

2. Unit Specific Requirements

3. Standard Requirements

4. General Requirements

5. Comments, notes and justifications regarding permit decisions.

1. Statement of Basis Statutory and Regulatory Authorities: This portion of the operation permit is issued pursuant to ss. 

285.60 to 285.66, Wis. Stats., Titles IV and V of the federal Clean Air Act (42 USC 7651 to 7661f), and chs. NR 407 and 409, 

Wis. Adm. Code
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 236

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

2. Specific Requirements for Units 1, 2 and 3

a. Sulfur Dioxide

(1) Limitation: (2) Compliance Plan:

(a) Sulfur dioxide emissions from EACH unit may not exceed 

the number of allowances that the source lawfully holds under 

the acid rain program, including allowances allocated directly 

to the source through the acid rain program and allowances 

obtained through the emissions trading provisions of the acid 

rain program, subject to the following qualifications:

(i) No permit revision may be required for increases in 

emissions that are authorized by allowances acquired pursuant 

to the acid rain program, provided that the increases do not 

require a permit revision under any other applicable 

requirement;

(ii) No limit may be placed on the number of allowances that 

may be held by the stationary source;

(iii) A stationary source may not use allowances as a defense 

to noncompliance with any applicable requirements other than 

the requirements of the acid rain program; and

(iv) Any acid rain allowance shall be accounted for according 

to the procedures established in the acid rain program. [s. NR 

407.09(2)(a), Wis. Adm. Code]

(2) The permittee shall operate EACH unit in compliance 

with the standard sulfur dioxide requirements of condition 3.c. 

of the acid rain portion of this permit. [s. NR 409.06(3)(a)2, 

Wis. Adm. Code]

(a) The permittee shall, as of the allowance transfer deadline, 

hold allowances in the facility’s compliance account [after 

deductions under 40 CFR 73.34(c)] not less than the total 

annual emissions of sulfur dioxide for the previous calendar 

year from the affected units at the facility. The permittee is 

not applying for any compliance options under 40 CFR 

72.40(b) or s. NR 409.09(1)(b), Wis. Adm. Code.171

[The allowance transfer deadline is midnight of the 60th day 

after the end of the calendar year if such date is a business 

day. If not, the deadline is midnight of the first business day 

thereafter.]

[40 CFR 72.9(c)(1)(i) and s. NR 409.06(3)(a)1., Wis. Adm. 

Code]

 171 This federal provision is an update of the earlier federal acid rain rule that is currently reflected in s. NR 

409.06(3)(a)1. Compliance with the federal rule satisfies this state requirement.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 237

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

2. Specific Requirements for Units 1, 2 and 3 - {Continued}

b. Nitrogen Oxides

(1) Limitation: (2) Compliance Plan:

(1) The owner or operator may not discharge, or allow to be 

discharged, emissions of NOx in excess of the following limits:172

(a) Unit 1: 0.50 pounds per million Btu of heat input on an annual 

average basis;

(b) Unit 2: 0.50 pounds per million Btu of heat input on an annual 

average basis;

(c) Unit 3: 0.45 pounds per million Btu on an annual average basis.

[ss. NR 409.06(4) and NR 409.065(2), Wis. Adm. Code]

 172 Previously, Wisconsin Public Service Corporation operated under a Phase II Nitrogen Oxide Averaging Plan 

which included Units 3 through 8 at the J.P. Pulliam Plant and Units 1 through 3 at the Weston Plant. The Nitrogen 

Oxide Averaging Plan expired in 2013 and has not been renewed with US EPA. Under that averaging plan WPSDC 

requested alternative contemporaneous emission limits for Units 1 through 3 at the Weston Plant. The applicable 

limitations are 0.50 pounds per million BTU for Units 1 through 2 and 0.45 pounds per million BTU for Unit 3.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 238

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

3. Standard Requirements for all Affected Units

a. Permit Requirements

(1) The designated representative of each affected source and each affected unit at the source shall:

(a) Except for a phase I acid rain permit to be issued by U.S. EPA, submit a complete acid rain portion of an operation permit 

application (including a compliance plan) under 40 CFR part 72 and ch. NR 409, Wis. Adm. Code in accordance with the 

deadlines specified in s. NR 409.08(1), Wis. Adm. Code and 40 CFR 72.30; and

(b) Submit in a timely manner any supplemental information that the Department determines is necessary in order to review an 

acid rain portion of an operation permit application and issue or deny an acid rain portion of an operation permit application. [s. 

NR 409.06(1)(a), Wis. Adm. Code]

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

(a) Operate the unit in compliance with a complete acid rain portion of an operation permit application or a superseding acid

rain portion of an operation permit issued by the Department; and

(b) Have an acid rain portion of an operation permit. [s. NR 409.06(1)(b), Wis. Adm. Code]

b. 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 parts 74, 75, and 76 and section 407 of 

the act (42 USC 7651f) and regulations implementing section 407 of the act. [s. NR 409.06(2)(a), Wis. Adm. Code]

(2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 and section 407 of the act (42 USC 

7651f) and regulations implementing section 407 of the act 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. 

[s. NR 409.06(2)(b), Wis. Adm. Code]

(3) The requirements of 40 CFR parts 74 and 75 and regulations implementing section 407 of the act (42 USC 7651f) do 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 operation permit for the source. [s. NR 

409.06(2)(c), Wis. Adm. Code]

c. Sulfur Dioxide Requirements

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

(a) Hold allowances, as of the allowance transfer deadline, in the facility's compliance account, after deductions under 40 CFR 

73.34(c), not less than the total annual emissions of sulfur dioxide for the previous calendar year from the affected units at the 

facility;173 and

(b) Comply with the applicable acid rain emissions limitations for sulfur dioxide. 

[40 CFR 72.9(c)(1)(i) and s. NR 409.06(3)(a), Wis. Adm. Code]

(2) Each ton of sulfur dioxide emitted in excess of the acid rain emissions limitations for sulfur dioxide shall constitute a 

separate violation. [s. NR 409.06(3)(b), Wis. Adm. Code]

(3) An affected unit shall be subject to the requirements under condition 3.c.(1) of the acid rain portion of this permit as 

follows:

(a) Starting January 1, 2000, for an affected unit under s. NR 409.01(1)(a)2., Wis. Adm. Code; or

(b) Starting on the later of January 1, 2000 or the monitor certification deadline under 40 CFR part 75, for an affected unit 

under s. NR 409.01(1)(a)3, Wis. Adm. Code. [s. NR 409.06(3)(c), Wis. Adm. Code]

(4) Allowances shall be held in, deducted from, or transferred among allowance tracking system accounts in accordance with 

the acid rain program. [s. NR 409.06(3)(d), Wis. Adm. Code]

(5) An allowance may not be deducted in order to comply with the requirements under condition 3.c.(1)(a) of this permit prior 

to the calendar year for which the allowance was allocated. [s. NR 409.06(3)(e), Wis. Adm. Code]

{Continued on Next Page...}

 173 This federal provision is an update of the earlier federal acid rain rule that is currently reflected in s. NR 

409.06(3)(a). Compliance with the federal rule satisfies the state requirement.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 239

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

3. Standard Requirements for all Affected Units – {Continued}

c. Sulfur Dioxide Requirements – {Continued}

{...Continued from Previous Page...}

(5) An allowance may not be deducted in order to comply with the requirements under condition 3.c.(1)(a) of this permit prior 

to the calendar year for which the allowance was allocated. [s. NR 409.06(3)(e), Wis. Adm. Code]

(6) An allowance allocated by the U.S. EPA 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 portion of an operation permit 

application, the acid rain portion of an operation permit or the written exemption under ss. NR 409.04 and 409.05, Wis. Adm. 

Code and no provision of law shall be construed to limit the authority of the United States to terminate or limit such 

authorization. [s. NR 409.06(3)(f), Wis. Adm. Code]

(7) An allowance allocated by the U.S. EPA under the acid rain program does not constitute a property right. [s. NR 

409.06(3)(g), Wis. Adm. Code]

d. Nitrogen Oxide Requirements

(1) The owners and operators of the source and each affected unit at the source shall comply with the applicable acid rain 

emission limitation for nitrogen oxides.

[s. NR 409.06(4), Wis. Adm. Code, is based on the Nitrogen Oxide Requirements set forth in 40 CFR Part 76 which requires 

the owners and operators of an affected unit at a source to comply with the applicable acid rain emission limitations for 

nitrogen oxides.]

e. 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 to the U.S. EPA, as required under 40 CFR part 77, and submit a copy to the Department. [s. NR 409.06(5)(a), Wis. 

Adm. Code]

(2) The owners and operators of an affected unit that has excess emissions in any calendar year shall:

(a) Pay to the U.S. EPA without demand the penalty required, and pay to the U.S. EPA upon demand the interest on that 

penalty, as required by 40 CFR part 77; and

(b) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. [s. NR 409.06(5)(b), Wis. Adm. Code]

f. 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 U.S. EPA or the Department:

(a) 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;

(b) All emissions monitoring information, in accordance with 40 CFR part 75;

(c) Copies of all reports, compliance certifications, and other submissions and all records made or required under the acid rain 

program; and,

(d) Copies of all documents used to complete an acid rain portion of an operation permit application and any other submission

under the acid rain program or to demonstrate compliance with the requirements of ch. NR 409, Wis. Adm. Code and the acid 

rain program. [s. NR 409.06(6)(a), Wis. Adm. Code]

(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 s. NR 409.13, Wis. Adm. Code and 40 

CFR part 75. [s. NR 409.06(6)(b), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 240

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

3. Standard Requirements for all Affected Units – {Continued}

g. Liability

(1) Any person who knowingly violates any requirement or prohibition of the acid rain program, a complete acid rain portion 

of an operation permit application, an acid rain portion of an operation permit, or a written exemption under ss. NR 409.04 and 

NR 409.05, Wis. Adm. Code shall be subject to enforcement by the Department pursuant to ch. NR 494, Wis. Adm. Code and 

ss. 285.83 and 285.87, Wis. Stats. Any person who knowingly violates any requirement or prohibition of the acid rain program, 

a complete acid rain portion of an operation permit application, an acid rain portion of an operation permit, or a written 

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 by the U.S. EPA pursuant to s. 113(c) of the Clean Air Act. [s. NR 409.06(7)(a), Wis. Adm. Code]

(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 by the Department pursuant to ch. NR 494, Wis. Adm. Code and ss. 285.83 

and 285.87, Wis. Stats. 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 by the U.S. EPA pursuant to s. 113(c) of the Clean Air 

Act and 18 U.S.C. 1001. [s. NR 409.06(7)(b), Wis. Adm. Code]

(3) No permit revision may excuse any violation of the requirements of ch. NR 409, Wis. Adm. Code, and the acid rain 

program that occurs prior to the date that the revision takes effect. [s. NR 409.06(7)(c), Wis. Adm. Code]

(4) Each affected source and each affected unit shall meet the requirements of ch. NR 409, Wis. Adm. Code, and the acid rain 

program. [s. NR 409.06(7)(d), Wis. Adm. Code]

(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. [s. NR 409.06(7)(e), Wis. Adm. Code]

(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 s. NR 

409.09(2), Wis. Adm. Code, 40 CFR 72.44 (Phase II repowering extension plans) and 40 CFR part 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 are not 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. [s. NR 409.06(7)(f), Wis. Adm. 

Code]

(7) Each violation of a provision of ch. NR 409, Wis. Adm. Code and 40 CFR parts 72, 73, 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. [s. NR 409.06(7)(g), Wis. Adm. Code]

h. Effect on Other Authorities

(1) No provision of the acid rain program, an acid rain portion of an operation permit application, an acid rain portion of an 

operation permit, or a written exemption under s. NR 409.04 or NR 409.05, Wis. Adm. Code, or 40 CFR part 72.7 or 72.8 may 

be construed as:

(a) Except as expressly provided in title IV of the act (42 USC 7651 to 7651o), 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;

(b) 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;

(c) Requiring a change of any kind in any state law regulating electric utility rates and charges, affecting any state law 

regarding the state regulation, or limiting the state regulation, including any prudence review requirements under state law;

(d) Modifying the federal power act (16 USC 791a et seq.) or affecting the authority of the federal energy regulatory 

commission under the federal power act; or,

(e) Interfering with or impairing any program for competitive bidding for power supply in a state in which the program is 

established. [s. NR 409.06(8), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 241

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

4. General Requirements for all Affected Units

a. Submissions

(1) The designated representative shall submit a certificate of representation, and any superseding certificate of representation, 

to the U.S. EPA in accordance with subpart B of 40 CFR part 72 and, concurrently, shall submit a copy to the Department. The 

designated representative may disregard this requirement if the aforementioned certificate has already been submitted to the 

U.S. EPA and the Department. [s. NR 409.07(1)(a), Wis. Adm. Code]

(2) Each submission under the acid rain program shall be submitted, signed and certified by the designated representative for 

all sources on behalf of which the submission is made. [s. NR 409.07(1)(b), Wis. Adm. Code]

(3) In each submission under the acid rain program, the designated representative shall certify, by his or her signature:

(a) The following statement, which shall be included verbatim in the submission: "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."

(b) The following statement which shall be included verbatim in the submission: "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 proof 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." [s. NR 409.07(1)(c), Wis. Adm. Code]

(4) The designated representative of a source shall serve notice on each owner and operator of the source and of an affected 

unit at the source:

(a) By the date of submission, of any acid rain program submissions by the designated representative;

(b) Within 10 business days of receipt of a determination, of any written determination by the U.S. EPA or the Department;

(c) Provided that the submission or determination covers the source or the unit. [s. NR 409.07(1)(e), Wis. Adm. Code]

(5) The designated representative of a source shall provide each owner and operator of an affected unit at the source a copy of 

any submission or determination under condition 4.b.(4) of the acid rain portion of this permit, unless the owner or operator 

expressly waives the right to receive a copy. [s. NR 409.07(1)(f), Wis. Adm. Code]

b. Acid Rain Portion of an Operation Permit Requirements

(1) The acid rain portion of this operation permit is a portion of the operation permit that is complete and segregable from all 

other air quality requirements and may not incorporate information contained in any other documents, other than documents 

that are readily available. [s. NR 409.11(1)(b), Wis. Adm. Code]

c. Appeal Procedures

(1) Appeals of the acid rain portion of this operation permit issued by the Department that do not challenge or involve 

decisions or actions of the U.S. EPA under 40 CFR parts 72, 73, 75, 77 and 78 and regulations implementing sections 407 and 

410 (42 USC 7651f and 7651i) of the act shall be conducted according to the procedures in ch. NR 407 and ss. 285.13(1), 

285.81 and 227.40 to 227.60, Wis. Stats. The permit shield under s. NR 409.10(2) shall continue to be in effect during the 

appeal process. Appeals of the acid rain portion of a permit that challenge or involve decisions or actions of the U.S. EPA shall 

follow the procedures under 40 CFR part 78 and section 307 of the act (42 USC 7607). Decisions or actions include, but are 

not limited to, allowance allocations, determinations concerning alternative monitoring systems and determinations of whether 

a technology is a qualifying repowering technology. [s. NR 409.11(2)(a), Wis. Adm. Code]

(2) No state or administrative or judicial appeal of the acid rain portion of an operation permit may be allowed to commence 

more than 30 days following the issuance of the acid rain portion of an operation permit, as provided by ss. 285.81 and 227.53, 

Wis. Stats. [s. NR 409.11(2)(b), Wis. Adm. Code]

(3) The U.S. EPA may intervene as a matter of right in any state administrative appeal of an acid rain portion of an operation 

permit or denial of an acid rain portion of an operation permit. [s. NR 409.11(2)(c), Wis. Adm. Code]
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Final Permit page 242

ZZZ. ACID RAIN PORTION OF OPERATION PERMIT

5. Comments, Notes and Justifications:

None.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART II – General Permit Conditions

PART II

GENERAL PERMIT CONDITIONS

FOR DIRECT STATIONARY SOURCES
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART II – General Permit Conditions

INSERT PART II ...................
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART III – CAIR APPLICATION

PART III

Clean Air Interstate Rule (CAIR) Requirements

Facility Name: Wisconsin Public Service Corporation – Weston

FID #: 737009020

Permit #: 737009020-P10

ORIS/Facility Code: 4078

The following Clean Air Interstate Rule (CAIR) Requirements apply to boiler B01 (identified by the 

facility as Unit 1), boiler B02 (identified by the facility as Unit 2), boiler B03 (identified by the facility as 

Unit 3), boiler B04 (identified by the facility as Unit 4), process P32A (identified by the facility as Unit 

32A, and process P32B (identified by the facility as Unit 32B):

Nitrogen Oxide – Annual

Sulfur Dioxide

Nitrogen Oxide – Ozone Season

The permittee shall comply with the CAIR requirements as outlined in the CAIR Permit Application (for 

sources subject to CAIR FIP) and 40 CFR 97.121, 97.122, 97.221, 97.222, 97.321 and 97.322.174

The CAIR Permit Application submitted by Wisconsin Public Service Corporation – Weston and dated 

May 23, 2007 is incorporated as Part III of this Operation Permit. (See attached.)

Table 1, s. NR 432.03(5), Wis. Adm. Code

CAIR NOx Allocations by CAIR NOx Unit

(in tons of CAIR NOx allowances)

Unit Location Unit Number 2012 2013 2014

Weston 1 321 321 321

Weston 2 531 531 531

Weston 3 2000 2000 2000

Weston 32 39 39 39

Table 2, s. NR 432.05(5), Wis. Adm. Code

CAIR NOx Ozone Season Allocations by CAIR NOx Unit

(in tons of CAIR NOx ozone season allowances)

Unit Location Unit Number 2012 2013 2014

Weston 1 137 137 137

Weston 2 233 233 233

Weston 3 849 849 849

Weston 32 21 21 21

 174 If US EPA revises the CAIR requirements, the permittee shall comply with any such revisions including changes 

to the CAIR Permit Application necessitated by the revisions. The permittee shall submit any revised CAIR Permit 

Application to the department along with an application to revise this operation permit if a revision of this permit is 

necessary.
FID 737009020; Permit No. 737009020-P10 & 03-RV-248-R6 – Final Permit PART III – CAIR APPLICATION - page 1

..... INSERT CAIR APPLICATION AS PART III
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans

Wisconsin Public Service – Weston Plant

PART IV

COMPLIANCE ASSURANCE MONITORING (CAM) PLANS
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 1

COMPLIANCE ASSURANCE MONITORING PLAN

WISCONSIN PUBLIC SERVICE CORPORATION 

WESTON POWER PLANT

UNITS 1, 2, 3, 4 and Material Handling Sources
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 2

WESTON POWER PLANT

UNIT 1

COMPLIANCE ASSURANCE MONITORING PROTOCOL

FOR PARTICULATE MASS EMISSIONS

I. Background

A. Emissions Units

Permit Identification/

Description: W1; coal-fired utility boiler

Permit Number: 737009020-P10

Facility: Weston Power Plant

Rothschild, WI

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Particulate Matter

Emissions Limit 0.10 lb/mmBtu and 85.8 lbs/hr

Current PM monitoring requirements for W1 are as noted in the applicable Air 

Pollution Control Operation Permit.

C. Control Technologies C01; Joy Western Plate & Wire Style Electrostatic 

Precipitator (ESP)

II. Monitoring Approach

The key elements of the monitoring approach for Unit 1 (including the indicators to be 

monitored, indicator ranges, and performance criteria) are presented in Table 1. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 3

Table 1 - Monitoring Approach for Unit 1

Indicator #1

I. Indicator Stack (S01) Opacity.

Measurement Approach The opacity is measured using a Continuous Opacity 

Monitoring System (COMS) at the stack for Unit 1 (S01).

II. Indicator Range An opacity in excess of 19% for any one-hour average 

operating period as measured by the COMS will be 

considered a CAM excursion.

III. Performance Criteria

Data Representativeness Opacity is related to the size and concentration of particles 

in the flue gas. As particulate mass emissions increase, it 

can be reasonably expected that stack opacity will also 

increase.

Unit 1 (W1) discharges to a dedicated stack with no bypass 

capabilities. The stack is equipped with a COMS that 

meets the installation and minimum acceptable accuracy 

requirements as specified in the applicable version of 40 

CFR 60, Performance Specification 1. The COMS is 

located downstream of the ESP and, therefore, reflects the 

performance of the control device (C01) for Unit 1.

Verification of Operational Status Not applicable. Monitoring approach uses existing 

equipment.

QA/QC Practices and Criteria Calibrate, maintain and operate the continuous emission 

monitor in accordance with the performance specifications 

in 40 CFR Part 75, Appendices A to I and Performance 

Specification 1 in 40 CFR Part 60, Appendix B.

Monitoring Frequency Continuous.

Data Collection Procedures The COMS collects data and the CEMS data acquisition 

system reduces the data to one-hour averages.

Averaging Period One hour averages, as measured by the COMS.

IV. Quality Improvement Plan (QIP) If excursions occur for more than 5% of the equipment 

operating time during any semi-annual reporting period, the 

Wisconsin Department of Natural Resources may require 

the development of a Quality Improvement Plan in 

accordance with §64.8 of 40 CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 4

WESTON POWER PLANT

UNIT 2

COMPLIANCE ASSURANCE MONITORING PROTOCOL

FOR PARTICULATE MASS EMISSIONS

I. Background

A. Emissions Units

Permit Identification/

Description: W2; coal-fired utility boiler

Permit Number: 737009020-P10

Facility: Weston Power Plant

Rothschild, WI

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Particulate Matter

Emissions Limit 0.10 lb/mmBtu and 100 lbs/hr

Current PM monitoring requirements for W2 are as noted in the applicable Air 

Pollution Control Operation Permit.

C. Control Technologies C02: Joy Western Plate & Wire Style ESP

II. Monitoring Approach

The key elements of the monitoring approach for Unit 2 (including the indicators to be 

monitored, indicator ranges, and performance criteria) are presented in Table 2. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 5

Table 2 - Monitoring Approach for Unit 2

Indicator #1

I. Indicator Stack (S02) Opacity.

Measurement Approach The opacity is measured using a Continuous Opacity 

Monitoring System (COMS) at the stack for Unit 2 (S02).

II. Indicator Range An opacity in excess of 10.5% for any one-hour average

operating period as measured by the COMS will be 

considered a CAM excursion.

III. Performance Criteria

Data Representativeness Opacity is related to the size and concentration of particles 

in the flue gas. As particulate mass emissions increase, it 

can be reasonably expected that stack opacity will also 

increase.

Unit 2 (W2) discharges to a dedicated stack with no bypass 

capabilities. The stack is equipped with a COMS that 

meets the installation and minimum acceptable accuracy 

requirements as specified in the applicable version of 40 

CFR 60, Performance Specification 1. The COMS is 

located downstream of the ESP and, therefore, reflects the 

performance of the control device (C02) for Unit 2.

Verification of Operational Status Not applicable. Monitoring approach uses existing 

equipment.

QA/QC Practices and Criteria Calibrate, maintain and operate the continuous emission 

monitor in accordance with the performance specifications 

in 40 CFR Part 75, Appendices A to I and Performance 

Specification 1 in 40 CFR Part 60, Appendix B.

Monitoring Frequency Continuous.

Data Collection Procedures The COMS collects data and the CEMS data acquisition 

system reduces the data to one-hour averages. 

Averaging Period One-hour averages as measured by the COMS.

IV. Quality Improvement Plan (QIP) If excursions occur for more than 5% of the equipment 

operating time during any semi-annual reporting period, the 

Wisconsin Department of Natural Resources may require 

the development of a Quality Improvement Plan in 

accordance with §64.8 of 40 CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 6

WESTON POWER PLANT

UNIT 3

COMPLIANCE ASSURANCE MONITORING PROTOCOL

FOR PARTICULATE MASS EMISSIONS

I. Background

A. Emissions Units

Permit Identification/

Description: W3; coal-fired utility boiler

Permit Number: 737009020-P10

Facility: Weston Power Plant

Rothschild, WI

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Particulate Matter

Emissions Limit 0.10 lb/mmBtu and 342.3 lbs/hr

Current PM monitoring requirements for W3 are as noted in applicable Air Pollution Control 

Operation and Construction permits.

C. Control Technologies C03; Environmental Elements Corporation Baghouse

II. Monitoring Approach

The key elements of the monitoring approach for Unit 3 (including the indicators to be 

monitored, indicator ranges, and performance criteria) are presented in Table 3. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 7

Table 3 - Monitoring Approach for Unit 3

Indicator #1 Indicator #2

I. Indicator Baghouse (C03) Differential 

Pressure.

Stack (S03) Opacity.

Measurement Approach The pressure differential is 

measured by electronic pressure 

transmitters, which are located at 

the inlet and the outlet of the 

baghouse.

The opacity is measured using 

a Continuous Opacity 

Monitoring System (COMS) 

at the stack for Unit 3 (S03).

II. Indicator Range 2.0 to 10.0 inches of water 

column. An excursion is defined 

as a differential pressure outside 

of the range.

Opacity in excess of 10% for 

any one-hour average

operating period as measured 

by the COMS will be 

considered a CAM excursion.

III. Performance Criteria

Data Representativeness The pressure differential is a 

measurement of the resistance of 

flow as the gas passes through 

the filter bag(s) and filter cake. 

Pressure transmitters are located 

at the inlet and outlet of the dust 

collector, which reflects the 

pressure drop across the entire 

baghouse. Each pressure 

transmitter has a minimum 

accuracy within 5% of the 

pressure drop within 1 inch of 

water column, whichever is 

greater.

Opacity is related to the size 

and concentration of particles 

in the flue gas. As particulate 

mass emissions increase, it 

can be reasonably expected 

that stack opacity will also 

increase.

Unit 3 (W3) discharges to a 

dedicated stack. The stack is 

equipped with COMS that 

meets the installation and 

minimum acceptable accuracy 

requirements as specified in 

the applicable version of 40 

CFR 60, Performance 

Specification 1. The COMS 

is located downstream of the 

baghouse and, therefore, 

reflects the performance of the 

control device (C03) for Unit 

3.

Verification of 

Operational Status

Not applicable. Monitoring 

approach uses existing 

equipment.

Not applicable. Monitoring 

approach uses existing 

equipment.

QA/QC Practices and 

Criteria

Equipment is repaired/replaced 

as needed. The equipment is 

calibrated annually.

Calibrate, maintain and 

operate the continuous 

emission monitor in 

accordance with the 

performance specifications in 

40 CFR Part 75, Appendices 

A to I and Performance 

Specification 1 in 40 CFR Part 

60, Appendix B.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 8

Monitoring Frequency Continuously while boiler is 

operating.

Continuous.

Data Collection 

Procedures

The differential pressure is 

monitored continuously through 

the distributed control system 

(DCS).

The COMS collects data and 

the CEMS data acquisition 

system reduces the data to 

one-hour averages. 

Averaging Period No averaging period for 

differential pressure.

One-hour averages as 

measured by the COMS.

IV. Quality Improvement 

Plan (QIP)

If excursions occur for more than 

5% of the equipment operating 

time during any semi-annual 

reporting period, the Wisconsin 

Department of Natural 

Resources may require the 

development of a Quality 

Improvement Plan in accordance 

with §64.8 of 40 CFR Part 64.

If excursions occur for more 

than 5% of the equipment 

operating time during any 

semi-annual reporting period, 

the Wisconsin Department of 

Natural Resources may 

require the development of a 

Quality Improvement Plan in 

accordance with §64.8 of 40 

CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 9

WESTON POWER PLANT

UNIT 4

COMPLIANCE ASSURANCE MONITORING PROTOCOL

FOR PARTICULATE MASS EMISSIONS

I. Background

A. Emissions Units

Permit Identification/

Description: W4; coal-fired utility boiler

Permit Number: 737009020-P10

Facility: Weston Power Plant

Rothschild, WI

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Particulate Matter

Emissions Limit 0.02 lb/mmBtu PM (averaged over any consecutive 3- hour period) 

and 103.52 lbs/hr (averaged over any consecutive 3-hour period)

0.018 lb/mmBtu PM10 (averaged over any consecutive 3-hour period)

Current PM and PM10 monitoring requirements for W4 are as noted in applicable Air 

Pollution Control Operation and Construction permits.

C. Control Technologies C04; Babcock & Wilcox Baghouse

II. Monitoring Approach

The key elements of the monitoring approach for Unit 4 (including the indicators to be 

monitored, indicator ranges, and performance criteria) are presented in Table 4. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 10

Table 4 - Monitoring Approach for Unit 4

Indicator #1 Indicator #2

I. Indicator Baghouse (C04) 

Differential Pressure.

Stack (S04) Opacity.

Measurement Approach The pressure differential 

is measured by electronic 

pressure transmitters, 

which are located at the 

inlet and the outlet of the 

baghouse.

The opacity is measured using a 

Continuous Opacity Monitoring 

System (COMS) at the stack for Unit 

4 (S04).

II. Indicator Range 2.0 to 10.0 inches of water 

column for B04. An 

excursion is defined as a 

differential pressure 

outside of the range.

An opacity in excess of 10% for any 

consecutive 3-hour average operating 

period will be considered a CAM 

excursion.

III. Performance Criteria

Data Representativeness The pressure differential 

is a measurement of the 

resistance of flow as the 

gas passes through the 

filter bag(s) and filter 

cake. Pressure 

transmitters are located at 

the inlet and outlet of the 

dust collector, which 

reflects the pressure drop 

across the entire 

baghouse. Each pressure 

transmitter has a 

minimum accuracy within 

5% of the pressure drop 

within 1 inch of water 

column, whichever is 

greater.

Opacity is related to the size and 

concentration of particles in the flue 

gas. As particulate mass emissions 

increase, it can be reasonably 

expected that stack opacity will also 

increase.

Unit 4 (W4) discharges to a 

dedicated stack .. The stack is 

equipped with a COMS that meets 

the installation and minimum 

acceptable accuracy requirements as 

specified in the applicable version of 

40 CFR 60, Performance 

Specification 1. The COMS is 

located downstream of the Baghouse 

and, therefore, reflects the 

performance of the control device 

(C04) for Unit 4.

Verification of 

Operational Status

Not applicable. 

Monitoring approach uses 

existing equipment.

Not applicable. Monitoring approach 

uses existing equipment.

QA/QC Practices and 

Criteria

Equipment Is 

repaired/replaced as 

needed. The equipment is 

calibrated annually.

Calibrate, maintain and operate the 

continuous emission monitor in 

accordance with the performance 

specifications in 40 CFR Part 75, 

Appendices A to I and Performance 

Specification 1 in 40 CFR Part 60, 

Appendix B.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 11

Monitoring Frequency Continuously while boiler 

is operating.

Continuous.

Data Collection 

Procedures

The differential pressure 

is monitored continuously 

through the distributed 

control system (DCS).

The COMS collects data and the 

CEMS data acquisition system 

reduces the data to each consecutive 

3-hour average periods.

Averaging Period No averaging period for 

differential pressure.

Each consecutive 3-hour period. 

IV. Quality Improvement 

Plan (QIP)

If excursions occur for 

more than 5% of the 

equipment operating time 

during any semi-annual 

reporting period, the 

Wisconsin Department of 

Natural Resources may 

require the development 

of a Quality Improvement 

Plan in accordance with 

§64.8 of 40 CFR Part 64.

If excursions occur for more than 5% 

of the equipment operating time 

during any semi-annual reporting 

period, the Wisconsin Department of 

Natural Resources may require the 

development of a Quality 

Improvement Plan in accordance 

with §64.8 of 40 CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 12

WESTON POWER PLANT

MATERIAL HANDLING PROCESSES

COMPLIANCE ASSURANCE MONITORING PROTOCOL

FOR PARTICULATE MASS EMISSIONS

I. Background

A. Emissions Units

Permit Identification/Description:

• P31A; coal unloading dumper house dust collector A

• P31B; coal unloading dumper house dust collector B

• P31C; junction house dust collector

• P32A; W3 and W4 crusher house dust collector A

• P32B; W3 and W4 crusher house dust collector B

• P32D; W3 coal storage silos and cascade conveyor dust collector A

• P32E; W3 coal storage silos and cascade conveyor dust collector B

• P34; W1 &W2 #8 coal transport conveyor dust collector

• P35A; W1 & W2 crusher house dust collector

• P35B; W1 & W2 conveyor C and coal bunker dust collector

• P36A; W3 fly ash silo transfer and handling dust collector

• P36B; W3 fly ash silo bin vent

• P37A; W1 and W2 fly ash silo transfer and handling dust collector

• P30; W4 System 1, New Reclaim Tunnel Exit #34

• P41; W4 System 2, New Junction House 2, #31

• P42; W4 System 3, New Junction House 3, #32

• P43; W4 System 4, Silo Fill System, #7

• P45; W4 System 2, Lime Storage Silo #27

• P49; W4 System 4 FGD Byproduct Recycle #24

• P50; W4 System 5, FGD Waste Silo #20

(Note: Processes P32C, P37B, P39, P44, P65 and P66 do not have potential pre-control 

device particulate matter emissions that are greater than 100 tons per year and therefore are 

not subject to CAM requirements, pursuant to Part 64, CFR. However, the permittee has 

elected to include these emissions units in this CAM Plan for consistency.)

Permit Number: 737009020-P10

Facility: Weston Power Plant

Rothschild, WI
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 13

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Particulate Matter Emissions Limits and Opacity Limits:

 Table 5 – Material Handling Particulate Matter Emission Limits and Opacity Limits

Source Control 

Device Description

Particulate Matter 

Emission Limit175

(whichever is more 

restrictive) 

Opacity 

Limit

P31A C31A Coal Unloading (Collector A) 1.60 lb/hr 10%

P31B C31B Coal Unloading (Collector B) 0.80 lb/hr 10%

P31C C31C Junction House 0.49 lb/hr 10%

P32A C32A W3 & W4 Crusher House 

(Collector A) 1.09 lb/hr 10%

P32B C32B W3 & W4 Crusher House 

(Collector B) 1.51 lb/hr 10%

P32C C32C W3 & W4 Crusher House 

(Collector C) 0.04 lbs/hr 20%

P32D C32D W3 Coal Storage Silos and Cascade 

Conveyor (Collector A)

1.76 lb/hr 10%

P32E C32E W3 Coal Storage Silos and Cascade 

Conveyor (Collector B) 2.21 lb/hr 10%

P34 C34 W1 & W2 #8 Coal Transport 

Conveyor 0.52 lb/hr 10%

P35A C35A W1 & W2 Crusher House 0.53 lb/hr 10%

P35B C35B W1 & W2 Conveyor C and Coal 

Bunker 1.03 lb/hr 10%

P36A C36A W3 Fly Ash Silo Transfer and 

Handling 0.38 lb/hr 20%

P36B C36B W3 Fly Ash Silo 0.23 lb/hr 20%

P37A C37A W1 & W2 Fly Ash Silo Transfer 

and Handling 0.58 lb/hr 20%

P37B C37B W1 & W2 Fly Ash Silo Transfer 

and Handling 0.13 lbs/hr 20%

P39 C39 W3 Flyash Storage Building 0.21 lbs/hr 20%

P30 C30 W4 System 1 New Reclaim Tunnel 

Exit #34

0.79 lb/hr and .01 

gr/dscf

10%

P41 C41 W4 System 2 New Junction House 

#31

2.59 lb/hr and .02 

gr/dscf

10%

P42 C42 W4 System 3 New Junction House 

#32

0.79 lb/hr and .01 

gr/dscf

10%

P43 C43 W4 System 4 Silo Fill #7 3.84 lb/hr and .01 

gr/dscf

10%

P44 C44 W4 System 1 Lime Storage Silo 

#22 0.10 lbs/hr 10%

P45 C45 W4 System 2 Lime Storage Silo 0.26 lb/hr and .01 10%

 175 Weston Power Plant Air Pollution Control Operation Permit 737009020-P02 provides emissions limits for PM and opacity, but no limits for PM10 are 

included in the permit. CAM regulations in Part 64.2(a)(1) state that for a unit to be subject to CAM, it must, among other things, “be subject to an emissions 

limitation or standard for the applicable regulated air pollutant....” For the purposes of CAM applicability, WPSC has conservatively assumed that PM is a 

surrogate for PM10. Therefore, WPSC considered the CAM rule applicable to those sources using a control device that are subject to a PM limit and have 

PM10 potential pre-control device emissions above 100 tpy.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 14

#27 gr/dscf

P49 C49 W4 System 4 FGD Byproduct 

Recycle #24

0.83 lb/hr and .02 

gr/dscf

10%

P50 C50 W4 System 5 FGD Waste Silo #20 0.326 lb/hr and .02 

gr/dscf

10%

P65 C65 W4 PAC Storage Silo 4A 0.21 lb/hr 10%

P66 C66 W4 PAC Storage Silo 4B 0.21 lb/hr 10%

(Note: Processes P32C, P37B, P39, P44, P65 and P66 (shaded in the table above) do not have potential pre-control device particulate 

matter emissions that are greater than 100 tons per year and therefore are not subject to CAM requirements, pursuant to Part 64, CFR. 

However, the permittee has elected to include these emissions units in this CAM Plan for consistency.)

C. Control Technologies

 Table 6 – Control Technologies Description and Pressure Drop

Source Control 

Device Control Device Description Manufacturer’s RecommendedPressure Differential

P31A C31A Carter Day Dust Collector A

0.5 – 7.0” w.c. A1

0.5 – 8.5” w.c. A2

P31B C31B Carter Day Dust Collector B 0.5 – 7.0” w.c. B1

0.5 – 8.5” w.c. B2

P31C C31C Carter Day Dust Collector 0.5 – 7.0” w.c.

P32A C32A Carter Day Dust Collector 0.5 – 7.0” w.c.

P32B C32B Carter Day Dust Collector 0.5 – 7.0” w.c.

P32C C32C Carter Day Dust Collector 0.5 – 7.0” w.c.

P32D C32D Carter Day Dust Collector 0.5 – 8.5” w.c.

P32E C32E Carter Day Dust Collector 0.5 – 8.5” w.c.

P34 C34 MAC Equipment Dust Collector 0.5 – 7.0” w.c.

P35A C35A Flex Kleen 0.5 – 7.0” w.c.

P35B C35B MAC Equipment Dust Collector 0.5 – 7.0” w.c.

P36A C36A United Conveyor Dust Collector 1.0 – 35” w.c.

P36B C36B United Conveyor Dust Collector -1.0 – 7.0” w.c.

P37A C37A United Conveyor Dust Collector 0.5 – 25” w.c.

P37B C37B United Conveyor Bin Vent -1.0 – 7.0” w.c.

P39 C39 Griffin Filters Dust Collector 0.5 – 8.0” w.c.

P30 C30 Airtrol, Inc. Dust Collector 2.0 – 8.0” w.c.

P41 C41 Airtrol, Inc. Dust Collector 2.0 – 8.0” w.c

P42 C42 Airtrol, Inc. Dust Collector 2.0 – 8.0” w.c

P43 C43 Airtrol, Inc. Dust Collector 2.0 – 8.0” w.c

P44 C44 United Conveyor Bin Vent -1.0 – 8.0” w.c.

P45 C45 United Conveyor Bin Vent -1.0 – 5.5” w.c

P49 C49 United Conveyor Bin Vent -1.0 – 5.5” w.c

P50 C50 United Conveyor Bin Vent -1.0 – 8.0” w.c

P65 C65 Torit Bin Vent -1.0 – 5.0” w.c.

P66 C66 Torit Bin Vent -1.0 – 5.0” w.c.

(Note: Processes P32C, P37B, P39, P44, P65 and P66 (shaded in the table above) do not have potential pre-control device particulate 

matter emissions that are greater than 100 tons per year and therefore are not subject to CAM requirements, pursuant to Part 64, CFR. 

However, the permittee has elected to include these emissions units in this CAM Plan for consistency.)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 15

II. Monitoring Approach

The key elements of the monitoring approach for each dust collector (including indicators to be 

monitored, indicator ranges, and performance criteria) are presented in Table 7.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 16

Table 7 - Monitoring Approach for Material Handling Dust Collectors 

Indicator #1 Indicator #2

I. Background

 A. Emission Units

P31A, P31B, P31C, P32A, P32B, P32C, P32D, P32E, P34, P35A, P35B, P36A, P36B, P37A, P36B, P39,

P41, P42, P43, P44, P45, P49, P50, P65, P66 (The data presented in the table applies to each process 

identified)

II. Monitoring Approach The key elements of the monitoring approach are presented below

A. Indicator Dust collector Pressure Differential Visible Inspections

 B. Measurement Approach The pressure differential is monitored using 

continuous differential pressure monitoring at the 

dust collector. 

If pressure differential monitoring indicates the need to 

complete a visual inspection, one visual inspection will 

be completed. 

C. Indicator Range When the process is operating, an alarm will be 

set to alert the operator if the pressure differential 

is outside the range in Table 6. 

Pressure differential outside of the acceptable 

range (not caused by maintenance activities) will 

trigger a visual inspection of the exhaust stack and 

corrective action, if necessary. 

An excursion is defined as any emissions noted as a 

result of a visual inspection of exhaust stack due to an 

alarm in Indicator #1.

D. Quality Improvement Plan (QIP) 

Threshold

The QIP threshold is nine excursions recorded within a 

semi-annual (six-month) period to be reported in the 

applicable semi-annual compliance monitoring report

III. Performance Criteria

A. Data Representativeness The pressure differential is a measurement of the 

resistance of flow as the gas passes through the 

filter bag(s) and filter cake. Pressure taps are 

located at the inlet and outlet of the dust collector.

Visible emissions are related to the size and 

concentration of particles in the exhaust. A properly 

operating dust collector system will have no visible 

emissions. Visible emission observations are made at 

the dust collector’s exhaust.

B. Verification of Operational Status Not applicable. Monitoring approach uses existing 

equipment.

Not applicable.

C. QA/QC Practices and Criteria Equipment is repaired/replaced as needed. The 

equipment is calibrated annually.

Not applicable. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 17

D. Monitoring Frequency Continuous When required by indicator #1

 E. Data Collection Procedures The investigative and corrective action taken as a 

result of a differential pressure alarm will be 

documented.

If pressure differential monitoring indicates the need to 

complete a visual inspection, one visual inspection will 

be completed and documented.

 F. Averaging Period No averaging period for the pressure drop. Not applicable.

(Note: Processes P32C, P37B, P39, P44, P65 and P66 do not have potential pre-control device particulate matter emissions that are greater than 100 tons per year and 

therefore are not subject to CAM requirements, pursuant to Part 64, CFR. However, the permittee has elected to include these emissions units in this CAM Plan for consistency.)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 18

MONITORING APPROACH JUSTIFICATION FOR UNITS 1 and 2

I. Background

Source Description

Weston Power Plant (Weston), located in Rothschild, Wisconsin, is owned and operated by 

Wisconsin Public Services Corporation (WPSC). Units 1 and 2 are dry-bottom boilers that burn 

pulverized coal to provide steam for the generation of electricity. Particulate mass (PM) 

emissions from each boiler are controlled by dedicated electrostatic precipitators (ESP) located 

downstream of the air preheater (“cold-side”).

The Unit 1 and Unit 2 ESPs are identical and consist of one gas path with four (4) transformer –

rectifier sets (TR-sets). Each TR set consist of 2 isolatable fields side by side capable of isolating 

1/8th of the collection surface at any time. Emissions from Unit 1 ESP and Unit 2 ESP are 

exhausted through dedicated stacks, S01 and S02, respectively. 

Emissions Limits

Each unit is subject to a particulate matter emission limits for fuel burning installations (NR 

415.06(2)(c)). The applicable PM emission limits used in this CAM plan are 0.10 lb/mmBtu and 

85.8 pounds per hour for boiler B01 and 0.10 lb/mmBtu and 100 pounds per hour for boiler B02. 

These limits are found in permit 07-SDD-301.

The applicable opacity emissions limit is 20% and additional information concerning this limit 

can be found in permit 07-SDD-301.

Monitoring Requirements

Weston is required to complete emission testing for particulate matter for each stack every 24 

months unless a waiver from the required biennial testing is received. Weston is also required to 

record ESP operating parameters once every eight hours or once per day, whichever yields the 

greater number of measurements (NR 439.055(2)(b)).

Each unit is also subject to the Wisconsin opacity monitoring requirements (NR 439.09(9)(a)(2)). 

Each stack is equipped with a Continuous Opacity Monitoring System (COMS). 

Condensable Particulate

In conjunction with each compliance test run, Weston used Other Test Method 028 (OTM-28, 

a.k.a., the dry impinge method, which was EPA’s proposed revision to Method 202 at the time of 

testing) or Method 202 to determine condensable emissions. The condensable results are 

included in the unit emission results in Tables 8 and 9. The average condensable results for Unit 

2 (0.005 lb/mmBtu) is lower than the results for Unit 1 (0.016 lb/mmBtu). WPSC has, as a 

conservative measure, incorporated the estimates of the condensable emissions within the 

indicator range selection process.

II. Rationale for Selection of Performance Indicators and Indicator Ranges

The purpose of this section is to provide technical justification in support of a compliance 

assurance monitoring protocol using opacity as the primary indicator for compliance with the 

applicable PM emissions limit. The COMS will be used as the primary CAM indicator for Unit 1 

and Unit 2 at Weston. Particulate testing conducted as part of the permit required compliance 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 19

testing was used to determine the opacity/mass relationship for each affected unit. This 

relationship was then used to select an opacity indicator range (or CAM trigger value), such that 

as long as the opacity is maintained at or below this value during normal boiler operation, the 

unit will also operate below the applicable PM emissions limit (or, in terms of the CAM rule, 

that there will be “a reasonable assurance of compliance with emission limitations or standards.”) 

Unit 1 and Unit 2, which are each served by a dedicated stack, the COMS will be used as the 

only CAM indicator. The selected indicator range that defines an excursion for Unit 1 will be 

stack opacity from S01 greater than 19% based on a one-hour average as measured by the 

COMS. The selected indicator range that defines an excursion for Unit 2 will be stack opacity 

from S02 greater than 10.5% based on a one-hour average as measured by the COMS.

WPSC believes that these are appropriate indicator ranges based on the opacity/mass 

relationships for each unit and that these ranges will provide a conservative compliance margin 

with the permitted emission limit due to the inclusion of the condensable particulate 

measurements. All excursions will be documented and reported on a unit basis including the 

associated corrective action.

Validation of Monitoring Approach

For a coal-fired boiler equipped with an ESP operating under normal load, the particle size 

distribution and specific surface area of the particles will remain relatively similar. This means 

that any change in opacity, as a first-order approximation, will be directly proportional to the 

mass concentration.176 Therefore, while opacity is not a direct measurement of PM, it can be 

used as a surrogate. If opacity is increasing, it can be reasonably expected that the PM

concentration is also increasing.

The physics of the opacity meter are based on Lambert’s Law, which can be expressed 

mathematically by the following equation:

4 1 x avgmavg S

O e

−

= −

Where: O = opacity of flue gas

Savg = specific surface area of the particles (m2

/g)

mavg = particulate mass concentration (g/Nm3

)

x = optical path length (m)

WPSC notes that the use of opacity as a CAM indicator for PM is considered presumptively 

acceptable under §64.3(d) of the Rule, provided there is sufficient data to show that this indicator 

range is appropriate. That is, the opacity indicator range must demonstrate a reasonable 

assurance of compliance with the applicable PM standard.

 176 Parker, K.R., Applied Electrostatic Precipitation
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 20

Validation of Indicator Ranges

PM emission test results from previous compliance tests were used to validate the selection of 

the monitoring approach and indicator range. 

For each compliance test, the boilers were operated at normal full load. This represents the 

highest level of PM emissions and will produce conservative indicator ranges under the proposed 

CAM approach. Each test consisted of at least three runs using EPA Reference Method 5 and 

Other Test Method (OTM) 28 or Method 202. Boiler and ESP operating data were also recorded 

to demonstrate stable, normal load operation during each test.

Unit 1 Results

Table 8 shows a summary of the compliance test results for Unit 1. For the 2005 compliance test, 

the data shows an average opacity of 13.24% and an average total PM emission rate of 0.0787 

lb/mmBtu. For the 2009 compliance test, the data shows an average opacity of 4.52% and an 

average total PM emission rate of 0.0571 lb/mmBtu. The average test data shows 32% margin of 

compliance with the total PM emission limit of 0.10 lb/mmBtu.

Table 8 - Unit 1 Compliance Test Results

Test Date

Stack

Opacity 

[%]

Filterable

PM 

Emissions 

[lb/mmBtu]

Condensable

PM 

Emissions 

[lb/mmBtu]

Total

PM 

Emissions 

[lb/mmBtu]

12/21/2005 13.53 0.0675 0.0115 0.0790

12/21/2005 13.41 0.0643 0.0146 0.0789

12/21/2005 12.78 0.0608 0.0174 0.0782

8/25/2009 4.39 0.0402 0.0064 0.0466

8/25/2009 4.46 0.0395 0.0300 0.0695

8/25/2009 4.70 0.0354 0.0199 0.0553

Figure 1 shows the opacity/unit mass relationship for Unit 1 for the compliance tests. A linear 

curve fit was produced with a chi-square goodness of fit (r2) result of 0.72.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 21

Unit 1 Opacity/Mass Relationship

y = 0.0025x + 0.046

R2

 = 0.7237

0

0.02

0.04

0.06

0.08

0.1

0 5 10 15 20 25

Opacity (%)

Total PM (lb/mmBtu)

Figure 1 – Unit 1 Opacity/Mass Relationship [lb/mmBtu]

The results suggest that an opacity indicator range of 19% (based on a one-hour average) for 

Unit 1 would provide a reasonable assurance of compliance with the PM emission limit. 

Unit 2 Results

Table 9 shows a summary of the compliance test results for Unit 2. For the 2005 compliance test, 

the data shows an average opacity of 8.69% and an average total PM emission rate of 0.072 

lb/mmBtu. For the 2009 compliance test, the data shows an average opacity of 6.5% and an 

average total PM emission rate of .0392 lb/mmBtu. The average test data shows a 44% margin of 

compliance with the total PM emission limit.

Table 9 - Unit 2 Compliance Test Results

Test Date

Stack 

Opacity 

[%]

Filterable

PM 

Emissions 

[lb/mmBtu]

Condensable

PM 

Emissions 

[lb/mmBtu]

Total

PM 

Emissions 

[lb/mmBtu]

12/22/2005 8.63 0.0523 0.0059 0.0582

12/22/2005 8.63 0.0771 0.0045 0.0817

12/22/2005 8.81 0.0729 0.0043 0.0772

8/27/2009 6.53 0.0338 0.0036 0.0374

8/27/2009 6.39 0.0325 0.0074 0.0399

8/27/2009 6.61 0.0308 0.0096 0.0404

Figure 2 shows the opacity/unit mass relationship for Unit 2 for the compliance tests. A linear 

curve fit was produced with a chi-square goodness of fit (r2

) result of 0.84.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 22

Unit 2 Opacity/Mass Relationship

y = 0.0152x - 0.0599

R2

 = 0.8469

0

0.02

0.04

0.06

0.08

0.1

0 5 10 15 20

Opacity (%)

Total PM (lb/mmBtu)

Figure 2 – Unit 1 Opacity/Mass Relationship [lb/mmBtu]

The results suggest that an opacity indicator range of 10.5% (based on a one-hour average) for 

Unit 2 would provide a reasonable assurance of compliance with the PM emission limit. 

Validation of Averaging Periods

The PM limits in the Weston operating permit do not allow for averaging periods. The PM stack 

tests utilized to establish the correlation between particulate matter emissions and opacity were 

conducted using three (3) one-hour test runs. Opacity is being used as a surrogate to demonstrate 

compliance with particulate matter emission limits and the data available shows a correlation on 

a one-hour average. In this case the data availability and limitations of the COMS equipment are 

taken into account.

Corrective Action

Upon detecting an excursion, Weston will implement corrective action to restore the indicator to 

below the indicator range. Corrective action will begin with an evaluation of the monitoring 

system to determine if the excursion is related to the monitoring system or the control device. To 

the extent possible, any corrective action should reduce the potential of similar excursions from 

recurring.

Reporting Requirements

All excursions must be reported in the plant’s semi-annual Title V compliance report. Weston 

will include the date and time of each excursion and a description of the corrective action that 

was performed. 

The Wisconsin Department of Natural Resources (DNR) may request a quality improvement 

plan (QIP) if the number of excursions exceeds 5% of the operating time during any semi-annual 

reporting period.177

Recordkeeping Requirements

Weston will retain all monitoring data and support information for a period of at least five years 

from the data of the monitoring sample, measurement, report or application. 

 177 The 5% QIP trigger is suggested in §64.8 of 40 CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 23

Conclusions

According to §64.4(b), the use of a COMS to demonstrate a reasonable assurance of compliance 

with a PM standard is considered “presumptively acceptable” for CAM. Presumptively 

acceptable monitoring approaches are considered by EPA to be acceptable for CAM and do not 

require additional justification. Furthermore, WPSC believes that the compliance test data 

convincingly demonstrate that the proposed monitoring approach and the selected indicator 

ranges meet the design requirements of §64.3 for Units 1 and 2.

During normal operation, compliance test data shows that the two units operate well below their 

respective PM emissions limits. During a potential ESP failure, where the opacity may reach the 

trigger level, a 5% margin of compliance with the PM emission limit is still maintained. 

An excursion, which is a reportable event under the CAM Rule, will be defined to meet the 

following criteria:

• For Unit 1, a stack opacity greater than 19% for one-hour average.

• For Unit 2, a stack opacity greater than 10.5% for any one-hour average. 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 24

MONITORING APPROACH JUSTIFICATION FOR UNITS 3 and 4

I. Background

Source Description

Weston Power Plant (Weston), located in Rothschild, Wisconsin is owned and operated by 

Wisconsin Public Services Corporation (WPSC). Unit 3 (B03) is a tangentially-fired boiler that 

burns pulverized coal to provide steam for the generation of electricity. Unit 4 (B04) is a 

supercritical pulverized coal-fired boiler that burns pulverized coal to provide steam for the 

generation of electricity. Both units are equipped with a baghouse to control particulate matter 

emissions. 

Emission Limits

Each unit is subject to a particulate matter emission limits for fuel burning installations (NR 

415.06(2)(c)). Boiler B03 is subject to the more restrictive New Source Performance Standard 

(NSPS) emission limitations of s. NR 440.19(3)(a)1., Wis. Adm. Code. The applicable PM 

emission limit used in the CAM plan for B03 is 0.10 lb/mmBtu and 342.3 lbs/hr. Boiler B04 is 

subject to the more restrictive NSPS emission limitation of s. NR 440.20(3), Wis. Adm. Code 

and a more restrictive PSD BACT limitation of s. NR 405.08(2), Wis. Adm. Code. The 

applicable PM and PM10 emission limits for B04 are 0.02 and 0.018 lb/mmBtu, respectively. 

These emission limitations are found in permits 06-SDD-102 (B03) and 03-RV-248-R4 (B04). 

The applicable opacity emission limit for both units is 20% and additional information 

concerning this limit can be found in 06-SDD-102 (B03) and 03-RV-248-R4 (B04).

Monitoring Requirements

Weston is required to complete emission testing for particulate matter for each stack every 24 

months unless a waiver from the required biennial testing is received. Weston is also required to 

record baghouse pressure differential once every eight operating hours or once per day, 

whichever yields the greater number of measurements (NR 439.055(1)(a)). Weston currently 

monitors baghouse performance through continuous measurement of baghouse differential 

pressure. The boilers are equipped with pressure sensors located upstream and downstream of 

the baghouse, which are used to calculate the pressure drop across the entire baghouse. 

The units are subject to the Wisconsin opacity monitoring requirements (NR 439.09(9)(a)(2)). 

Each stack is equipped with a Continuous Opacity Monitoring System (COMS). 

Compliance test data shows that each boiler operates well below the total PM and applicable 

PM10 emissions limits during normal operation (Tables 10, 11 and 12). The test data shows that 

the average test results for Weston 3 represent an 83% margin of compliance with the total PM 

emissions limit of 0.10 lb/mmBtu. The test data for Weston 4 shows that the average test results 

for total PM represent a 59% margin of compliance with the 0.02 lb/mmBtu limit and the 

average test results for total PM10 represent a 50% margin of compliance with the 0.018 

lb/mmBtu limit.

Condensable Particulate

In conjunction with each compliance test run, WPSC used Other Test Method 028 (OTM-28, 

a.k.a., the dry impinger method, which was EPA’s proposed revision to Method 202 at the time 

of testing) or Method 202 to determine condensable emissions. The condensable results are 

included in the unit emission results in Tables 10, 11, and 12. WPSC has, as a conservative 

measure, elected to incorporate the estimates of the condensable emissions within the indicator 

range selection process.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 25

II. Rationale for Selection of Performance Indicators and Indicator Ranges

The purpose of this section is to provide technical justification in support of a compliance 

assurance monitoring protocol using differential pressure across each baghouse as the primary 

indicator and opacity as a secondary indicator for compliance with the applicable PM/PM10

emissions limits. Units 3 and 4 are each equipped with a baghouse to control particulate matter 

emissions.. These baghouses utilize fabric filters to capture particulate matter emissions. In 

fabric filtration, particulate matter-laden flue gases flow into and through a number of filter bags, 

leaving the particulate retained on the fabric. The fabric itself performs a portion of the filtering, 

but its main role is to be the foundational media for a filter cake to form on its surface. The filter 

cake is responsible for the efficient filtering of fine particulate. Differential pressure across a 

baghouse provides a good indication of proper operation and the effectiveness of a baghouse in 

capturing particulate matter. A properly operating baghouse is effective in achieving 99%or 

greater capture (control efficiency) of filterable particulate matter178. 

The pressure differential data collected by the plant DCS during the particulate matter 

compliance testing conducted as part of the applicable permit requirements and the testing 

performed per EPA information collection request (ICR) was used to validate the manufacturer 

(OEM) recommended pressure differential ranges for the baghouses. This data validated the 

OEM recommended operational pressure differential ranges for the baghouses to ensure 

compliance with the applicable PM emissions limits (or, in terms of the CAM rule, that there will 

be “a reasonable assurance of compliance with emission limitations or standards.”) 

The COMS will be used as the secondary CAM indicator for these Units. The opacity indicator 

range was selected based on a review of the opacity data recorded during the compliance tests 

and Unit historical opacity data. Each unit historically operates below the selected ranges. The 

opacity under normal operation varies with load and operating conditions. Variability is 

typically a gradual increase or decrease, with occasional sudden spikes or dips most often seen 

during cleaning cycles. A sudden and sustained increase above the selected range could indicate 

a potential problem with the baghouse. As stated in 64.3(a)(2), affected sources will also 

monitor control device bypass operation. Because the opacity monitor is located downstream of 

the baghouse, any bypass operation will be indicated in the measured opacity so additional 

bypass monitoring is not required.

Validation of Monitoring Approach

For a coal-fired boiler equipped with a baghouse operating under normal load, the particle size 

distribution and specific surface area of the particles will remain relatively similar. In general, 

baghouses are designed to operate at a relatively constant pressure drop during steady –state 

boiler operation. Monitoring pressure drop provides a means of detecting a change in operation 

that could lead to an increase in emissions. An increase in pressure differential is indicative of 

fabric blinding or decreased permeability and a decrease in pressure differential is indicative of a 

change in operation such as broken bags which could also be indicated by the presence of 

increased opacity, load changes or low-load operation. 

Opacity is a good indicator of PM concentration if exhaust gas. A change in opacity, as a firstorder approximation, will be directly proportional to the particulate mass concentration. At 

normal steady load conditions, if opacity increases, it can be reasonably expected that the PM 

concentration is also increasing.

 178 EPA Air Pollution Cost Control Manual, Sixth Edition, Section 6, Chapter 1 (EPA/452/B-02-001)
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 26

Validation of Indicator Ranges

PM and PM10 (S04) compliance and ICR tests were used to validate the selection of the 

monitoring approach and indicator ranges.

During each compliance and ICR test, the boilers were operated at normal full load. This 

represents the highest level of PM emissions and will produce conservative indicator ranges 

under the proposed CAM approach. Each test consisted of at least three runs using EPA 

Reference Method 5, and Other Test Method 28 or Method 202. 

The indicator range for pressure differential for each baghouse was based on manufacturer 

recommendations which take into account the filter media, particulate characteristics and the 

operation of the boiler. Lower loads on the boiler will result in lower pressure differential 

readings, whereas higher loads will result in higher pressure differential readings (and greater 

emissions). The pressure differential data in Tables 10, 11 and 12, recorded by the plant DCS 

during the PM and PM10 compliance and ICR tests demonstrated that during high load operation 

the baghouse pressure differentials are within the manufacturer recommended ranges and the 

total PM and PM10 (S04) emissions are below the applicable limits. 

Each Unit has an applicable opacity limit of 20%. However, each Unit operates well below this 

opacity limit during normal operations. Since the Units operate well below 20% opacity limit, a 

range of 10% was chosen to indicate potential abnormal operation of the baghouse or possible 

control equipment bypass situation.

Unit 3 Results

Table 10 shows a summary of the compliance and the EPA ICR test results for Unit 3. The test 

data show that the Unit is in compliance with the 0.1 lb/mmBtu emission limitation while 

operating within the selected indicator ranges for pressure differential and stack opacity.

Table 10– Unit 3 Compliance Test Results

Test 

Date

Pres. 

Diff. 

A Side

Pres. 

Diff. 

B Side

Opacity Filterable PM 

Emissions 

[lb/mmBtu)

Condensable 

PM Emissions 

[lb/mmBtu)

Total PM 

Emissions 

[lb/mmBtu]

12/20/05 7.47 7.64 0.88 0.0076 0.0166 0.0242

12/20/05 7.50 7.66 0.89 0.0113 0.0337 0.045

12/20/05 7.60 7.50 0.90 0.0111 0.017 0.0281

08/14/09 7.23 6.96 0.39 0.0034 0.0210 0.0244

08/14/09 7.42 6.93 0.48 0.0033 0.0209 0.0242

08/14/09 7.52 6.79 0.39 0.0020 0.0028 0.0048

05/04/10 6.89 6.58 0.73 0.0020 0.0023 0.0043

05/05/10 6.52 6.71 0.60 0.0038 0.0027 0.0065

05/06/10 7.18 6.85 0.60 0.0035 0.0086 0.0120

Unit 4 Results

Tables 11 and 12 show a summary of the compliance and the EPA ICR test results for Unit 4. 

The test data show that the Unit is in compliance with the 0.02 lb/mmBtu total PM and 0.018 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 27

lb/mmBtu total PM10 emission limitations while operating within the selected indicator ranges 

for pressure differential and stack opacity.

Table 11 – Unit 4 PM Compliance Test Results

Test 

Date

Pres. 

Diff. 

A Side

Pres. 

Diff. 

B Side

Opacity Filterable PM 

Emissions 

[lb/mmBtu)

Condensable 

PM Emissions 

[lb/mmBtu)

Total PM 

Emissions 

[lb/mmBtu]

07/09/08 6.58 6.58 1.61 0.0040 0.0041 0.0081

07/09/08 6.60 6.61 1.60 0.0094 0.0039 0.0134

07/09/08 6.55 6.56 1.54 0.0084 0.0032 0.0116

05/11/10 6.91 7.00 0.40 0.0004 0.0054 0.0058

05/12/10 6.94 7.05 0.39 0.0006 0.0037 0.0043

05/13/10 6.94 7.05 0.28 0.0006 0.0051 0.0057

Table 12 – Unit 4 PM10 Compliance Test Results

Test 

Date

Pres. 

Diff. 

A Side

Pres. 

Diff. 

B Side

Opacity Filterable 

PM10

Emissions 

[lb/mmBtu)

Condensable 

PM10 

Emissions 

[lb/mmBtu)

Total PM10

Emissions 

[lb/mmBtu]

07/10/08 6.57 6.59 1.57 0.0009 0.0150 0.0160

07/10/08 6.57 6.59 1.53 0.0008 0.0090 0.0100

07/10/08 6.55 6.60 1.50 0.0018 0.0110 0.0120

05/11/10 6.91 7.00 0.40 0.0009 0.0054 0.0064

05/12/10 6.94 7.05 0.39 0.0008 0.0037 0.0045

05/13/10 6.94 7.05 0.28 0.0003 0.0051 0.0055

Validation of Averaging Periods

The PM limits in the Weston operating permit do not allow for averaging periods for boiler B03. 

The PM stack tests utilized to establish the correlation between particulate matter emissions and 

opacity were conducted using three (3) one-hour test runs. Opacity is being used as a surrogate 

to demonstrate compliance with particulate matter emission limits and the data available shows a 

correlation on a one-hour average. In this case the data availability and limitations of the COMS 

equipment are taken into account.

The BACT particulate matter emission limitations in the current permit for boiler B04 includes a 

3-hour averaging period. Therefore compliance with the emission limitation is determined “as 

averaged over any consecutive 3-hour period”. In this case a 3-hour rolling average for the 

opacity performance indicator may be appropriate.

An averaging period is not appropriate for parametric monitoring such as the baghouse 

differential pressure drop monitoring for the baghouses controlling B03 and B04.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 28

Corrective Action

Upon detecting an excursion, Weston will implement corrective action to restore the indicator to 

below the indicator range. Corrective action will begin with an evaluation of the monitoring 

system to determine if the excursion is related to the monitoring system or the control device. To 

the extent possible, any corrective action should reduce the potential of similar excursions from 

recurring.

Reporting Requirements

All excursions will be reported in the semi-annual Title V compliance report. Weston will 

include the date and time of each excursion and a description of the corrective action that was 

performed. 

The Wisconsin DNR may request a quality improvement plan (QIP) if the number of excursions 

exceeds 5% of the operating time during any semi-annual reporting period.179

Recordkeeping Requirements

Weston will retain all monitoring data and support information for a period of at least five years 

from the data of the monitoring sample, measurement, report or application. 

Conclusions

According to §64.4(b), the use of a pressure differential and COMS to demonstrate a reasonable 

assurance of compliance with a PM standard is considered “presumptively acceptable” for CAM. 

Presumptively acceptable monitoring approaches are considered by EPA to be acceptable for 

CAM and do not require additional justification. The appropriate section of the EPA CAM 

guidance document is attached for reference. Furthermore, WPSC believes that the compliance 

and ICR test data convincingly demonstrate that the proposed monitoring approach and the 

selected indicator ranges meet the design requirements of §64.3 for Units 3 and 4.

During normal operation, compliance and ICR test data shows that the two Units operate well 

below their respective PM emissions limits. As stated previously, CAM does not apply to the 

condensable emissions from these units. WPSC has, nonetheless, elected to evaluate the 

indicator ranges based on the inclusion of condensable emissions, which provides a conservative 

measure.

An excursion, which is a reportable event under the CAM Rule, will be defined to meet the 

following criteria:

• For Unit 3, an OEM recommended pressure differential above 10 or below 2 

inches of water column for any one-hour average, or a stack opacity greater than 

10% for any one-hour average.

• For Unit 4, an OEM recommended pressure differential above 10 or below 2 

inches of water column for any 3-hour rolling average or a stack opacity greater 

than 10% for any 3-hour rolling average.

 179 The 5% QIP trigger is suggested in §64.8 of 40 CFR Part 64.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 29

 MONITORING APPROACH JUSTIFICATION FOR MATERIAL HANDLING

I. Background

Source Description

Weston Power Plant, located in Rothschild, Wisconsin, is owned and operated by Wisconsin 

Public Service Corporation (WPSC). Material handling Processes P31A, P31B, P31C, P32A, 

P32B, P32D, P32E, P34, P35A, P35B, P36A, P36B, P37A, P41, P42, P43, P45, P49, P50 and 

their associated control devices have been identified as processes that are subject to CAM based 

on determinations by the Wisconsin Department of Natural Resources (WDNR).

Emissions Limits

Processes P31A, P31B, P31C, P32A, P32B, P32D, P32E, P35A, and P35B are subject to the 

particulate matter emission limits for processes in NR 415.05(2), Wis. Adm. Code, or more 

stringent permit-specific requirements. Process P34 is subject to the particulate matter emission 

limit in NR 415.05(1)(m), Wis. Adm. Code, or more stringent permit-specific requirements. 

Processes P41, P42, P43, P45, P49 and P50 are subject to the limits in NR 415.06(2)(c) and NR 

405.08, Wis. Adm. Code, or more stringent permit specific requirements. The applicable opacity 

emissions limit is 10% for processes P31A, P31B, P31C, P32A, P32B, P32D, P32E, P34, P35A, 

P35B, P41, P42, P43, P45, P49 and P50 and 20% for processes P36A, P36B, and P37A. 

Monitoring Requirements

WPSC is required to monitor the operation of air pollution control systems per requirements in 

Air Pollution Control Operation Permit 737009020-P02 and Air Pollution Control Construction 

Permit 03-RV-248-R4. Pressure differential is identified in NR 439.055(2)(b)1, Wis. Adm. 

Code, as the operational variable of interest for dust collector systems. WPSC currently monitors 

the pressure differential across each dust collector listed in this plan on a continuous basis during 

process operation. Alarms are initiated if the pressure differential is outside of the acceptable 

ranges identified in Table 6. Records are maintained of any visual inspections performed on each 

exhaust stack.

II. Justification

Rationale for Selection of Performance Indicators 

The purpose of this section is to provide technical justification in support of a compliance 

assurance monitoring protocol using a combination of pressure differential and visible emission 

inspections as the indicator for compliance with the applicable PM emissions limit.

In general, dust collectors are designed to operate over a relatively small range of pressure 

differential. Pressure differential across the dust collector system is a measurement of the 

resistance to flow as the particulate-laden gas stream passes through the filter bag(s) and filter 

cake. Low gas flow, insufficient filter cake, and loose or broken filter bags are typical causes of 

low pressure differential. While low gas flow may cause a low differential pressure alarm, low 

process gas flow is unlikely to cause an exceedance of the particulate emission limitation. High 

gas flow or excess filter cake build-up are typical causes of high pressure differential. While 

excess filter cake may cause a high differential pressure alarm, it is unlikely to cause an 

exceedance of the particulate emission limitation. These examples illustrate that while 

differential pressure is a useful indicator for dust collector performance, it must be used in 
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 30

conjunction with visible inspections to provide a more reliable indicator of control equipment 

failures. 

The design pressure differential ranges and performance guarantees for each control device have 

been provided by the equipment manufacturer. If control equipment is operated outside of the 

normal pressure differential ranges (not caused by maintenance activities), one visual inspection 

will be completed to determine if an excursion has occurred or if normal process variations are 

the cause of the high or low differential pressure measurement. An excursion only occurs if an 

alarm is received and visible emissions are observed during the visual inspection. 

Rationale for Selection of Indicator Ranges

Validation of Indicator Ranges

Particulate testing has been completed on selected baghouse systems while operating within the 

manufacturer’s designed pressure drop ranges as shown in Table 13. All emission results were 

below the permitted emission limit. 

The requirement to monitor pressure differential and respond to values outside of the ranges 

specified in Table 6 has been in place since the issuance of the Air Pollution Control Operation 

Permit 737009020-P02 and Construction Permit 03-RV-248-R4. Currently the pressure 

differential alarms that have occurred have resulted in no visible emissions being recorded. 

This indicates proper operation of the control device. 

Corrective Action

Upon receiving a pressure differential alarm WPSC will complete a visual inspection for stack 

exhaust emissions. Any visible emissions noted as a result of an alarm will be considered an 

excursion and corrective action will be taken to restore control device operation. To the extent 

possible, any corrective action should reduce the potential of similar excursions from recurring.

Reporting Requirements

All visible emissions that are noted and result from a pressure drop alarm will be considered an 

excursion, documented and reported in the plant’s semi-annual Title V compliance reports. 

WPSC must include the date and time of each excursion and a description of the corrective 

action that was performed. 

Recordkeeping Requirements

WPSC must retain all monitoring data and support information for a period of at least five years 

from the date of the monitoring sample, measurement, report or application. If more than 9 

excursions occur (on a per source basis) during a reporting period, WPSC will develop a Quality 

Improvement Plan in accordance with §64.8 of 40 CFR Part 64.

Conclusions

Operation of the baghouse systems within the pressure drop ranges specified in Table 6 provides 

reasonable assurance of compliance with the applicable PM emission limit during normal 

operation. One visual inspection will be completed any time the baghouse system is operated 

outside of the pressure drop ranges specified in Table 6.
FID 737009020; Permit No. 737009020-P13, 737009020-P16 & 03-RV-248-R6 – Draft Permit for Public Comment PART IV – CAM Plans - page 31

Table __13__ - Emission Testing for Select Material Handling Sources

Source Control 

Device Description

Particulate 

Matter Emission 

Limit1180

(whichever is more 

restrictive) 

Emission 

Test Results 

(Year of 

Testing)

Pressure 

Differential 

During 

Testing

P31A C31A Coal Unloading 

(Collector A) 1.60 lb/hr

1.439 lb/hr 

(2006)

A1 1.6 to 2.2 

A2 2.3 to 4.0 

P31B C31B Coal Unloading 

(Collector B) 0.80 lb/hr .677 lb/hr (2006)

B1 3.9 to 6.7 

B2 3.8 to 5.7 

P30 C30

W4 System 1 New 

Reclaim Tunnel Exit 

#34

0.79 lb/hr and .01 

gr/dscf

.29 lb/hr; 

.0098 gr/dscf 

(2008) 3.4 to 3.5

P41 C41 W4 System 2 New 

Junction House #31

2.59 lb/hr and .02 

gr/dscf

1.05 lb/hr; 

.0085 gr/dscf 

(2008)

2.4 to 2.6

P42 C42 W4 System 3 New 

Junction House #32

0.79 lb/hr and .01 

gr/dscf

.28 lb/hr; 

.0059 gr/dscf 

(2008)

2.3 to 3.0

P43 C43 W4 System 4 Silo 

Fill #7

3.84 lb/hr and .01 

gr/dscf

2.51 lb/hr; .01 

gr/dscf (2008) 4.5

P45 C45 W4 System 2 Lime 

Storage Silo #27

0.26 lb/hr and .01 

gr/dscf

.07 lb/hr; 

.0028 gr/dscf 

(2008)

0.7 to 1.6

P49 C49

W4 System 4 FGD 

Byproduct Recycle 

#24

0.83 lb/hr and .02 

gr/dscf

.022 lb/hr; 

.0031 gr/dscf 

(2008)

-0.6 to 1.7

P50 C50 W4 System 5 FGD 

Waste Silo #20

0.326 lb/hr and .02 

gr/dscf

.04 lb/hr; 

.0032 gr/dscf 

(2008)

-0.4 to 1.1

 180 The emission limits listed in this table do not include the applicable averaging periods. In addition, Weston Power Plant Air Pollution 

Control Operation Permit 737009020-P02 provides emissions limits for PM and opacity, but no limits for PM10 are included in the permit. CAM 

regulations in Part 64.2(a)(1) state that for a unit to be subject to CAM, it must, among other things, “be subject to an emissions limitation or 

standard for the applicable regulated air pollutant....” For the purposes of CAM applicability, WPSC has conservatively assumed that PM is a 

surrogate for PM10. Therefore, WPSC considered the CAM rule applicable to those sources using a control device that are subject to a PM limit 

and have PM10 potential pre-control device emissions above 100 tpy.