AIR POLLUTION CONTROL OPERATION PERMIT RENEWAL

EI FACILITY NO: 436123380 OPERATION PERMIT NO.: 436123380-P10

TYPE: Renewal of Part 70 source operation permit no. 436123380-P01

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

Name of Source: Manitowoc Public Utilities - Custer Street

Street Address: 5740 West Custer Street

Manitowoc, Manitowoc County, Wisconsin

Responsible Official, & Title: Nilaksh Kothari, General Manager 

is authorized to operate a single simple-cycle combustion turbine electric generating facility described in the plans 

and specifications dated July 6, 2012, and April 11, 2013, and in conformity with the conditions herein. 

This renewed operation permit expires on August 19, 2018 . [Section NR 407.09(1)(b)1., Wis. Adm. Code].

A renewal application must be submitted at least 6 months, but not more than 18 months, prior to the

expiration date [ss. 285.66(3)(a), Wis. Stats. and NR 407.04(2), Wis. Adm. Code]. [ss. 285.66(3)(a), Wis. 

Stats. and NR 407.04(2), Wis. Adm. Code].

No permittee may continue operation of a source after the operation permit expires, unless the permittee submits a 

timely and complete application for renewal of the permit. If a timely and complete application for renewal is 

submitted, the existing operation permit will not expire until the renewal application has been finally acted upon 

by DNR. [ss. 227.51(2), Wis. Stats. and NR 407.04(2), Wis. Adm. Code].

Conditions of the operation 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 Oshkosh, Wisconsin August 19, 2013

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

For the Secretary

By /s/

Imelda R. Hofmeister

Environmental Engineer Supervisor
PREAMBLE TO OPERATION PERMIT

An Asterisk (*) throughout this document denotes legal authority, limitations and conditions which are 

not federally enforceable [Section NR 407.09(3)(b), Wis. Adm. Code.].

Historical Summary of Permits/Orders Issued to the Facility.

The following permits, orders, etc., are adopted, under ss. 285.65(3), Wis. Stats., and NR 407.09(2)(d), 

Wis. Adm. Code, by Permit 436123380-P10 which then becomes the primary enforceable document:

Permit Number Issuance Date Sources Covered & Description1 Permits Adopted

98-RV-153 February 2, 1999 Construct process P01 & storage tank T01 None

436123380-P01 June 17, 2008 Total Facility operation permit 98-RV-153

10-JJW-230-EXM November 18, 2010 Replace stack for P01 None

436123380-P10 August 19, 2013 Total Facility operation permit renewal 436123380-P01, 98-RV-153

1 - Total Facility refers to all existing units at the facility at the time of issuance of the permit listed.

Stack and Process Index.

A. P01, S01 - Simple Cycle Combustion Turbine

B. T01 - Storage Tank

C. P02, S02 – 500 hp Black Start Diesel Engine

Insignificant Emissions Units.

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

maintenance, parts and equipment cleaning, etc.)

• Demineralization and Oxy Scavenging of Water for Boilers

• Purging of Natural Gas Lines 

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

• Pollution Control Equipment Maintenance

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

• Fire Control Equipment

• Janitorial Services

• Office Activities 

• Convenience Water Heating 

• Convenience Space Heating (< 5 MMBTU/hr)

• Sanitary Sewer and Plumbing Venting

Permit Shield. Unless precluded by the Administrator of the US EPA, compliance with all emission 

limitations in this operation permit is considered to be compliance with all emission limitations 

established under ss. 285.01 to 285.87, Wis. Stats., and emission limitations under the federal clean air 

act, that are applicable to the source if the permit includes the applicable limitation or if the Department 

determines that the emission limitations do not apply. The following emission limitations were reviewed 

in the analysis and preliminary determination and were determined not to apply to this stationary source: 

• NR 408 - The allowable VOC emissions for both gas and oil are restricted to less than 100 tons per 

year so that the facility is not subject to offset and LAER requirements under s. NR 408, Wis. Adm. 

code. 

• NR 420 - The facility is not subject to s. NR 420.03, Wis. Adm. Code because the storage tank is 

only used to store No. 2 fuel oil.

• 40 CFR Part 63, Subpart YYYY - The facility is not subject to the National Emission Standards for 

Hazardous Pollutants (NESHAP) for Stationary Combustion Turbines because the facility emits less 
than the major source threshold of s. 112(b) HAPs.

Part I - The headings for the areas in the permit are defined below. The legal authority for these 

limitations or methods follows them in [brackets].

Pollutant - This area will note which pollutant is being regulated by the permit. 

Limitations - This area will list all applicable emission limitations that apply to the source, including 

case-by-case limitations such as Latest Available Control Techniques (LACT), Best Available Control Technology (BACT), or Lowest Achievable Emission Rate (LAER). It will also list any voluntary restrictions on hours of operation, raw material use, or production rate requested by the permittee 

to limit potential to emit.

Compliance Demonstration - The compliance demonstration methods outlined in this area may be 

used to demonstrate compliance with the associated emission limit or work practice standard listed 

under the corresponding Limitations column. The compliance demonstration area contains limits on 

parameters or other mechanisms that will be monitored periodically to ensure compliance with the 

limitations. The requirement to test as well as initial and periodic test schedules, if testing is required, 

will be stated here. Notwithstanding the compliance determination methods which the owner or operator of a sources is authorized to use under ch. NR 439, Wis. Adm. Code, the Department may use 

any relevant information or appropriate method to determine a source’s compliance with applicable 

emission limitations.

Reference Test Methods, Recordkeeping, and Monitoring Requirements - Specific US EPA 

Reference test methods or other approved test methods will be contained in this area and are the 

methods that must be used whenever testing is required. A reference test method will be listed even if 

no testing is immediately required. Also included in this area are any recordkeeping requirements and 

their frequency and reporting requirements. Accuracy of monitoring equipment shall meet, at a 

minimum, the requirements of s. NR 439.055(3) and (4), Wis. Adm. Code, as specified in Part II of 

this permit.

Condition Type - This area will specify other conditions that are applicable to the entire facility that 

may not be tied to one specific pollutant.

Conditions - Specific conditions usually applicable to the entire facility or compliance requirements.

PART II - This section contains the general limitations that the permittee must abide by. These requirements are standard for most sources of air pollutants so they are included in this section with every permit.

PART III – This section contains the Compliance Assurance Monitoring (CAM) Plan that the permittee 

must abide by.
FID No. 436123380, Permit No. 436123380-P10 Page 4

Part I

A. P01, S01 - Simple Cycle Combustion Turbine

POLLUTANT a. LIMITATIONS b. COMPLIANCE

DEMONSTRATION

c. REFERENCE TEST METHODS, MONITORING AND

RECORDKEEPING

1. Particulate

Matter

Emissions

(PM)

(1) The emissions may not exceed 0.10 pound

per million Btu heat input to any stack (front

half and back half) when firing natural gas 

and/or No. 2 distillate fuel oil at loads 40% and 

greater. [s. NR 415.06(2) Wis. Adm. Code,

s.285.65(3), Wis. Stats., s. 285.65(7), Wis.

Stats.; 98-RV-153]

(1) The facility shall fire natural

gas and/or No. 2 distillate fuel oil 

having a maximum sulfur content 

of 0.50% in the simple cycle

combustion turbine. [ss.

285.65(3) and 285.65(10), Wis.

Stats.; 98-RV-153]

(1) Whenever compliance testing for PM is required, USEPA Method

5 and 202 shall be used. [s. NR 439.06(1), Wis. Adm. Code]

(2) The permittee shall retain on site plans and specifications of the

simple cycle combustion turbine.1 [s. NR 439.04(1)(d), Wis. Adm.

Code]

2. Visible

Emissions

(1) 20% opacity. [s. NR 431.05, Wis. Adm.

Code]

(1) The permittee shall only fire

natural gas and/or No. 2 distillate

fuel oil in the simple cycle

combustion turbine.2

 [ss.

285.65(3) and 285.65(10), Wis.

Stats.]

(1) Whenever compliance testing is required, USEPA Method 9 shall

be used. [s. NR 439.06(9)(a)1., Wis. Adm. Code]

(2) The permittee shall retain on site, plans and specifications of the

simple cycle combustion turbine.3

 [s NR 439.04(1)(d), Wis. Adm.

Code]

 1 Plans and specifications are sufficient because the simple cycle combustion turbine is designed to only burn natural gas and/or No. 2 distillate fuel oil. 2 Natural gas and distillate fuel oil are clean burning fuels. It is not expected that the visible emission limitation of 20% opacity would be exceeded while firing these fuels. 3

 Plans and specifications are sufficient because the simple cycle combustion turbine is designed to burn natural gas and/or No. 2 distillate fuel oil.
FID No. 436123380, Permit No. 436123380-P10 Page 5

A. P01, S01 - Simple Cycle Combustion Turbine (Continued)

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHODS,

MONITORING AND RECORDKEEPING

3. Sulfur

dioxide

(1) 170.50 pounds per hour

when firing natural gas

and/or No. 2 distillate fuel 

oil at 40% loads and 

greater. The sulfur content

of the No. 2 distillate fuel

oil used may not exceed

0.50% by weight.4

 [s.

285.65(3), Wis. Stats. and s.

285.65(7), Wis. Stats.; 98-

RV-153]

(1) To demonstrate compliance with condition I.A.3.a.(1), the

permittee shall take a representative sample from the batch of the

No. 2 distillate fuel oil received and have the sample analyzed for

the sulfur content. The Department will accept in lieu of an

analysis on each shipment, an analysis of a representative sample

of the batch of No. 2 distillate fuel oil from which the shipment

was taken. The permittee shall retain copies of its No. 2 distillate

fuel oil supplier's fuel sulfur content and heat content analyses at

the facility for each shipment of No. 2 distillate fuel oil received for

Process P01. The permittee shall further obtain certification from

the fuel supplier that the applicable methods in s. NR 439.07(2),

Wis. Adm. Code were followed by that supplier in the preparation

of said sulfur and heat content analyses. The shipment's quantity of

No. 2 distillate fuel oil shall be included with the copies of these

analyses. These records shall be maintained for a period of at least

5 years and shall be made available to the Department upon

request. [s. NR 439.04(1)(d), Wis. Adm. Code; 98-RV-153]

(1) Whenever compliance emission testing is required,

US EPA Method 6, 6A, 6B, 6C or 8 shall be used to

demonstrate compliance. [s. NR 439.06(2)(a), Wis.

Adm. Code]

(2) The permittee shall keep the following records:

(a) The sulfur content of the No. 2 distillate fuel oil;

(b) The heat content of the No. 2 distillate fuel oil.

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

4. Nitrogen

Oxides

(1) The emissions from the

simple cycle combustion

turbine may not exceed 120

pounds per hour when firing

natural gas and/or No. 2

distillate fuel oil at 40% 

loads and greater.5

 [ss. 

285.65(3) and 285.65(7),

Wis. Stats.; 98-RV-153]

(1) The permittee shall use water injection to control nitrogen

oxide emissions when No. 2 distillate fuel oil is fired in the

combustion turbine per the Startup and Shutdown Plan submitted to

the DNR. [s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats.; 98-

RV-153]

(2) The permittee shall install and operate a continuous monitoring

system to monitor the fuel consumption and automatically control

the flow of water to maintain compliance with A.4.a.(1) when the

turbine is fired. [s. 285.65(3), Wis. Stats.; 98-RV-153]

(3) The permittee shall incorporate the water to fuel ratio obtained

during the stack test in the malfunction prevention and abatement

plan. [s. 285.65(3), Wis. Stats., s. NR 439.11, Wis. Adm. Code; 

98-RV-153]

(1) Whenever compliance testing for NOx is required,

USEPA Method 20 shall be used. [s. NR 439.07(1)

(2) The permittee shall retain on site plans and

specifications of the simple cycle combustion turbine.6

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

(3) The permittee shall record the time and duration of

any malfunction of the continuous NOx control system

when the No. 2 distillate fuel oil is fired in the simple

cycle combustion turbine. [s. 285.65(3), Wis. Stats.; 

98-RV-153]

 4 The allowable emissions limit and the hours of operation limit in ZZZ.1 are established to ensure that sulfur dioxide emissions do not exceed 249 tons per year. 5 The allowable emissions limit and the hours of operation limit in ZZZ.1. are established to ensure that nitrogen oxides emissions do not exceed 249 tons per year. 6 These plans and specifications are sufficient because the simple cycle combustion turbine is designed to burn natural gas and/or No. 2 distillate fuel oil.
FID No. 436123380, Permit No. 436123380-P10 Page 6

A. P01, S01 - Simple Cycle Combustion Turbine (Continued)

POLLUTANT a. LIMITATIONS b. COMPLIANCE

DEMONSTRATION

c. REFERENCE TEST METHODS, MONITORING AND

RECORDKEEPING

5. Carbon Monoxide (1) The emissions from the simple cycle

combustion turbine may not exceed 120

pounds per hour when firing natural gas

and/or No. 2 distillate fuel oil at 40%

loads and greater.7

 [ss. 285.65(3) and

285.65(7), Wis. Stats.; 98-RV-153]

(1) The permittee shall demonstrate 

compliance by means of conditions in 

I.A.5.c.(2). [s. 285.65(3), Wis. Stats.; 98-

RV-153]

(1) Whenever compliance testing for CO is required, USEPA

Method 10 shall be used. [s. NR 439.06(4)(a), Wis. Adm.

Code]

(2) The permittee shall retain on site plans and specifications

of the simple cycle combustion turbine.8 [s. NR 439.04(1)(d),

Wis. Adm. Code]

6. Organic

Compounds

(1) The emissions from the simple cycle

combustion turbine may not exceed 84

pounds per hour when firing natural gas

and/or No. 2 distillate fuel oil at 40%

loads and greater. [ss. 285.65(3) and

285.65(7), Wis. Stats.; 98-RV-153]

(1) The permittee shall demonstrate 

compliance by means of conditions in 

I.A.6.c.(2). [s. 285.65(3), Wis. Stats.]

(1) Whenever compliance testing for organic compounds is

required, USEPA Method 18, 25, 25A, or 25B shall be used. 

[s. NR 439.06(3)(a), Wis. Adm. Code]

(2) The permittee shall retain on site plans and specifications

of the simple cycle combustion turbine. 9 [s. NR 439.04(1)(d),

Wis. Adm. Code]

 7 The allowable emissions limit and the hours of operation limit in ZZZ.1. are established to ensure that carbon monoxide emissions do not exceed 249 tons per year. 8 These plans and specifications are sufficient because the simple cycle combustion turbine is designed to burn natural gas and/or No. 2 distillate fuel oil 9 These plans and specifications are sufficient because the simple cycle combustion turbine is designed to burn natural gas and/or No. 2 distillate fuel oil.
FID No. 436123380, Permit No. 436123380-P10 Page 7

B. T01 - Storage Tank

POLLUTANT a. LIMITATIONS b. COMPLIANCE

DEMONSTRATION

c. REFERENCE TEST METHODS, MONITORING

AND RECORDKEEPING

1. Volatile

Organic

Compounds

(1) The permittee shall only store No. 2 fuel oil with 0.50% sulfur

by weight or less in this tank. [s. NR 419.03, Wis. Adm. Code.; 

98-RV-153]

(2) No person shall cause, allow or permit organic compound

emissions into the ambient air which substantially contribute to the

exceeding of an air standard or cause air pollution. No person shall

cause, allow or permit organic compounds to be used or handled

without using good operating practices and taking reasonable

precautions to prevent the spillage, escape or emission of organic

compounds, solvent, or mixtures. Such precautions shall include,

but are not limited to use of caution to prevent spillage or leakage

when filling tanks, trucks or trailers. [s. NR 419.03, Wis. Adm.

Code.]

(1) The permittee shall 

comply with A.3.b.(1)

for demonstrating 

compliance with volatile 

organic compounds 

emission limits. [s. 

285.65(3), Wis. Stats.] 

(1) Whenever compliance testing for organic compounds 

is required, USEPA Method 25 shall be used. [s. NR 

439.06(3), Wis. Adm. Code]

(2) The permittee shall comply with A.3.c.(2) for 

demonstrating compliance with the monitoring and 

recordkeeping requirement. [s. 285.65(3), Wis. Stats.] 
FID No. 436123380, Permit No. 436123380-P10 Page 8

C. S02, P02 – 500 hp Black Start Diesel Engine

CONDITION 

TYPE

a. LIMITATIONS b. COMPLIANCE DEMONSTRATION c. REFERENCE TEST METHODS, 

MONITORING AND RECORDKEEPING

1. National 

Emissions 

Standards for 

Hazardous Air 

Pollutants for 

Stationary 

Reciprocating 

Internal 

Combustion 

Engines, 40 CFR 

63, Subpart ZZZZ 

(1) The permittee shall:10

(a) Change the engine oil and filter every 500 

hours of operation or annually, whichever comes 

first,

(b) Inspect the air cleaner every 1,000 hours of 

operation or annually, whichever comes first; and

(c) Inspect all hoses and belts every 500 hours of 

operation or annually, whichever comes first, and 

replace as necessary.

[40 CFR 63.6603(a), Table 2d to Subpart ZZZZ 

of Part 63]

(2) The permittee shall minimize the engine’s 

time spent at idle during startup and minimize the 

engine’s startup time to a period needed for 

appropriate and safe loading of the engine, not to 

exceed 30 minutes. [40 CFR 63.6625(h)]

(3) The permittee shall operate and maintain the 

engine according to the manufacturer’s emissionrelated written instructions or develop and follow 

a maintenance plan which must provide to the 

extent practicable for the maintenance and 

operation of the engine in a manner consistent 

with good air pollution control practice for 

minimizing emissions. [40 CFR 63.6625(e), 

Table 6 to Subpart ZZZZ of Part 63]

(1) The permittee may utilize an oil analysis program 

as described below in order to extend the oil change 

requirement in condition C.1.a.(1)(a):

(a) The oil analysis program must be performed at the 

same frequency specified for changing the oil in 

C.1.a.(1)(a). 

(b) The analysis program must at a minimum analyze 

the following three parameters: Total Base Number, 

viscosity and percent water content. 

(c) The condemning limits for these parameters are as 

follows: Total Base Number is less than 30 percent of 

the Total Base Number of the oil when new; viscosity 

of the oil has changed by more than 20 percent from 

the viscosity of the oil when new; or percent water 

content (by volume) is greater than 0.5. 

(d) If all of the condemning limits are not exceeded, 

the permittee is not required to change the oil. 

(e) If any of the condemning limits are exceeded, the 

permittee must change the oil within 2 days of 

receiving the results of the analysis; if the engine is 

not in operation when the results of the analysis are 

received, the permittee must change the oil within 2 

days or before commencing operation, whichever is 

later.

(f) The analysis program must be part of the 

maintenance plan for the engine.

[40 CFR 63.6625(i)]

(1) The permittee shall maintain records of:

(a) The occurrence and duration of each 

malfunction of operation or air pollution 

control and monitoring equipment;

(b) Actions taken during periods of 

malfunction to minimize emissions in 

accordance with 40 CFR 63.6605(b), 

including corrective actions to restore 

malfunctioning process and air pollution 

control and monitoring equipment to its 

normal or usual manner of operation; 

(c) Manufacturer’s emission-related written 

instructions or your own maintenance plan for 

the engine; and

(d) Maintenance conducted on the engine in 

order to demonstrate that you operated and 

maintained the engine according to your own 

maintenance plan.

[40 CFR 63.6655(a)(2) and (5); (d) and 

(e)(3)]

(2) If the oil analysis program described in 

C.1.b.(1) is utilized, the permittee shall keep 

records of the parameters that are analyzed as 

part of the program, the results of the 

analysis, and the oil changes for the engine. 

[40 CFR 63.6625(i)]

 10 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required under 

this condition, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law, the management practice can be 

delayed until the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management practice should be performed as soon as practicable after the emergency 

has ended or the unacceptable risk under Federal, State, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the Federal, State or 

local law under which the risk was deemed unacceptable.
FID No. 436123380, Permit No. 436123380-P10 Page 9

ZZZ. Conditions Applicable to the Entire Facility

CONDITION

TYPE

a. SPECIFIC CONDITIONS

1. Limiting

potential to emit11

(1) The operating hours for the single simple-cycle combustion turbine (P01) may not exceed 194 hours per month averaged over any 12 consecutive month

period. [s.285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats.; 98-RV-153]

(2) The permittee may fire only natural gas and/or No. 2 distillate fuel oil having a sulfur content of 0.50% or less by weight. [s. 285.65(7), Wis. Stats.; 98-

RV-153]

(3) (a) The simple cycle combustion turbine may not be operated at less than 9.8 MW output (40% load) excluding start up and shutdown operation per the

Startup and Shutdown Plan submitted to the DNR. 

(b) The maximum electrical output may not exceed 24.5 MW output.

[s. 285.65(3), Wis. Stats., s. 285.65(7), Wis. Stats.; 98-RV-153]

(4) The permittee shall install a monitor to measure the megawatts (MW) output on a continuous basis to demonstrate compliance with the permit condition

(3) above. [s. 285.65(3), Wis. Stats.; 98-RV-153]

(5) The permittee shall keep the following records on a daily basis to demonstrate compliance with permit conditions ZZZ.1.a.(1) – (4).

(a) The date, starting and ending times, and the ambient conditions under which the turbine has been operated.

(b) The MW output that the turbine has generated.

(c) The number of hours the turbine has been operated on each fuel.

(d) The amounts and type of fuel used. 

[s. 285.65(3), Wis. Stats., s. NR 439.04, Wis. Adm. Code; 98-RV-153]

(6) The permittee shall use the records of the hours operated daily to calculate the hours the process operated each month. [s. 285.65(3), Wis. Stats., s. NR 

439.04, Wis. Adm. Code; 98-RV-153]

2. Stack

Parameters12

(1) The height of the stack S01 shall be at least 35 feet 4 inches above ground level. [s. 285.65(3), Wis. Stats.; 98-RV-153]

(2) The dimensions at the outlet of the stack may not exceed 13 feet 2 inches x 10 feet 11 inches. [s. 285.65(3), Wis. Stats.; 98-RV-153]

(3) The stack may not be equipped with rainhat or other device which impedes the upward flow of the exhaust gases. [s. 285.65(3), Wis. stats.; 98-RV-153]

(4) The permittee shall keep and maintain technical drawings, blueprints or equivalent records of the physical stack parameters. [s. NR 439.04(1)(d), Wis.

Adm. Code; 98-RV-153]

 11 These conditions are established so that the potential emissions for volatile organic compounds will not exceed 99 tons per year and potential emissions for carbon monoxide, nitrogen oxides and 

sulfur dioxide emissions from the facility will not exceed 249 tons per year.

12 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. 436123380, Permit No. 436123380-P10 Page 10

ZZZ. Conditions Applicable to the Entire Facility (Continued)

CONDITION

TYPE

a. SPECIFIC CONDITIONS

3. Start Up and Shut

Down

(1) Emissions in operation excess of the emission limitations set forth in this permit may be allowed if the emissions are temporary and due to startup or

shutdown of operations carried out in accord with a plan and schedule approved by the Department. [s. NR 436.03(2)(b), Wis. Adm. Code; 98-RV-153]

(2) The permittee shall submit a startup and shutdown plan and schedule to the DNR. If the plan is approved by the Department, the permittee shall

thereafter comply with the conditions, schedules, reporting, recordkeeping and all other requirements in the approved plan. [s. NR 436.03(2)(b), Wis. Adm.

Code and s. NR 439.03(1)(a), Wis. Adm. Code; 98-RV-153]

4. Compliance Reports/Records; Malfunction Prevention and Abatement Plan; Stack Testing Requirements

a. Limitations:

(1) Compliance Reports/Records.

(a) The permittee shall submit periodic monitoring reports. [s. NR 407.09(1)(c)3., Wis. Adm. Code]

(b) The permittee shall submit periodic certification of compliance. [s. NR 407.09(4)(a)3., Wis. Adm. Code]

(c) 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]

(2) Malfunction Prevention and Abatement Plan.

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

(b) All air pollution control equipment shall be operated and maintained in conformance with 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.

(c) The facility shall submit the plan to the Wisconsin Department of Natural Resources, Northeast Region Headquarters, 2984 Shawano Avenue, Green Bay, WI, 54313-6727,

upon request. The department may amend the plan if deemed necessary for malfunction prevention or for the reduction of excess emissions during malfunctions. 

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

(3) Stack Testing Requirements

(a) If the compliance emission test(s) cannot be conducted within the time frames specified in this permit, the permit holder may request and the Department may approve, in 

writing, an extension of time to conduct the test(s).

(b) 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.

(c) 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 equivalent test method may be substituted for the reference 

test method. The notification and test plan shall be submitted to the Wisconsin Department of Natural Resources, Northeast Region Headquarters, 2984 Shawano Avenue, Green 

Bay, WI, 54313-6727.

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

[s. NR 439.07, Wis. Adm. Code]
FID No. 436123380, Permit No. 436123380-P10 Page 11

ZZZ. Conditions Applicable to the Entire Facility (Continued)

4. Compliance Reports/Records; Malfunction Prevention and Abatement Plan; Stack Testing Requirements (Continued)

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 6 months. 

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

(b) The report shall be submitted to the Wisconsin Department of Natural Resources Northeast Region 

Headquarters, 2984 Shawano Avenue Box 10448, Green Bay, WI, 54307-0448 within 60 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.

[s. 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 Northeast Region Headquarters, 2984 Shawano Avenue, Green 

Bay, WI, 54313-6727 and to Compliance Data – Wisconsin, Air and Radiation Division, US EPA, 77 W. 

Jackson, Chicago, IL 60604. 

(a) The time period to be addressed by the report is the January 1 to December 31 period which precedes the 

report.

(b) The report shall be submitted to the Wisconsin Department of Natural Resources Northeast Region 

Headquarters, 2984 Shawano Avenue Box 10448, Green Bay, WI, 54307-0448 and to US EPA within 60 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.

[s. NR 439.03(1)(c), Wis. Adm. Code]

(3) 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. 

(a) This malfunction prevention and abatement plan shall include installation, maintenance 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. 

(b) 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. 

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

(1) A written copy of the malfunction prevention and abatement 

plan shall be kept at the plant and shall be updated once every 

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

(2) The facility shall maintain an inventory of normal consumable items necessary to ensure operation of the control 

device(s) in conformance with the manufacturer's specifications 

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

(3) The facility shall maintain records of the instrumentation 

calibrations. [s. NR 439.04, Wis. Adm. Code]
FID No. 436123380, Permit No. 436123380-P10 Page 12

ZZZ. Conditions Applicable to the Entire Facility (Continued)

CONDITION 

TYPE

a. SPECIFIC CONDITIONS

5. Compliance 

Assurance 

Monitoring (CAM)

(1) The permittee shall comply with the CAM plan which is attached to this permit as Part III. [40 CFR Part 64]

(2) The permittee shall prepare and submit an approvable CAM plan to the DNR with each operation permit renewal application. The permittee shall 

identify the pollutants, units, and equipment within the facility which are subject to the CAM Rule according to the requirements outlined in 40 CFR Part 

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

(3) The CAM plan shall include but not be limited to:

(a) The information required in 40 CFR Part 64.4.

(b) The monitoring, data recording, and other items required in 40 CFR Part 64.6(c).

[s. 285.65(13), Wis. Stats.]

(4) A copy of the CAM plan shall be kept at the plant and shall be updated in concurrence with the operation permit renewal application. [s. NR 

439.04(1)(d), Wis. Adm. Code]
FID No. 436123380, Permit No. 436123380-P10

PART III

CAM PLAN

For NOx Control of the Custer CT

1. APPLICABILITY

1.1. Control Technology: Water injection

1.2. Pollutants

Primary: Nitrogen oxides (NOx); (NO, NO2, NO3)

1.3. Process/Emission units: Stationary gas turbine – P01

2. MONITORING APPROACH DESCRIPTION

2.1. Indicators monitored: Water-to-fuel ratio (WFR)

2.2. Rationale for monitoring approach: Water injection reduces the combustion temperature and therefore reduces thermal NOx formation. 

Water injection is initiated and terminated as detailed in the start-up/shut-down plan to protect the turbine.

2.3. Monitoring Location: P01 Digital Control System

• Water injection rate: Inlet water feed supply.

• Fuel use: Inlet fuel line(s).

2.4. Analytical Devices Required: Digital Control System

• Water injection rate: Liquid flow meter.

• Fuel use: Natural gas meter for gas flow and oil meter for fuel oil flow.

2.5. Data Acquisition and Measurement System Operation

• Frequency of measurement: Continuous on digital control system.

• Reporting units: GPM (water) per mA. Note: mA (milliamp) is a measure of control system output to the fuel control 

valves.

• Recording process: Operator to record water to fuel ratio every hour.

• Unit has an automatic alarm function to notify operator that the water flow is not within the specified values.
FID No. 436123380, Permit No. 436123380-P10

2.6. Data Requirements

• The WFR curve was created during the initial emission testing and resides in the control system logic as a protected file.

• Historical plant records of fuel feed rate and water injection rate measurements and WFR calculations.

2.7. Specific QA/QC Procedures: Calibrate, maintain and operate instrumentation that takes into account manufacturer’s specifications.

3. COMMENTS

3.1. Digital controls in the form of a GE Fanuc PLC, Servo Output and input boards and a redundant temperature monitoring PLC control the 

operation of the CT. In addition to providing all the HMI, communications, alarm and logic requirements, the control systems main function 

is to provide an output signal to the fuel control valves. 

3.2. The main fuel control output from the control system is the VCE signal (4 to 20 mA) that acts on the liquid and gas control valves to control 

machine speed/output. VCE is the abbreviation for Electronic Control Voltage or sometimes stated as Variable Control Voltage. The VCE 

signal is determined by the lower of the Startup, Speed or Temperature control loops. The VCE signal determines the physical position of 

both the liquid and gas fuel throttle valves. VCE will not be proportional to MW output due to variations in temperature and fuel parameters. 

3.3. The VCE output was utilized to establish the linear water injection rate to the turbine. The machine was operated at a low power level (~10 

MW) and the water injection rate required for permit compliance was determined. The VCE was recorded at this point along with the water 

injection flow rate. The machine was operated at maximum power level and the water injection rate required for permit compliance was 

again determined, and the VCE recorded. A linear relationship between VCE and the required water injection rates at both the high and low 

outputs determined the water injection setpoint curve. These values were programmed into the Programmable Logic Controller for gas and 

fuel oil and are protected from being changed. The control system performance was demonstrated by compliance stack testing at several 

loads.

3.4. During operation, the operator controls the MW output of the machine, this in turn varies the VCE output and the control system provides a 

variable water injection setpoint. Fuel flow will be different for different machine outputs based on machine condition, outside air temp and 

fuel inputs. The system provides a water flow proportional to fuel flow and fuel type. Operation procedures for the unit include verification 

that the water injection is in AUTO and comes on above 11MW as detailed in the start-up shut-down plan.

3.5. The recorded values of water to fuel ratio have units of GPM per mA. The water/fuel ratio will not be a consistent value for a MW load on a 

day to day basis because as the machine is using more fuel it also uses more water. Additionally the system will provide an alarm to the 

operator if the water injection rate varies by more than 2 gpm from the setpoint for 30 seconds. This will alert the operator to troubleshoot 

the water injection system.