AIR POLLUTION CONTROL CONSTRUCTION PERMIT

EI FACILITY NO: 737227040 CONSTRUCTION PERMIT NO.: 10-SDD-058-R1

TYPE:

Construction Permit for Process(es): B01, B02, P121, F122, F123, F125, F126, P131, P132,F133 and P141

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

Adm. Code,

Name of Source: WE Energies – Biomass Fueled Cogeneration Facility

Street Address: 210 Grand Avenue, Rothschild, WI

Responsible Official, & Title: Anthony Bernier, Director – Steam Services and Chilled Water 

Business

is authorized to construct described in the plans and specifications dated March 24, 2010, May 27, 2010, 

August 4, 2010, October 1, 2010, October 26, 2010, October 28, 2010, November 16, 2010 and October 

4, 2012 and operate boilers, material handling processes and other equipment / operations in conformity 

with the conditions herein. The authority to construct, modify, replace and/or reconstruct any process 

covered in this Construction Permit expires on March 28,2014.. This approved period to construct, 

modify, replace and/or reconstruct may be extended for up to 18 months upon request for cause, prior to 

expiration, unless otherwise specified by this construction permit. The conditions of this construction 

permit are permanent and may only be revised through a revision of the construction permit or through 

the issuance of a new construction permit. [s. 285.60(1), Wis. Stats.]

Conditions of the construction permit and the operation permit marked with an asterisk (*) have been 

created outside of the Wisconsin’s federally approved State Implementation Plan (SIP) and are not 

federally enforceable.

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

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

Dated at Madison, Wisconsin April 4, 2013

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

For the Secretary

By s/s Bart Sponseller 4/4/13

Bart Sponseller, Director

Bureau of Air Management
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 2 of 48

Part I

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

1. Particulate Matter including PM10 and PM2.5

a. Limitations: Best Available Control Technology (BACT). 

(1) 0.0076 pounds/MMBTU at all times (s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058)

(2) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 

12-month period.

(s. NR 405.08, Wis. Adm. Code , and 10-SDD-058)

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

(1) The boiler may only combust pipeline quality natural 

gas. (s. NR 405.08, 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) shall be used to demonstrate compliance or an 

alternate method approved in writing by the Department, 

shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for 

PM2.5, US EPA Other Test Method 201A for filterable and 

US EPA Method 202 for condensable particulate shall be 

used to demonstrate compliance or an alternate method 

approved in writing by the Department, shall be used. [s. 

NR 439.06(1), Wis. Adm. Code]

(3) Maintain a monthly record of the hours of operation of 

boiler B02, a record of the total MMBTU of natural gas 

combusted in that month and the monthly average quantity 

of natural gas combusted in the most recent 12-month 

period. These records to be available within 10 days of the 

end of any month (s. NR 439.04, Wis. Adm. Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 3 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

2. Sulfur dioxide

a. Limitations: 

(1) 0.0006 pounds/MMBTU heat input when combusting natural gas at all times (s. 285.65(7), Stats. , and 10-SDD058)

(2) Use of natural gas as specified in cond. A.2.b.(1) of this permit

(3) 3.25 tons in any month, averaged over any consecutive 12-month period, from boilers B01 and B02 combined.

(4) 0.2 pounds in any hour.

(5) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 

12-month period.

(s. 285.65(7), Stats. and 10-SDD-058)

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

(1) The boiler may only combust pipeline quality natural 

gas (s. 285.65(7), WI Stats.).

(1) Reference Test Method for Sulfur Dioxide Emissions:

Whenever compliance emission testing is required, US 

EPA Method 6, 6A or 6C shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department, shall be used. 

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

(2) Within 10 days of the end of any month, the permittee 

shall calculate the sulfur dioxide emissions for that month 

for boiler B02 and the total emissions of sulfur dioxide for 

boilers B01 and B02 (combined) for the previous 12 

months of operation (s. NR 439.04, Wis. Adm. Code).

(3) The permittee shall maintain a record of the calculations 

required under cond. I.A.2.c.(2) of this permit (s. NR 

439.04, Wis. Adm. Code).
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 4 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

3. Nitrogen oxides

a. Limitations1: BACT.2 

(1) 10 ppmvd (parts per million by volume) corrected to 5% oxygen, averaged over any 30 consecutive day period; 

and

(2) 7 pounds in any hour.

(3) Installation and use of ultra-low NOx burner technology for combustion of natural gas.

(4) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 

12-month period.

(5) 0.20 pounds/MMBTU heat input, including periods of startup, shutdown or malfunction, averaged over any 30 

consecutive day period (40 CFR 60.44b and s. 285.65(13) Wi Stats.)

(s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058)

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

(1) The permittee shall install and properly operate an ultra 

low NOx burner system for combusting natural gas in 

boiler B02 (s. NR 405.08, Wis. Adm. Code)

(2) Prior to startup of the boiler, the permittee shall install, 

maintain, calibrate and operate a continuous emission 

monitor (CEM) for measuring nitrogen oxides emissions 

from that boiler which meets the requirements of 

Performance specification 2 in 40CFR part 60, Appendix 

B. (ss. NR 405.08 and NR 439.09(2), Wis. Adm. Code).

(3) The permittee shall calibrate, maintain, and operate the 

continuous emission monitoring system (CEMS) required 

to be installed under cond. I.A.3.b.(2) of this permit. The 

CEM for the boiler shall be operational whenever nitrogen 

oxides may be being emitted from that boiler [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(4) Within 90 days of startup of the boiler, the CEM for 

that boiler shall be certified in accordance with 

Performance specification 2 in 40CFR part 60, Appendix B 

(ss. NR 405.08 and NR 439.09, Wis. Adm. Code)

(5) Within 120 days of startup of the boiler, the permittee 

shall submit a QA/QC plan for the NOx CEM for that 

boiler to the Department for review (ss. NR 405.08 and NR 

439.04(1), Wis. Adm. Code)

(6) The permittee shall follow the quality control and 

(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]

(2) The permittee shall maintain all of the following 

records:

(a) The calculated emission rates required under cond. 

A.3.b.(7) of this permit. The 30-day period calculations 

shall be available within 5 days of the end of any 30-day 

period;

(b) A copy of the QA/QC plan for the CEM;

(c) Any records required under the QA/QC plan;

(d) a record of the 15 minute CEM readings, corrected to 

5% oxygen, for each hour of boiler operation and the 

hourly emission rate for each hour of operation;

(e) a daily record of the quantity of natural gas used in 

cubic feet. (s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under par. (a) or a summary excess emission report 

under par. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

 

1 The NSPS limit for natural gas is 0.2 lb/MMBTU (approx. 170 ppmvd for gas) on a 30-day average basis.

2 The 30-day average emission rate may not include any hours or days in which that fuel type was not combusted.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 5 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

quality assurance plan required under cond. A.3.b.(5) of 

this permit at all times. This includes following the Plan as 

submitted to the Department and the Plan prior to as 

approved by the Department for the continuous emission 

monitoring system (CEMS) required for NOx emissions 

[ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. 

Code]

(7) The permittee shall demonstrate compliance with the 

NOx emission limitations as follows: 

a) Compliance with the hourly emission rate shall be 

determined by summing the 15 minute CEM readings and 

generating an hourly average emission rate.

(b) Compliance with any 30-day average emission 

limitation shall be determined using the following 

methodology: 

i. Averaging the valid 15 minute NOx measurements in any 

hour to determine an hourly average NOx emission rate; 

ii. Calculating the average 30-day emission rate by 

averaging the hourly emission rates for each hour of 

operation in the past 30 days; and

iii. A new 30-day rolling average emission rate is 

calculated each operating day as the average of all of the 

hourly NOx emission data for the preceding 30 operating 

days.

(s. NR 405.08, Wis. Adm. Code)

(8) The boiler may only combust pipeline quality natural 

gas. (s. NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be conducted 

within 180 days after the start of operation of the process to 

show compliance with the emission limitation.3[s. NR 

439.07, Wis. Adm. Code]

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of nitrogen oxides is defined as 

follows:

i. any hour in which the nitrogen oxides emission rate 

exceeds the hourly emission rate in cond. I.A.3.a.(2) of this 

permit; or

ii. Any 30-day period hour in which the nitrogen oxides 

emission rate exceeds the 30-day average emission rate in 

cond. I.A.3.a.(1)&(5) of this permit.

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40

CFR 60.46b and s. 285.65(13), Stats.)

(4) Maintain a monthly record of the hours of operation of 

boiler B02 and a record of the total hours of operation in 

the most recent 12-month period. These records to be 

available within 10 days of the end of any month (s. NR 

439.04, Wis. Adm. Code)

 

3

If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the 

Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 6 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

4. Carbon Monoxide (CO) 

a. Limitations: BACT. 

(1) 0.060 pounds/MMBTU heat input averaged over any 30-day period (including all periods of operation); and

(2) 70 pounds in any hour.

(3) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 

12-month period.

(s. NR 405.08, Wis. Adm. Code)

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

(1) Prior to startup of a boiler, the permittee shall install a 

continuous emission monitor (CEM) for measuring carbon 

monoxide emissions from that boiler which meets the 

requirements of Performance Specification 4 in 40CFR Part 

60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. 

Adm. Code)

(2) The permittee shall calibrate, maintain and operate the 

continuous emission monitoring system (CEMS) required 

to be installed under cond. I.A.4.b.(1) of this permit. The 

CEM for the boiler shall be operational whenever carbon 

monoxide may be being emitted from that boiler [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(3) Within 90 days of startup of the boiler, the CEM for 

that boiler shall be certified in accordance with 

Performance Specification 4 in 40CFR Part 60, Appendix 

B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(4) Within 120 days of startup of the boiler, the permittee 

shall submit a QA/QC plan for the CO CEM for that boiler 

to the Department for review.

(5) The permittee shall follow the quality control and 

quality assurance plan required under cond. A.3.b.(4) of 

this permit at all times. This includes following the Plan as 

submitted to the Department and the Plan prior to as 

approved by the Department for the continuous emission 

monitoring system (CEMS) required for CO emissions [ss. 

NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(6) The permittee shall demonstrate compliance with the 

CO emission limit as follows: 

a) Compliance with the hourly emission rate shall be 

determined by summing the 15 minute CEM readings and 

generating an hourly average emission rate.

(b) Compliance with any 30-day average emission 

limitation shall be determined using the following 

(1) Reference Test Method for carbon Monoxide 

Emissions: Whenever compliance emission testing is 

required, US EPA Method 10, 10A or 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) The permittee shall maintain the following records: 

(a) The calculated emission rates required under cond. 

I.A.4.b.(6) of this permit. The 30-day period calculations 

shall be available within 5 days of the end of any 30-day 

period;

(b) the total heat input to the boiler;

(c) A copy of the QA/QC plan for the CEM;

(d) Any records required under the QA/QC plan;

(e) a record of the 15 minute CEM readings, corrected to 

3% oxygen, for each hour of boiler operation and the 

hourly emission rate for each hour of operation.

(3) The owner or operator of a continuous emissions 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 7 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

methodology: 

i. Averaging the valid 15 minute CO measurements in any 

hour to determine an hourly average CO emission rate; 

ii. Calculating the average 30-day emission rate by 

averaging the hourly emission rates for each hour of 

operation in the past 30 days; and

iii. A new 30-day rolling average emission rate is 

calculated each operating day as the average of all of the 

hourly CO emission data for the preceding 30 operating 

days.

(c) No period when the boiler is not operating may be used 

in calculating the 30 day average emission rate.

(s. NR 405.08, Wis. Adm. Code)

(7) Initial compliance emission tests shall be conducted 

within 180 days after the start of operation of the process to 

show compliance with the emission limitation.4[s. NR 

439.07, Wis. Adm. Code]

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of carbon monoxide is defined as 

follows:

i. any hour in which the carbon monoxide emission rate for 

a boiler exceeds the 1-hour emission rate in cond. 

I.A.4.a.(2) of this permit; or

ii. any 30-day period hour in which the carbon monoxide 

emission rate for a boiler exceeds the 30-day average 

emission rate in cond. I.A.4.a.(1) of this permit.

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

(4) Maintain a monthly record of the hours of operation of 

boiler B02 and a record of the total hours of operation in 

the most recent 12-month period. These records to be 

available within 10 days of the end of any month (s. NR 

439.04, Wis. Adm. Code)

 

4

If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the 

Department may approve, in writing, an extension of time to conduct the test(s).
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 8 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

5. Volatile organic compounds (VOC)

a. Limitations: BACT. 

(1) Comply with the carbon monoxide emissions limitations in conds. I.A.4.a.(1) and (2) of this permit.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

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

(1) Comply with the requirements of conds. I.A.4.b.(1)-(7) 

of this permit

(s. NR 405.08, Wis. Adm. Code)

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, US EPA Method 

25A or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. 

NR 439.06(3)(a), Wis. Adm. Code]

(2) Comply with the recordkeeping requirements of conds. 

I.A.4.c.(2)-(4) of this permit (s. NR 439.04, Wis. Adm. 

Code)

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

6. Fluorides

a. Limitations: BACT. 

(1) Combust only Natural gas in boiler B02.

(2) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 

12-month period

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

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

(1) The boiler may only combust pipeline quality natural 

gas (s. NR 405.08, Wis. Adm. Code)

(1) Reference Test Method for Fluoride Emissions:

Whenever compliance emission testing is required, US 

EPA Method 13 or 13A or an alternate method approved in 

writing by the Department shall be used to demonstrate 

compliance. [s. NR 439.06, Wis. Adm. Code]

(2) Maintain a monthly record of the hours of operation of 

boiler B02 and a record of the total hours of operation in 

the most recent 12-month period. These records to be 

available within 10 days of the end of any month (s. NR 

439.04, Wis. Adm. Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 9 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

7. Visible Emissions (Opacity)

a. Limitations: BACT. 

(1) 10% opacity; and

(2) Combust only natural gas in boiler B02.

(ss. NR 405.08 and NR 431.05, Wis. Adm. Code and NSPS and 10-SDD-058)

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

(1) The boiler may only combust pipeline quality natural 

gas.

(s. NR 405.08, Wis. Adm. Code)

(2) Initial compliance emission tests shall be conducted 

within 180 days after the start of operation of the process to 

show compliance with the emission limitation.5[s. NR 

439.07, Wis. Adm. Code]

(3) The permittee shall perform the compliance emission 

tests required under condition I.A.7.b.(2) every 60 months 

within 60 days from the date of the anniversary date of the 

original stack test. [s. NR 439.075(3)(b) Wis. Adm. Code]

(1) Reference Test Method for Opacity: 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), Wis. Adm. Code]

 

5

If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the 

Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 10 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

8. Greenhouse Gases

a. Limitations: BACT.

(1) Greenhouse gas emissions may not exceed 185 lb CO2 per 1,000 pounds of steam produced, 

or 508 lb CO2 per MWh of steam produced per month, averaged over any consecutive 12-month period. (s. NR 405.08, 

Wis. Adm. Code and 10-SDD-058)

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

(1) Prior to startup of a boiler, the permittee shall

install, maintain, calibrate and operate a continuous 

emission monitor (CEM) for measuring carbon 

dioxide emissions from that boiler which meets the 

requirements of Performance specification 2 in 

40CFR part 60, Appendix B. (ss. NR 405.08 and NR 

439.09(2), Wis. Adm. Code).

(2) The permittee shall calibrate, maintain, and 

operate the continuous emission monitoring system 

(CEMS) required to be installed under cond. 

I.A.8.b.(1) of this permit. The CEM for a boiler 

shall be operational whenever carbon dioxide may 

be being emitted from that boiler [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. 

Code]

(3) Within 90 days of startup of a boiler, the CEM 

for that boiler shall be certified in accordance with 

Performance specification 2 in 40CFR part 60, 

Appendix B (ss. NR 405.08 and NR 439.09, Wis. 

Adm. Code)

(4) Within 120 days of startup of a boiler, the 

permittee shall submit a QA/QC plan for the CO2 

CEM for that boiler to the Department for review 

(ss. NR 405.08 and NR 439.04(1), Wis. Adm. Code)

(5) The permittee shall follow a quality control and 

quality assurance plan, prior to Department approval 

and as approved by the Department, for the 

continuous emission monitoring system (CEMS) 

required by conditions I.A.8.b.(1)&(2). [ss. NR 

407.09(4)(a)1., and NR 439.09(8), Wis. Adm. 

Code]

(6) Prior to startup of a boiler, the permittee shall 

install, maintain, calibrate and operate meters for 

steam flow, temperature and pressure; and measure 

gross process steam output in pounds per hour and 

MW-hours on a continuous basis.

(7) The permittee shall demonstrate compliance with 

the CO2e emission limitations as follows: 

(1) Reference Test Method for Carbon Dioxide Emissions:

Whenever compliance emission testing is required, US EPA 

Method 3A 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 maintain all of the following records:

(a) The calculated emission rates required under cond. 

A.1.3.b.(7) of this permit. The 30-day period calculations shall 

be available within 5 days of the end of any 30-day period;

(b) A copy of the QA/QC plan for the CEM;

(c) Any records required under the QA/QC plan;

(d) a record of the 15 minute CEM readings, for each hour of 

boiler operation and the hourly emission rate for each hour of 

operation;

(e) a daily record of the quantity of natural gas in cubic feet.

(s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions monitoring 

system shall submit quarterly excess emission reports to the 

department within 30 days following the end of each calendar 

quarter in accordance with subd. (a). The owner or operator shall 

submit either a full excess emission report under par. (a) or a 

summary excess emission report under par. (b), as specified in 

writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period during 

which the monitoring system was inoperative for any reason or 

causes, including monitor malfunction or calibration, except for 

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 any period during 

which the process being monitored was inoperative.

v. When no period of excess emissions occurred during the
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 11 of 48

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

(a) Compliance with any 12-month average emission 

limitation shall be determined using the following 

methodology: 

i. Averaging the valid 15 minute CO2 measurements 

in any hour to determine an hourly average CO2

emission rate; 

ii. Calculating the average 12-month emission rate 

by averaging the hourly emission rates for each hour 

of operation in the past 12 months; and

iii. A new 12-month average emission rate is 

calculated each month as the average of all of the 

hourly CO2 emission data for the preceding 12 

month period.

(s. NR 405.08, Wis. Adm. Code)

(8) The boiler may only combust pipeline quality 

natural gas. (s. NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be 

conducted within 180 days after the ”initial 

operation” of the process to show compliance with 

the emission limitation.6[s. NR 439.07, Wis. Adm. 

Code]

(10) The permittee shall perform the compliance 

emission tests required under condition I.A.3.b.(9) 

every 60 months within 60 days from the date of the 

anniversary date of the original stack test. [s. NR 

439.075(1)(b) Wis. Adm. Code]

quarter and the monitoring system had no period of downtime, an 

excess emissions report shall be filed stating such information.

(b) The summary excess emission report shall be submitted on a 

form provided by the department or in a format approved by the 

department, in writing

(c) An excess emission of carbon dioxide is defined as follows:

i. any 12-month period in which the carbon dioxide emission 

rate exceeds the 12-month average emission rate in cond. 

I.A.8.a.(1) of this permit.

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

(4) Maintain a monthly record of the hours of operation of boiler 

B02 and a record of the total hours of operation in the most 

recent 12-month period. These records to be available within 10 

days of the end of any month (s. NR 439.04, Wis. Adm. Code)

 

6

If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the 

Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 12 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

1. Particulate Matter including PM10 and PM2.5 (PM)

a. Limitations: Best Available Control Technology (BACT) and Maximum Achievable Control Technology 

(MACT)

BACT: (1) 0.024 pounds/MMBTU including backhalf (condensible) particulate matter for biomass alone or co-fired 

with natural gas, averaged over any 24-hour period (s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058); 

(2) 0.0076 pounds/MMBTU including backhalf (condensible) particulate matter for exclusive natural gas combustion (s. 

NR 405.08, Wis. Adm. Code and 10-SDD-058)

MACT: (3) 0.008 pounds/MMBTU filterable particulate matter only, averaged over any 24-hour period (s. 285.65(13), 

Stats. and 10-SDD-058). 

MACT: (4) At least 10% of the total heat input, on an annual average heat input basis, to Boiler B01 shall come from the 

combustion of biomass as defined in cond. ZZZ 1.a.(1) of this permit (s. 285.65(13), Stats. and 10-SDD-058)

BACT and MACT: (5) Fuel limitations as specified in cond. B.1.b.(1) of this permit (s. NR 405.08, Wis. Adm. Code and 

285.65(13), Stats. and 10-SDD-058)

(6) Heat input to the boiler from natural gas shall be no greater than 250 mmBtu in any hour (s. NR 405.08, Wis. Adm. 

Code and 10-SDD-058).

(7) 19.2 pounds in any hour (BACT) (s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

(8) 0.10 pounds/MMBTU heat input (s. NR 415.06(2)(c), Wis. Adm. Code)

(9) 0.085 pounds/MMBTU heat input, except during periods of startup, shutdown or malfunction (40 CFR 60.43b and s. 

285.65(13) Wi Stats.)

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

(1) The boiler may only combust pipeline quality natural 

gas and biomass as defined in cond. ZZZ.1.a.(2) of this 

permit (s. NR 405.08, Wis. Adm. Code)

(2) At all times that particulate matter may be emitted from 

this boiler, the boiler exhaust shall pass through a baghouse 

prior to emission to the atmosphere (s. NR 405.08, Wis. 

Adm. Code and s. 285.65(13), Stats.)

(3) Prior to startup of a boiler, the permittee shall install a 

continuous emission monitor (CEM) for measuring 

particulate matter emissions which meet the requirements 

of Performance Specification 11 in 40CFR Part 60, 

Appendix B (s. NR 405.08, Wis. Adm. Code and s. 

285.65(13), Stats.)

(4) The permittee shall calibrate, maintain, and operate the 

continuous emission monitoring system (CEM) required to 

be installed under cond. I.B.1.b.(3) of this permit. The 

CEM for a boiler shall be operational whenever particulate 

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required for PM10, US EPA Method 5, including backhalf 

(Method 202) shall be used to demonstrate compliance or 

an alternate method approved in writing by the Department, 

shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for 

PM2.5, US EPA Method 201A for filterable and US EPA 

Method 202 for condensable particulate shall be used to 

demonstrate compliance or an alternate method approved in 

writing by the Department, shall be used. [s. NR 

439.06(1), Wis. Adm. Code]

(3) The permittee shall keep a record of any fuel received 

for use in boiler B01 which is not natural gas or biomass [s. 

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

(4) The permittee shall maintain daily records, summarized 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 13 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

matter may be emitted from boiler B01 [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(5) Within 90 days of startup of a boiler, the CEM for that 

boiler shall be certified and correlated in accordance with 

Performance Specification 11 in 40CFR Part 60, Appendix 

B (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), 

Stats.)

(6) Within 120 days of startup of a boiler, the permittee 

shall submit a QA/QC plan for the PM CEM for that boiler 

to the Department for review.

(7) The permittee shall follow a quality control and quality 

assurance plan, prior to Department approval and as 

approved by the Department, for the continuous emission 

monitoring system (CEM) required by conditions 

I.B.1.b.(3)&(4) [ss. NR 407.09(4)(a)1., and NR 439.09(8), 

Wis. Adm. Code]

(8) All fuel sampling required under this permit shall be 

done in conformance with permit cond. I.ZZZ.4.a.(4) (s. 

NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be conducted 

within 180 days after the initial operation of the boiler to 

show compliance with the emission limitations in 

conds.1.a.(1)&(7). Additionally, the first compliance 

emission tests, only, shall also quantify the emission rate of 

PM10 and PM2.5 [s. NR 439.07, Wis. Adm. Code]

(10) The permittee shall perform the compliance emission 

tests required under condition I.B.1.a.(9) every 24 months 

within 60 days from the date of the last stack test. [s. NR 

439.075(3)(b) Wis. Adm. Code]

(11) The permittee shall demonstrate compliance with the 

PM emission limits as follows:

(a) For the 24-hour emission limitation in cond. 1.a.(3). of 

this section:

i. By summing the 15 minute data points to calculate an 

hourly average emission rate (s. NR 405.08, Wis. Adm. 

Code)

ii. By averaging the hourly average emission rates to 

determine a 24-hour average emission rate

iii. No hour in which the boiler is non-operational may be 

used to compliance with hourly or 24-hour average PM 

emission limitations

(b) For the emission limitations in cond. 1.a.(1), (7) & (8):

i. through the biennial stack testing required in cond. b.(10) 

of this section; and

monthly of all of the following and make such records 

available within 5 days of the end of any month:

(a) the total heat input to boiler B01 from all fuels;

(b) the hourly heat input rate for each fuel burned in that 

hour; and 

(f) a record of the 15 minute CEM readings for each hour 

of boiler operation and the hourly emission rate for each 

hour of operation;

(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. 

Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(4) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;

(b) Any records required under the QA/QC plan;

(c) Design plans or specifications that indicate that the 

boiler does not have the capacity of combusting more than 

250 MMBTU/hour of natural gas.

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

(5) The owner or operator of a continuous emissions 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing.

(c) An excess emission of particulate matter is defined as:
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 14 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

ii. demonstrating compliance with the particulate matter 

emission limitation in cond. a.3. of this section; and

iii. demonstrating compliance with the sulfur dioxide 

emission limitation in cond. I.B.2.a.(1) of this permit

(c) Compliance with the emission limitation for natural gas 

combustion shall be demonstrated by combusting only 

pipeline quality natural gas.

(s. NR 439.04, Wis. Adm. Code)

i. any 1-hour period in which the particulate matter 

emission rate for a boiler exceeds the 1-hour emission rate 

in conds. I.B.1.a.(7) of this permit;

ii. any 24-hour period in which the particulate matter 

emission rate for a boiler exceeds the 24-hour emission rate 

in cond. I.B.1.a.(1) or(3) of this permit

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40

CFR 60.46b and s. 285.65(13), Stats.)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 15 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

2. Sulfur Dioxide

a. Limitations:

(1) 8 pounds in any hour; and 

(2) 3.25 tons in any month averaged over any 12-month period from boilers B01 and B02 (combined) 

(3) Heat input to the boiler from natural gas shall be less than 250 mmBtu per hour.

(4) Fuel limitations as specified in cond. B.2.b.(1) of this permit 

(5) 0.20 pounds/MMBTU heat input averaged over any 30 consecutive day period (40 CFR 60.42b and s. 

285.65(13) Wi Stats.)

(s. NR 404.04, Wis. Adm. Code and s. 285.65(7), WI Stats. and 10-SDD-058)

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

(1) The boiler may only combust pipeline quality natural 

gas and biomass as defined in cond. ZZZ.1.a.(2) of this 

permit (s. 285.65(7), Wis. Stats.)

(2) Prior to startup of a boiler, the permittee shall install a 

continuous emission monitor (CEM) for measuring sulfur 

dioxide emissions which meet the requirements of 40 CFR 

Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 

439.06(4), Wis. Adm. Code. (ss. NR 405.08 and NR 

439.09(2) Wis. Adm. Code and s. 285.65(13), Stats.)

(3) The permittee shall calibrate, maintain, and operate the 

continuous emission monitoring system (CEM) required to 

be installed under cond. I.B.2.b.(2) of this permit. The 

CEM for a boiler shall be operational whenever sulfur 

dioxide may be emitted from boiler B01 [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(4) Within 90 days of startup of a boiler, the CEM for that 

boiler shall be certified in accordance with 40 CFR Part 75, 

s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 439.06(4), 

Wis. Adm. Code. (s. NR 405.08, Wis. Adm. Code and s. 

285.65(13), Stats.)

(5) Within 120 days of startup of a boiler, the permittee 

shall submit a QA/QC plan for the SO2 CEM for that boiler 

to the Department for review.

(6) The permittee shall follow a quality control and quality 

assurance plan, prior to Department approval and as 

approved by the Department, for the continuous emission 

(1) Reference Test Method for Sulfur Dioxide Emissions:

Whenever compliance emission testing is required, US 

EPA Method 6, 6A or 6C shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department, shall be used. [s. NR 439.06(2), Wis. 

Adm. Code]

(2) The permittee shall maintain daily records, summarized 

monthly, of all of the following and make such records 

available within 5 days of the end of any month:

(a) the total heat input to boiler B01 from all fuels;

(b) the total heat input rate to boiler B01 from natural gas 

used in that month; and

(c) a record of the 15 minute CEM readings for each hour 

of boiler operation and the hourly emission rate for each 

hour of operation.

(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. 

Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(3) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;

(b) Any records required under the QA/QC plan;

(c) Design plans or specifications that indicate that the 

boiler does not have the capacity of combusting more than 

250 MMBTU/hour of natural gas.

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

(4) The owner or operator of a continuous emissions 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 16 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

monitoring system (CEM) required by conditions 

I.B.2.b.(2)&(3) [ss. NR 407.09(4)(a)1., and NR 439.09(8), 

Wis. Adm. Code]

(7) The permittee shall demonstrate compliance with the 

SO2 emission limits by summing the 15 minute CEM 

readings and generating an hourly average SO2 emission 

rate (s. NR 405.08, Wis. Adm. Code)

(8) Initial compliance emission tests shall be conducted 

within 180 days after initial operation of the process to 

show compliance with the emission limitation. [s. NR 

439.07, Wis. Adm. Code]

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of sulfur dioxide is defined as 

follows:

i. any 1-hour period in which the sulfur dioxide emission 

rate for a boiler exceeds the 1-hour emission rate in cond. 

I.B.2.a.(1) of this permit.

ii. any 30-day period in which the sulfur dioxide emission 

rate for a boiler exceeds the emission rate in cond. 

I.B.2.a.(5) of this permit 

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40 

CFR60.47b)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 17 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

3. Nitrogen oxides

a. Limitations: Best Available Control Technology (BACT): Emissions may not exceed:

(1) 0.10 pounds/MMBTU averaged over any 30 consecutive day period and use of Selective Non-Catalytic 

Reduction (SNCR) (s. NR 405.08, Wis. Adm. Code and 10-SDD-058);

(2) 320 pounds in any hour; and (ss. NR 405.08 and NR 404.04, Wis. Adm. Code and 10-SDD-058 

(3) Fuel limitations as specified in cond. B.3.b.(1) of this permit (s. NR 405.08, Wis. Adm. Code and 285.65(13), 

Stats. and 10-SDD-058)

(4) Heat input to the boiler from natural gas shall be less than 250 mmBtu per hour (s. NR 405.08, Wis. Adm. Code and 

10-SDD-058)

(5) 0.20 pounds/MMBTU heat input, including periods of startup, shutdown or malfunction, averaged over any 30 

consecutive day period (40CFR60.44b and s. 285.65(13) Wi Stats.)

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

(1) The boiler may only combust pipeline quality natural 

gas and biomass as defined in cond. ZZZ.1.a.(2) of this 

permit (s. NR 405.08, Wis. Adm. Code)

(2) Prior to startup of the boiler, the permittee shall install a 

continuous emission monitor (CEM) for measuring 

nitrogen oxide emissions which meet the requirements of 

40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and 

s. NR 439.06(4), Wis. Adm. Code. (ss. NR 405.08 and NR 

439.09(2) Wis. Adm. Code and s. 285.65(13), Stats.)

(3) The permittee shall calibrate, maintain, and operate the 

continuous emission monitoring system (CEM) required to 

be installed under cond. I.B.3.b.(2) of this permit. The 

CEM for a boiler shall be operational whenever nitrogen 

oxides may be emitted from boiler B01 [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(4) Within 90 days of startup of the boiler, the CEM for 

that boiler shall be certified and correlated in accordance 

with 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code 

and s. NR 439.06(4), Wis. Adm. Code. (s. NR 405.08, Wis. 

Adm. Code and s. 285.65(13), Stats.)

(5) Within 120 days of startup of the boiler, the permittee 

shall submit a QA/QC plan for the PM CEM for that boiler 

to the Department for review.

(1) The permittee shall keep a record of any fuel received 

for use in boiler B01 which is not natural gas or biomass [s. 

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

(2) The permittee shall maintain daily records, summarized 

monthly of all of the following and make such records 

available within 5 days of the end of any month:

(a) the total heat input to boiler B01 from all fuels;

(b) the total heat input rate to boiler B01 from each fuel 

used in that month;

(c) The calculated emission rates required under cond. 

B.3.b.(7) of this permit, and;

(d) a record of the 15 minute CEM readings for each hour 

of boiler operation and the hourly emission rate for each 

hour of operation.

(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. 

Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(3) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;

(b) Any records required under the QA/QC plan;

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

(4) The owner or operator of a continuous emissions 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 18 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

(6) The permittee shall follow a quality control and quality 

assurance plan, prior to Department approval and as 

approved by the Department, for the continuous emission 

monitoring system (CEM) required by conditions 

I.B.3.b.(2)&(3) [ss. NR 407.09(4)(a)1., and NR 439.09(8), 

Wis. Adm. Code]

(7) The permittee shall demonstrate compliance with the 

NOx emission limitations as follows: 

(a) Compliance with the hourly emission rate shall be 

determined by summing the 15 minute CEM readings and 

generating an hourly average emission rate.

(b) Compliance with any 30-day average emission 

limitation shall be determined using the following 

methodology: 

i. Averaging the valid 15 minute NOx measurements in any 

hour to determine an hourly average NOx emission rate; 

ii. Calculating the average 30-day emission rate by 

averaging the hourly emission rates for each hour of 

operation in the past 30 days; and

iii. A new 30-day rolling average emission rate is 

calculated each operating day as the average of all of the 

hourly NOx emission data for the preceding 30 operating 

days.

(d) No hour in which the boiler is non-operational may be 

used to determine compliance with any NOx emission 

limitation.

(8) Initial compliance emission tests shall be conducted 

within 180 days after initial operation of the boiler to show 

compliance with the emission limitation. [s. NR 439.07, 

Wis. Adm. Code]

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of nitrogen oxides is defined as 

follows:

i. any 1-hour period in which the nitrogen oxides emission 

rate for the boiler exceeds the 1-hour emission rate in cond. 

I.B.3.a.(2) of this permit; or

ii. any 30-day period in which the nitrogen oxides emission 

rate for the boiler exceeds the 30-day average emission rate 

in conds. I.B.3.a.(1)&(5) of this permit.

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 

40CFR60.46b and s. 285.65(13), Stats.)

(5) Reference Test Method for Nitrogen Oxide Emissions:

Whenever compliance emission testing is required, US 

EPA Method 7 or an alternate method approved in writing 

by the Department shall be used to demonstrate compliance 

or an alternate method approved in writing by the 

Department, shall be used. [s. NR 439.06(6), Wis. Adm. 

Code]
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 19 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

4. Carbon Monoxide (CO) 

a. Limitations: BACT and MACT7. Emissions may not exceed:

(1) 0.12 pounds/MMBTU heat input averaged over any 12-month period including all periods of operation (MACT 

and BACT); 

(2) 0.12 pounds/MMBTU heat input averaged over any 30-day period excluding periods of boiler startup and 

shutdown (MACT and BACT); and

(3) 800 pounds in any hour.

(s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats. and 10-SDD-058)

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

(1) Prior to startup of a boiler, the permittee shall install a 

continuous emission monitor (CEM) for measuring carbon 

monoxide emissions from that boiler which meets the

requirements of Performance Specification 4 in 40CFR Part 

60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. 

Adm. Code)

(2) The permittee shall maintain, calibrate and operate the 

continuous emission monitoring system (CEMS) required 

to be installed under cond. I.B.4.b.(1) of this permit. The 

CEM for a boiler shall be operational whenever carbon 

monoxide may be being emitted from the boiler [ss. NR 

407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(3) Within 90 days of startup, the CEM shall be certified in 

accordance with Performance Specification 4 in 40CFR 

Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. 

Adm. Code)

(4) Within 120 days of startup of a boiler, the permittee 

shall submit a QA/QC plan for the CO CEM for that boiler 

to the Department for review.

(5) The permittee shall follow a quality control and quality 

assurance plan, prior to Department approval and as 

approved by the Department, for the continuous emission 

monitoring system (CEMS) required by conditions

I.B.4.b.(1)&(2). [ss. NR 407.09(4)(a)1., and NR 

439.09(8), Wis. Adm. Code]

(6) The permittee shall demonstrate compliance with the 

CO emission limit as follows: 

(a) Compliance with the hourly emission rate shall be 

determined by summing the 15 minute CEM readings and 

(1) Reference Test Method for Carbon Monoxide 

Emissions: Whenever compliance emission testing is 

required, US EPA Method 10, 10A or 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) The permittee shall maintain daily records, summarized 

monthly of all of the following and make such records 

available within 5 days of the end of any month:

(a) the total heat input to boiler B01 from all fuels;

(b) the total heat input rate to boiler B01 from each fuel 

used in that month; and

(c) The calculated emission rates required under cond. 

I.B.4.b.(6) of this permit, and;

(d) a record of the 15 minute CEM readings for each hour 

of boiler operation and the hourly emission rate for each 

hour of operation.

(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. 

Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(3) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;

(b) Any records required under the QA/QC plan;

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

(4) The owner or operator of a continuous emissions 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

 

7 The MACT emission limitation is for control of organic HAP’s (i.e. products of incomplete combustion).
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 20 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

generating an hourly average emission rate.

(b) Compliance with any 30-day average emission 

limitation shall be determined using the following 

methodology: 

i. Averaging the valid 15 minute NOx measurements in any 

hour to determine an hourly average NOx emission rate; 

ii. Calculating the average 30-day emission rate by 

averaging the hourly emission rates for each hour of 

operation in the past 30 days; and

iii. A new 30-day rolling average emission rate is 

calculated each operating day as the average of all of the 

hourly NOx emission data for the preceding 30 operating 

days.

(c) No period in which the boiler is not operating may be 

used in calculating the average emissions from the boiler.

(s. NR 405.08, Wis. Adm. Code)

(7) Initial compliance emission tests shall be conducted 

within 180 days after initial operation of the boiler to show 

compliance with the emission limitation.8[s. NR 439.07, 

Wis. Adm. Code]

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of carbon monoxide is defined as 

follows:

i. any 1-hour period in which the carbon monoxide 

emission rate for the boiler exceeds the 1-hour emission 

rate in cond. I.B.4.a.(3) of this permit; or

ii. any 30-day period in which the carbon monoxide 

emission rate for the boiler exceeds the 30-day average 

emission rate in cond. I.B.4.a.(2) of this permit.

iii. any 12-month period in which the carbon monoxide 

emission rate for the boiler exceeds the 12 month emission 

rate in cond. I.B.4.a.(1) of this permit 

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

 

8

.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 21 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

5. Volatile organic compounds (VOC)

a. Limitations: BACT. 

(1) Comply with the carbon monoxide emissions limitations in conds. I.B.4.a.(1), (2) and (3) of this permit.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

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

(1) Comply with the requirements of conds. I.B.4.b.(1)-(6) 

of this permit

(s. NR 405.08, Wis. Adm. Code)

(2) Initial emission tests shall be conducted within 180 days 

after initial operation of the boiler to determine the VOC 

emission rate from boiler B01. [s. NR 439.07, Wis. Adm. 

Code]

(1) Reference Test Method for VOC Emissions: Whenever 

compliance emission testing is required, US EPA Method 

25A or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. 

NR 439.06(3)(a), Wis. Adm. Code]

(2) Comply with the recordkeeping requirements of conds. 

I.B.4.c.(2)-(4) of this permit (s. NR 439.04, Wis. Adm. 

Code)

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

6. Fluorides

a. Limitations: BACT. 

(1) Combust only biomass or natural gas in boiler B01.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

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

(1) Combust only biomass or natural gas in boiler B01

(s. NR 405.08, Wis. Adm. Code).

(2) Initial emission tests shall be conducted within 180 days 

after initial operation of the boiler to determine the fluoride 

emission rate from boiler B01. [s. NR 439.07, Wis. Adm. 

Code]

(1) Reference Test Method for Fluoride Emissions:

Whenever compliance emission testing is required, US 

EPA Method 13 or 13A or an alternate method approved in 

writing by the Department shall be used to demonstrate 

compliance. [s. NR 439.06, Wis. Adm. Code]

(2) Comply with the recordkeeping requirements of cond. 

I.B.1.c.(3) of this permit (s. NR 439.04, Wis. Adm. Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 22 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

7. Visible Emissions (Opacity)

a. Limitations: BACT. 

(1) Not more than 10% opacity; and

(2) Combust only biomass or natural gas in boiler B01.

(ss. NR 405.08 and NR 431.05, Wis. Adm. Code and 10-SDD-058)

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

(1) Comply with the requirements of conds. I.B.1.b.(1)-(9) 

of this permit

(s. NR 405.08, Wis. Adm. Code)

(2) Initial compliance emission tests shall be conducted 

within 180 days after the start of operation of the process to 

show compliance with the emission limitation. [s. NR 

439.07, Wis. Adm. Code]

(3) Prior to startup of a boiler, the permittee shall install a 

continuous opacity monitor (COM) for measuring opacity 

from the boiler which meets the requirements of 40 CFR 

Part 60, Appendix B, Performance Specification 1 (s. NR 

405.08 and NR 439.09(1), Wis. Adm. Code)

(4) The permittee shall maintain, calibrate and operate the 

continuous opacity monitoring system (COMS) required to 

be installed under cond. I.B.7.b.(3) of this permit. The 

COM for the boiler shall be operational whenever the 

boiler is operating [ss. NR 407.09(4)(a)1., and NR 

439.09(1), Wis. Adm. Code]

(5) Within 90 days of startup, the COM shall be certified in 

accordance with Performance Specification 1 in 40 CFR 

Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. 

Adm. Code)

(6) Within 120 days of startup of a boiler, the permittee 

shall submit a QA/QC plan for the COM for the boiler to 

the Department for review.

(7) The permittee shall follow a quality control and quality 

assurance plan, prior to Department approval and as 

approved by the Department, for the continuous opacity 

monitoring system (COM) required by conditions

I.B.7.b.(3)&(4). [ss. NR 407.09(4)(a)1., and NR 

439.09(8), Wis. Adm. Code]

(8) The permittee shall demonstrate compliance with the 

(1) Reference Test Method for Opacity: 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), Wis. Adm. Code]

(2) Comply with the recordkeeping requirements of cond. 

I.B.1.c.(1)-(4) of this permit (s. NR 439.04, Wis. Adm. 

Code)

(3) The permittee shall maintain 

a record of the 6-minute average COM readings for each 

hour of boiler operation (s. NR 439.04(1), Wis. Adm. 

Code); 

(4) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;

(b) Any records required under the QA/QC plan.

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

(5) The owner or operator of a continuous opacity 

monitoring system shall submit quarterly excess emission 

reports to the department within 30 days following the end 

of each calendar quarter in accordance with subd. (a). The 

owner or operator shall submit either a full excess emission 

report under subd. (a) or a summary excess emission report 

under subd. (b), as specified in writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 time of any period 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 23 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

visible emission limit as follows: 

(a) by completing one cycle of sampling and

analyzing for each successive 10−second period; and 

(b) one cycle of data recording for each successive 

6−minute period.

during which the monitoring system was inoperative for 

any reason or causes, including monitor malfunction or 

calibration, except for 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 any 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 emissions report shall be filed stating 

such information.

(b) The summary excess emission report shall be submitted 

on a form provided by the department or in a format 

approved by the department, in writing

(c) An excess emission of opacity is defined as any 

6−minute period during which the average opacity exceeds 

the applicable emission limit.

(ss. NR 405.08 and NR 439.09(10)(b)1., Wis. Adm. 

Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 24 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

8 . Mercury

a. Limitations: MACT 9

(1) Not more than 0.2 x 10-6pounds/MMBTU (0.2 pounds per trillion BTU heat input) heat. This limitation 

applicable at all times with compliance demonstrated through a stack test and fuel mercury content limitations.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

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

(1) Within 180 days of initial operation, conduct a stack test 

on boiler B01 to demonstrate compliance with the mercury 

emission limitation in cond. I.B.8.a.(1) of this permit. This 

test to be repeated annually within 60 days of the 

anniversary date of the initial compliance test. (s. 

285.65(13), Stats.)

(2) At a minimum of 6 months prior to commencing 

operation of boiler B01, submit a plan for monitoring the 

fuel mercury content to ensure that the mercury emission 

limitations are being met. The Department, after public 

comment, may approve, amend or disapprove this plan. 

Boiler B01 may not operate without an approved 

monitoring plan (s. NR 405.08, Wis. Adm. Code).

(1) Reference Test Method for Mercury Emissions:

Whenever compliance emission testing is required, US 

EPA Method 29, ASTM-D6784-02 or an alternate method 

approved in writing by the Department shall be used to 

demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

9. Dioxin/Furans

a. Limitations: MACT. 10

(1) Not more than 0.007 nanograms per dry standard cubic meter (ng/dscm) as toxic equivalents (TEQ), corrected 

 

9, 

The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous Air 

Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters"; Vol. 75 Federal Register No. 

107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes 

operational for this permitted source. If that occurs and if the new federal rule establishes an emission limitation for dioxin/furans 

which is different from the limit set forth above, the permittee may file a permit revision request with the Department, seeking to 

conform the permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Section 285.27(2), Wis. Stats., 

the Department will take action to consider the approval of the revision request pursuant to applicable air permit rules and procedures 

which include the issuance of a public notice and opportunity for public comment.

10 The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous 

Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters"; Vol. 75 Federal Register No. 

107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes 

operational for this permitted source. If that occurs and if the new federal rule establishes an emission limitation for mercury which is 

different from the limit set forth above, the permittee may file a permit revision request with the Department, seeking to conform the 

permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Section 285.27(2), Wis. Stats., the 

Department will take action to consider the approval of the revision request pursuant to applicable air permit rules and procedures 

which include the issuance of a public notice and opportunity for public comment.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 25 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

to 7% oxygen on a 3-hour average.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

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

(1) Comply with all of the compliance demonstration 

requirements of conds. I.B.4.b., I.B.8.b. and I.B.10.b. of 

this permit (s. 285.65(13), Stats.)

(2) Within 180 days of initial operation, conduct a stack 

test on boiler B01 to determine the dioxin and furan 

emission rates for this boiler. This test shall be repeated 

every 5 years within 60 days of the anniversary date of the 

initial test. (s. 285.65(13), Stats.)

(1) Reference Test Method for dioxin Emissions: Whenever 

compliance emission testing is required, US EPA Method 

23 or an alternate method approved in writing by the 

Department shall be used to demonstrate compliance. [s. 

NR 439.06, Wis. Adm. Code]

(2) Comply with all of the recordkeeping requirements of 

conds. I.B.4.c., I.B.8.c. and I. B.10.c. of this permit (s. NR 

439.04, Wis. Adm. Code)

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

10. Hydrogen Chloride (HCl)

a. Limitations: MACT.11 

(1) Not more than 0.004 pounds/MMBTU heat input. This limitation applicable at all times with compliance

demonstrated through a stack test and fuel chlorine content limitations.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

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

(1) Within 180 days of initial operation, conduct a stack 

test on boiler B01 to demonstrate compliance with the HCl 

emission limitation in cond. I.B.10.a.(1) of this permit. 

This test to be repeated annually within 60 days of the 

anniversary date of the initial compliance test. (s. 

285.65(13), Stats.)

(2) At a minimum of 6 months prior to commencing 

operation of boiler B01, submit a plan for monitoring the 

fuel chlorine content to ensure that the HCl emission 

limitations are being met. The Department, after public 

comment, may approve, amend or disapprove this plan. 

Boiler B01 may not operate without an approved 

monitoring plan (s. NR 405.08, Wis. Adm. Code).

(1) Reference Test Method for HCl Emissions: Whenever 

compliance emission testing is required, US EPA Method 

26 or 26A or an alternate method approved in writing by 

the Department shall be used to demonstrate compliance. 

[s. NR 439.06, Wis. Adm. Code]

 

11 The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous 

Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters"; Vol. 75 Federal Register No. 

107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes 

operational for this permitted source. If that occurs and if the new federal rule establishes an emission limitation for mercury which is 

different from the limit set forth above, the permittee may file a permit revision request with the Department, seeking to conform the 

permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Section 285.27(2), Wis. Stats., the 

Department will take action to consider the approval of the revision request pursuant to applicable air permit rules and procedures 

which include the issuance of a public notice and opportunity for public comment.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 26 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 27 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

11. Greenhouse Gases

(a) Limitations: BACT.

(1) Greenhouse gas emissions may not exceed 3,050 pounds of CO2 per MWh of gross output, averaged over any 

consecutive 12-month period.

Gross output means the gross useful work performed by the steam generated. When the unit is 

generating only electricity, the gross useful work performed is the gross electrical output from the 

turbine/generator set. For cogeneration, the gross useful work performed is the gross electrical 

output plus 75 percent of the useful thermal output measured relative to ISO conditions that is not 

used to generate additional electrical output (i.e., steam delivered to an industrial process).

. (s. NR 405.08, Wis. Adm. Code)

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

(1) Prior to startup of a boiler, the permittee shall 

install, maintain, calibrate and operate a continuous 

emission monitor (CEM) for measuring carbon dioxide 

emissions from that boiler which meets the 

requirements of Performance specification 2 in 40CFR 

part 60, Appendix B. (ss. NR 405.08 and NR 

439.09(2), Wis. Adm. Code).

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

the continuous emission monitoring system (CEMS) 

required to be installed under cond. I.A.11.b.(1) of this 

permit. The CEM for a boiler shall be operational 

whenever carbon dioxide may be being emitted from 

that boiler [ss. NR 407.09(4)(a)1., and NR 439.09(5), 

Wis. Adm. Code]

(3) Within 90 days of startup of a boiler, the CEM for 

that boiler shall be certified in accordance with 

Performance specification 2 in 40CFR part 60, 

Appendix B (ss. NR 405.08 and NR 439.09, Wis. Adm. 

Code)

(4) Within 120 days of startup of a boiler, the permittee 

shall submit a QA/QC plan for the CO2 CEM for that 

boiler to the Department for review (ss. NR 405.08 and 

NR 439.04(1), Wis. Adm. Code)

(5) The permittee shall follow a quality control and 

quality assurance plan, prior to Department approval 

and as approved by the Department, for the continuous 

emission monitoring system (CEMS) required by 

conditions I.B.11.b.(1)&(2). [ss. NR 407.09(4)(a)1., 

and NR 439.09(8), Wis. Adm. Code]

(6) Prior to startup of a boiler, the permittee shall 

(1) Reference Test Method for Carbon Dioxide Emissions:

Whenever compliance emission testing is required, US EPA 

Method 3A 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 maintain all of the following records:

(a) The calculated emission rates required under cond. 

A.1.3.b.(7) of this permit. The 30-day period calculations shall 

be available within 5 days of the end of any 30-day period;

(b) A copy of the QA/QC plan for the CEM;

(c) Any records required under the QA/QC plan;

(d) a record of the hourly CEM readings, for each hour of boiler 

operation and the hourly emission rate for each hour of 

operation;

(e) a daily record of the quantity of natural gas in cubic feet and 

heat input to the boiler.

(s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions monitoring 

system shall submit quarterly excess emission reports to the 

department within 30 days following the end of each calendar 

quarter in accordance with subd. (a). The owner or operator shall 

submit either a full excess emission report under par. (a) or a 

summary excess emission report under par. (b), as specified in 

writing by the department.

(a) The full excess emission reports required under this 

subsection shall 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, 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 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 28 of 48

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler 

is subject to NSPS (Part 60, Subparts D and Db).

install, maintain, calibrate and operate a wattmeter to 

measure gross electrical output in MWh on a 

continuous basis.

(7) Prior to startup of a boiler, the permittee shall 

install, maintain, calibrate and operate meters for steam 

flow, temperature and pressure; and measure gross 

process steam output in pounds per hour and MWhours on a continuous basis.

(8) The permittee shall demonstrate compliance with 

the CO2 emission limitations as follows: 

(a) Compliance with any 12-month average emission 

limitation shall be determined using the following 

methodology: 

i. Averaging the valid 15 minute CO2 measurements in 

any hour to determine an hourly average CO2 emission 

rate; 

ii. Calculating the average 12-month emission rate by 

averaging the hourly emission rates for each hour of 

operation in the past 12 months; and

iii. A new 12-month average emission rate is 

calculated each month as the average of all of the 

hourly CO2 emission data for the preceding 12 month 

period.

(s. NR 405.08, Wis. Adm. Code)

(9) The boiler may only combust pipeline quality 

natural gas and biomass as defined in cond. ZZZ.1.a.(2) 

of this permit (s. 285.65(7), Wis. Stats.) (s. NR 405.08, 

Wis. Adm. Code)

(10) Initial compliance emission tests shall be 

conducted within 180 days after the initial operation of 

the boiler to show compliance with the emission 

limitation.12 [s. NR 439.07, Wis. Adm. Code]

(11) The permittee shall perform the compliance 

emission tests required under condition I.B.11.b.(10) 

every 60 months within 60 days from the date of the 

anniversary date of the original stack test. [s. NR 

439.075(1)(b) Wis. Adm. Code]

emissions.

iii. The date and starting and ending time of any period during 

which the monitoring system was inoperative for any reason or 

causes, including monitor malfunction or calibration, except for 

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 any 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 emissions report shall be filed stating such information.

(b) The summary excess emission report shall be submitted on a 

form provided by the department or in a format approved by the 

department, in writing

(c) An excess emission of carbon dioxide is defined as follows:

i. Any consecutive 12-month period in which the carbon dioxide 

emission rate exceeds the consecutive 12-month period emission 

rate in cond. I.B.11.a.(1) of this permit.

(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

 

12 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the 

Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 29 of 48

C. P121, S121 – Biomass fuels material handling processes (unloading, screening, hogging and conveying)

1 Particulate Matter including PM10 and PM2.5 (PM)

a. Limitations: Best Available Control Technology (BACT):

(1) PM - 0.004 grains per dry standard cubic foot of exhaust gas 

(2) 3.75 pounds per hour

(3) All material conveyors shall be fully enclosed

(s. NR 405.08, Wis. Adm. Code)

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

(1) Initial compliance emission tests for the dust collection 

system for P121 shall be conducted within 180 days of 

startup of P121 in accordance with cond. I. ZZZ.4. of this 

permit [s. NR 439.07, Wis. Adm. Code]

(2) All material handling operations shall be conducted in 

an enclosed building or within enclosures. Such enclosures 

or buildings shall be equipped with a dust collections 

system and baghouse or use a wet dust suppression system 

whenever solid material may become airborne.

(3) The pressure drop across the fabric filter baghouse or 

baghouse system shall be maintained within the range 

identified by testing in condition I.C.1.b.(1). of this permit. 

[s. NR 407.09(4)(a)1., Wis. Adm. Code]

(4) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(5) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required for PM10, US EPA Method 5, including backhalf 

(Method 202) shall be used to demonstrate compliance or 

an alternate method approved in writing by the Department, 

shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for 

PM2.5, US EPA Method 201A for filterable and US EPA 

Method 202 for condensable particulate for condensable 

shall be used to demonstrate compliance or an alternate 

method approved in writing by the Department, shall be 

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

(3) The permittee shall record the pressure drop across the

fabric filter baghouse system at least once each operating 

shift whenever the dust collection system is in operation. 

[s. NR 439.055(2)(b)1., Wis. Adm. Code]

(4) The permittee shall keep records of all inspections, 

checks and any maintenance or repairs performed on the 

dust collection system, containing the date of the action, a 

description of the action, initials of inspector, and the 

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

(5) Instrumentation to monitor the pressure drop across the 

fabric filter baghouse system shall be installed and operated 

properly. [s. NR 439.055(1)(a), Wis. Adm. Code]

(6)The permittee shall record the time and date when the 

wet dust suppression system is in operation, all opacity 

observations made during operation of the wet suppression 

system and any corrective actions taken (including when 

taken) to prevent fugitive dust from becoming airborne (s. 

NR 439.04, Wis. Adm. Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 30 of 48

C. P121, S121 – Biomass fuels material handling processes (unloading, screening, hogging and conveying)
FID No. 737227040, Permit No. 10-SDD-058 Page 31 of 48

C. P121, S121 – Biomass fuels material handling processes (unloading, screening, hogging and conveying)

2. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) Initial compliance emission tests for the dust collection 

system for P121 shall be conducted within 180 days of 

startup of P121 in accordance with cond. I. ZZZ.4. of this 

permit [s. NR 439.07, Wis. Adm. Code]

(2) All material handling operations shall be conducted in 

an enclosed building or within enclosures. Such enclosures 

or buildings shall be equipped with a dust collections 

system and baghouse or use a wet dust suppression system 

whenever solid material may become airborne [s. NR 

406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(3) The pressure drop across the fabric filter baghouse 

system shall be maintained within the range identified by 

condition I.C.1.b.(1). of this permit. [s. NR 407.09(4)(a)1., 

Wis. Adm. Code]

(3) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with emission limits. [s. 

285.65(3), Wis. Stats.]

(4) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(5) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

(1) Reference Test Method for Visible Emissions: 

Whenever compliance emission testing is required, US 

EPA Method 9 or Method 22 shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. 

Adm. Code]

(2) The permittee shall record the pressure drop across the 

fabric filter baghouse system at least once each operating 

shift whenever the dust collection system is in operation. 

[s. NR 439.055(2)(b)1., Wis. Adm. Code]

(3) The permittee shall keep records of all inspections, 

checks and any maintenance or repairs performed on the 

dust collection system, containing the date of the action, a 

description of the action, initials of inspector, and the 

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

(4) Instrumentation to monitor the pressure drop across the 

fabric filter baghouse system shall be installed and operated 

properly. [s. NR 439.055(1)(a), Wis. Adm. Code]

(5)The permittee shall record the time and date when the 

wet dust suppression system is in operation, all opacity 

observations made during operation of the wet suppression 

system and any corrective actions taken (including when 

taken) to prevent fugitive dust from becoming airborne (s. 

NR 439.04, Wis. Adm. Code)
FID No. 737227040, Permit No. 10-SDD-058 Page 32 of 48

D. F122 –Self Unloading Truck Unloading Station

1. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

5% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) Initial compliance emission tests for F122 shall be 

conducted within 180 days of startup of F122 in accordance 

with cond. I. ZZZ.4. of this permit [s. NR 439.07, Wis. 

Adm. Code]

(2) Particulate matter emissions shall be controlled using 

self unloading trucks in combination with the dust 

collection system for P121 and/or a wet dust suppression 

system [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. 

Code]

(3) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with emission limits. [s. 

285.65(3), Wis. Stats.]

(4) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(5) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

(1) Reference Test Method for Visible Emissions: 

Whenever compliance emission testing is required, US 

EPA Method 9 or Method 22 shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. 

Adm. Code]

(2)The permittee shall record the time when the wet dust 

suppression system is in operation, all opacity observations 

made during operation of the wet suppression system and 

any corrective actions taken (including when taken) to 

prevent fugitive dust from becoming airborne (s. NR 

439.04, Wis. Adm. Code)

E. F123 Biomass fuel storage and reclaim

1. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

5% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) Particulate matter emissions shall be controlled using a 

biomass fuels storage building designed to enclose the 

entire storage pile and the reclaim activities[s. NR 406.10 

and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(2) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with visible emission 

limit. [s. 285.65(3), Wis. Stats.]

(1) Reference Test Method for Visible Emissions: 

Whenever compliance emission testing is required, US 

EPA Method 9 or Method 22 shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. 

Adm. Code]

(3)The permittee shall record the time when any corrective 

actions taken (including when taken) to prevent fugitive 

dust from becoming airborne (s. NR 439.04, Wis. Adm. 
FID No. 737227040, Permit No. 10-SDD-058 Page 33 of 48

(3) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(5) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

Code)

F. P131,P132 – Lime storage silo vent (P131) and boiler ash system vents (S131, S132A, S132B)

1. Particulate Matter including PM10 and PM2.5 (PM) (BACT) 

a. Limitations: Best Available Control Technology (BACT):

(1) P131, use of silo bin vent system

 (a) PM - 0.004 grains per dry standard cubic foot of exhaust gas and 0.034 pounds per hour

 (b) PM2.5 - 0.002 grains per dry standard cubic foot of exhaust gas and 0.017 pounds per hour

(2) P132, S132A, use of ash storage vent system #1

 (a) PM - 0.004 grains per dry standard cubic foot of exhaust gas and 0.029 pounds per hour

 (b) PM2.5 - 0.002 grains per dry standard cubic foot of exhaust gas and 0.014 pounds per hour

(3) P132, S132B, use of ash storage vent system #2

 (a) PM - 0.004 grains per dry standard cubic foot of exhaust gas and 0.029 pounds per hour

 (b) PM2.5 - 0.002 grains per dry standard cubic foot of exhaust gas and 0.014 pounds per hour

(4) All material conveyors shall be fully enclosed

[s. NR 415.06(2)(c), Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code,] (s. NR 405.08, Wis. Adm. Code)

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

(1) The permittee shall determine the hourly emissions 

using operating parameters and OEM emission factors 

within 180 days after the start of operation of the process to 

show compliance with the emission limitation. [s. 

285.65(3), Wis. Stats.]

(2) Particulate matter emissions shall be controlled using a 

using silo bin vent system to meet the BACT limits. [s. NR 

405.08(2), Wis. Adm. Code]

(3) The silo bin vent system be operated at all times when 

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required for PM US EPA Method 5, including backhalf 

(Method 202) shall be used to demonstrate compliance or 

an alternate method approved in writing by the Department, 

shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for 

PM2.5, US EPA Method 201A for filterable and US EPA 

Method 202 for condensable shall be used to demonstrate 

compliance or an alternate method approved in writing by 
FID No. 737227040, Permit No. 10-SDD-058 Page 34 of 48

F. P131,P132 – Lime storage silo vent (P131) and boiler ash system vents (S131, S132A, S132B)

the process is in operation [s. NR 406.10 and s. NR 

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

(4) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with emission limits. [s. 

285.65(3), Wis. Stats.]

(5) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats.]

(6) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

(7) For P131, S131, the pressure drop across the bin vent 

filter shall be monitored at least once per day for any day 

that the process operates (s. NR 405.08, Wis. Adm. Code)

the Department, shall be used. [s. NR 439.06(1), Wis. 

Adm. Code]

(3) The permittee shall keep and maintain on site technical 

drawings, blueprints or equivalent records of the silo bin 

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

(4) The permittee shall keep records of all inspections, 

checks and any maintenance or repairs performed on the 

silo bin vent system, containing the date of the action, 

initials of inspector, and the results. [s. NR 439.04(1)(d), 

Wis. Adm. Code]

(5) The permittee shall record the time and date when 

corrective actions are taken to prevent fugitive dust from 

being generated by the process (s. NR 439.04, Wis. Adm. 

Code)

(6) A record of the pressure drop readings required under 

cond. F.b.(7) of this permit (s. NR 439.04, Wis. Adm. 

Code)
FID No. 737227040, Permit No. 10-SDD-058 Page 35 of 48

F. P131,P132A and P132B – Lime storage silo (P131) and boiler ash silos (P132A, P132B)

2. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) The silo bin vent system shall be operated at all times 

when the process is in operation. [s. NR 406.10 and s. NR 

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

(2) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with emission limits. [s. 

285.65(3), Wis. Stats.]

(3) Whenever fugitive dust emissions are observed from the 

process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats]

(4) All material conveyors shall be fully enclosed (s. NR 

405.08, Wis. Adm. Code)

(1) Reference Test Method for Visible Emissions: 

Whenever compliance emission testing is required, US 

EPA Method 9 or Method 22 shall be used to demonstrate 

compliance or an alternate method approved in writing by 

the Department shall be used. [s. NR 439.06(9)(a)1., Wis. 

Adm. Code]

(2) The permittee shall keep records of all inspections, 

checks and any maintenance or repairs performed on the 

silo bin vent system, containing the date of the action, 

initials of inspector, and the results. [s. NR 439.04(1)(d), 

Wis. Adm. Code]

(3) The permittee shall record the time when corrective 

actions are taken to prevent fugitive dust from being 

generated by the process (s. NR 439.04, Wis. Adm. 

Code)
FID No. 737227040, Permit No. 10-SDD-058 Page 36 of 48

G. P141 – New cooling tower

1. Particulate Matter including PM10 and PM2.5 (PM) (BACT) 

a. Limitations: Best Available Control Technology (BACT):

(1) each cell shall be equipped, maintained and operated with high efficiency drift eliminators designed to limit the loss of 

droplets from the units to not more than 0.0005 percent of the water circulation rate; 

(2) emissions may not exceed: 

(a) 0.072 pounds per hour of total of PM.

(b) 0.00016 pounds per hour of PM2.5.

(s. NR 405.08, Wis. Adm. Code)

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

(1) The total dissolved solids (TDS) concentration in the 

cooling water may not exceed 1,600 ppm (0.16 %). [ss. NR 

439.04 and NR 405.08, Wis. Adm. Code]

(2) The permittee shall operate the Cooling Tower in 

accordance with the manufacturer’s recommendations [s. 

NR 405.08, Wis. Adm. Code]

(3) The permittee shall operate the cooling tower to prevent 

significant contribution to fog or icing on off-site roadways 

and areas surrounding the facility. [s. NR 405.08, Wis. Adm. 

Code]

(1) The permittee shall determine and record the following 

on a weekly basis or more frequently if required:13

(a) the concentration of Total Dissolved Solids (TDS) in 

the cooling water, in parts per million (ppm);

(b) the cooling tower water circulation rate, gallons per 

minute, and;

(c) the calculated average particulate matter emission rates, 

for PM and PM2.5 in pounds per hour. [s. NR 439.04, Wis. 

Adm. Code]

(2) The permittee shall maintain on file:

(a) the design loss specifications for the drift eliminators;

(b) manufacturer’s recommended procedures for 

inspection and maintenance;

(c) a description of the type of water treatment system in 

use in the cooling towers. The description is to include the 

average concentration and material safety data sheets, 

MSDS, for each water treatment additive. [ss. NR 439.04 

and NR 468.30(4)(a), Wis. Adm. Code]

G. P141 – New cooling tower

2. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) The permittee shall operate the Cooling Tower in 

accordance with the manufacturer’s recommendations and 

the malfunction prevention and abatement plan for the 

equipment associated with this process. [s. NR 405.08, Wis. 

Adm. Code]

(2) The permittee shall operate the cooling tower to prevent 

significant contribution to fog or icing on off-site roadways 

and areas surrounding the facility. [s. NR 405.08, Wis. Adm. 

Code] 

(1) The permittee shall maintain on file:

(a) the design loss specifications for the drift eliminators;

(b) manufacturer’s recommended procedures for 

inspection and maintenance;

(c) a description of the type of water treatment system in 

use in the cooling towers. The description is to include the 

average concentration and material safety data sheets, 

MSDS, for each water treatment additive. [ss. NR 439.04 

and NR 468.30(4)(a), Wis. Adm. Code]

 

13 More frequent monitoring may be required to maintain manufactures guarantees, or for compliance with other regulatory requirements such as 

WPDES permit. Calculations are based on Cooling Tower Emissions Quantification Using the Cooling Tower Institute Test Code ATC-40 and TDS 

concentration specific to the facility.
FID No. 737227040, Permit No. 10-SDD-058 Page 37 of 48

H. F125 & F133 - Biomass delivery trucks haul roads & Boiler ash haul roads

Pollutant: 1. Particulate Matter Emissions (BACT).

a. Limitations:

(1)The permittee shall pave the haul roads.

(2) Use of Wet dust suppression

[s. NR 405.08, Wis. Adm. Code, s. NR 431.05, Wis. Adm. Code, s. 285.65(3), Wis. Stats., s. 285.65(3), Wis. Stats.]

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

(1) All facility haul roads shall be paved.

(2) The process shall be monitored in accordance with a 

Fugitive Dust Control Plan. The Department may request 

the permittee to review and amend the plan if necessary to 

maintain emissions in compliance with emission limits. [s. 

285.65(3), Wis. Stats.]

(3) Whenever fugitive dust emissions are observed from 

the process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(1) Reference Test Method for Particulate Matter 

Emissions: Whenever compliance emission testing is 

required, the appropriate US EPA Method 9 shall be used 

to demonstrate compliance or an alternate method 

approved in writing by the Department, shall be used. [s. 

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

(2) The permittee shall record the time when any corrective 

actions taken (including when taken) to prevent fugitive 

dust from becoming airborne (s. NR 439.04, Wis. Adm. 

Code)
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 38 of 48

I. F126, S126 – Mid transfer tower (wood transfer from Domtar wood room to the CFB boiler)

1. Opacity (visible emissions)

a. Limitations: Best Available Control Technology (BACT):

5% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code] 

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

(1) Initial compliance emission tests for F126 shall be 

conducted within 180 days of startup of F126 in accordance 

with cond. I. ZZZ.4. of this permit [s. NR 439.07, Wis. 

Adm. Code]

(2) ) All material transfer operations shall be conducted in 

an enclosed conveyor system

(s. NR 405.08, Wis. Adm. Code)

(3) Whenever fugitive dust emissions are observed from 

the process, the permittee shall take corrective actions to 

prevent fugitive dust from becoming airborne. [s. 

285.65(3), Wis. Stats

(1) Reference Test Method for Visible Emissions: 

Whenever compliance emission testing is required for 

F126, US EPA Method 9 or Method 22 shall be used to 

demonstrate compliance or an alternate method approved in 

writing by the Department, shall be used. [s. NR 

439.06(9)(a)1., Wis. Adm. Code]
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 39 of 48

ZZZ. Conditions Applicable to the Entire Facility. 

1. Biomass definitions.

a. Definition of biomass for:

(1) For Federal MACT requirements only: Biomass means but is not limited to, wood residue, and wood products 

(e.g. trees, tree stumps, tree limbs, bark, lumber, sawdust, sanderdust, chips, scraps, slabs, millings, and shavings); animal 

manure, including litter and other bedding materials; vegetative agricultural and silvicultural materials, such as logging 

residues (slash), nut and grain hulls and chaff (e.g. almond, walnut, peanut, rice, and wheat), bagasse, orchard prunings, 

corn stalks, coffee bean hulls and grounds.

(2) For all other permit requirements: means a resource that derives energy from wood or plant material or residue, 

clean solid wood waste and crops grown for use as a resource. Fuel sources may include the following and other 

qualifying clean biomass sources:

• logging residue

• discarded woody material from primary manufacturing facilities such as paper mills, sawmills, or chip mills

• on-site pulp & paper wastewater treatment plant residue

• leftover woody material from secondary manufacturers such as door, window, cabinet manufacturers

• woody biomass from municipality wood waste, tree services, and construction companies

• clean solid wood waste from discarded wood packaging such as pallets/crating and from construction and 

demolition activities

• woody biomass plantations, energy crops and agricultural residues.

Biomass excludes edible portions of food crops, refuse derived fuel, treated wood, municipal solid waste, sewerage 

sludge, and animal waste.

(3) The definition of biomass in cond. ZZZ.1.a.(1) of this permit does not allow the combustion of any of the materials 

excluded from being defined as biomass in cond. ZZZ.1.a.(2) of this permit.

(s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

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

2. Stack Parameters

a. Limitations: All stacks at the facility shall meet the parameters in subd. b. of this section (s. NR 405.08, Wis. Adm. 

Code and 

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

(a) Boilers:

 (i) B01, Stack S01: the height shall be at a minimum 265 

feet above ground level and the inside diameter shall be no 

greater than 10 feet;

 (ii) B02, Stack S02: : the height shall be at a minimum 

180 above ground level and the inside diameter shall be no 

greater than 9 feet;

 (b) Cooling Tower: 

(1) 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]

Note: These requirements are included because the source 

was reviewed with these stack parameters and it was 

determined that no increments or ambient air quality 

standards will be violated when constructed as proposed.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 40 of 48

 (i) P141, Stack S141: the height of each cell shall be 

maintained at a minimum 65 feet above ground level and 

the inside diameter of each cell shall be no greater than 32

feet;

(c) Material handling:

(i) P121, S121: the height shall be maintained at a 

minimum 110 feet above ground level and the inside 

diameter shall be no greater than 5 feet;

(ii) (ii) P131, S131: the height shall be maintained at a 

minimum 50 feet above ground level and the inside 

diameter shall be no greater than 1.33 feet;

(iii) P132A, S132A: the height of the vent shall be 

maintained at a minimum 64 feet above ground level and 

the inside diameter shall be no greater than 1 foot; and

(iv) P132B, S132B: the height of the vent shall be 

maintained at a minimum 20 feet above ground level and 

the inside diameter shall be no greater than 0.42 feet.

[s. NR 404. 04(3) & (8), and NR 404.05(3), Wis. Adm. Code, s. 

285.65(3), Stats.]

(2) Except for S131, S132A, and S132B the stacks may not

be equipped with a rainhat or other device that may impede 

the upward velocity of the exhaust gasses. [s. NR 404. 04(3) 

& (8), and NR 404.05(3), Wis. Adm. Code, s. 285.65(3), Stats.]

3. Malfunction Prevention and Abatement Plan and Fugitive Dust Plan

a. Limitations:

(1) A malfunction prevention and abatement plan shall be prepared and followed for the plant.

[s. NR 439.11, Wis. Adm. Code]

(2) All air pollution control equipment shall be operated and maintained in conformance with good engineering practices 

(i.e. operated and maintained according to manufacturer’s specifications and directions) to minimize the possibility 

for the exceedance of any emission limitations.

[s. NR 439.11(4), Wis. Adm. Code]

(3) The facility shall submit an amended plan to include all process and boilers included in this permit to the Wisconsin 

Department of Natural Resources, West Central Region Air Management Program, Wausau Service Center for 

review. This submittal shall be made within 120 days of initial operation of boiler B01. The department may amend 

the plan if deemed necessary for malfunction prevention or for the reduction of excess emissions during malfunctions.

[s. NR 439.11(2), Wis. Adm. Code]
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 41 of 48

(4) The permittee shall submit a Fugitive Dust Plan to the Department for review at least 120 days prior to the startup of 

process P121, F122, F123, F126, P131 or P132 (120 days prior to the startup of the first of these processes to be started 

up). The Plan shall, at a minimum, include the following elements and precautions for limiting fugitive dust14 emissions:

(a) Use, where possible, of water or chemicals for control of dust from construction operations;

(b) Application of asphalt, water, suitable chemicals or plastic covering on dirt roads, material stockpiles and other 

surfaces which can create airborne dust, provided such application does not create a hydrocarbon, odor or water pollution 

problem; and

(c) Covering or securing of materials likely to become airborne while being moved on public roads, railroads or navigable

waters.

[s. NR 405.08, Wis. Adm. Code]

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

(1) The malfunction prevention and abatement plan shall 

be developed to prevent, detect and correct 

malfunctions or equipment failures which may cause 

any applicable emissions limitation to be violated or 

which may cause air pollution.

[s. NR 439.11(1), Wis. Adm. Code] 

(2) This malfunction prevention and abatement plan shall 

include installation, maintenance and routine 

calibration procedures for the process monitoring and 

control equipment instrumentation. This plan shall 

require an instrumentation calibration at the frequency 

specified by the manufacturer, yearly or at a frequency 

based on good engineering practice as established by 

operational history, whichever is more frequent. 

Inspection and calibration shall also be conducted 

whenever instrumentation anomalies are noted.

[ss. NR 407.09(1)(c)1.c., NR 439.055(4) and s. NR 

439.11, Wis. Adm. Code] 

(3) The malfunction prevention and abatement plan shall 

require a copy of the operation and maintenance 

manual for the control equipment to be maintained on 

site. The plan shall contain all of the elements in s. NR 

439.11(1)(a) - (h), Wis. Adm. Code.

[s. NR 439.11, Wis. Adm. Code]

(1) The permittee shall maintain the following records:

(a) A copy of the malfunction prevention and abatement 

plan; and

(b) any records required to be maintained under the 

malfunction prevention and abatement plan.

(s. NR 439.04, Wis. Adm. Code)

 

14 The use of the term “fugitive dust” anywhere in this permit is not meant to imply that these emissions are considered fugitive 

emissions under ch. NR 405, Wis. Adm. Code.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 42 of 48

4. Stack Testing and Fuel Sampling Requirements.

a. Limitations:

(1) If any required compliance emission test(s) cannot be conducted within the time frames specified in this permit, the 

permit holder may request and the Department may approve, in writing, an extension of time to conduct the test(s). 

Such an extension shall not exceed 90 calendar days.

[s. NR 439.07, Wis. Adm. Code]

(2) All testing shall be performed with the emissions unit operating at capacity or as close to capacity as practicable and 

in accordance with approved procedures. If operation at capacity is not feasible, the source shall operate at a capacity 

level which is approved by the Department in writing.

[s. NR 439.07(1), Wis. Adm. Code]

(3) The Department shall be informed at least 20 working days prior to any stack testing, so a Department representative 

can witness the testing. At the time of notification, a compliance emission test plan shall also be submitted to the 

Department for approval. When approved in writing, an equivalent test method may be substituted for the reference 

test method. The notification and test plan shall be submitted to the Wisconsin Department of Natural Resources, 

West Central Region Air Management Program, Wausau Service Center.

[s. NR 439.07(2), Wis. Adm. Code]

(4) Conduct all sampling of liquid fossil fuels in accordance with s. NR 439.08(2), Wis. Adm. Code [s. NR 439.08(2), 

Wis. Adm. Code

(5) Use USEPA method 19 to convert measured concentration values to pounds/MMBTU values when needed (s. NR 

405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(6) Unless otherwise approved by the Department in writing, all stack testing required for Boiler B01 shall be done 

using only biomass as the fuel and at least 95% of maximum boiler capacity (i.e. heat input minimum of 760 

MMBTU/hour) (s. NR 405.08 and 10-SDD-058) 

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

(1) Two copies of the report on any compliance emission 

tests shall be submitted to the Department for 

evaluation within 60 days following the completion of 

tests.

[s. NR 439.07(9), Wis. Adm. Code]

(1) The permittee shall maintain the following records:

(a) a copy of all stack test results for test required under this 

permit;

(b) any requests for an extension of time to perform any 

testing required under this permit, including the 

Department’s written response to such requests.

(s. NR 439.04, Wis. Adm. Code) 

5. Compliance Reports/Records.

a. Limitations:

(1) Except as provided under ZZZ.7.a.(1), upon issuance of the operation permit, the permittee shall submit periodic 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 43 of 48

monitoring reports.

[s. NR 407.09(1)(c)3., Wis. Adm. Code]

(2) Except as provided under ZZZ.7.a.(1), upon issuance of the operation permit, the permittee shall submit periodic 

certification of compliance.

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

(3) The records required under this permit shall be retained for at least five (5) years and shall be made available to 

department personnel upon request during normal business hours.

[s. NR 439.04, s. NR 439.05, Wis. Adm. Code]

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

(1) The permittee shall submit a monitoring report which 

contains the results of monitoring or a summary of 

monitoring results required by this permit to the 

Department every six (6) months.

(a) The time periods to be addressed by the submittal 

January 1 to June 30 and July 1 to December 31.

(b) The report shall be submitted to the Wisconsin 

Department of Natural Resources, West Central Region

Air Management Program, Wausau Service Center,

within 45 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.

(e) The content of the submittal is described in item D. of 

Part II of the operation permit.

[ss. NR 407.09(1)(c)3. & NR 439.03(1)(b), Wis. Adm. 

Code]

(2) The permittee shall submit an annual certification of 

compliance with the requirements of this permit to the 

Wisconsin Department of Natural Resources, West

Central Region Air Management Program, Wausau 

Service Center and to Compliance Data - Wisconsin, 

None Applicable.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 44 of 48

Air and Radiation Division, US EPA, 77 W. Jackson 

Street, Chicago, IL 60604.

(a) The time period to be addressed by the report is 

January 1 to December 31 of the preceding year.

(b) The report shall be submitted to the Wisconsin 

Department of Natural Resources and the US EPA 

within 45 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.

[ss. NR 407.09(4)(a)3. & NR 439.03(1)(c), Wis. Adm. 

Code]

7. Construction Permit 10-SDD-058 Transitional Language.

a. Limitations:

(1) Notifications. The permittee shall inform the Department of the following dates within 15 days of the date on which 

the activity actually occurs:

(a) The date construction commences on any new emission units addressed in Permit 10-SDD-058.

(b) The date new emission unit becomes operational.

For purposes of this permit, “operational” shall be defined as the first time of any process related air contaminant is 

emitted into the ambient air.

(2) For purposes of this permit only, “Initial operation” for Biomass fired boiler (Emission Unit B01) shall be defined as 

the time when the generator of the associated boiler is first synchronized with the electrical grid, and “initial 

operation” for the Natural Gas fired Boiler (Emission Unit B02) shall be defined as the time when the boiler first 

provides steam for it intended purpose.

[s. NR 439.03(1), Wis. Adm. Code (Permit 10-SDD-058)]

(3) Construction Authorization Expiration. The Authorization to Construct, under Construction Permit 10-SDD-058 

expires 36 months after the date of issuance. Construction or modification and an initial operation period for 

equipment shakedown, testing and Department evaluation of operation to assure conformity with the permit 

conditions is authorized for each emissions unit covered in this permit. Please note that the sources covered by this 
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 45 of 48

permit are required to meet all emission limits and conditions contained in the permit at all times, including during the 

initial operation period. If 36 months is an insufficient time period for construction or modification, equipment 

shakedown, testing and Department evaluation of operation, the permit holder may request and the Department may 

approve in writing an extension of this permit. The conditions of the construction permit are permanent, unless 

revised, superseded or revoked.

[ss. 285.60(1)(a)2. and 285.66(1), Wis. Stats., and s. NR 406.12, Wis. Adm. Code (Permit 10-SDD-058)]

(4) New Emission Units Once constructed and operating, all new processes and boilers shall operate under the 

conditions in Section I. and II. of this construction permit 10-SDD-058.

[s. NR 439.03(1), Wis. Adm. Code (Permit 10-SDD-058)]

(5) Completion of Operation Permit Application. The permittee shall update the permit application if any changes 

occur which are not specified or described in the plans and specifications approved under construction permit 10-

SDD-058 .

[s. NR 407.04(1)(b), Wis. Adm. Code (Permit 10-SDD-058)]

(6) Existing Domtar Pulp and Paper Mill’s Emission Units. Prior to the date that any new emission units associated with the 

Biomass Facility becomes operational, Domtar Paper Company LLC shall complete the following physical and operational 

changes to the Pulp and Paper Mill (FID 737010450). These changes shall be federally enforceable through a construction permit 

under NR 406. 

(a) Boilers B11 and B13, the hog-fuel and Natural gas & distillate oil fired boilers, respectively, shall not be operated 

whenever any of the new emission units of the Biomass Facility are operating,.

(b) i. Boilers B10 and B12, Natural gas & distillate oil fired boiler shall not be operated whenever the Circulating 

Fluidized Bed Boiler – B01 of the Biomass Facility is operating. 

ii. Boilers B10 and B12 shall only combust natural gas and emissions unit B10 shall be limited to a firing rate of 60 

MMBTU/hour whenever any emission units of the Biomass Facility other than the Circulating Fluidized Bed Boiler 

– B01 are operating.

iii. The permittee shall maintain records to demonstrate that the boiler and other process operation restrictions in cons. (a) 

and (b) of this Section are met at all times the emission units of the Biomass Facility are operating.

(c) Emission Unit P44, Wood chip cyclone system shall not discharge through a stack to the ambient air

(d) Emission Unit P56, Lime storage silo’s stack shall be discharge in a vertical direction at a height of 26.5 feet.

(e) Stack S90A, Pulper cyclone stack shall be discharge in a vertical direction at a height of 42 feet with an inside 

diameter of 3.3 feet at outlet.

(f) Stack S90B, Pulper vent shall be discharge in a vertical direction at a height of 26 feet with an inside diameter of 1.5
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 46 of 48

feet at outlet.

(g) Stack S90C, Shredder cyclone stack shall be discharge in a vertical direction at a height of 28 feet with an inside 

diameter of 3.3 feet at outlet

[ss. 285.65(3)&(7), Stats.]

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

(1) Notifications. The permittee shall submit to the 

Department of Natural Resources, West Central Region 

Air Management Program, Wausau Service Center in 

writing, within 15 days of the date the event, the 

following:

(a) The date construction commences on the any new 

emission unit addressed in Permit 10-SDD-058 .

(b) The date new emission unit becomes operational.

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10-

SDD-058)] 

(2) Submittal of Compliance Testing Information and 

other updates. The permittee shall submit to the 

department any updates of the permit application. 

Updates are required if any changes that occur which 

are not specified or described in the plans and 

specifications dated March 24, 2010 thru October 4, 

2012. The updates shall be made within 60 days of the 

date of the change. Other information to be submitted 

shall include the notification requirements and stack 

tests results 

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10-

SDD-058)]

(3) All submittals described in this permit shall be made in 

writing and include the name of the facility, the 

facility’s address, the construction permit number and a 

description of the affected emission unit(s).

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10-

SDD-058)]

None Applicable.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 47 of 48

8. MACT fuel sampling and monitoring requirements

a. Limitations:

(1) All fuel sampling and fuel monitoring used top demonstrate compliance with a MACT standard for boiler B01 

shall be conducted in accordance with these requirements (s. 285.65(7)&(13), Stats.)

c. Test Methods, Recordkeeping, and Monitoring:

(1) Sampling for mercury shall be done in accordance with 

all of the following:

(a) Collect fuel samples:

i. Procedure in §63.7521(c) or ASTM D6323–98 (2003) 

(b) Composite fuel samples use Procedure in §63.7521(d) 

or equivalent.

(c) Preparation composited fuel samples:

i. SW–846–3050B (for solid samples)

ii. SW–846–3020A (for liquid samples); or 

iii. ASTM D5198–92 (2003) (for

biomass) or equivalent.

(d) Determine heat content of the fuel by ASTM E711–87 

(for biomass) (IBR, see §63.14(b)) or equivalent.

(e) Determine moisture content of the fuel type:

i. ASTM D3173–03 (IBR, see §63.14(b));or

ii. ASTM E871–82 (1998) (IBR, see §63.14(b)) or 

equivalent.

(f) Measure mercury concentration in fuel sample:

i. SW–846–7471A (for solid samples); or 

ii. SW–846–7470A (for liquid samples) or equivalent.

(2) Sampling for chlorine shall be done in accordance with 

all of the following:

(a) Collect fuel samples:

i. Procedure in §63.7521(c); or

ii. ASTM D6323–98 (2003) (for biomass) (IBR, see 

§63.14(b)) or equivalent.

(b) Composite fuel samples use the Procedure in 

§63.7521(d) or equivalent.

(c)Prepare composited fuel samples

i. SW–846–3050B (for solid samples); 

ii. SW–846–3020A (for liquid samples); or 

ii. ASTM D5198–92 (2003) (for biomass) (IBR, see 

§63.14(b)) or equivalent.

(d) Determine heat content of the fuel type using ASTM 

E711–87 (1996) (for biomass) (IBR, see §63.14(b)) or 

equivalent.

(e) Determine moisture content of the fuel type:

i. ASTM D3173–03 (IBR, see §63.14(b)); or

ii. ASTM E871–82 (1998) or equivalent.

f. Measure chlorine concentration in fuel:

i. SW–846–9250; or

ii. ASTM E776–87 (1996) (for biomass)

None Applicable.
FID No. 737227040, Permit No. 10-SDD-058-R1 Page 48 of 48