AIR POLLUTION CONTROL CONSTRUCTION PERMIT

EI FACILITY NO: 737227040 CONSTRUCTION PERMIT NO.: 10-SDD-058

TYPE: Construction Permit for Process(es): B01, B02, P121, F122, F123, P124, F125, P131, P132, F133 and P141

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

Name of Source: We Energies – Biomass Fueled Cogeneration Facility

Street Address: 200 Grand Avenue, Rothschild, WI

Responsible Official, & Title: Scott A. Patulski, VP-Fossil Operations

is authorized to construct described in the plans and specifications dated Marc h 24, 2010, May 27, 2010, August 4, 2010, October 1, 2010, October 26, 20 10, October 28, 2010, and November 16, 2010 and operate boilers, material handling processes and othe r equipment / operations in conformity with the

conditions herein. The aut hority to construct, modify, replace and/ or reconstruct any process covered in this Construction Permit expires thirty (36) months from the date of issuance. This approved period to construct, modify, replace and/or reconstruct may be extended for up to 18 months upon request for cause, prior to expiration, unless otherwise specified by this construction permit. The conditions of this construction permit are permanent a nd may only be revised through a revision of the construction permit or through the issuance of a new construction permit. [s. 285.60(1), Wis. Stats.]

Conditions of the construction permit and the operati on permit marked with an asterisk (*) have been created outside of the Wisconsin’s federally approved State Implementation Plan (SIP) and are not federally enforceable.

This authorization requires compliance by the permit holder with the emission limitations, monitoring requirements and other terms and conditions set forth in Parts I and II hereof.

Dated at Madison, Wisconsin March 28, 2011

STATE OF WISCONSIN
DEPARTMENT OF NATURAL RESOURCES For the Secretary

By s/s JHM John H. Melby, Jr. Director Bureau of Air ManagementFID No. 737227040, Permit No. 10-SDD-058 Page 2 of 46

Part I

A. Boiler B02 – 350 MMBTU/hour natural gas. This boiler is subject to NSPS (Part 60, Subparts D and Db).

1. Particulate Matter including PM10 and PM2.5
a. Limitations: Best Available Control Technology (BACT).

(1) 0.0076 pounds/MMBTU at all times (s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058)

(2) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 12-month period.

(s. NR 405.08, Wis. Adm. Code , and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The boiler may only combust pipeline quality natural gas. (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Particulate Matter
Emissions: Whenever compliance emission testing is required, US EPA Method 5, including backhalf (Method 202) shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for PM2.5, US EPA Other Test Method 201A for filterable and US EPA Method 202 for condensable particulate shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(3) Maintain a monthly record of the hours of operation of boiler B02, a record of the total MMBTU of natural gas combusted in that month and the monthly average quantity of natural gas combusted in the most recent 12-month period. These records to be ava ilable within 10 days of the end of any month (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 3 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

2. Sulfur dioxide

a. Limitations:

(1) 0.0006 pounds/MMBTU heat input when combusting natu ral gas at all times (s. 285.65(7), Stats. , and 10-SDD058)

(2) Use of natural gas as specified in cond. A.2.b.(1) of this permit

(3) 3.25 tons in any month, averaged over any consecuti ve 12-month period, from boilers B01 and B02 combined.

(4) 0.2 pounds in any hour.

(5) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 12-month period.

(s. 285.65(7), Stats. and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The boiler may only combust pipeline quality natural gas (s. 285.65(7), WI Stats.). ( 1) Reference Test Method for Sulfur Dioxide Emissions: Whenever compliance emission testing is required, US EPA Method 6, 6A or 6C shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(2), Wis. Adm. Code]

(2) Within 10 days of the end of any month, the permittee
shall calculate the sulfur dioxide emissions for that month
for boiler B02 and the total emissions of sulfur dioxide for boilers B01 and B02 (combined) for the previous 12 months of operation (s. NR 439.04, Wis. Adm. Code).

(3) The permittee shall maintain a record of the calculations required under cond. I.A.2.c.(2) of this permit (s. NR 439.04, Wis. Adm. Code).FID No. 737227040, Permit No. 10-SDD-058 Page 4 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

3. Nitrogen oxides

a. Limitations 1 : BACT. 2

(1) 10 ppmvd (parts per million by volume) corrected to 5% oxygen, aver aged over any 30 consecutive day period;

and

(2) 7 pounds in any hour.

(3) Installation and use of ultra-low NOx bur ner technology for combustion of natural gas.

(4) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 12-month period.

(5) 0.20 pounds/MMBTU heat input, including periods of st artup, shutdown or malfunction, averaged over any 30 consecutive day period (40 CFR 60.44b and s. 285.65(13) Wi Stats.)

(s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The permittee shall install and properly operate an ultra low NOx burner system for combusting natural gas in boiler B02 (s. NR 405.08, Wis. Adm. Code)

(2) Prior to startup of the boiler, the permittee shall install, maintain, calibrate and opera te a continuous emission monitor (CEM) for measuring nitrogen oxides emissions from that boiler which meets the requirements of Performance specification 2 in 40CFR part 60, Appendix B. (ss. NR 405.08 and NR 439.09(2), Wis. Adm. Code).

(3) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEMS) required to be installed under cond. I.A.3.b.(2) of this permit. The CEM for the boiler shall be operational whenever nitrogen oxides may be being emitted from that boiler [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code ]

(4) Within 90 days of startup of the boiler, the CEM for
that boiler shall be certified in accordance with Performance specification 2 in 40CFR part 60, Appendix B (ss. NR 405.08 and NR 439.09, Wis. Adm. Code)

(5) Within 120 days of startup of the boiler, the permittee shall submit a QA/QC plan for the NOx CEM for that boiler to the Department for review (ss. NR 405.08 and NR 439.04(1), Wis. Adm. Code) (1) Reference Test Method for Nitrogen Oxide Emissions: Whenever compliance emission testing is required, US EPA Method 7, 7E or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall maintain all of the following
records: (a) The calculated emission rates required under cond. A.3.b.(7) of this permit. The 30-day period calculations shall be available within 5 days of the end of any 30-day period;
(b) A copy of the QA/QC plan for the CEM;
(c) Any records required under the QA/QC plan;
(d) a record of the 15 minute CEM readings, corrected to 3% oxygen, for each hour of boiler operation and the hourly emission rate for each hour of operation;
(e) a daily record of the quantity of natural gas used in cubic feet). (s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under par. (a) or a summary excess emission report under par. (b), as specified in writing by the department.

1 The NSPS limit for natural gas is 0.2 lb/MMBTU (approx. 17 0 ppmvd for gas) on a 30-day average basis.

2 The 30-day average emission rate may not include any hours or days in which that fuel type was not combusted.

3 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.FID No. 737227040, Permit No. 10-SDD-058 Page 5 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db). (6) The permittee shall follow the quality control and quality assurance plan required under cond. A.3.b.(5) of this permit at all times. This includes following the Plan as submitted to the Department and the Plan prior to as approved by the Department for the continuous emission monitoring system (CEMS) required for NOx emissions [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(7) The permittee shall demonstrate compliance with the
NOx emission limitations as follows:

a) Compliance with the hourly emission rate shall be determined by summing the 15 minute CEM readings and generating an hourly average emission rate.

(b) Compliance with any 30-day average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute NOx measurements in any hour to determine an hourly average NOx emission rate; ii. Calculating the average 30-day emission rate by averaging the hourly emission rates for each hour of operation in the past 30 days; and iii. A new 30-day rolling average emission rate is calculated each operating day as the average of all of the hourly NOx emission data for the preceding 30 operating days

.

(s. NR 405.08, Wis. Adm. Code)

(8) The boiler may only combust pipeline quality natural gas. (s. NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be conducted within 180 days after the start of operation of the process to show compliance with the emission limitation. 3 [s. NR 439.07, Wis. Adm. Code] (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of nitrogen oxides is defined as
follows: i. any hour in which the nitrogen oxides emission rate exceeds the hourly emission rate in cond. I.A.3.a.(1)(b) of this permit; or ii. Any 30-day period hour in which the nitrogen oxides emission rate exceeds the 30-day average emission rate in cond. I.A.3.a.(1)&(5) of this permit.
(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40 CFR 60.46b and s. 285.65(13), Stats.)

(4) Maintain a monthly record of the hours of operation of boiler B02 and a record of the total hours of operation in the most recent 12-month period. These records to be available within 10 days of the end of any month (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 6 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

4. Carbon Monoxide (CO)

a. Limitations: BACT.

(1) 0.060 pounds/MMBTU heat input averaged over any 30-day period (including all periods of operation); and

(2) 70 pounds in any hour.

(3) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 12-month period.

(s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Prior to startup of a boiler, the permittee shall install a
continuous emission monito r (CEM) for measuring carbon
monoxide emissions from that boiler which meets the requirements of Performance Specification 4 in 40CFR Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(2) The permittee shall calibrate, maintain and operate the continuous emission monitoring system (CEMS) required to be installed under cond. I.A.4.b.(2) of this permit. The CEM for the boiler shall be operational whenever carbon monoxide may be being emitted from that boiler [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code ]

(3) Within 90 days of startup of the boiler, the CEM for
that boiler shall be certified in accordance with Performance Specification 4 in 40CFR Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(4) Within 120 days of startup of the boiler, the permittee shall submit a QA/QC plan for the CO CEM for that boiler to the Department for review.

(5) The permittee shall follow the quality control and quality assurance plan required under cond. A.3.b.(5) of this permit at all times. This includes following the Plan as submitted to the Department and the Plan prior to as approved by the Department for the continuous emission monitoring system (CEMS) required for CO emissions [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(6) The permittee shall demonstrate compliance with the
CO emission limit as follows: a) Compliance with the hourly emission rate shall be determined by summing the 15 minute CEM readings and generating an hourly average emission rate. (1) Reference Test Method for carbon Monoxide
Emissions: Whenever compliance emission testing is required, US EPA Method 10, 10A or 10B or an alternate method approved in writing by the Department shall be used to demonstrate compliance. (s. NR 439.06(4), Wis. Adm. Code) (2) The permittee shall maintain the following records:

(a) The calculated emission rates required under cond. A.1.3.b.(6) of this permit. The 30-day period calculations shall be available within 5 days of the end of any 30-day period;
(b) the total heat input to the boiler;
(c) A copy of the QA/QC plan for the CEM;
(d) Any records required under the QA/QC plan;
(e) a record of the 15 minute CEM readings, corrected to 3% oxygen, for each hour of boiler operation and the hourly emission rate for each hour of operation; (f) the 30-day period calculations shall be available within 5 days of the end of any 30-day period. (3) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report

4 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the Department may approve, in writing, an ex tension of time to conduct the test(s).FID No. 737227040, Permit No. 10-SDD-058 Page 7 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db). (b) Compliance with any 30-day average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute CO measurements in any hour to determine an hourly average CO emission rate; ii. Calculating the average 30-day emission rate by averaging the hourly emission rates for each hour of operation in the past 30 days; and iii. A new 30-day rolling average emission rate is calculated each operating day as the average of all of the hourly CO emission data for the preceding 30 operating days

. (c) No period when the boiler is not operating may be used in calculating the 30 day average emission rate. (s. NR 405.08, Wis. Adm. Code)

(7) Initial compliance emission tests shall be conducted within 180 days after the start of operation of the process to show compliance with the emission limitation. 4 [s. NR 439.07, Wis. Adm. Code] shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of carbon monoxide is defined as
follows: i. any hour in which the carbon monoxide emission rate for
a boiler exceeds the 8-hour emission rate in cond. I.A.4.a.(3) of this permit; or ii. any 30-day period hour in which the carbon monoxide emission rate for a boiler exceeds the 30-day average emission rate in cond. I.A.4.a.(1) of this permit. (ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

(4) Maintain a monthly record of the hours of operation of boiler B02 and a record of the total hours of operation in the most recent 12-month period. These records to be available within 10 days of the end of any month (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 8 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

5. Volatile organic compounds (VOC)

a. Limitations: BACT.

(1) Comply with the carbon monoxide emissions limitat ions in conds. I.A.4.a.(1) and (2) of this permit.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Comply with the requirements of conds. I.A.4.b.(1)-(7) of this permit (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for VOC Emissions: Whenever compliance emission testing is required, US EPA Method 25A or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06(3)(a), Wis. Adm. Code]
(2) Comply with the recordkeeping requirements of conds. I.A.4.c.(2)-(4) of this permit (s. NR 439.04, Wis. Adm. Code)

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

6. Fluorides

a. Limitations: BACT.

(1) Combust only Natural gas in boiler B02.

(2) The total heat input to Boiler B02 may not exceed 180,845 mmBtu per month, averaged over any consecutive 12-month period

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) The boiler may only combust pipeline quality natural gas (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Fluoride Emissions: Whenever compliance emission testing is required, US EPA Method 13 or 13A or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]

(2) Maintain a monthly record of the hours of operation of boiler B02 and a record of the total hours of operation in the most recent 12-month period. These records to be available within 10 days of the end of any month (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 9 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

7. Visible Emissions (Opacity)

a. Limitations: BACT.

(1) 10% opacity; and

(2) Combust only natural gas in boiler B02.

(ss. NR 405.08 and NR 431.05, Wis. Adm. Code and NSPS and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

( 1) The boiler may only combust pipeline quality natural

gas. (s. NR 405.08, Wis. Adm. Code)

(2) Initial compliance emission tests shall be conducted within 180 days after the start of operation of the process to show compliance with the emission limitation. 5 [s. NR 439.07, Wis. Adm. Code]

(3) The permittee shall perform the compliance emission tests required under condition I.A.7.b.(2) every 60 months within 60 days from the date of the anniversary date of the original stack test. [s. NR 439.075(3)(b) Wis. Adm. Code] (1) Reference Test Method for Opacity: Whenever compliance emission testing is required, US EPA Method 9 or an alternate method approved in writing by the Department, shall be used to demonstrate compliance. [s. NR 439.06(9), Wis. Adm. Code]

5 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.FID No. 737227040, Permit No. 10-SDD-058 Page 10 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

8. Greenhouse Gases

a. Limitations: BACT.

(1) Greenhouse gas emissions may not exceed 185 lb CO 2 per 1,000 pounds of steam produced,
or 508 lb CO 2 per MWh of steam produced per month, averaged over any consecutive 12-month period. (s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Prior to startup of a boiler, the permittee shall install, maintain, calibrate and operate a continuous emission monitor (CEM) for measuring carbon
dioxide emissions from that boiler which meets the requirements of Performance specification 2 in 40CFR part 60, Appendix B. (ss. NR 405.08 and NR 439.09(2), Wis. Adm. Code).

(2) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEMS) required to be installed under cond. I.A.8.b.(2) of this permit. The CEM for a boiler shall be operational whenever carbon dioxide may be being emitted from that boiler [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm.
Code ]

(3) Within 90 days of startup of a boiler, the CEM
for that boiler shall be certified in accordance with Performance specification 2 in 40CFR part 60, Appendix B (ss. NR 405.08 and NR 439.09, Wis. Adm. Code)

(4) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the CO2 CEM for that boiler to the Department for review (ss. NR 405.08 and NR 439.04(1), Wis. Adm. Code)

(5) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEMS) required by condition [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(6) Prior to startup of a boiler, the permittee shall install, maintain, calibrate and operate meters for steam flow, temperature and pressure; and measure gross process steam output in pounds per hour and
MW-hours on a continuous basis. (7) The permittee shall demonstrate compliance with
the CO 2 e emission limitations as follows: (1) Reference Test Method for Carbon Dioxide Em issions: Whenever compliance emission testing is required, US EPA Method 3A or an alternate method approved in writing by the Department shall be used to de monstrate compliance. [s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall maintain all of the following records: (a) The calculated emission rates required under cond. A.1.3.b.(7) of this permit. The 30-day period calculations shall be available within 5 days of the end of any 30-day period;
(b) A copy of the QA/QC plan for the CEM;
(c) Any records required under the QA/QC plan;
(d) a record of the 15 minute CEM readings, for each hour of boiler operation and the hourly emission rate for each hour of operation;
(e) a daily record of the quantity of natural gas in cubic feet),
(s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under par. (a) or a summary excess emission report under par. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known
causes or for unknown causes. The re port shall identify the cause of any malfunction and the measures taken to reduce excess
emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or adjustments made to the system. iv. The date and starting and ending time of any period during

6 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.FID No. 737227040, Permit No. 10-SDD-058 Page 11 of 46

A. Boiler B02 – 350 MMBTU/hour natural gas. This bo iler is subject to NSPS (Part 60, Subparts D and Db).

(a) Compliance with any 12-month average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute CO2 measurements in any hour to determine an hourly average CO2 emission rate; ii. Calculating the average 12-month emission rate by averaging the hourly emission rates for each hour of operation in the past 12 months; and iii. A new 12-month average emission rate is calculated each month as the average of all of the hourly CO2 emission data for the preceding 12 month period

. (s. NR 405.08, Wis. Adm. Code)

(8) The boiler may only combust pipeline quality natural gas. (s. NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be conducted within 180 days after the ”initial operation” of the process to show compliance with
the emission limitation. 6 [s. NR 439.07, Wis. Adm. Code]

(10) The permittee shall perform the compliance emission tests required under condition I.A.3.b.(8) every 60 months within 60 days from the date of the anniversary date of the original stack test. [s. NR 439.075(1)(b) Wis. Adm. Code] which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of carbon dioxide is defined as follows: i. any 12-month period hour in which the carbon dioxide emission rate exceeds the 12-month average emission rate in cond. I.A.8.a.(1) of this permit. (ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)

(4) Maintain a monthly record of the hours of operation of boiler B02 and a record of the total hours of operation in the most recent 12-month period. These records to be available within 10 days of the end of any month (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 12 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

1. Particulate Matter including PM10 and PM2.5 (PM)

a . Limitations: Best Available Control Technology (BACT) and Maximum Achievable Control Technology (MACT)

BACT: (1) 0.024 pounds/MMBTU includi ng backhalf (condensible) particulat e matter for biomass alone or co-fired with natural gas, averaged over any 24-hour pe riod (s. NR 405.08, Wis. Adm. Code and NSPS and 10-SDD-058 );

(2) 0.0076 pounds/MMBTU including backhalf (condensible) particulate matter for exclusive natural gas combustion (s. NR 405.08, Wis. Adm. Code and 10-SDD-058 )

MACT: (3) 0.008 pounds/MMBTU filterable particulate matter only, averaged over any 24-hour period (s. 285.65(13),

Stats. and 10-SDD-058 ).

MACT: (4) At least 10% of the total heat input, on an annual average heat input basis, to Boiler B01 shall come from the
combustion of biomass as defined in cond. ZZZ 1.a.(1) of this permit (s. 285.65(13), Stats. and 10-SDD-058 )

BACT and MACT: (5) Fuel limitations as specified in cond. B. 1.b.(1) of this permit (s. NR 405.08, Wis. Adm. Code and 285.65(13), Stats. and 10-SDD-058 )

(6) Heat input to the boiler from natural gas shall be no greater than 250 mmBtu in any hour (s. NR 405.08, Wis. Adm.
Code and 10-SDD-058 ).

(7) 19.2 pounds in any hour (BACT) (s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

(8) 0.10 pounds/MMBTU heat input (s. NR 415.06(2)(c), Wis. Adm. Code)

(9) 0.085 pounds/MMBTU heat input, except during periods of startup, shutdown or malfunction (40 CFR 60.43b and s. 285.65(13) Wi Stats.)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The boiler may only combust pipeline quality natural gas and biomass as defined in cond. ZZZ.1.a.(2) of this permit (s. NR 405.08, Wis. Adm. Code)

(2) At all times that particulate matter may be emitted from this boiler, the boiler exhaus t shall pass through a baghouse prior to emission to the atmosphere (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(3) Prior to startup of a boiler, the permittee shall install a continuous emission monitor (CEM) for measuring particulate matter emissions which meet the requirements of Performance Specification 11 in 40CFR Part 60, Appendix B (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(4) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEM) required to be installed under cond. I.B.1.b.(3) of this permit. The CEM for a boiler shall be operational whenever particulate matter may be emitted from boiler B01 [ss. NR (1) Reference Test Method for Particulate Matter
Emissions: Whenever compliance emission testing is required for PM10, US EPA Method 5, including backhalf (Method 202) shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for PM2.5, US EPA Method 201A for filterable and US EPA Method 202 for condensable particulate shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(3) The permittee shall keep a record of any fuel received for use in boiler B01 which is not natural gas or biomass [s. NR 439.04(1)(d), Wis. Adm. Code.]

(4) The permittee shall maintain daily records, summarized monthly of all of the following and make such recordsFID No. 737227040, Permit No. 10-SDD-058 Page 13 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code]

(5) Within 90 days of startup of a boiler, the CEM for that
boiler shall be certified and correlated in accordance with Performance Specification 11 in 40CFR Part 60, Appendix B (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(6) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the PM CEM for that boiler to the Department for review.

(7) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEM) required by conditions I.B.1.b.(3)&(4) [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(8) All fuel sampling required under this permit shall be done in conformance with permit cond. I.ZZZ.4.a.(4) (s. NR 405.08, Wis. Adm. Code)

(9) Initial compliance emission tests shall be conducted within 180 days after the initial operation of the boiler to show compliance with the emission limitations in conds.1.a.(1)&(7). Additionally, the first compliance emission tests, only, shall also quantify the emission rate of PM10 and PM2.5 [s. NR 439.07, Wis. Adm. Code]

(10) The permittee shall perform the compliance emission tests required under condition I.B.1.a.(9) every 24 months within 60 days from the date of the last stack test. [s. NR 439.075(3)(b) Wis. Adm. Code]

(11) The permittee shall demonstrate compliance with the
PM emission limits as follows: (a) For the 24-hour emission limitation in cond. 1.a.(3). of
this section: i. By summing the 15 minute data points to calculate an hourly average emission rate (s. NR 405.08, Wis. Adm. Code) ii. By averaging the hourly average emission rates to determine a 24-hour average emission rate iii. No hour in which the boiler is non-operational may be used to compliance with hourly or 24-hour average PM
emission limitations (b) For the emission limitations in cond. 1.a.(1), (7) & (8): i. through the biennial stack testing required in cond. b.(10) of this section; and ii. demonstrating compliance with the particulate matter available within 5 days of the end of any month:
(a) the total heat input to boiler B01 from all fuels;
(b) the hourly heat input rate for each fuel burned in that hour; and
(f) a record of the 15 minute CEM readings for each hour of boiler operation and the hourly emission rate for each hour of operation;
(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)
(4) The permittee shall maintain the following records:
(a) A copy of the QA/QC plan for the CEM;
(b) Any records required under the QA/QC plan; (c) Design plans or specifications that indicate that the boiler does not have the capacity of combusting more than 250 MMBTU/hour of natural gas. [s. NR 439.04(1), Wis. Adm. Code]

(5) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing. (c) An excess emission of particulate matter is defined as: i. any 1-hour period in which the particulate matter
emission rate for a boiler exceeds the 1-hour emission rateFID No. 737227040, Permit No. 10-SDD-058 Page 14 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). emission limitation in cond. a.3. of this section; and iii. demonstrating compliance with the sulfur dioxide emission limitation in cond. b.2.a.(1) of this permit (c) Compliance with the emission limitation for natural gas combustion shall be demonstrated by combusting only pipeline quality natural gas. (s. NR 439.04, Wis. Adm. Code) in conds. I.B.1.a.(1)-(3) of this permit; ii. any 24-hour period in which the particulate matter
emission rate for a boiler exceeds the 1-hour emission rate in conds. I.B.1.a.(9) of this permit
(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40 CFR 60.46b and s. 285.65(13), Stats.)FID No. 737227040, Permit No. 10-SDD-058 Page 15 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

2. Sulfur Dioxide

a. Limitations:

(1) 8 pounds in any hour; and

(2) 3.25 tons in any month averaged over any 12-mo nth period from boilers B01 and B02 (combined)

(3) Heat input to the boiler from natural g as shall be less than 250 mmBtu per hour.

(4) Fuel limitations as specified in cond. B.2.b.(1) of this permit

(5) 0.20 pounds/MMBTU heat input averaged over an y 30 consecutive day period (40 CFR 60.42b and s. 285.65(13) Wi Stats.)

(s. NR 404.04, Wis. Adm. Code and s. 285.65(7), WI Stats. and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The boiler may only combust pipeline quality natural gas and biomass as defined in cond. ZZZ.1.a.(2) of this permit (s. 285.65(7), Wis. Stats.)

(2) Prior to startup of a boiler, the permittee shall install a continuous emission monitor (CEM) for measuring sulfur dioxide emissions which meet the requirements of 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 439.06(4), Wis. Adm. Code. (ss. NR 405.08 and NR 439.09(2) Wis. Adm. Code and s. 285.65(13), Stats.)

(3) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEM) required to be installed under cond. I.B.2.b.(2) of this permit. The CEM for a boiler shall be operational whenever sulfur dioxide may be emitted from boiler B01 [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code ]

(4) Within 90 days of startup of a boiler, the CEM for that boiler shall be certified in accordance with 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 439.06(4), Wis. Adm. Code. (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(5) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the SO2 CEM for that boiler to the Department for review.

(6) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEM) required by conditions (1) Reference Test Method for Sulfur Dioxide Emissions: Whenever compliance emission testing is required, US EPA Method 6, 6A or 6C shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(2), Wis.
Adm. Code ]
(2) The permittee shall maintain daily records, summarized monthly, of all of the following and make such records available within 5 days of the end of any month:
(a) the total heat input to boiler B01 from all fuels;
(b) the total heat input rate to boiler B01 from natural gas used in that month; and
(c) a record of the 15 minute CEM readings for each hour of boiler operation and the hourly emission rate for each hour of operation;
(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(3) The permittee shall maintain the following records:
(a) A copy of the QA/QC plan for the CEM;
(b) Any records required under the QA/QC plan; (c) Design plans or specifications that indicate that the boiler does not have the capacity of combusting more than 250 MMBTU/hour of natural gas.

[s. NR 439.04(1), Wis. Adm. Code]

(4) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emissionFID No. 737227040, Permit No. 10-SDD-058 Page 16 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). I.B.2.b.(2)&(3) [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(7) The permittee shall demonstrate compliance with the SO2 emission limits by summing the 15 minute CEM readings and generating an hourly average SO2 emission rate (s. NR 405.08, Wis. Adm. Code)

(8) Initial compliance emission tests shall be conducted within 180 days after initial operation of the process to show compliance with the emission limitation. [s. NR 439.07, Wis. Adm. Code] reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of sulfur dioxide is defined as
follows: i. any 1-hour period in which the sulfur dioxide emission
rate for a boiler exceeds the 1-hour emission rate in cond. I.B.2.a.(1) of this permit. b. any 30-day period in which the sulfur dioxide emission
rate for a boiler exceeds the emission rate in cond. I.B.2.a.(5) of this permit
(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40 CFR60.47b)FID No. 737227040, Permit No. 10-SDD-058 Page 17 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

3. Nitrogen oxides

a. Limitations: Best Available Control Technology (BACT): Emissions may not exceed:

(1) 0.10 pounds/MMBTU averaged over any 30 consecutive day period and use of Selective Non-Catalytic Reduction (SNCR) (s. NR 405.08, Wis. Adm. Code and 10-SDD-058);

(2) 320 pounds in any hour; and (ss. NR 405.08 and NR 404.04, Wis. Adm. Code and 10-SDD-058

(3) Fuel limitations as specified in cond. B.3.b.(1) of this permit (s. NR 405.08, Wis. Adm. Code and 285.65(13), Stats. and 10-SDD-058)

(4) Heat input to the boiler from natural gas shall be less than 250 mmBtu per hour (s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

(5) 0.20 pounds/MMBTU heat input, including periods of startup, shutdown or malfunction, averaged over any 30 consecutive day period (40CFR60.44 b and s. 285.65(13) Wi Stats.)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The boiler may only combust pipeline quality natural gas and biomass as defined in cond. ZZZ.1.a.(2) of this permit (s. NR 405.08, Wis. Adm. Code)

(2) Prior to startup of the boiler, the permittee shall install a continuous emission monitor (CEM) for measuring nitrogen oxide emissions which meet the requirements of 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 439.06(4), Wis. Adm. Code. (ss. NR 405.08 and NR 439.09(2) Wis. Adm. Code and s. 285.65(13), Stats.)

(3) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEM) required to be installed under cond. I.B.3.b.(2) of this permit. The CEM for a boiler shall be operational whenever nitrogen oxides may be emitted from boiler B01 [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code ]

(4) Within 90 days of startup of the boiler, the CEM for
that boiler shall be certified and correlated in accordance with 40 CFR Part 75, s. NR 440.20(7)(b), Wis. Adm. Code and s. NR 439.06(4), Wis. Adm. Code. (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(5) Within 120 days of startup of the boiler, the permittee shall submit a QA/QC plan for the PM CEM for that boiler to the Department for review.

(6) The permittee shall follow a quality control and quality (1) The permittee shall keep a record of any fuel received for use in boiler B01 which is not natural gas or biomass [s. NR 439.04(1)(d), Wis. Adm. Code.]
(2) The permittee shall maintain daily records, summarized monthly of all of the following and make such records available within 5 days of the end of any month:
(a) the total heat input to boiler B01 from all fuels;
(b) the total heat input rate to boiler B01 from each fuel used in that month; (c) The calculated emission rates required under cond. B.3.b.(7) of this permit, and;
(d) a record of the 15 minute CEM readings for each hour of boiler operation and the hourly emission rate for each hour of operation;
(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)

(3) The permittee shall maintain the following records:
(a) A copy of the QA/QC plan for the CEM;
(b) Any records required under the QA/QC plan; [s. NR 439.04(1), Wis. Adm. Code]

(4) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emissionFID No. 737227040, Permit No. 10-SDD-058 Page 18 of 46

B. Boiler B01 – Biomass and natural gas fired boiler with a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEM) required by conditions I.B.3.b.(2)&(3) [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(7) The permittee shall demonstrate compliance with the
NOx emission limitations as follows: (a) Compliance with the hourly emission rate shall be determined by summing the 15 minute CEM readings and generating an hourly average emission rate. (b) Compliance with any 30-day average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute NOx measurements in any hour to determine an hourly average NOx emission rate; ii. Calculating the average 30-day emission rate by averaging the hourly emission rates for each hour of operation in the past 30 days; and iii. A new 30-day rolling average emission rate is calculated each operating day as the average of all of the hourly NOx emission data for the preceding 30 operating days

.

(d) No hour in which the boiler is non-operational may be used to determine compliance with any NOx emission
limitation.

(8) Initial compliance emission tests shall be conducted within 180 days after initial operation of the boiler to show compliance with the emission limitation. [s. NR 439.07, Wis. Adm. Code] report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of nitrogen oxides is defined as
follows: i. any 1-hour period in which the nitrogen oxides emission
rate for the boiler exceeds the 1-hour emission rate in cond. I.B.3.a.(2) of this permit; or ii. any 30-day period in which the nitrogen oxides emission rate for the boiler exceeds the 30-day average emission rate in conds. I.B.3.a.(1)&(5) of this permit.
(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code; 40CFR60.46b and s. 285.65(13), Stats.)

(5) Reference Test Method for Nitrogen Oxide Emissions: Whenever compliance emission testing is required, US EPA Method 7 or an alternate method approved in writing by the Department shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(6), Wis. Adm. Code]FID No. 737227040, Permit No. 10-SDD-058 Page 19 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

4. Carbon Monoxide (CO)

a. Limitations: BACT and MACT 7 . Emissions may not exceed:

(1) 0.12 pounds/MMBTU heat input averaged over any 12-mo nth period including all periods of operation (MACT and BACT);

(2) 0.12 pounds/MMBTU heat input averaged over any 30-day period excluding periods of boiler startup and shutdown (MACT and BACT); and

(3) 800 pounds in any hour.

(s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats. and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Prior to startup of a boiler, the permittee shall install a
continuous emission monito r (CEM) for measuring carbon
monoxide emissions from that boiler which meets the requirements of Performance Specification 4 in 40CFR Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(2) The permittee shall maintain, calibrate and operate the continuous emission monitoring system (CEMS) required to be installed under cond. I.B.4.b.(1) of this permit. The CEM for a boiler shall be operational whenever carbon monoxide may be being emitted from the boiler [ ss. NR 407.09(4)(a)1., and NR 439.09(5), Wis. Adm. Code ]

(3) Within 90 days of startup, the CEM shall be certified in accordance with Performance Specification 4 in 40CFR Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(4) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the CO CEM for that boiler to the Department for review.

(5) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEMS) required by condition [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(6) The permittee shall demonstrate compliance with the
CO emission limit as follows: (a) Compliance with the hourly emission rate shall be determined by summing the 15 minute CEM readings and generating an hourly average emission rate. (1) Reference Test Method for Carbon Monoxide
Emissions: Whenever compliance emission testing is required, US EPA Method 10, 10A or 10B or an alternate method approved in writing by the Department shall be used to demonstrate compliance. (s. NR 439.06(4), Wis. Adm. Code)
(2) The permittee shall maintain daily records, summarized monthly of all of the following and make such records available within 5 days of the end of any month:
(a) the total heat input to boiler B01 from all fuels;
(b) the total heat input rate to boiler B01 from each fuel used in that month; and
(c) The calculated emission rates required under cond. I.B.4.b.(6) of this permit, and;
(d) a record of the 15 minute CEM readings for each hour of boiler operation and the hourly emission rate for each hour of operation;
(s. 285.65(13), Wis. Stats.; s. NR 439.04(1), Wis. Adm. Code and NSPS; s. NR 440.205(10)(d), Wis. Adm. Code)
(3) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;
(b) Any records required under the QA/QC plan; [s. NR 439.04(1), Wis. Adm. Code]

(4) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department.

7 The MACT emission limitation is for control of organic HAP’s (i.e. products of incomplete combustion).

8

.FID No. 737227040, Permit No. 10-SDD-058 Page 20 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). (b) Compliance with any 30-day average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute NOx measurements in any hour to determine an hourly average NOx emission rate; ii. Calculating the average 30-day emission rate by averaging the hourly emission rates for each hour of operation in the past 30 days; and iii. A new 30-day rolling average emission rate is calculated each operating day as the average of all of the hourly NOx emission data for the preceding 30 operating days

. (c) No period in which the boiler is not operating may be used in calculating the averag e emissions from the boiler. (s. NR 405.08, Wis. Adm. Code)

(7) Initial compliance emission tests shall be conducted within 180 days after initial operation of the boiler to show compliance with the emission limitation. 8 [s. NR 439.07, Wis. Adm. Code] (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of carbon monoxide is defined as
follows: i. any 1-hour period in which the carbon monoxide
emission rate for the boiler exceeds the 1-hour emission rate in cond. I.B.4.a.(3) of this permit; or ii. any 30-day period in which the carbon monoxide emission rate for the boiler exceeds the 30-day average emission rate in cond. I.B.4.a.(1) or (2) of this permit.
(ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 21 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

5. Volatile organic compounds (VOC)

a. Limitations: BACT.

(1) Comply with the carbon monoxide emissions limitatio ns in conds. I.B.4.a.(1), (2) and (3) of this permit.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) Comply with the requirements of conds. I.B.4.b.(1)-(6) of this permit (s. NR 405.08, Wis. Adm. Code)

(2) Initial emission tests shall be conducted within 180 days after initial operation of the boiler to determine the VOC emission rate from boiler B01. [s. NR 439.07, Wis. Adm. Code] (1) Reference Test Method for VOC Emissions: Whenever compliance emission testing is required, US EPA Method 25A or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06(3)(a), Wis. Adm. Code]
(2) Comply with the recordkeeping requirements of conds. I.B.4.c.(2)-(4) of this permit (s. NR 439.04, Wis. Adm. Code)

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

6. Fluorides

a. Limitations: BACT.

(1) Combust only biomass or natural gas in boiler B01.

(s. NR 405.08, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) Combust only biomass or natural gas in boiler B01 (s. NR 405.08, Wis. Adm. Code). (2) Initial emission tests shall be conducted within 180 days after initial operation of the boiler to determine the fluoride emission rate from boiler B01. [s. NR 439.07, Wis. Adm. Code] (1) Reference Test Method for Fluoride Emissions: Whenever compliance emission testing is required, US EPA Method 13 or 13A or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]
(2) Comply with the recordkeeping requirements of cond. I.B.1.c.(3) of this permit (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 22 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

7. Visible Emissions (Opacity)

a. Limitations: BACT.

(1) Not more than 10% opacity; and

(2) Combust only biomass or natural gas in boiler B01.

(ss. NR 405.08 and NR 431.05, Wis. Adm. Code and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

( 1) Comply with the requirements of conds. I.B.1.b.(1)-(9) of this permit (s. NR 405.08, Wis. Adm. Code) (2) Initial compliance emission tests shall be conducted within 180 days after the start of operation of the process to show compliance with the emission limitation. [s. NR 439.07, Wis. Adm. Code]

(3) Prior to startup of a boiler, the permittee shall install a continuous opacity monitor (COM) for measuring opacity from the boiler which meets the requirements of 40 CFR Part 60, Appendix B, Performance Specification 1 (s. NR 405.08 and NR 439.09(1), Wis. Adm. Code)

(4) The permittee shall maintain, calibrate and operate the continuous opacity monitoring system (COMS) required to be installed under cond. I.B.7.b.(4) of this permit. The COM for the boiler shall be operational whenever the boiler is operating [ ss. NR 407.09(4)(a)1., and NR 439.09(1), Wis. Adm. Code ]

(5) Within 90 days of startup, the COM shall be certified in accordance with Performance Specification 1 in 40 CFR Part 60, Appendix B (s. NR 405.08 and NR 439.09(4), Wis. Adm. Code)

(6) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the COM for the boiler to the Department for review.

(7) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous opacity monitoring system (COM) required by condition [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code]

(8) The permittee shall demonstrate compliance with the
visible emission limit as follows: (a) by completing one cycle of sampling and (1) Reference Test Method for Opacity: Whenever compliance emission testing is required, US EPA Method 9 or an alternate method approved in writing by the Department, shall be used to demonstrate compliance. [s. NR 439.06(9), Wis. Adm. Code]
(2) Comply with the recordkeeping requirements of cond. I.B.1.c.(1)-(3) of this permit (s. NR 439.04, Wis. Adm. Code)

(3) See I.B.1.c.(4)

(4) The permittee shall maintain
a record of the 6-minute average COM readings for each hour of boiler operation (s. NR 439.04(1), Wis. Adm. Code);
(3) The permittee shall maintain the following records:

(a) A copy of the QA/QC plan for the CEM;
(b) Any records required under the QA/QC plan; [s. NR 439.04(1), Wis. Adm. Code]

(4) The owner or operator of a continuous opacity monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under subd. (a) or a summary excess emission report under subd. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the
emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known causes or for unknown causes. The report shall identify the cause of any malfunction and the
measures taken to reduce excess emissions. iii. The date and starting and ending time of any periodFID No. 737227040, Permit No. 10-SDD-058 Page 23 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). analyzing for each successive 10

− second period; and (b) one cycle of data recording for each successive

6

− minute period. during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or ad justments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating
such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of opacity is defined as any

6

− minute period during which the average opacity exceeds the applicable emission limit.
(ss. NR 405.08 and NR 439.09(10)(b)1., Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 24 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

8 . Mercury

a. Limitations: MACT 9

(1) Not more than 0.2 x 10 -6 pounds/MMBTU (0.2 pounds per trillion BTU heat input) heat. This limitation applicable at all times with compliance demonstrated th rough a stack test and fuel mercury content limitations.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

( 1) Within 180 days of initial operation, conduct a stack test on boiler B01 to demonstrate compliance with the mercury emission limitation in cond. I.B.8.a.(1) of this permit. This test to be repeated annually within 60 days of the anniversary date of the initial compliance test. (s. 285.65(13), Stats.) (2) At a minimum of 6 months prior to commencing operation of boiler B01, submit a plan for monitoring the fuel mercury content to ensure that the mercury emission limitations are being met. The Department, after public comment, may approve, amend or disapprove this plan. Boiler B01 may not operate without an approved monitoring plan (s. NR 405.08, Wis. Adm. Code). (1) Reference Test Method for Mercury Emissions: Whenever compliance emission testing is required, US EPA Method 29, ASTM-D6784-02 or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

9. Dioxin/Furans

a. Limitations: MACT. 10

(1) Not more than 0.007 nanograms per dry standard cubic meter (ng/dscm) as toxic equivalents (TEQ), corrected to 7% oxygen on a 3-hour average.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

9, The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutiona l Boilers and Process Heaters"; Vol. 75 Federal Register No. 107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes operational for this permitted source. If that occurs and if th e new federal rule establishes an emission limitation for dioxi n/furans which is different from the limit set forth above, the permittee may file a permit revision request with the Department, seekin g to conform the permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Section 285.27(2), Wis. St ats., the Department will take action to consider the approval of the revision request pursuant to applicable air permit rules and pr ocedures which include the issuance of a public no tice and opportunity for public comment.

10 The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institu tional Boilers and Process Heaters"; Vol. 75 Federal Regis ter No. 107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes operational for this permitted source. If that occurs and if th e new federal rule establishes an emission limitation for mercu ry which is different from the limit set forth above, the permittee may file a permit revision request with the Department, seeking to conf orm the permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Sectio n 285.27(2), Wis. Stats., theFID No. 737227040, Permit No. 10-SDD-058 Page 25 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) Comply with all of the compliance demonstration requirements of conds. I.B.4.b., I.B.8.b. and I.B.10.b. of this permit (s. 285.65(13), Stats.) (2) Within 180 days of initial operation, conduct a stack
test on boiler B01 to determine the dioxin and furan emission rates for this boiler. This test shall be repeated every 5 years within 60 days of the anniversary date of the initial test. (s. 285.65(13), Stats.) (1) Reference Test Method for dioxin Emissions: Whenever compliance emission testing is required, US EPA Method 23 or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]
(2) Comply with all of the recordkeeping requirements of conds. I.B.4.c., I.B.8.c. and I. B.10.bc of this permit (s. NR 439.04, Wis. Adm. Code)

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

10. Hydrogen Chloride (HCl)

a. Limitations: MACT. 11

(1) Not more than 0.004 pounds/MMBTU heat input. This limitation applicable at all times with compliance demonstrated through a stack test and fuel chlorine content limitations.

(s. 285.65(13), Wis. Stats. and 10-SDD-058)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) Within 180 days of initial operation, conduct a stack test on boiler B01 to demonstrate compliance with the HCl emission limitation in cond. I.B.10.a.(1) of this permit. This test to be repeated annually within 60 days of the anniversary date of the initial compliance test. (s. 285.65(13), Stats.) (2) At a minimum of 6 months prior to commencing operation of boiler B01, submit a plan for monitoring the
fuel chlorine content to ensure that the HCl emission limitations are being met. The Department, after public comment, may approve, amend or disapprove this plan. Boiler B01 may not operate without an approved monitoring plan (s. NR 405.08, Wis. Adm. Code). (1) Reference Test Method for HCl Emissions: Whenever compliance emission testing is required, US EPA Method 26 or 26A or an alternate method approved in writing by the Department shall be used to demonstrate compliance. [s. NR 439.06, Wis. Adm. Code]

Department will take action to consider the approval of the revisi on request pursuant to applicab le air permit rules and proced ures which include the issuance of a public no tice and opportunity for public comment.

11 The final U.S. EPA Boiler MACT rule (proposed 40 CFR Part 63, Subpart DDDDD, "National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institu tional Boilers and Process Heaters"; Vol. 75 Federal Regis ter No. 107, pp. 32006-32073; June 4, 2010) is scheduled to be issued before the date of the new emission unit (the boiler) becomes operational for this permitted source. If that occurs and if th e new federal rule establishes an emission limitation for mercu ry which is different from the limit set forth above, the permittee may file a permit revision request with the Department, seeking to conf orm the permit limit with the new federal Boiler MACT rule. Consistent with the requirements of Sectio n 285.27(2), Wis. Stats., the Department will take action to consider the approval of the revisi on request pursuant to applicab le air permit rules and proced ures which include the issuance of a public no tice and opportunity for public comment.FID No. 737227040, Permit No. 10-SDD-058 Page 26 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db).

11. Greenhouse Gases

(a) Limitations: BACT.

(1) Greenhouse gas emissions may not exceed 3,050 pounds of CO 2 per MWh of gross output, averaged over any consecutive 12-month period.

Gross output means the gross useful work performed by the steam generated. When the unit is generating only electricity, the gross useful work performed is the gross electrical output from the turbine/generator set. For cogeneration, the gro ss useful work performed is the gross electrical output plus 75 percent of the useful thermal output measured relative to ISO conditions that is not used to generate additional electrical output (i .e., steam delivered to an industrial process).

. (s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Prior to startup of a boiler, the permittee shall install, maintain, calibrate and operate a continuous emission monitor (CEM) for measuring carbon dioxide
emissions from that boiler which meets the requirements of Performance specification 2 in 40CFR part 60, Appendix B. (ss. NR 405.08 and NR 439.09(2), Wis. Adm. Code).

(2) The permittee shall calibrate, maintain, and operate the continuous emission monitoring system (CEMS) required to be installed under cond. I.A.11.b.(1) of this permit. The CEM for a boiler shall be operational whenever carbon dioxide may be being emitted from that boiler [ ss. NR 407.09(4)(a)1., and NR 439.09(5),
Wis. Adm. Code ]

(3) Within 90 days of startup of a boiler, the CEM for
that boiler shall be certified in accordance with Performance specification 2 in 40CFR part 60, Appendix B (ss. NR 405.08 and NR 439.09, Wis. Adm. Code)

(4) Within 120 days of startup of a boiler, the permittee shall submit a QA/QC plan for the CO2 CEM for that boiler to the Department for review (ss. NR 405.08 and NR 439.04(1), Wis. Adm. Code)

(5) The permittee shall follow a quality control and quality assurance plan, prior to Department approval and as approved by the Department, for the continuous emission monitoring system (CEMS) required by condition [ ss. NR 407.09(4)(a)1., and NR 439.09(8), Wis. Adm. Code] (1) Reference Test Method for Carbon Dioxide Em issions: Whenever compliance emission testing is required, US EPA Method 3A or an alternate method approved in writing by the Department shall be used to de monstrate compliance. [s. NR 439.06(6), Wis. Adm. Code]

(2) The permittee shall maintain all of the following records: (a) The calculated emission rates required under cond. A.1.3.b.(7) of this permit. The 30-day period calculations shall be available within 5 days of the end of any 30-day period;
(b) A copy of the QA/QC plan for the CEM;
(c) Any records required under the QA/QC plan;
(d) a record of the hourly CEM readings, for each hour of boiler operation and the hourly emission rate for each hour of operation;
(e) a daily record of the quantity of natural gas in cubic feet and heat input to the boiler.
(s. NR 439.04(1), Wis. Adm. Code)

(3) The owner or operator of a continuous emissions monitoring system shall submit quarterly excess emission reports to the department within 30 days following the end of each calendar quarter in accordance with subd. (a). The owner or operator shall submit either a full excess emission report under par. (a) or a summary excess emission report under par. (b), as specified in writing by the department. (a) The full excess emission reports required under this subsection shall contain the following information: i. The date and starting and ending times or duration of each period of excess emissions and the magnitude of the emissions. ii. The periods of excess emissions that occur during startups, shutdowns, process malfunction, fuel problems, other known
causes or for unknown causes. The re port shall identify the cause

12 If the compliance emission tests cannot be conducted within 180 days after the start of initial operation, the permit holder may request and the Department may approve, in writing, an extension of time to conduct the test(s). See I.ZZZ.4.FID No. 737227040, Permit No. 10-SDD-058 Page 27 of 46

B. Boiler B01 – Biomass and natural gas fired boiler wi th a capacity not to exceed 800 MMBTU/hour. The boiler is subject to NSPS (Part 60, Subparts D and Db). (6) Prior to startup of a boiler, the permittee shall install, maintain, calibrate and operate a wattmeter to measure gross electrical output in MWh on a
continuous basis.

(7) Prior to startup of a boiler, the permittee shall install, maintain, calibrate and operate meters for steam flow, temperature and pressure; and measure grossprocess steam output in pounds per hour and MWhours on a continuous basis.

(8) The permittee shall demonstrate compliance with
the CO 2 emission limitations as follows:

(a) Compliance with any 12-month average emission limitation shall be determined using the following methodology: i. Averaging the valid 15 minute CO2 measurements in any hour to determine an hourly average CO2 emission
rate; ii. Calculating the average 12-month emission rate by averaging the monthly emission rates for each month of operation in the past 12 months; and iii. A new 12-month average emission rate is calculated each month as the average of all of the hourly CO2 emission data for the preceding 12 month period

. (s. NR 405.08, Wis. Adm. Code)

(9) The boiler may only combust pipeline quality natural gas and biomass as defined in cond. ZZZ.1.a.(2) of this permit (s. 285.65(7), Wis. Stats.) (s. NR 405.08, Wis. Adm. Code)

(10) Initial compliance emission tests shall be conducted within 180 days af ter the initial operation of the boiler to show compliance with the emission
limitation. 12 [s. NR 439.07, Wis. Adm. Code]

(11) The permittee shall perform the compliance emission tests required under condition I.A.3.b.(9) every 60 months within 60 days from the date of the anniversary date of the original stack test. [s. NR 439.075(1)(b) Wis. Adm. Code] of any malfunction and the measures taken to reduce excess
emissions. iii. The date and starting and ending time of any period during which the monitoring system was inoperative for any reason or causes, including monitor malfunction or calibration, except for zero and span checks. The report shall identify the repairs or adjustments made to the system. iv. The date and starting and ending time of any period during which the process being monitored was inoperative. v. When no period of excess emissions occurred during the quarter and the monitoring system had no period of downtime, an excess emissions report shall be filed stating such information. (b) The summary excess emission report shall be submitted on a form provided by the department or in a format approved by the department, in writing (c) An excess emission of carbon dioxide is defined as follows: i. Any consecutive 12-month period in which the carbon dioxide emission rate exceeds the consecutive 12-month period emission rate in cond. I.B.11.a.(1) of this permit; (ss. NR 405.08 and NR 439.09(10), Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 28 of 46

C. P121, S121 – Biomass fuels material handling proce sses (unloading, screening, hogging and conveying)

1 Particulate Matter including PM10 and PM2.5 (PM)
a. Limitations: Best Available Control Technology (BACT):

(1) PM - 0.004 grains per dry standard cubic foot of exhaust gas

(2) 3.75 pounds per hour

(3) All material conveyors shall be fully enclosed

(s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Initial compliance emission tests for the dust collection system for P121 shall be conducted within 180 days of startup of P121 in accordance with cond. I. ZZZ.4. of this permit [s. NR 439.07, Wis. Adm. Code]

(2) All material handling oper ations shall be conducted in an enclosed building or within enclosures. Such enclosures or buildings shall be equipped with a dust collections system and baghouse or use a wet dust suppression system whenever solid material may become airborne.

(3) The pressure drop across the fabric filter baghouse or baghouse system shall be maintained within the range identified by testing in condition I.C.1.b.(1). of this permit. [s. NR 407.09(4)(a)1., Wis. Adm. Code]

(4) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats

(5) All material conveyors sha ll be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Particulate Matter
Emissions: Whenever compliance emission testing is required for PM10, US EPA Method 5, including backhalf (Method 202) shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for PM2.5, US EPA Method 201A for filterable and US EPA Method 202 for condensable particulate for condensable shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(3) The permittee shall record the pressure drop across the fabric filter baghouse system at least once each operating shift whenever the dust collection system is in operation. [s. NR 439.055(2)(b)1., Wis. Adm. Code]

(4) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the dust collection system, containing the date of the action, a description of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(5) Instrumentation to monitor the pressure drop across the fabric filter baghouse system sha ll be installed and operated properly. [s. NR 439.055(1)(a), Wis. Adm. Code]

(6)The permittee shall record the time and date when the wet dust suppression system is in operation, all opacity observations made during operation of the wet suppression system and any corrective actions taken (including when taken) to prevent fugitive dust from becoming airborne (s. NR 439.04, Wis. Adm. Code))FID No. 737227040, Permit No. 10-SDD-058 Page 29 of 46FID No. 737227040, Permit No. 10-SDD-058 Page 30 of 46

C. P121, S121 – Biomass fuels material handling proce sses (unloading, screening, hogging and conveying)
2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Initial compliance emission tests for the dust collection system for P121 shall be conducted within 180 days of startup of P121 in accordance with cond. I. ZZZ.4. of this permit [s. NR 439.07, Wis. Adm. Code]

(2) All material handling oper ations shall be conducted in an enclosed building or within enclosures. Such enclosures or buildings shall be equipped with a dust collections system and baghouse or use a wet dust suppression system whenever solid material may become airborne [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(3) The pressure drop across the fabric filter baghouse system shall be maintained within the range identified by condition I.C.1.b.(1). of this permit. [s. NR 407.09(4)(a)1., Wis. Adm. Code]

(3) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with emission limits. [s. 285.65(3), Wis. Stats.]

(4) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats

(5) All material conveyors sha ll be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Visible Emissions: Whenever compliance emission testing is required, US
EPA Method 9 or Method 22 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall record the pressure drop across the fabric filter baghouse system at least once each operating shift whenever the dust collection system is in operation. [s. NR 439.055(2)(b)1., Wis. Adm. Code]

(3) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the dust collection system, containing the date of the action, a description of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(4) Instrumentation to monitor the pressure drop across the fabric filter baghouse system sha ll be installed and operated properly. [s. NR 439.055(1)(a), Wis. Adm. Code]

(5)The permittee shall record the time and date when the wet dust suppression system is in operation, all opacity observations made during operation of the wet suppression system and any corrective actions taken (including when taken) to prevent fugitive dust from becoming airborne (s. NR 439.04, Wis. Adm. Code)FID No. 737227040, Permit No. 10-SDD-058 Page 31 of 46

D. F122 –Self Unloading Truck Unloading Station
2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

5% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Initial compliance emission tests for the dust collection system for P122 shall be conducted within 180 days of startup of P121 in accordance with cond. I. ZZZ.4. of this permit [s. NR 439.07, Wis. Adm. Code]

(2) Particulate matter emissions shall be controlled using self unloading trucks in combination with the dust collection system for P121 and/or a wet dust suppression system [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(3) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with emission limits. [s. 285.65(3), Wis. Stats.]

(4) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats

(5) All material conveyors shall be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Visible Emissions: Whenever compliance emission testing is required, US
EPA Method 9 or Method 22 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the fabric filter baghouse system, containing the date of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(3)The permittee shall record the time when the wet dust suppression system is in operation, all opacity observations made during operation of the wet suppression system and any corrective actions taken (including when taken) to prevent fugitive dust from becoming airborne (s. NR 439.04, Wis. Adm. Code)

C. F123 Biomass fuel storage and reclaim

2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

5% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) Particulate matter emissions shall be controlled using a biomass fuels storage building designed to enclose the entire storage pile and the reclaim activities[s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(2) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with visible emission limit. [s. 285.65(3), Wis. Stats.] (1) Reference Test Method for Visible Emissions: Whenever compliance emission testing is required, US
EPA Method 9 or Method 22 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]

(3)The permittee shall record the time when any corrective actions taken (including when taken) to prevent fugitive dust from becoming airborne (s. NR 439.04, Wis. Adm.FID No. 737227040, Permit No. 10-SDD-058 Page 32 of 46

(3) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats

(5) All material conveyors sha ll be fully enclosed (s. NR 405.08, Wis. Adm. Code) Code)

D. P124A and P124B – CFB Boiler Fuel Storage Silos (2)

1. Particulate Matter including PM10 and PM2.5 (PM) (BACT)
a. Limitations: Best Available Control Technology (BACT):

(1) PM - 0.004 grains per dry sta ndard cubic foot of exhaust gas

(2) 0.01 pounds per hour from each silo vent.

(3) All material conveyors shall be fully enclosed

(s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The permittee shall determine the hourly emissions using operating parameters and OEM emission factors within 180 days after the start of operation of the process to show compliance with the emission limitation. [s. 285.65(3), Wis. Stats.]

(2) Particulate matter emissions shall be controlled using a using silo bin vent system to meet the BACT limits. [s. NR 405.08(2), Wis. Adm. Code]

(3) The silo bin vent system be operated at all times when the process is in operation [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(4) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan. [s. 285.65(3), Wis. Stats.]

(5) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats.]

(6) All material conveyors shall be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Particulate Matter
Emissions: Whenever compliance emission testing is required for PM10, US EPA Method 5, including backhalf (Method 202) shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for PM2.5, US EPA Method 201A for filterable and US EPA Method 202 for condensable particulate for condensable shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall keep and maintain on site technical drawings, blueprints or equivalent records of the silo bin vent system [s. NR 439.04(1)(d), Wis. Adm. Code]

(3) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the silo bin vent system, containing the date of the action, a description of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(4) The permittee shall record the time and date and a description of any corrective actions which are taken to prevent fugitive dust from be ing generated by the process (s. NR 439.04, Wis. Adm. CodeFID No. 737227040, Permit No. 10-SDD-058 Page 33 of 46

D. P124A and P124B – CFB Boiler Fuel Storage Silos (2)
2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. T est Methods, Recordkeeping, and Monitoring:
(1) The silo bin vent system be operated at all times when the process is in operation. [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(2) The process shall be monitore d in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan. [s. 285.65(3), Wis. Stats.]

(3) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats]

(4) All material conveyors shall be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Visible Emissions: Whenever compliance emission testing is required,
US EPA Method 9 or Method 22 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code] (2) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the silo bin vent system, containing the date of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(3) The permittee shall record the time, date and a description of any corrective actions which are taken to prevent fugitive dust from being generated by the process (s. NR 439.04, Wis.
Adm. Code

E. P131 and P132 – 

### Boiler bed material silo and 

### boiler ash silo

1. Particulate Matter including PM10 and PM2.5 (PM) (BACT)
a. Limitations: Best Available Control Technology (BACT):

(1) P131, use of silo bin vent system

(a) PM - 0.004 grains per dry standard cubic foot of exhaust gas and 0.01ounds per hour

(b) PM2.5 - 0.002 grains per dry standard c ubic foot of exhaust gas and 0.005pounds per hour

(2) P132, use of silo bin vent system

(a) PM - 0.004 grains per dry standard cubi c foot of exhaust gas and 0.034 pounds per hour

(b) PM2.5 - 0.002 grains per dry standard c ubic foot of exhaust gas and 0.012 pounds per hour

(3) All material conveyors shall be fully enclosedFID No. 737227040, Permit No. 10-SDD-058 Page 34 of 46

E. P131 and P132 – 

### Boiler bed material silo and 

### boiler ash silo
[s. NR 415.06(2)(c), Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code,] (s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The permittee shall determine the hourly emissions using operating parameters and OEM emission factors within 180 days after the start of operation of the process to show compliance with the emission limitation. [s. 285.65(3), Wis. Stats.]

(2) Particulate matter emissions shall be controlled using a using silo bin vent system to meet the BACT limits. [s. NR 405.08(2), Wis. Adm. Code]

(3) The silo bin vent system be operated at all times when the process is in operation [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(4) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with emission limits. [s. 285.65(3), Wis. Stats.]

(5) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats.]

(6) All material conveyors shall be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Particulate Matter
Emissions: Whenever compliance emission testing is required for PM10, US EPA Method 5, including backhalf (Method 202) shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) Whenever compliance emission testing is required for PM2.5, US EPA Method 201A for filterable and US EPA
Method 202 for condensable for condensable shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall keep and maintain on site technical drawings, blueprints or equivalent records of the silo bin vent system [s. NR 439.04(1)(d), Wis. Adm. Code]

(4) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the silo bin vent system, containing the date of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code] (6) The permittee shall record the time and date when corrective actions are taken to prevent fugitive dust from being generated by the process (s. NR 439.04, Wis. Adm.
CodeFID No. 737227040, Permit No. 10-SDD-058 Page 35 of 46

E. P131 and P132 – 

### Boiler bed material silo and 

### boiler ash silo

2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:
(1) The silo bin vent system be operated at all times when the process is in operation . [s. NR 406.10 and s. NR 407.09(4)(a)1., Wis. Adm. Code]

(2) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with emission limits. [s. 285.65(3), Wis. Stats.]

(3) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats]

(4) All material conveyors sha ll be fully enclosed (s. NR 405.08, Wis. Adm. Code) (1) Reference Test Method for Visible Emissions: Whenever compliance emission testing is required, US
EPA Method 9 or Method 22 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code] (2) The permittee shall keep records of all inspections, checks and any maintenance or repairs performed on the silo bin vent system, containing the date of the action, initials of inspector, and the results. [s. NR 439.04(1)(d), Wis. Adm. Code]

(3) The permittee shall record the time when corrective actions are taken to prevent fugitive dust from being generated by the process (s. NR 439.04, Wis. Adm.
CodeFID No. 737227040, Permit No. 10-SDD-058 Page 36 of 46

F. P144 – New cooling tower

1. Particulate Matter including PM10 and PM2.5 (PM) (BACT)
a. Limitations: Best Available Control Technology (BACT):

(1) each cell shall be equipped, maintained and operated with high efficiency drift eliminators designed to limit the loss of droplets from the units to not more than 0.0005 percent of the water circulation rate;
(2) emissions may not exceed:
(a) 0.072 pounds per hour of total of PM.
(b) 0.00020 pounds per hour of PM2.5.
(s. NR 405.08, Wis. Adm. Code)

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) The total dissolved solids (T DS) concentration in the cooling water may not exceed 1,600 ppm (0.16 %). [ss. NR 439.04 and NR 405.08, Wis. Adm. Code]
(2) The permittee shall operate the Cooling Tower in
accordance with the manufacturer’s recommendations [s. NR 405.08, Wis. Adm. Code]
(3) The permittee shall operate the cooling tower to prevent significant contribution to fog or icing on off-site roadways and areas surrounding the facility. [s. NR 405.08, Wis. Adm. Code] (1) The permittee shall determine and record the following on a weekly basis or more frequently if required: 13
(a) the concentration of Total Dissolved Solids (TDS) in the cooling water, in parts per million (ppm); (b) the cooling tower water circulation rate, gallons per minute, and; (c) the calculated average particulate matter emission rates,
for PM and PM 2.5 in pounds per hour. [s. NR 439.04, Wis. Adm. Code]
(2) The permittee shall maintain on file: (a) the design loss specifications for the drift eliminators; (b) manufacturer’s recommended procedures for inspection and maintenance; (c) a description of the type of water treatment system in use in the cooling towers. Th e description is to include the average concentration and material safety data sheets, MSDS, for each water treatment additive. [ss. NR 439.04 and NR 468.30(4)(a), Wis. Adm. Code]

F. P144 – New cooling tower
2. Opacity (visible emissions)
a. Limitations: Best Available Control Technology (BACT):

10% opacity [s. NR 431.05, Wis. Adm. Code, s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Me thods, Recordkeeping, and Monitoring:

(1) The permittee shall operate the Cooling Tower in
accordance with the manufacturer’s recommendations and the malfunction prevention and abatement plan for the equipment associated with this process. [ s. NR 405.08, Wis.

Adm. Code ]
(2) The permittee shall operate the cooling tower to prevent significant contribution to fog or icing on off-site roadways and areas surrounding the facility. [ s. NR 405.08, Wis. Adm.

Code ] (1) The permittee shall maintain on file: (a) the design loss specifications for the drift eliminators; (b) manufacturer’s recommended procedures for inspection and maintenance; (c) a description of the type of water treatment system in use in the cooling towers. Th e description is to include the average concentration and material safety data sheets, MSDS, for each water treatment additive. [ss. NR 439.04 and NR 468.30(4)(a), Wis. Adm. Code]

13 More frequent monitoring may be required to maintain manufactures guarantees, or for compliance with other regulatory requirem ents such as WPDES permit. Calcul ations are based on Cooling Tower Emissions Quantification Using the Cooling Tower Institute Test Code ATC-40 and TDS concentration specific to the facility.FID No. 737227040, Permit No. 10-SDD-058 Page 37 of 46



### G. F125 & F133 - Biomass delivery trucks haul roads & Boiler ash haul roads

Pollutant: 1. Particulate Matter Emissions (BACT).

a. Limitations:

(1)The permittee shall pave the haul roads.
(2) Use of Wet dust suppression
[s. NR 405.08, Wis. Adm. Code, s. NR 431.05, Wis. Adm. Code, s. 285.65(3), Wis. Stats., s. 285.65(3), Wis. Stats.]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) All facility haul roads shall be paved. (2) The process shall be mon itored in accordance with a Fugitive Dust Control Plan. The Department may request the permittee to review and amend the plan if necessary to maintain emissions in compliance with emission limits. [s. 285.65(3), Wis. Stats.]
(3) Whenever fugitive dust emissions are observed from the process, the permittee shall take corrective actions to prevent fugitive dust from becoming airborne. [s. 285.65(3), Wis. Stats (1) Reference Test Method for Particulate Matter Emissions: Whenever compliance emission testing is required, the appropriate US EPA Method 9 shall be used to demonstrate compliance or an alternate method approved in writing by the Department, shall be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall record the time when any corrective actions taken (including when taken) to prevent fugitive dust from becoming airborne (s. NR 439.04, Wis. Adm. Code))FID No. 737227040, Permit No. 10-SDD-058 Page 38 of 46

ZZZ. Conditions Applicable to the Entire Facility.

1. Biomass definitions.

a. Definition of biomass for:

(1) For Federal MACT requirements only: Biomass means but is not limited to, wood residue, and wood products (e.g

. trees, tree stumps, tree limbs, bark, lumber, sawdust, sanderd ust, chips, scraps, slabs, millings, and shavings); animal manure, including litter and other bedding materials; vegetative agricultural and s ilvicultural materials, such as logging residues (slash), nut and grain hulls and chaff (e.g. almond, walnut, peanut, rice, and wheat), bagasse, orchard prunings, corn stalks, coffee bean hulls and grounds.

(2) For all other permit requirements: means a resource th at derives energy from wood or plant material or residue, clean solid wood waste and crops grown for use as a res ource. Fuel sources may include the following and other qualifying clean biomass sources:

• logging residue

• discarded woody material from primary manufacturing facilities such as paper mills, sawmills, or chip mills

• on-site pulp & paper wastewater treatment plant residue

• leftover woody material from secondary manufacturers such as door, window, cabinet manufacturers

• woody biomass from municipality wood waste, tree services, and construction companies

• clean solid wood waste from discarded wood packaging such as pallets/crating and from construction and

demolition activities

• woody biomass plantations, energy crops and agricultural residues. Biomass excludes edible portions of food crops, refuse deri ved fuel, treated wood, municipal solid waste, sewerage sludge, and animal waste.

(3) The definition of biomass in cond. ZZZ.1.a.(1) of this permit does not allow the combustion of any of the materials excluded from being defined as biomass in cond. ZZZ.1.a.(2) of this permit.

(s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

2. Stack Parameters
a. Limitations: All stacks at the facility shall meet the parameters in subd. b. of this section (s. NR 405.08, Wis. Adm.
Code and

b. Compliance Demonstration c. Test Methods, Recordkeeping, and Monitoring:
(a) Boilers:

(i) B01, Stack S01 : the height shall be at a minimum 265 feet above ground level and the in side diameter shall be no greater than 10 feet;

(ii) B02, Stack S02 : : the height shall be at a minimum 180 above ground level and the insi de diameter shall be no greater than 9 feet;

(b) Cooling Tower: (1) The permittee shall keep and maintain on site technical drawings, blueprints or equivalent records of the physical stack parameters. [s. NR 439.04(1)(d), Wis. Adm. Code]

Note: These requirements are included because the source was reviewed with these stack parameters and it was determined that no increments or ambient air quality standards will be violated when constructed as proposed.FID No. 737227040, Permit No. 10-SDD-058 Page 39 of 46

(i) P141, Stack S141: the height of each cell shall be maintained at a minimum 70 feet above ground level and the inside diameter of each cell shall be no greater than 25 feet; (c) Material handling: (i) P121, S121: the height shall be maintained at a minimum 100 feet above ground level and the inside diameter shall be no greater than 5 feet; (ii) P124, S124: the height of each vent shall be maintained at a minimum 110 feet above ground level and the inside diameter shall be no greater than 1 foot; (iii) P131, S131: the height shall be maintained at a minimum 110 feet above ground level and the inside diameter shall be no greater than 2.0 feet; (iv) P132, S132: the height of each bin vent shall be maintained at a minimum 65 feet above ground level and the inside diameter shall be no greater than 2 feet; [s. NR 404. 04(3) & (8), and NR 404.05(3), Wis. Adm. Code, s. 285.65(3), Stats.]

(2) The stacks may not be equipped with a rainhat or other device that may impede the upward velocity of the exhaust

gasses. [s. NR 404. 04(3) & (8), and NR 404.05(3), Wis. Adm. Code, s. 285.65(3), Stats.]

3. Malfunction Prevention and Abat ement Plan and Fu gitive Dust Plan

a. Limitations:

(1) A malfunction prevention and abatement plan shall be prepared and followed for the plant.

[s. NR 439.11, Wis. Adm. Code]

(2) All air pollution control equipment shall be operated and maintained in conformance w ith good engineering practices (i.e. operated and maintained according to manufacturer’s specifications and directions) to minimize the possibility for the exceedance of any emission limitations.

[s. NR 439.11(4), Wis. Adm. Code]

(3) The facility shall submit an amended plan to include all process and boilers included in this permit to the Wisconsin Department of Natural Resources, South Central Region Headquarters for review. This submittal shall be made within 120 days of startup of boiler B01. The department may amend the plan if deemed necessary for malfunction prevention or for the reduction of excess emissions during malfunctions.

[s. NR 439.11(2), Wis. Adm. Code]

(4) The permittee shall submit a Fugitive Dust Plan to the Department for review at least 120 days prior to the startup ofFID No. 737227040, Permit No. 10-SDD-058 Page 40 of 46

process P121, F122, F123, P124A&B, P131 or P132 (120 days prio r to the startup of the first of these processes to be started up). The Plan shall, at a minimum, include th e following elements and precautions for limiting fugitive dust 14

emissions:

(a) Use, where possible, of water or chemicals for control of dust from construction operations; (b) Application of asphalt, water, suitable chemicals or pl astic covering on dirt roads, material stockpiles and other surfaces which can create airborne dust, provided such app lication does not create a hydrocarbon, odor or water pollution problem; and (c) Covering or securing of materials likely to become airborne while being moved on public ro ads, railroads or navigable

waters. [s. NR 405.08, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The malfunction prevention and abatement plan shall be developed to prevent, detect and correct malfunctions or equipment failures which may cause any applicable emissions limitation to be violated or which may cause air pollution.

[s. NR 439.11(1), Wis. Adm. Code]

(2) This malfunction prevention and abatement plan shall
include installation, ma intenance and routine calibration procedures for the process monitoring and control equipment instrumentation. This plan shall require an instrumentation calibration at the frequency specified by the manufacturer, yearly or at a frequency based on good engineering practice as established by operational history, whichever is more frequent. Inspection and calibration shall also be conducted

whenever instrumentation anomalies are noted.

[ss. NR 407.09(1)(c)1.c., NR 439.055(4) and s. NR
439.11, Wis. Adm. Code]

(3) The malfunction prevention and abatement plan shall require a copy of the operation and maintenance manual for the control equipment to be maintained on site. The plan shall contain all of the elements in s. NR 439.11(1)(a) - (h), Wis. Adm. Code.

[s. NR 439.11, Wis. Adm. Code] (1) The permittee shall maintain the following records: (a) A copy of the malfunction prevention and abatement plan; and (b) any records required to be maintained under the malfunction prevention and abatement plan. (s. NR 439.04, Wis. Adm. Code)

4. Stack Testing and Fuel Sampling Requirements.

14 The use of the term “fugitive dust” anywhere in this permit is not meant to imply that these emissions are considered fugitive emissions under ch. NR 405, Wis. Adm. Code.FID No. 737227040, Permit No. 10-SDD-058 Page 41 of 46

a. Limitations:

(1) If any required compliance emission test(s) cannot be conduc ted within the time frames specified in this permit, the permit holder may request and the Departme nt may approve, in writing, an extensi on of time to conduct the test(s). Such an extension shall not exceed 90 calendar days.

[s. NR 439.07, Wis. Adm. Code]

(2) All testing shall be performed with the emissions unit operating at capacity or as close to capacity as practicable and in accordance with approved procedures. If operation at capacity is not feasible, the source shall operate at a capacity level which is approved by the Department in writing.

[s. NR 439.07(1), Wis. Adm. Code]

(3) The Department shall be informed at least 20 working days prior to any stack testing, so a Department representative can witness the testing. At the time of notification, a compliance emission test plan shall also be submitted to the Department for approval. When approved in writing, an e quivalent test method may be substituted for the reference test method. The notification and test plan shall be s ubmitted to the Wisconsin Department of Natural Resources, West Central Region Headquarters.

[s. NR 439.07(2), Wis. Adm. Code]

(4) Conduct all sampling of liquid fossil fuels in accordance with s. NR 439.08(2), Wis. Adm. Code [s. NR 439.08(2),
Wis. Adm. Code

(5) Use USEPA method 19 to convert measured concentra tion values to pounds/MMBTU values when needed (s. NR 405.08, Wis. Adm. Code and s. 285.65(13), Stats.)

(6) Unless otherwise approved by the Department in writing, all stack testing required for Boiler B01 shall be done using only biomass as the fuel and at least 95% of maximum boiler capacity (i.e. heat input minimum of 760 MMBTU/hour) (s. NR 405.08 and 10-SDD-058)

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Two copies of the report on any compliance emission tests shall be submitted to the Department for evaluation within 60 days following the completion of

tests.

[s. NR 439.07(9), Wis. Adm. Code] (1) The permittee shall maintain the following records: (a) a copy of all stack test r esults for test required under this permit; (b) any requests for an extension of time to perform any testing required under this permit, including the Department’s written response to such requests. (s. NR 439.04, Wis. Adm. Code)

5. Compliance Reports/Records.

a. Limitations:

(1) Except as provided under ZZZ.7.a.(7), upon issuance of th e operation permit, the pe rmittee shall submit periodic monitoring reports.FID No. 737227040, Permit No. 10-SDD-058 Page 42 of 46

[s. NR 407.09(1)(c)3., Wis. Adm. Code]

(2) Except as provided under ZZZ.7.a.(7), upon issuance of th e operation permit, the pe rmittee shall submit periodic certification of compliance.

[s. NR 407.09(4)(a)3., Wis. Adm. Code]

(3) The records required under this permit shall be retained for at least five (5) years and shall be made available to department personnel upon request during normal business hours.

[s. NR 439.04, s. NR 439.05, Wis. Adm. Code]

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) The permittee shall submit a monitoring report which contains the results of monitoring or a summary of monitoring results required by this permit to the Department every six (6) months.

(a) The time periods to be addressed by the submittal January 1 to June 30 and July 1 to December 31.

(b) The report shall be submitted to the Wisconsin Department of Natural Resources, West Central Region Air Management Program, Wausau Service Center, within 45 days after the end of each reporting period.

(c) All deviations from and violations of applicable requirements shall be clearly identified in the submittal.

(d) Each submittal shall be certified by a responsible official as to the truth, accuracy and completeness of the report.

(e) The content of the submittal is described in item D. of Part II of the operation permit.

[ss. NR 407.09(1)(c)3. & NR 439.03(1)(b), Wis. Adm.
Code]

(2) The permittee shall submit an annual certification of compliance with the requirements of this permit to the Wisconsin Department of Natural Resources, West Central Region Headquarters and to Compliance Data -
Wisconsin, Air and Radiation Division, US EPA, 77 W. Jackson Street, Chicago, IL 60604. None Applicable.FID No. 737227040, Permit No. 10-SDD-058 Page 43 of 46

(a) The time period to be addressed by the report is January 1 to December 31 of the preceding year.

(b) The report shall be submitted to the Wisconsin Department of Natural Resources and the US EPA within 45 days after the end of each reporting period.

(c) The information included in the report shall comply with the requirements of Part II, Section N of this permit.

(d) Each report shall be certified by a responsible official as to the truth, accuracy and completeness of the report.

[ss. NR 407.09(4)(a)3. & NR 439.03(1)(c), Wis. Adm. Code]

7. Construction Permit 10-SDD-058 Transitional Language.

a. Limitations:

(1) Notifications. The permittee shall inform the Department of the following dates within 15 days of the date on which the activity actually occurs:

(a) The date construction commences on any new emission units addressed in Permit 10-SDD-058.

(b) The date new emission unit becomes operational.

For purposes of this permit, “operational” shall be defined as the first time of any process related air contaminant is

emitted into the ambient air.

(2) For purposes of this permit only, “Initial operation” for Bi omass fired boiler (Emission Unit B01) shall be defined as the time when the generator of the associated boiler is first synchronized with the electrical grid, and “initial operation” for the Natural Gas fired Boiler (Emission Unit B0 2) shall be defined as the time when the boiler first provides steam for it intended purpose.

[s. NR 439.03(1), Wis. Adm. Code (Permit 10-SDD-058)]

(3) Construction Authorization Expiration. The Authorization to Construct, under Construction Permit 10-SDD-058 expires 36 months after the date of issuance. Construc tion or modification and an initial operation period for equipment shakedown, testing and De partment evaluation of operation to assure conformity with the permit

conditions is authorized for each emissi ons unit covered in this permit. Please note that the sources covered by this permit are required to meet all emission li mits and conditions contained in the permit at all times, including during the initial operation period. If 36 months is an insufficient time period for construction or modification, equipmentFID No. 737227040, Permit No. 10-SDD-058 Page 44 of 46

shakedown, testing and Department ev aluation of operation, the permit holde r may request and the Department may approve in writing an extension of this permit. The c onditions of the construction permit are permanent, unless revised, superseded or revoked.

[ss. 285.60(1)(a)2. and 285.66(1), Wis. Stats., and s. NR 406.12, Wis. Adm. Code (Permit 10-SDD-058)]

(4) New Emission Units Once constructed and operating, all new pr ocesses and boilers shall operate under the

conditions in Section I. and II. of this construction permit 10-SDD-058.

[s. NR 439.03(1), Wis. Adm. Code (Permit 10-SDD-058)]

(5) Completion of Operation Permit Application. The permittee shall update the permit application if any changes occur which are not specified or descr ibed in the plans and specifications approved under c onstruction permit 10-

SDD-058 .

[s. NR 407.04(1)(b), Wis. Adm. Code (Permit 10-SDD-058)]

(6) Existing Domtar Pulp and Paper Mill’s Emission Units. Prior to the date that any new emission units associated with the Biomass Facility becomes operational, Domtar Paper Company LLC shall complete the following physical and operational changes to the Pulp and Paper Mill (FID 737010450). These changes shall be federally enforceable through a construction permit under NR 406.

(a) Emission Units B10 and B13, Natural gas & distillate o il fired boilers shall not be operated whenever any of the new emission units of the Biomass Facility are operating,.

(b) Emission Unit B12, Natural gas & distillate oil fired boile r shall not be operated whenev er the Circulating Fluidized Bed Boiler – B01 of the Biomass Facility is operating. Em ission Unit B12 shall only combust natural gas, whenever any of other emission units of the Biomass Facility are operating.

(c) Emission Unit P44, Wood chip cyclone system shall not discharge through a stack to the ambient air

(d) Emission Unit P56, Lime storage silo’s stack shall be di scharge in a vertical direction at a height of 26.5 feet.

(e) Stack S90A, Pulper cyclone stack shall be discharge in a vertical direction at a height of 42 feet with an inside

diameter of 3.3 feet at outlet.

(f) Stack S90B, Pulper vent shall be discharge in a vertical dir ection at a height of 26 feet with an inside diameter of 1.5

feet at outlet.

(g) Stack S90C, Shredder cyclone stack shall be discharge in a vertical direction at a height of 28 feet with an inside
diameter of 3.3 feet at outlet

b. Compliance Demonstration: c. Test Methods, Recordkeeping, and Monitoring:

(1) Notifications. The permittee shall submit to the None Applicable.FID No. 737227040, Permit No. 10-SDD-058 Page 45 of 46

Department of Natural Resources, West Central Region Headquarters in writing, within 15 days of the date the event, the following:

(a) The date construction commences on the any new

emission unit addressed in Permit 10-SDD-058 .

(b) The date new emission unit becomes operational.

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10-
SDD-058)]

(2) Submittal of Compliance Testing Information and
other updates. The permittee shall submit to the department any updates of the permit application. Updates are required if any changes that occur which are not specified or described in the plans and specifications dated March 24, 2010 thru January 10, 2011 . The updates shall be made within 60 days of the date of the change. Other information to be submitted shall include the notification requirements and stack

tests results

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10-
SDD-058)]

(3) All submittals described in this permit shall be made in writing and include the name of the facility, the facility’s address, the construction permit number and a description of the affected emission unit(s).

[s. NR 439.04(1)(d), Wis. Adm. Code (Permit 10- SDD-058)]

8. MACT fuel sampling and monitoring requirements

a. Limitations: (1) All fuel sampling and fuel monitoring used top dem onstrate compliance with a MACT standard for boiler B01
shall be conducted in accordance with th ese requirements (s. 285.65(7)&(13), Stats.)

c. Test Methods, Recordkeeping, and Monitoring:

(1) Sampling for mercury shall be done in accordance with all of the following: (a) Collect fuel samples: None Applicable.FID No. 737227040, Permit No. 10-SDD-058 Page 46 of 46

i. Procedure in §63.7521(c) or ASTM D6323–98 (2003) (b) Composite fuel samples use Procedure in §63.7521(d) or equivalent. (c) Preparation composited fuel samples: i. SW–846–3050B (for solid samples) ii. SW–846–3020A (for liquid samples); or iii. ASTM D5198–92 (2003) (for biomass) or equivalent. (d) Determine heat content of the fuel by ASTM E711–87 (for biomass) (IBR, see §63.14(b)) or equivalent. (e) Determine moisture content of the fuel type: i. ASTM D3173–03 (IBR, see §63.14(b));or ii. ASTM E871–82 (1998) (IBR, see §63.14(b)) or equivalent. (f) Measure mercury concentration in fuel sample: i. SW–846–7471A (for solid samples); or ii. SW–846–7470A (for liquid samples) or equivalent. (2) Sampling for chlorine shall be done in accordance with all of the following: (a) Collect fuel samples: i. Procedure in §63.7521(c); or ii. ASTM D6323–98 (2003) (for biomass) (IBR, see §63.14(b)) or equivalent. (b) Composite fuel samples use the Procedure in §63.7521(d) or equivalent. (c)Prepare composited fuel samples i. SW–846–3050B (for solid samples); ii. SW–846–3020A (for liquid samples); or ii. ASTM D5198–92 (2003) (for biomass) (IBR, see §63.14(b)) or equivalent. (d) Determine heat content of the fuel type using ASTM E711–87 (1996) (for biomass) (IBR, see §63.14(b)) or equivalent. (e) Determine moisture content of the fuel type: i. ASTM D3173–03 (IBR, see §63.14(b)); or ii. ASTM E871–82 (1998) or equivalent.
f. Measure chlorine concentration in fuel: i. SW–846–9250; or ii. ASTM E776–87 (1996) (for biomass)