**Preliminary Determination, FID No**

**. 436123380**  **, Permit No. 436123380** 

**- P10**  **Page 1**  **of 6** 

ANALYSIS AND PRELIMI NARY DETERMINATION F OR THE

RENEWAL OF OPERATION PERMIT 436123380

- P01

FOR

MANITOWOC PUBLIC UTI LITIES

- CUSTER STREET

LOCATED AT

5740 WEST C USTER ST REET, 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 Desig nee: /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 Departme nt 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., an d 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 precaut ionary 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

c ontrol 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/Operat or: 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 D ate: July 1 1 , 2012

Dates of Additional Submittal s : 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 insignifican t 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 back up fuel. The turbine is also capable of burning a mix of gas and oil. Emissions of nitrogen oxides (NO

x ) 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 Exis ting 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 th e 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 Oxy gen 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 determination s for operation permit number 436123380

- P01 and construction permit 98

- RV

- 153 and remain unchang ed as a result of this renewal. Please refer to the preliminary determination s for these permits for a detailed description of the applicable requirements and emission calculations for the emissions units.

WISCONSIN HAZARDOUS AIR POLLUTANT (NR 445) REVIE W

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. P lease 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, t he 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 Reciprocat ing 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 doe s 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.

COMPLI ANCE 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

lim itation 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 a pplicant 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 unchan ged as a result of this renewal. Please refer to th at preliminary determination for a detailed description of the control technologies for the emissions units.

AIR QUALITY REVIEW An air dispersion mod eling 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 smal l equivalent inside diameter resulting in a higher exhaust gas exit velocity. Therefore, a new dispersion modeling analysis is not required . Results of the 98

- RV

153 modeling analysis are shown below. Note that the background concentrations in the tabl e below have been updated to current background levels

.

M ANITOWOC P UBLIC U TILITIES

- C USTER S TREET
Source Concentrations

NO X Ann ual SO 2 Ann ual SO 2 24

- Hr SO 2 3

- Hr PM 10 Ann ual PM 10 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/PM 10 /PM 2.5 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. Faci lity 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 als o 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 emis sions 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 s ource 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) N on

- 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

determination s for construction permit 98

- RV

- 153 and operation permit 436123380

- P01

. The only changes to

these requirements are the addition o f 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 re quirements 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 s s. 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

increme nt.

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 re new ed 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 re newal

. These proposed conditions may be changed as a result of public

co mments 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 operatio n permit re newal

.