• 

Minnesota Pollution Control Agency 

520LafayetteRoad North I St. Paul, Minnesota 55155-4194 I 651-296-6300 

800·657-3864 I 651-282-5332 T1Y I www.pca.state.mn.us I Equal Opportunity Employer 

February 3, 2015 

Mr. George T. Czerniak, Division Director 

Air and Radiation Division 

U.S. Environmental Protection Agency, Region 5 

77 West Jackson Boulevard 

Mail Code: A-18J 

Chicago, Illinois 60604 

Dear Mr. Czerniak: 

At the request of the U.S. Environmental Protection Agency (EPA), the Minnesota Pollution Control 

Agency (MPCA) is submitting this letter to provide additional detail relating to the information provided 

in our June 12, 2014, Infrastructure State Implementation Plan (SIP) submission for the 2008 ozone, 

2010 nitrogen dioxide (N02) and sulfur dioxide (S02), and 2012 particulate matter of less than 2.5 

micrometers in diameter (PM2.5) National Ambient Air Quality Standards (NAAQS), especially with 

regards to the requirements of Section 110(a)(2)(A): Emission Limits and Other Control Measures. Minn. 

Stat. ch. 116 gives the MPCA the authority to develop rules and regulations and also allows the MPCA to 

implement current rules and apply existing controls and emissions limits to help maintain new 

standards. 

Multi-pollutant limits 

Minnesota has several methods of limiting emissions from facilities in the state. The primary way in 

which emissions of nitrogen oxides (NOx) and volatile organic compounds (VOCs) (ozone precursors), 

N02, S021 and P M2.5 are limited in Minnesota is through limits held in Part 70 permits. 

Minnesota also has rules that limit emissions at facilities around the state. Minn. R. 7009.0020 states 

"No person shall emit any pollutant in such an amount or in such a manner as to cause or contribute to a 

violation of any ambient air quality standard beyond such person's property line ... " Minn. R. 7009.0080 

sets the State Ambient Air Quality Standards. These standards are currently being updated to reflect the 

current NAAQS as part of the MPCA's Omnibus Air Rulemaking. In the meantime, however, the NAAQS 

continue to be applicable requirements. 

Subsequent to Minnesota's June 12, 2014, Infrastructure SIP submittal, the EPA finalized efforts to begin 

implementation of the Cross-State Air Pollution Rule (CSAPR), which is, as of January 1, 2015, currently 

in effect. CSAPR, implemented by EPA as a Federal Implementation Plan, is intended to address 

110(a)(2)(D)(i)(l) "good neighbor" obligations for eastern states for the 1997 ozone and PM2.5 and 2005 

PM2.5 NAAQS. Minnesota is subject to CSAPR's annual S02 and NOx programs to address downwind PM2.s 

attainment and maintenance obligations. CSAPR is expected to result in NOx and S02 emissions 

reductions from subject power plants, which will further assist Minnesota's efforts to attain and 

maintain the 2008 ozone, 2010 N02 and S02, and 2012 PM2.5 NAAQS. 
Mr. George T. Czerniak 

Page 2 

February 3, 2015 

These rules and permits combine to help protect all of the NAAQS addressed in Minnesota's 

June 12, 2014, Infrastructure SIP submittal. 

Pollutant-specific limits 

Minnesota also has pol lutant-specific methods of limiting emissions. Most of the state's pollutantspecific limits are for S02 and particulate matter (PM) because the state previously had nonattainment 

areas for those pollutants. As part of the state's efforts to come into attainment with the NAAQS for SOz 

and P M, limits on emissions were placed in the state's rules and permits. The state has fewer pol lutantspecific limits for VOCs and NOx because Minnesota has never been designated nonattainment for NOz 

or ozone. The following is a summary of the pollutant-specific limits in Minnesota that help ensure the 

continued attainment of the NAAQS for N02, S02, ozone, and PM25• 

Sulfur dioxide 

Minnesota contains. areas under maintenance plans for S02. In order to ensure continued attainment of 

the NAAQS, Minnesota's SIP includes permits and administrative orders with S02 emission limits for 

facilities in the state's S02 maintenance areas. The enforceable documents with permanent SIP 

conditions are (status as of January 2015): 

Source Permit Number or State EPA Approval Date & FR 

Order Effective Date Citation 

Associated Milk Producers 10900010-001 05/05/97 03/09/01; 66 FR 14087 

1148-83-0T-1 

Franklin Heating Station 

[10900019] 

06/19/98 03/09/01; 66 FR 14087 

IBM 10900006-001 06/03/98 03/09/01; 66 FR 14087 

Olmsted Waste-to- Energy Facility 10900005-002 08/23/07 04/21/09; 74 FR 18138 

Rochester Public Utilities- 10900020-003 02/07/08 04/24/09; 74 FR 18638 Cascade Creek 

Rochester Public Utilities- Silver 10900011-004 09/07/07 12/02/09; 74 FR 63066 Lake 

Saint Mary's Hospital 10900008-002 10/14/09 08/12/10; 75 FR 48864 

ELT Minneapolis, River Road 

Industrial 0300245-001 04/08/10 08/03/10; 75 FR 45480 

(United Defense, LP) 

Federal Cartridge Company 00300156-003 12/28/07 04/04/09; 74 FR 18634 

05/27/92 04/14/94; 59 FR 17703 

GAF Building Materials Administrative Order 

09/18/97 02/08/99; 64 FR 5936 

Hoffman Enclosures 00300155-001 01/31/08 04/04/09; 74 FR 18634 
Mr. George T. Czerniak 

Page 3 

February 3, 2015 

Source 

Minneapolis Energy Center, Inc. 

(NRG Energy Center Mpls) 

Xcel Energy- Inver Hills Plant 

Xcel Energy- Riverside Plant 

Flint Hills Resources, L.P. 

Northern Tier Energy 

(Marathon Petroleum) 

Permit Number or 

Order 

Administrative Order 

03700015-003 

05300015-001 

Administrative Order 

16300003-016 

State EPA Approval Date & FR 

Effective Date Citation 

05/27/92 04/14/94; 59 FR 17706 

10/27/06 12/05/07; 72 FR 68508 

05/11/99 02/26/02; 67 FR 8727 

08/29/11 05/15/13; 78 FR 28501 

09/11/09 12/28/10; 75 FR 81471 

In addition to the S02 SIP conditions, the administrative order issued to Xcel Energy- Northern States 

Power Company, Sherburne County Generating Station as part of Minnesota's Regional Haze SIP 

includes S02 limits. 

Other state rules incorporated into the SIP that set S02 emission limits include: 

• Minn. R. 7011.0500 to 7011.0553 Indirect Heating Fossil Fuel Burning Equipment 

• Minn. R. 7011.0600 to 7011.0625 Direct Heating Fossil Fuel Burning Equipment 

• Minn. R. 7011.1400 to 7011.1430 Petroleum Refineries 

• Minn. R. 7011.1600 to 7011.1605 Sulfuric Acid Plants 

• Minn. R. 7011.2300 Stationary Internal Combustion Engines 

Additionally, Minn. R. 7011.0900 to 7011.0909 for hot mix asphalt plants includes fuel sulfur content 

restrictions aimed at limiting S02 emissions. 

All of these rules and enforceable documents help ensure the protection of the 2010 S02 NAAQS. 

Particulate matter 

Limits and controls intended to limit emissions of PM generally or particulate matter of less than 10 

micrometers in diameter (PM10) can also be expected to control PM2.5, since PM2.5 is a subset of these 

other two categories. Control technologies intended to limit emissions of filterable PM10 will also reduce 

emissions of filterable PM2.5 and help to protect the PM2.s NAAQS. Therefore, the following section 

contains controls for PM, PM10, and P M2.5• 
Mr. George T. Czerniak 

Page 4 

February 3, 2015 

Minnesota contains areas under maintenance plans for P M. In order to ensure continued attainment of 

the NAAQS, Minnesota's SIP includes permits and administrative orders with PM emission limits for 

facilities in the state's PM maintenance areas. The enforceable documents with permanent SIP 

conditions are (status as of January 2015): 

Source Permit Number or State EPA Approval Date & FR 

Order Effective Date Citation 

Rochester Public Utilities-Silver 10900011-004 09/07/07 12/02/09; 74 FR 63066 Lake 

Aggregate Industries, Yard A 12300007-002 04/23/09 05/10/10; 75 FR 11461 (formerly J.L. Shiely) 

Commercial Asphalt Plant 905 1230034 7-002 09/10/99 07 /12/00; 65 FR 42861 

Gerdau Ameristeel 12300055-004 08/28/08 05/20/09; 74 FR 23632 

Great Lakes Coal & Dock Co 08/25/92 02/15/94; 59 FR 7218 

{Great Western Dock and Administrative Order 

Terminal) 12/21/94 06/13/95; 60 FR 31088 

01/26/93 02/15/94; 59 FR 7218 

Harvest States Cooperatives Administrative Order 

12/21/94 06/13/95; 60 FR 31088 

Lafarge North America, Childs 12300391-002 12/17/06 9/11/07; 72 FR 51713 Road Terminal 

Lafarge Corp., Red Rock 12300353-002 05/07/02 08/19/04; 68 FR 51371 

Metropolitan Council, Metro 12300053-006 02/25/10 12/16/10; 75 FR 78602 Wastewater Treatment Plant 

St. Paul Terminals Administrative Order 02/02/96 07 /22/97; 62 FR 39120 Red Rock Road 

State rules that limit emissions of PM and help protect the 2012 PM2.5 NAAQS include: 

• Minn. R. 7011.0150 Preventing Particulate Matter from Becoming Airborne 

• Minn. R. 7011.0500 to 7011.0553 Indirect Heating Fossil Fuel Burning Equipment 

• Minn. R. 7011.0600 to 7011.0625 Direct Heating Fossil Fuel Burning Equipment 

• Minn. R. 7011.0710 to 7011.0735 Industrial Process Equipment 

• Minn. R. 7011.0850 to 7011.0859 Concrete Manufacturing Plant Standards of Performance 

• Minn. R. 7011.0900 to 7011.0922 Hot Mix Asphalt Plants 

• Minn. R. 7011.1000 to 7011.1015 Bulk Agricultural Commodity Facilities 

• Minn. R. 7011.1100 to 7011.1125 Coal Handling Facilities 

• Minn. R. 7011.1300 to 7011.1325 Incinerators 

• Minn. R. 7011.1400 to 7011.1430 Petroleum Refineries 
Mr. George T. Czerniak 

Page 5 

February 3, 2015 

Volatile organic compounds (ozone precursors) 

Minnesota's state rules incorporate by reference the National Emission Standards for Hazardous Air 

Pollutants, which limit VOC emissions. The primary method by which Minnesota limits VOC emissions is 

through the issuance of Part 70 permits. These limits help protect the 2008 ozone NAAQS. 

Nitrogen oxides (ozone precursors) and nitrogen dioxide 

State rules that limit NOx and N02 emissions and help protect the 2008 ozone and 2010 N02 NAAQS, 

respectively, include: 

• Minn. R. 7011.0500 to 7011.0553 Indirect Heating Fossil Fuel Burning Equipment 

• Minn. R. 7011.1700 to 7011.1705 Nitric Acid Plants 

Additionally, the administrative order issued to Xcel Energy- Northern States Power Company, 

Sherburne County Generating Station as part of Minnesota's Regional Haze SIP Includes NOx limits. 

Conclusion 

The MPCA's authority under Minn. Stat. ch. 116 to create new rules and implement existing emission 

limits and controls allows Minnesota to meet the requirements of 110(a)(2)(A): Emission Limits and 

Other Control Measures. 

The MPCA hopes that this letter will provide the desired additional detail to Minnesota's Infrastructure 

SIP submittal of June 12, 2014, with regards to the requirements of 110(a){2)(A). Through the MPCA's 

discussions with your office, Minnesota believes that the June 12, 2014, Infrastructure SIP submittal 

meets the requirements described in "Guidance on Infrastructure State Implementation Plan (SIP) 

Elements under Clean Air Act Sections 110(a)(1) and 110(a)(2)," issued on September 13, 2013. Please 

contact Amanda Jarrett Smith of the MPCA's staff at 651-757-2486 or amanda.smith@state.mn.us if you 

have any questions regarding Minnesota's SIP. 

Assistant Commissioner for Air Policy 

JDT/AJS:Id