1. S. 1

– Draft first page of permit AIR POLLUTION CONTROL OPERATION PERMIT

EI FACILITY NO: 113225200 PERMIT NO.: 113225200

- F01

TYPE: 

### Synthetic Minor, Non

- Part 70

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

Name of Source: City Center West

Street A d dress: 525 Junction Road

, Madison

, Dane County, Wisconsin

Responsible Official, & Title: Mr. John Kothe

, Vice President

- Operations

is authorized to operate in conformity with the conditions he rein.

THIS OPERATION PERMIT EXPIRES [Section NR 407.09(1)(b)1., Wis. Adm. Code] April 19, 2012



### A RENEWAL APPLICATION MUST BE SUBMITTED AT LEAST 6 MONTHS, BUT NOT MORE THAN 18 MONTHS, PRIOR TO THIS EXPIRATION DATE [ss. 285.66(3)(a), Wis. Stats. and NR 407 .04(2), Wis. Adm. Code].

No permittee may continue operation of a source after the operation permit expires, unless the permittee submits a timely application for renewal of the permit. If you submit a timely application for renewal, the existing operatio n permit will not expire until the renewal application has been finally acted upon by DNR. [ss. 227.51(2), 285.62(8)(b), Wis. Stats. and NR 407.04(2), Wis. Adm. Code].

This authorization requires compliance by the permit holder with the emission limitation s, monitoring requirements
and other terms and conditions set forth in Parts I and II hereof.

Dated at Fitchburg , Wisco n sin April 19, 20 07

STATE OF WISCONSIN DEPARTMENT OF NATURAL RESOURCES 

### For the Secretary

By /s/ Thomas Roushar Thomas Roush ar Air Management Program Supervisor**FID 113225200; Permit No. 113225200** 

**- F01.** 

2. S. 2

– Preamble PREAMBLE TO OPERATION PERMIT



### An Asterisk (*) throughout this document denotes legal authority, limitations and conditions which are not federally enforceable [Section NR 407.09(3)(b), Wis. Adm. Co de.].

Stack and Process Index

.

1. P01, S01 Diesel Generator

2. P02, S02 Diesel Generator

3. P03, S03 Emergency Generator

Insignificant Emission Units: 

### Boiler, Turbine, and HVAC System Maintenance. Convenience Space Heating (< 5 million BTU/hr Burning Gas, Liquid, or Wood). Convenience Water Heating. Fire Control Equipment. Janitorial Activities. Maintenance of Grounds, Equipment, and Buildings (lawn care, p ainting, etc.). Office Activities. Sanitary Sewer and Plumbing Venting.

Permit Shield

. Unless precluded by the Administrator of the US EPA, compliance with all emission limitations in this operation permit is considered to be compliance with all emission limitations esta b lished under ss. 285.01 to 285.87, Wis. Stats., and emission limitations under the federal clean air act, that are applicable to the source if the permit includes the applicable limitation or if the Depa rtment dete r mines that the emission limitations do not apply. The following emission limitations were reviewed in the analysis and preliminary determination and were determined not to apply to this stationary source:

none

Part I

— The headings for the ar eas in the permit are defined below. The legal authority for these limit a tions or methods follows them in [brackets].

Pollutant



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

Limitations



### – This area will list all applicable emiss ion limitations that apply to the source, including case

- by

- case limitations such as Latest Available Control Techniques (LACT), Best Available Co n trol Technology (BACT), or Lowest Achievable Emission Rate (LAER). It will also list any volu n tary restrict ions on hours of operation, raw material use, or production rate requested by the permittee to limit potential to emit.

Compliance Demonstration



### – The compliance demonstration methods outlined in this area may be used to demonstrate compliance with the ass ociated emission limit or work practice standard listed under the corresponding Limitations 

### column. The compliance demonstration area contains limits on parameters or other mechanisms that will be monitored periodically to ensure compliance with the limita tions. The requirement to test as well as initial and periodic test schedules, if testing is required, will be stated here. Notwithstanding the**FID 113225200; Permit No. 113225200** 

**- F01.** 



### compliance determination methods which the owner or o p erator of a sources is authorized to use under ch. NR
439 , Wis. Adm. Code, the Department may use any relevant information or appropriate method to determine a source’s compliance with applicable emission limitations.

Reference Test Methods, Recordkeeping, and Monitoring Requirements



### – Specific US EPA Reference test methods or other approved test methods will be contained in this area and are the methods that must be used whenever testing is required. A reference test method will be listed even if no testing is immediately required. Also included
in this area are any recordkeeping requirements and their fr e quency and reporting requirements. Accuracy of monitoring equipment shall meet, at a minimum, the r e quirements of s. NR 439.055(3) and (4), Wis. Adm. Code, as specified in Part II of this permit.

Condition Type



### – This area will specify other conditions that are applicable to the entire facility that may not be tied to one specific pollutant.

Conditions



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

PART II

— This sect ion contains the general limitations that the permittee must abide by. These r e quirements are standard for most sources of air pollutants so they are included in this section with every pe r mit.**FID 113225200; Permit No. 113225200** 

**- F01.**  **Page 4**  **of 15** 

PART I APPLICABLE EMISSION LIMITATIONS AND REQUIREMENTS

A. Each of Process P01, Stack S01, and Process P02, Stack S02

— Diesel Generator.

Pollutant a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Requirements

1. Particulate Matter (PM) Emissions (1) 1.35 pounds per hour 1 [s. 285.65(7), Wis. Stats.] (2) Diesel fuel used at each generator may not exceed 9,999 gallons in any 12 consecutive months. The permittee requested this limitation to avoid the applicability of s. NR 445.09(3), Wis. Adm. Code. [s. 285.65(7 ), Wis. Adm. Code] (1) The permittee may only use diesel oil with no more than 15 parts per million by weight of sulfur as fuel. [s. 285.65(7), Wis. Stats.]

(2) The permittee shall maintain and calibrate the engine to peak performance once every 500 ho urs of operation or once every other year, whichever is more frequent. [ss. 285.63(1)(a) and 285.65(3), Wis. Stats.] (1) For each delivery of diesel oil, the permittee shall obtain documentation from the fuel oil supplier stating the sulfur content by wei ght of the diesel oil. [s. NR 439.04, Wis. Adm. Code] (2) Whenever compliance emissions testing is required, the following, or another method approved in writing by the Department, shall be used: (a) USEPA Method 5, for non

- condensible particulate matte r, and (b) USEPA Method 202 for condensible particulate matter. [s. NR 439.06(1), Wis. Adm. Code] (3) The permittee shall record and maintain the information on the engine tuneup required in condition I.A .1.b.(2) and have the records available during insp ections by Department personnel. [s. NR 439.04(1)(a)6, Wis. Adm. Code] (4) The permittee shall keep and maintain monthly records of the amounts of diesel fuel used at each generator to demonstrate compliance with I.A.1.a.(2). [s. NR 439.04(1)(a)6, Wis. Ad m. Code]

2. Nitrogen Oxides (NO x ) (1) 44.65 pounds per hour [s. 285.65(7), Wis. Stats.]

(2) Each generator may not be operated for more than 16.66 hours per month, averaged over any 12 consecutive months. This limit is proposed by the permittee to b e minor for Part 70. 2 [s. 285.65(7), Wis. Stats.] (1) The permittee shall maintain and calibrate the engine to peak performance once every 500 hours of operation or once every other year, whichever is more frequent. [ss. 285.63(1)(a) and 285.65(3), Wis. Stats.] (1) Whenever nitrogen oxides emissions compliance testing is required, USEPA Method 7 in 40 CFR part 60, Appendix A, incorporated by reference in s. NR 484.04, Wis. Adm. Code, or another method approved in writing by the Department, shall be used . [s. NR 439.06(6)(a), Wis. Adm. Code] (2) The permittee shall keep and maintain monthly records of the hours of operation for each generator to demonstrate compliance with I.A.2.a.(2). [s. NR 439.04, Wis. Adm. Code]

1 This emission limit has been proposed by the permittee to ensure that the national ambient air quality standards for particul ate matter are attained and maintained and is more restrictive than s. NR 485.055, Wis. Adm. Code.

2 This limit will keep the facility NO x potential to emit (PTE) less than 100 tons per year, the Part 70 major source threshold level in ch. 407, Wis. Adm. Code.**FID 113225200; Permit No. 113225200** 

**- F01.**  **Page 5**  **of 15** 

A. Each of Process P01, Stack S01, and Process P02, Stack S02

— Diesel Generator.

Pollutant a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Requirements

3. Visible Emissions (1) 20% Opaci ty [s. NR 431.05, Wis. Adm. Code] (1) To meet the em ission limit in I.A.3.a(1), the permittee may only use diesel oil with no more than 15 parts per million by weight of sulfur as fuel. [s. 285.65(7), Wis. Stats.] (1) Whenever visible emissions complia nce testing is required, USEPA Method 9 in 40 CFR part 60, Appendix A, incorporated by reference in s. NR 484.04, Wis. Adm. Code, or another method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]**FID 113225200; Permit No. 113225200** 

**- F01.**  **Page 6**  **of 15** 

B. Process P03 , Stack(s) S03

— Diesel Fuel Emergency Generator

. Pollutant a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Requirements
1. All Pollutants (1) Each emergency electric generator may only be used in emerg ency situations and for periodic testing purposes. [s. NR 436.03(2)(c), Wis. Adm. Code]

(2) The permittee shall notify the Department within 24 hours of emergency generator start up, for start ups other than those for periodic testing purposes. The Depa rtment may or may not give approval for continued equipment use. This notification shall include:

(a) Date of start

- up of the generator(s); (b) Time of start

- up of the generator(s); (c) The operating load of each generator; (d) A list of the other emissi ons units at the facility operating during the emergency situation; (e) The fuel that each operating emissions units at the facility is using; and (f) The load of each operating emissions unit at the facility. [s. NR 436.03(2)(c), Wis. Adm. Code] (1) D istillate oil with no more than 15 parts per million by weight of sulfur is the only fuel that

m a y be fired in the emergency generators. [s. 285.65(7), Wis. Stats.] (1) The permittee shall keep records of when the emergency generators are operated for either periodic testing purposes or emergency situations. These records shall include:

(a) Date(s) of operation of the generator(s); (b) Start

- up time of each generator; (c) Shut

- down time of each generator; (d) The hours each generator operated; (e) An indication of whether each generator was operated for periodic testing or an emergency situation. (f) The average operating load of each generator; [s. NR 439.04(1)(d), Wis. Adm. Code]

2 . Particulate Matter (PM) Emissions (1) During testing of th e generator, the particulate matter emissions may not exceed 0. 22 pound per hour 3 . [s. NR 485.055, Wis. Adm. Code, and s. 285.65(3), Wis. Stats.] (1) The permittee may only use diesel oil with no more than 15 parts per million by weight of sulfur as fuel . [s. 285.65(7), Wis. Stats.] (1) The permittee shall retain on site, plans and specifications of the generator. [s. NR 439.04(1)(d), Wis. Adm. Code] (2) Reference Test Method for Particulate Matter Emissions: Whenever compliance emission testing is re quired, US EPA Method 5 and Method 202 shall be used to demonstrate compliance. [s. NR 439.06(1), Wis. Adm. Code]

3 Th is emission limit has been proposed by the permittee to ensure that the national ambient air quality standards for particulat e matter are attained and maintained and is more restrictive than s. NR 485.055, Wis. Adm. Code.**FID 113225200; Permit No. 113225200** 

**- F01.**  **Page 7**  **of 15** 

B. Process P03 , Stack(s) S03

— Diesel Fuel Emergency Generator

. Pollutant a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Requirements
3. Visible Emissions (1) 20% Opacity [s. NR 431.05, Wis. Adm. Code] (1) To meet the emission limit in I. C .3.a(1), the permittee may only use diesel oil with no more than 15 parts per million by weight of sulfur as fuel. [s. 285.65(7), Wis. Stats.] (1) Whenever visible emissions compliance testing is required, USEPA Method 9 in 40 CFR part 60, Appendix A, incorporated by reference in s. N R 484.04, Wis. Adm. Code, or another method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 8**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments



### 1

. Stack Testing Requirements. (1) Whenever compliance emission test(s)
cannot be conducted within the time frames specified in this permit, the permit holder may request and the Depa rtment may approve, in writing,
an extension of time to conduct the test(s).

[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 appro ved 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 a 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 substit uted for the
reference test method. The notification and test plan shall be submitted to the (1) T wo 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] None Applicable.**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 9**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments 

### Wisconsin Department of Natural Resources, South Central Region Headquarters, 3911 Fish Hatchery Road, Fitchburg, WI 53711

.

[s. NR 439.07(2), Wis. Adm. Code]

2

. Compliance Reports/Records

. (1) Except as provided under ZZZ.3.a.(5), upon issuance of the operation permit, the permittee shall submit periodic monitoring reports.

[s. NR 407.09(1)(c)3., Wis. Adm. Code]

(2) Except as provided under ZZZ.3.a.(5), 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 norm al business hours.

[s. NR 439.04, s. NR 439.05, Wis. Adm. Code] (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 twelve (12) month s.

(a) The time periods to be addressed by the submittal January 1 to December 31.

(b) The report shall be submitted to the Wisconsin Department of Natural Resources South Central Region Headquarters, 3911 Fish Hatchery Road, Fitchburg, WI 53711

, 

### within 30 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 comp leteness of the None Applicable.**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 10**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments


### 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

req uirements of this permit to the Wisconsin Department of Natural Resources South Central Region Headquarters, 3911 Fish Hatchery Road, Fitchburg, WI 53711

.

(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 South Central Region Headquarters, 3911 Fish Hatchery Road, Fitchburg, WI 53711

, within 30 days after the end of each reporting period.

(c) The information included in the r eport shall comply with the requirements of**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 11**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments 

### Part II, Section N of this permit.

(d) Each report shall be certified by a responsible official as to the truth,

accu racy and completeness of the report.

[ss. NR 407.09(4)(a)3. & NR 439.03(1)(c), Wis. Adm. Code ]

3

. Construction Permit
07

- POY

- 022
Transitional Language (1) Notifications. The permittee shall inform the Department of the following
dates:

(a) The date construction commences on any new or modified emission unit(s)
addressed in Permit 07

- POY

- 022.

(b) The date the modified emission unit(s) (P01, P02) 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.

[s. NR 439.03(1), Wis. Adm. Code (Permit 07

- POY

- 022 )]

(2) Construction Authorization Expira

tion. The Authorization to Construct,
under Construction Permit 07

- POY

- (1) Notifications The permittee shall
submit to the Department of Natural
Re sources South Central Region Headquarters , South Central Region Headquarters, 3911 Fish Hatchery Road, Fitchburg, WI 53711

, in writing, within 15 days of the date th e event, the following:

(a) The date construction commences on the new or modified emission unit(s)
addressed in Permit 07

- POY

- 022.

(b) The date the modified emission unit(s) (P01, P02) becomes operational.

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 07

- PO Y

- 022)]

(2) Malfunction Prevention and Abate

ment Plan. The owner or operator shall update the facility’s Malfunction None Applicable.**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 12**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments



### 022 expires 18 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 con formity with the permit
conditions is authorized for each
emissions unit cov ered in this permit. Please note that the sources covered by this permit are re quire d to meet all
emission limits and conditions contained in the permit at all times, including during the initial op eration period. If 18 months is an insuf ficient time period for construction or modification, equipment shakedown, testing and Depar tment evaluation of operation, the permit holder may re

quest 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 07

- POY

- 022 )]

(3) Malfunction Prevention and Abate

ment Plan. The permittee shall update the facility’s Malfunction Prevention Prevention and Abatement Plan to in

clude the modified emission unit (P01, P02) within 60 days of the date each unit becomes operational.

[s. NR 439.11(1), Wis. Adm. Code (Permit 07

- POY

- 022)]

(3) Submittal of Compliance Testing In

formation and other updates. The permittee shall submit to the depart

ment any updates of the permit appli

cation. Updates are required if any changes that occur which are not speci

fied or described in the plans and speci

fications dated January 29, 2007 (application received), January 31, 2007, February 1, 2007, February 5, 2007, and March 2, 2007 . The updates shall be made within 60 days of the date of the chang e. Other information
to be sub mitted shall include the
notification re quirements, stack tests results and the update of the facility’s Malfunction prevention and Abatement Plan. The continued operation of the
modified and new emission units
addressed in this construction permit are prohibited once the authorization to

construct ex pires per Condition
ZZZ.3 .a.(2), unless any required**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 13**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments 

### and Abatement Plan to include the op

eration and maintenance of the control equipment associated with the modified emission unit(s) (P01, P02).

[s. NR 439.11, Wis. Adm. Code (Permit 07

- POY

- 022 )]

(4) Compliance Reports/Records. The permittee shall submit periodic moni

toring reports and certification of com

pliance as requi red by s. ZZZ. 2 .a.(1) and (2) for any modified and new emission unit for the period when that unit becomes operational. Note that compliance monitoring and reporting requirements and limitations of any
unmodified units remain in effect.

(5) Completion of O peration Permit Ap

plication. The permittee shall update the permit application if any changes occur which are not specified or de

scribed in the plans and specifications approved under construction permit 07

- POY

- 022

.

NR 407.04(1)(b), Wis. Adm. Code (Permi t 07

- POY

- 022) ] updates have been submitted and the permittee has satisfied the notification requirements of Condition ZZZ.3 .b.(1).

[s. NR 4 39.04(1)(d), Wis. Adm. Code (Permit 07

- POY

- 022) ]

(5) 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 num

ber and a description of the affected
emission u nit(s).

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 07

- POY

- 022 )]**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 14**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments

4. Stack Parameters (1) For stack S01 serving generator P01:

(a) The stack height shall be at least 14 feet above ground level. (ss. 285.63(1)(a) and 285.65(3), Wis. Stat s.)

( b ) The stack inside diameter at the outlet may not exceed 1.33 feet. (ss. 285.63(1)(a) and 285.65(3), Wis. Stats.)

(c) The stack may not be equipped with a rainhat or other device that may impede the upward velocity of the exhaust gas. (ss. 285.63(1) (a) and 285.65(3), Wis. Stats.)

( d ) 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)

(2) For stack S02 serving generator P02:

( a ) The stack height shall be at least 45 feet (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] (1) The permittee shall keep and maintain on

site technical dra wings, blueprints or equivalent records of the physical stack parameters. [s. NR 439.04(1)(d), Wis. Adm. Code]**FID 113225200; Permit No. 113**  **22 5200** 

**- F01**  **Page 15**  **of 15** 

ZZZ. Conditions Applicable to the Entire Facility. {Table_Heading}

Condition a. Limitations b. Compliance Demonstration c. Reference Test Methods, Record keeping and Monitoring Require ments
above ground level. (ss. 285.63(1)(a) and 285.65(3), Wis. Stats.)

(b) The stack inside diameter at the outlet may not exceed 1.33 feet. (ss. 285.63(1)(a) and 285.65(3), Wis. Stats.)

( c ) The stack may not be equippe d with a rainhat or other device that may impede the upward velocity of the exhaust gas. (ss. 285.63(1)(a) and 285.65(3), Wis. Stats.)

( d ) The permittee shall keep and maintain on site technical drawings, blueprints or equivalent records of the physical st ack parameters. (s. NR 439.04(1)(d), Wis. Adm. Code)

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.