Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 1 of 6

ANALYSIS AND PRELIMINARY DETERMINATION FOR THE

RENEWAL OF OPERATION PERMIT 436123380-P01

FOR

MANITOWOC PUBLIC UTILITIES - CUSTER STREET

LOCATED AT

5740 WEST CUSTER STREET,

MANITOWOC, MANITOWOC COUNTY, WISCONSIN

Operation Permit Renewal No.: 436123380-P10

Facility ID No.: 436123380

This review was performed by the Wisconsin Department of Natural Resources, Northeast Region Headquarters

in accordance with Chapter 285, Wis. Stats., and Chapters NR 400 to NR 499, Wis. Adm. Code. 

Reviewed by: Dave Minkey Date: 05/20/2013

Peer review 

conducted by: /s/ Brad Pyle Date: 05/21/2013

Preliminary Determination Approved by: Signature Date

Regional Supervisor or Central Office Designee: /s/ Imelda Hofmeister 05/21/2013

Stationary Source Modeling Team Leader: N/A

Compliance Engineer (reviewed/approved): /s/ Randy Matty 05/21/2013

cc: Bureau of Air Management (AM/7 – Operation Permits)

Manitowoc Public Library, 707 Quay St, Manitowoc, WI 54220-4220
Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 2 of 6

INTRODUCTION

Sources which are not exempt from the operation permit requirements under Section 407.03, Wis. Adm. Code, 

that were issued an operation permit from the Department of Natural Resources, are required to obtain a renewed 

air pollution control operation permit. Sources subject to the requirements must submit a permit renewal 

application to the Department by the date set forth in Sections 285.66(3)(a), Wis. Stats., and NR 407.04(2), Wis. 

Adm. Code. The renewal application is then reviewed following the provisions set forth in Sections 285.62, 

285.63 and 285.64, Wis. Stats., and Chapter NR 407, Wis. Adm. Code.

Subject sources are to be reviewed for their air pollution control technology and for their impact upon the air 

quality. This is to insure compliance with all applicable rules and statutory requirements. The review will show 

why the source(s) operation should be approved, conditionally approved, or disapproved. It will encompass 

emission calculations and air quality analysis using US EPA models, if applicable. Emissions from volatile 

organic compound (VOC) sources and small sources whose emissions are known to be insignificant are normally 

not modeled. As a precautionary note, the emission estimates may be based on US EPA emission factors (AP-42) 

or theoretical data and can vary from actual stack test data.

This review is based on information contained within the renewal application submitted for an air pollution 

control operation permit. A renewed operation permit may be issued if the criteria set forth in sections 285.63, 

284.64 and 285.66, Wis. Stats., are met.

A final decision on the renewal will not be made until the public has had an opportunity to comment on the 

Department’s analysis, preliminary determination and draft permit. After all comments have been considered, a 

proposed permit will be drafted and sent to the United States Environmental Protection Agency (US EPA) for a 

45-day review period. Any person may petition the US EPA under 40 CFR Part 70.8(d) within 60 days after the 

expiration of the 45-day review period to make an objection to the permit. Unless the US EPA objects in writing 

to the issuance of the permit as proposed within that 45-day period, the Department will issue the final permit as 

proposed. The conditions proposed in the draft permit may be revised in any final permit issued based on 

comments received or further evaluation by the Department.

GENERAL APPLICATION INFORMATION

Owner/Operator: Manitowoc Public Utilities - Custer Street 

1303 S 8th St 

Manitowoc, WI 54220-5313

Responsible Official: Nilaksh Kothari, General Manager

(920) 686-4351 

Application Contact Person: Thomas E. Reed, Environmental Engineer

(920) 686-4384

Application Submitted By: Thomas E. Reed, Environmental Engineer

(920) 686-4384

Application Receipt Date: July 11, 2012

Dates of Additional Submittals: April 11, 2013

 

Date of Complete Application: July 31, 2012

 
Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 3 of 6

PROJECT DESCRIPTION

This permit is the renewal of the operation permit for Manitowoc Public Utilities – Custer Street. The only 

physical change to the facility since the issuance of the previous operation permit is the replacement of the 

combustion turbine stack. The Department issued construction permit exemption 10-JJW-230-EXM for the 

replacement of the stack.

The Department will be making the following changes/additions to the permit:

• Remove the 500 hp black start diesel engine from the list of insignificant sources and add the applicable 

requirements from the National Emissions Standards for Hazardous Air Pollutants for Stationary 

Reciprocating Internal Combustion Engines, 40 CFR 63, Subpart ZZZZ.

• Add the applicable requirements of the Compliance Assurance Monitoring (CAM) rule in 40 CFR Part 64 for 

NOx emissions from the combustion turbine. 

• Minor changes/corrections to formatting and grammar.

Other Actions: 

None.

SOURCE DESCRIPTION

The Manitowoc Public Utilities – Custer Street facility is located in Manitowoc and is an electric generating 

facility consisting of a combustion turbine. The turbine is a single simple-cycle combustion turbine with a gross 

capacity of approximately 24.25 megawatts (at ISO condition and 59 °F) when firing natural gas, and 

approximately 23.75 megawatts (at ISO condition and 59 °F) when firing oil. The combustion turbine generating 

unit utilizes natural gas as its primary fuel, with No. 2 fuel oil as a backup fuel. The turbine is also capable of 

burning a mix of gas and oil. Emissions of nitrogen oxides (NOx) from the combustion turbine are controlled by 

the use of a water injection system when firing No. 2 fuel oil and/or natural gas.

Description of Existing Emissions Units.

The following emissions units at the facility were reviewed in the preliminary determination for operation permit 

436123380-P01 and remain unchanged as a result of the renewal:

Stack # Process # Process Description

S01 P01 24.25 MW simple-cycle combustion turbine

-- T01 112,828 gallon No. 2 fuel oil fixed roof storage tank

S02 P02 500 hp black start diesel engine

Please refer to the preliminary determination for operation permit 436123380-P01 for a detailed description of 

these emissions units.

The parameters for the combustion turbine replacement stack are shown below:

Stack # Discharge 

Direction

Exhaust 

Obstacle?

Width 

(ft)

Length 

(ft)

Height 

(ft)

S01 Up No 12 9.75 35.33

Insignificant Emissions Units.

• Maintenance of Grounds, Equipment, and Buildings (lawn care, painting, preventive maintenance, 

parts and equipment cleaning, etc.)

• Demineralization and Oxygen Scavenging of Water for Boilers

• Purging of Natural Gas Lines 

• Boiler, Turbine, and HVAC System Maintenance, including chemicals

• Pollution Control Equipment Maintenance
Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 4 of 6

• Internal Combustion Engine(s) Used for Warehouse and Material Transfer

• Fire Control Equipment

• Janitorial Services

• Office Activities 

• Convenience Water Heating 

• Convenience Space Heating (< 5 MMBTU/hr)

• Sanitary Sewer and Plumbing Venting

CROSS MEDIA IMPACTS

No additional cross media impacts are expected as a result of the permit renewal.

APPLICABLE REQUIREMENTS AND EMISSION CALCULATIONS.

The applicable requirements and emission calculations for all emission units at the facility were reviewed under 

the preliminary determinations for operation permit number 436123380-P01 and construction permit 98-RV-153 

and remain unchanged as a result of this renewal. Please refer to the preliminary determinations for these permits

for a detailed description of the applicable requirements and emission calculations for the emissions units.

WISCONSIN HAZARDOUS AIR POLLUTANT (NR 445) REVIEW

There are numerous hazardous pollutants expected to be emitted from the operation of the facility. These 

pollutants are regulated by Chapter NR 445, Wis. Adm. Code, and were reviewed in the preliminary 

determination for operation permit 436123380-P01. Please refer to the preliminary determination for that permit 

for details of the analysis.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) REVIEW

The facility is classified as an area source of federal HAP. As such, the combustion turbine is not subject to the 

National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines in 40 CFR 63, 

Subpart YYYY. 

The 500 hp black start diesel engine is subject to the requirements of the National Emissions Standards for 

Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines in 40 CFR 63, Subpart ZZZZ

for black start engines located at area sources.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) REVIEW

The combustion turbine does not appear to be subject to the NSPS for Stationary Gas Turbines in 40 CFR Part 60, 

Subpart GG and s. NR 440.50, Wis. Adm. Code, because the unit was constructed prior to October 3, 1977, and 

does not appear to have been modified since this time.

COMPLIANCE ASSURANCE MONITORING (CAM) REVIEW

The preliminary determination for operation permit 436123380-P01 stated that the combustion turbine was not 

subject to CAM because the facility was not using a control device to achieve compliance with an emission 

limitation or standard. However, facility utilizes water injection to comply with the NOx emission limit of 120 

pounds per hour. Water injection is considered a control device under the CAM rule. The applicant submitted a 

CAM plan April 11, 2013. The Department has reviewed this plan and finds it to be acceptable. The CAM plan 

will be attached to the permit as Part III.

COMPLIANCE AND TECHNOLOGY REVIEW

The control technologies for all emissions units were reviewed under the preliminary determination for operation 

permit 436123380-P01 and remain unchanged as a result of this renewal. Please refer to that preliminary 

determination for a detailed description of the control technologies for the emissions units. 

AIR QUALITY REVIEW

An air dispersion modeling analysis was performed in support of construction permit 98-RV-153. The only 

change to the facility since that permit was issued was the replacement of the combustion turbine stack. The 
Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 5 of 6

replacement stack will provide better dispersion due to a small equivalent inside diameter resulting in a higher 

exhaust gas exit velocity. Therefore, a new dispersion modeling analysis is not required. Results of the 98-RV153 modeling analysis are shown below. Note that the background concentrations in the table below have been 

updated to current background levels.

MANITOWOC PUBLIC UTILITIES-CUSTER STREET

Source Concentrations

NOX

Annual

SO2

Annual

SO2

24-Hr

SO2

3-Hr

PM10

Annual

PM10

24-Hr

CO

8-Hr

CO

1-Hr

S01 Impact (μg/m3) 0.0 0.5 1.5 2.5 0.0 0.2 0.2 0.4

Significant Impact Level (μg/m3) 1.0 1.0 5.2 25.0 1.0 5.0 500.0 2000.0

Background (μg/m3) 24.1 8.6 30.5 43.2 19.0 47.0 1,191.2 1,362.7

Total (μg/m3) 24.1 9.1 32.0 45.7 19.0 47.2 1191.4 1363.1

NAAQS (μg/m3) 100.0 80.0 365.0 1300.0 50.0 150.0 10000.0 40000.0 

% of NAAQS 24.1% 11.4% 8.8% 3.5% 38.0% 31.5% 11.9% 3.4%

TOTAL FACILITY EMISSIONS

Pollutant Potential to Emit Part 70 Major 

Source Threshold

PSD Major 

Source Threshold

lb/hr ton/yr ton/yr ton/yr

Particulate Matter/PM10/PM2.5 33.8 39.3 100 250

Sulfur Dioxide 170.5 198.5 100 250

Nitrogen Oxides 120.0 139.7 100 250

Carbon Monoxide 120.0 139.7 100 250

Volatile Organic Compounds 84.1 98.0 100 250

Lead 5.8x10-5 6.8x10-5 100 250

Federal HAP -- <<25 25 --

FACILITY AND PROJECT CLASSIFICATION

1. Existing Facility Status.

The existing facility is a major source under Part 70 because potential emissions of sulfur dioxide, nitrogen 

oxides and carbon monoxide exceed 100 tons per year. The existing facility is a minor source under PSD and 

an area source of federal HAP.

2. Facility Status After the Renewed Permit is Issued.

After renewal, the facility will continue to be a major source under Part 70 because potential emissions of 

sulfur dioxide, nitrogen oxides and carbon monoxide exceed 100 tons per year. The facility will also continue 

to be a minor source under PSD and an area source of federal HAP.

3. EPA Class Code After the Renewed Permit is Issued.

“A” [Means the source’s maximum theoretical emissions and potential to emit for one or more 

pollutants are greater than major source thresholds. The source is a major source (has a FOP)];

“SM80” [Means the source’s maximum theoretical emissions of one or more pollutants are greater than 

major source thresholds and potential to emit is at least 80% but less than 100% of major 

source thresholds. The source is a non-major source (has a FESOP)];

“SM” [Means the source’s maximum theoretical emissions of one or more pollutants are greater than 

major source thresholds but potential to emit for all pollutants is less than 80% of major source 

thresholds. The source is a non-major source (usually has a FESOP or a ROP)];

“B” [Means the source’s maximum theoretical emissions and potential to emit for all pollutants are 

less than major source thresholds. The source is a non-major source (has a SOP or a ROP)].
Preliminary Determination, FID No. 436123380, Permit No. 436123380-P10 Page 6 of 6

4. Summary.

NSR Applicability

Existing Facility After Permit Renewal

Major Minor Major Minor

PSD X X

Non-Attainment N/A N/A

Federal HAP X X

Part 70 

Applicability

Facility After Permit Renewal

Part 70 FESOP (Syn. Minor) Non-part 70

Status X

\

EPA Class Code

EPA Class Code After Permit Renewal

A SM80 SM B

Status X

COMPLIANCE DEMONSTRATION METHODS, MONITORING, AND RECORD KEEPING

The compliance demonstration methods for all emissions units at the facility were reviewed under the preliminary 

determinations for construction permit 98-RV-153 and operation permit 436123380-P01. The only changes to 

these requirements are the addition of the applicable requirements of the National Emissions Standards for 

Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 40 CFR 63, Subpart ZZZZ, 

for the 500 hp black start diesel engine and the addition of the applicable requirements of the Compliance 

Assurance Monitoring (CAM) rule for NOx emissions from the combustion turbine.

CRITERIA FOR OPERATION PERMIT APPROVAL

For renewal of the facility’s operation permit, the criteria for operation permit approval set forth in ss. 285.63 and 

285.64, Wis. Stats. must be met.

The Department finds that:

1. The source will meet applicable emission limits and other requirements.

2. The source will not cause nor exacerbate a violation of an ambient air quality standard or ambient air 

increment.

PRELIMINARY DETERMINATION FOR OPERATION PERMIT RENEWAL NO. 436123380-P10

The Wisconsin Department of Natural Resources has reviewed application and other materials submitted by 

Manitowoc Public Utilities - Custer Street for renewal of existing operation permit 436123380-P01 and hereby 

makes a preliminary determination that a renewed operation permit may be issued with the following Draft 

Applicable Limits and Draft Permit Conditions. A final decision regarding emission limits and conditions will be 

made after the Department has reviewed and evaluated all comments received during the public comment period. 

The proposed emission limits and other proposed conditions in the Draft Permit are written in the same form that 

they will appear in the operation permit renewal. These proposed conditions may be changed as a result of public 

comments or further evaluation by the Department. The United States Environmental Protection Agency will be 

given the opportunity to comment on the operation permit renewal of any Part-70 source prior to the Department 

making a final decision on the operation permit renewal.