Attachment 1: Permit No. 03700015-004 issued to Inver Hills (SIP3 relevant) and related technical support document 

Permit No. 03700015-004 was issued to Northern States Power Company’s Xcel Energy – Inver Hills Generating Plant on 

Jul 16, 2014. The permit and technical support document can also be found online: 

http://www.pca.state.mn.us/index.php/view-document.html?gid=21400. 




TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-1 07/16/14

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of

the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you

must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to

do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total

facility requirements.

Subject Item: Total Facility

What to do Why to do it

SOURCE SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table

of Contents. The Permittee shall comply with all requirements contained in the

appendices.

Minn. R. 7007.0800, subp. 2

Parameters Used in Modeling: The stack heights, emission rates, and other

parameters used in the modeling for the SO2 SIP are listed in Appendix C of this

permit. The Permittee must submit to the Commissioner for approval any revisions

of these parameters and must wait for a written approval before making such

changes. The information submitted must include, at a minimum, the locations,

heights and diameters of the stacks, locations and dimensions of nearby buildings,

the velocity and temperatures of the gases emitted, and the emission rates. The

plume dispersion charateristics due to the revisions of the information must be

equivalent to or better than the dispersion characteristics modeled in the SO2 SIP

submittal. The Permittee shall demonstrate this equivalency in the proposal. If the

information does not demonstrate equivalent or better dispersion characteristics, or

if a conclusion cannot readily be made about the dispersion, the Permittee must

remodel.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7009.0020

State Implementation Plan Recordkeeping: Retain all records at the stationary

source for a period of five (5) years from the date of the required monitoring,

sample, measurement, or report that corresponds with the "Title I Condition: SIP

for SO2 NAAQS" requirement.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Quarterly Report for the State Implementation Plan for Sulfur Dioxide:

Not more than 30 days after the end of each calendar quarter starting 07/28/1992,

the Permittee shall submit a report containing the following information:

1) The percent sulfur content by weight and the heating value of the fuel oil in

million British Thermal Units per gallon; and

2) A summary of any exceedances of the emission limitation, monthly fuel use

limitation and the sulfur content limitation during the calendar quarter. The report

shall provide an explanation of each exceedance which occurred or a statement

stating that no exceedances occurred. The report shall also state if fuel oil was

burned during the monitored quarter.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS"

shall be reported semi-annually with the Semi-annual Deviations Report required

by this permit. Reporting shall occur even if there were no deviations for this

reporting period.

Minn. R. 7007.0800, subp. 6(C)1; Alternative to SIP

Quarterly Report.

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR hdr

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR

Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the

actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test

at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may

result in a significant emissions increase (SEI). If the ATPA test is not used for the

project, or if there is no RP that the proposed project could result in a SEI, these

requirements do not apply to that project. The Permittee is only subject to the

Preconstruction Documentation requirement for a project where a RP occurs only

within the meaning of Section 52.21(r)(6)(vi)(b).

Even though a particular modification is not subject to New Source Review (NSR),

or where there isn't a RP that a proposed project could result in a SEI, a permit

amendment, recordkeeping, or notification may still be required by Minn. R.

7007.1150 - 7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.

7007.3000; Minn. R. 7007.0800, subp. 2
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-2 07/16/14

Preconstruction Documentation -- Before beginning actual construction on a

project, the Permittee shall document the following:

1. Project description

2. Identification of any emission unit (EU) whose emissions of an NSR pollutant

could be affected

3. Pre-change potential emissions of any affected existing EU, and the projected

post-change potential emissions of any affected existing or new EU.

4. A description of the applicability test used to determine that the project is not a

major modification for any regulated NSR pollutant, including the baseline actual

emissions, the projected actual emissions, the amount of emissions excluded due

to increases not associated with the modification and that the EU could have

accommodated during the baseline period, an explanation of why the amounts

were excluded, and any creditable contemporaneous increases and decreases that

were considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.

7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R.

7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant

that could increase as a result of the project and that were analyzed using the

ATPA test, and the potential emissions of any regulated NSR pollutant that could

increase as a result of the project and that were analyzed using potential

emissions in the hybrid test. The Permittee shall calculate and maintain a record of

the sum of the actual and potential (if the hybrid test was used in the analysis)

emissions of the regulated pollutant, in tons per year on a calendar year basis, for

a period of 5 years following resumption of regular operations after the change, or

for a period of 10 years following resumption of regular operations after the change

if the project increases the design capacity of or potential to emit of any unit

associated with the project.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.

7007.3000; Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual,

plus potential if used in hybrid test) emissions differ from the preconstruction

projection and exceed the baseline actual emissions by a significant amount as

listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the

Agency within 60 days after the end of the year in which the exceedances occur.

The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of

the facility contact person

b. The annual emissions (actual, plus potential if any part of the project was

analyzed using the hybrid test) for each pollutant for which the preconstruction

projection and significant emissions increase are exceeded.

c. Any other information, such as an explanation as to why the summed emissions

differ from the preconstruction projection.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.

7007.3000; Minn. R. 7007.0800, subps. 4 & 5

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient Air

Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality

Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated

upon written request by the MPCA.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R.

7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4; Minn. R.

7009.0010-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutes

emissions, which would otherwise violate a federal or state air pollution control

rule, without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment whenever

the corresponding process equipment and emission units are operated.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,

subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and

maintenance plan for all air pollution control equipment. At a minimum, the O & M

plan shall identify all air pollution control equipment and control practices and shall

include a preventative maintenance program for the equipment and practices, a

description of (the minimum but not necessarily the only) corrective actions to be

taken to restore the equipment and practices to proper operation to meet

applicable permit conditions, a description of the employee training program for

proper operation and maintenance of the control equipment and practices, and the

records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall

immediately take all practical steps to modify operations to reduce the emission of

any regulated air pollutant. The Commissioner may require feasible and practical

modifications in the operation to reduce emissions of air pollutants. No emissions

units that have an unreasonable shutdown or breakdown frequency of process or

control equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-3 07/16/14

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or

storage of any material in a manner which may allow avoidable amounts of

particulate matter to become airborne. Comply with all other requirements listed in

Minn. R. 7011.0150.

Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.

7030.0010 to 7030.0080 at all times during the operation of any emission units.

This is a state only requirement and is not enforceable by the EPA Administrator or

citizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures and

requirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.

7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.

ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table

B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance

Test

Performance Test Plan: due 30 days before each Performance Test

Performance Test Pre-test Meeting: due 7 days before each Performance Test

Performance Test Report: due 45 days after each Performance Test

Performance Test Report - Microfiche Copy: due 105 days after each

Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative

format as allowed by Minn. R. 7017.2018.

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4,

Minn. R. 7017.2035, subps. 1-2

Limits set as a result of a performance test (conducted before or after permit

issuance) apply until superseded as stated in the MPCA's Notice of Compliance

letter granting preliminary approval. Preliminary approval is based on formal review

of a subsequent performance test on the same unit as specified by Minn. R.

7017.2025, subp. 3. The limit is final upon issuance of a permit amendment

incorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration - The Permitee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or

2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including

the date conducted, and any corrective action that resulted. The Permitee shall

include the calibration frequencies, procedures, and manufacturer's specifications

(if applicable) in the Operations and Maintenance Plan. Any requirements applying

to continuous emission monitors are listed separately in this permit.

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or

C, monitoring a process or control equipment connected to that process is not

necessary during periods when the process is shutdown, or during checks of the

monitoring systems, such as calibration checks and zero and span adjustments. If

monitoring records are required, they should reflect any such periods of process

shutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwise

specified within this permit, for a period of five (5) years from the date of

monitoring, sample, measurement, or report. Records which must be retained at

this location include all calibration and maintenance records, all original recordings

for continuous monitoring instrumentation, and copies of all reports required by the

permit. Records must conform to the requirements listed in Minn. R. 7007.0800,

subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (as

required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms

(as required by Minn. R. 7007.1350, subp. 2), including records of the emissions

resulting from those changes.

Minn. R. 7007.0800, subp. 5(B)
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-4 07/16/14

If the Permittee determines that no permit amendment or notification is required

prior to making a change, the Permittee must retain records of all calculations

required under Minn. R. 7007.1200. For expiring permits, these records shall be

kept for a period of five years from the date the change was made or until permit

reissuance, whichever is longer. The records shall be kept at the stationary source

for the current calendar year of operation and may be kept at the stationary source

or office of the stationary source for all other years. The records may be

maintained in either electronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a

planned shutdown of any control equipment or process equipment if the shutdown

would cause any increase in the emissions of any regulated air pollutant. If the

owner or operator does not have advance knowledge of the shutdown, notification

shall be made to the Commissioner as soon as possible after the shutdown.

However, notification is not required in the circumstances outlined in Items A, B

and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of

the cause of the shutdown and the estimated duration. The owner or operator shall

notify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown

of more than one hour duration of any control equipment or process equipment if

the breakdown causes any increase in the emissions of any regulated air pollutant.

The 24-hour time period starts when the breakdown was discovered or reasonably

should have been discovered by the owner or operator. However, notification is not

required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,

subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated

duration. The owner or operator shall notify the Commissioner when the

breakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soon

as possible after discovery, notify the Commissioner or the state duty officer, either

orally or by facsimile, of any deviation from permit conditions which could

endanger human health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:

Within 2 working days of discovery, notify the Commissioner in writing of any

deviation from permit conditions which could endanger human health or the

environment. Include the following information in this written description:

1. the cause of the deviation;

2. the exact dates of the period of the deviation, if the deviation has been

corrected;

3. whether or not the deviation has been corrected;

4. the anticipated time by which the deviation is expected to be corrected, if not

yet corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

Minn. R. 7007.1150 - 7007.1500

Application for Permit Reissuance: due 180 days before expiration of existing

permit.

Minn. R. 7007.0400, subp. 2

Extension Requests: The Permittee may apply for an Administrative Amendment

to extend a deadline in a permit by no more than 120 days, provided the proposed

deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and

pt. 63 are examples of deadlines for which the MPCA does not have authority to

grant extensions and therefore do not meet the requirements of Minn. R.

7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: Due on or before April 1 of each calendar year

following permit issuance, to be submitted on a form approved by the

Commissioner.

Minn. R. 7019.3000 - 7019.3100

Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-5 07/16/14

Subject Item: GP 001 Electric Generating Combustion Turbines

Associated Items: EU 001 Combustion Turbine 1

EU 002 Combustion Turbine 2

EU 003 Combustion Turbine 3

EU 004 Combustion Turbine 4

EU 005 Combustion Turbine 5

EU 006 Combustion Turbine 6

What to do Why to do it

The requirements of this group apply individually to each associated item in this

group unless specified.

hdr

EMISSION AND OPERATIONAL REQUIREMENTS hdr

Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 2; Minn. R. 7011.2300, subp. 2

Sulfur Content of Fuel: less than or equal to 0.48 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS LIMIT WILL BE TERMINATED ON THE DATE THE USEPA APPROVES

THE REVISION TO THE SIP.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 2

Sulfur Content of Fuel: less than or equal to 0.005 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 2

Allowable Fuel Types: Distillate fuel oil and natural gas. Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 2

Total Combined Distillate Fuel Usage: less than or equal to 9.41 million

gallons/month using 12-month Rolling Average

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

MONITORING REQUIREMENTS hdr

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-6 07/16/14

Fuel Oil Analysis (cont.)

 3) If the fuel delivery sample analysis result is no greater than 0.48% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.10% by weight. The sulfur

content will be assured by:

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.48 percent

by weight; and by

 2) Sampling and analyzing the fuel in accordance with the following:

 a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 c) If any delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-7 07/16/14

Fuel Oil Analysis (cont.)

 3) If the fuel delivery sample analysis result is no greater than 0.005% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.005% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.0015% by weight. The sulfur

content will be assured by:

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.0015

percent by weight; and by

 2) Sampling and analyzing the fuel in accordance with the following:

 a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 c) If any delivery sample analysis result is greater than 0.0015% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP

RECORDKEEPING hdr

Fuel Supplier Certification or Guarantee: Keep on site a copy of the fuel supplier

certification or guarantee identifying the type of fuel oil and the percent by weight

sulfur content range.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 4(B)

Daily Recordkeeping: On each day of operation, the Permittee shall record the

total quantity of all fuel used at the facility. This shall be based on flowmeters.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 4(B)

Fuel Usage Recordkeeping: By the 15th day of each month, the Permittee shall

use daily fuel usage records to calculate the monthly fuel usage on a 12-month

rolling average basis.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 4(B)

SO2, and Emissions and Operating Records.

The Permittee shall generate and maintain records containing information to

demonstrate compliance with the emission limitation and operating requirements.

The Permittee shall retain records containing the following information:

 1) The results of the fuel oil analyses for sulfur content (percent by weight) and

heating value (million British Thermal Units per gallon), the date the fuel oil was

sampled, and the methods used to sample the fuel oil and determine the sulfur

content and heating value of the fuel oil.

 2) Monthly and 12-month rolling average fuel oil use. The records shall be

signed by the person entering information into the record.

Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50;

40 CFR pt. 52, subp. Y, MN SIP; Minn. R. 7007.0800,

subp. 5

The Permittee shall install, calibrate, maintain and operate flowmeters for all fuel

used at the facility.

Minn. R. 7007.0800, subp. 4 and 5
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-8 07/16/14

Subject Item: GP 002 Emergency Diesel Generators

Associated Items: EU 007 Diesel Generator 1 ODG-GEN-001

EU 008 Diesel Generator 2 ODG-GEN-002

What to do Why to do it

The requirements of this group apply individually to each associated item in this

group, unless specified.

hdr

EMERGENCY RICE DEFINITION hdr

The Permittee shall operate EU 007 and EU 008 according to the requirements in

paragraphs 40 CFR Section 63.6640 (f)(1) through (3). Any operation other than

emergency operation, maintenance and testing, emergency demand response,

and operation in non-emergency situations for 50 hours per year, as described in

40 CFR Section 63.6640(f)(1) through (3), is prohibited. If the engine is not

operated according to the requirements in 40 CFR Section 63.6640(f)(1) through

(3), the engine will not be considered an emergency engine under this subpart and

will need to meet all requirements for non-emergency engines.

(continued below)

40 CFR Section 63.6640(f); Minn. R. 7011.8150

(1) There is no time limit on the use of emergency stationary RICE in emergency

situations.

(2) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) counts as

part of the 100 hours per calendar year allowed by this paragraph (f)(2).

40 CFR Section 63.6640(f)(1) - (2); Minn. R.

7011.8150

2(i) The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indicating that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per

calendar year.

40 CFR Section 63.6640(f)(2)(i); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14),

or other authorized entity as determined by the Reliability Coordinator, has

declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability

Standard EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

40 CFR Section 63.6640(f)(2)(ii) - (2)(iii); Minn. R.

7011.8150

(3) Emergency stationary RICE located at major sources of HAP may be operated

for up to 50 hours per calendar year in non-emergency situations. The 50 hours of

operation in non-emergency situations are counted as part of the 100 hours per

calendar year for maintenance and testing and emergency demand response

provided in 40 CFR Section 63.6640(f)(2) above. The 50 hours per year for

non-emergency situations cannot be used for peak shaving or non-emergency

demand response, or to generate income for a facility to supply power to an

electric grid or otherwise supply power as part of a financial arrangement with

another entity.

40 CFR Section 63.6640(f)(3); Minn. R. 7011.8150

EMISSION AND OPERATING LIMITS hdr

Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the unit is 0.05 lb/MMBtu due to equipment design and allowable

fuels.

Minn. R. 7011.2300, subp. 2

Fuel Type: Distillate oil only, by design. 40 CFR Section 72.7(a)(2); Minn. R. 7007.1075; Minn.

R. 7005.0100, subp. 35a
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-9 07/16/14

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight on an annual

average.

40 CFR Section 72.7(a)(3); Minn. R. 7007.1075

Operating Hours: less than or equal to 816 hours/year using 12-month Rolling Sum

as a total for GP 002.

Title I Condition: To avoid classification as a major

modification under 40 CFR Section 52.21 and Minn. R.

7007.3000

MONITORING AND RECORDKEEPING hdr

The Permittee shall obtain from the fuel supplier a certificate or other record

indicating that the fuel delivered for use in the GP 002 emission units has a sulfur

content less then or equal to 0.05 percent by weight on a 12-month annual

average.

40 CFR Section 72.7; Minn. R. 7007.0800, subp. 4

and 5

Average Annual Suflur Content Determination

The Permittee shall calculate the annual average sulfur content, as a percentage

by weight, using the equation in 40 CFR Section 72.7(d)(2). In lieu of the factor,

volume times density, in the equation, the factor, mass (Mn), may be used, where

Mn is: mass of the nongaseous fuel in a delivery during the year to the unit of

which the nth sample is taken, in lb.

Fuel shall be sampled at least once for every delivery.

40 CFR Section 72.7(d)(3); Minn. R. 7007.1075

For a period of 5 years from the date the records are created, the Permittee shall

retain at the source records demonstrating that the requirements of 40 CFR

Section 72.7(a) are met. The 5-year period for keeping records may be extended

for cause, at any time prior to the end of the period, in writing by the Administrator

or the permitting authority.

(i) Such records shall include, for each delivery of fuel to the unit, the type of fuel,

the sulfur content, and the sulfur content of each sample taken.

(ii) The Permittee bears the burden of proof that the requirements of 40 CFR

Section 72.7(a) are met.

40 CFR Section 72.7(f)(3); Minn. R. 7007.1075

Loss of exemption. An exempt unit shall be treated as an affected unit under the

Acid Rain Program on the earliest of the following dates:

(A) The date on which the unit first serves one or more generators with total

nameplate capacity in excess of 25 MWe;

(B) The date on which the unit burns any coal or coal-derived fuel except for

coal-derived gaseous fuel with a total sulfur content no greater than natural gas; or

(C) January 1 of the year following the year in which the annual average sulfur

content for nongaseous fuel burned at the unit exceeds 0.05 percent by weight (as

determined under 40 CFR Section 72.7(d)).

40 CFR Section 72.7(f)(4)(i); Minn. R. 7007.1075

For each day of operation of any GP 002 emission unit(s), record the operating

start and stop times. By the 15th of each month, calculate and record the total

combined GP 002 operating hours for the previous month, and for the previous

12-month period (12-month rolling sum).

Title I Condition: To avoid classification as a major

modification under 40 CFR Section 52.21 and Minn. R.

7007.3000
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-10 07/16/14

Subject Item: GP 005 Emergency Diesel Engines

Associated Items: EU 009 Fire Pump diesel engine

EU 010 Substation black start diesel generator

What to do Why to do it

The requirements of this group apply individually to each associated item in this

group.

hdr

EMISSION AND OPERATIONAL REQUIREMENTS hdr

Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the units is 0.29 lb/MMBtu due to equipment design and allowable

fuels.

Minn. R. 7011.2300, subp. 2

Circumvention: The Permittee shall not build, erect, install, or use any article,

machine, equipment, or process to conceal an emission that would otherwise

constitute noncompliance with a relevant standard. Such concealment includes,

but is not limited to:

(1) The use of diluents to achieve compliance with a relevant standard based on

the concentration of a pollutant in the effluent discharged to the atmosphere or

(2) The use of gaseous diluents to achieve compliance with a relevant standard for

visible emissions.

40 CFR Section 63.4(b); Minn. R. 7011.7000

Change oil and filter every 500 hours of operation or annually, whichever comes

first. The Permittee has the option of utilizing an oil analysis program in order to

extend the oil change requirement as described below.

40 CFR Section 63.6602; 40 CFR pt. 63, subp. ZZZZ,

Table 2c; Minn. R. 7011.8150

Inspect air cleaner every 1,000 hours of operation or annually, whichever comes

first, and replace as necessary.

40 CFR Section 63.6602; 40 CFR pt. 63, subp. ZZZZ,

Table 2c; Minn. R. 7011.8150

Inspect all hoses and belts every 500 hours of operation or annually, whichever

comes first, and replace as necessary.

40 CFR Section 63.6602; 40 CFR pt. 63, subp. ZZZZ,

Table 2c; Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle and minimize the

engine's startup time at startup to a period needed for appropriate and safe loading

of the engine, not to exceed 30 minutes, after which time the non-startup emission

limitations apply.

40 CFR Section 63.6602; 40 CFR pt. 63, subp. ZZZZ,

Table 2c; Minn. R. 7011.8150

The Permittee shall be in compliance with the emission limitations and operating

limitations in this subpart that apply at all times.

40 CFR Section 63.6605(a); Minn. R. 7011.8150

At all times the Permittee shall operate and maintain EU 009 and EU 010,

including associated air pollution control equipment and monitoring equipment, in a

manner consistent with safety and good air pollution control practices for

minimizing emissions. The general duty to minimize emissions does not require

the Permittee to make any further efforts to reduce emissions if levels required by

this standard have been achieved. Determination of whether such operation and

maintenance procedures are being used will be based on information available to

the Administrator which may include, but is not limited to, monitoring results,

review of operation and maintenance procedures, review of operation and

maintenance records, and inspection of the source.

40 CFR Section 63.6605(b); Minn. R. 7011.8150

The Permittee shall operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer's emission-related written

instructions or develop a maintenance plan which must provide to the extent

practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

40 CFR Section 63.6625(e); Minn. R. 7011.8150

The Permittee shall install a non-resettable hour meter on EU 009 and EU 010 if

one is not already installed by the compliance date.

40 CFR Section 63.6625(f); Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle during startup and

minimize the engine's startup time to a period needed for appropriate and safe

loading of the engine, not to exceed 30 minutes, after which time the emission

standards applicable to all times other than startup apply.

40 CFR Section 63.6625(h); Minn. R. 7011.8150
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-11 07/16/14

The Permittee has the option of utilizing an oil analysis program in order to extend

the specified oil change requirement. The oil analysis must be performed at the

same frequency specified for changing the oil. The analysis program must at a

minimum analyze the following 3 parameters: Total Base Number, viscosity, and

percent water content. The condemning limits for these parameters are as follows:

Total Base Number is less than 30 percent of the Total Base Number of the oil

when new; viscosity of the oil has changed by more than 20 percent from the

viscosity of the oil when new; or percent water content (by volume) is greater than

0.5.

(continued below)

40 CFR Section 63.6625(i); Minn. R. 7011.8150

(continued from above)

If none of the condemning limits are exceeded, the engine owner or operator is not

required to change the oil. If any of the limits are exceeded, the engine owner or

operator must change the oil within 2 business days of receiving the results of the

analysis; if the engine is not in operation when the results of the analysis are

received, the engine owner or operator must change the oil within 2 business days

or before commencing operation, whichever is later. The owner or operator must

keep records of the parameters that are analyzed as part of the program, the

results of the analysis, and the oil changes for the engine. The analysis program

must be part of the maintenance plan for the engine.

40 CFR Section 63.6625(i); Minn. R. 7011.8150

The Permittee shall demonstrate continuous compliance with each emission

limitation and operating limitation in Table 2c of 40 CFR pt. 63, subp. ZZZZ that

apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ.

40 CFR Section 63.6640(a); Minn. R. 7011.8150

The Permittee shall operate and maintain the stationary RICE according to the

manufacturer's emission related operation and maintenance instructions; or the

Permittee shall develop and follow a maintenance plan which shall provide to the

extent practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

40 CFR Section 63.6640(a); 40 CFR Section

63.6655(d); 40 CFR pt. 63 subp. ZZZZ, Table 6; Minn.

R. 7011.8150

The Permittee shall comply with the General Provisions in 40 CFR Section 63.1

through 63.15, as applicable.

40 CFR Section 63.6665; 40 CFR pt. 63 subp. ZZZZ,

Table 8; Minn. R. 7011.8150

REQUIREMENTS FOR EMERGENCY STATIONARY RICE hdr

The Permittee shall operate the emergency stationary RICE according to the

requirements in paragraphs 40 CFR Section 63.6640 (f)(1) through (4) of 40 CFR

Section 63.6640(f). Any operation other than emergency operation, maintenance

and testing, emergency demand response, and operation in non-emergency

situations for 50 hours per year, as described in 40 CFR Section 63.6640(f)(1)

through (4), is prohibited. If the engine is not operated according to the

requirements in 40 CFR Section 63.6640(f)(1) through (4), the engine will not be

considered an emergency engine under this subpart and will need to meet all

requirements for non-emergency engines.

40 CFR Section 63.6640(f); Minn. R. 7011.8150

(1) There is no time limit on the use of emergency stationary RICE in emergency

situations.

(2) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) and (4)

counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

40 CFR Section 63.6640(f)(1) - (2); Minn. R.

7011.8150

The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indication that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per year.

40 CFR Section 63.6640(f)(2)(i); Minn. R. 7011.8150
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-12 07/16/14

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see Section 63.14), or other

authorized entity as determined by the Reliability Coordinator, has declared an

Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard

EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

40 CFR Section 63.6640(f)(2)(ii) - (2)(iii); Minn. R.

7011.8150

The Permittee may operate the emergency stationary RICE up to 50 hours per

calendar year in non-emergency situations, but those 50 hours are counted

towards the 100 hours per calendar year provided for maintenance and testing and

emergency demand response provided in 40 CFR Section 63.6640(f)(2). The 50

hours per year for non-emergency situations cannot be used for peak shaving or

non-emergency demand response, or to generate income for a facility to supply

power to an electric grid or otherwise supply power as part of a financial

arrangement with another entity.

40 CFR Section 63.6640(f)(3); Minn. R. 7011.8150

RECORDKEEPING REQUIREMENTS hdr

The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a

form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, or record.

Except that the most recent 2 years of data do not have to be retained on site.

40 CFR Section 63.10(b)(1); Minn. R. 7019.0100,

subp. 2(B)

The Permittee shall keep the records required in Table 6 of 40 CFR pt 63, subp.

ZZZZ, to show continuous compliance with each emission or operating limitation

that applies.

40 CFR Section 63.6655(d); Minn. R. 7011.8150

The Permittee shall keep records of the maintenance conducted on the stationary

RICE in order to demonstrate that the Permittee operated and maintained the

stationary RICE and after-treatment control device (if any) according to the

maintenance plan.

40 CFR Section 63.6655(e); Minn. R. 7011.8150

The Permittee shall keep records of the hours of operation of the engine that are

recorded through the non-resettable hour meter. The Permittee shall document

how many hours are spent for emergency operation; including what classified the

operation as emergency and how many hours are spent for non-emergency

operation. If the engine is used for demand response operation, the Permittee shall

keep records of the notification of the emergency situation, and the time the engine

was operated as part of demand response.

40 CFR Section 63.6655(f); Minn. R. 7011.8150

The Permittee shall maintain all records in a form suitable and readily available for

expeditious review according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record

for 5 years following the date of each occurrence, measurement, maintenance,

corrective action, report, or record.

The Permittee shall keep each record readily accessible in hard copy or electronic

form for at least 5 years after the date of each occurrence, measurement,

maintenance, corrective action, report, or record, according to 40 CFR section

63.10(b)(1).

40 CFR Section 63.6660; 40 CFR Section 63.10(b)(1);

Minn. R. 7011.8150; Minn R. 7019.0100, subp. 2(B)

REPORTING AND NOTIFICATION REQUIREMENTS hdr

The Permittee shall report each instance in which the stationary RICE did not meet

each applicable emission limitation or operating limitation. These instances are

deviations from the emission and operating limitations. These deviations shall be

reported according to the requirements in 40 CFR Section 63.6650.

40 CFR Section 63.6640(b); Minn. R. 7011.8150

The Permittee shall report each instance when the applicable requirements in

Table 8 of 40 CFR pt. 63, subp. ZZZZ were not met.

40 CFR Section 63.6640(e); 40 CFR pt. 63, subp.

ZZZZ, Table 8; Minn. R. 7011.8150

The Permittee shall report any failure to perform the work practice on the schedule

required in 40 CFR pt. 63, Table 2c due to an emergency or an unacceptable risk

under Federal, State or local law. The work practice shall be performed as soon as

practicable after the emergency has ended or the unacceptable risk under Federal,

State, or local law has abated.

40 CFR Section 63.6602; 40 CFR pt. 63, subp. ZZZZ,

Table 2c; Minn. R. 7011.8150
TABLE A: LIMITS AND OTHER REQUIREMENTS

Xcel Energy - Inver Hills Generating Plt

03700015 - 004

Facility Name:

Permit Number:

A-13 07/16/14

Subject Item: TK 001 distillate oil

What to do Why to do it

EMISSION AND OPERATIONAL LIMITS hdr

Opacity: less than or equal to 20 percent opacity. Minn. R. 7011.0715, subp. 1(B)
TABLE B: SUBMITTALS

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

B-1 07/16/14

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

- accumulated insignificant activities,

- installation of control equipment,

- replacement of an emissions unit, and

- changes that contravene a permit term.

Send any application for a permit or permit amendment to:

 Fiscal Services

 Minnesota Pollution Control Agency

 520 Lafayette Road North

 St. Paul, Minnesota 55155-4194

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts

7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall

be certified as appropriate if certification is required by an applicable rule or permit condition.

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A

or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list

one-time only and recurrent submittal requirements.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

 Chief Air Enforcement

 Air and Radiation Branch

 EPA Region V

 77 West Jackson Boulevard

 Chicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

 U.S. Environmental Protection Agency

 Clean Air Markets Division

 1200 Pennsylvania Avenue NW (6204N)

 Washington, D.C. 20460

Unless another person is identified in the applicable Table, send all other submittals to:

 AQ Compliance Tracking Coordinator

 Industrial Division

 Minnesota Pollution Control Agency

 520 Lafayette Road North

 St. Paul, Minnesota 55155-4194
TABLE B: RECURRENT SUBMITTALS

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

B-2 07/16/14

What to send When to send Portion of Facility Affected

Quarterly Report due 30 days after end of each calendar

quarter starting 07/28/1992. The report shall

contain the following: 1) The percent sulfur

content by weight and the heating value of the

fuel oil in million British Thermal Units per

gallon; 2) Summary of any exceedances of

the emission limitation, monthly fuel use

limitation and the sulfur content limitation

during the calendar quarter. The report shall

provide an explanation of each exceedance

which occurred or a statement stating that no

exceedances occurred. The report shall also

state if fuel oil was burned during the

monitored quarter.

Total Facility

Semiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance. The first

semiannual report submitted by the Permittee

shall cover the calendar half-year in which the

permit is issued. The first report of each

calendar year covers January 1 - June 30.

The second report of each calendar year

covers July 1 - December 31. If no deviations

have occurred, the Permittee shall submit the

report stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar year

following Permit Issuance (for the previous

calendar year). The Permittee shall submit

this to the Commissioner on a form approved

by the Commissioner. This report covers all

deviations experienced during the calendar

year.

Total Facility
Appendix B: Insignificant Activities 

Facility Name: Xcel Energy – Inver Hills Generating Plant 

Permit Number: 03700015-004 

The table below lists the insignificant activities that are currently at the facility and their associated 

general applicable requirements. 

Minn. R. 

7007.1300, 

subpart

Rule Description of the Activity Applicable 

Requirement 

3(H)3 Brazing, soldering, and welding equipment Minn. R. 

7011.0710/0715

3(K) Spray paint equipment used for facility upkeep Minn. R. 

7011.0715

4 Temporary (emergency) heating equipment (small portable propane 

heaters)

Minn. R. 

7011.0510/0515

4 Internal combustion engines (<250hp) burning distillate oil, gasoline, 

or natural gas

Minn. R. 

7011.2300

4 VOC fugitives from pumps, valves, and flanges on distillate oil 

forwarding systems

Minn. R. 

7011.0715

4 Water tank heater for fire protection system Minn. R. 

7011.2300

4 Temporary engines for various compressors and pumps (<250h hp) Minn. R. 

7011.2300

4 VOC fugitive emissions from solvents Minn. R. 

7011.0715

4 Various small fuel oil tanks (two 3300 gal tanks by generator 

building, one 300 gal tank by fuel forwarding house, six 300 gal 

oil/waste water tanks under loading rack, one 500 gal tank 

southwest of plant, one 250 gal tank inside foam house)

Minn. R. 

7011.1505
Appendix C: New Unit Exemptions for EU007 and EU008

Facility Name: Xcel Energy - Inver Hills Generating Plant 

Permit Number: 03700015-004 

Appendix D: Modeling Parameters 

Facility Name: Xcel Energy - Inver Hills Generating Plant 

Permit Number: 03700015-004 

The table below lists the required monitoring parameters for the facility.

Citation Requirement 

Title I Condition: SIP 

for SO2 NAAQS, 40 

CFR pt. 50; 40 CFR pt. 

52, subp. Y, MN SIP 

Stack Height: greater than or equal to 32 feet from ground level. This requirement 

applies to each individual stack.

Title I Condition: SIP 

for SO2 NAAQS, 40 

CFR pt. 50; 40 CFR pt. 

52, subp. Y, MN SIP 

Stack Cross-Sectional Area: less than or equal to 150 square feet (7.5 x 20 feet). This 

requirement applies to each individual stack.

Title I Condition: SIP 

for SO2 NAAQS, 40 

CFR pt. 50; 40 CFR pt. 

52, subp. Y, MN SIP 

Air Flow Rate: greater than or equal to 1,150,000 actual cubic feet/minute for each 

individual stack exhaust. This limit represents the modeled exhaust flow rate from 

each stack vent at maximum peak load/peak SO2 emissions. It is not representative 

of the flow rates at lower loads. 

Title I Condition: SIP 

for SO2 NAAQS, 40 

CFR pt. 50; 40 CFR pt. 

52, subp. Y, MN SIP 

Temperature: greater than or equal to 1050 degrees F for each individual stack 

exhaust. This limit represents the modeled exhaust temperature in each stack vent 

at maximum peak load/peak SO2 emissions. It Is not representative of the exhaust 

temperature at lower loads. 
Technical Support Document, Permit Action Number: 03700015-004 

Page 1 of 11 

 TECHNICAL SUPPORT DOCUMENT

For 

 AIR EMISSION PERMIT NO. 03700015-004

This technical support document (TSD) is intended for all parties interested in the permit and to meet 

the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and 

Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual 

justification for each applicable requirement or policy decision considered in the preliminary 

determination to issue the permit. 

1. General Information 

1.1 Applicant and Stationary Source Location 

Table 1. Applicant and Source Address 

Applicant/Address Stationary Source/Address 

(SIC Code: 4911, 5171) 

Northern States Power Company, a Minnesota 

Corporation

414 Nicollet Mall MP7B

Minneapolis, MN 55401-1993 

Xcel Energy - Inver Hills Generating Plant 

3185 117th Street East

Inver Grove Heights

Dakota County, Minnesota 55077 

Contact: Jonathan Amos 

Phone: 612-330-7682 

1.2 Facility Description 

The Inver Hills Generating Plant is a peak electrical generation facility with a capacity of 440 megawatts 

(MW). The facility is composed of six identical pre-NSPS General Electric natural gas or fuel oil-fired 

simple cycle combustion turbine/generator sets. The facility is on call to operate, as needed, any or all 

of the six primary turbine/generator sets. Each turbine is capable of using natural gas and distillate oil 

as a fuel source. Natural gas is the primary fuel, and fuel oil is used mostly during curtailment of natural 

gas (which is typically in the winter unless a natural gas pipeline break occurs during non-winter 

months). The Permittee has indicated that historically the overall fuel usage for the turbines is 90 

percent natural gas and 10 percent fuel oil. There are also two emergency generators powered by 

diesel engines and several insignificant emission sources on site. Distillate oil and other petroleum 

products are stored in a 10 million gallon above ground storage tanks. 

1.3 Description of the Activities Allowed by this Permit Action 

This permit action is the reissuance of the Part 70 operating permit. 

1.4 Description of Notifications and Applications Included in this Action 

Table 2. Notifications and Applications Included in this Action

Date Received DQ# Application/Notification Type and description

04/20/2011 3467 Part 70 Reissuance Application 
Technical Support Document, Permit Action Number: 03700015-004 

Page 2 of 11 

1.5 Facility Emissions 

Table 3. Total Facility Potential to Emit Summary 

PM

tpy

PM10

tpy

PM2.5

tpy

SO2

tpy

NOx

tpy

CO

tpy

CO2e 

tpy 

VOC 

tpy

Single 

HAP

tpy 

All 

HAPs

tpy 

Total Facility Limited 

Potential Emissions 

298 298 298 12,256 22,100 179 3,980,000 66 19.1 33.1 

Total Facility Actual 

Emissions (2013) 

0.239 0.225 0.179 1.17 120 0.90 * 0.714 * 

*Not reported in MN emission inventory. 

Table 4. Facility Classification 

Classification Major/Affected Source Synthetic Minor/Area Minor/Area 

PSD X 

Part 70 Permit Program X 

Part 63 NESHAP X 

1.6 Changes to Permit 

· Updates to reflect current MPCA templates and standard citation formatting; 

· Emission calculations were updated to now include CO2e; 

· Removed State Implementation Plan (SIP) limits that were terminated on the date the USEPA 

approved the revision to the SIP; 

· Residual fuel oil has been removed as an allowable fuel type in accordance with the revised SIP; 

· Changed permit language so requirements are more clearly applied to each unit individually 

within a group; 

· Two previously insignificant activities are now subject to NESHAP Subpart ZZZZ are now included 

as emission units. The substation black start diesel generator is now EU 009, and the fire pump 

diesel engine is now EU 010. These emission units make up the newly created GP 005; 

· New unit exemption language for the acid rain program has been updated in both the permit 

and the appendix; 

· Modeling parameters have been moved from the permit to the appendix; 

· Removed stacks/vents from groups. 

· Tank 002 (TK002) and Tank 003 (TK003) have been removed from the permit. The tanks were 

emptied, cleaned, and isolated from fuel delivery. Only the structures remain on site. 

· Inlet fogging system is currently in-operable, and there are no plans to restore the system in the 

foreseeable future, so the requirements for operating with inlet foggers have been removed 

from the permit. 

1.7 Changes to the State Implementation Plan 

The Pine Bend area surrounding Xcel’s Inver Hills facility currently meets all National and Minnesota 

Ambient Air Quality Standards (NAAQS and MAAQS). At one time, however, the area’s ambient air 

exceeded the sulfur dioxide (SO2) NAAQS. In response, the MPCA crafted conditions designed to bring 

the area into attainment with the standards. Those conditions applied to this and other facilities 
Technical Support Document, Permit Action Number: 03700015-004 

Page 3 of 11 

determined to be responsible for the ambient air quality problems. The MPCA is required to have a plan 

to maintain compliance with the NAAQS. Conditions in the permit identified as “Title I Condition: SIP for 

SO2 NAAQS” are elements of this maintenance plan.

During the reissuance of the Part 70 operating permit for its Inver Hills Generating Plant, Xcel Energy has 

requested that the MPCA change limits that are included in Minnesota’s State Implementation Plan to 

maintain the Pine Bend area (the area surrounding the Inver Hills Generating Plant) as an attainment 

(maintenance) area for sulfur dioxide (SO2). 

The requested changes are summarized in Table 5. 

Table 5. Changes to the SIP Conditions 

Permit Limitation or 

Condition 

Description of Change Effect 

Sulfur content of fuel The maximum allowable fuel sulfur 

content to be changed from 0.48 

percent by weight to 0.005 percent 

by weight. 

The maximum sulfur content of the fuel 

currently being provided to the facility is 

0.0015 percent by weight so the lowered 

limit should have no effect. 

Fuel Oil Analysis Method A of demonstrating 

compliance to be changed from 0.48 

percent by weight to 0.005 percent 

by weight. Method B to be changed 

from 0.10 percent by weight to 

0.0015 percent by weight. This has 

been done to reflect the lower sulfur 

content of fuel oil. 

As long as the fuel oil contains less than 

0.0015 percent sulfur by weight, the 

facility will be able to use a less onerous 

compliance option.

This request is the result of a cooperative effort by Xcel Energy, Flint Hills Resources, and the MPCA. At 

its Inver Hills facility, Xcel receives Ultra Low Sulfur Diesel from the nearby Flint Hills refinery that is

guaranteed to have a maximum sulfur content of 15 ppmw (0.0015% by weight). This sulfur content is 

much lower than the limit in the permit (0.48% by weight), so Xcel Energy has requested that the limit 

be lowered to more appropriately reflect the actual sulfur content of the fuel. The new conditions are 

more conservative than those contained in the previous permit, and (following their approval by EPA) 

they will continue to assure that compliance with the SO2 NAAQS is maintained, and to help 

accommodate anticipated construction in the Pine Bend area.

Minnesota must incorporate these changes into its SIP after which EPA must approve them. For this 

reason, the conditions that are to be eliminated include language indicating that they are no longer 

applicable only after EPA approves the change. 

 

2. Regulatory and/or Statutory Basis 

New Source Review 

The facility is an existing major source under New Source Review regulations. No changes are authorized 

by this permit. 
Technical Support Document, Permit Action Number: 03700015-004 

Page 4 of 11 

Part 70 Permit Program 

The facility is a major source under the Part 70 permit program. 

New Source Performance Standards (NSPS) 

The Permittee has stated that no New Source Performance Standards apply to the operations at this 

facility. 

National Emission Standards for Hazardous Air Pollutants (NESHAP) 

The facility exceeds the 10 tpy and 25 tpy emission thresholds for single and total HAPS, so the facility is 

a major source of HAPS. 

The combustion turbines are affected sources subject to 40 CFR 63 Subpart YYYY. However, they are 

existing stationary combustion turbines, and therefore have no applicable requirements from this 

NESHAP (see 40 CFR Section 63.6095). 

GP 002 contains two emergency diesel generators (EU 007 and EU 008) that do not need to meet the 

requirements of the NESHAP Subpart ZZZZ because the generators are >500 hp, and are not 

contractually obligated to be available for more than 15 hours per calendar year in accordance with 40 

CFR §63.6590(b)(3)(iii).

GP 005 contains a fire pump diesel engine (EU 009) and a substation black start diesel generator (EU 

010) that are subject to the same requirements of NESHAP Subpart ZZZZ because the units are both 

classified as emergency compression ignition RICE, that are <500 hp, and located at a major source of 

HAP emissions. 

Compliance Assurance Monitoring (CAM) 

None of the units at the facility are subject to CAM because there is no control equipment. 

Acid Rain Program 

The facility has two post-1990 Caterpillar emergency diesel-fired reciprocating internal combustion 

engines that are grid connected and therefore subject to Title IV. The Permittee committed to limiting 

diesel fuel sulfur content to 0.05 percent by weight in these units and applied for a new unit exemption 

from EPA’s Acid Rain program. 

Clean Air Interstate Rule (CAIR) / Transport Rule (TR) NOX Annual Trading Program [also known as the 

Cross-State Air Pollution Rule (CSAPR)] 

Xcel Energy – Inver Hills Generating Plant was subject to CAIR when it was initially promulgated. 

However, several actions have taken place resulting in CAIR no longer being an applicable requirement: 

· November 3, 2009 – Applicability of CAIR was stayed in Minnesota as of December 3, 2009, 

except as described in 40 CFR § 52.1240(b). (40 CFR §§ 51.123(a)(3), 51.124(a)(2), 51.125(a)(3), 

52.35(e)) 

· August 8, 2011 – 40 CFR §§ 52.1240(c) and 52.1241(c) were promulgated, replacing CAIR with 

TR/CSAPR. 

· December 30, 2011 – Applicability of TR/CSAPR was stayed by the United States Court of 

Appeals, and EPA was ordered to go back to CAIR. 
Technical Support Document, Permit Action Number: 03700015-004 

Page 5 of 11 

The stay of CAIR in Minnesota required sources to hold NOX as NO2 allowances equivalent to their initial 

allocation. EPA was to deduct and terminate these allowances. The CAMD records now show that zero 

CAIR NOX as NO2 allowances are held by Minnesota sources, as allowances have been deducted for 

program termination. The stay of CAIR in Minnesota continues to be in effect and therefore, no CAIR or 

CSAPR applicable requirements remain for this facility, at this time. 

Minnesota State Rules 

Portions of the facility are subject to Minn. R. 7011.2300 (Standards of Performance for Stationary 

Internal Combustion Engines). 

TK 001 (Distillate Oil Tank) is not subject to Minn. R. 7011.1505 (Standards of Performance for Storage 

Vessels) because the vapor pressure of fuel oil falls below the 128 mm Hg (2.5 psia) threshold. The 

highest vapor pressure identified in the application for distillate fuel oil no. 2 fuel oil has a vapor 

pressure of about 6 mm Hg (0.115 psia). TK 001 is subject to Minn. R. 7011.0715 (Standards of 

Performance for Post-1969 Industrial process Equipment) as the tank began operation in 1972. 

Table 6. Regulatory Overview of Facility 

Subject 

Item* Applicable Regulations Rationale 

GP 001 

(Combustion 

Turbines)

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion 

Engines. Determination of applicable limits from rule:

· The group contains 6 stationary internal combustion engines. 

40 CFR § 52.1220 State Implementation Plan Conditions for Sulfur Dioxide 

Maintenance Area. Determination of applicable limits from rule: 

· The facility is located in an area with a site specific SIP for SO2. 

GP 002 

(Diesel 

Generators) 

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion 

Engines. Determination of applicable limits from rule:

· The group contains 2 stationary internal combustion engines. 

40 CFR § 72.7 Acid Rain program: Exemption for New Units. The Permittee has 

applied for new unit exemption from the EPA’s Acid Rain program.

GP 005 

(Emergency 

Engines) 

Minn. R. 7011.2300 Standards of Performance for Stationary Reciprocating Internal

Combustion Engines. Determination of applicable limits from rule:

· The group contains 2 stationary internal combustion engines. 

40 CFR pt. 63, subp. ZZZZ 

Minn. R. 7011.8150

NESHAP for Stationary Reciprocating Internal Combustion Engines 

(RICE). Determination of applicable limits from rule:

· The units are emergency compression ignition RICE; 

· <500 hp; and 

· Are located at a major source. 

TK 001 

(Distillate oil) 

Minn. R. 7011.0715 The Industrial Process Equipment rule applies as a default since no 

other standard applies. 

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.).
Technical Support Document, Permit Action Number: 03700015-004 

Page 6 of 11 

3. Technical Information 

This section discusses a number of technical and regulatory decisions that were made during the review 

of the application and during permit drafting. 

3.1 Calculations of Potential to Emit 

Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, while 

Attachment 2 contains detailed spreadsheets and supporting information prepared by the MPCA and 

the Permittee. 

On January 1st, 2014 new Green House Warming Potentials (GWP) for Methane and Nitrous Oxide went 

into effect. These new GWPs have been taken into account and included in the emissions calculations 

for CO2e. 

3.2 Monitoring 

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have 

sufficient knowledge of the facility to certify that the facility is in compliance with all applicable 

requirements. 

In evaluating the monitoring included in the permit, the MPCA considered the following: 

· the likelihood of the facility violating the applicable requirements; 

· whether add-on controls are necessary to meet the emission limits; 

· the variability of emissions over time; 

· the type of monitoring, process, maintenance, or control equipment data already available for 

the emission unit; 

· the technical and economic feasibility of possible periodic monitoring methods; and 

· the kind of monitoring found on similar units elsewhere. 

·

Table 7 summarizes the monitoring requirements. 

Table 7. Monitoring 

Subject 

Item* Requirement (basis) Monitoring Discussion 

GP 001 

(Combustion 

Turbines) 

Opacity ≤ 20% once 

operating temp. is 

attained. 

SO2 ≤ 0.50 lbs/MMBtu 

heat input

(Minn. R. 7011.2300) 

None Each combustion turbine was tested once during 

the five-year permit term while burning fuel oil. In 

each case, the opacity reading was 0%. Because 

there appears to be little chance of violating the 

20% limit, the requirement to conduct periodic 

opacity testing has been eliminated from the 

permit.

The facility demonstrating compliance with the 

sulfur content of fuel limit will ensure compliance 

with the SO2 heat input limit. 
Technical Support Document, Permit Action Number: 03700015-004 

Page 7 of 11 

Subject 

Item* Requirement (basis) Monitoring Discussion 

Sulfur Content of Fuel ≤ 

0.005 percent by weight 

for all fuels.

Fuel Oil Usage ≤ 9.41 

million gallons on a 12-

month rolling average 

basis.

(Title I Condition: SIP for 

SO2 NAAQS, 40 CFR pt. 50; 

40 CFR pt. 52, subp. Y, MN 

SIP) 

Fuel Sulfur 

Content 

Restriction / 

Sulfur Dioxide 

Limit

The fuel oil supplier must provide a certification or 

other record that the sulfur content of the fuel oil 

meets the limit. The facility currently receives fuel 

that is guaranteed to have a maximum sulfur 

content of 0.0015 percent by weight. This is well 

below the required limit so an exceedance is 

unlikely. The supplier guarantee can be found in 

Attachment 4 of this TSD. 

The amount of fuel used at the facility must be 

tracked daily. The sulfur content of each shipment 

of fuel oil used at the facility must be analyzed upon 

receipt. On a monthly basis, the facility 

determinates compliance with the fuel usage limit. 

Sulfur dioxide emission rates are also calculated 

from these data. 

GP 002 

(Diesel 

Generators) 

Opacity ≤ 20% once 

operating temp. is 

attained. 

SO2 ≤ 0.50 lbs/MMBtu

(Minn. R. 7011.2300)

None It is unlikely that the opacity limit will be exceeded 

due to the decreased particle formation from the 

low sulfur content of fuel used. 

The potential to emit for SO2 from the unit is 0.05 

lb/MMBtu. Due to the allowable fuel used at the 

facility it is unlikely to exceed the limit.

Operating Hours ≤ 816 

hours/year using 12-

month Rolling Sum as a 

total for GP 002

(Title I Condition: To avoid 

classification as a major 

modification under 40 CFR 

§ 52.21 and Minn. R. 

7007.3000) 

Daily 

recordkeeping 

of the time of 

the start and 

stop of 

operation; 

monthly 

calculation of 

12-month 

rolling sum.

The combined limit on the two emergency diesel 

generators ensures that NOX emissions remain 

below PSD levels. Daily recordkeeping is used for 

tracking usage (when the units are actually 

operating). Actual hours of operation have been 

significantly less than the allowed 816 hours, so a 

relaxed calculation period of a month is 

appropriate.

Fuel oil sulfur content limit 

£ 0.05 percent by weight. 

(40 CFR § 72.7(a)(3); Minn. 

R. 7007.1075) 

Fuel Sulfur 

Content 

Restriction / 

Sulfur Dioxide 

Limit

The fuel oil supplier must provide a certification or 

other record that the sulfur content of the fuel oil 

meets the limit. That supplier guarantee can be 

found in attachment 4 of this TSD.

This level of monitoring meets the standard of 

reasonable precision, reliability, accessibility, and 

timeliness required by the regulation.
Technical Support Document, Permit Action Number: 03700015-004 

Page 8 of 11 

Subject 

Item* Requirement (basis) Monitoring Discussion 

GP 005 

(Emergency 

Engines)

Opacity ≤ 20% once 

operating temp. is 

attained. 

SO2 ≤ 0.50 lbs/MMBtu

(Minn. Rule 7011.2300) 

None. It is unlikely that the opacity limit will be exceeded 

due to the decreased particle formation from the 

low sulfur content of fuel used. 

The potential to emit for SO2 from the unit is 0.29 

lb/MMBtu. Due to the allowable fuel used at the 

facility it is unlikely to exceed the limit.

100 hours per calendar 

year provided for 

maintenance and testing. 

(40 CFR pt. 63, subp. ZZZZ; 

Minn. R. 7011.8150) 

The 

installation of 

a nonresettable 

hour meter 

will be used to 

record hours 

of emergency 

and nonemergency 

operations. 

These units are only used in emergency situations 

and routine maintenance so it is unlikely to exceed 

the operational requirements. 

TK 001 

(Distillate oil) 

Opacity ≤ 20%

(Minn. R. 7011.0715) 

None. The tanks are not expected to generate particulate 

matter or opacity.

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 

3.3 Insignificant Activities 

Xcel Energy - Inver Hills Generating Pit has several operations which are classified as insignificant 

activities under the MPCA’s permitting rules. These are listed in Appendix B to the permit. 

Table 8. Insignificant Activities 

Insignificant Activity 

General Applicable 

Emission limit Discussion 

Fuel use: space heaters fueled 

by propane, less than 420,000 

Btu/hr

PM ≤ 0.6 or 0.4 

lb/MMBtu, depending on 

year constructed

Opacity ≤ 20% with 

exceptions

(Minn. R. 

7011.0510/0515) 

For this unit, based on the fuels used and EPA 

published emissions factors, it is highly unlikely that 

it could violate the applicable requirement. In 

addition, these types of units are typically operated 

and vented inside a building, so testing for PM or 

opacity is not feasible.

Indirect heating equipment 

with a capacity less than 

420,000 Btu/hour, etc.

PM ≤ 0.6 or 0.4, 

depending on year 

constructed 

Opacity ≤ 20% with 

exceptions

(Minn. R. 

7011.0510/0515) 

For these units, based on the fuels used and EPA 

published emissions factors, it is highly unlikely that 

they could violate the applicable requirements.
Technical Support Document, Permit Action Number: 03700015-004 

Page 9 of 11 

Insignificant Activity 

General Applicable 

Emission limit Discussion 

Brazing, soldering or welding 

equipment

PM, variable depending 

on airflow

Opacity ≤ 20%

(Minn. R. 

7011.0710/0715) 

For these units, based on EPA published emissions 

factors, it is highly unlikely that they could violate

the applicable requirement. In addition, these units 

are typically operated and vented inside a building, 

so testing for PM or opacity is not feasible. 

Individual units with potential 

emissions less than 2000 

lb/year of certain pollutants

PM, variable depending 

on airflow

Opacity ≤ 20% (with 

exceptions)

(Minn. R. 7011.0715 and 

Minn. R. 7011.0610) 

or

SO2 ≤ 0.5 lb/MMBtu

Opacity ≤ 20%

(Minn. R. 7011.2300) 

The facility contains temporary engines for various 

compressors and pumps as well as internal 

combustion engines burning distillate oil, gasoline, 

or natural gas. There are also VOC fugitive emissions

from solvents (parts washers no longer use 

solvents), and from pumps, valves, and flanges on 

the distillate oil forwarding system/loading rack. Due 

to the limited use and size of the engines (<250hp) it 

is unlikely that these units will exceed the 

requirements.

Infrequent use of spray paint 

equipment for routine 

housekeeping or plant upkeep 

activities not associated with 

primary production processes 

at the stationary source 

PM, variable depending 

on airflow or process 

weight rate

Opacity ≤ 20%

(Minn. R. 7011.0715)

While spray equipment will have the potential to 

emit particulate matter, these particular activities 

are those not associated with production, so they 

would be infrequent and usually occur outdoors. 

Testing or monitoring is not feasible. 

Various small fuel oil tanks 

that do not have a tankage 

capacity of more than 10,000 

gallons

There are no standards of 

performance 

promulgated in this part 

for storage vessels with a 

storage capacity of 2,000 

gallons or less.

(Minn. R. 7011.1505) 

Based on the capacity of the tanks and total 

throughput, it is highly unlikely that they could 

violate the applicable requirement or that testing 

would be feasible. 

3.4 Permit Organization 

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. The 

permit conditions are placed at the group level. Group 001 includes the six electric generating 

combustion turbines (six emission units). Group 002 includes the two emergency diesel generators. 

In addition, there are two appendices to the permit. (Appendix A is reserved for the Operator’s 

Summary which is not used with this permit.) Appendix B contains a listing of the Insignificant Activities 

at the facility. Appendix C records the New Unit Exemptions from the requirements of the Acid Rain 

program for Emission Units EU007 and EU008 (See 40 CFR § 72.7 for more information), and Appendix C 

contains the modeling parameters associated with the stacks for each of the electric generating 

combustion turbines (i.e., the stacks for the members of Group 1.) 
Technical Support Document, Permit Action Number: 03700015-004 

Page 10 of 11 

3.5 Comments Received 

Public Notice Period: 06/02/2014 - 07/01/2014 

EPA 45-day Review Period: 06/02/2014 - 07/16/2014 

Comments were not received from the public during the public notice period. 

Comments were not received from the EPA during their review period. Changes to the permit were not 

made as a result of the comments. 

4. Permit Fee Assessment 

This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under 

Minn. R. 7002.0016, subp. 1. 

5. Conclusion 

Based on the information provided by Northern States Power dba Xcel Energy, the MPCA has reasonable 

assurance that the proposed operation of the emission facility, as described in the Air Emission Permit 

No. 03700015-004 and this TSD, will not cause or contribute to a violation of applicable federal 

regulations and Minnesota Rules. 

Staff Members on Permit Team: Robert Little (permit engineer) 

Brent Rohne (enforcement) 

Marc Severin (compliance) 

Dick Cordes (peer reviewer) 

Beckie Olson (permit writing assistant) 

Sandy Simbeck (administrative support) 

Amanda Smith (SIP contact) 

AQ File No. 202S; DQ 3467

Attachments: 1. Facility Emissions Summary 

2. Facility Description and CD-01 Forms 

3. Points Calculator 

4. Supplier Guarantee 

Xcel Energy – Inver Hills Generating Plant

03700015-004

Attachment 1

Facility Emissions Summary
ants Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.53E-01 lb/10^6 Btu November 2007 Stack Test 344.88 1510.58 1510.58 NAPM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

SOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NA

Total VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NA

Acrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA

1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NA

Formaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NA

Naphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

PAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

Propylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NA

Toluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NA

Xylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NA

Total HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

e Oil) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

e Oil) NOx 923.00 MMBtu/hr 6.42E-01 lb/10^6 Btu November 2007 Stack Test 592.57 2595.44 2595.44 NAe Oil) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

e Oil) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

e Oil) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

e Oil) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

e Oil) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

e Oil) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

e Oil) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

e Oil) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

e Oil) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

e Oil) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

e Oil) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

e Oil) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NA

e Oil) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

e Oil) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

e Oil) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

e Oil) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

e Oil) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

e Oil) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

e Oil) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

e Oil) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GWP

G) CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None

G) CH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 None G) N O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 None 2G) Total GHG

GWP

ate Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None

ate Oil) CH4 923.00 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 6.09E+00 2.67E+01 2.67E+01 2.67E+01 None ate Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None 2
ants Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.28E-01 lb/10^6 Btu November 2007 Stack Test 320.46 1403.60 1403.60 NA

PM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NAPM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NASOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NA

816 hours (EU007 & EU008 combined)

Total VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NA

Acrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA

1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NA

Formaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NA

Naphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

PAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

Propylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NA

Toluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NA

Xylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NA

Total HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

te Oil) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

te Oil) NOx 923.00 MMBtu/hr 5.95E-01 lb/10^6 Btu November 2007 Stack Test 549.19 2405.43 2405.43 NA

te Oil) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA urs (EU007 & EU008 combined)

te Oil) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

te Oil) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

te Oil) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

te Oil) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

te Oil) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

te Oil) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

te Oil) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

te Oil) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

te Oil) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

te Oil) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

te Oil) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NA

te Oil) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

te Oil) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

te Oil) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

te Oil) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

te Oil) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

te Oil) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

te Oil) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

te Oil) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GW

G) CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None

G) CH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 NoneG) N O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 NoneG) Total GHG

GW

ate Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None
ants Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

ate Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None

ate Oil) Total GHG
nts Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.54E-01 lb/10^6 Btu November 2007 Stack Test 345.86 1514.86 1514.86 NAPM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

SOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NATotal VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NAAcrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NAFormaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NANaphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NAPAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NAPropylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NAToluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NAXylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NATotal HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

Oil) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

Oil) NOx 923.00 MMBtu/hr 6.32E-01 lb/10^6 Btu November 2007 Stack Test 583.34 2555.01 2555.01 NA

Oil) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

Oil) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

Oil) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

Oil) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

Oil) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NAOil) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

Oil) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

Oil) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

Oil) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

Oil) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

Oil) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GWP

CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None 1 40 CCH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 None 25 40 CN O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 None 298 40 C

Total GHG

GWP

 Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None 1 40 C

 Oil) CH4 923.00 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 6.09E+00 2.67E+01 2.67E+01 2.67E+01 None 25 40 C Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None 298 40 C Oil) Total GHG
nts Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.59E-01 lb/10^6 Btu November 2007 Stack Test 350.74 1536.25 1536.25 NAPM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

SOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NATotal VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NAAcrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NAFormaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NANaphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NAPAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NAPropylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NAToluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NAXylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NATotal HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

Oil) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

Oil) NOx 923.00 MMBtu/hr 6.24E-01 lb/10^6 Btu November 2007 Stack Test 575.95 2522.67 2522.67 NA

Oil) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

Oil) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

Oil) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

Oil) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

Oil) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NAOil) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

Oil) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

Oil) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

Oil) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

Oil) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

Oil) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GWP

CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None 1 40 CCH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 None 25 40 CN O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 None 298 40 C

Total GHG

GWP

 Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None 1 40 C

 Oil) CH4 923.00 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 6.09E+00 2.67E+01 2.67E+01 2.67E+01 None 25 40 C Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None 298 40 C Oil) Total GHG
s Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.69E-01 lb/10^6 Btu November 2007 Stack Test 360.51 1579.05 1579.05 NA

PM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

PM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NA

SOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NA

Total VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NA

Acrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA

1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NA

Formaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NA

Naphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

PAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

Propylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NA

Toluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NA

Xylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NA

Total HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

) NOx 923.00 MMBtu/hr 6.45E-01 lb/10^6 Btu November 2007 Stack Test 595.34 2607.57 2607.57 NA

) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NA

) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GWP

CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None 1 40 CFR CH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 None 25 40 CFR N O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 None 298 40 CFR 

Total GHG

GWP

Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None 1 40 CFR 

Oil) CH4 923.00 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 6.09E+00 2.67E+01 2.67E+01 2.67E+01 None 25 40 CFR Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None 298 40 CFR 

Oil) Total GHG
ts Shaded areas are worst case pollutant for both fuel types.

Pollutant

Max 

Process

 Rate

Process 

Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to 

Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit 

(ton/yr)

Limited 

Potential to 

Emit

(ton/yr) Existing Permit Limit

CO 977.00 MMBtu/hr 2.00E-03 lb/10^6 Btu August 1, 2000 Stack Test 1.95 8.56 8.56 NA

NOx 977.00 MMBtu/hr 3.65E-01 lb/10^6 Btu November 2007 Stack Test 356.61 1561.93 1561.93 NA

PM 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NAPM10 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NAPM2.5 977.00 MMBtu/hr 6.60E-03 lb/10^6 Btu AP-42 Table 3.1-2 6.45 28.24 28.24 NASOx 977.00 MMBtu/hr 1.32E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.13 0.56 0.56 NA

Total VOC 977.00 MMBtu/hr 2.10E-03 lb/10^6 Btu AP-42 Table 3.1-2 2.05 8.99 8.99 NA

Acetaldehyde 977.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.17 0.17 NA

Acrolein 977.00 MMBtu/hr 6.40E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.03 0.03 NA

Benzene 977.00 MMBtu/hr 1.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.01 0.05 0.05 NA

1,3 Butadiene 977.00 MMBtu/hr 4.30E-07 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.00 0.00 NA

Ethylbenzene 977.00 MMBtu/hr 3.20E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.14 0.14 NA

Formaldehyde 977.00 MMBtu/hr 7.10E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.69 3.04 3.04 NA

Naphthalene (PAH) 977.00 MMBtu/hr 1.30E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

PAHs 977.00 MMBtu/hr 2.20E-06 lb/10^6 Btu AP-42 Table 3.1-3 0.00 0.01 0.01 NA

Propylene Oxide 977.00 MMBtu/hr 2.90E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.03 0.12 0.12 NA

Toluene 977.00 MMBtu/hr 1.30E-04 lb/10^6 Btu AP-42 Table 3.1-3 0.13 0.56 0.56 NA

Xylenes 977.00 MMBtu/hr 6.40E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.06 0.27 0.27 NA

Total HAPs (NG) 977.00 MMBtu/hr 1.03E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.00 4.40 4.40 NA

Oil) CO 923.00 MMBtu/hr 3.30E-03 lb/10^6 Btu AP-42 Table 3.1-1 3.05 13.34 13.34 NA

Oil) NOx 923.00 MMBtu/hr 6.57E-01 lb/10^6 Btu November 2007 Stack Test 606.41 2656.08 2656.08 NA

Oil) PM 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NAOil) PM10 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) PM2.5 923.00 MMBtu/hr 1.20E-02 lb/10^6 Btu AP-42 Table 3.1-2 11.08 48.51 48.51 NA

Oil) SOx 923.00 MMBtu/hr 5.05E-01 lb/10^6 Btu AP-42 Table 3.1-2 466.12 2041.58 2041.58 2041.58

less than or equal to 0.5 lb/MMBtu

Oil) Total VOC 923.00 MMBtu/hr 4.10E-04 lb/10^6 Btu AP-42 Table 3.1-2 0.38 1.66 1.66 NA

Oil) Arsenic 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Benzene 923.00 MMBtu/hr 5.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.05 0.22 0.22 NA

Oil) Beryllium 923.00 MMBtu/hr 3.10E-07 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) 1,3 Butadiene 923.00 MMBtu/hr 1.60E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.01 0.06 0.06 NA

Oil) Cadmium 923.00 MMBtu/hr 4.80E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) Chromium 923.00 MMBtu/hr 1.10E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.04 0.04 NA

Oil) Formaldehyde 923.00 MMBtu/hr 2.80E-04 lb/10^6 Btu AP-42 Table 3.1-4 0.26 1.13 1.13 NA

Oil) Lead 923.00 MMBtu/hr 1.40E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.01 0.06 0.06 NA

Oil) Manganese 923.00 MMBtu/hr 7.90E-04 lb/10^6 Btu AP-42 Table 3.1-5 0.73 3.19 3.19 NA

Oil) Mercury 923.00 MMBtu/hr 1.20E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.00 0.00 NA

Oil) Naphthalene (PAH) 923.00 MMBtu/hr 3.50E-05 lb/10^6 Btu AP-42 Table 3.1-4 0.03 0.14 0.14 NA

Oil) Nickel 923.00 MMBtu/hr 4.60E-06 lb/10^6 Btu AP-42 Table 3.1-5 0.00 0.02 0.02 NA

Oil) PAHs 923.00 MMBtu/hr 4.00E-05 lb/10^6 Btu AP-42 Table 3.1-3 0.04 0.16 0.16 NA

Oil) Selenium 923.00 MMBtu/hr 2.50E-05 lb/10^6 Btu AP-42 Table 3.1-5 0.02 0.10 0.10 NA

Oil) Total HAPs (Oil) 977.00 MMBtu/hr 1.29E-03 lb/10^6 Btu AP-42 Table 3.1-3 1.26 5.51 5.51 NA

GWP

CO2 977.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.29E+00 5.65E+00 5.65E+00 5.65E+00 None 1 40 CFCH4 977.00 mmbtu/hr 2.20E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E+00 9.41E+00 9.41E+00 9.41E+00 None 25 40 CFN O2 977.00 mmbtu/hr 2.20E-04 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.15E-01 9.41E-01 9.41E-01 9.41E-01 None 298 40 CF

Total GHG

GWP

 Oil) CO2 923.00 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.50E+05 6.58E+05 6.58E+05 6.58E+05 None 1 40 CF

 Oil) CH4 923.00 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 6.09E+00 2.67E+01 2.67E+01 2.67E+01 None 25 40 CF Oil) N O2 923.00 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.22E+00 5.34E+00 5.34E+00 5.34E+00 None 298 40 CF

 Oil) Total GHG
Pollutant

Max 

Process

 Rate

Process Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit (ton/yr)

Limited 

Potential to 

Emit 

(ton/yr) Existing Permit Limit

CO 16.6 MMBtu/hr NA NA Manufacturer's Data 11.32 49.58 49.58 4.62 816 hours (EU007 & EU008 combined)

NOx 16.6 MMBtu/hr NA NA Manufacturer's Data 86.50 378.87 378.87 35.29 816 hours (EU007 & EU008 combined)

PM 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)

PM10 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)PM2.5 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)SOx 16.6 MMBtu/hr NA NA Manufacturer's Data 0.85 3.72 3.72 0.35 816 hours (EU007 & EU008 combined) & 0.05 %S 

Total VOC 16.6 MMBtu/hr NA NA Manufacturer's Data 1.39 6.09 6.09 0.57 816 hours (EU007 & EU008 combined)

Acetaldehyde 16.6 MMBtu/hr 2.52E-05 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)

Acrolien 16.6 MMBtu/hr 7.88E-06 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)Arsenic 16.6 MMBtu/hr 4.00E-06 lb/MMBtu AP-42 Table 1.3-10 (9/98) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)

Benzene 16.6 MMBtu/hr 7.76E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.01 0.06 0.06 0.01 816 hours (EU007 & EU008 combined)Formaldehyde 16.6 MMBtu/hr 7.89E-05 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)

Naphthalene 16.6 MMBtu/hr 7.89E-05 lb/MMBtu AP-42 Table 3.4-4 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)

Toluene 16.6 MMBtu/hr 2.81E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.02 0.02 0.00 816 hours (EU007 & EU008 combined)

Xylenes 16.6 MMBtu/hr 1.93E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)

TOTAL HAPs 0.02 0.10 0.10 0.01

CO 16.6 MMBtu/hr NA NA Manufacturer's Data 11.32 49.58 49.58 4.62 816 hours (EU007 & EU008 combined)

NOx 16.6 MMBtu/hr NA NA Manufacturer's Data 86.50 378.87 378.87 35.29 816 hours (EU007 & EU008 combined)

PM 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)

PM10 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)PM2.5 16.6 MMBtu/hr NA NA Manufacturer's Data 0.80 3.50 3.50 0.33 816 hours (EU007 & EU008 combined)SOx 16.6 MMBtu/hr NA NA Manufacturer's Data 0.85 3.72 3.72 0.35 816 hours (EU007 & EU008 combined) & 0.05 %S 

Total VOC 16.6 MMBtu/hr NA NA Manufacturer's Data 1.39 6.09 6.09 0.57 816 hours (EU007 & EU008 combined)

Acetaldehyde 16.6 MMBtu/hr 2.52E-05 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)

Acrolien 16.6 MMBtu/hr 7.88E-06 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)Arsenic 16.6 MMBtu/hr 4.00E-06 lb/MMBtu AP-42 Table 1.3-10 (9/98) 0.00 0.00 0.00 0.00 816 hours (EU007 & EU008 combined)

Benzene 16.6 MMBtu/hr 7.76E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.01 0.06 0.06 0.01 816 hours (EU007 & EU008 combined)Formaldehyde 16.6 MMBtu/hr 7.89E-05 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)

Naphthalene 16.6 MMBtu/hr 7.89E-05 lb/MMBtu AP-42 Table 3.4-4 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)Toluene 16.6 MMBtu/hr 2.81E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.02 0.02 0.00 816 hours (EU007 & EU008 combined)

Xylenes 16.6 MMBtu/hr 1.93E-04 lb/MMBtu AP-42 Table 3.4-3 (10/96) 0.00 0.01 0.01 0.00 816 hours (EU007 & EU008 combined)

TOTAL HAPs 0.02 0.10 0.10 0.01

GWP

CO2 16.6 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 2.70E+03 1.18E+04 1.18E+04 5.50E+02 None CH4 16.6 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.09E-01 4.79E-01 4.79E-01 2.23E-02 None 25N O2 16.6 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.19E-02 9.58E-02 9.58E-02 4.46E-03 None 298

Total GHG

GWP

CO2 16.6 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 2.70E+03 1.18E+04 1.18E+04 5.50E+02 None CH4 16.6 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.09E-01 4.79E-01 4.79E-01 2.23E-02 None 25N O2 16.6 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.19E-02 9.58E-02 9.58E-02 4.46E-03 None 298

Total GHG
Pollutant

Max 

Process

 Rate

Process Rate

 Units

Emission

 Factor Emission 

Factor Units Emission Factor Source

Emission 

Rate

 (lb/hr)

Uncontrolled 

Potential to Emit

 (ton/yr)

Pollution 

Control 

Efficiency 

(%)

Controlled 

Potential to 

Emit (ton/yr)

Limited 

Potential to 

Emit 

(ton/yr) Existing Permit Limit

CO 0.9 MMBtu/hr 9.50E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.82 0.21 0.21 500 hours (EPA memo)

NOx 0.9 MMBtu/hr 4.41E+00 lb/MMBtu AP-42 Table 3.3-1 (10/96) 3.81 0.95 0.95 500 hours (EPA memo)

PM 0.9 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.27 0.07 0.07 500 hours (EPA memo)

PM10 0.9 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.27 0.07 0.07 500 hours (EPA memo)PM2.5 0.9 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.27 0.07 0.07 500 hours (EPA memo)SOx 0.9 MMBtu/hr 2.90E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.25 0.06 0.06 500 hours (EPA memo) & 0.05 %S 

Total VOC 0.9 MMBtu/hr 3.60E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.31 0.08 0.08 500 hours (EPA memo)

Acetaldehyde 0.9 MMBtu/hr 7.67E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Acrolien 0.9 MMBtu/hr 9.25E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

1,3-Butadiene 0.9 MMBtu/hr 3.91E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Benzene 0.9 MMBtu/hr 9.33E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Formaldehyde 0.9 MMBtu/hr 1.18E-03 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Naphthalene 0.9 MMBtu/hr 8.48E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Toluene 0.9 MMBtu/hr 4.09E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Xylenes 0.9 MMBtu/hr 2.85E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

TOTAL HAPs 0.00 0.00 0.00

CO 0.4 MMBtu/hr 9.50E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.36 0.09 0.09 500 hours (EPA memo)

NOx 0.4 MMBtu/hr 4.41E+00 lb/MMBtu AP-42 Table 3.3-1 (10/96) 1.68 0.42 0.42 500 hours (EPA memo)

PM 0.4 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.12 0.03 0.03 500 hours (EPA memo)

PM10 0.4 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.12 0.03 0.03 500 hours (EPA memo)PM2.5 0.4 MMBtu/hr 3.10E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.12 0.03 0.03 500 hours (EPA memo)SOx 0.4 MMBtu/hr 2.90E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.11 0.03 0.03 500 hours (EPA memo) & 0.05 %S 

Total VOC 0.4 MMBtu/hr 3.60E-01 lb/MMBtu AP-42 Table 3.3-1 (10/96) 0.14 0.03 0.03 500 hours (EPA memo)

Acetaldehyde 0.4 MMBtu/hr 7.67E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Acrolien 0.4 MMBtu/hr 9.25E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

1,3-Butadiene 0.4 MMBtu/hr 3.91E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Benzene 0.4 MMBtu/hr 9.33E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Formaldehyde 0.4 MMBtu/hr 1.18E-03 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Naphthalene 0.4 MMBtu/hr 8.48E-05 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Toluene 0.4 MMBtu/hr 4.09E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

Xylenes 0.4 MMBtu/hr 2.85E-04 lb/MMBtu AP-42 Table 3.3-2 (10/96) 0.00 0.00 0.00 500 hours (EPA memo)

TOTAL HAPs 0.00 0.00 0.00

GWP

CO2 0.9 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 1.41E+02 3.51E+01 3.51E+01 None CH4 0.9 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 5.70E-03 1.42E-03 1.42E-03 None 25N O2 0.9 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 1.14E-03 2.85E-04 2.85E-04 None 298

Total GHG

GWP

e CO2 0.4 mmbtu/hr 1.63E+02 lb/mmbtu 40 CFR 98, Subpart C, Table C-1 6.20E+01 1.55E+01 1.55E+01 None 

e CH4 0.4 mmbtu/hr 6.60E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 2.51E-03 6.29E-04 6.29E-04 None 25e N O2 0.4 mmbtu/hr 1.32E-03 lb/mmbtu 40 CFR 98, Subpart C, Table C-2 5.03E-04 1.26E-04 1.26E-04 None 298

e Total GHG
xcel points.xlsx Tanks

Printed on: 4/23/2014 1:42 PM Page 10 of10

Xcel Energy - Inver Hills Generating Plant

Criteria and Hazardous Air Pollutants

Tanks VOCs

TK 002 See Tanks 4.0 print out

TK 003

TK 004

Added from Xcel response:

Delta ID Description

Working Loss

(lbs)

Breathing Loss

(lbs)

Total Emissions

(lbs)

TK 001 IH Tank #2 267.77 2067.56 2335.33
Xcel Energy – Inver Hills Generating Plant

03700015-004

Attachment 2

Facility Description and CD-01 Forms
ST. PAUL, MN 55155-4194

Show: All Records

Action:AQD Facility ID: 03700015

Facility Name:

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD

2 June, 2014 11:29

FACILITY DESCRIPTION: EMISSION UNIT (EU)

Max

Fuel

Input

(mil Btu)

Xcel Energy - Inver Hills Generating Plt

Retired

By

(Action)

Operator Description ID No. Emission

Unit

Status

Added

By

(Action)

Control

Equip.

ID No(s).

Stack/

Vent

ID No(s).

Operator

ID

for Item

Insignificant

Activity

SIC Manufacturer Model

Number

Max.

Design

Capacity

Maximum

Design

Capacity

Materials Units n Units d

977 1 Combustion Turbine 1 EU 001 Active PER 001 SV 001 (M) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T977 2 Combustion Turbine 2 EU 002 Active PER 001 SV 002 (M) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T977 3 Combustion Turbine 3 EU 003 Active PER 001 SV 003 (M) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T977 4 Combustion Turbine 4 EU 004 Active PER 001 SV 004 (M) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T977 5 Combustion Turbine 5 EU 005 Active PER 001 SV 005 (P) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T977 6 Combustion Turbine 6 EU 006 Active PER 001 SV 006 (M) Hr Hours Heat 4911 General Electric 7001B 977 Mmbtu Million British T

16.81 7 PER 003 Diesel Generator 1

ODG-GEN-001

EU 007 Active PER 001 SV 007 (M) Hr Hours 4911 Caterpillar 3516TA 121 Gal Gallons

16.81 8 Diesel Generator 1

ODG-GEN-001

EU 007 Active PER 003 SV 007 (M) Hr Hours 4911 Caterpillar 3516TA 121 Gal Gallons

16.81 9 PER 003 Diesel Generator 2

ODG-GEN-002

EU 008 Active PER 001 SV 008 (M) Hr Hours 4911 Caterpillar 3516TA 121 Gal Gallons

16.81 10 Diesel Generator 2

ODG-GEN-002

EU 008 Active PER 003 SV 008 (M) Hr Hours 4911 Caterpillar 3516TA 121 Gal Gallons

.864 11 Fire Pump diesel engine EU 009 Active PER 004 Hr Hours 4911 6.3 Gal Gallons.381 12 Substation black start diesel

generator

EU 010 Active PER 004 Hr Hours 4911 2.78 Gal Gallons

Page 1 of 1 (a)
2 June, 2014 11:29

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. Elevator

Type

Bottleneck Pct.

Fuel/

Space

Heat

Firing Method Added

By

(Action)

Removal

Date

Initial

Startup

Date

Commence

Const.

Date

Emission

Unit

Status

1 EU 001 PER 001 01/01/1972 01/01/1971 Active2 EU 002 PER 001 01/01/1972 01/01/1971 Active3 EU 003 PER 001 01/01/1972 01/01/1971 Active4 EU 004 PER 001 01/01/1972 01/01/1971 Active5 EU 005 PER 001 01/01/1972 01/01/1971 Active6 EU 006 PER 001 01/01/1972 01/01/1971 Active7 EU 007 PER 001 03/21/1996 Active8 EU 007 PER 003 07/01/1996 03/21/1996 Active9 EU 008 PER 001 03/21/1996 Active

10 EU 008 PER 003 07/01/1996 03/21/1996 Active

11 EU 009 PER 004 Active

12 EU 010 PER 004 Active

Page 1 of 1 (b)
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 1 of 16 2 Jun, 2014 11:26

Subject Item: Total Facility

NC/

CA

Type Citation Requirement

1.0 CD hdr SOURCE SPECIFIC REQUIREMENTS

CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Table

of Contents. The Permittee shall comply with all requirements contained in the

appendices.

2.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7009.0020

Parameters Used in Modeling: The stack heights, emission rates, and other

parameters used in the modeling for the SO2 SIP are listed in Appendix C of this

permit. The Permittee must submit to the Commissioner for approval any revisions

of these parameters and must wait for a written approval before making such

changes. The information submitted must include, at a minimum, the locations,

heights and diameters of the stacks, locations and dimensions of nearby buildings,

the velocity and temperatures of the gases emitted, and the emission rates. The

plume dispersion charateristics due to the revisions of the information must be

equivalent to or better than the dispersion characteristics modeled in the SO2 SIP

submittal. The Permittee shall demonstrate this equivalency in the proposal. If the

information does not demonstrate equivalent or better dispersion characteristics, or

if a conclusion cannot readily be made about the dispersion, the Permittee must

remodel.

3.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

State Implementation Plan Recordkeeping: Retain all records at the stationary

source for a period of five (5) years from the date of the required monitoring,

sample, measurement, or report that corresponds with the "Title I Condition: SIP

for SO2 NAAQS" requirement.

4.0

S/A Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Quarterly Report: due 30 days after end of each calendar quarter starting

07/28/1992. The report shall contain the following: 1) The percent sulfur content

by weight and the heating value of the fuel oil in million British Thermal Units per

gallon; 2) Summary of any exceedances of the emission limitation, monthly fuel

use limitation and the sulfur content limitation during the calendar quarter. The

report shall provide an explanation of each exceedance which occurred or a

statement stating that no exceedances occurred. The report shall also state if fuel

oil was burned during the monitored quarter.

5.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Quarterly Report for the State Implementation Plan for Sulfur Dioxide:

Not more than 30 days after the end of each calendar quarter starting 07/28/1992,

the Permittee shall submit a report containing the following information:

1) The percent sulfur content by weight and the heating value of the fuel oil in

million British Thermal Units per gallon; and

2) A summary of any exceedances of the emission limitation, monthly fuel use

limitation and the sulfur content limitation during the calendar quarter. The report

shall provide an explanation of each exceedance which occurred or a statement

stating that no exceedances occurred. The report shall also state if fuel oil was

burned during the monitored quarter.

6.0

CD Minn. R. 7007.0800, subp. 6(C)1;

Alternative to SIP Quarterly

Report.

Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS"

shall be reported semi-annually with the Semi-annual Deviations Report required

by this permit. Reporting shall occur even if there were no deviations for this

reporting period.

7.0

8.0 CD hdr DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR

CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subp. 2

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR

Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the

actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test

at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may

result in a significant emissions increase (SEI). If the ATPA test is not used for the

project, or if there is no RP that the proposed project could result in a SEI, these

requirements do not apply to that project. The Permittee is only subject to the

Preconstruction Documentation requirement for a project where a RP occurs only

within the meaning of Section 52.21(r)(6)(vi)(b).

Even though a particular modification is not subject to New Source Review (NSR),

or where there isn't a RP that a proposed project could result in a SEI, a permit

amendment, recordkeeping, or notification may still be required by Minn. R.

7007.1150 - 7007.1500.

9.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 2 of 16 2 Jun, 2014 11:26

CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.1200, subp. 4;

Minn. R. 7007.0800, subps. 4 & 5

Preconstruction Documentation -- Before beginning actual construction on a

project, the Permittee shall document the following:

1. Project description

2. Identification of any emission unit (EU) whose emissions of an NSR pollutant

could be affected

3. Pre-change potential emissions of any affected existing EU, and the projected

post-change potential emissions of any affected existing or new EU.

4. A description of the applicability test used to determine that the project is not a

major modification for any regulated NSR pollutant, including the baseline actual

emissions, the projected actual emissions, the amount of emissions excluded due

to increases not associated with the modification and that the EU could have

accommodated during the baseline period, an explanation of why the amounts

were excluded, and any creditable contemporaneous increases and decreases that

were considered in the determination.

The Permittee shall maintain records of this documentation.

10.0

CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant

that could increase as a result of the project and that were analyzed using the

ATPA test, and the potential emissions of any regulated NSR pollutant that could

increase as a result of the project and that were analyzed using potential

emissions in the hybrid test. The Permittee shall calculate and maintain a record of

the sum of the actual and potential (if the hybrid test was used in the analysis)

emissions of the regulated pollutant, in tons per year on a calendar year basis, for

a period of 5 years following resumption of regular operations after the change, or

for a period of 10 years following resumption of regular operations after the change

if the project increases the design capacity of or potential to emit of any unit

associated with the project.

11.0

CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual,

plus potential if used in hybrid test) emissions differ from the preconstruction

projection and exceed the baseline actual emissions by a significant amount as

listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the

Agency within 60 days after the end of the year in which the exceedances occur.

The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of

the facility contact person

b. The annual emissions (actual, plus potential if any part of the project was

analyzed using the hybrid test) for each pollutant for which the preconstruction

projection and significant emissions increase are exceeded.

c. Any other information, such as an explanation as to why the summed emissions

differ from the preconstruction projection.

12.0

13.0 CD hdr OPERATIONAL REQUIREMENTS

CD Minn. Stat. Section 116.07, subds.

4a & 9; Minn. R. 7007.0100, subp.

7(A), 7(L), & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4; Minn.

R. 7009.0010-7009.0080

The Permittee shall comply with National Primary and Secondary Ambient Air

Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality

Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated

upon written request by the MPCA.

14.0

CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutes

emissions, which would otherwise violate a federal or state air pollution control

rule, without reducing the total amount of pollutant emitted.

15.0

CD Minn. R. 7007.0800, subp. 2;

Minn. R. 7007.0800, subp. 16(J)

Air Pollution Control Equipment: Operate all pollution control equipment whenever

the corresponding process equipment and emission units are operated.

16.0

CD Minn. R. 7007.0800, subps. 14

and 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and

maintenance plan for all air pollution control equipment. At a minimum, the O & M

plan shall identify all air pollution control equipment and control practices and shall

include a preventative maintenance program for the equipment and practices, a

description of (the minimum but not necessarily the only) corrective actions to be

taken to restore the equipment and practices to proper operation to meet

applicable permit conditions, a description of the employee training program for

proper operation and maintenance of the control equipment and practices, and the

records kept to demonstrate plan implementation.

17.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 3 of 16 2 Jun, 2014 11:26

CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall

immediately take all practical steps to modify operations to reduce the emission of

any regulated air pollutant. The Commissioner may require feasible and practical

modifications in the operation to reduce emissions of air pollutants. No emissions

units that have an unreasonable shutdown or breakdown frequency of process or

control equipment shall be permitted to operate.

18.0

CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or

storage of any material in a manner which may allow avoidable amounts of

particulate matter to become airborne. Comply with all other requirements listed in

Minn. R. 7011.0150.

19.0

CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R.

7030.0010 to 7030.0080 at all times during the operation of any emission units.

This is a state only requirement and is not enforceable by the EPA Administrator or

citizens under the Clean Air Act.

20.0

CD Minn. R. 7007.0800, subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and

requirements as found in Minn. R. 7007.0800, subp. 9(A).

21.0

CD Minn. R. 7007.0800, subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R.

7007.0800, subp. 16.

22.0

23.0 CD hdr PERFORMANCE TESTING

CD Minn. R. ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R.

ch. 7017 unless otherwise noted in Tables A, B, and/or C.

24.0

CD Minn. R. 7017.2018; Minn. R.

7017.2030, subps. 1-4, Minn. R.

7017.2035, subps. 1-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table

B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance

Test

Performance Test Plan: due 30 days before each Performance Test

Performance Test Pre-test Meeting: due 7 days before each Performance Test

Performance Test Report: due 45 days after each Performance Test

Performance Test Report - Microfiche Copy: due 105 days after each

Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative

format as allowed by Minn. R. 7017.2018.

25.0

CD Minn. R. 7017.2025, subp. 3 Limits set as a result of a performance test (conducted before or after permit

issuance) apply until superseded as stated in the MPCA's Notice of Compliance

letter granting preliminary approval. Preliminary approval is based on formal review

of a subsequent performance test on the same unit as specified by Minn. R.

7017.2025, subp. 3. The limit is final upon issuance of a permit amendment

incorporating the change.

26.0

27.0 CD hdr MONITORING REQUIREMENTS

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permitee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or

2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including

the date conducted, and any corrective action that resulted. The Permitee shall

include the calibration frequencies, procedures, and manufacturer's specifications

(if applicable) in the Operations and Maintenance Plan. Any requirements applying

to continuous emission monitors are listed separately in this permit.

28.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or

C, monitoring a process or control equipment connected to that process is not

necessary during periods when the process is shutdown, or during checks of the

monitoring systems, such as calibration checks and zero and span adjustments. If

monitoring records are required, they should reflect any such periods of process

shutdown or checks of the monitoring system.

29.0

30.0 CD hdr RECORDKEEPING
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 4 of 16 2 Jun, 2014 11:26

CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise

specified within this permit, for a period of five (5) years from the date of

monitoring, sample, measurement, or report. Records which must be retained at

this location include all calibration and maintenance records, all original recordings

for continuous monitoring instrumentation, and copies of all reports required by the

permit. Records must conform to the requirements listed in Minn. R. 7007.0800,

subp. 5(A).

31.0

CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as

required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms

(as required by Minn. R. 7007.1350, subp. 2), including records of the emissions

resulting from those changes.

32.0

CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is required

prior to making a change, the Permittee must retain records of all calculations

required under Minn. R. 7007.1200. For expiring permits, these records shall be

kept for a period of five years from the date the change was made or until permit

reissuance, whichever is longer. The records shall be kept at the stationary source

for the current calendar year of operation and may be kept at the stationary source

or office of the stationary source for all other years. The records may be

maintained in either electronic or paper format.

33.0

34.0 CD hdr REPORTING/SUBMITTALS

CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a

planned shutdown of any control equipment or process equipment if the shutdown

would cause any increase in the emissions of any regulated air pollutant. If the

owner or operator does not have advance knowledge of the shutdown, notification

shall be made to the Commissioner as soon as possible after the shutdown.

However, notification is not required in the circumstances outlined in Items A, B

and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of

the cause of the shutdown and the estimated duration. The owner or operator shall

notify the Commissioner when the shutdown is over.

35.0

CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown

of more than one hour duration of any control equipment or process equipment if

the breakdown causes any increase in the emissions of any regulated air pollutant.

The 24-hour time period starts when the breakdown was discovered or reasonably

should have been discovered by the owner or operator. However, notification is not

required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,

subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated

duration. The owner or operator shall notify the Commissioner when the

breakdown is over.

36.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon

as possible after discovery, notify the Commissioner or the state duty officer, either

orally or by facsimile, of any deviation from permit conditions which could

endanger human health or the environment.

37.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:

Within 2 working days of discovery, notify the Commissioner in writing of any

deviation from permit conditions which could endanger human health or the

environment. Include the following information in this written description:

1. the cause of the deviation;

2. the exact dates of the period of the deviation, if the deviation has been

corrected;

3. whether or not the deviation has been corrected;

4. the anticipated time by which the deviation is expected to be corrected, if not

yet corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation.

38.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year

following Permit Issuance. The first semiannual report submitted by the Permittee

shall cover the calendar half-year in which the permit is issued. The first report of

each calendar year covers January 1 - June 30. The second report of each

calendar year covers July 1 - December 31. If no deviations have occurred, the

Permittee shall submit the report stating no deviations.

39.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 5 of 16 2 Jun, 2014 11:26

CD Minn. R. 7007.1150 - 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

40.0

CD Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of existing

permit.

41.0

CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment

to extend a deadline in a permit by no more than 120 days, provided the proposed

deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and

pt. 63 are examples of deadlines for which the MPCA does not have authority to

grant extensions and therefore do not meet the requirements of Minn. R.

7007.1400, subp. 1(H).

42.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year following

Permit Issuance (for the previous calendar year). The Permittee shall submit this

to the Commissioner on a form approved by the Commissioner. This report covers

all deviations experienced during the calendar year.

43.0

CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: Due on or before April 1 of each calendar year

following permit issuance, to be submitted on a form approved by the

Commissioner.

44.0

45.0 CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 6 of 16 2 Jun, 2014 11:26

Subject Item: GP 001 Electric Generating Combustion Turbines

Associated Items: EU 001 Combustion Turbine 1

EU 002 Combustion Turbine 2

EU 003 Combustion Turbine 3

EU 004 Combustion Turbine 4

EU 005 Combustion Turbine 5

EU 006 Combustion Turbine 6

NC/

CA

Type Citation Requirement

CD hdr The requirements of this group apply individually to each associated item in this

group unless specified.

1.0

2.0 CD hdr EMISSION AND OPERATIONAL REQUIREMENTS

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

3.0

LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2; Minn. R.

7011.2300, subp. 2

4.0 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input

LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

Sulfur Content of Fuel: less than or equal to 0.48 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS LIMIT WILL BE TERMINATED ON THE DATE THE USEPA APPROVES

THE REVISION TO THE SIP.

5.0

LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

Sulfur Content of Fuel: less than or equal to 0.005 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

6.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

7.0 Allowable Fuel Types: Distillate fuel oil and natural gas.

LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Total Combined Distillate Fuel Usage: less than or equal to 9.41 million

gallons/month using 12-month Rolling Average

8.0

9.0 CD hdr MONITORING REQUIREMENTS

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

10.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 7 of 16 2 Jun, 2014 11:26

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 3) If the fuel delivery sample analysis result is no greater than 0.48% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.10% by weight. The sulfur

content will be assured by:

11.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.48 percent

by weight; and by

 2) Sampling and analyzing the fuel in accordance with the following:

 a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

12.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 c) If any delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

13.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

14.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 8 of 16 2 Jun, 2014 11:26

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 3) If the fuel delivery sample analysis result is no greater than 0.005% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.005% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.0015% by weight. The sulfur

content will be assured by:

15.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.0015

percent by weight; and by

 2) Sampling and analyzing the fuel in accordance with the following:

 a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

16.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

 c) If any delivery sample analysis result is greater than 0.0015% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

17.0

18.0 CD hdr RECORDKEEPING

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Fuel Supplier Certification or Guarantee: Keep on site a copy of the fuel supplier

certification or guarantee identifying the type of fuel oil and the percent by weight

sulfur content range.

19.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Daily Recordkeeping: On each day of operation, the Permittee shall record the

total quantity of all fuel used at the facility. This shall be based on flowmeters.

20.0

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Fuel Usage Recordkeeping: By the 15th day of each month, the Permittee shall

use daily fuel usage records to calculate the monthly fuel usage on a 12-month

rolling average basis.

21.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 9 of 16 2 Jun, 2014 11:26

CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 5

SO2, and Emissions and Operating Records.

The Permittee shall generate and maintain records containing information to

demonstrate compliance with the emission limitation and operating requirements.

The Permittee shall retain records containing the following information:

 1) The results of the fuel oil analyses for sulfur content (percent by weight) and

heating value (million British Thermal Units per gallon), the date the fuel oil was

sampled, and the methods used to sample the fuel oil and determine the sulfur

content and heating value of the fuel oil.

 2) Monthly and 12-month rolling average fuel oil use. The records shall be

signed by the person entering information into the record.

22.0

CD Minn. R. 7007.0800, subp. 4 and

5

The Permittee shall install, calibrate, maintain and operate flowmeters for all fuel

used at the facility.

23.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 10 of 16 2 Jun, 2014 11:26

Subject Item: GP 002 Emergency Diesel Generators

Associated Items: EU 007 Diesel Generator 1 ODG-GEN-001

EU 008 Diesel Generator 2 ODG-GEN-002

NC/

CA

Type Citation Requirement

CD hdr The requirements of this group apply individually to each associated item in this

group, unless specified.

1.0

2.0 CD hdr EMERGENCY RICE DEFINITION

CD 40 CFR Section 63.6640(f); Minn.

R. 7011.8150

The Permittee shall operate EU 007 and EU 008 according to the requirements in

paragraphs 40 CFR Section 63.6640 (f)(1) through (3). Any operation other than

emergency operation, maintenance and testing, emergency demand response,

and operation in non-emergency situations for 50 hours per year, as described in

40 CFR Section 63.6640(f)(1) through (3), is prohibited. If the engine is not

operated according to the requirements in 40 CFR Section 63.6640(f)(1) through

(3), the engine will not be considered an emergency engine under this subpart and

will need to meet all requirements for non-emergency engines.

(continued below)

3.0

CD 40 CFR Section 63.6640(f)(1) -

(2); Minn. R. 7011.8150

(1) There is no time limit on the use of emergency stationary RICE in emergency

situations.

(2) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) counts as

part of the 100 hours per calendar year allowed by this paragraph (f)(2).

4.0

CD 40 CFR Section 63.6640(f)(2)(i);

Minn. R. 7011.8150

2(i) The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indicating that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per

calendar year.

5.0

CD 40 CFR Section 63.6640(f)(2)(ii) -

(2)(iii); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14),

or other authorized entity as determined by the Reliability Coordinator, has

declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability

Standard EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

6.0

CD 40 CFR Section 63.6640(f)(3);

Minn. R. 7011.8150

(3) Emergency stationary RICE located at major sources of HAP may be operated

for up to 50 hours per calendar year in non-emergency situations. The 50 hours of

operation in non-emergency situations are counted as part of the 100 hours per

calendar year for maintenance and testing and emergency demand response

provided in 40 CFR Section 63.6640(f)(2) above. The 50 hours per year for

non-emergency situations cannot be used for peak shaving or non-emergency

demand response, or to generate income for a facility to supply power to an

electric grid or otherwise supply power as part of a financial arrangement with

another entity.

7.0

8.0 CD hdr EMISSION AND OPERATING LIMITS

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

9.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 11 of 16 2 Jun, 2014 11:26

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the unit is 0.05 lb/MMBtu due to equipment design and allowable

fuels.

10.0

CD 40 CFR Section 72.7(a)(2); Minn.

R. 7007.1075; Minn. R.

7005.0100, subp. 35a

11.0 Fuel Type: Distillate oil only, by design.

LIMIT 40 CFR Section 72.7(a)(3); Minn.

R. 7007.1075

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight on an annual

average.

12.0

LIMIT Title I Condition: To avoid

classification as a major

modification under 40 CFR

Section 52.21 and Minn. R.

7007.3000

Operating Hours: less than or equal to 816 hours/year using 12-month Rolling Sum

as a total for GP 002.

13.0

14.0 CD hdr MONITORING AND RECORDKEEPING

CD 40 CFR Section 72.7; Minn. R.

7007.0800, subp. 4 and 5

The Permittee shall obtain from the fuel supplier a certificate or other record

indicating that the fuel delivered for use in the GP 002 emission units has a sulfur

content less then or equal to 0.05 percent by weight on a 12-month annual

average.

15.0

CD 40 CFR Section 72.7(d)(3); Minn.

R. 7007.1075

Average Annual Suflur Content Determination

The Permittee shall calculate the annual average sulfur content, as a percentage

by weight, using the equation in 40 CFR Section 72.7(d)(2). In lieu of the factor,

volume times density, in the equation, the factor, mass (Mn), may be used, where

Mn is: mass of the nongaseous fuel in a delivery during the year to the unit of

which the nth sample is taken, in lb.

Fuel shall be sampled at least once for every delivery.

16.0

CD 40 CFR Section 72.7(f)(3); Minn.

R. 7007.1075

For a period of 5 years from the date the records are created, the Permittee shall

retain at the source records demonstrating that the requirements of 40 CFR

Section 72.7(a) are met. The 5-year period for keeping records may be extended

for cause, at any time prior to the end of the period, in writing by the Administrator

or the permitting authority.

(i) Such records shall include, for each delivery of fuel to the unit, the type of fuel,

the sulfur content, and the sulfur content of each sample taken.

(ii) The Permittee bears the burden of proof that the requirements of 40 CFR

Section 72.7(a) are met.

17.0

CD 40 CFR Section 72.7(f)(4)(i);

Minn. R. 7007.1075

Loss of exemption. An exempt unit shall be treated as an affected unit under the

Acid Rain Program on the earliest of the following dates:

(A) The date on which the unit first serves one or more generators with total

nameplate capacity in excess of 25 MWe;

(B) The date on which the unit burns any coal or coal-derived fuel except for

coal-derived gaseous fuel with a total sulfur content no greater than natural gas; or

(C) January 1 of the year following the year in which the annual average sulfur

content for nongaseous fuel burned at the unit exceeds 0.05 percent by weight (as

determined under 40 CFR Section 72.7(d)).

18.0

CD Title I Condition: To avoid

classification as a major

modification under 40 CFR

Section 52.21 and Minn. R.

7007.3000

For each day of operation of any GP 002 emission unit(s), record the operating

start and stop times. By the 15th of each month, calculate and record the total

combined GP 002 operating hours for the previous month, and for the previous

12-month period (12-month rolling sum).

19.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 12 of 16 2 Jun, 2014 11:26

Subject Item: GP 005 Emergency Diesel Engines

Associated Items: EU 009 Fire Pump diesel engine

EU 010 Substation black start diesel generator

NC/

CA

Type Citation Requirement

CD hdr The requirements of this group apply individually to each associated item in this

group.

1.0

2.0 CD hdr EMISSION AND OPERATIONAL REQUIREMENTS

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

3.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the units is 0.29 lb/MMBtu due to equipment design and allowable

fuels.

4.0

CD 40 CFR Section 63.4(b); Minn. R.

7011.7000

Circumvention: The Permittee shall not build, erect, install, or use any article,

machine, equipment, or process to conceal an emission that would otherwise

constitute noncompliance with a relevant standard. Such concealment includes,

but is not limited to:

(1) The use of diluents to achieve compliance with a relevant standard based on

the concentration of a pollutant in the effluent discharged to the atmosphere or

(2) The use of gaseous diluents to achieve compliance with a relevant standard for

visible emissions.

5.0

CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Change oil and filter every 500 hours of operation or annually, whichever comes

first. The Permittee has the option of utilizing an oil analysis program in order to

extend the oil change requirement as described below.

6.0

CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Inspect air cleaner every 1,000 hours of operation or annually, whichever comes

first, and replace as necessary.

7.0

CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Inspect all hoses and belts every 500 hours of operation or annually, whichever

comes first, and replace as necessary.

8.0

CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle and minimize the

engine's startup time at startup to a period needed for appropriate and safe loading

of the engine, not to exceed 30 minutes, after which time the non-startup emission

limitations apply.

9.0

CD 40 CFR Section 63.6605(a); Minn.

R. 7011.8150

The Permittee shall be in compliance with the emission limitations and operating

limitations in this subpart that apply at all times.

10.0

CD 40 CFR Section 63.6605(b); Minn.

R. 7011.8150

At all times the Permittee shall operate and maintain EU 009 and EU 010,

including associated air pollution control equipment and monitoring equipment, in a

manner consistent with safety and good air pollution control practices for

minimizing emissions. The general duty to minimize emissions does not require

the Permittee to make any further efforts to reduce emissions if levels required by

this standard have been achieved. Determination of whether such operation and

maintenance procedures are being used will be based on information available to

the Administrator which may include, but is not limited to, monitoring results,

review of operation and maintenance procedures, review of operation and

maintenance records, and inspection of the source.

11.0

CD 40 CFR Section 63.6625(e); Minn.

R. 7011.8150

The Permittee shall operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer's emission-related written

instructions or develop a maintenance plan which must provide to the extent

practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

12.0

CD 40 CFR Section 63.6625(f); Minn.

R. 7011.8150

The Permittee shall install a non-resettable hour meter on EU 009 and EU 010 if

one is not already installed by the compliance date.

13.0

CD 40 CFR Section 63.6625(h); Minn.

R. 7011.8150

The Permittee shall minimize the engine's time spent at idle during startup and

minimize the engine's startup time to a period needed for appropriate and safe

loading of the engine, not to exceed 30 minutes, after which time the emission

standards applicable to all times other than startup apply.

14.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 13 of 16 2 Jun, 2014 11:26

CD 40 CFR Section 63.6625(i); Minn.

R. 7011.8150

The Permittee has the option of utilizing an oil analysis program in order to extend

the specified oil change requirement. The oil analysis must be performed at the

same frequency specified for changing the oil. The analysis program must at a

minimum analyze the following 3 parameters: Total Base Number, viscosity, and

percent water content. The condemning limits for these parameters are as follows:

Total Base Number is less than 30 percent of the Total Base Number of the oil

when new; viscosity of the oil has changed by more than 20 percent from the

viscosity of the oil when new; or percent water content (by volume) is greater than

0.5.

(continued below)

15.0

CD 40 CFR Section 63.6625(i); Minn.

R. 7011.8150

(continued from above)

If none of the condemning limits are exceeded, the engine owner or operator is not

required to change the oil. If any of the limits are exceeded, the engine owner or

operator must change the oil within 2 business days of receiving the results of the

analysis; if the engine is not in operation when the results of the analysis are

received, the engine owner or operator must change the oil within 2 business days

or before commencing operation, whichever is later. The owner or operator must

keep records of the parameters that are analyzed as part of the program, the

results of the analysis, and the oil changes for the engine. The analysis program

must be part of the maintenance plan for the engine.

16.0

CD 40 CFR Section 63.6640(a); Minn.

R. 7011.8150

The Permittee shall demonstrate continuous compliance with each emission

limitation and operating limitation in Table 2c of 40 CFR pt. 63, subp. ZZZZ that

apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ.

17.0

CD 40 CFR Section 63.6640(a); 40

CFR Section 63.6655(d); 40 CFR

pt. 63 subp. ZZZZ, Table 6; Minn.

R. 7011.8150

The Permittee shall operate and maintain the stationary RICE according to the

manufacturer's emission related operation and maintenance instructions; or the

Permittee shall develop and follow a maintenance plan which shall provide to the

extent practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

18.0

CD 40 CFR Section 63.6665; 40 CFR

pt. 63 subp. ZZZZ, Table 8; Minn.

R. 7011.8150

The Permittee shall comply with the General Provisions in 40 CFR Section 63.1

through 63.15, as applicable.

19.0

20.0 CD hdr REQUIREMENTS FOR EMERGENCY STATIONARY RICE

CD 40 CFR Section 63.6640(f); Minn.

R. 7011.8150

The Permittee shall operate the emergency stationary RICE according to the

requirements in paragraphs 40 CFR Section 63.6640 (f)(1) through (4) of 40 CFR

Section 63.6640(f). Any operation other than emergency operation, maintenance

and testing, emergency demand response, and operation in non-emergency

situations for 50 hours per year, as described in 40 CFR Section 63.6640(f)(1)

through (4), is prohibited. If the engine is not operated according to the

requirements in 40 CFR Section 63.6640(f)(1) through (4), the engine will not be

considered an emergency engine under this subpart and will need to meet all

requirements for non-emergency engines.

21.0

CD 40 CFR Section 63.6640(f)(1) -

(2); Minn. R. 7011.8150

(1) There is no time limit on the use of emergency stationary RICE in emergency

situations.

(2) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) and (4)

counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

22.0

CD 40 CFR Section 63.6640(f)(2)(i);

Minn. R. 7011.8150

The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indication that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per year.

23.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 14 of 16 2 Jun, 2014 11:26

CD 40 CFR Section 63.6640(f)(2)(ii) -

(2)(iii); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see Section 63.14), or other

authorized entity as determined by the Reliability Coordinator, has declared an

Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard

EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

24.0

CD 40 CFR Section 63.6640(f)(3);

Minn. R. 7011.8150

The Permittee may operate the emergency stationary RICE up to 50 hours per

calendar year in non-emergency situations, but those 50 hours are counted

towards the 100 hours per calendar year provided for maintenance and testing and

emergency demand response provided in 40 CFR Section 63.6640(f)(2). The 50

hours per year for non-emergency situations cannot be used for peak shaving or

non-emergency demand response, or to generate income for a facility to supply

power to an electric grid or otherwise supply power as part of a financial

arrangement with another entity.

25.0

26.0 CD hdr RECORDKEEPING REQUIREMENTS

CD 40 CFR Section 63.10(b)(1); Minn.

R. 7019.0100, subp. 2(B)

The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a

form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, or record.

Except that the most recent 2 years of data do not have to be retained on site.

27.0

CD 40 CFR Section 63.6655(d); Minn.

R. 7011.8150

The Permittee shall keep the records required in Table 6 of 40 CFR pt 63, subp.

ZZZZ, to show continuous compliance with each emission or operating limitation

that applies.

28.0

CD 40 CFR Section 63.6655(e); Minn.

R. 7011.8150

The Permittee shall keep records of the maintenance conducted on the stationary

RICE in order to demonstrate that the Permittee operated and maintained the

stationary RICE and after-treatment control device (if any) according to the

maintenance plan.

29.0

CD 40 CFR Section 63.6655(f); Minn.

R. 7011.8150

The Permittee shall keep records of the hours of operation of the engine that are

recorded through the non-resettable hour meter. The Permittee shall document

how many hours are spent for emergency operation; including what classified the

operation as emergency and how many hours are spent for non-emergency

operation. If the engine is used for demand response operation, the Permittee shall

keep records of the notification of the emergency situation, and the time the engine

was operated as part of demand response.

30.0

CD 40 CFR Section 63.6660; 40 CFR

Section 63.10(b)(1); Minn. R.

7011.8150; Minn R. 7019.0100,

subp. 2(B)

The Permittee shall maintain all records in a form suitable and readily available for

expeditious review according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record

for 5 years following the date of each occurrence, measurement, maintenance,

corrective action, report, or record.

The Permittee shall keep each record readily accessible in hard copy or electronic

form for at least 5 years after the date of each occurrence, measurement,

maintenance, corrective action, report, or record, according to 40 CFR section

63.10(b)(1).

31.0

32.0 CD hdr REPORTING AND NOTIFICATION REQUIREMENTS

CD 40 CFR Section 63.6640(b); Minn.

R. 7011.8150

The Permittee shall report each instance in which the stationary RICE did not meet

each applicable emission limitation or operating limitation. These instances are

deviations from the emission and operating limitations. These deviations shall be

reported according to the requirements in 40 CFR Section 63.6650.

33.0

CD 40 CFR Section 63.6640(e); 40

CFR pt. 63, subp. ZZZZ, Table 8;

Minn. R. 7011.8150

The Permittee shall report each instance when the applicable requirements in

Table 8 of 40 CFR pt. 63, subp. ZZZZ were not met.

34.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 15 of 16 2 Jun, 2014 11:26

CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

The Permittee shall report any failure to perform the work practice on the schedule

required in 40 CFR pt. 63, Table 2c due to an emergency or an unacceptable risk

under Federal, State or local law. The work practice shall be performed as soon as

practicable after the emergency has ended or the unacceptable risk under Federal,

State, or local law has abated.

35.0
MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Page 16 of 16 2 Jun, 2014 11:26

Subject Item: TK 001 distillate oil

NC/

CA

Type Citation Requirement

1.0 CD hdr EMISSION AND OPERATIONAL LIMITS

2.0 CD Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity.
Xcel Energy – Inver Hills Generating Plant

03700015-004

Attachment 3

Points Calculator
Points-Based Fee Calculator

Worksheet in ole_main (DQ 4168)

1) AQ Facility ID No.: 03700015 Total Points 0

2) Facility Name: Xcel Energy - Inver Hills Generating Plant

3) Small business? y/n? No 

4) DQ Numbers (including all rolled) : 3467 

5) Date of each Application Received: 12/12/2013

6) Final Permit No. 03700015-004

7) Permit Staff Robert Little

8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)? No

Application Type DQ No. Qty. Points Total Points Details

Administrative Amendment 1 0

Minor Amendment 4 0

Applicability Request 10 0

Moderate Amendment 15 0

Major Amendment 25 0

Individual State Permit - First Time 50 0

Individual Part 70 Permit - First Time 75 0

Additional Points

Modeling Review 15 0

BACT Review 15 0

LAER Review 15 0

CAIR/Part 75 CEM analysis 10 0

NSPS Review 10 0

NESHAP Review 10 0

Case-by-case MACT Review 20 0

Netting 10 0

Limits to remain below threshold 10 0

Plantwide Applicability Limit (PAL) 20 0

AERA review 15 0

Variance request under 7000.7000 35 0

Confidentiality request under 7000.1300 2 0

EAW review

Part 4410.4300, subparts 18, item A; and 29 15 0

Part 4410.4300, subparts 8, items A & B; 10, items A 

to C; 16, items A & D; 17, items A to C & E to G; and 

18, items B & C

35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, 

items B & C; and 17 item D

70 0

NOTES: 
Xcel Energy – Inver Hills Generating Plant

03700015-004

Attachment 4

Supplier Guarantee



Attachment 2: Permit No. 03700015-003 issued to Inver Hills (SIP2 relevant) 

Permit No. 03700015-003 can also be found online: http://www.pca.state.mn.us/index.php/viewdocument.html?gid=1930. 
TDD (for hearing and speech impaired only): (651) 282-5332 

Printed on recycled paper containing at least 10% fibers from paper recycled by consumers 

AIR EMISSION PERMIT NO. 03700015- 003 

(Part 70 Reissuance) 

IS ISSUED TO

Northern States Power Co dba Xcel Energy 

XCEL ENERGY – INVER HILLS GENERATING PLANT 

3185 117th Street East 

Inver Grove Heights, Dakota County, MN 55077 

The emission units, control equipment and emission stacks at the stationary source authorized in this 

permit are as described in the following permit application(s): 

Permit Type Application Date 

Total Facility Operating Permit 

Major Amendment 11/20/2002 

Total Facility Operating Permit - Reissuance 9/30/2004 

This permit authorizes the Permittee to operate the stationary source at the address listed above unless 

otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any 

changes or modifications to the stationary source must be performed in compliance with Minn. R. 

7007.1150 to 7007.1500, and any additions or changes to conditions incorporated into Minnesota’s State

Implementation Plan (SIP) under 40 CFR § 52.1220, designated “Title I Condition: State Implementation

Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP” must go through the federal SIP approval 

process before becoming effective. Terms used in the permit are as defined in the state air pollution

control rules unless the term is explicitly defined in the permit. 

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated 

into the SIP under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection 

Agency (EPA) Administrator or citizens under the Clean Air Act. 

Permit Type: Federal; Pt 70; Title I SIP Conditions (SO2)

Issue Date: October 27, 2006 

Expiration: October 27, 2011 

All Title I Conditions do not expire. 

 

 Richard J. Sandberg, Manager 

 Air Quality Permits Section 

 Industrial Division 

 

for Brad Moore 

 Acting Commissioner 

 Minnesota Pollution Control Agency 
TABLE OF CONTENTS 

Notice to the Permittee 

Permit Shield 

Facility Description 

Table A: Limits and Other Requirements 

Table B: Submittals 

Table C: Compliance Schedule 

Appendix A: Operator’s Summary (Not used in this permit) 

Appendix B: Insignificant Activities 

Appendix C: New Unit Exemptions for EU007 and EU008 
NOTICE TO THE PERMITTEE: 

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s 

(MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on

these programs, including information on obtaining any required permits, please contact the MPCA 

general information number at: 

 Metro Area (651) 296-6300 

 

 Outside Metro Area 1-800-657-3864 

 TTY (651) 282-5332 

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be

sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. 

Questions about this air emission permit or about air quality requirements can also be directed to the

telephone numbers and address listed above. 

PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be 

deemed compliance with the specific provision of the applicable requirement identified in the permit as 

the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2,

notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, 

any person (including the Permittee) may also use other credible evidence to establish compliance or 

noncompliance with applicable requirements. 
FACILITY DESCRIPTION: 

Xcel Energy’s Inver Hills Generating Plant is a peak electrical generation facility with a capacity of 440 

megawatts. The facility is on call to operate, as needed, any or all of six identical pre-NSPS General 

Electric primary turbine/generator sets. Each turbine is capable of using natural gas, distillate oil, or 

residual oil as a fuel source. Historically, natural gas has been the primary fuel source. Fuel oil is most 

frequently used during curtailment of the natural gas supply. The turbines commenced operation prior to 

November 15, 1990; thus, they are not subject to Title IV of the Clean Air Act (the Acid Rain 

Provisions).

The Inver Hills Generating Plant also has two post-1990 Caterpillar emergency diesel-fired reciprocating 

internal combustion engine generators. The Permittee has applied for a new unit exemption and agreed to 

limit diesel fuel sulfur content to 0.05 percent by weight. 

Another activity at the site is the storage of distillate oil and other petroleum products in ten milliongallon above-ground storage tanks. There are also several insignificant sources. 

PER 003 

Air Emission Permit No. 03700015-003 is the reissuance of the Part 70 permit for the Xcel Energy – Inver 

Hills Generating Plant. It supersedes Air Emission Permit No. 03700015-002. The permit does not authorize 

any new construction or physical modifications, although some changes have been made to the permit 

primarily to facilitate changes to SIP. 

The SIP conditions in the permit ensure that the air quality in the area around the Inver Hills Generating 

Plant (the Pine Bend area) remain in compliance with the National Ambient Air Quality Standards 

(NAAQS) for sulfur dioxide. This permit streamlines the facility’s SIP requirements. In doing so, the 

permit becomes more restrictive (i.e., more protective of the NAAQS). The Title I SIP conditions in the 

permit will be submitted to the EPA for its approval of the changes to the SIP. 

A small number of housekeeping changes have also been made in this permit. 
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of

the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must

take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)

lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility

requirements.

Subject Item: Total Facility

What to do Why to do it

 A. OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with the General Conditions listed in Minn. R.

7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.

7030.0010 to 7030.0080 at all times during the operation of any emission units.

This is a state only requirement and is not enforceable by the EPA Administrator or

citizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: Upon presentation of credentials and other documents as may be

required by law, allow the Agency, or its representative, to enter the Permittee's

premises to have access to and copy any records required by this permit, to inspect

at reasonable times (which include any time the source is operating) any facilities,

equipment, practices or operations, and to sample or monitor any substances or

parameters at any location.

Minn. R. 7007.0800, subp. 9(A)

Circumvention: Do not install or use a device or means that conceals or dilutes

emissions, which would otherwise violate a federal or state air pollution control rule,

without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall

immediately take all practical steps to modify operations to reduce the emission of

any regulated air pollutant. The Commissioner may require feasible and practical

modifications in the operation to reduce emissions of air pollutants. No emissions

units that have an unreasonable shutdown or breakdown frequency of process or

control equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Parameters Used in Modeling: The stack heights, emission rates, and other

parameters used in the modeling for the SO2 SIP are listed in GP 003 of this

permit. The Permittee must submit to the Commissioner for approval any revisions

of these parameters and must wait for a written approval before making such

changes. The information submitted must include, at a minimum, the locations,

heights and diameters of the stacks, locations and dimensions of nearby buildings,

the velocity and temperatures of the gases emitted, and the emission rates. The

plume dispersion charateristics due to the revisions of the information must be

equivalent to or better than the dispersion characteristics modeled in the SO2 SIP

submittal. The Permittee shall demonstrate this equivalency in the proposal. If the

information does not demonstrate equivalent or better dispersion characteristics, or

if a conclusion cannot readily be made about the dispersion, the Permittee must

remodel.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7009.0020

The Permittee shall comply and upon written request demonstrate compliance, with

National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50,

and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to

7009.0080.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &

9; Minn. R. 7007.0100, supbs. 7A, 7L & 7M; Minn. R.

7007.0800, subps. 1, 2 & 4; Minn. R.

7009.0100-7009.0080.

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or

storage of any material in a manner which may allow avoidable amounts of

particulate matter to become airborne. Comply with all other requirements listed in

Minn. R. 7011.0150.

Minn. R. 7011.0150

 B. POLLUTION CONTROL EQUIPMENT REQUIREMENTS hdr

Air Pollution Control Equipment: Operate all pollution control equipment whenever

the corresponding process equipment and emission units are operated, unless

otherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,

subp. 16(J)

 C. TESTING REQUIREMENTS hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.

ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table

B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Test

Performance Test Plan: due 30 days before each Performance Test

Performance Test Pre-test Meeting: due 7 days before each Performance Test

Performance Test Report: due 45 days after each Performance Test

Performance Test Report - Microfiche Copy: due 105 days after each Performance

Test

The Notification, Test Plan, and Test Report may be submitted in alternative format

as allowed by Minn. R. 7017.2018.

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.

R. 7017.2035, subp. 1-2

Operating and/or production limits will be placed on emission units based on

operating conditions during performance testing. Limits set as a result of a

performance test (conducted before or after permit issuance) apply until new

operating/production limits are set following formal review of a performance test as

specified by Minn. R. 7017.2025.

Minn. R. 7017.2025

The results of a performance test are not final until issuance of a review letter by

MPCA, unless specified otherwise by Minn R. 7017.2001 - 7017.2060.

Minn. R. 7017.2020, subp. 4

 D. MONITORING REQUIREMENTS hdr

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or

C, monitoring a process or control equipment connected to that process is not

necessary during periods when the process is shutdown, or during checks of the

monitoring systems, such as calibration checks and zero and span adjustments. If

monitoring records are required, they should reflect any such periods of process

shutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

Monitoring Equipment Calibration: Annually calibrate all required monitoring

equipment (any requirements applying to continuous emission monitors are listed

separately in this permit).

Minn. R. 7007.0800, subp. 4(D)

 E. RECORDKEEPING hdr

Recordkeeping: Maintain records describing any insignificant modifications (as

required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as

required by Minn. R. 7007.1350 subp. 2), including records of the emissions

resulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

Recordkeeping: Retain all records at the stationary source for a period of five (5)

years from the date of monitoring, sample, measurement, or report. Records which

must be retained at this location include all calibration and maintenance records, all

original recordings for continuous monitoring instrumentation, and copies of all

reports required by the permit. Records must conform to the requirements listed in

Minn. R. 7007.0800, subp. 5(A).

Minn. R. 7007. 0800, subp. 5(C)

State Implementation Plan Recordkeeping: Retain all records at the stationary

source for a period of five (5) years from the date of the required monitoring,

sample, measurement, or report that corresponds with the "Title I Condition: State

Implementation Plan for SO2" requirement.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Operation and Maintenance Plan: Retain at the stationary source an operation and

maintenance plan for all air pollution control equipment.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,

subp. 16(J)

 F. REPORTING hdr

Oral or Written (faxed) Notification of Deviations Endangering Human Health or the

Environment: As soon as possible after discovery, notify the Commissioner or the

state duty officer, either orally or by facsimile, of any deviation from permit

conditions which could endanger human health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:

Within 2 working days of discovery, notify the Commissioner in writing of any

deviation from permit conditions which could endanger human health or the

environment. Include the following information in this written description:

1. the cause of the deviation;

2. the exact dates of the period of the deviation, if the deviation has been corrected;

3. whether or not the deviation has been corrected;

4. the anticipated time by which the deviation is expected to be corrected, if not yet

corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation.

Minn. R. 7019.1000, subp. 1
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown

of more than one hour duration of any control equipment or process equipment if

the breakdown causes any increase in the emissions of any regulated air pollutant.

The 24-hour time period starts when the breakdown was discovered or reasonably

should have been discovered by the owner or operator. However, notification is not

required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,

subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated

duration. The owner or operator shall notify the Commissioner when the

breakdown is over.

Minn. R. 7019.1000, subp. 2

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a

planned shutdown of any control equipment or process equipment if the shutdown

would cause any increase in the emissions of any regulated air pollutant. If the

owner or operator does not have advance knowledge of the shutdown, notification

shall be made to the Commissioner as soon as possible after the shutdown.

However, notification is not required in the circumstances outlined in Items A, B

and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of

the cause of the shutdown and the estimated duration. The owner or operator shall

notify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment

to extend a deadline in a permit by no more than 120 days, provided the proposed

deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Deviations from requirements cited as "Title I Conditions: State Implementation

Plan for SO2" shall be reported semi-annually with the Semi-annual Deviations

Report required by this permit. Reporting shall occur even if there were no

deviations for this reporting period.

Minn. R. 7007.0800, subp. 6(C)1; Alternative to SIP

Quarterly Report.

Quarterly Report for the State Implementation Plan for Sulfur Dioxide:

Not more than 30 days after the end of each calendar quarter starting 07/28/1992,

the Permittee shall submit a report containing the following information:

1) The percent sulfur content by weight and the heating value of the fuel oil in

million British Thermal Units per gallon; and

2) A summary of any exceedances of the emission limitation, monthly fuel use

limitation and the sulfur content limitation during the calendar quarter. The report

shall provide an explanation of each exceedance which occurred or a statement

stating that no exceedances occurred. The report shall also state if fuel oil was

burned during the monitored quarter.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Emissions Inventory Report: due 91 days after end of each calendar year following

permit issuance (April 1). To be submitted on a form approved by the

Commissioner.

Minn. R. 7019.3000 through 7019.3010

G. DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW

SOURCE REVIEW

hdr

These requirements apply where there is a reasonable possibility that a proposed

project, analyzed using the actual-to-projected-actual (ATPA) test and found to not

be part of a major modification, may result in a significant emissions increase. If

the ATPA test is not used for a particular project, or if there is not a reasonable

possibility that the proposed project could result in a significant emissions increase,

then these requirements do not apply to that project.

Even though a particular modification is not subject to New Source Review, a

permit amendment, recordkeeping, or notification may still be required under Minn.

R. 7007.1150 - 7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.

R. 7007.3000
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-4

Preconstruction Documentation -- Before beginning actual construction on a

project, the Permittee shall document the following information:

1. A description of the project

2. Identification of the emission unit(s) whose emissions of an NSR pollutant could

be affected

3. A description of the applicability test used to determine that the project is not a

major modification for any regulated NSR pollutant, including the baseline actual

emissions, the potential emissions, the projected actual emissions, the amount of

emissions excluded due to increases not associated with the modification and that

the unit(s) could have accommodated during the baseline period, an explanation of

why the amounts were excluded, and any creditable contemporaneous increases

and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.

R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant

that could increase as a result of the project and that were analyzed using the

ATPA test, and the potential emissions of any regulated NSR pollutant that could

increase as a result of the project and that were analyzed using potential

emissions. The Permittee shall calculate and maintain a record of the sum of the

actual and potential (if used in the analysis) emissions of the regulated pollutant, in

tons per year on a calendar year basis, for a period of 5 years following resumption

of regular operations after the change, or for a period of 10 years following

resumption of regular operations after the change if the project increases the

design capacity of or potential to emit of any unit associated with the project.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.

R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual

plus potential, if applicable) emissions differ from the preconstruction projection and

exceed the baseline actual emissions by a significant amount as listed at 40 CFR

Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days

after the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of

the facility contact person

b. The annual emissions (actual plus potential, if any part of the project was

analyzed using potential emissions) for each pollutant for which the preconstruction

projection and significant emissions increase are exceeded.

c. Any other information, such as an explanation as to why the summed emissions

differ from the preconstruction projection.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.

R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-5

Subject Item: GP 001 Electric Generating Combustion Turbines

Associated Items: EU 001 Combustion Turbine 1

EU 002 Combustion Turbine 2

EU 003 Combustion Turbine 3

EU 004 Combustion Turbine 4

EU 005 Combustion Turbine 5

EU 006 Combustion Turbine 6

SV 001 Stack 1, Gas Turbine 1

SV 002 Stack 2, Gas Turbine 2

SV 003 Stack 3, Gas Turbine 3

SV 004 Stack 4, Gas Turbine 4

SV 005 Stack 5, Gas Turbine 5

SV 006 Stack 6, Gas Turbine 6

What to do Why to do it

EMISSION AND OPERATIONAL LIMITS hdr

Opacity: less than or equal to 20 percent once operating temperatures have been

attained. This limit applies to each unit individually.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.67 lbs/million Btu heat input on an

instantaneous basis. This limit applies to each unit individually.

THIS LIMIT WILL BE TERMINATED ON THE DATE THE USEPA APPROVES

THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP;

allowed under Minn. R. 7011.2300, subp. 2

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input on an

instantaneous basis. This limit applies to each unit individually.

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 2; Minn. R. 7011.2300, subp. 2

Allowable Fuel Types: Distillate fuel oil, residual fuel oil, and natural gas.

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 2

Allowable Fuel Types: Distillate fuel oil and natural gas.

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 2

Fuel Oil Usage: Not to exceed 9.41 million gallons per month on a 12-month rolling

average basis.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Sulfur Content of Fuel: less than or equal to 0.64 percent by weight for all fuels.

THIS LIMIT WILL BE TERMINATED ON THE DATE THE USEPA APPROVES

THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Sulfur Content of Fuel: less than or equal to 0.48 percent by weight for all fuels.

(Compliance with this limit demonstrates with the 0.50 lb SO2/million BTU limit.)

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 2

Operating Hours: less than or equal to 3800 hours/year (12-month rolling sum

basis) for all six units combined while operating inlet foggers and combusting fuel

oil.

Minn. R. 7007.0800, subp. 2 to limit inlet cooling

increase of SO2 and NOx emissions to less than 100

tpy to avoid Environmental Review required by Minn.

R. 4410.4300

MONITORING REQUIREMENTS hdr
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-6

Fuel Oil Analysis:

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

The Permittee shall obtain the fuel oil sulfur content and heating value by either of

the following methods:

a. By obtaining and retaining a fuel supplier certification from the fuel supplier for

each shipment of distillate, residual, or diesel fuel oil delivered to the Facility. Each

fuel supplier certification shall include the following information:

 1) The name of the supplier;

 2) The location of where the sample was drawn for analysis to determine the

sulfur content of the fuel oil. Specifically, the certification shall include whether

each shipment was sampled as delivered to the Facility, or whether the sample was

drawn from the storage tanks at the fuel oil supplier's or oil refiner's facility, or other

location;

 3) The sulfur content of the fuel oil from which the shipment came;

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Oil Analysis (cont.):

 4) The method used to determine the sulfur content shall be American Society

for Testing Materials (ASTM) Method D-1552 or another EPA approved ASTM

Method as listed in 40 CFR 60, Appendix A, Method 19, Sec. 5.2.2; and

 5) The heating value (million British Thermal Units per gallon) of the fuel oil

determined in accordance with ASTM Methods D-240, D-1989 or other EPA

approved methods,

OR,

b. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Oil Analysis (cont.):

 3) If the fuel delivery sample analysis result is no greater than 0.64% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.64% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from the

fuel line to the gas turbines. The sample shall be analyzed for sulfur content and

heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Oil Analysis:

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

The Permittee shall obtain the fuel oil sulfur content and heating value by one of the

following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

 1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-7

Fuel Oil Analysis (cont.)

 3) If the fuel delivery sample analysis result is no greater than 0.48% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

 4) If the delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

 5) In January and July of each year, the Permittee shall collect a sample from the

fuel line to the gas turbines. The sample shall be analyzed for sulfur content and

heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.10% by weight. The sulfur

content will be assured by:

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Oil Analysis (cont.)

 1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.10 percent

by weight; and by

 2) Sampling and analyzing the fuel in accordance with the following:

 a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

 b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Oil Analysis (cont.)

 c) If any delivery sample analysis result is greater than 0.10% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Fuel Supplier Certification: Keep on site a copy of the fuel supplier certification

identifying the type of fuel oil and the percent by weight sulfur content range.

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 4(B)

Fuel Supplier Certification or Guarantee: Keep on site a copy of the fuel supplier

certification or guarantee identifying the type of fuel oil and the percent by weight

sulfur content range.

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 4(B)

Daily Recordkeeping. On each day of operation, the Permittee shall record the

total quantity of all fuel used at the facility. This shall be based on flowmeters.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 4(B)

Fuel Usage Recordkeeping: By the 15th day of each month, the Permittee shall

use daily fuel usage records to calculate the monthly fuel usage on a 12-month

rolling average basis.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 4(B)

SO2 Emission Rate From Fuel Oil Combustion:

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

The Permittee shall calculate the SO2 emission rate using the sulfur content and

heating value with the following formula:

 Emissions Rate = N x %sulfur/

 (lb SO2/MMBtu) heating value (Btu/gal)

Where N = 142,000 for distillate oil and 157,000 for residual oil

The units for N = Btu lbs SO2/(MMBtu)(gal)

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 4(B)
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-8

RECORDKEEPING hdr

SO2 and Emissions and Operating Records.

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

The Permittee shall generate and maintain records containing information to

demonstrate compliance with the emission limitation and operating requirements.

The Permittee shall retain records containing the following information:

1) The fuel oil supplier's certifications containing the information listed in the

previous monitoring requirements and the date of each fuel oil delivery

cross-referenced to the certification accompanying that delivery; or the results of

the fuel oil analyses for sulfur content (percent by weight) and heating value (million

British Thermal Units per gallon), the date the fuel oil was sampled, and the

methods used to sample the fuel oil and determine the sulfur content and heating

value of the fuel oil.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

SO2 and Emissions and Operating Records (cont.)

2) Monthly and 12-month rolling average fuel oil use. The records shall be signed

by the person entering information into the record.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

SO2 and Emissions and Operating Records.

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION INTO THE SIP.

The Permittee shall generate and maintain records containing information to

demonstrate compliance with the emission limitation and operating requirements.

The Permittee shall retain records containing the following information:

 1) The results of the fuel oil analyses for sulfur content (percent by weight) and

heating value (million British Thermal Units per gallon), the date the fuel oil was

sampled, and the methods used to sample the fuel oil and determine the sulfur

content and heating value of the fuel oil.

 2) Monthly and 12-month rolling average fuel oil use. The records shall be signed

by the person entering information into the record.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP; Minn.

R. 7007.0800, subp. 5

Inlet Fogging Monthly Recordkeeping: by the 15th day of each month, calculate

and record the inlet fogging operating hours, while combusting fuel oil, for the

previous month and the previous 12-month period (12-month rolling sum).

Minn. R. 7007.0800, subp. 5

Inlet Fogging Daily Recordkeeping: Each day record the following for each

emission unit in GP 001 whenever inlet fogging was used:

1. Start and stop times of inlet fogger operation;

2. Individual and total hours of operation of the inlet foggers;

3. Type of fuel consumed during inlet fogging operation;

4. Time of any fuel changes during inlet fogging operation.

Minn. R. 7007.0800, subp. 5
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-9

Subject Item: GP 002 Emergency Diesel Generators

Associated Items: EU 007 Diesel Generator 1 ODG-GEN-001

EU 008 Diesel Generator 2 ODG-GEN-002

SV 007 Stack 7, Diesel Generator 1

SV 008 Stack 8, Diesel Generator 2

What to do Why to do it

Operating Hours: less than or equal to 816 hours/year using 12-month Rolling Sum

as a total for GP 002.

Title I Condition: To remain a nonmajor modification

for NOx under 40 CFR Section 52.21.

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight 40 CFR 72.7, New Unit Exemption, Acid Rain

Program; meets requirement of Minn. R. 7011.2300

subp. 2

Opacity: less than or equal to 20 percent once operating temperatures are attained

(applies individually to each emission unit or stack)

Minn. R. 7011.2300, subp. 1

The permittee shall obtain from the fuel supplier a certificate or other record

indicating that the fuel delivered for use in the GP 002 emission units has a sulfur

content less than or equal to 0.05 percent by weight on a 12-month annual

average.

40 CFR 72.7, New Unit Exemption, Acid Rain

Program, Minn. R. 7007.0800, subp. 4 and 5

Recordkeeping: For each day of operation of any GP 002 emission unit(s), record

the operating start and stop times. By the 15th of each month, calculate and record

the total combined GP 002 operating hours for the previous month, and for the

previous 12-month period (12-month rolling sum).

Title I Condition: To remain a nonmajor modification

for NOx under 40 CFR Section 52.21.
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-10

Subject Item: GP 003 Electric Generating Combustion Turbine Stack Vents

Associated Items: SV 001 Stack 1, Gas Turbine 1

SV 002 Stack 2, Gas Turbine 2

SV 003 Stack 3, Gas Turbine 3

SV 004 Stack 4, Gas Turbine 4

SV 005 Stack 5, Gas Turbine 5

SV 006 Stack 6, Gas Turbine 6

What to do Why to do it

Stack Height: greater than or equal to 32 feet from ground level. This requirement

applies to each individual stack.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Stack Cross-Sectional Area: less than or equal to 150 square feet (7.5 x 20 feet).

This requirement applies to each individual stack.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Air Flow Rate: greater than or equal to 1150000 actual cubic feet/minute for each

individual stack exhaust. This limit represents the modeled exhaust flow rate from

each stack vent at maximum peak load/peak SO2 emissions. It is not

representative of the flow rates at lower loads.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP

Temperature: greater than or equal to 1050 degrees F for each individual stack

exhaust. This limit represents the modeled exhaust temperature in each stack vent

at maximum peak load/peak SO2 emissions. It is not representative of the exhaust

temperature at lower loads.

Title I Condition: State Implementation Plan (SIP) for

SO2 NAAQS, 40 CFR pt. 50 and Minnesota SIP
TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/06

Xcel Energy Inver Hills Generating Plant

03700015 - 003

Facility Name:

Permit Number:

A-11

Subject Item: GP 004 Storage Tanks 

Associated Items: TK 001 distillate oil

TK 002 distillate oil

TK 003 distillate oil

What to do Why to do it

EMISSION AND OPERATIONAL LIMITS hdr

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)
TABLE B: SUBMITTALS

Facility Name: Xcel Energy Inver Hills Generating Plant

Permit Number: 03700015 - 003

B-1 10/27/06

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A

or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list

one-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts

7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall

be certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

 AQ Permit Technical Advisor

 Industrial Division

 Minnesota Pollution Control Agency

 520 Lafayette Road North

 St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:

- accumulated insignificant activities,

- installation of control equipment,

- replacement of an emissions unit, and

- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

 AQ Compliance Tracking Coordinator

 Industrial Division

 Minnesota Pollution Control Agency

 520 Lafayette Road North

 St. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

 Mr. George Czerniak

 Air and Radiation Branch

 EPA Region V

 77 West Jackson Boulevard

 Chicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

 U.S. Environmental Protection Agency

 Clean Air Markets Division

 1200 Pennsylvania Avenue NW (6204N)

 Washington, D.C. 20460
TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS

Facility Name: Xcel Energy Inver Hills Generating Plant

Permit Number: 03700015 - 003

B-2 10/27/06

What to send When to send Portion of Facility Affected

Application for Permit Reissuance due 180 days before expiration of Existing

Permit

Total Facility
TABLE B: RECURRENT SUBMITTALS

Facility Name: Xcel Energy Inver Hills Generating Plant

Permit Number: 03700015 - 003

B-3 10/27/06

What to send When to send Portion of Facility Affected

Quarterly Report due 30 days after end of each calendar

quarter starting 07/28/1992. The report shall

contain the following: 1) The percent sulfur

content by weight and the heating value of the

fuel oil in million British Thermal Units per

gallon; 2) Summary of any exceedances of

the emission limitation, monthly fuel use

limitation and the sulfur content limitation

during the calendar quarter. The report shall

provide an explanation of each exceedance

which occurred or a statement stating that no

exceedances occurred. The report shall also

state if fuel oil was burned during the

monitored quarter.

Total Facility

Semiannual Deviations Report due 30 days after end of each calendar

half-year starting 07/25/2000 . The first report

of each calendar year covers January 1 - June

30. The second report of each calendar year

covers July 1 - December 31. If no deviations

have occured, the Permittee shall submit the

report stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar year

starting 07/25/2000 (for the previous calendar

year). The Certification shall be submitted on

a form approved by the Commissioner, both to

the Commissioner and to the US EPA

regional office in Chicago. This report covers

all deviations experienced during the calendar

year.

Total Facility
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

Appendix A 

(Not used in Permit Number 03700015-003)
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

Appendix B

Insignificant Activities

Brazing, soldering and welding equipment 

Spray paint equipment used for facility upkeep 

Temporary (emergency) heating equipment (small portable propane heaters) 

Internal combustion engines (< 250 hp) burning distillate oil, gasoline or natural gas 

VOC fugitives from pumps, valves, and flanges on distillate oil forwarding systems and loading 

rack

Substation Black Start Diesel Generator (150 hp) 1

Fire Pump Diesel Engine (340 hp) 1

Water Tank Heater for fire protection systems 

Temporary engines for various compressors and pumps (< 250 hp) 

VOC fugitive emissions from solvents (parts washers no longer use solvents) 

Various small fuel oil tanks (two 3300 gallon tanks by generator building; one 300 gallon tank 

by fuel forwarding house; six 300 gallon oil/waste water tanks under loading rack; one 500 

gallon tank southwest of plant; one 250 gallon tank inside foam house) 

 

1

 Emergency / backup equipment PTE is based on 500 hours per year worst case assumptions, in 

accordance with EPA policy. 
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

Appendix C

New Unit Exemptions for EU007 and EU008 

New Unit Exemption 

For more information, see instructions and refer to 40 CFR 72.7 

This submission is New Revised 

Step 1 

Identify the new unit by plant 

name, State, ORIS Code (if 

assigned) and Unit ID#. 

Inver Hills Generating Plant 

Plant Name

MN

State

1913

ORIS 

Code

7

Unit ID#

Step 2 

List to one decimal place the 

nameplate capacity of each 

generator served by the unit. 

Then total these entries 

and enter the result. 

 Total 

1.8

MWe Mwe MWe MWe Mwe

Step 3 

List all fuels currently 

burned or expected to be 

burned, by the unit and the 

percent sulfur content by 

weight of each. 

 Fuel (current) Sulfur Content Fuel (expected) Sulfur 

Content

 (current) (expected) 

Diesel fuel 0.05% Diesel fuel 0.05%

 

 

Step 4 

Identify the first full calendar 

X

1.8

MWe
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

year in which the unit meets 

(or will meet) the requirements 

of 40 CFR 72.7(a). January 1, __2000___________ 

Special Provisions 

step 5 

Read the special provisions. 

(1) The owners and operators and, to the extent applicable, the designated representative of a

unit exempt under 40 CFR 72.7 shall (i) comply with the requirements of 40 CFR 72.7(a) for all periods for 

which the unit is exempt under 40 CFR 72.7 and (ii) comply with the requirements of the Acid Rain Program 

concerning all periods for which the exemption is not in effect, even if such requirements arise, or must be 

complied with, after the exemption takes effect. 

(2) For any period for which a unit is exempt under 40 CFR 72.7, the unit is not an affected unit 

under the Acid Rain Program and 40 CFR parts 70 and 71 and is not eligible to be an opt-in source 

under 40 CFR part 74. As an unaffected unit, the unit shall continue to be subject to any other 

applicable requirements under 40 CFR parts 70 and 71. 

(3) For a period of 5 years from the date the records are created, the owners and operators of a unit

exempt under 40 CFR 72.7 shall retain at the source that includes the unit records demonstrating 

that the requirements of 40 CFR 72.7(a) are met. The 5-year period for keeping records may be 

extended for cause, at any time prior to the end of the period, in writing by the Administrator or the 

permitting authority. Such records shall include, for each delivery of fuel to the unit or for fuel 

delivered to the unit continuously by pipeline, the type of fuel, the sulfur content, and the sulfur 

content of each sample taken. The owners or operators bear the burden of proof that the 

requirements of paragraph 40 CFR 72.7(a) are met. 

(4) On the earliest of the following dates, a unit exempt under 40 CFR 72.7(b), (c), or (e) shall lose 

its exemption and become an affected unit under the Acid Rain Program and 40 CFR parts 70 and 

71: (i) the date on which the unit first serves one or more generators with total nameplate capacity in 

excess of 25 MWe; (ii) the date on which the unit burns any coal or coal-derived fuel except for coalderived gaseous fuel with a total sulfur content no greater than natural gas; or (iii) January 1 of the 

year following the year in which the annual average sulfur content for gaseous fuel burned at the unit 

exceeds 0.05 percent by weight (as determined under 40 CFR 72.7(d)) or for nongaseous fuel 

burned at the unit exceeds 0.05 percent by weight (as determined under 40 CFR 72.7(d)). 

Notwithstanding 40 CFR 72.30(b) and (c), the designated representative for a unit that loses its 

exemption under 40 CFR 72.7 shall submit a complete Acid Rain permit application on the later of 

January 1, 1998 or 60 days after the first date on which the unit is no longer exempt. For the 

purpose of applying monitoring requirements under 40 CFR 75, a unit that loses its exemption under 

72.7 shall be treated as a new unit that commenced commercial operation on the first date on which 

the unit is no longer exempt. 
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

New Unit Exemption

For more information, see instructions and refer to 40 CFR 72.7 

This submission is New Revised 

Step 1 

Identify the new unit by plant 

name, State, ORIS Code (if 

assigned) and Unit ID#. 

Inver Hills Generating Plant 

Plant Name

MN

State

1913

ORIS 

Code

8

Unit ID#

Step 2 

List to one decimal place the 

nameplate capacity of each 

generator served by the unit. 

Then total these entries 

and enter the result. 

 Total 

1.8

MWe MWe MWe MWe MWe

Step 3 

List all fuels currently 

burned or expected to be 

burned, by the unit and the 

percent sulfur content by 

weight of each. 

 Fuel (current) Sulfur Content Fuel (expected) Sulfur 

Content

 (current) (expected) 

Diesel fuel 0.05% Diesel fuel 0.05%

 

 

Step 4 

Identify the first full calendar 

year in which the unit meets 

(or will meet) the requirements 

of 40 CFR 72.7(a). January 1, __2000___________ 

Special Provisions 

X

1.8

MWe
APPENDIX MATERIAL 

Facility Name: Xcel Energy Inver Hills Generating Plant 

Permit Number: 03700015-003 

step 5 

Read the special provisions. 

(1) The owners and operators and, to the extent applicable, the designated representative of a

unit exempt under 40 CFR 72.7 shall (i) comply with the requirements of 40 CFR 72.7(a) for all periods for 

which the unit is exempt under 40 CFR 72.7 and (ii) comply with the requirements of the Acid Rain Program 

concerning all periods for which the exemption is not in effect, even if such requirements arise, or must be 

complied with, after the exemption takes effect. 

(2) For any period for which a unit is exempt under 40 CFR 72.7, the unit is not an affected unit 

under the Acid Rain Program and 40 CFR parts 70 and 71 and is not eligible to be an opt-in source 

under 40 CFR part 74. As an unaffected unit, the unit shall continue to be subject to any other 

applicable requirements under 40 CFR parts 70 and 71. 

(3) For a period of 5 years from the date the records are created, the owners and operators of a unit

exempt under 40 CFR 72.7 shall retain at the source that includes the unit records demonstrating 

that the requirements of 40 CFR 72.7(a) are met. The 5-year period for keeping records may be 

extended for cause, at any time prior to the end of the period, in writing by the Administrator or the 

permitting authority. Such records shall include, for each delivery of fuel to the unit or for fuel 

delivered to the unit continuously by pipeline, the type of fuel, the sulfur content, and the sulfur 

content of each sample taken. The owners or operators bear the burden of proof that the 

requirements of paragraph 40 CFR 72.7(a) are met. 

(4) On the earliest of the following dates, a unit exempt under 40 CFR 72.7(b), (c), or (e) shall lose 

its exemption and become an affected unit under the Acid Rain Program and 40 CFR parts 70 and 

71: (i) the date on which the unit first serves one or more generators with total nameplate capacity in 

excess of 25 MWe; (ii) the date on which the unit burns any coal or coal-derived fuel except for coalderived gaseous fuel with a total sulfur content no greater than natural gas; or (iii) January 1 of the 

year following the year in which the annual average sulfur content for gaseous fuel burned at the unit 

exceeds 0.05 percent by weight (as determined under 40 CFR 72.7(d)) or for nongaseous fuel 

burned at the unit exceeds 0.05 percent by weight (as determined under 40 CFR 72.7(d)). 

Notwithstanding 40 CFR 72.30(b) and (c), the designated representative for a unit that loses its 

exemption under 40 CFR 72.7 shall submit a complete Acid Rain permit application on the later of 

January 1, 1998 or 60 days after the first date on which the unit is no longer exempt. For the 

purpose of applying monitoring requirements under 40 CFR 75, a unit that loses its exemption under 

72.7 shall be treated as a new unit that commenced commercial operation on the first date on which 

the unit is no longer exempt. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 1 of 23 

Date: 1/16/2007 

TECHNICAL SUPPORT DOCUMENT

For

AIR EMISSION PERMIT NO. 03700015-003

This Technical Support Document (TSD) is intended for all parties interested in the permit and 

to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 

70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the 

legal and factual justification for each applicable requirement or policy decision considered in 

the preliminary determination to issue the draft/proposed permit. 

1. General Information 

1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address 

(SIC Code: 4911) 

Northern States Power (dba Xcel Energy) 

414 Nicollet Mall 

Minneapolis, MN 55401-1993 

3185 117th Street East 

Inver Grove Heights (Dakota County), 

Minnesota

Contact: John Chelstrom 

Phone: (612)330-7682

1.2. Description of the Permit Action

The Inver Hills Generating Plant is a peak electrical generation facility with a capacity of 440 

megawatts (MW). The facility is composed of six identical pre-NSPS General Electric natural 

gas or fuel oil-fired simple cycle combustion turbine/generator sets. The facility is on call to 

operate, as needed, any or all of the six primary turbine/generator sets. Each turbine is capable 

of using natural gas, distillate oil, or residual oil as a fuel source. Natural gas is the primary fuel, 

and fuel oil is used mostly during curtailment of natural gas (which is almost always a winter 

phenomena, unless a natural gas pipeline break occurs during non-winter months). The 

Permittee has indicated that historically the overall fuel usage for the turbines is 90 percent 

natural gas and 10 percent fuel oil. There are also two emergency generators powered by diesel 

engines and several insignificant emission sources on site. Distillate oil and other petroleum 

products are stored in three 10 million gallon above ground storage tanks. 

The turbines are not subject to Title IV because they commenced operation before 

November 15, 1990, (§72.6(b)(1)). The facility also has two post-1990 Caterpillar emergency 

diesel-fired reciprocating internal combustion engines that are grid connected and therefore 

subject to Title IV. The Permittee committed to limiting diesel fuel sulfur content to 0.05 

percent by weight in these units and applied for a new unit exemption from EPA’s Acid Rain 

program. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 2 of 23 

Date: 1/16/2007 

Due to the low level of public interest in this facility (ascertained by the low levels of complaints 

received by the MPCA about the facility and the facility’s relatively low emissions), no 

Community Involvement Team was convened to educate the public about the reissuance of the 

Part 70 permit. 

1.3 Description of any Changes Allowed with this Permit Issuance

The permit application submitted by Xcel Energy (“Xcel”) contained no new physical changes 

or changes in the method of operation at the facility. The facility, however, proposed changes to 

some of the State Implementation Plan (SIP) conditions in the permit. 

The Pine Bend area surrounding Xcel’s Inver Hills facility currently meets all National and 

Minnesota Ambient Air Quality Standards (NAAQS and MAAQS). At one time, however, the 

area’s ambient air exceeded the sulfur dioxide (SO2) NAAQS. In response, the MPCA crafted 

conditions designed to bring the area into attainment with the standards. Those conditions 

applied to this and other facilities determined to be responsible for the ambient air quality 

problems. The MPCA is required to have a plan to maintain compliance with the NAAQS. 

Conditions in the permit identified as “Title I Condition: State Implementation Plan (SIP) for 

SO2 NAAQS” are elements of this maintenance plan. 

This permit prepares for the simplification of conditions in Minnesota’s SO2 SIP. The company 

proposes to forego some flexibility allowed under the previous permit for this simplification. 

The new conditions are more conservative than those contained in the previous permit, as 

(following their approval by EPA) they will impose lower sulfur fuel content limits; reduce the 

number of allowable fuels; eliminate alternative means of demonstrating compliance; and 

remove alternative recordkeeping requirements. A new compliance method is added, allowing 

the company to avoid certain analyses if fuel with a much lower sulfur content is used. 

Minnesota must incorporate these changes into its SIP after which EPA must approve them. For 

this reason, the conditions that are to be eliminated include language indicating that they are no 

longer applicable only after EPA approves the change. 

A detailed analysis of the changes to the permit and the rationale for making those changes is 

provided in Attachment 4.
Technical Support Document, Permit Action Number: 03700015-003 

Page 3 of 23 

Date: 1/16/2007 

1.4 Description of All Amendments Issued Since the Issuance of the Last Total Facility 

Permit.

Permit Number and 

Issuance Date

Action Authorized

03700015-001

July 25, 2000

Initial Part 70 permit 

 Transferred Administrative Order conditions to Part 70 

permit (transfer effective July 8, 2004; see 69 FR 31891, 

June 8, 2004) 

 Added conditions authorizing installation and use of an inlet 

cooling (inlet fogging) system

03700015-002

September 10, 2003

Major permit amendment 

 Revised Title V modeling requirements 

 Removed certain unneeded limits on CO and NOX emissions 

related to the inlet fogging system 

1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary 

 PM 

(tpy)

PM10

(tpy)

SO2

(tpy)

NOx

(tpy)

CO

(tpy)

VOC

(tpy)

Single

HAP

(tpy)

All

HAPs

(tpy)

Total Facility 

Limited Potential 

Emissions 

292 292 12300 21400 89 55 18.2 31.3 

Total Facility Actual 

Emissions (2005) 

3.5 3.5 8.7 220 1.0 0.9 HAPs not 

reported in 

emission 

inventory

Table 2. Facility Classification

Classification Major/Affected 

Source

Synthetic Minor Minor 

PSD X 

Part 70 Permit Program X 

Part 63 NESHAP X 
Technical Support Document, Permit Action Number: 03700015-003 

Page 4 of 23 

Date: 1/16/2007 

2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under New Source Review regulations. (Potential 

emission of PM, PM10, and SO2 exceed the 250 tpy threshold, as do potential and actual 

emissions of NOX.) No physical changes or changes in the method of operation are authorized 

by this permit. 

Part 70 Permit Program

The facility is a major source under the Part 70 permit program. (The potential of the facility to 

emit PM10, SO2 and NOX exceeds the 100 tpy threshold. In addition, the facility’s emissions 

exceed the 10 tpy and 25 tpy thresholds for single and total Hazardous Air Pollutants (HAPs). 

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility. 

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility’s emissions exceed the 10 tpy and 25 tpy thresholds for single and total HAPs, so the 

facility is a major HAP source. The combustion turbines are affected sources subject to 40 CFR 

63 Subpart YYYY. Since, however, they are existing stationary combustion turbines, there are 

no applicable requirements for them in this NESHAP. (See 40 CFR § 63.6095.) 

Compliance Assurance Monitoring (CAM)

None of the units at the facility are subject to CAM because they have no control equipment. 

Minnesota State Rules

Portions of the facility are subject to Minn. R. 7011.2300 (Standards of Performance for 

Stationary Internal Combustion Engines). 

The distillate oil tanks associated with the facility are not subject to Minn. R. 7011.1505 

(Standards of Performance for Storage Vessels) since the vapor pressure of the oil falls below 

128 mm Hg (2.5 psia). (The highest vapor pressure identified in the application for distillate fuel 

oil no. 2 fuel oil has a vapor pressure of about 6 mm Hg (0.115 psia).) 
Technical Support Document, Permit Action Number: 03700015-003 

Page 5 of 23 

Date: 1/16/2007 

Table 3. Regulatory Overview of Facility 

EU, GP, 

or SV 

Applicable Regulations Comments 

GP001

(EU001 – 

EU006)

Standards of Performance 

for Stationary Internal 

Combustion Engines

(Minn. R. 7011.2300) 

SO2 emission limit: d 0.5 lbs/MMBtu (the SIP limit 

overrides this limit for the gas turbines) 

Opacity limit: d 20 percent once operating temp. is 

attained

Standards of Performance 

for Existing Stationary 

Internal Combustion 

Engines

(Minn. R. 7011.2300)

SO2 emission limit: d 1.6 lbs/MMBtu 

Opacity limit: d 20 percent once operating temp. is 

attained

State Implementation Plan 

Conditions for Sulfur 

Dioxide Maintenance Area 

(40 CFR § 52.1220) 

(The latest revision became 

effective July 8, 2004. See 

69 FR 31891, June 8, 2004.) 

Fuel oil sulfur content limit: d 0.64 percent by weight 

(after EPA approval, this is reduced to 0.5 percent by 

weight)

Fuel oil usage limitation: d 9.41 million gallons per 

month based on a 12-month rolling average. 

SO2 emission limit: d 0.67 lbs/MMBtu (after EPA 

approval, this is reduced to 0.50 lbs/MMBtu) 

National Emission 

Standards for Hazardous 

Air Pollutants for Stationary 

Combustion Turbines

(40 CFR 63 Subpart YYYY)

The emission units in GP001 are existing stationary 

combustion turbines. The NESHAP has no 

requirements for these types of units. 

GP002

(EU007,

EU008)

Standards of Performance 

for Stationary Internal 

Combustion Engines

(Minn. R. 7011.2300) 

SO2 emission limit: d 0.5 lbs/MMBtu 

Opacity limit: d 20 percent once operating temp. is 

attained

Acid Rain program:

Exemption for New Units

(40 CFR § 72.7) 

Fuel oil sulfur content limit: d 0.05 percent by weight 
Technical Support Document, Permit Action Number: 03700015-003 

Page 6 of 23 

Date: 1/16/2007 

EU, GP, 

or SV 

Applicable Regulations Comments 

GP004

(TK001,

TK002,

TK003)

Industrial Process 

Equipment Rule (Minn. R. 

7011.0715)

Opacity limit: d 20 percent

Particulate limit: d 0.3 gr/dscf unless required to 

comply with the less stringent of either Minn. R. 

7011.0730 or Minn. R. 7011.0735

[This condition is not included in the permit since the 

tanks will not emit particulate matter.] 

These 10,000,000 gallon tanks were installed in 1972.

They are not subject to Minn. Rule 7011.1505, Subp. 

2.C.(1) (Standards of Performance for Storage Tanks)

because the vapor pressure of the stored liquid is less 

than 1 psia. Absent a separate standard, IPER applies.

3. Technical Information 

This section discusses a number of technical and regulatory decisions that were made during the 

review of the application and during permit drafting. 

3.1 Calculations of Potential to Emit

Xcel submitted emission calculations that were reviewed and corrected. The most recent version 

of AP-42 was the source of criteria pollutant and Hazardous Air Pollutant emission factors for 

the six combustion turbines and the two diesel generators. Volatile organic emissions from the 

tanks were calculated using the TANKS 4.0 program. 

Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, while 

Attachment 2 contains detailed spreadsheets and supporting information prepared by the MPCA 

and the Permittee. 

3.2 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility 

to have sufficient knowledge of the facility to certify that the facility is in compliance with all 

applicable requirements. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 7 of 23 

Date: 1/16/2007 

In evaluating the monitoring included in the permit, the MPCA considers the following: 

x The likelihood of violating the applicable requirements; 

x Whether add-on controls are necessary to meet the emission limits; 

x The variability of emissions over time; 

x The type of monitoring, process, maintenance, or control equipment data already 

available for the emission unit; 

x The technical and economic feasibility of possible periodic monitoring methods; and 

x The kind of monitoring found on similar units elsewhere. 

Table 4 summarizes the periodic monitoring requirements for those emission units for which the 

monitoring required by the applicable requirement is nonexistent or inadequate. 

Table 4. Periodic Monitoring 

Emission

Unit or 

Group

Requirement

(basis)

Additional

Monitoring

Discussion

GP001

(EU001 – 

EU006)

Minn. R. 

7011.2300

Performance Tests 

for Opacity 

Each combustion turbine was tested once 

during the five-year permit term while 

burning fuel oil. In each case, the opacity 

reading was 0%.1 Because there appears to 

be little chance of violating the 20% limit, 

the requirement to conduct periodic opacity 

testing has been eliminated from the permit. 

 State 

Implementati

on Plan for 

Sulfur

Dioxide

Fuel Sulfur Content 

Restriction / Sulfur 

Dioxide Limit 

The amount of fuel used at the facility must 

be tracked daily. The sulfur content of each 

shipment of fuel oil used at the facility must 

be analyzed upon receipt. On a monthly 

basis, the facility determinates compliance 

with the fuel usage limit. Sulfur dioxide 

emission rates are also calculated from these 

data.

This level of monitoring is appropriate due 

to the low level of SO2 emissions at the 

facility and the low concentration of sulfur in 

the oil relative to the limit. 

 

1

 Opacity tests were performed on August 1, 2000 (CT #1 and #2); April 24, 2001 (CT #3); April 9, 2002 

(CT #4); April 2, 2003 (CT #5); and May 27, 2004 (CT #6). These tests were reviewed by the MPCA. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 8 of 23 

Date: 1/16/2007 

Emission

Unit or 

Group

Requirement

(basis)

Additional

Monitoring

Discussion

GP002

(EU007,

EU008)

Title I 

Condition:

40 CFR 

§ 52.21 

(limits hours 

of operation; 

keeps NOX

emissions 

below PSD 

thresholds)

Daily

recordkeeping of 

the time of the start 

and stop of 

operation; monthly 

calculation of 12-

month rolling sum 

The combined limit on the two emergency 

diesel generators ensures that NOX emissions 

remain below PSD levels. Daily 

recordkeeping is needed for determining 

usage (when the units are actually 

operating). Actual hours of operation have 

been much less than the allowed 816 hours, 

so a relaxed calculation period of a month is 

appropriate.

 40 CFR 

§ 72.7 (New 

Unit

Exemption 

for the Acid 

Rain

program) 

Fuel Sulfur Content 

Restriction / Sulfur 

Dioxide Limit 

The amount of fuel used at the facility must 

be tracked daily. The fuel oil supplier must 

provide a certification or other record that 

the sulfur content of the fuel oil meets the 

limit. On a monthly basis, the facility 

determinates compliance with the fuel usage 

limit. Sulfur dioxide emission rates are also 

calculated from these data. 

This level of monitoring meets the standard 

of reasonable precision, reliability, 

accessibility, and timeliness required by the 

regulation.

GP004 Minn. R. 

7011.0715

None The Industrial Process Equipment rule 

applies as a default since no other standard 

applies. The tanks are not expected to 

generate particulate matter or opacity. 

3.3 Insignificant Activities

Xcel Energy’s Inver Hills Generating Plant has several operations that are identified as 

insignificant activities. These activities have no applicable requirements and have no associated 

periodic monitoring requirements. They are listed in Appendix B to the permit.
Technical Support Document, Permit Action Number: 03700015-003 

Page 9 of 23 

Date: 1/16/2007 

3.4 Modeling Submittal

Xcel was required to submit dispersion modeling information for PM10 and NOX for this facility 

by November 23, 2003. Xcel fulfilled this requirement. The requirement has been removed 

from the permit. 

3.5 “Additional” Emission Units

Three existing tanks were previously considered insignificant activities but are now identified as 

emission units. Their emissions are now calculated to exceed one ton of VOCs per year, which 

exceeds the threshold for insignificant activities. They have been added to Delta so that their 

emissions will be quantified and reported; however, there are no applicable conditions for the 

tanks, so there are no permit conditions addressing these tanks.

3.6 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of 

requirements. The permit conditions are placed at the group level. Group 1 includes the six 

electric generating combustion turbines (six emission units). Group 2 includes the two 

emergency diesel generators. Group 3 consists of the stacks for each of the electric generating 

combustion turbines (i.e., the stacks for the members of Group 1.) 
Technical Support Document, Permit Action Number: 03700015-003 

Page 10 of 23 

Date: 1/16/2007 

In addition, there are two appendices to the permit. (Appendix A is reserved for the Operator’s 

Summary which is not used with this permit.) Appendix B contains a listing of the Insignificant 

Activities at the facility. Appendix C records the New Unit Exemptions from the requirements 

of the Acid Rain program for Emission Units EU007 and EU008. (See 40 CFR § 72.7 for more 

information.) 

3.7 Comments Received

The Public Notice Period began on September 8, 2006 and ended October 9, 2006. No 

comments were received from the public during the public notice period. 

The EPA 45-day Review Period began on September 8, 2006 and ended October 23, 2006. No 

comments were received from the public during the public notice period. During this period, 

discussions were held with EPA reviewers for the State Implementation Plan (SIP). (These 

reviewers were interested in the permit because it contains conditions identified as a “Title I 

Condition: State Implementation Plan (SIP) for SO2 NAAQS” that will be incorporated into 

Minnesota’s SIP.) These discussions identified some misunderstandings between the MPCA and 

EPA Region 5. The misunderstandings were clarified without any changes to the permit. 

3.8 Post-Public Notice Permit Changes

During the public comment period, MPCA staff noticed that a SIP condition (i.e., a condition 

identified as a “Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS”) requiring 

a Quarterly Report was a submittal/action requirement and, therefore, part of Table B of the 

permit. Since Table B contains no citations, EPA had not identified this condition as part of the 

SIP. To ensure that this requirement would be included in the SIP when EPA modified 

Minnesota’s Plan, a permit condition was added basically duplicating this submittal/action 

requirement so that it would appear with the appropriate citation in Table A. (The new condition 

can be found under the Reporting heading of the Facility section.)

No additional public comment period or EPA review was needed since the condition reiterates 

an existing condition. A reference to this change has also been added to the “Summary of 

Changes to SIP Conditions” in Attachment 4. 

4. Conclusion

Based on the information provided by Xcel Energy, the MPCA has reasonable assurance that the 

proposed operation of the emission facility, as described in the Air Emission Permit No. 

03700015-003 and this technical support document, will not cause or contribute to a violation of 

applicable federal regulations and Minnesota Rules. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 11 of 23 

Date: 1/16/2007 

Staff Members on Permit Team: 

Richard Cordes Permit writer/engineer 

Emily Hansen Enforcement 

Curt Stock Stack testing 

Catherine Neuschler State Implementation Plan 

Marshall Cole Peer reviewer 

Attachments to the Technical Support Document: 

Attachment 1 PTE Summary Spreadsheet 

Attachment 2 Calculation Spreadsheets 

Attachment 3 Facility Description and CD-01 Forms 

Attachment 4 Changes to SIP Conditions 
Technical Support Document, Permit Action Number: 03700015-003 

Page 12 of 23 

Date: 1/16/2007 

Attachment 1 to the Technical Support Document

for Permit Action Number 03700015-003 

PTE Summary Spreadsheet 
Technical Support Document, Permit Action Number: 03700015-003 

Page 13 of 23 

Date: 1/16/2007 

Attachment 2 to the Technical Support Document

for Permit Action Number 03700015-003 

Calculation Spreadsheet 
Technical Support Document, Permit Action Number: 03700015-003 

Page 14 of 23 

Date: 1/16/2007 

Attachment 3 to the Technical Support Document

for Permit Action Number 03700015-003 

Facility Description and CD-01 Forms
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Page 16 of 23 

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Page 17 of 23 

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Attachment 4 to the Technical Support Document

for Permit Action Number 03700015-003 

Changes to the SIP Conditions 

In the application for a renewal of the Part 70 operating permit for its Inver Hills Generating 

Plant, Xcel Energy requested that the MPCA change a number of conditions that are included in 

Minnesota’s State Implementation Plan (SIP) to maintain the Pine Bend area (the area 

surrounding the Inver Hills Generating Plant) as an attainment (maintenance) area for sulfur 

dioxide (SO2).2

There have been two very significant changes since the State Implementation Plan (SIP) for the 

Inver Hills Generating Station was first prepared. First, the Pine Bend area is now in attainment 

with the National Ambient Air Quality Standards (NAAQS) for SO2. (This continues to be 

demonstrated, most recently in the ambient air quality modeling included with the July 18, 2006 

SIP submittal from the Minnesota Pollution Control Agency to Region 5 of the U.S. 

Environmental Protection Agency. That submittal includes changes to the SIP proposed by Flint 

Hills Resources, LP for its Rosemount refinery.) Second, low-sulfur fuels are commonly 

produced and are widely available. 

At its Inver Hills facility, Xcel receives a shipment of low-sulfur fuel oil by pipeline roughly 

every other year. Fuel analysis reports reviewed in 2006 indicate that the sulfur content of the 

delivered fuel ranges between 0.01 and 0.03 percent sulfur by weight (0.01 - 0.03 wt percent).

The MPCA agreed to make some of the changes requested by Xcel. In addition, the MPCA 

initiated changes to clarify the SIP conditions.3

 The changes to the SIP conditions continue to 

assure that compliance with the SO2 NAAQS is maintained. 

The permit reflects the following changes to the SIP that were proposed for facility’s combustion 

turbines:

Sulfur dioxide limit. The maximum allowable sulfur dioxide emission rate will be changed from 

0.67 pounds per million BTU to 0.50 pounds per million BTU. This lower emission rate is 

 

2

 The MPCA submitted the Title I SIP conditions in Air Emission Permit No. 03700015-001 to the US 

Environmental Protection Agency in August 2002. EPA reviewed and approved those Title I SIP 

conditions as of July 2, 2004. (See 69 FR 31891.) The approval of those SIP conditions represents 

the most recent action on the SIP conditions for this facility. 

3

 Air Emission Permit No. 03700015-001 (and, subsequently, 03700015-002) included an alternative 

Fuel Supplier Certification for GP 001 (Electric Generating Combustion Turbines) identified as an 

”Alternative to SIP monitoring for the Fuel Oil Analysis and SO2 Emission Rate calculation.” However, 

this condition was not identified as a Title I Condition for the SIP. Since it lacked this identification, the 

MPCA did not believe it was approved by US EPA into the SIP in its July 2, 2004 action. 

 To provide a less onerous fuel certification process protective of the SO2 NAAQS, the MPCA is 

proposing an alternative method of fuel oil analysis that, upon approval by US EPA, will become a part 

of the SO2 SIP for the Inver Hills Generating Plant. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 20 of 23 

Date: 1/16/2007 

already allowed as an alternative to the existing limit. However, the higher maximum emission 

rate will be eliminated from the permit after the SIP change is approved by EPA. 

Allowable fuels. The SIP conditions in the permit currently allow the combustion of natural gas, 

distillate oil, and residual oil. Residual oil will be removed as an allowable fuel. The remaining 

fuels are currently allowed by the permit, but the fuel likely to have the highest sulfur content – 

residual oil – will not be able to be burned after EPA approves the SIP changes. 

Fuel oil sulfur content. The permit’s SIP conditions currently allow a fuel oil sulfur content of 

0.64 percent by weight. The proposed permit would reduce the maximum allowable fuel sulfur 

content to 0.48 percent by weight (after EPA’s approval). A maximum fuel sulfur content of 

0.48 wt percent effectively limits the emissions of sulfur dioxide below 0.50 lb/MMBtu, as 

shown below:

 ̧

 ̧

1

·

 ̈

 ̈

©

§

d

  ̧

 ̧

1

·

 ̈

 ̈

©

§

 ̧

 ̧

1

·

 ̈

 ̈

©

§

 ̧

 ̧

1

·

 ̈

 ̈

©

§

 ̧

 ̧

1

·

 ̈

 ̈

©

§

MMBTU FO

lb SO

MMBTU FO

lb SO

MMBTU FO

BTU FO

lb S

lb SO

BTU FO

lb FO

lb FO

lb S

_

_

5.0

_

_

.0 499

_

1000000_ _

32 07. _ _

64 06. _ _

19429_ _

_

100_ _

0.485_ _

2

2 2

Note: Heating values for No. 2 distillate oil range from 19429 Btu/lb to 19701 Btu/lb.

Use of the lower end of the range is the more conservative option. 

Thus, compliance with the 0.50 lb SO2/MMBtu limit is demonstrated by compliance with the 

fuel sulfur content limit of 0.48 percent by weight. 

Fuel oil analysis. The SIP conditions in the current permit provide two options for Xcel to 

demonstrate compliance with the fuel sulfur limit. The first is by obtaining a fuel oil 

certification indicating that each shipment meets the allowed limits. While fuel oil suppliers 

may have routinely provided certifications when the SIP was originally developed for the Pine 

Bend area, fuel certification are no longer available from these suppliers. (In their place, the fuel

supplier will provide a guarantee that shipments will meet a fuel oil specification.) Because of 

this, the first option described above – acquiring a certification on each shipment – is no longer a 

feasible alternative. This option will be eliminated from the SIP and the permit. 

The alternative compliance method in the SIP (and the permit) allows the facility to perform an 

analysis for sulfur content in the fuel oil, including the testing of the fuel oil in the fuel line to the 

gas turbines in January and in July. Since the Inver Hills facility now receives low-sulfur fuel oil 

(less than 0.05 percent sulfur by weight), these conditions are overly rigorous. In particular, 

there are difficulties in obtaining fuel oil certifications for each individual shipment, and the 

sampling and testing of the fuel oil in the fuel lines seems exceptionally burdensome. (The 

facility’s supplier guarantees that the sulfur content of the fuel oil will not exceed 0.05 percent 

by weight. A copy of this guarantee is presented at the end of this attachment.) 
Technical Support Document, Permit Action Number: 03700015-003 

Page 21 of 23 

Date: 1/16/2007 

Because of this, an additional method of compliance has been proposed. The first requirement of 

this new option would be for Xcel to obtain an assurance from its fuel suppliers that the oil it 

receives would contain less than 0.10 percent sulfur by weight. This certification would not be 

required for each shipment but could be a “blanket” guarantee for anticipated (future) deliveries, 

such as the one included with the TSD. The fuel supplier would be required to notify Xcel of 

exceptional events (i.e., when the delivered oil exceeded the 0.10 percent threshold). In those 

cases, the new option would not be available and Xcel would need to comply with the remaining 

option from the existing SIP and permit. 

The second requirement of this new compliance option would be for Xcel to sample and analyze 

the fuel oil when it is delivered. Again, a 0.10 weight percent sulfur threshold would be used.

(Again, if the sulfur content of the fuel oil, as sampled and analyzed by Xcel, exceeds 0.10 

percent, Xcel would need to comply with the other option.) 

Since the fuel oil used in the combustion turbines is transported to the facility by pipeline, the 

facility would sample the incoming fuel oil as it is pumped into the storage tanks. Independent 

samples would be taken at the beginning, middle and end of the shipment, with each sample 

analyzed so that compliance with the fuel oil sulfur limits could be demonstrated with each 

sample. 

Because the threshold of 0.10 weight percent is below the proposed threshold of 0.48 weight 

percent by a factor of nearly five, this new option provides sufficient assurance that the SO2

NAAQS will continue to be attained. 

Table: Summary of Changes to SIP Conditions 

Permit Limitation or 

Condition

Description of Change Effect 

Sulfur dioxide limit The maximum allowable sulfur 

dioxide emission rate will be 

changed from 0.67 pounds per 

million BTU to 0.50 pounds 

per million BTU. 

The new, lower emission rate is 

already allowed as an alternative 

to the existing limit. However, the 

maximum emission rate will be 

reduced.

Limitation on types of 

fuels burned 

Residual oil will be eliminated 

as an allowable fuel. 

The remaining fuels are currently 

allowed by the permit, but the fuel 

likely to have the highest sulfur 

content can no longer be burned. 

Sulfur content of fuel The maximum allowable fuel 

sulfur content will be changed 

from 0.64 percent by weight to 

0.48 percent by weight. 

The lower sulfur content is already 

allowed. However, the maximum 

fuel sulfur content will be reduced. 
Technical Support Document, Permit Action Number: 03700015-003 

Page 22 of 23 

Date: 1/16/2007 

Permit Limitation or 

Condition

Description of Change Effect 

Fuel Oil Analysis The compliance option that 

relies on a fuel supplier’s 

certification will be eliminated.

Fuel oil suppliers no longer certify 

sulfur content on each fuel 

shipment, so this option has not 

recently been used. There is no 

real effect from its elimination. 

Fuel Oil Analysis A different method of 

demonstrating compliance 

with the fuel sulfur content 

limit will be added. 

As long as the fuel oil contains 

less than 0.10 percent sulfur by 

weight, the company will be able 

to use a less onerous compliance 

option.

Fuel Supplier 

Certification 

The new condition provides an 

option to keep a guarantee or a 

certification from the fuel 

supplier on hand instead 

requiring a certification. 

This supports the new method of 

demonstrating compliance with the 

fuel sulfur limit. That method 

requires a guarantee from the fuel 

supplier rather than a certification. 

SO2 Emission Rate 

calculation

The description of how to 

calculate the emissions rate 

will be removed. 

None. The calculation above 

ensures that compliance with the 

fuel sulfur content of 0.48 percent 

by weight cannot lead to an 

exceedance of the 0.50 lb SO2 per 

million BTU limit. 

SO2 and Emissions and 

Operating Records 

The requirement to retain 

records related to fuel oil 

sampling and analyses 

performed by the company 

will be removed. 

Existing conditions requiring that 

records related to retaining fuel oil 

supplier’s certifications for five 

years will be kept in the permit. 

Quarterly Reporting 

requirement 

A condition was added 

mirroring the language of a 

submittal/action condition 

already in the permit. No new 

requirements were added. 

The new condition will appear in 

Table A of the permit with a 

citation that identifies it as a 

“Title I Condition: State 

Implementation Plan (SIP) for 

SO2 NAAQS.” 
Technical Support Document, Permit Action Number: 03700015-003 

Page 23 of 23 

Date: 1/16/2007 

Supplier Guarantee 
Attachment 3: Permit No. 03700015-003 red-line version 
MINNESOTAPOLLUTION CONTROLAGENCY

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COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Subject Item: Total Facility

NC/

CA

Type Citation Requirement

1.0 CD hdr SOURCE SPECIFIC REQUIREMENTS

2.0 CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Table

of Contents. The Permittee shall comply with all requirements contained in the

appendices.

3.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7009.0020

Parameters Used in Modeling: The stack heights, emission rates, and other

parameters used in the modeling for the SO2 SIP are listed in Appendix C of this

permit. The Permittee must submit to the Commissioner for approval any revisions

of these parameters and must wait for a written approval before making such

changes. The information submitted must include, at a minimum, the locations,

heights and diameters of the stacks, locations and dimensions of nearby buildings,

the velocity and temperatures of the gases emitted, and the emission rates. The

plume dispersion charateristics due to the revisions of the information must be

equivalent to or better than the dispersion characteristics modeled in the SO2 SIP

submittal. The Permittee shall demonstrate this equivalency in the proposal. If the

information does not demonstrate equivalent or better dispersion characteristics, or

if a conclusion cannot readily be made about the dispersion, the Permittee must

remodel.

4.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

State Implementation Plan Recordkeeping: Retain all records at the stationary

source for a period of five (5) years from the date of the required monitoring,

sample, measurement, or report that corresponds with the "Title I Condition: SIP

for SO2 NAAQS" requirement.

5.0 S/A Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Quarterly Report: due 30 days after end of each calendar quarter starting

07/28/1992. The report shall contain the following: 1) The percent sulfur content

by weight and the heating value of the fuel oil in million British Thermal Units per

gallon; 2) Summary of any exceedances of the emission limitation, monthly fuel

use limitation and the sulfur content limitation during the calendar quarter. The

report shall provide an explanation of each exceedance which occurred or a

statement stating that no exceedances occurred. The report shall also state if fuel

oil was burned during the monitored quarter.

6.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Quarterly Report for the State Implementation Plan for Sulfur Dioxide:

Not more than 30 days after the end of each calendar quarter starting 07/28/1992,

the Permittee shall submit a report containing the following information:

1) The percent sulfur content by weight and the heating value of the fuel oil in

million British Thermal Units per gallon; and

2) A summary of any exceedances of the emission limitation, monthly fuel use

limitation and the sulfur content limitation during the calendar quarter. The report

shall provide an explanation of each exceedance which occurred or a statement

stating that no exceedances occurred. The report shall also state if fuel oil was

burned during the monitored quarter.

7.0 CD Minn. R. 7007.0800, subp. 6(C)1;

Alternative to SIP Quarterly

Report.

Deviations from requirements cited as "Title I Condition: SIP for SO2 NAAQS"

shall be reported semi-annually with the Semi-annual Deviations Report required

by this permit. Reporting shall occur even if there were no deviations for this

reporting period.

8.0 CD hdr DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR

9.0 CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subp. 2

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR

Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the

actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test

at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may

result in a significant emissions increase (SEI). If the ATPA test is not used for the

project, or if there is no RP that the proposed project could result in a SEI, these

requirements do not apply to that project. The Permittee is only subject to the

Preconstruction Documentation requirement for a project where a RP occurs only

within the meaning of Section 52.21(r)(6)(vi)(b).

Even though a particular modification is not subject to New Source Review (NSR),

or where there isn't a RP that a proposed project could result in a SEI, a permit

amendment, recordkeeping, or notification may still be required by Minn. R.

7007.1150 - 7007.1500.
MINNESOTAPOLLUTION CONTROLAGENCY

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COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

10.0 CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.1200, subp. 4;

Minn. R. 7007.0800, subps. 4 & 5

Preconstruction Documentation -- Before beginning actual construction on a

project, the Permittee shall document the following:

1. Project description

2. Identification of any emission unit (EU) whose emissions of an NSR pollutant

could be affected

3. Pre-change potential emissions of any affected existing EU, and the projected

post-change potential emissions of any affected existing or new EU.

4. A description of the applicability test used to determine that the project is not a

major modification for any regulated NSR pollutant, including the baseline actual

emissions, the projected actual emissions, the amount of emissions excluded due

to increases not associated with the modification and that the EU could have

accommodated during the baseline period, an explanation of why the amounts 

were excluded, and any creditable contemporaneous increases and decreases that

were considered in the determination.

The Permittee shall maintain records of this documentation.

11.0 CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant

that could increase as a result of the project and that were analyzed using the

ATPA test, and the potential emissions of any regulated NSR pollutant that could

increase as a result of the project and that were analyzed using potential

emissions in the hybrid test. The Permittee shall calculate and maintain a record of

the sum of the actual and potential (if the hybrid test was used in the analysis)

emissions of the regulated pollutant, in tons per year on a calendar year basis, for

a period of 5 years following resumption of regular operations after the change, or

for a period of 10 years following resumption of regular operations after the change

if the project increases the design capacity of or potential to emit of any unit

associated with the project.

12.0 CD Title I Condition: 40 CFR Section

52.21(r)(6); Minn. R. 7007.3000;

Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual,

plus potential if used in hybrid test) emissions differ from the preconstruction

projection and exceed the baseline actual emissions by a significant amount as

listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the

Agency within 60 days after the end of the year in which the exceedances occur.

The report shall contain:

a. The name and ID number of the facility, and the name and telephone number of

the facility contact person

b. The annual emissions (actual, plus potential if any part of the project was

analyzed using the hybrid test) for each pollutant for which the preconstruction

projection and significant emissions increase are exceeded.

c. Any other information, such as an explanation as to why the summed emissions

differ from the preconstruction projection.

13.0 CD hdr OPERATIONAL REQUIREMENTS

14.0 CD Minn. Stat. Section 116.07, subds.

4a & 9; Minn. R. 7007.0100, subp.

7(A), 7(L), & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4; Minn.

R. 7009.0010-7009.0080

The Permittee shall comply with National Primary and Secondary Ambient Air

Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality

Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated

upon written request by the MPCA.

15.0 CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutes

emissions, which would otherwise violate a federal or state air pollution control

rule, without reducing the total amount of pollutant emitted.

16.0 CD Minn. R. 7007.0800, subp. 2;

Minn. R. 7007.0800, subp. 16(J)

Air Pollution Control Equipment: Operate all pollution control equipment whenever

the corresponding process equipment and emission units are operated.

17.0 CD Minn. R. 7007.0800, subps. 14

and 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and

maintenance plan for all air pollution control equipment. At a minimum, the O & M

plan shall identify all air pollution control equipment and control practices and shall

include a preventative maintenance program for the equipment and practices, a

description of (the minimum but not necessarily the only) corrective actions to be

taken to restore the equipment and practices to proper operation to meet

applicable permit conditions, a description of the employee training program for

proper operation and maintenance of the control equipment and practices, and the

records kept to demonstrate plan implementation.
MINNESOTAPOLLUTION CONTROLAGENCY

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COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

18.0 CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall

immediately take all practical steps to modify operations to reduce the emission of

any regulated air pollutant. The Commissioner may require feasible and practical

modifications in the operation to reduce emissions of air pollutants. No emissions

units that have an unreasonable shutdown or breakdown frequency of process or

control equipment shall be permitted to operate.

19.0 CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or

storage of any material in a manner which may allow avoidable amounts of

particulate matter to become airborne. Comply with all other requirements listed in

Minn. R. 7011.0150.

20.0 CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R.

7030.0010 to 7030.0080 at all times during the operation of any emission units.

This is a state only requirement and is not enforceable by the EPA Administrator or

citizens under the Clean Air Act.

21.0 CD Minn. R. 7007.0800, subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and

requirements as found in Minn. R. 7007.0800, subp. 9(A).

22.0 CD Minn. R. 7007.0800, subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R.

7007.0800, subp. 16.

23.0 CD hdr PERFORMANCE TESTING

24.0 CD Minn. R. ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R.

ch. 7017 unless otherwise noted in Tables A, B, and/or C.

25.0 CD Minn. R. 7017.2018; Minn. R.

7017.2030, subps. 1-4, Minn. R.

7017.2035, subps. 1-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See Table

B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance

Test

Performance Test Plan: due 30 days before each Performance Test

Performance Test Pre-test Meeting: due 7 days before each Performance Test

Performance Test Report: due 45 days after each Performance Test

Performance Test Report - Microfiche Copy: due 105 days after each

Performance Test

The Notification, Test Plan, and Test Report may be submitted in alternative

format as allowed by Minn. R. 7017.2018.

26.0 CD Minn. R. 7017.2025, subp. 3 Limits set as a result of a performance test (conducted before or after permit

issuance) apply until superseded as stated in the MPCA's Notice of Compliance

letter granting preliminary approval. Preliminary approval is based on formal review

of a subsequent performance test on the same unit as specified by Minn. R.

7017.2025, subp. 3. The limit is final upon issuance of a permit amendment

incorporating the change.

27.0 CD hdr MONITORING REQUIREMENTS

28.0 CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permitee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or

2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including

the date conducted, and any corrective action that resulted. The Permitee shall

include the calibration frequencies, procedures, and manufacturer's specifications

(if applicable) in the Operations and Maintenance Plan. Any requirements applying

to continuous emission monitors are listed separately in this permit.

29.0 CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or

C, monitoring a process or control equipment connected to that process is not

necessary during periods when the process is shutdown, or during checks of the

monitoring systems, such as calibration checks and zero and span adjustments. If

monitoring records are required, they should reflect any such periods of process

shutdown or checks of the monitoring system.

30.0 CD hdr RECORDKEEPING
MINNESOTAPOLLUTION CONTROLAGENCY

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COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

31.0 CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise

specified within this permit, for a period of five (5) years from the date of

monitoring, sample, measurement, or report. Records which must be retained at

this location include all calibration and maintenance records, all original recordings

for continuous monitoring instrumentation, and copies of all reports required by the

permit. Records must conform to the requirements listed in Minn. R. 7007.0800,

subp. 5(A).

32.0 CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as

required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms

(as required by Minn. R. 7007.1350, subp. 2), including records of the emissions

resulting from those changes.

33.0 CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is required

prior to making a change, the Permittee must retain records of all calculations

required under Minn. R. 7007.1200. For expiring permits, these records shall be

kept for a period of five years from the date the change was made or until permit

reissuance, whichever is longer. The records shall be kept at the stationary source

for the current calendar year of operation and may be kept at the stationary source

or office of the stationary source for all other years. The records may be

maintained in either electronic or paper format.

34.0 CD hdr REPORTING/SUBMITTALS

35.0 CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a

planned shutdown of any control equipment or process equipment if the shutdown

would cause any increase in the emissions of any regulated air pollutant. If the

owner or operator does not have advance knowledge of the shutdown, notification

shall be made to the Commissioner as soon as possible after the shutdown.

However, notification is not required in the circumstances outlined in Items A, B

and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of

the cause of the shutdown and the estimated duration. The owner or operator shall

notify the Commissioner when the shutdown is over.

36.0 CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown

of more than one hour duration of any control equipment or process equipment if

the breakdown causes any increase in the emissions of any regulated air pollutant.

The 24-hour time period starts when the breakdown was discovered or reasonably

should have been discovered by the owner or operator. However, notification is not

required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,

subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated

duration. The owner or operator shall notify the Commissioner when the

breakdown is over.

37.0 CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon

as possible after discovery, notify the Commissioner or the state duty officer, either

orally or by facsimile, of any deviation from permit conditions which could

endanger human health or the environment.

38.0 CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:

Within 2 working days of discovery, notify the Commissioner in writing of any

deviation from permit conditions which could endanger human health or the

environment. Include the following information in this written description:

1. the cause of the deviation;

2. the exact dates of the period of the deviation, if the deviation has been

corrected;

3. whether or not the deviation has been corrected;

4. the anticipated time by which the deviation is expected to be corrected, if not

yet corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation.

39.0 S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year

following Permit Issuance. The first semiannual report submitted by the Permittee

shall cover the calendar half-year in which the permit is issued. The first report of

each calendar year covers January 1 - June 30. The second report of each

calendar year covers July 1 - December 31. If no deviations have occurred, the

Permittee shall submit the report stating no deviations.
MINNESOTAPOLLUTION CONTROLAGENCY

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Page 5 of 16 1 Jul, 2014 10:40

COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

40.0 CD Minn. R. 7007.1150 - 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

41.0 CD Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of existing

permit.

42.0 CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment

to extend a deadline in a permit by no more than 120 days, provided the proposed

deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and

pt. 63 are examples of deadlines for which the MPCA does not have authority to

grant extensions and therefore do not meet the requirements of Minn. R.

7007.1400, subp. 1(H).

43.0 S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year following

Permit Issuance (for the previous calendar year). The Permittee shall submit this

to the Commissioner on a form approved by the Commissioner. This report covers

all deviations experienced during the calendar year.

44.0 CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: Due on or before April 1 of each calendar year

following permit issuance, to be submitted on a form approved by the

Commissioner.

45.0 CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.
MINNESOTAPOLLUTION CONTROLAGENCY

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COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Subject Item: GP 001 Electric Generating Combustion Turbines

Associated Items: EU 001 Combustion Turbine 1

EU 002 Combustion Turbine 2

EU 003 Combustion Turbine 3

EU 004 Combustion Turbine 4

EU 005 Combustion Turbine 5

EU 006 Combustion Turbine 6

NC/

CA

Type Citation Requirement

1.0 CD hdr The requirements of this group apply individually to each associated item in this

group unless specified.

2.0 CD hdr EMISSION AND OPERATIONAL REQUIREMENTS

3.0 LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

4.0 LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2; Minn. R.

7011.2300, subp. 2

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input

5.0 LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

Sulfur Content of Fuel: less than or equal to 0.48 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS LIMIT WILL BE TERMINATED ON THE DATE THE USEPA APPROVES

THE REVISION TO THE SIP.

6.0 LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

Sulfur Content of Fuel: less than or equal to 0.005 percent by weight for all fuels.

(Compliance with this limit demonstrates compliance with the 0.50 lb SO2/million

BTU limit.)

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APPROVES THE REVISION TO THE SIP.

7.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 2

Allowable Fuel Types: Distillate fuel oil and natural gas.

8.0 LIMIT Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Total Combined Distillate Fuel Usage: less than or equal to 9.41 million

gallons/month using 12-month Rolling Average

9.0 CD hdr MONITORING REQUIREMENTS

10.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

THIS CONDITION WILL BE TERMINATED ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;
MINNESOTAPOLLUTION CONTROLAGENCY

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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

11.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

3) If the fuel delivery sample analysis result is no greater than 0.48% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

4) If the delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.10% by weight. The sulfur

content will be assured by:

12.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.48 percent

by weight; and by

2) Sampling and analyzing the fuel in accordance with the following:

a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

13.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

c) If any delivery sample analysis result is greater than 0.48% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

14.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

THIS CONDITION WILL BECOME EFFECTIVE ON THE DATE THE USEPA

APROVES THE REVISION TO THE SIP.

Fuel Oil Analysis:

The Permittee shall obtain the fuel oil sulfur content and heating value by one of

the following methods:

METHOD A. By sampling and analyzing the fuel in accordance to the following:

1) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

2) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

15.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

3) If the fuel delivery sample analysis result is no greater than 0.005% sulfur, the

Permittee shall compute a weighted average sulfur content of the fuel in the tank

using the analysis from the fuel delivery sample and any previous value for sulfur

content of fuel in the tank.

4) If the delivery sample analysis result is greater than 0.005% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

5) In January and July of each year, the Permittee shall collect a sample from

the fuel line to the gas turbines. The sample shall be analyzed for sulfur content

and heating value. The results shall be used as the new sulfur content and heating

value of the fuel in the tank.

OR,

METHOD B. By limiting fuel oil sulfur content to 0.0015% by weight. The sulfur

content will be assured by:

16.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

1) Obtaining and retaining a guarantee from the fuel supplier indicating that each

shipment of fuel oil delivered to the Facility will not contain more that 0.0015

percent by weight; and by

2) Sampling and analyzing the fuel in accordance with the following:

a) While the fuel tank is being filled, the Permittee shall collect a sample of the

fuel delivery in accordance with ASTM Method D-4057 or other EPA approved

method;

b) The Permittee shall analyze fuel delivery samples to determine the sulfur

content in accordance with ASTM Method D-1552 or other approved EPA method

and heating value of the fuel in accordance with ASTM Method D-240, D-1989 or

other approved EPA method;

17.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP

Fuel Oil Analysis (cont.)

c) If any delivery sample analysis result is greater than 0.0015% sulfur, then a

sample must be taken from the fuel tank and analyzed for sulfur content and

heating value. The Permittee shall use the tank analysis as the new sulfur content

and heating value of the fuel in the tank.

18.0 CD hdr RECORDKEEPING

19.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Fuel Supplier Certification or Guarantee: Keep on site a copy of the fuel supplier

certification or guarantee identifying the type of fuel oil and the percent by weight

sulfur content range.

20.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Daily Recordkeeping: On each day of operation, the Permittee shall record the

total quantity of all fuel used at the facility. This shall be based on flowmeters.

21.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 4(B)

Fuel Usage Recordkeeping: By the 15th day of each month, the Permittee shall

use daily fuel usage records to calculate the monthly fuel usage on a 12-month

rolling average basis.
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

22.0 CD Title I Condition: SIP for SO2

NAAQS, 40 CFR pt. 50; 40 CFR

pt. 52, subp. Y, MN SIP; Minn. R.

7007.0800, subp. 5

SO2, and Emissions and Operating Records.

The Permittee shall generate and maintain records containing information to

demonstrate compliance with the emission limitation and operating requirements.

The Permittee shall retain records containing the following information:

1) The results of the fuel oil analyses for sulfur content (percent by weight) and

heating value (million British Thermal Units per gallon), the date the fuel oil was

sampled, and the methods used to sample the fuel oil and determine the sulfur

content and heating value of the fuel oil.

2) Monthly and 12-month rolling average fuel oil use. The records shall be

signed by the person entering information into the record.

23.0 CD Minn. R. 7007.0800, subp. 4 and

5

The Permittee shall install, calibrate, maintain and operate flowmeters for all fuel

used at the facility.
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Subject Item: GP 002 Emergency Diesel Generators

Associated Items: EU 007 Diesel Generator 1 ODG-GEN-001

EU 008 Diesel Generator 2 ODG-GEN-002

NC/

CA

Type Citation Requirement

1.0 CD hdr The requirements of this group apply individually to each associated item in this

group, unless specified.

2.0 CD hdr EMERGENCY RICE DEFINITION

3.0 CD 40 CFR Section 63.6640(f); Minn.

R. 7011.8150

The Permittee shall operate EU 007 and EU 008 according to the requirements in

paragraphs 40 CFR Section 63.6640 (f)(1) through (3). Any operation other than

emergency operation, maintenance and testing, emergency demand response,

and operation in non-emergency situations for 50 hours per year, as described in

40 CFR Section 63.6640(f)(1) through (3), is prohibited. If the engine is not

operated according to the requirements in 40 CFR Section 63.6640(f)(1) through

(3), the engine will not be considered an emergency engine under this subpart and

will need to meet all requirements for non-emergency engines.

(continued below)

4.0 CD 40 CFR Section 63.6640(f)(1) -

(2); Minn. R. 7011.8150

(1) ) There is no time limit on the use of emergency stationary RICE in

emergency situations.

(2) ) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) counts as

part of the 100 hours per calendar year allowed by this paragraph (f)(2).

5.0 CD 40 CFR Section 63.6640(f)(2)(i);

Minn. R. 7011.8150

2(i) The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indicating that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per

calendar year.

6.0 CD 40 CFR Section 63.6640(f)(2)(ii) -

(2)(iii); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14),

or other authorized entity as determined by the Reliability Coordinator, has

declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability

Standard EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

7.0 CD 40 CFR Section 63.6640(f)(3);

Minn. R. 7011.8150

(3) Emergency stationary RICE located at major sources of HAP may be operated

for up to 50 hours per calendar year in non-emergency situations. The 50 hours of

operation in non-emergency situations are counted as part of the 100 hours per

calendar year for maintenance and testing and emergency demand response

provided in 40 CFR Section 63.6640(f)(2) above. The 50 hours per year for

non-emergency situations cannot be used for peak shaving or non-emergency

demand response, or to generate income for a facility to supply power to an

electric grid or otherwise supply power as part of a financial arrangement with

another entity.

8.0 CD hdr EMISSION AND OPERATING LIMITS

9.0 LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

10.0 LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the unit is 0.05 lb/MMBtu due to equipment design and allowable

fuels.

11.0 CD 40 CFR Section 72.7(a)(2); Minn.

R. 7007.1075; Minn. R.

7005.0100, subp. 35a

Fuel Type: Distillate oil only, by design.

12.0 LIMIT 40 CFR Section 72.7(a)(3); Minn.

R. 7007.1075

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight on an annual

average.

13.0 LIMIT Title I Condition: To avoid

classification as a major

modification under 40 CFR

Section 52.21 and Minn. R.

7007.3000

Operating Hours: less than or equal to 816 hours/year using 12-month Rolling Sum

as a total for GP 002.

14.0 CD hdr MONITORING AND RECORDKEEPING

15.0 CD 40 CFR Section 72.7; Minn. R.

7007.0800, subp. 4 and 5

The Permittee shall obtain from the fuel supplier a certificate or other record

indicating that the fuel delivered for use in the GP 002 emission units has a sulfur

content less then or equal to 0.05 percent by weight on a 12-month annual

average.

16.0 CD 40 CFR Section 72.7(d)(3); Minn.

R. 7007.1075

Average Annual Suflur Content Determination

The Permittee shall calculate the annual average sulfur content, as a percentage

by weight, using the equation in 40 CFR Section 72.7(d)(2). In lieu of the factor,

volume times density, in the equation, the factor, mass (Mn), may be used, where

Mn is: mass of the nongaseous fuel in a delivery during the year to the unit of

which the nth sample is taken, in lb.

Fuel shall be sampled at least once for every delivery.

17.0 CD 40 CFR Section 72.7(f)(3); Minn.

R. 7007.1075

For a period of 5 years from the date the records are created, the Permittee shall

retain at the source records demonstrating that the requirements of 40 CFR

Section 72.7(a) are met. The 5-year period for keeping records may be extended

for cause, at any time prior to the end of the period, in writing by the Administrator

or the permitting authority.

(i) Such records shall include, for each delivery of fuel to the unit, the type of fuel,

the sulfur content, and the sulfur content of each sample taken.

(ii) The Permittee bears the burden of proof that the requirements of 40 CFR

Section 72.7(a) are met.

18.0 CD 40 CFR Section 72.7(f)(4)(i);

Minn. R. 7007.1075

Loss of exemption. An exempt unit shall be treated as an affected unit under the

Acid Rain Program on the earliest of the following dates:

(A) The date on which the unit first serves one or more generators with total

nameplate capacity in excess of 25 MWe;

(B) The date on which the unit burns any coal or coal-derived fuel except for

coal-derived gaseous fuel with a total sulfur content no greater than natural gas; or

(C) January 1 of the year following the year in which the annual average sulfur

content for nongaseous fuel burned at the unit exceeds 0.05 percent by weight (as

determined under 40 CFR Section 72.7(d)).

19.0 CD Title I Condition: To avoid

classification as a major

modification under 40 CFR

Section 52.21 and Minn. R.

7007.3000

For each day of operation of any GP 002 emission unit(s), record the operating

start and stop times. By the 15th of each month, calculate and record the total

combined GP 002 operating hours for the previous month, and for the previous

12-month period (12-month rolling sum).
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Subject Item: GP 005 Emergency Diesel Engines

Associated Items: EU 009 Fire Pump diesel engine

EU 010 Substation black start diesel generator

NC/

CA

Type Citation Requirement

1.0 CD hdr The requirements of this group apply individually to each associated item in this

group.

2.0 CD hdr EMISSION AND OPERATIONAL REQUIREMENTS

3.0 LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent once operating temperatures have been

attained.

4.0 LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential

to emit from the units is 0.29 lb/MMBtu due to equipment design and allowable

fuels.

5.0 CD 40 CFR Section 63.4(b); Minn. R.

7011.7000

Circumvention: The Permittee shall not build, erect, install, or use any article,

machine, equipment, or process to conceal an emission that would otherwise

constitute noncompliance with a relevant standard. Such concealment includes,

but is not limited to:

(1) ) The use of diluents to achieve compliance with a relevant standard based

on the concentration of a pollutant in the effluent discharged to the atmosphere

or

(2) ) The use of gaseous diluents to achieve compliance with a relevant standard

f i ibl i i 6.0 CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Change oil and filter every 500 hours of operation or annually, whichever comes

first. The Permittee has the option of utilizing an oil analysis program in order to

extend the oil change requirement as described below.

7.0 CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Inspect air cleaner every 1,000 hours of operation or annually, whichever comes

first, and replace as necessary.

8.0 CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

Inspect all hoses and belts every 500 hours of operation or annually, whichever

comes first, and replace as necessary.

9.0 CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle and minimize the

engine's startup time at startup to a period needed for appropriate and safe loading

of the engine, not to exceed 30 minutes, after which time the non-startup emission

limitations apply.

10.0 CD 40 CFR Section 63.6605(a); Minn.

R. 7011.8150

The Permittee shall be in compliance with the emission limitations and operating

limitations in this subpart that apply at all times.

11.0 CD 40 CFR Section 63.6605(b); Minn.

R. 7011.8150

At all times the Permittee shall operate and maintain EU 009 and EU 010, including

associated air pollution control equipment and monitoring equipment, in a 

manner consistent with safety and good air pollution control practices for

minimizing emissions. The general duty to minimize emissions does not require

the Permittee to make any further efforts to reduce emissions if levels required by

this standard have been achieved. Determination of whether such operation and

maintenance procedures are being used will be based on information available to

the Administrator which may include, but is not limited to, monitoring results, 

review of operation and maintenance procedures, review of operation and

maintenance records, and inspection of the source.

12.0 CD 40 CFR Section 63.6625(e); Minn.

R. 7011.8150

The Permittee shall operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer's emission-related written

instructions or develop a maintenance plan which must provide to the extent

practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

13.0 CD 40 CFR Section 63.6625(f); Minn.

R. 7011.8150

The Permittee shall install a non-resettable hour meter on EU 009 and EU 010 if

one is not already installed by the compliance date.

14.0 CD 40 CFR Section 63.6625(h); Minn.

R. 7011.8150

The Permittee shall minimize the engine's time spent at idle during startup and

minimize the engine's startup time to a period needed for appropriate and safe

loading of the engine, not to exceed 30 minutes, after which time the emission

standards applicable to all times other than startup apply.
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Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

15.0 CD 40 CFR Section 63.6625(i); Minn.

R. 7011.8150

The Permittee has the option of utilizing an oil analysis program in order to extend

the specified oil change requirement. The oil analysis must be performed at the

same frequency specified for changing the oil. The analysis program must at a

minimum analyze the following 3 parameters: Total Base Number, viscosity, and

percent water content. The condemning limits for these parameters are as follows:

Total Base Number is less than 30 percent of the Total Base Number of the oil

when new; viscosity of the oil has changed by more than 20 percent from the

viscosity of the oil when new; or percent water content (by volume) is greater than

0.5.

(continued below)

16.0 CD 40 CFR Section 63.6625(i); Minn.

R. 7011.8150

(continued from above)

If none of the condemning limits are exceeded, the engine owner or operator is not

required to change the oil. If any of the limits are exceeded, the engine owner or

operator must change the oil within 2 business days of receiving the results of the

analysis; if the engine is not in operation when the results of the analysis are

received, the engine owner or operator must change the oil within 2 business days

or before commencing operation, whichever is later. The owner or operator must

keep records of the parameters that are analyzed as part of the program, the

results of the analysis, and the oil changes for the engine. The analysis program

must be part of the maintenance plan for the engine.

17.0 CD 40 CFR Section 63.6640(a); Minn.

R. 7011.8150

The Permittee shall demonstrate continuous compliance with each emission

limitation and operating limitation in Table 2c of 40 CFR pt. 63, subp. ZZZZ that

apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ.

18.0 CD 40 CFR Section 63.6640(a); 40

CFR Section 63.6655(d); 40 CFR

pt. 63 subp. ZZZZ, Table 6; Minn.

R. 7011.8150

The Permittee shall operate and maintain the stationary RICE according to the

manufacturer's emission related operation and maintenance instructions; or the

Permittee shall develop and follow a maintenance plan which shall provide to the

extent practicable for the maintenance and operation of the engine in a manner

consistent with good air pollution control practice for minimizing emissions.

19.0 CD 40 CFR Section 63.6665; 40 CFR

pt. 63 subp. ZZZZ, Table 8; Minn.

R. 7011.8150

The Permittee shall comply with the General Provisions in 40 CFR Section 63.1

through 63.15, as applicable.

20.0 CD hdr REQUIREMENTS FOR EMERGENCY STATIONARY RICE

21.0 CD 40 CFR Section 63.6640(f); Minn.

R. 7011.8150

The Permittee shall operate the emergency stationary RICE according to the

requirements in paragraphs 40 CFR Section 63.6640 (f)(1) through (4) of 40 CFR

Section 63.6640(f). Any operation other than emergency operation, maintenance

and testing, emergency demand response, and operation in non-emergency

situations for 50 hours per year, as described in 40 CFR Section 63.6640(f)(1)

through (4), is prohibited. If the engine is not operated according to the

requirements in 40 CFR Section 63.6640(f)(1) through (4), the engine will not be

considered an emergency engine under this subpart and will need to meet all

requirements for non-emergency engines.

22.0 CD 40 CFR Section 63.6640(f)(1) -

(2); Minn. R. 7011.8150

(1) ) There is no time limit on the use of emergency stationary RICE in

emergency situations.

(2) ) The Permittee may operate the emergency stationary RICE for any

combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through

(iii) for a maximum of 100 hours per calendar year. Any operation for

non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) and (4)

counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

23.0 CD 40 CFR Section 63.6640(f)(2)(i);

Minn. R. 7011.8150

The Permittee may operate the emergency stationary RICE for the purpose of

maintenance checks and readiness testing, provided that the tests are

recommended by Federal, State or local government, the manufacturer, the

vendor, the regional transmission organization or equivalent balancing authority

and transmission operator, or the insurance company associated with the engine.

The Permittee may petition the Administrator for approval of additional hours to be

used for maintenance checks and readiness testing, but a petition is not required if

the Permittee maintains records indication that Federal, State, or local standards

require maintenance and testing of emergency RICE beyond 100 hours per year.
MINNESOTAPOLLUTION CONTROLAGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194

Page 14 of 16 1 Jul, 2014 10:40

COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

24.0 CD 40 CFR Section 63.6640(f)(2)(ii) -

(2)(iii); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand

response for periods in which the Reliability Coordinator under the North American

Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity

and Energy Emergencies (incorporated by reference, see Section 63.14), or other

authorized entity as determined by the Reliability Coordinator, has declared an

Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard

EOP-002-3.

2(iii) Emergency stationary RICE may be operated for periods where there is a

deviation of voltage or frequency of 5 percent or greater below standard voltage or

frequency.

25.0 CD 40 CFR Section 63.6640(f)(3);

Minn. R. 7011.8150

The Permittee may operate the emergency stationary RICE up to 50 hours per

calendar year in non-emergency situations, but those 50 hours are counted

towards the 100 hours per calendar year provided for maintenance and testing and

emergency demand response provided in 40 CFR Section 63.6640(f)(2). The 50

hours per year for non-emergency situations cannot be used for peak shaving or

non-emergency demand response, or to generate income for a facility to supply

power to an electric grid or otherwise supply power as part of a financial

arrangement with another entity.

26.0 CD hdr RECORDKEEPING REQUIREMENTS

27.0 CD 40 CFR Section 63.10(b)(1); Minn.

R. 7019.0100, subp. 2(B)

The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a

form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, or record.

Except that the most recent 2 years of data do not have to be retained on site.

28.0 CD 40 CFR Section 63.6655(d); Minn.

R. 7011.8150

The Permittee shall keep the records required in Table 6 of 40 CFR pt 63, subp.

ZZZZ, to show continuous compliance with each emission or operating limitation

that applies.

29.0 CD 40 CFR Section 63.6655(e); Minn.

R. 7011.8150

The Permittee shall keep records of the maintenance conducted on the stationary

RICE in order to demonstrate that the Permittee operated and maintained the

stationary RICE and after-treatment control device (if any) according to the

maintenance plan.

30.0 CD 40 CFR Section 63.6655(f); Minn.

R. 7011.8150

The Permittee shall keep records of the hours of operation of the engine that are

recorded through the non-resettable hour meter. The Permittee shall document

how many hours are spent for emergency operation; including what classified the

operation as emergency and how many hours are spent for non-emergency

operation. If the engine is used for demand response operation, the Permittee shall

keep records of the notification of the emergency situation, and the time the engine

was operated as part of demand response.

31.0 CD 40 CFR Section 63.6660; 40 CFR

Section 63.10(b)(1); Minn. R.

7011.8150; Minn R. 7019.0100,

subp. 2(B)

The Permittee shall maintain all records in a form suitable and readily available for

expeditious review according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record

for 5 years following the date of each occurrence, measurement, maintenance,

corrective action, report, or record.

The Permittee shall keep each record readily accessible in hard copy or electronic

form for at least 5 years after the date of each occurrence, measurement,

maintenance, corrective action, report, or record, according to 40 CFR section

63.10(b)(1).

32.0 CD hdr REPORTING AND NOTIFICATION REQUIREMENTS

33.0 CD 40 CFR Section 63.6640(b); Minn.

R. 7011.8150

The Permittee shall report each instance in which the stationary RICE did not meet

each applicable emission limitation or operating limitation. These instances are

deviations from the emission and operating limitations. These deviations shall be

reported according to the requirements in 40 CFR Section 63.6650.

34.0 CD 40 CFR Section 63.6640(e); 40

CFR pt. 63, subp. ZZZZ, Table 8;

Minn. R. 7011.8150

The Permittee shall report each instance when the applicable requirements in

Table 8 of 40 CFR pt. 63, subp. ZZZZ were not met.
MINNESOTAPOLLUTION CONTROLAGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194

Page 15 of 16 1 Jul, 2014 10:40

COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

35.0 CD 40 CFR Section 63.6602; 40 CFR

pt. 63, subp. ZZZZ, Table 2c;

Minn. R. 7011.8150

The Permittee shall report any failure to perform the work practice on the schedule

required in 40 CFR pt. 63, Table 2c due to an emergency or an unacceptable risk

under Federal, State or local law. The work practice shall be performed as soon as

practicable after the emergency has ended or the unacceptable risk under Federal,

State, or local law has abated.
MINNESOTAPOLLUTION CONTROLAGENCY

AIR QUALITY

520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194

Page 16 of 16 1 Jul, 2014 10:40

COMPLIANCE PLAN CD-01

Facility Name: Xcel Energy - Inver Hills Generating Plt

Permit Number: 03700015 - 004

Subject Item: TK 001 distillate oil

NC/

CA

Type Citation Requirement

1.0 CD hdr EMISSION AND OPERATIONAL LIMITS

2.0 CD Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity.
Attachment 4: Public Notice 

The public notice for this SIP revision was published in the State Register on January 20, 2015 with the public comment 

period commencing on January 20, 2015 and ending on February 20, 2015. A copy of the public notice is included here. 

The public notice for the joint Title I/Title V permit was published in South St. Paul’s Southwest Review newspaper on 

June 1, 2014 as well as on the MPCA website, with the public comment period commencing on June 2, 2014 and ending 

on July 1, 2014. A copy of the public notice is included here. 

Minnesota Pollution Control Agency 

Environmental Analysis and Outcomes Division 

Public Notice of Proposed State Implementation Plan Revision 

NOTICE IS HEREBY GIVEN that the Commissioner of the Minnesota Pollution Control Agency (MPCA) has 

determined that the State Implementation Plan (SIP) conditions for Flint Hills Resources LLC’s Pine Bend Refinery (FHR) 

located at 13775 Clark Road, Rosemount, Dakota County, Minnesota and Northern States Power Company’s Xcel Energy 

– Inver Hills Generating Plant (Inver Hills) located at 3185 117th Street East, Inver Grove Heights, Dakota County, 

Minnesota should be amended. Both facilities are located in the Rosemount/Pine Bend area of the Twin Cities Sulfur 

Dioxide (SO2) maintenance area for the three-hour, 24-hour, and annual SO2 National Ambient Air Quality Standards 

(NAAQS). 

FHR is currently subject to an Administrative Order (Order) containing Title I requirements which are included in 

Minnesota’s SIP and were found necessary to demonstrate compliance with the NAAQS for SO2. Air Emission Permit No. 

03700011-012 incorporates Title I requirements for FHR that are currently included in the Order. Under its Title I 

authority, the MPCA is revising the SIP conditions and will be formally requesting that the U.S. Environmental Protection 

Agency (EPA) amend Minnesota’s SIP to replace the Order and its requirements with the Title I SIP conditions specified 

in Air Emission Permit No. 03700011-012, which will serve as a joint Title I SIP/Title V document. These Title I conditions 

do not expire. This SIP revision is in being conducted in conjunction with the issuance of Air Emission Permit No. 

03700011-012. This permit was placed on public notice on December 23, 2014 until January 21, 2015. The permit and 

related documentation can be found on the MPCA’s website at http://www.pca.state.mn.us/yrwc6a9, listed under 

Tuesday, December 23, 2014 (on the Archived Public Notices page after January 21, 2015). After its issuance, the permit 

will be submitted to EPA for inclusion into Minnesota’s SIP to replace the Order. Until the time that the EPA accepts 

Permit No. 03700011-012 into the SIP, the Order is in full effect and FHR must comply with all aspects of it. Once EPA 

approves Permit No. 03700011-012 into the SIP, the MPCA will revoke the Order and the joint Title I/Title V permit will 

become the applicable enforcement document. 

Inver Hills’ permit incorporates Title I requirements which are included in Minnesota’s SIP and were found 

necessary to demonstrate compliance with the NAAQS for SO2. Title I conditions in Inver Hill’s Air Emission Permit No. 

03700015-003 are already included in Minnesota’s SIP. Under its Title I authority, the MPCA is revising the SIP 

conditions for this facility and will be formally requesting that the EPA amend Minnesota’s SIP to include the new and 

revised Title I SIP conditions in Inver Hill’s Air Emissions Permit No. 03700015-004, which will serve as a joint Title I 

SIP/Title V document. These Title I conditions do not expire. Permit No. 03700015-004 was placed on public notice from 

June 2, 2014 to July 1, 2014 and the MPCA subsequently issued the permit which is the enforceable document for Inver 

Hills. The permit can be viewed on the MPCA’s website at http://www.pca.state.mn.us/index.php/viewdocument.html?gid=21400. 

The proposed SIP revision is now available for public comment. 

Background. Title I of the Clean Air Act delegates to the states the authority to manage an air quality program 

and requires attainment of the NAAQS as promulgated by the EPA. Both the FHR facility and the Inver Hills facility are 

located in the Rosemount/Pine Bend area of the Twin Cities SO2 maintenance area for the three-hour, 24-hour, and 

annual SO2 NAAQS. A maintenance area is an area which at one time failed to meet one or more NAAQS, but is now in 

compliance and has an EPA-approved plan for continued attainment. Both FHR and Inver Hills are subject to facilityspecific Title I SIP conditions to ensure continued attainment of the SO2 NAAQS. 

Purpose of the SIP revision. This SIP revision is intended to incorporate new and revised Title I conditions for 

FHR, replace the existing Order, and incorporate all Title I SIP conditions into Permit No. 03700011-012, which will serve 

as a joint Title I/Title V document. The primary purpose of this SIP revision is to add a new process to enable the 

removal and recovery of more sulfur from fuel produced at the refinery. This new process will allow FHR to produce 

gasoline that meets the EPA’s Tier 3 gasoline sulfur standard, which is designed to improve ambient air quality. Changes 

to FHR’s SIP conditions that are included in Permit No. 03700011-012 as proposed are as follows: 
· Installation of a new process to convert gas-containing sulfur and nitrogen into a stable, non-hazardous, 

aqueous liquid fertilizer, ammonium thiosulfate (ATS), which will result in a new SO2 emission point. 

· Changes to the fuel gas sulfur monitoring requirements for the 45 unit mix drum to add direct monitoring of fuel 

gas total sulfur as an additional monitoring option to the current requirement to monitor at a representative 

stack for sulfur dioxide emissions. Remove outdated requirements for monitoring H2S. 

· Incorporate new, more restrictive language reflecting FHR’s current flaring policy, which allows for flaring only in 

the event of malfunction. 

· Assorted updates that serve to clarify the requirements of the Order by removing completed requirements and 

placeholders. 

This SIP revision also incorporates revised Title I requirements for Inver Hills, held in Permit No. 03700015-004 which 

serves as a joint Title I/Title V document, into Minnesota’s SIP. The changes to Inver Hill’s SIP conditions are as follows: 

· Residual fuel oil has been removed as an allowable fuel type in accordance with the revised SIP. 

· Removed SIP limits that were terminated on the date that EPA approved the revision to the previous SIP. 

There are no SIP-relevant construction changes being made to the Inver Hills facility and therefore this proposed SIP 

revision does not authorize any new operations or emission units at that facility. 

Air dispersion modeling has been conducted to verify that the changes proposed in this notice will not have an 

adverse impact on compliance with the NAAQS for SO2. 

MPCA contact person. The MPCA contact person is Amanda Jarrett Smith. Written comments, requests, and 

petitions should be mailed to: Amanda Jarrett Smith, Minnesota Pollution Control Agency, Environmental Analysis and 

Outcomes Division, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194; telephone: 651-757-2486 or toll free 

1-800-657-3864; fax: 651-297-8324; and e-mail: amanda.smith@state.mn.us. TTY users may call the MPCA at 

TTY 651-252-5332 or 1-800-657-3864. 

Availability of SIP. A copy of the proposed SIP revision is available on the MPCA’s web site at 

http://www.pca.state.mn.us/yrwc6a9. A copy of the proposed SIP revision is also available upon request by contacting 

Amanda Jarrett Smith at 651-757-2486 or amanda.smith@state.mn.us, or can be mailed to any interested person upon 

the MPCA’s receipt of a written request. Additional materials relating to the SIP revision are available for inspection by 

appointment at the MPCA, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194, between the hours of 8:00 a.m. 

and 4:00 p.m., Monday through Friday. To examine these materials, or for more information, please contact Amanda 

Jarrett Smith. All MPCA offices may be reached by calling 1-800-657-3864. 

Public comment period and potential public meeting. Your comments must be in writing and received by 

the MPCA by 4:30 p.m. on February 20, 2015. Written comments may be submitted to her at the address, facsimile

number, or e-mail address listed above. 

A public information meeting will only be held if one is requested by 4:30 p.m. on February 20, 2015. If such a 

meeting is requested, it will be held on February 26, 2015 at 1:30 p.m. at the MPCA St. Paul Office, 520 Lafayette Road 

North, St. Paul, Minnesota 55155-4194. To find out if a public information meeting will be held, please contact Amanda 

Jarrett Smith at 651-757-2486 or amanda.smith@state.mn.us after February 20, 2015 at 4:30 p.m. The public 

information meeting, if one is requested, will provide information, receive public input, and answer questions about the 

proposed SIP revision. If the public information meeting is held, additional written comments on the proposed 

documents will be accepted until 4:30 p.m. on March 6, 2015, following the same guidelines described above. 

Request to have MPCA Citizens’ Board make decision. You have the right to submit a petition to the MPCA 

Commissioner asking that the MPCA Citizens’ Board make the decision on submitting the proposed SIP revision to the 

EPA. Your petition must be in writing and must be received by the MPCA contact person listed above by 4:30 p.m. on 

February 20, 2015. Whether the petition will be granted or denied is at the sole discretion of the MPCA Commissioner. 

The MPCA Citizens’ Board will only make the decision on the proposed SIP revision if the MPCA Commissioner grants 
your petition or if an MPCA Citizens’ Board member makes a timely request to have the decision made by the MPCA 

Citizens’ Board.
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 TUESDAY 20 January 2015

 Volume 39, Number 29

 Pages 1071 - 1110
Minnesota State Register

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Contents

(Cite 39 SR 1073) Minnesota State Register, TUESDAY 20 January 2015 Page 1073

Minnesota Rules: Amendments & Additions

Vol. 39, #27-29: Monday 5 Jan. - TUESDAY 20 Jan. 2015................................. 1074

Proposed Rules

Public Utilities Commission (PUC)

Proposed Permanent Rules Relating to Residential

 White Pages Directory Publication and Distribution....................................... 1075

Expedited Rules

Health Department (MDH)

Adopted Expedited Rules Regulating Medical Cannabis Manufacturers....... 1080

Expedited Emergency Rules

Natural Resources Department (DNR)

Adopted Expedited Emergency Game and Fish Rules:

 Upper Red Lake Walleye Harvest............................................................................. 1086

Exempt Rules

Labor and Industry Department (DLI)

Occupational Safety and Health Division:

Proposed Exempt Permanent Rules Adopting Federal OSHA Standards........ 1088

Executive Orders

Office of the Governor

Emergency Executive Order 15-01: Declaring a State of Emergency

 in Minnesota and Providing Assistance to Stranded Motorists..................... 1090

Appointments

Iron Range Resources and Rehabilitation

Appointment of Commissioner Mark Phillips......................................................... 1091

Official Notices

Accountancy Board

Request for Comments on Possible Amendment to Rules Governing

 Expedited Licensing for Veterans and Housekeeping Updates....................... 1092

Architecture, Engineering, Land Surveying, Landscape

 Architecture, Geoscience and Interior Design

Request for Comments on Possible Amendment to Rules Governing

 Expedited Licensing for Veterans and Housekeeping Updates....................... 1093

Labor and Industry Department (DLI)

Labor Standards Unit:

Correction to Commercial Prevailing Wage Rates.................................................. 1094

Pollution Control Agency (MPCA)

Watershed Division:

Availability of the Draft Sauk River Watershed Restoration and

 Protection Strategy (WRAPS) Report and Request for Comment................... 1094

Watershed Division:

Public Notice of Availability of the Draft St. Clair Lake

 Total Maximum Daily Load and Request for Comment........................................ 1096

Environmental Analysis and Outcomes Division:

Public Notice of Proposed State Implementation Plan Revision....................... 1098

Transportation Department (Mn/DOT)

Notice to Bidders: Suspensions/Debarments as of January 12, 2015.............. 1100

Other Helpful Resources:

For additional contracts go to:

 http://www.mmd.admin.state.mn.us/solicitations.htm

 Contract information is available from the Materials Management (MMD)

 Helpline (651) 296-2600, or Web site: www.mmd.admin.state.mn.us

 For additional grants go to the Office of Grants Management (OGM) at:

 http://www.grants.state.mn.us/public/

 Revisor of Statutes - RULES STATUS:

 https://www.revisor.mn.gov/rules/rule_search.php

 Statewide Integrated Financial Tools (SWIFT) Supplier Portal:

 http://supplier.swift.state.mn.us

 Contract information is available from the Materials Management (MMD)

 Helpline (651) 296-2600, or Web site: www.mmd.admin.state.mn.us

 Minnesota State Register information is available from Minnesota’s

 Bookstore (651) 297-3000, or (800) 657-3757, Web site:

 www.minnesotasbookstore.com

State Grants & Loans

Transportation Department (MnDOT)

Office of Civil Rights:

Available Grant for Educational Institution to Participate as a Host Site

 in the National Summer Transportation Institute (NSTI) 2015 Program....... 1101

State Contracts

Administration Administration (Admin)

Real Estate and Construction Services:

Request for Proposal to Lease Office Space in Marshall, Minnesota................. 1102

Colleges and Universities, Minnesota State (MnSCU)

Minnesota State University Moorhead:

Request for Proposals for Retail Banking Campus Branch:

 Comstock Memorial Union......................................................................................... 1102

St. Cloud State University:

Availability of Request for Proposal for Owner’s Representative Services

 for Student Health and Academic Renovation - Eastman Hall......................... 1103

Winona State University:

Request for Proposals for Contract Services to

 Produce Recruiting Communications...................................................................... 1103

Sports Facilities Authority (MSFA)

Advertisement for Proposals for Document Management System....................... 1103

Transportation Department (Mn/DOT)

Engineering Services Division:

Contracting Opportunities for a Variety of Highway Related

 Technical Activities (“Consultant Pre-Qualification Program”).................... 1104

Engineering Services Division:

Professional/Technical Contract Opportunities and

 Taxpayers’ Transportation Accountability Act Notices.................................... 1105

Minnesota Zoo

Notice for the Minnesota Zoo Amphitheater Seating Renovation..................... 1105

Non-State Public Bids, Contracts & Grants

Metropolitan Airports Commission (MAC)

Minneapolis-Saint Paul International Airport:

Call for Bids for Intelligent Monitoring and Control Systems 2015 (P7)....... 1106

Minneapolis-Saint Paul International Airport:

Call for Bids for Modular Cooling Tower Installation........................................... 1106

Minneapolis-Saint Paul International Airport:

Call for Bids for 2015 Checkpoint Consolidation.................................................. 1107

Minneapolis-Saint Paul International Airport:

Call for Bids for 2015 Parking Structure Rehabilitation...................................... 1108

Minnesota’s Bookstore........................................................ 1108
 Minnesota Rules: Amendments and Additions

NOTICE: How to Follow State Agency Rulemaking in the State Register

 The State Register is the official source, and only complete listing, for all state agency rulemaking in its various stages. State

 agencies are required to publish notice of their rulemaking action in the State Register. Published every Monday, the State Register

 makes it easy to follow and participate in the important rulemaking process. Approximately 80 state agencies have the authority

 to issue rules. Each agency is assigned specific Minnesota Rule chapter numbers. Every odd-numbered year the Minnesota Rules

 are published. Supplements are published to update this set of rules. Generally speaking, proposed and adopted exempt rules do not

 appear in this set because of their short-term nature, but are published in the State Register.

 An agency must first solicit Comments on Planned Rules or Comments on Planned Rule Amendments from the public

 on the subject matter of a possible rulemaking proposal under active consideration within the agency (Minnesota Statutes §§ 14.101).

 It does this by publishing a notice in the State Register at least 60 days before publication of a notice to adopt or a notice of hearing,

 or within 60 days of the effective date of any new statutory grant of required rulemaking.

 When rules are first drafted, state agencies publish them as Proposed Rules, along with a notice of hearing, or a notice of intent

 to adopt rules without a hearing in the case of noncontroversial rules. This notice asks for comment on the rules as proposed.

 Proposed emergency rules, and withdrawn proposed rules, are also published in the State Register. After proposed rules have gone

 through the comment period, and have been rewritten into their final form, they again appear in the State Register as Adopted Rules.

 These final adopted rules are not printed in their entirety, but only the changes made since their publication as Proposed Rules. To see

 the full rule, as adopted and in effect, a person simply needs two issues of the State Register, the issue the rule appeared in as proposed,

 and later as adopted.

 The State Register features partial and cumulative listings of rules in this section on the following schedule: issues #1-13 inclusive;

 issues #14-25 inclusive (issue #26 cumulative for issues #1-26); issues #27-38 inclusive (issue #39, cumulative for issues #1-39); issues

 #40-52 inclusive, with final index (#1-52, or 53 in some years). An annual subject matter index for rules was separately printed usually

 in August, but starting with Volume 19 now appears in the final issue of each volume. For copies or subscriptions to the State Register,

 contact Minnesota’s Bookstore, 660 Olive Street (one block east of I-35E and one block north of University Ave), St. Paul, MN

 55155, phone: (612) 297-3000, or toll-free 1-800-657-3757. TTY relay service phone number: (800) 627-3529

Page 1074 Minnesota State Register, TUESDAY 20 January 2015 (Cite 39 SR 1074)

 Volume 39 - Minnesota Rules

 Index for Rules Appearing in Issues #27-29:

 Monday 5 Jan. - TUESDAY 20 Jan. 2015

Labor and Industry Department

International Residence Code:

1309.0311 (adopted exempt)...................................................... 1003

Health Department

4654.0800 (adopted expedited).................................................. 1046

4770.0200; .0300; .0400; .0500; .0600; .0700; .0800; .0850; .0900;

 .1000; .1100; .1200; .1300; .1600; .1700; .2000; .2100; .2200; .2300

 (adopted expedited).............................................................. 1080

Labor and Industry

Occupational Safety and Health Division:

5205.0010 (proposed exempt).................................................... 1088

Natural Resources Department

6232.2800; .3200; .4400 (adopted expedited)............................... 1006

6230.0250 s. 1; 6232.2800 s. 5, 6, 7; .2900 s. 2, 9; .3200 s. 3,

 (published in the State Register, vol. 37 38, page 1478 1381,

 April 15 21, 2013 2014); 6234.2400 s. 2 (published in the State

 Register, vol. 38, page 185, August 5, 2013); 6236.0300 s. 2;

 .0810 (published in the State Register, vol. 38, page 791,

 December 2, 2013); 6240.0400 s. 2 (published in the State Register,

 vol. 38, page 183, August 5, 2013) (repealed expedited)............ 1006

6264.0400 (adopted expedited emergency)................................. 1086

6264.0400, subpart 59, published in the State Register,

 volume 39, page 729, November 24, 2014, are repealed.............. 1086

Public Utilities Commission (PUC)

7810.0100; .2900; .2950; 7811.0600; 7812.0600 (proposed)........... 1075

Human Services Department

9544.0005; .0010; .0020; .0030; .0040; .0050; .0060; .0070; .0080;

 .0090; .0100; .0110; .0120; .0130; .0140 (proposed)................... 1031

9525.2700; .2710 s. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14a,

 15, 16a, 16b, 17, 19, 19a, 20, 21a, 22, 23, 24, 25, 26, 27, 28,

 29, 31, 32, 33a, 34, 35; .2720; .2730; .2740; .2750 s. 1, 1a,

 2, 2a, 4; .2760 s. 1, 2, 4, 5, 6; .2770 s. 1, 2, 5, 6; .2780 s. 2,

 3, 4, 5, 7; .2790; .2800; .2810 (proposed repealer effective

 August 31, 2015)................................................................... 1031
Page 1098 Minnesota State Register, TUESDAY 20 January 2015 (Cite 39 SR 1098)

(3) a timely request for a contested case hearing is pending. You may participate in the activities of the MPCA Board

 as provided in Minnesota Rules 7000.0650.

 The written comments, requests, and petitions submitted on or before the last day of the public comment period stated on page one of

this notice will be considered in the final decision on the TMDL report. If the MPCA does not receive written comments, requests, or

petitions during the public comment period, the MPCA staff, as authorized by the Board, will make the final decision on the draft TMDL

Report.

Dated: January 2015

Minnesota Pollution Control Agency (MPCA)

 Environmental Analysis and Outcomes Division

Public Notice of Proposed State Implementation Plan Revision

 NOTICE IS HEREBY GIVEN that the Commissioner of the Minnesota Pollution Control Agency (MPCA) has determined that the

State Implementation Plan (SIP) conditions for Flint Hills Resources LLC’s Pine Bend Refinery (FHR) located at 13775 Clark Road,

Rosemount, Dakota County, Minnesota and Northern States Power Company’s Xcel Energy – Inver Hills Generating Plant (Inver Hills)

located at 3185 - 117th Street East, Inver Grove Heights, Dakota County, Minnesota should be amended. Both facilities are located in the

Rosemount/Pine Bend area of the Twin Cities Sulfur Dioxide (SO2

) maintenance area for the three-hour, 24-hour, and annual SO2 National

Ambient Air Quality Standards (NAAQS).

 FHR is currently subject to an Administrative Order (Order) containing Title I requirements which are included in Minnesota’s SIP and

were found necessary to demonstrate compliance with the NAAQS for SO2

. Air Emission Permit No. 03700011-012 incorporates Title

I requirements for FHR that are currently included in the Order. Under its Title I authority, the MPCA is revising the SIP conditions and

will be formally requesting that the U.S. Environmental Protection Agency (EPA) amend Minnesota’s SIP to replace the Order and its

requirements with the Title I SIP conditions specified in Air Emission Permit No. 03700011-012, which will serve as a joint Title I SIP/

Title V document. These Title I conditions do not expire. This SIP revision is in being conducted in conjunction with the issuance of Air

Emission Permit No. 03700011-012. This permit was placed on public notice on December 23, 2014 until January 21, 2015. The permit

and related documentation can be found on the MPCA’s website at: http://www.pca.state.mn.us/yrwc6a9 , listed under Tuesday, December 23, 2014 (on the Archived Public Notices page after January 21, 2015). After its issuance, the permit will be submitted to EPA for

inclusion into Minnesota’s SIP to replace the Order. Until the time that the EPA accepts Permit No. 03700011-012 into the SIP, the Order

is in full effect and FHR must comply with all aspects of it. Once EPA approves Permit No. 03700011-012 into the SIP, the MPCA will

revoke the Order and the joint Title I/Title V permit will become the applicable enforcement document.

 Inver Hills’ permit incorporates Title I requirements which are included in Minnesota’s SIP and were found necessary to demonstrate

compliance with the NAAQS for SO2

. Title I conditions in Inver Hill’s Air Emission Permit No. 03700015-003 are already included in

Minnesota’s SIP. Under its Title I authority, the MPCA is revising the SIP conditions for this facility and will be formally requesting that

the EPA amend Minnesota’s SIP to include the new and revised Title I SIP conditions in Inver Hill’s Air Emissions Permit No. 03700015-

004, which will serve as a joint Title I SIP/Title V document. These Title I conditions do not expire. Permit No. 03700015-004 was placed

on public notice from June 2, 2014 to July 1, 2014 and the MPCA subsequently issued the permit which is the enforceable document for

Inver Hills. The permit can be viewed on the MPCA’s website at http://www.pca.state.mn.us/index.php/view-document.html?gid=21400.

 The proposed SIP revision is now available for public comment.

 Background. Title I of the Clean Air Act delegates to the states the authority to manage an air quality program and requires attainment

of the NAAQS as promulgated by the EPA. Both the FHR facility and the Inver Hills facility are located in the Rosemount/Pine Bend area

of the Twin Cities SO2

 maintenance area for the three-hour, 24-hour, and annual SO2 NAAQS. A maintenance area is an area which at one

time failed to meet one or more NAAQS, but is now in compliance and has an EPA-approved plan for continued attainment. Both FHR

and Inver Hills are subject to facility-specific Title I SIP conditions to ensure continued attainment of the SO2

 NAAQS.

 Purpose of the SIP revision. This SIP revision is intended to incorporate new and revised Title I conditions for FHR, replace the

existing Order, and incorporate all Title I SIP conditions into Permit No. 03700011-012, which will serve as a joint Title I/Title V

Official Notices
(Cite 39 SR 1099) Minnesota State Register, TUESDAY 20 January 2015 Page 1099

document. The primary purpose of this SIP revision is to add a new process to enable the removal and recovery of more sulfur from fuel

produced at the refinery. This new process will allow FHR to produce gasoline that meets the EPA’s Tier 3 gasoline sulfur standard, which

is designed to improve ambient air quality. Changes to FHR’s SIP conditions that are included in Permit No. 03700011-012 as proposed

are as follows:

· Installation of a new process to convert gas-containing sulfur and nitrogen into a stable, non-hazardous, aqueous liquid

fertilizer, ammonium thiosulfate (ATS), which will result in a new SO2

 emission point.

· Changes to the fuel gas sulfur monitoring requirements for the 45 unit mix drum to add direct monitoring of fuel gas total sulfur

as an additional monitoring option to the current requirement to monitor at a representative stack for sulfur dioxide emissions. Remove

outdated requirements for monitoring H2

S.

· Incorporate new, more restrictive language reflecting FHR’s current flaring policy, which allows for flaring only in the event

of malfunction.

· Assorted updates that serve to clarify the requirements of the Order by removing completed requirements and placeholders.

 This SIP revision also incorporates revised Title I requirements for Inver Hills, held in Permit No. 03700015-004 which serves as a joint

Title I/Title V document, into Minnesota’s SIP. The changes to Inver Hill’s SIP conditions are as follows:

· Residual fuel oil has been removed as an allowable fuel type in accordance with the revised SIP.

· Removed SIP limits that were terminated on the date that EPA approved the revision to the previous SIP.

 There are no SIP-relevant construction changes being made to the Inver Hills facility and therefore this proposed SIP revision does not

authorize any new operations or emission units at that facility.

 Air dispersion modeling has been conducted to verify that the changes proposed in this notice will not have an adverse impact on

compliance with the NAAQS for SO2

.

 MPCA contact person. The MPCA contact person is Amanda Jarrett Smith. Written comments, requests, and petitions should be

mailed to:

Amanda Jarrett Smith

Minnesota Pollution Control Agency

Environmental Analysis and Outcomes Division

520 Lafayette Road North

St. Paul, Minnesota 55155-4194

Telephone: (651) 757-2486 or

Toll free: 1-800-657-3864

Fax: (651) 297-8324

E-mail: amanda.smith@state.mn.us

TTY users may call the MPCA at: (651) 252-5332 or 1-800-657-3864

 Availability of SIP. A copy of the proposed SIP revision is available on the MPCA’s web site at http://www.pca.state.mn.us/yrwc6a9.

A copy of the proposed SIP revision is also available upon request by contacting Amanda Jarrett Smith at (651) 757-2486 or

amanda.smith@state.mn.us, or can be mailed to any interested person upon the MPCA’s receipt of a written request. Additional materials

relating to the SIP revision are available for inspection by appointment at the MPCA, 520 Lafayette Road North, St. Paul, Minnesota

55155-4194, between the hours of 8:00 a.m. and 4:00 p.m., Monday through Friday. To examine these materials, or for more information,

please contact Amanda Jarrett Smith. All MPCA offices may be reached by calling 1-800-657-3864.

 Public comment period and potential public meeting. Your comments must be in writing and received by the MPCA by 4:30 p.m.

on February 20, 2015. Written comments may be submitted to her at the address, facsimile number, or e-mail address listed above.

 A public information meeting will only be held if one is requested by 4:30 p.m. on February 20, 2015. If such a meeting is requested,

it will be held on February 26, 2015 at 1:30 p.m. at the MPCA St. Paul Office, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

To find out if a public information meeting will be held, please contact Amanda Jarrett Smith at 651-757-2486 or amanda.smith@state.mn.us

after February 20, 2015 at 4:30 p.m. The public information meeting, if one is requested, will provide information, receive public input,

and answer questions about the proposed SIP revision. If the public information meeting is held, additional written comments on the

proposed documents will be accepted until 4:30 p.m. on March 6, 2015, following the same guidelines described above.

Official Notices
Page 1100 Minnesota State Register, TUESDAY 20 January 2015 (Cite 39 SR 1100)

 Request to have MPCA Citizens’ Board make decision. You have the right to submit a petition to the MPCA Commissioner asking

that the MPCA Citizens’ Board make the decision on submitting the proposed SIP revision to the EPA. Your petition must be in writing

and must be received by the MPCA contact person listed above by 4:30 p.m. on February 20, 2015. Whether the petition will be granted

or denied is at the sole discretion of the MPCA Commissioner. The MPCA Citizens’ Board will only make the decision on the proposed

SIP revision if the MPCA Commissioner grants your petition or if an MPCA Citizens’ Board member makes a timely request to have the

decision made by the MPCA Citizens’ Board.

Minnesota Department of Transportation (Mn/DOT)

Notice to Bidders: Suspensions/Debarments as of January 12, 2015

NOTICE OF DEBARMENT

NOTICE IS HEREBY GIVEN that MnDOT has ordered that the following vendors be debarred for a period of three (3) years,

effective May 6, 2013 until May 6, 2016:

• Gary Francis Bauerly and his affiliates, Rice, MN

• Gary Bauerly, LLC and its affiliates, Rice, MN

• Watab Hauling Co. and its affiliates, Rice, MN

 NOTICE IS HEREBY GIVEN that MnDOT has ordered that the following vendors be debarred for a period of three (3) years,

effective September 17, 2014 until September 17, 2017:

• Jeffrey Plzak and his affiliates, Loretto, MN

• Laurie Plzak and her affiliates, Loretto, MN

• Honda Electric Incorporated and its affiliates, Loretto, MN

• Jeffrey and Laurie Plzak doing business as Honda Electric Logistics, and its affiliates, Loretto, MN

NOTICE IS HEREBY GIVEN that MnDOT has ordered that the following vendors be debarred for a period of three (3) years, effective

January 12, 2015 until January 12, 2018:

• Marlin Dahl, Granada, MN

• Dahl Trucking, Elmore, MN

• Elmore Truck and Trailer, Inc., Elmore, MN

Minnesota Statute section 161.315 prohibits the Commissioner, counties, towns, or home rule or statutory cities from awarding or

approving the award of a contract for goods or services to a person who is suspended or debarred, including:

1) any contract under which a debarred or suspended person will serve as a subcontractor or material supplier,

2) any business or affiliate which the debarred or suspended person exercises substantial influence or control, and

3) any business or entity, which is sold or transferred by a debarred person to a relative or any other party over whose actions

 the debarred person exercises substantial influence or control, remains ineligible during the duration of the seller’s or

 transfer’s debarment.

Official Notices

Attachment 5: Completeness Review 

A. Administrative Materials (40 CFR pt. 51, Appendix V, Part 2.1) 

The EPA’s Criteria for Determining the Completeness of Plan Submittals, published at 40 CFR part 51, Appendix V, 

requires states to provide the basic documents that show that the State has properly followed the administrative 

requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with 

these requirements, are discussed here: 

1) Formal Letter of Submittal: 

“A formal letter of submittal from the Governor or his designee, requesting EPA 

approval of the plan or revision thereof.”

Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, John Linc Stine, to the 

EPA Region V Administrator, Susan Hedman. The office of the Commissioner of the MPCA is statutorily created in 

Minnesota Statute § 116.03, subd. 1 (a). The Commissioner is appointed by the Governor, and the duties of the position 

include acting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federal 

law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the 

Commissioner. The Commissioner shall comply with any and all requirements of such federal law or such rules and 

regulations promulgated thereunder to facilitate application for, receipt, and disbursement of such funds.” Minn. Stat. § 

116.03 subd. 3. 

2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form 

“Evidence that the State has adopted the plan in the State code or body of regulations; 

or issued the permit, order, consent agreement (hereafter ‘document’) in final form. 

That evidence shall include the date of adoption or final issuance as well as the effective 

date of the plan, if different from the adoption/issuance date.”

Attachment 1 contains the joint Title I/Title V permit issued to Xcel Inver Hills, which consists of Air Emission Permit No. 

03700015-004. The joint Title I/Title V document includes relevant SIP conditions, labeled “Title I Condition: SIP for SO2 

NAAQS, 40 CFR pt. 50”. This Air Emission Permit became effective as soon as it was signed. All Title I SIP conditions are 

non-expiring. 

3) Legal Authority Documentation: 

“Evidence that the State has the necessary legal authority under State law to adopt and 

implement the plan.”

This SIP revision request is an update to MPCA’s Pine Bend SO2 SIP. This SIP was submitted by the MPCA in July 1992 and 

approved by EPA in the Federal Register on September 9, 1994. EPA’s approval of a redesignation request for the area 

was published on May 31, 1995 (60 FR 28339). Attachment C of the initial submittal documents MPCA’s legal authority 

to submit SIP revisions and to issue, modify, and revoke permits, as well as to enforce those permits. 

On May 2, 1995, EPA approved MPCA’s revised operating permit program as a SIP revision (60 FR 21447). MPCA 

submitted the operating permit program for inclusion in the SIP in part so that permits issued under the program could 

be considered federally enforceable vehicles for imposing emissions limitations on culpable sources located in 

nonattainment areas. 

EPA’s conclusion that MPCA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace 

Administrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to 

David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EPA Region 5 to Michael Sandusky of the MPCA and in 
a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have 

been submitted with previous SIP revisions. 

4) Compliance with State Procedures: 

“Evidence that the state followed all of the procedural requirements of the State’s laws 

and constitution in conducting and completing the adoption/issuance of the plan.”

MPCA complied with all relevant state procedures for issuing the permit as well as the SIP revision, including a public 

notice period and the opportunity to request a hearing. 

5) Public Notice: 

“Evidence that public notice was given of the proposed change consistent with the 

procedures approved by the EPA, including the date of the publication of the notice.”

The public notice for the SIP revision was published in the State Register on January 20, 2015 with the public comment 

period commencing on January 20, 2015 and ending on February 20, 2015. During the public comment period, a copy of 

the SIP revision was made available at the MPCA office located in St. Paul and on the MPCA’s website. A copy of the 

public notice is attached (Attachment 4). 

The public notice for the joint Title I/Title V permit was published in South St. Paul’s Southwest Review newspaper on 

June 1, 2014 as well as on the MPCA website, with the public comment period commencing on June 2, 2014 and ending 

on July 1, 2014. During the public comment period, a copy of the permit was made available on the MPCA’s website and 

at the MPCA offices in St. Paul. A copy of the public notice is attached (Attachment 4). 

 

6) Public Hearing Certification: 

“Certification that public hearing(s) were held in accordance with the information 

provided in the public notice and the State’s laws and constitution, if applicable.”

The public notice states: “A public information meeting will only be held if one is requested by 4:30 p.m. on February 20, 

2015. If such a meeting is requested, it will be held on February 26, 2015 at 1:30 p.m. at the MPCA St. Paul Office, 520 

Lafayette Road North, St. Paul, Minnesota 55155-4194. To find out if a public information meeting will be held, please 

contact Amanda Jarrett Smith at 651-757-2486 or amanda.smith@state.mn.us after February 20, 2015 at 4:30 p.m. The 

public information meeting, if one is requested, will provide information, receive public input, and answer questions 

about the proposed SIP revision. If the public information meeting is held, additional written comments on the proposed 

documents will be accepted until 4:30 p.m. on March 6, 2015, following the same guidelines described above.”

No public meeting was requested. 

7) Public Comments and State Response: 

“Compilation of the public comments and State’s response thereto.”

No public comments on the SIP were received. 

B. Technical Support: 

1) Pollutants Regulated: 

“Identification of all regulated pollutants affect by the plan.”
The regulated pollutant subject to this SIP revision is sulfur dioxide (SO2). 

2) Source Identification 

“Identification of the locations of affected sources including the EPA 

attainment/nonattainment designation of the locations and the state of the Attainment 

Plan for the affected area(s).”

The affected source within the Pine Bend portion of the AQCR131/Twin Cities SO2 maintenance area is Northern States 

Power Company’s Xcel Energy – Inver Hills Generating Plant. Further information on the facility is included in the 

attached Technical Support Document (Attachment 1). 

3) Emissions Quantification: 

“Quantification of the changes in the plan; allowable emissions from the affected 

sources; estimates of changes in current actual emissions from affected sources or, 

where appropriate, quantification of the changes in actual emissions through 

calculations of the differences between certain baseline levels and allowable emissions 

anticipated as a result of the revision.”

The changes allowed in this SIP revision call require that Inver Hills use a lower-sulfur content liquid fuel. This change 

will result in a reduction of SO2 emissions from this facility. Details can on the SIP changes can be found in the 

Background Document. 

4) NAAQS Protections: 

“The State’s demonstration that the NAAQS, prevention of significant deterioration 

increments, reasonable further progress demonstration, and visibility, as applicable, are 

protected if the plan is approved and implemented.”

The changes allowed in this SIP revision call require that Inver Hills use a lower-sulfur content liquid fuel. This change 

will result in a reduction of SO2 emissions from this facility. Details can on the SIP changes can be found in the 

Background Document. The proposed changes at the facility will help to maintain 3-hour, 24-hour, and annual SO2 

NAAQS and will not negatively impact the 1-hour standard.

5) Modeling Information 

“Modeling information required to support the proposed revision, including input data, 

output data, models used, justification of the model selections, ambient monitoring 

data used, meteorological data used, justification for use of off-site data (where used), 

modes of models used, assumptions, and other information relevant to the 

determination of adequacy of the modeling analysis.”

Because the revision to Inver Hills’ SIP will reduce SO2 emissions from the facility, air dispersion modeling was not 

conducted. 

6) Continuous Emission Reduction 

“Evidence, where necessary, that emission limitations are based on continuous emission 

reduction technology.”

These requirements are addressed in the permit and joint Title I/Title V document issued to the source (Attachment 1). 
7) Emission Level Assurance 

“Evidence that the plan contains emission limitations, work practice standards and 

recordkeeping/requirements, where necessary, to ensure emissions levels.”

These requirements are addressed in the permit and joint Title I/Title V document issued to the source (Attachment 1). 

8) Compliance/Enforcement 

“Compliance and enforcement strategies, including how compliance will be determined 

in practice.”

These requirements are addressed in the permit and joint Title I/Title V document issued to the source (Attachment 1). 

9) Special Economic and Technological Justifications: 

“Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary.”

Does not apply to this SIP submittal.