# 1 AIR POLLUTION CONTROL OPERATION PERMIT

EI FACILITY NO: 415186750 PERMIT NO.: 415186750-F20

TYPE: Operation Permit Renewal, synthetic minor non-Part 70 source

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

Name of Source: Washington Island Electric Cooperative

Street Address: Route One – Box 14, Washington Island, WI 54246

Responsible Official, & Title: Robert B. Cornell, Washington Island Cooperative

is authorized to operate an electric utility and power gene rating station in conformity with the conditions herein.

THIS OPERATION PERMIT EXPIRES

[Section NR 407.09(1)(b)1., Wis. Adm. Code] FEBRUARY 9, 2015

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 time ly and complete application for renewal of the permit. If you

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

application has been finally acted upon by DNR. [ss. 227.51(2), Wis. Stats. and NR 407.04(2), Wis. Adm. Code].

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

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

Dated at Green Bay, Wisconsin, 2 – 9 - 2010

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

For the Secretary

By /s/ James Crawford for

Richard Wulk

Environmental Engineer Supervisor

# 2 PREAMBLE

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

enforceable.

Historical Summary of Permits/Or ders Issued to the Facility.

The following permits, orders, etc., are adopted, under ss. 285.65(3), Wis. Stats., and NR 407.09(2)(d), Wis. Adm. Code, by

Permit 415186750-F20 which then become s the primary enfo rceable document:

Permit/Order

Number Issuance Date Sources Covered & Description 1 

# Permits Adopted

94-POY-058 June 8, 1995 Construction of P08 and P09 None

415186750-F01 October 20, 1997 Total Facility Operation Permit 94-POY-058

415186750-F10 November 4, 2002 Tota l Facility Operation Permit Renewal 415186750-F01,

94-POY-058

1 

# – Total Facility refers to all existing units at the facility at the time of issuance of the permit listed.

Stack and Process Index

A. Stacks S03 & S04, Processes P03 & P04 – Two small diesel genera tors. P03 is rated at 170 hp and was installed in 1945.

P04 is rated at 390 hp and was installed in 1951.

B. Stacks S08 & S09, Processes P08 and P09 – Two Caterpillar diesel generators rated at 2,288 hp, both installed in 1996.

Insignificant Emission Units

 Maintenance of Grounds, Equipment, and Buildings

 Office Activities

 Sanitary Sewer and Plumbing Venting

 Boilers B01 and B02 (0.3 MMBtu/hr distillate oil fired)

 Two distillate fuel oil storage tanks

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 emi ssion limitations established under ss. 285.01 to 285.87, Wis.

Stats., and emission limitations under the federal clean air act, that are applicable to the so urce if the permit includes the

applicable limitation or if the Department determines that the emission limitations do not apply. The following emission

limitations were reviewed in the analysis and preliminary determ ination and were determined not to apply to this stationary

source: None

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

follows them in [brackets].

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

Limitations – This area will list all applicable emission limitati ons that apply to the source, including case-by-case

limitations such as Latest Available Control Techniques (LACT), Best Available Control Technology (BACT), or

Lowest Achievable Emission Rate (LAER). It will also list any voluntary restrictions on hours of operation, raw material

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

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

compliance with the associated em ission limit or work practice standard listed under the corresponding Limitations

# 3 column. The compliance demonstration area contains limits on parameters or other mechanisms that will be monitored

periodically to ensure compliance with the limitations. The requirement to test as well as initial and periodic test

schedules, if testing is required, will be stated here. No twithstanding the compliance determination methods which the

owner or operator of a sources is authorized to use under ch. NR 439, Wis. Adm. Code, the Department may use any

relevant information or appropriate method to determine a source’s compliance with a pplicable emission limitations.

Reference Test Methods, Recordkeep ing, and Monitoring Requirements – Specific USEPA Reference test methods

or other approved test methods will be contained in this area and are the methods th at must be used whenever testing is

required. A reference test method will be listed even if no te sting is immediately required. Also included in this area are

any recordkeeping requirements and their frequency and reporting requirements. Accuracy of monitoring equipment

shall meet, at a minimum, the requirements of s. NR 439.055(3) and (4), Wis. Adm. Code, as specified in Part II of this

permit.

Condition Type – This area will specify other conditions that are app licable 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.

Compliance Demonstration – This area contains monitoring and testing requirements and methods to demonstrate

compliance with the conditions.

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

for most sources of air pollutants so they are included in this section with every permit.4PART IAPPLICABLE LIMITATIONSAND SPECIFIC CONDITIONSA. Stacks S03 & S04; Processes P03 & P04 – Process P03 isa 170 hp diesel generator installed in 1945. P04 is a 390 hp diesel generator installed in 1951.Note: The limitations in this table apply to each generator individually unless otherwise indicated.POLLUTANTa. LIMITATIONSb. COMPLIANCE DEMONSTRATIONc. REFERENCE TEST METHODS, RECORDKEEPING ANDMONITORING REQUIREMENTS1.ParticulateMatter Emissions(1)0.50 pound of particulatematter per million BTU ofheat input. [s. NR 485.055,Wis. Adm. Code](1)The permittee may burn only Numbers 1 and 2distillate fuel oil in the diesel generators.1[s. NR407.09(4)(a)3.b., Wis. Adm. Code](1)Reference Test Method for Particulate Matter Emissions:Whenever particulate matter emission testing is required by theDepartment, the permittee shall use U.S. EPA Method 5, includingbackhalf. [s. NR 439.06(1), Wis. Adm. Code](2)The permittee shall keep records of the type and amount of fuelburned in the diesel generators on a monthly basis. [s. NR439.04(1)(d), Wis. Adm. Code]2.VisibleEmissions(1) 40% opacity or number 2on the Ringlemann chart. [s.NR 431.04(1), Wis. Adm.Code](1) Same as particulate matter. See A.1.b.(1)above.(1)Reference Test Method for Visible Emissions: Whenever visibleemission testing is required by the Department, the permittee shall useU.S. EPA Method 9. [s. NR 439.06(9)1., Wis. Adm. Code](2)Same as particulate matter. See I.A.1.c.(2) above.1Using a particulate matter emission factor of 0.0022 pounds per horsepower-hour (#/hp-hour) for distillate fuel oil, the generator's horsepower rating and maximum fuel consumption,and a higher heating value for distillate fuel oil of 0.14 million BTU per gallon, the particulate matter emissions are 0.314 pounds per million BTU of heat input. The emission factorcomes from the October 1996 update to AP-42 (section 3.3).5B. Stacks S08 & S09; Processes P08 & P09 – Two Caterpillar diesel generators rated at 2288 horsepower. These generators wereinstalled in 1996 under constructionpermit 94-POY-058.Note: The limitations in this table apply to each generator individually unless otherwise indicated.POLLUTANTa. LIMITATIONSb. COMPLIANCE DEMONSTRATIONc. REFERENCE TEST METHODS, RECORDKEEPING ANDMONITORING REQUIREMENTS1.ParticulateMatter Emissions(1)0.50 pounds ofparticulate matter per millionBTU of heat input. [s. NR485.055, Wis. Adm. Code](1)The permittee may burn only Numbers 1 and 2distillate fuel oil in this diesel generator.2[s. NR407.09(4)(a)3.b., Wis. Adm. Code](1)Reference Test Method for Particulate Matter Emissions:Whenever particulate matter emission testing is required by theDepartment, the permittee shall use U.S. EPA Method 5, includingbackhalf. [s. NR 439.06(1), Wis. Adm. Code](2)The permittee shall keep records of the type and amount of fuelburned in this diesel generator on a monthly basis. [s. NR439.04(1)(d), Wis. Adm. Code]2.VisibleEmissions(1)20% opacity or number 1on the Ringlemann chart. [s.NR 431.05, Wis. Adm.Code](1)Same as particulate matter. See I.B.1.b.(1)above.(1)Reference Test Method for Visible Emissions: Whenever visibleemission testing is required by the Department, the permittee shall useU.S. EPA Method 9. [s. NR 439.06(9), Wis. Adm. Code](2)Same as particulate matter. See I.B.1.c.(2) above.3.Stack Parameters(1)The height of stacks S08and S09 shall be at least 28feet above ground level. [s.285.65(3), Wis. Stats.](2)The inside diameter atthe outlet of stacks S08 andS09 may not exceed 1.1 feet.[s. 285.65(3), Wis. Stats.](1)See the recordkeeping requirements specified inI.B.3.c.(1).(1)The permittee shall maintain engineering drawings that indicatethe stack height and stack insidediameter for each stack. [s. NR439.04(1)(d), Wis. Adm. Code]2Using a particulate matter emission factor of 0.0022 pounds per horsepower-hour (#/hp-hour) for distillate fuel oil, the generator's horsepower rating and maximum fuel consumption,and a higher heating value for distillate fuel oil of 0.14 million BTU per gallon, the particulate matter emissions are 0.314 pounds per million BTU of heat input. The emission factorcomes from the October 1996 update to AP-42 (section 3.3).6Z. Total Facility LimitationsCONDITION TYPEa. LIMITATIONSb. COMPLIANCEDEMONSTRATIONc. RECORDKEEPING AND MONITORING REQUIREMENTS1.Fuel use limit for P08and P09(1)The permittee may not burnmore than 300,000 gallons ofNumbers 1 and 2 distillate fuelin generators P08 and P09,combined, during each 12consecutive month period.3[s.285.65(7), Wis. Stats.](1)Compliance with the limitation inI.Z.1.a.(1) shall be demonstrated throughkeeping records of fuel oil usage for P08and P09. [s. NR 407.09(4)(a)3.b., Wis.Adm. Code](1)The permittee shall keep records of the amount of distillate fuel oilburned in P08 and P09, combined, for each month and for each 12consecutive month period. [s. NR 439.04(1)(d), Wis. Adm. Code]2.Restriction on hoursof operation of P03 andP04(1)The permittee may notoperate generators P03 andP04 for more than 500 hours,each, during each 12consecutive month period. [s.285.65(7), Wis. Stats.](1)Compliance with the limitation inI.Z.2.a.(1) shall be demonstrated throughkeeping records of the hours of operationof generators P03 and P04. [s. NR407.09(4)(a)3.b., Wis. Adm. Code](1)The permittee shall keep records of the number of hours of operationof P03 and of P04 for each month and for each 12 consecutive monthperiod. [s. NR 439.04(1)(d), Wis. Adm. Code]3.Fuel oil sulfur contentlimit(1)The sulfur content ofNumbers 1 and 2 distillate fueloil used at the facility may notexceed 0.5% by weight. [s.NR 407.09(2)(d), Wis. Adm.Code, and s. 285.65(7), Wis.Stats.](1)When requested by the Department,the permittee shall demonstratecompliance with the fuel oil sulfur limit inI.Z.3.a.(1) using certification from the fuelsupplier. [s. NR 407.09(4)(a)3.b., Wis.Adm. Code](1)The permittee shall keep recordsof fuel supplier certification thatinclude the name of the fuel supplier and the sulfur content of the fueloil received. [s. NR 439.04(1)(d), Wis. Adm. Code]3The permittee elected to take the restrictions in I.Z.1., I.Z.2. and I.Z.3. in order to be a synthetic minor source under Part70. These limitations restrict emissions to below 80% ofthe major source thresholds.7Z. Total Facility LimitationsCONDITION TYPEa. CONDITIONSb. COMPLIANCE DEMONSTRATION4.Reporting(1)The permittee shall submitperiodic monitoring reports.[s. NR 407.09(1)(c)3., Wis.Adm. Code](2)The permittee shall submitperiodic compliancecertifications. [s. NR407.09(4)(a)3., Wis. Adm.Code](1)The permittee shall submit a monitoring report which contains the results of monitoring or a summary ofmonitoring results required by this permit to the Department every 12 months.(a)The time periods to be addressed by the submittal are January 1 to December 31 of each year.(b)The report shall be submitted to the Wisconsin Department of Natural Resources Northeast RegionHeadquarters, 2984 Shawano Avenue, Green Bay, WI 54313-6727 within 60 days after the end of each reportingperiod.(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 thereport.(e)The content of the submittal is described in item D. of Part II of the operation permit.[s. NR 439.03(1)(b), Wis. Adm. Code](2)The permittee shall submit an annualcertification of compliance with the requirements of this permit to theWisconsin Department of Natural Resources Northeast Region Headquarters, 2984 Shawano Avenue, Green Bay,WI 54313-6727.(a)The time period to be addressed by the report is the January 1 to December 31 period which precedes the report.(b)The report shall be submitted to the Wisconsin Department of Natural Resources Northeast RegionHeadquarters within 60 days after the endof each reporting period.(c)The information included in the report shall comply withthe requirements of Part II, Section N of this permit.(d)Each report shall be certified by a responsible official as to the truth, accuracy and completeness of the report.[s. NR 439.03(1)(c), Wis. Adm. Code]CONDITION TYPEa. CONDITIONS5.Compliance Testing(1)If any required compliance emission test(s) cannot be conducted within the time frames specified in this permit, the permit holder may requestand the Department 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 operatingat capacity or as close to capacity as practicable and in accordance with approvedprocedures. If operation at capacity is not feasible, the sourceshall 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. Atthe time of notification, a compliance emission test plan shall also be submitted to the Department for approval. When approvedin writing, anequivalent test method may be substituted for the reference test method. The notification and test plan shall be submitted to the WisconsinDepartment of Natural Resources. [s. NR 439.07(2), Wis. Adm. Code](4)Two copies of the report on any compliance emission tests shall be submitted to the Department for evaluation within 60 days following thecompletion of tests. [s. NR 439.07(9), Wis. Adm. Code]8Z. Total Facility LimitationsCONDITION TYPEa. CONDITIONS6.Additional ReferenceTest Methods(1)Reference Test Method for PM10 Emissions: Whenever PM10 emission testing is required by the Department, the permittee shall use U.S. EPAMethod 201 or 201A. [s. NR 439.06(1m), Wis. Adm. Code](2)Reference Test Method for Liquid Fossil Fuel Sampling: Whenever liquid fossil fuel sampling is required, it shall be performed according to themost current version of ASTM D4057 (as of January 2010 the current version is D4057-95), Standard Practice for Manual Samplingof Petroleum andPetroleum Products, or the most current version of ASTM D4177 (as of January 2010 the current version is D4177-95), Standard Practice forAutomatic Sampling of Petroleum and Petroleum Products. [s. NR 439.08(2)(a), Wis. Adm. Code](3)Reference Test Method of Sulfur Content in Liquid Fossil Fuel: Whenever the sulfur content of a liquid fossil fuel sampling is required, it shall bedetermined according to the most current version of ASTM D129(as of January 2010 the current version is D129-00), Standard Test Method for Sulfurin Petroleum and Petroleum Products (General Bomb Method), the most current version of ASTM D1552 (as of January 2010 the current version isD1552-03), Standard Test Method for Sulfur in Petroleum Products(High-Temperature Method), or the most current version of ASTM D4294 (as ofJanuary 2010 the current version is D4294-03), Standard Test Method for Sulfur in Petroleum Products by Energy-Dispersive X-rayFluorescenceSpectroscopy. [s. NR 439.08(2)(b), Wis. Adm. Code](4)Reference Test Method of Heat Content in Liquid Fossil Fuel: Whenever the heat content of a liquid fossil fuel sampling is required, it shall beperformed according to the most current version of ASTM D240(as of January 2010 the current version is D240-02), Standard TestMethod for Heat ofCombustion of Liquid Hydrocarbon Fuels by a Bomb Calorimeter. [s. NR 439.08(2)(c), Wis. Adm. Code]7.Alternate OperatingScenario: Use of rawmaterials not included inthe permit application(1)If the permittee has the capability to burn or use a raw materialnot included in the application reviewed for this permit, the permittee may usethis material without first obtaining a construction permit provided the following conditions are met:(a)The source has continuously had such design capability to burn or use the raw material.(b)The use will not cause or exacerbate theviolation of an ambient air quality standard or an ambient air increment.(c)The use is not prohibited by any permit, plan approval or special order applicable to the source.(d)The use will not result in a violation of any emission limit in chs. NR 405, 408, 409, 415 to 436, and 445, Wis. Adm. Code.(e)The use will not subject the source to any standard or regulation under s. 112 of the Clean Air Act (42 USC 7412).[s. NR 406.04(4)(a), Wis. Adm. Code](2)Any calculations and supporting material required to demonstratecompliance shall be kept on file by the permittee. [ss. NR 407.09(1)(c)2. andNR 439.04(1)(d), Wis. Adm. Code]