2 

PART I - APPLICABLE LIMITATIONS AND REQUIREMENTS 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

1.Particulate Matter Emissions (PM/PM10) 

(1) (a)The emissions may not exceed 33 pounds per hour. [s. NR 415.06(2)(c), Wis. Adm. Code; s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats.] (2) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) The use of natural gas and, (b) The use of good combustion practices, and (c) Complying with the emission limitation of condition I.A.1.a. (1).[s. NR 405.08, Wis. Adm. Code] 

(1) The permittee shall demonstrate compliance with the applicable PM/PM10 hourly 

emission limit by performing a stack test using USEPA Methods 5 and 202, within 240 daafter the initial operation of the process. (a) Compliance emission tests shall be conducted at 100% load operation. 

(b) If operation at 100% load is not feasible, the source shall operate at a capacity level thais approved by the Department in writing. (c) If the compliance emission tests cannot be conducted within 240 days after the initial operation, the permittee may request in writing and the Department may approve, in writinan extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall demonstrate compliance with the particulate matter hourly emission limits when firing natural gas within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid.[s. NR 439.075(2)(a)1,; s. 285.65(10

Wis. Stats., Code and s. 285.65(3), Wis. Stats.] (3) The facility shall fire only natural gas in this process. This condition is established to meet BACT emission limits. [s. NR 405.08, Wis. Adm. Code; ss. 285.65(3) and 285.65(10Wis. Stats.] (4) (a) The permittee shall maintain the ranges of the parameters identified in condition 

I.F.8.a.(1)(b), to meet good combustion practices.  (b) The permittee shall comply with condition I.F.8.a.(1)(a) and (b) for demonstrating compliance with the good combustion practices requirements. 

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

2.Sulfur Dioxide 

(1)The permittee shall: 

(a) Use pipeline natural gas as 

(1) The facility shall fire natural gas in the process. This condition is established to meet emission limits.[s. NR 405.08, Wis. Adm. Code; ss. 285.65(3) and 285.65(10), Wis. Stats.] 
3 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

Emissions (SO2) 

defined under 40 CFR Part 72.2, and (b) limit the hourly emissions to 1.48 pounds per hour. [s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] 

(2) The permittee shall use the sampling and analysis protocol for SO2 as found in 40 CFR Part 75 Appendix D to demonstrate that the sulfur content of the natural gas is less than the sulfur content limit in I.A.7.a.(2). This sampling protocol represents an approved plan under NR 440.50(5)(b)2., for demonstrating compliance with the sulfur dioxide emission rate in NR 440.50(4)(a). [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] (3)If the facility changes its delivery of fuel to the facility, the permittee shall re-verify the 

sulfur content as described in I.A.2.b.(2). [s. 285.65(3), Wis. Stats.] (4) Sulfur content monitoring of the natural gas may be conducted by the permittee or natural gas supplier to satisfy permit condition I.A.2.b. (2) and (3).[s. 285.65(3), Wis. Stats

(5) The permittee shall follow the procedures identified in 40 CFR Part 75, Appendix D. 

2.3. for determining SO2 emissions for compliance with 40 CFR Part 75.[s. 285.65(3), WiStats., s. 285.65(10), Wis. Stats.] 
4 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 3.Nitrogen Oxides Emissions (NOx) 

(1) Normal operation: (a) Excluding start up and shut down , the hourly emissions may not exceed 3.0 ppmdv @ 15% O2 based on a 30 days rolling average when firing natural gas. [s. 285.65(3), Wis. Stats.; s. 285.65(7), Wis. Stats.; s. NR 428.04(2)(g)1.d., Wis. Adm. Code] (2) Start up and Shut down 

emissions: (a) The emissions during a cold startup and shut down may not exceed 586 pounds for each startup/shut down event. The emissions during a warm or hot startup and shut down may not exceed 355 pounds for each startup/shut down event. (b)The total emissions from the start up and shut down of all fourcombustion turbines combined may not exceed 318.0 tons in any 12 consecutive month period. (c) For purposes of calculating emissions to demonstrate compliance with condition (b), each cold start up period is defined as a startup and shutdown with a 

(1) The permittee shall demonstrate compliance with the applicable Nox emission limit in 

condition I.A.3.a.(1) and (2)(a), by performing a stack test using USEPA Method 7 or 7E, 

within 240 days after initial operation of the process. (a) Compliance emission tests for emission limits in condition I.A.3.a.(1) shall be conducteat 100% load operation and when the calculated combustion reference temperature reaches 

2,280 degrees F during the initial stack testing. The permittee may petition the Department to waive testing requirements at combustion reference temperature of 2,280 degree F durinthe 60-month retest. (b) If operation at 100% load operations is not feasible, the source shall operate at a capacilevel that is approved by the Department in writing. (c) The permittee shall also determine the start up and shut down nitrogen oxides emissionwithin 240 days after initial operation of the process. Emissions will be measured continuously over the entire start up and shut down period. (d) If the compliance emission tests cannot be conducted within 240 days after initial operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall perform the compliance emission tests required under condition 

I.A.3.b.(1) within 30 days following the 5 year anniversary date of the previous stack test along as the permit remains valid.[s.285.65(10), Wis. Stats., and s. 285.65(3), Wis. Stats.] 

(3) The permittee shall demonstrate compliance with the NOx emission limit as follows:

(a) Daily average concentration shall be calculated by using the hourly average corrected t15% oxygen for each operating hour.(b) Monthly and annual emissions shall be calculated by combining the NOx concentration 

and diluent concentration (in % O2 or % CO2) measurement consistent with the procedurespecified in 40 CFR Part 75 Appendix F. The first 12 consecutive month period shall commence on the first day of the month the facility begins to generate electricity for sale, 

including the sale of test generation. [s. 285.65(3), Wis. Stats.]

(4) The permittee shall install and operate continuous emissions monitoring systems 

(CEMs) for NOx , carbon dioxide or oxygen and a continuous fuel flow monitoring system within 60 operating days after initial operation of the turbine. The CEMs shall be calibrate

1 Note 1: Start up is defined as that period of time with the start of ignition and when the calculated combustion reference temperature reache

will begin when the calculated combustion reference temperature drops below 2,230 degrees F and end when the flame is out. 
5 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

total duration of 151 to 250 minutes and each warm or hot start up period is defined as a startup and shutdown with a total duration of 150 minutes or less. When startup and shutdown durations exceeds these levels, emissions shall be calculated by accumulating additional warm startup events to equal or exceed the actual startup and shutdown period. [s. 285.65(3), Wis. 

Stats.] See Note 1.1

(3) The permittee shall meet the 30 day rolling average emission limit by: (a) The use of natural gas, and, (b) The use of dry low NOx

combustors, and (c) The use of Selective Catalytic Reduction system, and (e) Complying with the emission limitation of condition I.A.3.a.(1).[s. 285.65(3), Wis. Stats.] 

within the earlier of 90 operating days or 180 calendar days of the first sale of electricity, including the sale of any test generation. Continuous emissions monitoring systems shall binstalled and operated in accordance with 40 CFR Part 75 and s. NR 439.06(6)(b), Wis. Adm. Code requirements. The permittee shall submit an QA/QC plan for the CEMs to the SER, NER Air program. [s. 285.65(3), Wis. St.; s. NR 439.06, WAD] (5) (a) The permittee shall keep operating records of all start ups and shut downs and track start up and shut down time of the CTG by CEMs. Data systems [s. 285.65(3), Wis. Stats.]

(b) The permittee shall provide this information to the Department at least four months prito the expiration of the construction permit. This information will be used to write the operation permit. [s. 285.65(3), Wis. Stats.] (6) Mass emissions during start up and shut down shall be calculated by the use of test data (or CEM data) and actual fuel flow rates. [s. 285.65(3), Wis. Stats.]

(7)The permittee shall operate the combustion turbine and duct burner in a manner consistent with the good combustion practices requirements to minimize emissions of nitrogen oxides during start up, malfunction, and shut down, including:(a) Operation in accordance with the manufacturer's written instructions or other written instructions developed by the permittee; (b) Review of operating parameters of the unit during start up, malfunction and breakdown or shut down as necessary to make adjustments to reduce or eliminate excess emissions; c) Operation of the SCR system as soon as and as long as the unit operating conditions are amenable to its effective use. [s. 285.65(3), Wis. Stats.](8)Except during start up and shut down, the permittee shall ensure that the SCR control 

equipment for the turbine generator is operating whenever the combustion reference temperature exceeds 2,280 degrees F.. [s. 285.65(3), Wis. Stats.](9) Prior to performing the initial stack test required in condition I.A.3.b.(1), the permittee shall install and operate a continuous monitor to monitor the temperature at the inlet to the SCR. [s. 285.65(3), Wis. Stats.](10) The permittee shall identify during the initial operation period the normal operating 

temperature range at the inlet to the SCR and provide this information to the Department aleast four months prior to the expiration of the construction permit. [s. 285.65(3), Stats.] 
6 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 4.Carbon Monoxide Emissions (CO) 

(1) Normal operation: (a)Except during start up and shut down periods the emissions may not exceed 3.0 ppmdv @ 15% O2 based on a calendar day.[s. 285.65(3), Wis. Stats.; s. 285.65(7), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2) Start up and shut down emissions: (a) The emissions during a cold startup and shut down may not exceed 1026 pounds for each start up/shut down event.  The emissions during a warm or hot startup and shut down may not exceed 807 pounds for each startup/shut down event. (b) The total emissions from the start up and shut down of all four combustion turbines combined may not exceed 630.6 tons in any 12 consecutive month period. See Note 1.2

(c) For purposes of calculating emissions to demonstrate compliance with condition (b), each cold start up period is defined 

(1) The permittee shall demonstrate compliance with the applicable CO emission limit in condition I.A.4.a.(1) and (2)(a), by performing a stack test using USEPA Method 10, within 240 days after initial operation of the process. 

(a) Compliance emission tests for limits in condition I.A.4.a.(1) shall be conducted, at 100% load operations, and when the combustion reference temperature reaches 2,280 degree F during the initial stack testing. The permittee may petition the Department to waive testing requirements at combustion reference temperature of 2,280 degrees F durinthe 60-month retest. (b) If operation at 100% load operation is not feasible, the source shall operate at a capacilevel that is approved by the Department in writing. (c) The permittee shall also determine the start up and shut down carbon monoxide emissions within 240 days after initial operation of the process. Emissions shall be measured continuously over the entire start up and shut down period. (d) If the compliance emission tests cannot be conducted within 240 days after initial operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall perform the compliance emission tests required under condition 

I.A.4.b.(1) within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid.[s.285.65(10), Wis. Stats., and s. 285.65(3), Wis. Stats(3) The permittee shall demonstrate compliance with the carbon monoxide emission limit as follows:(a) Daily average concentration shall be calculated over each 24-hour rolling period.(b) Monthly and annual emissions totals shall be calculated by combining the CO concentration and diluent concentration (in % O2 or % CO2) measurement consistent wit

the procedures specified in 40 CFR Part 75 Appendix F. The first 12 consecutive month period shall commence the first day of the month the facility begins to generate electricity for sale, including the sale of any test generation. [s. 285.65(3), Wis. Stats.]

(4) The permittee shall install and operate continuous emissions monitoring systems 

(CEMs) for CO and oxygen or CO2 within 60 operating days after initial operation of the turbine. The CEMs shall be calibrated within the earlier of 90 operating days or 180 

2 Note 1: Start up is defined as that period of with the start of ignition and end when the calculated combustion reference temperature reaches 

begin when the calculated combustion reference temperature drops below 2,230 degrees F and end when the flame is out. 
7 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

as a startup and shutdown with a total duration of 151 to 250 minutes and each warm or hot start up period is defined as a startup and shutdown with a total duration of 150 minutes or less. When startup and shutdown durations exceeds these levels, emissions shall be calculated by accumulating additional warm startup events to equal or exceed the actual startup and shutdown period. [s. NR 405.08, Wis. Adm. Code.; s. 285.65(7), Wis. Stats.] (3) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) The use of natural gas, and (b) The use of good combustion practices, (c) The use of oxidation catalyst, and (d) Complying with the emission limitation of condition I.A.4.a.(1).[s. NR 405.08, Wis. Adm. Code] 

calendar days of the first sale of electricity, including the sale of any test generation. Continuous emissions monitoring systems shall be installed and operated in accordance with 40 CFR Part 60 Appendix B performance specification 4, and s. NR 439.06(4), Wis. Adm. Code requirements. [s. 285.65(3), Wis. Stats.; s. NR 439.06, Wis. Adm. Code]

(5) (a)The permittee shall keep operating records of all start ups and shut downs and track start up and shut down time of the CTG by CEMs data system. [s. 285.65(3), Wis. Stats.](b) The permittee shall provide this information to the Department at least four months prior to the expiration of the construction permit. This information will be used to prepare the operation permit. [s. 285.65(3), Wis. Stats.] 

(6) Mass emissions during start up and shut down shall be calculated by the use of one of the following: (a) emission test data or; (b) CEM data in combination with actual fuel flow rates.. [s. 285.65(3), Wis. Stats.]

(7) The permittee shall operate the combustion turbine in a manner consistent with good combustion practices to minimize emissions of carbon monoxide during start up, malfunction, and shut down, including: (a) operation in accordance with the manufacturer's written instructions or other written 

instructions developed by the permittee;(b) review of operating parameters of the unit during start up, malfunction and breakdown or shutdown as necessary to make adjustments to reduce or eliminate excess emissions;

(c) Operation of the oxidation catalyst system as soon as and as long as the unit operating conditions are amenable to its effective use. [s. 285.65(3), Wis. Stats.] (8) The facility shall fire natural gas in this process. This condition is established to meet BACT emission limits.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. AdmCode] (9) (a) The permittee shall maintain the ranges of the parameters identified in condition 

I.F.8.a.(1)(b), to meet good combustion practices.

(b) The permittee shall comply with condition I.F.8.a.(1)(a) and (b) for demonstrating compliance with the good combustion practices requirements. [s. 285.65(3), Wis. Stats.]

(10) Except during start up and shut down, the permittee shall ensure that the oxidation catalyst control equipment for the turbine generator is operating whenever the combustion 

reference temperature exceeds 2,280 degrees F. [s. 285.65(3), Wis. Stats.]

(11) Prior to performing the initial stack test required in condition I.A.4.b.(1), the permittshall install and operate a continuous monitor to monitor the temperature at the inlet to thoxidation catalyst. [s. 285.65(3), Wis. Stats.] 
8 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

(12) The permittee shall identify during the initial operation period the normal operating temperature range at the inlet to the oxidation catalyst and provide this information to the Department at least four month prior to the expiration of the construction permit. [s. 285.65(3), Wis. Stats.] 

5.Volatile Organic Compound Emissions (VOC) 

(1) Normal operation: (a) Except during start up and shut down periods, the emissions may not exceed 1.2 ppmdv @ 15% O2 based on a calendar day average when the duct burners are in 

(1) The permittee shall demonstrate compliance with the applicable VOC emission limit icondition I.A.5.a.(1) and (2)(a), by performing a stack test using USEPA Method 25A or 

18, within 240 days after the initial operation of the process. 

(a) Compliance emission tests for limits in condition I.A.5.a.(1) shall be conducted, at 100% load operation, and when the calculated combustion reference temperature reaches 2,280 degrees F operation during the initial stack testing. The permittee may petition the 

3 Note 1: Start up is defined as that period of time with the start of ignition and end when the calculated combustion reference temperatu

down will begin when the calculated combustion reference temperature drops below 2,230 degrees F and end when the flame is out.
9 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

operation. (b) Except during start up and shut down periods, the emissions may not exceed 0.8 ppmdv @ 15% O2 based on a calendar day average when the duct burners are not in operation. (c) The duct burner heat input of all four combustion turbines combined may not exceed 4,452,000 mmBtu in any consecutive 12-month period. [s. 285.65(3), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2) Start up and Shut down emissions: (a) The emissions during a cold start up and shut down may not exceed 92 pounds for each start up/shut down event. The emissions during a warm or hot startup and shut down may not exceed 77 pounds for each startup/shut down event. (b) The total emissions from the start up and shut down of all four combustion turbines combined may not exceed 58.4 tons in any 12 consecutive month period. See Note 1.3

(c) For purposes of calculating emissions to demonstrate 

Department to waive testing requirements at combustion reference temperature of 2,280 degrees F during the 60-month retest. (b) If operation at 100% load operation is not feasible, the source shall operate at a capacilevel that is approved by the Department in writing. (c) The permittee shall also determine the start up and shut down volatile organic compounds emissions during the initial stack testing within 240 days after the initial operation of the process. Emissions shall be measured continuously over the entire start u

and shut down period. (d) If the compliance emission tests cannot be conducted within 240 days after the initial operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall perform the compliance emission tests required under condition 

I.A.5.b.(1) within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid.[s. 285.65(10), Wis. Stats.; and s. 285.65(3), Wis. Stats.] (3) The permittee shall demonstrate compliance with the VOC emission limit by monitoring CO emissions with the CO CEMS. The permittee shall use the equation in condition I.A.5.b.(4) to keep daily, monthly and annual VOC emissions records in tons. [285.65(3), Wis. Stats.](4)(a)The permittee shall monitor VOC emissions during operation as occurring at a rate determined by the equation: VOC actual = VOClimit X (COactual / COlimit)

(b) The permittee shall maintain records for each hour of operation that indicate whether 

duct firing is on or off.

(c) The permittee shall monitor and record the hourly fuel combustion in each duct 

burner.

(d) The permittee shall maintain records of the duct burner heat input for all four 

combustion turbines combined on a monthly and 12-month average basis to demonstrate compliance with condition I.A.5.a.(1)(c).

(5) (a)The permittee shall keep operating records of all start ups and shut downs and track start up and shut down time of the CTG by the CO CEMs. [s. 285.65(3), Wis. Stats.] (b) The permittee shall provide this information to the Department at least four months prior to the expiration date of the construction permit. This information will be used to 
10 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

compliance with condition (b), each cold start up period is defined as a startup and shutdown with a total duration of 151 to 250 minutes and each warm or hot start up period is defined as a startup and shutdown with a total duration of 150 minutes or less. When startup and shutdown durations exceeds these levels, emissions shall be calculated by accumulating additional warm startup events to equal or exceed the actual startup and shutdown period. [s. NR 405.08, Wis. Adm. Code.; s. 285.65(7), Wis. Stats.] (3) The permittee shall apply Best Available Control Technology (BACT).BACT shall be met by: (a) The use of natural gas, and (b) The use of good combustion practices, and (c) The use of oxidation catalyst, and (d) Complying with the emission limitation of condition I.A.5.a.(1). [s. NR 405.08, Wis. Adm. Code] 

prepare the operation permit. [s. 285.65(3), Wis. Stats.] (6) Mass emissions during start up and shut down shall be calculated by the use of test da(or CEM data) and actual fuel flow rates (for calculating heat input rates). [s285.65(3), St

(7) The permittee shall operate the combustion turbine in a manner consistent with good combustion practices to minimize emissions of VOCs during start up, malfunction, and 

shut down, including:(a) Operation in accordance with the manufacturer's written instructions or other written 

instructions developed by the permittee;(b) Review of operating parameters of the unit during start up, malfunction and breakdowor shut down as necessary to make adjustments to reduce or eliminate excess emissions;(c) Operation of the oxidation catalyst system as soon as and as long as the unit operating 

conditions are amenable to its effective use. [s. 285.65(3), Wis. Stats.]

(8) The facility shall fire only natural gas in this process. This condition is established to meet BACT emission limits.[ss.285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis

Adm. Code] (9) (a) The permittee shall maintain the ranges of the parameters identified in condition I.F.8.a.(1)(b), to meet good combustion practices. (b) The permittee shall comply with condition I.F.8.a.(1)(a) and (b) for demonstrating compliance with the good combustion practices requirements. [s.285.65(3), Wis. Stats.] (10) Except during start up and shut down, the permittee shall ensure that the oxidation catalyst control equipment for the turbine generator is operating whenever the turbine is 

fully operated. [s.285.65(3), Wis. Stats.] (11) Prior to performing the initial stack test required in condition I.A.5.b.(1), the permittshall install and operate a continuous monitor to monitor the temperature at the inlet to thoxidation catalyst. [s. 285.65(3), Wis. Stats.] (12) The permittee shall identify during the initial operation period the normal operating temperature range at the inlet to the oxidation catalyst and provide this information to the Department at least four months prior to the expiration of the construction permit. [s. 285.65(3), Wis. Stats.] 

6.Hazardous air pollutants regulated under 

(1) Formaldehyde emissions with and without duct firing may not exceed 0.56 pounds per hour. [s. 

(1) The permittee shall demonstrate compliance with the applicable formaldehyde emissiolimit in condition I.A.6.a.(1), by performing a stack test using USEPA Method 0011, 

within 240 days after initial operation of the process. 
11 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION sec. 112 of the Clean Air Act 

285.65(7), Wis. Stats.] See Note 14

(a) (I) Compliance emission tests for limits in condition I.A.6.a.(1) shall be conducted at 100% load operation during the initial stack testing. . (b)If operation at 100% load operation is not feasible, the source shall operate at a capacitlevel that is approved by the Department in writing. (c) If the compliance emission tests cannot be conducted within 240 days after initial operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall perform the compliance emission tests required under conditions I.A.6.b.(1) within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid. [s. 285.65(10), Wis. Stats.; and s. 285.653(3), Wis. Stats.] (3) The facility shall fire only natural gas in the process. This condition is established to 

meet hourly emission limits. (ss. 285.65(3), 285.65(13), and 285.65(10), Wis. Stats.] (4) (a) The permittee shall maintain the ranges of the parameters identified in condition I.F.8.a.(1)(b), to meet hourly emission rate. (b) The permittee shall comply with the condition I.F.8.a.(1)(a) and (b) for demonstrating compliance with the hourly emission rate. [s. 285.65(3), Wis. Stats.] 

7.Sulfuric acid Emissions (H2SO4) 

(1)(a) The emissions may not exceed 2.27 pounds per hour. [ s.285.65(3), Wis. Stats.; s. 285.65(70, Wis. Stats.] (2) The permittee shall: (a) Use natural gas, and (b) Limit the sulfur content in the natural gas to 0.8 grain/100 scf (0.003% by 

(1) The permittee shall demonstrate compliance with the applicable H2SO4 hourly 

emission limit by performing a stack test using USEPA Method 8, within 240 days after 

initial operation of the process. (a)Compliance emission tests shall be conducted at 100% load operation when firing natural gas. (b)If operation at 100% load is not feasible, the source shall operate at a capacity level thais approved by the Department in writing. 

4 Note 1: The permittee will meet the hourly emission limit by use of good combustion practices. The Department acknowledges that additio

be achieved as a result of the operation of the CO oxidation catalyst, the control technology used for controlling carbon monoxide and volatThe permittee shall conduct stack testing for formaldehyde emissions, both upstream and downstream of the CO oxidation catalyst, to deter

that may be achieved as a result of the operation of the CO oxidation catalyst. The Department will use the stack testing information to esta

formaldehyde when an operation permit is issued for the facility. 
12 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

weight), and (c) Comply with the emission limitation of condition I.A.7.a.(1). [s. 285.65(3), Wis. Stats.; s. 285.65(7), Wis. Stats.] 

(c) If the compliance emission tests cannot be conducted within 240 days after initial operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), WAC] (2) The permittee shall perform the compliance emission tests required under condition 

I.A.7.b.(1) within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid.[s. 285.65(10), Wis. Stats.; s. 285.65(3), Wis. Stats.] (3) The facility shall fire only natural gas in the process. This condition is established to 

meet hourly emission limits.[s. NR 405.08, Wis. Adm. Code; ss. 285.65(3) and 285.65(10Wis. Stats.] (4) (a) The permittee shall use pipeline natural gas as defined in 40 CFR Part 75 AppendiD s. 2.3.1.4(a). (b) The permittee shall sample the natural gas for sulfur content of the fuel and the Gross Caloric Value (GCV) and/or percentage by volume of methane twice monthly for the firssix months of operation, with all samples being at least 10 days apart. If these results indicate values that are less than the sulfur content specified in I.A.7.a.(2), the frequency sampling shall be done semi-annually thereafter (first and third quarters).Sampling is only 

required during a calendar quarter in which the facility has operated.[s. 285.65(3), Wis. 

Stats.; s. 285.65(10), Wis. Stats.](c) Each sample must meet the definition of pipeline natural gas as defined in 40 CFR Par75, Appendix D s. 2.3.1.4(a). (d) The facility may use 0.0006 #/Mbtu sulfur dioxide as a default emission factor. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] (5)If the facility changes its delivery of fuel to the facility, the permittee shall re-verify thsulfur content as described in I.A.2.b.(2). [s. 285.65(3), Wis. Stats.] (6) Sulfur content monitoring of the natural gas may be conducted by the permittee or natural gas supplier to satisfy permit condition I.A.2.b. (4) and (5).[s. 285.65(3), W. Stats

8.Ammonia Emissions 

(1)The emissions may not exceed 10 ppmdv @15% O2 and 30.10 

pounds per hour based on a 24-hour rolling average. [ s. NR 445.04(1), Wis. Adm. Code; s. 285.65(7), Wis. Stats.] See Note 15

(1) The permittee shall demonstrate compliance with applicable ammonia emission limit 

by performing a stack test using USEPA conditional test Method 027, within 240 days after initial operation of the process. (a)Compliance emission tests shall be conducted at 100% load operation . 

(b)If operation at 100% load is not feasible, the source shall operate at a capacity level tha

is approved by the Department in writing. (c) If the compliance emission tests cannot be conducted within 240 days after initial 

5 Note 1: These emissions do not result from combustion. Aqueous ammonia is used as the reagent for the SCR. Ammonia that does not react i
13 

A. Processes #s P11, P12, P21, P22,Stacks #s S11, S12, S21, S22 – Combined-Cycle Combustion Turbine Generators (CTG ) [General EleThe following emission limitations apply to each Combined-Cycle Combustion Turbine Generator (CTG) POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

operation of the process, the permittee may request in writing and the Department may approve, in writing, an extension of time to conduct the test(s).[s. NR 439.075(3), Wis. Adm. Code] (2) The permittee shall perform the compliance emission tests required under condition 

I.A.8.b.(1) within 30 days following the 5 year anniversary date of the previous stack test as long as the permit remains valid.[s. 285.65(10), Wis. Stats., s. 285.65(3), Wis. Stats.] 

. Visible Emissions 

(1) 20% opacity [s. NR 431.05, Wis. Adm. Code] See Note 16

(1) A visible emissions compliance test shall be performed simultaneous with the PM emissions test required in condition I.A.1.b.(1).[s. NR 439.06(9)(a)1, Wis. Adm. Code] (2) The permittee shall fire only natural gas in the process. This condition is established to meet the visible emission limits.[ss. 285.65(3) and 285.65(10), Wis. Stats.] 

6 Note 1: Opacity limits in excess of 20% are allowed when equipment is being cleaned or a new fire started, but may not exceed 80% for 5 m

may not be cleaned or fire started more than 3 times per day. 
14 

B. Process #P05, Stack # S05 - Diesel Engine Generator POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE 

MONITORI

1.Particulate Matter Emissions (PM/PM10) 

(1) The emissions may not exceed 0.89 pound per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] (2) The hours of operation may not exceed 500 hours in any 12 consecutive month period.[s. 285.65(7), Wis. Stats.] (3) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) The use of 0.05% by weight sulfur diesel fuel oil, and (b) Complying with the emission limitation of condition I.B.1.a.(1).[s. NR 405.08, Wis. Adm. Code] 

(1)The permittee shall determine the PM/PM10 hourly emissions by: 

(a) Using operating parameters and certified emission test data as required by 40 CFR Part 89, and (b) Performing a stack test on the diesel engine generator, within 240 days after initial operation of the process. This stack testing requirement applies only to the initial stack testing. [s. 285.65(3), Wis. Stats.] (2) The facility shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet the BACT emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the diesel engine generator; and (b) A list of items that will be checked and maintained and their frequency, to ensure that the diesel engine generator is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit.[s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever corequired, test proMethods 5 and 2approved in writused.[s. NR 439.

(2) The permitte

electronic recordhours of operatiocondition I.B.1.a285.65(10), Wis(3) The permittespecifications thcapabilities. [s. N(4) The permittemaintenance reqNR 439.04(1)(a)

2.Sulfur Dioxide Emissions (SO2) 

(1) The emissions may not exceed 0.38 pound per hour. [s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] (2) The hours of operation may not exceed 500 hours in any 12 consecutive month period.[s. 285.65(7), Wis. Stats.] (3) The permittee shall: (a) Use 0.05% by weight sulfur diesel fuel oil, and (b) Comply with the emission limitation of condition I.B.2.a.(1).[s. 285.65(7), Wis. Stats.] 

(1) The facility shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2)The permittee shall determine SO2 hourly emissions using fuel 

consumption records, fuel sulfur content, and AP-42 provided emission factors. [s. 285.65(3), Wis. Stats.] (3) The permittee shall provide the following information to the 

Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the diesel engine generator; and (b) A list of items that will be checked and maintained and their frequency, to ensure that the diesel engine generator is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] (4) A representative sample shall be taken from each fuel lot of fuel oil received. The sample shall be analyzed by the permittee for the sulfur content by weight using procedures outline in s. NR 439.08(2), Wis. 

(1) Whenever codioxide is requiralternate method Department, shaAdm. Code] (2)The permittee which records thdemonstrate com[s. 285.65(3), WStats.] (3) The permittespecifications thdesign capabilitiAdm. Code] (4) The permittemaintenance reqNR 439.04(1)(a)(5)The permittee under condition 
15 

B. Process #P05, Stack # S05 - Diesel Engine Generator POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE 

MONITORI

Adm. Code, and the analysis shall be retained by the permittee for a period of at least five years.[s. 285.65(3), Wis. Stats.] (5)The Department will accept, in lieu of an analysis on each fuel lot 

under (4) above, an analysis of a representative sample of the fuel lot of distillate fuel oil from which the fuel lot was taken.[s. 285.65(3), Wis. Stats.] (6) The permittee shall retain copies of its distillate fuel oil supplier's 

fuel sulfur and heat content analyses at the facility for each fuel lot of distillate fuel oil received pursuant to 40 CFR 60.334 for a period of five years. [s. NR 439.04(2), Wis. Adm. Code; s. 285.65(3), Wis. Stats.] (7) The permittee shall further obtain certification from the fuel supplier that the applicable methods in s. NR 439.08(2), Wis. Adm. Code, were followed, if applicable, by that supplier in the preparation of said sulfur and heat content analyses. The fuel lot's quantity of distillate fuel oil shall be included with the copies of this analyses.[s. 285.65(3), Wis. Stats.] 

439.04(1)(d), W

3.Nitrogen Oxides Emissions (NOx) 

(1) The emissions may not exceed 27.36 pounds per hour. [s. 285.65(3), Wis . Stats; s. 285.65(7), Wis. Stats.; s. NR 428.04(2)(h), Wis. Adm. Code] (2) The hours of operation may not exceed 500 hours in any 12 consecutive month period.[s. 285.65(7), Wis. Stats.] (3) The permittee shall: (a) Use 0.05% by weight sulfur diesel fuel oil, and (b) Comply with the emission limitation of condition I.B.3.a.(1).[s. 285.65(7), Wis. Stats.] 

(1) The permittee shall determine NOx hourly emissions using operating parameters and certified emission test data as required by 40 CFR Part 89. [s. 285.65(3), Wis. Stats.] 

(2) The facility shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet hourly emission limit. [ss. 285.65(3) and 285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the diesel engine generator; (b) A list of items that will be checked and maintained and their frequency, to ensure that the diesel engine generator is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever cooxides is requireUSEPA Method approved in writused.[s. NR 439(2)The permittee which records thdemonstrate com285.65(3), Wis. (3) The permittespecifications thdesign capabilitiAdm. Code] (4) The permittemaintenance reqNR 439.04(1)(a)

4.Carbon Monoxide Emissions (CO) 

(1) The emissions may not exceed 18.85 pounds per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.] (2) The hours of operation may 

(1) The permittee shall determine CO hourly emissions using operating parameters and certified emission test data as required by 40 CFR Part 89. [s. 285.65(3), Wis. Stats.] (2) The facility shall fire 0.05% by weight sulfur diesel fuel oil. This condition is established to meet BACT emission limit. [ss. 285.65(3) 

(1) Whenever comonoxide is reqPart 89,USEPA approved in writused.[s. NR 439
16 

B. Process #P05, Stack # S05 - Diesel Engine Generator POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE 

MONITORI

not exceed 500 hours in any 12 consecutive month period.[s. 285.65(7), Wis. Stats.] (3) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) the use of 0.05% by weight sulfur diesel fuel oil, and (b) complying with the emission limitation of condition I.B.4.a.(1).[s. NR 405.08, Wis. Adm. Code] 

and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code]  (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the diesel engine generator; (b) a list of items that will be checked and maintained and their frequency, to ensure that the diesel engine generator is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit.[s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(2)The permittee which records thdemonstrate com285.65(3), Wis. (3) The permittespecifications thdesign capabilitiAdm. Code] (4) The permittemaintenance reqNR 439.04(1)(a)

5.Volatile Organic Compound Emissions (VOC) 

(1) The emissions may not exceed 2.15 pounds per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.] (2) The hours of operation may not exceed 500 hours in any 12 consecutive month period.[s. 285.65(7), Wis. Stats.] (3) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) The use of 0.05% by weight sulfur diesel fuel oil, and (b) Complying with the emission limitation of condition I.B.5.a.(1).[s. NR 405.08, Wis. Adm. Code] 

(1) The permittee shall determine VOC BACT hourly emissions using operating parameters and certified emission test data as required by 40 CFR Part 89. [s. 285.65(3), Wis. Stats.] (2) The facility shall fire 0.05% by weight sulfur diesel fuel oil. This condition is established to meet BACT emission limit. [ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the diesel engine generator; (b) A list of items that will be checked and maintained and their frequency, to ensure that the diesel engine generator is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit.[s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever corequired, test pro89,USEPA Methmethod approveshall be used.[s. (2) The permittewhich records thto demonstrate c285.65(3), Wis. (3) The permittespecifications thdesign capabilitiAdm. Code] (4) The permittemaintenance reqNR 439.04(1)(a)

6. Visible Emissions 

(1) 20% opacity [s. NR 431.05, Wis. Adm. Code]See Note 1.7

(1) The permittee shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet the BACT emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.] 

(1) Whenever coUSEPA Method 439.06(9)(a)1., W

7. Sulfuric acid emissions 

(1)The hours of operation may not exceed 500 hours in any 12 consecutive month period. [s. 

 (1) The facility shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet emission limit. [s. 285.65(3) and 285.65(10), Wis. Stats.] 

(1) Whenever cois required, USEmethod approved 

7 Note 1: Opacity limits in excess of 20% are allowed when equipment is being cleaned or a new fire started, but may not exceed 80% for 5 min
17 

B. Process #P05, Stack # S05 - Diesel Engine Generator POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE 

MONITORI

285.65(7), Wis. Stats.] (2) The emissions may not 

exceed 0.59 pound per hour. [s. 285.65(3),Wis. Stats., and s. 285.65(7), Wis. Stats.] 

(2) The permittee shall comply with permit conditions I.B.2.b.(3) - (7) for demonstrating compliance with the emission limits. [s. 285.65(3), Wis. Stats.] 

shall be used. [s. (2)The permittee records the montdemonstrate com[s. 285.65(3), WStats.] (3) The permitteconditions I.B.2.compliance with requirement for Blimit. [s. 285.65(

8. Hazardous air pollutants regulated under sec. 112 of the Clean Air Act 

(1)The permittee shall use (a) 0.05% by weight sulfur diesel fuel oil, and (b) Good operation practices. [s. 285.65(7), Wis. Stats.] (2) The hours of operation may not exceed 500 hours in any 12 consecutive month period. [s. 285.65(7), Wis. Stats.]  The hourly emission rate may not exceed 0.01pound per hour. [s. 285.65(7), Wis. Stats.]This condition is established to ensure the federal HAPs are not subject to case by case MACT requirements. 

(1) The facility shall fire 0.05% by weight or less sulfur diesel fuel oil. This condition is established to meet the emission limit. [s. 285.65(10), Wis. Stats.] (2) The permittee shall comply with permit condition I.B.5.b.(3) for demonstrating compliance with the emission limit. [s. 285.65(3), Wis. Stats.] 

(1) Whenever cois required, USEmethod approved shall be used. [s. (2)The permittee conditions I.B.5.compliance with requirements for 285.65(3), Wis. (3) The permittewhich records thto demonstrate cI.B.8.a.(2). [s. 28Wis. Stats.] 
18 

 C. Process #P19, Stack S19 – Natural Gas-Fired Auxiliary BoilerPOLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENC

MONITORI

1.Particulate Matter Emissions (PM/PM10) 

(1) (a)The emissions may not exceed 0.74 pound per hours.[s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.] (2) The permittee shall apply Best Available Control Technology (BACT).BACT shall be met by: (a) The use of natural gas as the sole fuel; (b) Good combustion practices; and (c) Complying with the emission limitation of condition I.C.1.a.(1). [s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats.] 

(1) The permittee shall determine PM/PM10 hourly emissions by: (a) 

Using fuel consumption records and emissions factor determined by stack testing; and(b) Performing a stack test within 240 days after initial operation of the process. This requirement for stack testing applies only to the initial stack testing. [s. 285.65(3), Wis. Stats.] (2) The facility shall fire natural gas only in this boiler. This condition is established to meet BACT emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever corequired, USEPA alternate method Department, shaAdm. Code] (2) The permittespecifications thcapabilities of thWis. Adm. Code(3) The permittemaintenance reqNR 439.04(1)(a)

2.Sulfur Dioxide Emissions (SO2) 

(1) (a)The emissions may not exceed 0.06 pound per hour.[s. 285.65(7), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2) The permittee shall: (a) Use natural gas as the sole fuel; and (b) Comply with the emission limitation of condition I.C.2.a.(1). [s. 285.65(3), Wis. Stats.; s. 285.65(7), Wis. Stats.] 

(1) The boiler shall fire natural gas only. This condition is established to meet hourly emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2) The permittee shall determine SO2 hourly emissions by using fuel 

consumption records and AP-42 emissions factor. [s. 285.65(3), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit:(a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and the frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever codioxide is requiran alternate methDepartment, shaAdm. Code] (2) The permittespecifications thdesign capabilitiAdm. Code] (3) The permittein condition I.C.Wis. Adm. Code

3.Nitrogen Oxides Emissions 

1. (a) The emissions may not exceed 13.7 pounds per hour. 

(1) The permittee shall determine NOx hourly emissions by using fuel 

consumption records and AP-42 emissions factor. [s. 285.65(3), Wis. 

(1)Whenever co

required, USEPA 
19 

 C. Process #P19, Stack S19 – Natural Gas-Fired Auxiliary BoilerPOLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENC

MONITORI

(NOx) (b) If the boiler is operated 

during any ozone season with a capacity factor greater than 20%, the permittee shall complete a combustion optimization to minimize nitrogen oxides emissions in accordance with s. NR 439.096. (c) An emission unit as described in (b) above which first operates with a capacity factor exceeding 20% in an ozone season shall complete a combustion optimization by December 31 of the calendar year following the ozone season. (d) The owner or operator of an nitrogen oxide units subject to a combustion optimization requirement shall operate the emissions unit in a manner consistent with the results of the combustion optimization. (e) The owner or operator of a source subject to nitrogen oxide emissions of optimization requirements shall perform monitoring sufficient to determine compliance with the requirements. The monitoring required shall be either continuous monitoring of nitrogen oxides emissions or periodic monitoring of parameters adequate to ascertain the quality of the combustion and shall conform to the source's approved combustion optimization plan pursuant to s. NR 439.096, Wis. Adm. Code. 

Stats.] (2) The facility shall monitor the amount and types of fuel fired in this boiler. This condition is established to meet the emission limit and meet New Source Performance Standards (NSPS) requirements. [s. NR 440.207, Wis. Adm. Code] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] (4) The facility shall fire natural gas in this boiler. This condition is established to meet the emission limit. [ss. 285.65(3), and 285.65(10), Wis. Stats.] 

method approveshall be used. (2) The permittespecifications thdesign capabilitiAdm. Code] (3) The permittemaintenance reqNR 439.04(1)(d(4)The permittee 

that shows comp(4). [s. 285.65(3
20 

 C. Process #P19, Stack S19 – Natural Gas-Fired Auxiliary BoilerPOLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENC

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[s. 285.65(3), Wis. Stats.; s. 285.65(7), Wis. Stats.; s. NR 428.04(2)(a)2., Wis. Adm. Code] 

4.Carbon Monoxide Emissions (CO) 

(1) (a) The emissions may not exceed 7.77 pounds per hour.[s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.] (2) The permittee shall apply Best Available Control Technology (BACT).BACT shall be met by: (a) The use of good combustion practices, and (b) The use of natural gas as the sole fuel; and (c) Complying with the emission limitation of condition I.C.4.a.(1) [s. 285.65(3), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] 

(1) The permittee shall determine CO hourly emissions by using fuel consumption records and AP-42 emissions factor. [s. 285.65(3), Wis. Stats.] (2)The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.] (3)The facility shall fire natural gas in this boiler. This condition is established to meet the BACT emission limit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] 

(1) Whenever comonoxide is reqalternate method Department, shaAdm. Code] (2) The permittespecifications thdesign capabilitiAdm. Code] (3) The permittemaintenance req[s. NR 439.04(1

5.Volatile Organic Compound Emissions (VOC) 

(1) (a) The emissions may not 

exceed 0.53 pound per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats.] (2) The permittee shall apply Best Available Control Technology (BACT). BACT shall be met by: (a) The use of natural gas as the sole fuel, (b) The use of good 

(1) The permittee shall determine VOC hourly emissions by using fuel consumption records and AP-42 emissions factor. [s. 285.65(3), Wis. Stats.] (2) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; and (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information 

(1) Whenever corequired, USEPA alternate method Department, shaAdm. Code] (2) The permittespecifications thdesign capabilitiAdm. Code] (3)The permittee 
21 

 C. Process #P19, Stack S19 – Natural Gas-Fired Auxiliary BoilerPOLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENC

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combustion practices, and (c) Complying with the emission limitation of condition I.C.5.a.(1).[s. NR 405.08, Wis. Adm. Code] 

will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] (3) The facility shall fire natural gas in this boiler. This condition is established to meet the BACT emission limit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] 

maintenance req[s. NR 439.04(1

6.Sulfuric Acid Emissions (H2SO4) 

(1) (a) The emissions may not 

exceed 0.09 pound per hour. [s. 285.65(7), Wis. Stats.] 

(1) The permittee shall determine H2SO4 hourly emissions by using fuel consumption records and AP-42 emissions factor. [s. 285.65(3), Wis. Stats.] (2) The facility shall fire natural gas only in this boiler. This condition is established to meet emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever corequired, USEPA method approveshall be used.[s. (2) The permittespecifications thcapabilities of thWis. Adm. Code(3) The permittemaintenance reqNR 439.04(1)(a)
22 

 C. Process #P19, Stack S19 – Natural Gas-Fired Auxiliary BoilerPOLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENC

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7.Hazardous air pollutants regulated under sec. 112 of the Clean Air Act 

(1)The permittee shall(a) use of natural gas and, (b)use of good combustion practices, and (c) limit the hourly emission rate to 0.01 pound per hour. This condition is established to ensure that the HAP are not subject to case by case MACT requirements. [s. 285.65(13), Wis. Stats.] See Note 18

(1)The permittee shall perform a stack test to demonstrate that the 

formaldehyde emissions are not exceeded. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.; and s. 285.65(13), Wis. Stats.] (2) The stack test shall be conducted within 240 days after the initial operation of the process. (a) Compliance test shall be conducted at 100% load operation .(b) If operation at 100% load is not feasible, the 

source shall operate at a capacity level, which is approved by the Department in writing.(c) If the compliance emission test cannot be conducted within 240 days after the initial operation, the permit holder 

may request in writing and the Department may approve, in writing an extension of time to conduct the test(s). [s. NR 439.07(1), Wis. Adm. Code] (3) The permittee shall determine the formaldehyde hourly emissions by using fuel consumption records and results from the most recent stack test. [s. 285.65(3), Wis. Stats.] (4) The facility shall fire only natural gas in the boiler. This condition is established to meet emission limits. (ss. 285.65(3), 285.65(13) and 285.65(10), Wis. Stats.] (5) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer’s OEM that outlines the procedures that should be followed to maintain the auxiliary boiler; (b) A list of items that will be checked and maintained and their frequency, to ensure that the auxiliary boiler is operating properly. This information will be used by the Department to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever coformaldehyde is or an alternate mDepartment, shaAdm. Code] (2) The permittespecifications thdesign capabilitispecifications ardesigned to burn 439.04(1)(d), W(3) The permittemaintenance reqNR 439.04(1)(a)285.65(3), Wis. 

8. Visible Emissions 

(1) 20% opacity.[s. NR 431.05, Wis. Adm. Code] See Note 1.9

(1) The facility shall fire natural gas as the sole fuel in this boiler. 

This condition is established to meet the visible emission limit. [ss. 285.65(3), and 285.65(10), Wis. Stats.] 

(1) Whenever coUSEPA Method 439.06(9)(a)1., W

8 Note 1: The permittee will meet the hourly emission limit by use of good combustion practices. The Department will use the stack testing 

accurate emission limit for formaldehyde when an operation permit is issued for the facility. 

9 Note 1: Opacity limits in excess of 20% are allowed when equipment is being cleaned or a new fire started, but may not exceed 80% for 5 m

may not be cleaned or fire started more than 3 times per day. 
23 

D. Process #P06, Stack #S06 - Gas Conditioning Heater POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHOD

RECORDKEEPING 

1.Particulate Matter Emissions (PM/PM10) 

(1) The emissions may not exceed 0.08 pound per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] (2) The permittee shall apply Best Available Control technology (BACT). BACT shall be met by: (a) The use of natural gas, and (b) Complying with the emission limitation of condition I.D.1.a.(1). [s. NR 405.08, Wis. Adm. Code] 

(1) The facility shall fire natural gas in this process. This condition is established to meet BACT emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2)The permittee shall use the design rate for fuel use and AP-42 emission factors or alternate data approved in writing by the Department to determine the PM/PM10 hourly emissions. [s. 285.65(3) and s. 

285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer's OEM that outlines the procedures that should be followed to maintain the gas conditioning heaters. (b) A list of items that will be checked and maintained and their frequency to ensure that the gas conditioning heaters is operating properly. This information will be used to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever compliance testing for 

Methods 5 and 202 or an alternate meDepartment shall be used.[s. NR 439(2) The permittee shall retain on site, indicate the process's fuel design capaWis. Adm. Code] (3) The permittee shall record informin condition I.D.1.b.(3). [s. NR 439.0

2.Sulfur Dioxide Emissions (SO2) 

(1) The emissions may not exceed 0.02 pound per hour. [s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats.] 

(1) The facility shall fire natural gas in the process. This condition is established to meet emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.] (2)The permittee shall use the design rate for fuel use and AP-42 emission factors or alternate data approved in writing by the Department to determine the SO2 hourly emissions. [s. 285.65(3) and s. 

285.65(10), Wis. Stats.] (3) The permittee shall follow the sampling protocol for natural gas as identified in permit condition I.A.2.b.(4). [s. 285.65(3), Wis. Stats.] (4) Sulfur content monitoring of the natural gas may be conducted by the permittee or natural gas supplier to satisfy permit condition I.D.2.b.(3). [s. 285.65(3), Wis. Stats.] 

(1) Whenever compliance testing fo

Method 6or 6Cor an alternate methoDepartment shall be used. [s. NR 43(2) The permittee shall retain on site

indicate the process's fuel design caWis. Adm. Code] (3) The records required under I.D.2

for a period of at least five years and Department upon request.[sec. NR 4Code] 

3.Nitrogen oxides (1) The emissions may not (1) The facility shall fire natural gas in the process. (1) Whenever compliance testing fo
24 

D. Process #P06, Stack #S06 - Gas Conditioning Heater POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHOD

RECORDKEEPING 

Emissions (NOx) exceed 0.36 pound per 

hour and 0.10 pound per million BTU . [s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.; s. NR 428.04(2)(f), Wis. Adm. Code] (2) The permittee shall:(a) 

Use natural gas, and (b) Comply with the emission limitation of condition I.D.3.a.(1). [s. 285.65(3), Wis. Stats.] 

This condition is established to meet emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.] (2) The permittee shall use the design rate for fuel 

use and AP-42 emission factors or alternate data approved in writing by the Department to determine the NOx hourly emissions. [s. 285.65(3) 

and s. 285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer's OEM that outlines the procedures that should be followed to maintain the gas conditioning heaters. (b) A list of items that will be checked and maintained and their frequency to ensure that the gas conditioning heaters is operating properly. This information will be used to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

Method 7 or 7E or an alternate methDepartment shall be used.[s. NR 43(2) The permittee shall retain on siteindicate the process's fuel design caWis. Adm. Code] (3) The permittee shall record informrequired in condition I.D.3.b.(3). [s. Code] 

4.Carbon Monoxide Emissions (CO) 

(1) The emissions may not exceed 0.47 pounds per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] (2) The permittee shall apply Best Available Control technology (BACT). BACT shall be met by: (a) The use of natural gas, and (b) Complying with the emission limitation of condition I.D.4.a.(1). [s. NR 405.08, Wis. Adm. Code] 

(1) The facility shall fire natural gas in the process. 

This condition is established to meet the BACT emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2) The permittee shall use the design fuel rate use and AP-42 emission factors or alternate data approved in writing by the Department to determine the CO hourly emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer's OEM that outlines the procedures that should be followed to maintain the gas conditioning heaters. (b) A list of items that will be checked and maintained and their frequency to ensure that the gas conditioning heaters is operating properly. 

(1) Whenever compliance testing fo

Method 10 or an alternate method aDepartment shall be used.[s. NR 43(2) The permittee shall retain on siteindicate the process's fuel design caWis. Adm. Code] (3) The permittee shall record informrequired in condition I.D.4.b.(3). [s. Code] 
25 

D. Process #P06, Stack #S06 - Gas Conditioning Heater POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHOD

RECORDKEEPING 

This information will be used to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

5.Volatile Organic Compounds Emissions (VOC) 

(1) The emissions may not exceed 0.06 pound per hour. [s. NR 405.08, Wis. Adm. Code; s. 285.65(7), Wis. Stats.; s. 285.65(3), Wis. Stats.] (2) The permittee shall 

apply Best Available Control technology (BACT). BACT shall be met by: (a) The use of natural gas and, (b) Complying with the emission limitation of condition I.D.5.a.(1 [s. NR 405.08, Wis. Adm. Code] 

(1) The facility shall fire natural gas in the process. 

This condition is established to meet the BACT emission limit. [ss. 285.65(3) and 285.65(10), Wis. Stats.; s. NR 405.08, Wis. Adm. Code] (2)The permittee shall use the design rate for fuel use and AP-42 emission factors or alternate data approved in writing by the Department to determine the VOC hourly emissions. [s. 285.65(3) and s. 285.65(10), Wis. Stats.] (3) The permittee shall provide the following information to the Department at least four months prior to the expiration of the construction permit: (a) A copy of the manufacturer's OEM that outlines the procedures that should be followed to maintain the gas conditioning heaters. (b) A list of items that will be checked and maintained and their frequency to ensure that the gas conditioning heaters is operating properly. This information will be used to establish appropriate permit conditions in the operation permit. [s. 285.65(3), Wis. Stats.; s. 285.65(10), Wis. Stats.] 

(1) Whenever compliance testing foMethod 25A or 18 or an alternate mDepartment shall be used.[s. NR 43(2) The permittee shall retain on siteindicate the process's fuel design caWis. Adm. Code] (3) The permittee shall record informrequired in condition I.D.5.b.(3). [s. Code] 

6. Visible Emissions (1) 20% opacity 

[s. NR 431.05, Wis. Adm. Code] See Note 1.10

(1) The permittee shall only fire natural gas in the process. This condition is established to meet the visible emission limit.[ss. 285.65(3) and 285.65(10), Wis. Stats.] 

(1) Whenever compliance testing is rbe used.[s. NR 439.06(9)(a)1., Wis. 

7. Hazardous air pollutants regulated under sec. 112 of the 

(1)The permittee shall: (a) Use natural gas, and (b) Good operating practices. 

(1)The facility shall fire natural gas in the process. This condition is established to meet the emission limit. [s. 285.65(3) and s. 285.65(10), Wis. Stats.] 

(1)Whenever compliance testing for fMethod 0011, or an alternate method Department, shall be used. [s. NR 439

10 Note 1: Opacity limits in excess of 20% are allowed when equipment is being cleaned or a new fire started, but may not exceed 80% for 5 m

may not be cleaned or fire started more than 3 times per day. 
26 

D. Process #P06, Stack #S06 - Gas Conditioning Heater POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHOD

RECORDKEEPING 

Clean Air Act [s. 285.65(3), Wis. Stats.] 

(2) The hourly emission rate may not exceed 0.01pound per hour for formaldehyde. This condition is established to ensure that the HAP are not subject to case by case MACT requirements. [s. 285.65(3), Wis. Stats.] 

(2) The permittee shall comply with permit condition I.D.5.b.(3) for demonstrating compliance with the emission limit. [s. 285.65(3), Wis. Stats.] 

(2)The permittee shall comply with pfor demonstrating compliance with threquirements for formaldehyde emissStats.] 
27 

E. Process # T01 -Fuel Oil Storage Tank POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHOD

RECORDKEEPING 

1.Volatile Organic Compounds (VOCs) 

(1) The permittee shall apply Best Available Control Technology (BACT) In order to meet BACT the storage tank shall have a fixed roof, and the storage tank shall have a submerged fill pipe. The permittee shall store only distillate fuel oil in the storage tank. [s. NR 405.08, Wis. Adm. Code; s. 285.65(3), Wis. Stats.] 

(1) The permittee shall keep the records of the following to comply with the BACT emission limitations: a) Type of fuel oil stored ; b) Vapor pressure of the fuel oil; c) Tank design specifications. [ ss. 285.65(3) and 285.65(10), Wis. Stats.] 

(1) The permittee shall keep records condition I.E.1.b.(1) for a period of information available to the DepartmWis. Stats.; s. 285.65(7), Wis. Stats.
28 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

1. Compliance Testing 

(1)Whenever stack testing is required: (a)The Department shall be informed at least 20 working days prior to any stack testing so a Department representative c

of notification, a compliance emission test plan shall also be submitted to the Department for approval. When approved bUSEPA-approved Method may be substituted for the recommended test method.[s. NR 439.07(2), Wis. Adm. Code] 

(b)Two copies of the report on the tests shall be submitted to the Department for evaluation within 60 days following the 

may grant extension of up to 30 days for test report submittal. [s. NR 439.07(9), Wis. Adm. Code] 

2. Construction Progression 

(1) The permittee shall inform the Wisconsin Department of Natural Resources, SER, Plymouth Service Center, 1155 PilPlymouth, WI 53073 in writing of the completion of specific stages of construction for the emissions unit covered in this a notice of the following: (a)Notice of commencing construction shall be submitted within 15 days of the start of construction. (b)Notice of intent to initially operate the source(s) covered by this permit, 30 days prior to the anticipated date of initial 

(c)Notice of the actual date of initial operation shall be submitted within 15 days of the initial operation. [s. NR 439.03(1), Wis. Adm. Code] 

3. Expiration of the Construction Permit 

(1)This construction permit expires (70 months from the original issuance date of December 2, 2002, or October 2, 2008) 

Construction or modification and an initial operation period for equipment shakedown, testing and Department evaluation 

with the permit conditions is authorized for each emissions unit covered in this permit. Please note that the sources cover

meet all emission limits and conditions contained in the permit at all times, including during the initial operation period. Nmay be provided beyond the 70 months construction period.[ss. 285.65(1)(a)2 and 285.66(1), Stats.] 

4.Completion of Operation Permit Application 

(1) The compliance information required to complete the Operation Permit for the emission units included in this permit Department at least 4 months prior to the expiration of the Construction Permit. Except as provided in s. 285.65(8), Wis. covered by this permit after this permit expires is prohibited until an operating permit for these sources has been issued backnowledges that the permittee timely submitted its application for an Operation Permit. [s. 285.60(1)(b)1., Wis. Stats.] 

5. Operation Requirements 

(1) The permittee shall prepare within 30 days after the end of each calendar quarter, a report that contains: (a) The date, starting and ending times that processes #s P11, P12, P21, p22 have been operated. If no operation occurs du

prepared stating so. (b) The combustion reference temperature each processes #s P11, P12, P21, P22 was operated at, based on the cumulativ(c)The date and starting and ending times of each period of excess emissions. (d) The date and starting and ending time of any period during which the monitoring system was out of service. The repoadjustments made to the system (where applicable). (e) The date and starting and ending time of any period during which the process being monitored was inoperative (where (f)If no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an filed stating such information (where applicable).  [s. 285.65(3), Wis. Stats.] (2) (a) The permittee shall keep records (manufacturer's information) to show that the dry low NOx combustors were inst

P11, P12, P21,P22 to meet emission limits for NOx.[s. 285.65(3), Wis. Stats.] 

6. (a) Monitoring of operations to satisfy new source performance standard 

(1)The combustion turbine Processes #s P11, P12, P21, P22 are subject to the requirements of 40 CFR Part 60, Subpart G

60.334(b)(2), the permittee may request custom fuel monitoring schedules. Fuel Sampling for nitrogen content will not bwill be the only fuel used in the turbines at this site. Additionally, NOx CEMS will be installed and operated in accordan

The source shall meet all of the following requirements: 
29 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

(NSPS) requirements for Processes #s P11, P12, P21, P22

(a)The permittee shall install and operate a continuous monitoring system to monitor and record the fuel consumption. T

within plus or minus 5.0% and must be approved by the Department. (b) The permittee shall monitor sulfur content of the fuel being fired in the turbine. Please see permit condition I.A.2.b.(2

analysis for sulfur content is required, the Gas Processor Association Standard 2377-1 “Test for Hydrogen Sulfide and Ca

Using Length of Stain Tubes,” or an alternate method approved in writing by the Department, shall be used. (c)For the purpose of reports required under s. NR 440.07(3), Wis. Adm. Code, ( a copy of the requirements is attached to excess emissions that shall be reported are defined as follows: i. Sulfur dioxide. Any period during which the sulfur content of the fuel being fired in the gas turbine exceeds 0.8 grains/

percent by weight), as determined by the custom fuel monitoring schedule in Condition I.A.2.(b)(2) -(4). [s. NR 440.50(5), Wis. Adm. Code, s. 285.65(3), Wis. Stats., s. 285.65(10), Wis. Stats.]

7.Test methods and procedures to satisfy new source performance standards (NSPS) requirements for Processes #s P11, P12, P21, P22. 

(1) The reference methods in 40 C.F.R. Part 60, Appendix A, incorporated by reference in s. NR 440.17, Wis. Adm. Cod

440.08(2), Wis. Adm. Code, shall be used to determine compliance with the standards prescribed in s. NR 440.50(3)combustion turbines Processes #s P11, P12, P21, P22 are subject to the requirements of 40 CFR Part 60, Subpart GGthe following requirements: 

For processes #s P11, P12, P21, P22: (a) The permittee shall use Reference Method 7 or 7E for the concentration of nitrogen oxides and oxygen. The span val

NOx.(b)The Nox emission level measured by Reference Method 20 shall be adjusted to ISO standard day conditions by the folcorrection factor.  Nox = Nox,obs (Pref / Pobs)0.5 e19(H-0.00633) (288oK/TAMB )1.53 

Where: Nox is the emissions rate of NOx at 15% oxygen and ISO standard ambient conditions, volume percent 

Nox,obs is the measured NOx concentration, ppmv 

Pref is the reference combustors inlet absolute pressure at 101.3 kilopascals ambient pressure, mmhg 

Pobs is the measured combustors inlet absolute pressure at test ambient pressure, mmHg H is the specific humidity of ambient air at test, g H2O/g air e is the transcendental constant (2.718) TAMB is the temperature of ambient air at test, K The adjusted NOx emission level shall be used to determine compliance with s. NR 440.50(3), Wis. Adm. Code

(c)Manufacturers may develop custom ambient condition correction factors for each gas turbine model they manufacture pressure, ambient air pressure, ambient air humidity and ambient air temperature to adjust the NOx emission level measu

provided for in s. NR 440.08, Wis. Adm. Code to ISO standard day conditions. These ambient condition correction factoand must be approved for use by the Department in writing before the initial performance test required by s. NR 440.08, W

(2)The auxiliary boiler (P19) is subject to the NSPS for Industrial-Commercial-Institutional Steam Generating Units 40 C

(a)The permittee shall monitor the fuel consumption. [s. NR 440.207, Wis. Adm. Code] (3)The duct burners(P11, P12, P21, and P22) are subject to the NSPS for Utility Steam Generating Units 40 C.F.R. 60, Su(a) NOx emissions from the duct burners shall be limited to 1.6 pounds per megawatt-hour (lb/MWh).The emission limit
30 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

limit. (b)PM/ PM10 emissions shall not exceed 0.03 lb/MMBtu. The BACT limits are more stringent than the NSPS limit. (c)SO2 emissions shall not exceed 0.2 lb/MMBtu. The emission limits are more stringent than the NSPS limit. 

(4)The method for determining compliance with s. NR 440.50(4), Wis. Adm. Code provided in s. NR 440.08(2), shall be 

(a)Reference Method 6 or 6C of 40 C.F.R. Part 60, Appendix A, incorporated by reference in s. NR 440.17, Wis. Adm. Csulfur dioxide and oxygen or 2.a. ASTM D2880-71 for the sulfur content of liquid fuels and ASTM D1072-80, D3031-81sulfur content of gaseous fuels (these methods are incorporated by reference in s. NR 440.17, Wis. Adm. Code).These mewith s. NR 440.50(5)(b), Wis. Adm. Code. (b)The applicable ranges of some ASTM methods mentioned in sub-par. (a) are not adequate to measure the levels of sulsamples prior to analysis (with verification of the dilution ratio) is allowable subject to the approval of the Department in (c)Whenever a natural gas analysis for sulfur content is required, the Gas Processor Association Standard 2377-1 “Test foDioxide in Natural Gas Using Length of Stain Tubes,” or an alternate method approved in writing by the Department, shaAdm. Code] 

8. Monitoring parameters for good combustion practices (good combustion practices was determined to be BACT) and recordkeeping requirements for demonstrating compliance with Best Available Control Technology for volatile organic compounds (VOC), particulate matter(PM), and carbon monoxide (CO) for Processes #s P11, P12, P21, P22 

(1)The permittee shall: (a) During the initial performance testing, perform monitoring of unit heat input according to 40 CFR Part 75, Appendix (b)During the initial performance testing, perform simultaneous monitoring of the following parameters for VOC and PMsubmit a stack test protocol for approval. i) For Natural gas: Compressor inlet temperature and turbine exhaust gas temperature, oF; Fuel flow rate (MMcf/hr); Cal

temperature, oF.  (c)During operation, the facility will continuously monitor and record the unit heat input and the operating parameters id

basis. Unit emissions will be calculated using the CEMS in accordance with 40 CFR Part 75 Appendix F. [s. 285.65(3), Wis. Stats.] (d)The permittee shall provide the initial performance testing information to the Department at least four months prior to 

permit. This information will be used by the Department to establish appropriate conditions in the operation permit.[s. 28

9. Control of fugitive dust during facility construction 

(1) The permittee shall not cause, allow, or permit any materials to be handled, transported, or stored without taking prec

matter from becoming airborne. The permittee shall not allow a structure, a parking lot, or a road to be used, constructedtaking such precautions. Such precautions shall include, but not be limited to: (s. NR 415.04, Wis. Adm. Code) 

(a) Use, where possible, of water or chemicals for control of dust in the construction operations. 

(b) Application of asphalt, oil, water, suitable chemicals, or plastic covering on dirt roads, material stockpiles, and other 

dust, provided such application does not create a hydrocarbon, odor, or water pollution problem. 
31 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

(c) Installation and use of hoods, fans, and air cleaning devices to enclose and vent the areas where dusty materials are h

(d) Covering or securing of materials likely to become airborne while being moved on public roads or railroads. (e) The paving or maintenance of roadways areas so as not to create air pollution. [s. NR 415.04, Wis. Adm. Code] 

 b. REPORTING, RECORDKEEPING AND MONITORING R10.Reporting (1)The facility shall submit periodic reports upon 

the issuance of the operation permit.[s. NR 407.09(1)(c)3., Wis. Adm. Code] 

(1) Submit to the Wisconsin Department of Natural Resources, SERPilgrim Road, P. O. Box 408, Plymouth, WI 53073 a report detailinand/or monitoring required to demonstrate compliance, as describepermit. This report shall be submitted by March 1, for the previous by September 1, for the previous January 1 through June, for each yeffect. The report contents shall be based on the requirements foun

permit.[s. NR 439.03(1)(b) and (2), Wis. Adm. Code] (2) Submit certification of compliance with state and federal air regDepartment of Natural Resources, SER, Plymouth Service Center, Plymouth, WI 53073 by March 1, for the period from January 1 to 

of each year the operation permit is in effect. The content of the suof Part II of this permit.[s. NR 439.03(1)(c), Wis. Adm. Code] (3) Submit quarterly excess emissions report to the Wisconsin DepSER, within 30 days of the end of each calendar quarter after the opThe report shall contain the following information: 1. the date and starting and ending times or duration of each period 2. the period of excess emissions that occur during control equipmemalfunctions, fuel problems, other known causes or for unknown c3. the cause of any malfunction and the measures taken to reduce ex4. the date and starting and ending times of any period during whicinoperative for any reason or causes, including monitor malfunction span checks. The report shall identify the repairs or adjustments m5. the date and starting and ending time of a period during which thinoperative; 6. when no period of excess emissions occurred during the quarter period of downtime, an excess report shall be filed during such info

11. Stack Parameters (1) The height of each stack shall be at least: 

(a) S11, S12, S21, S22 each 210 feet above ground level; (a) S05, 120 feet above ground level; (b) S19, 120 feet above ground level; (c) S06, 25 feet above ground level. [s. 285.65(3), 

Wis. Stats.] 

(2) The equivalent cross section diameter at the outlet of each stacks may be no more than: 

(1)The permittee shall keep and maintain technical drawings, bluep

physical stack parameters. [s. NR 439.04(1)(d), Wis. Adm. Code] 
32 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

(a) S11, S12, S21, S22 each 19.0 feet; (b) S05, 0.67 feet; (c) S19, 4.0 feet; (d) S06, 0.5 feet. [s. 285.65(3), Wis. Stats.] 

(3) The stacks may not be equipped with rainhats or other device which impede the upward flow of the exhaust gases. [s. 285.65(3), Wis. Stats.] 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. 

12.Recordkeeping requirements 

(1) All records required under this permit shall be maintained for a period of at least five years and the records shall be made available to the Department representative upon request.[s. 285.65(3), Wis. Stats., s. NR 439.04(2), Wis. Adm. Code] 
33 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

13. Acid rain requirements 

 (1) The permittee shall obtain and secure allowances equal to the actual annual SO2emissions.(Allowances are available through the Chicago Board of Trade and other sources) [40 CFR Parts 72 and 75, s. NR 409.06(3), Wis. Adm. Code] (2) The permittee shall have a Designated Representative (DR) in accordance with 40 CFR Part 72.The DR shall be responsible for submitting required permits, compliance plans and emission monitoring reports, allowance plans and compliance certifications; and will be the responsible official with regards to all matters under the acid rain program. [40 CFR Part 72 and 75, s. NR 409.07, Wis. Adm. Code] (3)The permittee shall install continuous emissions monitoring systems (CEMs) or alternative monitoring systems that meet the specification of 40 CFR Part 75. [40 CFR Part 75, s. NR 409.06(2), Wis. Adm. Code] 

(1)The permittee shall submit a Phase II acid rain permit to the Dep

the date on which the unit commences operation. [s. 285.65(3), WisAdm. Code] 

14. Turbine start up/shut down. (Processes #s P11, P12, P21, P22) 15.Initial operation period for processes #s P11, P12, P21, P22 16. Shut Down. 

(1) Start up is the period with the start of ignition and end when the combustion temperature reaches 2,280 degress F. [s. 285.65(3), Wis. Stats.] (2) Shut down is the period when the combustion temperature drops below 2,230 degrees F and end when the flame is out . [s. 285.65(3), Wis. Stats.] (1) The initial operation period for the processes P11, P12, P21, P22begins when the combustion turbines are first fire started. (1) The existing coal fired boilers, Units 1, 2, 3, 4 and 6 will be shut down and retired prior to the initial operation of the processes #s P11, P12, P21 and P22. [s. 285.65(3), Wis. Stats.] 

(1) The permittee shall keep operating records and tracking of all st

CEM.[s. 285.65(3), Wis. Stats.]  (2) The permittee shall keep and maintain records of the combustiStats.] (1)The permittee shall keep operating records as to when each of th

[s. 285.65(3), Wis. Stats.] (1)The permittee shall inform the Department is writing the dates wshut down and retired. [s. 285.65(3), Wis. Stats.]
34 

F. Conditions Specific to the Construction Permit CONDITION TYPE 

a. SPECIFIC CONDITIONS 

17.Reevaluating BACT 18. Acquisition of Emission Offsets 19. Supersede 

(1) The permittee shall submit information for reevaluating BACT to the Department at least 18 months prior to the construction of any permitted processes that have not begun construction within eighteen months from the date of the issuance of the permit. [s. 285.65(3), Wis. Stats.] (1) The permittee shall obtain Volatile Organic Compound offsets at a minimum ratio of 1.3 or a total of 101.53 credits. [s. NR 408.06(4)(d), Wis. Adm. Code] (2) The permittee will ensure that the actual transfer of credits has taken place prior to commencing operation of the power plant.[s. NR 408.06, Wis. Adm. Code]  (3) The permittee shall provide information on whether actual transfer of credits has occurred prior to commencing operation of the power plant to the DNR, Bureau of Air Management, 101 S. Webster Street, P.O. Box 7921, Madison, WI 53707. [s. 285,65(3), Wis. Stats., s. NR 408.06, Wis. Adm. Code] (1) This permit supersedes permit 01-RV-071. [s. 285.65(3), Wis. Stats.] 
 AIR POLLUTION CONTROL CONSTRUCTION PERMIT 

 

EI FACILITY NO. 246004000 PERMIT NOS. 04-RV-175 

STACK NO.(S). S05, S06, S19, S11, S12, S21, S22 

SOURCE NO.(S). P05, P06, P11, P12, P19, P21, P22, T01 

 THIS CONSTRUCTION PERMIT EXPIRES 70 MONTHS FROM THE ORIGINAL ISSUANCE DATE OF 

DECEMBER 2, 2002, OR OCTOBER 2, 2008. 

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

 Name of Source: Wisconsin Electric Power Company (WE) – Port Washington Generating Station. 

 Street Address: 146 South Wisconsin Street 

 Port Washington, Wisconsin 

 Responsible Official & Title: Steven R. Quade, Asset Manager – Peaking Power Facilities 

is authorized to construct and initially operate four combined cycle combustion turbines with duct burners and heat recovery steam generators 

(HRGS), emergency diesel engine, gas heater, auxiliary boiler and a storage tank described in the plans and specifications dated between July 

1, 2004 and October 8, 2004 conformity with the conditions herein. 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 this day of . 

STATE OF WISCONSIN 

DEPARTMENT OF NATURAL RESOURCES 

For the Secretary 

By ____________________________________________ 

 Lloyd L. Eagan, Director 

 Bureau of Air Management 

 
CERTIFIED MAIL

RETURN RECEIPT REQUESTED FILE CODE: 4530-1 

Steven R. Quade 

Asset Manager – Peaking Power Facilities 

WE Energies 

231 W. Michigan Street 

Milwaukee, WI 53203 

Dear Mr. Quade: 

Your application for an air pollution control construction permit has been processed in accordance with s. 285.61, 

Wis. Stats. 

The enclosed permit is issued to provide authorization for your source to construct and initially operate four 

combined cycle combustion turbines with duct burners and heat recovery steam generators (HRGS), emergency 

diesel engine, gas heater, auxiliary boiler and a storage tank at Wisconsin Electric Power Company - Port 

Washington Generating Station in accordance with the requirements and conditions set forth within Parts I and II of 

the permit. Please read it carefully. This construction permit expires 70 months from the original issuance date of 

December 2, 2002, or October 2, 2008. The source(s) covered in this permit may not operate after this permit 

expires unless a complete operating permit application for the source(s) has been submitted. Compliance 

information required to complete the operation permit application for the source(s) included in this construction 

permit should be submitted at least 4 months prior to the permit expiration date. 

Enclosed with the permit is a bill for the cost of reviewing and acting upon your air pollution control permit. This 

bill is due and payable within 30 days of the date of the issuance of the permit. The remittance should be made 

payable to Wisconsin Department of Natural Resources and returned to the address on the bill. Please return one 

copy of the bill with your payment. 

A copy of this permit should be available at the source for inspection by any authorized representative of the 

Department. Questions about this permit should be directed to Wisconsin Department of Natural Resources, SER, 

Plymouth Service Center, 1155 Pilgrim Road, P. O. Box 408, Plymouth, WI 53073. 

 

 NOTICE OF APPEAL RIGHTS 

If you believe that you have a right to challenge this decision, you should know that Wisconsin statutes establish 

time periods within which requests to review Department decisions must be filed. 

To request a contested case hearing pursuant to s. 285.81, Wis. Stats., you have 30 days after the decision is 

mailed, or otherwise served by the Department, to serve a petition for a contested case hearing on the Secretary of 

the Department of Natural Resources. Any such petition for hearing shall set forth specifically the issue sought to 

be reviewed, the interest of the petitioner, the reasons why a hearing is warranted and the relief desired. 

For judicial review of a decision pursuant to ss. 227.52 and 227.53, Wis. Stats., you have 30 days after the decision 

is mailed, or otherwise served by the Department, to file your petition with the appropriate circuit court and serve 

the petition on the Department. Such a petition for judicial review shall name the Department of Natural 

Resources as the respondent. 

This notice is provided pursuant to s. 227.48(2), Wis. Stats. 

STATE OF WISCONSIN 

DEPARTMENT OF NATURAL RESOURCES 
Raj Vakharia, Review Engineer 

Permits & Stationary Source Modeling Section 

Bureau of Air Management 

cc: Air Enforcement Branch - EPA, Region V 

South East Region, Plymouth Service Center, Air Program 

Enclosure 
BEFORE THE DEPARTMENT OF NATURAL RESOURCES 

 AIR MANAGEMENT PROGRAM 

 FINDINGS OF FACT 

 CONCLUSIONS OF LAW 

 AND DECISION

Findings of Fact

The Department of Natural Resources (DNR) finds that: 

1) Wisconsin Electric Power Company (WE) – Port Washington Generating Station., 146 South Wisconsin 

 Street, Port Washington, Wisconsin, has applied for an air pollution control construction permit. The 

 Authorized representative of the facility is Steven R. Quade, Asset Manager – Peaking Power Facilities. 

2) Wisconsin Electric Power Company (WE) – Port Washington Generating Station, submitted an air 

pollution control permit application and plans and specifications and any additional information 

describing the air pollution source between July 1, 2004 and October 8, 2004. 

3) DNR has reviewed Wisconsin Electric Power Company (WE) – Port Washington Generating Station’s 

air permit application, plans, specifications and other information available to DNR. 

4) DNR has prepared an analysis and a Preliminary Determination on the approvability of the permit 

application. 

5) This permit is for the construction of an air pollution source. 

6) DNR has complied with the procedures set forth in s. 285.61, Wis. Stats. 

8) The proposed air pollution source meets all of the applicable criteria in s. 285.63, Wis. Stats. 

8) DNR has complied with the requirements of s. 1.11, Wis. Stats., and ch. NR 150, Wis. Adm. Code. 

Conclusions of Law

DNR concludes that: 

1) DNR has authority under s. 285.11(1), Wis. Stats., to promulgate rules contained in chs. NR 400-

499, Wis. Adm. Code, including but not limited to rules containing emission limits, compliance 

schedules and compliance determination methods. 

2) DNR has the authority under ss. 285.11(1), (5), and (6), 285.27 (1) and (2) and 285.65, Wis. Stats., 

and chs. NR 400-499, Wis. Adm. Code, to establish emission limits for sources of air pollution. 

3) DNR has the authority to issue air pollution control permits and to include conditions in such permits 

under ss. 285.60, 285.61, 285.63 and 285.65, Wis. Stats. 
4) The emission limits included in this permit are authorized by ss. 285.65, Wis. Stats., and chs. 

NR 400-499, Wis. Adm. Code. 

5) DNR is required to comply with s. 1.11, Wis. Stats., and ch. NR 150, Wis. Adm. Code, in 

conjunction with issuing an air pollution control permit. 

Decision

Wisconsin Electric Power Company (WE) – Port Washington Generating Station, is authorized to construct 

and initially operate four combined cycle combustion turbines with duct burners and heat recovery steam 

generators (HRGS), emergency diesel engine, gas heater, auxiliary boiler and a storage tank described in the 

plans and specifications dated between July 1, 2004 and October 8, 2004 in conformity with the emission 

limits, monitoring, recordkeeping and reporting requirements and specific and general conditions set forth 

in this permit. 
Date: October 10, 2004 File Code: 4560 

 FID# 

246004000 

To: Lloyd Eagan – AM/7 

From: Raj Vakharia – AM/7 

Subject: Wisconsin Electric Power Company (WE) – Port Washington Generating Station. 

 Modify existing permit 01-RV-071. 

Wisconsin Electric Power Company – Port Washington Generating Station has submitted to the Department 

of Natural Resources air permit application for permit revision. 

The proposed revisions in this application include changes to express the startup and shutdown limits for the 

combustion turbines in terms of emissions per event rather than in terms of average hourly emissions. Other 

changes include updates to the diesel generator NOx and PM emissions limits to reflect the engine 

manufacturer’s actual expected emission rates. The proposed changes in this application would result in a 

decrease in potential emissions of carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), 

sulfuric acid mist (H2SO4) and formaldehyde (CH2O), The proposed changes will also result in an increase 

in VOC emissions. The total potential VOC emissions for this project will continue to be less than 100 tons 

per year. 

This permit application was reviewed under the Prevention of Significant Deterioration (PSD) rule set forth 

in ch. NR 405, Wis. Adm. Code, and under the non-attainment New Source Review rule set forth in ch. NR 

408, Wis. Adm. Code. The air pollutants that were covered by the PSD permit review included Particulate 

Matter Emissions (PM/PM10) and Carbon Monoxide (CO). Volatile Organic Compounds (VOC) are subject 

to non-attainment New Source Review. 

The Bureau of Air Management of the DNR has analyzed these materials and has preliminarily determined 

that the project should meet applicable criteria for permit approval as stated in sec. 285.63, Wis. Stats., 

including both the emission limits and the ambient air standards and that the applications are approvable. 

This proposed PSD source will consume increment. The Table below lists, by pollutant, the amount of 

increment consumed by the proposed source when all the sources identified in the proposed project are 

constructed. 

 Increment Analysis Results 

(All Concentrations in μg/m3

) 

PM10 - 24hr PM10 -Annual NOx - Annual 

New Sources Impact 21.9 1.44 5.05 

PSD Class II Increment 30.0 17.0 25.0 

% Increment Consumed 73.0 8.5 21.1 
 

The DNR received a request from Wisconsin Energy Corporation - Port Washington Generating Station to 

hold a public hearing to receive public comments on this air pollution control permit application. 

The public notice was posted in the Ozaukee Press on September 2, 2004. 

The public hearing was held: 

 

 Friday, October 8, 2004 at 1:00 pm 

 Ozaukee County Administration Center 

 Auditorium 

 121 W. Main Street 

 Port Washington, WI 

The only person who appeared at the hearing was Mr. Terry Coughlin, Manager, Air Management Program, 

WE Energy. WE Energy had also provided written comments on September 30, 2004. A copy of their 

comments included as part of the attachment 1. Tom Steidl and I talked with Mr. Coughlin at the hearing and 

indicated to him that the DNR will require WE Energy to test at least two combustion turbines instead of 

four. We Energy also provided language for testing natural gas as allowed under 40 CFR Part 75. I found 

this language acceptable as a result of which this language will be incorporated in the final permit. 

The DNR also received comments from US EPA on September 30, 2004. The Department’s response to the 

comments is included as part of the Attachment 2. 

In the preliminary determination the Department concluded that the project will meet applicable criteria for 

permit approval as stated in sec. 285.63, Wis. Stats., including both emission the emission limits and the 

ambient air standards and that the applications are approvable. 

After reviewing the comments from WE Energy and US EPA, Region V, my conclusion is that the project 

still meets the applicable criteria for permit approval as stated in sec. 285.63, Wis. Stats., including both the 

emission limits and the ambient air standards. I recommend to approve the final permit. 

Cc: Ron Dillahaunt, SER Plymouth Service Center 

 Susan Siepkowski, US EPA Region V 

 
 Attachment 1 
 Attachment 2 

 
 

Comment #1: In the Pd data tables 3, 4, 5, and 6 seem to be missing. Could you 

Please make sure that the tables are placed into the Pd? We also would 

like to see them, can you please forward us a copy when you get them 

together? 

Response: Copies of these tables were sent to US EPA on September 30th. Also a copy of these tables 

also attached with the response summary. 

Comment #2. On page 27 of the Pd, it states that there will be a net increase of 

total emissions by 78.1 TPY. This does not seem to add up to the 

Increase of total emissions presented in table 1. The only increase 

that exists is, emissions of VOC by 5.4 TPY. Could you please clarify? 

Response: Table 1 of the PD presents air pollutant emission changes for the Port Washington Generating 

Station based on the proposed revisions in this application. All emissions are in tons per year. 

 Table 1 

Pollutant Current Potential to 

Emit 

Revised Permit 

Potential to Emit 

Change Increases 

(Decreases) 

Carbon Monoxide CO 949.8 37.0 (12.8) 

Nitrogen Oxides NOx 990.7 764.7 (125.0) 

Particulate Matter PM 581.0 581.9 0.0 

Particulate Matter PM10 581.9 581.9 0.0 

Sulfur Dioxide SO2 25.6 23.7 (1.9) 

Organic 

Compounds 

VOC 92.3 97.7 5.4 

Ammonia NH3 527.4 527.4 0.0 

Sulfuric Acid Mist H2SO4 39.3 36.4 (2.9) 

Currently the facility has an permit 01-RV-071 which limits the VOC emissions to 92.3 tons per year. 

The revised permit limits VOC emissions to 97.7 tons per year. 

The net emissions from this project is 97.7 tons per year. The past-actual emissions are 19.6 tons. 

Therefore the net emission increase of VOC from this project will be 78.1 tons per year. That is what’s 

reflected on page 27 of the PD. The tables 1, 2, and 3 support these calculations. This increase in 

emissions must be offset by a ratio of 1.3 to 1. Thus, the amount of emission reductions necessary to 

offset this project is {(1.3) x (78.1)} 101.5 tons. 

Comment #3. We understand that this area is classified as "severe" 

non-attainment for ozone. Is the storage tank that is being installed 

subject to LAER or BACT? Since there is going to be a major increase 

of VOC emissions from the facility, wouldn't the storage tank be subject 

to LAER? 

Response: PWGS is located in an area classified as "severe" non-attainment for ozone. A source that has 

a potential to emit 25 tons of VOC per year is considered a major source ozone non-attainment area. The 

PWGS modifications, with estimated net emissions increase of tons per year are subject to major nonattainment new source review. PWGS, with a net emissions increase of between 25 and 100 tons per year 

of VOC, must apply BACT for VOC emissions. BACT is determined in the same manner as for PSD 

review. Because PWGS's potential to emit is less than 100 tons per year, s. NR 408.03(6), Wis. Adm. 
 

Code allow the facility to apply BACT as long PWGS is willing to offset the increase in emissions at a 

ratio of at least 1.3 to 1. 

The net emissions from this project is 97.7 tons per year. The past-actual emissions are 19.6 tons. 

Therefore the net emission increase of VOC from this project will be 78.1 tons per year. This increase in 

emissions must be offset by a ratio of 1.3 to 1. Thus, the amount of emission reductions necessary to 

offset this project is {(1.3) x (78.1)} 101.5 tons. 

Comment #4. The permit does not contain an emission rate for VOC emissions from 

the storage tank. What is the proposed emission rate and why isn't it 

in the permit as part of the emission limitations? 

Response: A new 2,000 gallons fuel oil storage tank will be constructed for the emergency diesel generator. 

The tank will be located inside the diesel generator building adjacent to and east of the new facility. The 

total VOC emissions are estimated at 0.00008 tons per year (or 0.160 lbs/yr or 0.0000183 lb/hr) based on 

U.S. EPA Tank 4.0 Program Version 4.09b. This information obtained from the preliminary determination 

document. 

The reason the department did not establish an hourly emission rate because the VOC emissions will be 

considered indoor fugitive emissions and also even if these emissions were vented through a stack because 

of the low emission rates it is doubtful that the stack emissions could be verified by a stack test. The permit 

did establish BACT as follows: In order to meet BACT the storage tank shall have a fixed roof, and the storage 

tank shall have a submerged fill pipe. The permittee shall store only distillate fuel oil in the storage tank

Comment #5: The NOx emission limits for the diesel generator are changed in this 

permit from 15.21 lbs/hr to 27.36 lbs/hr. In the permit, the emission 

rate for NOx is indeed 27.36 lbs/hr, but in the pd on page 31, it states 

that, "The emissions from the diesel generator will be limited to 15.21 

pounds per hour...". If this is a mistake, would you please correct the 

pd so that it corresponds with the permit? Will the 27.36 lbs/hr limit 

still meet the NSPS limit? 

Response: Yes this is a typographical mistake. There are no NSPS requirements for internal combustion 

engines applicable to the emergency diesel generator. This is also indicated in the rule applicability 

section of the preliminary determination document. 

Comment #6: There is a printing error on page 2 of the permit. Under table 1 

for CO, the "Revised Permit Potential to Emit" should probably read 

937.0 instead of 37.0. 

Response: Yes there is a typographical error on Table for CO. The Table 1 should read 937 instead of 

37.0.