### AIR POLLUTION CONTROL OPERATION PERMIT RE NEWAL

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 C uster 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 1 9 , 2018

. [Section NR 407.09(1)(b)1., Wis. Adm. Code]

.

A renewal application must be submitted at least 6 months, but not mo re 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 su bmits 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 authoriz ation 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 fe derally 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 & Description 1 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 Heatin g

• Convenience Space Heating (< 5 MMBTU/hr)

• Sanitary Sewer and Plumbing Venting

Permit S hield. 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 em ission 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 em ission 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 fac ility 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 Con

trol Technology (BACT), or Lowest Achievable Emission Rate (LAER). It will also list any volun

tary restrictions on hours of operation, raw material use, or production rate requested by the permittee

to limit potential to emit.

Complian ce 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. Notw ithstanding the compliance determination methods which the owner or op

erator 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 testin g 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 fre quency 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 pollu tant.

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 require

ments are standard for most sources of air pollutants so they are included in this section with every per

mit.

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 B tu 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.

Stat s

. ; 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.

Stat s .] (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 P lans and specifications are sufficient because the simple cycle combustion turbine is designed to only burn natural gas and/o r No. 2 distillate fuel oil.

2 Natural gas and d istillate fuel oil are clean burning fuels. It is not expected that the visible e mission limitation of 20% opacity would be exce eded while firing these fuels.

3 P lans and specifications are sufficient because the simple cycle combustion turbine is design ed 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 a t 40%

loads and greater. 5 [ss.

285.65(3) and 285.65(7),

Wis. Stat s

. ; 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 NO

x 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 desig ned 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. Stat s

. ; 98

- RV

- 153 ] (1) The permi t tee 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. Stat s

. ; 98

- RV

- 153 ] (1) The permi t tee 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 l imit 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 desig ned 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 mixt ures. 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 permi ttee 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 p er mittee 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 a nd 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, whicheve r 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 emission

related written instructions or develop and follow

a maintenance plan which must p rovide 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 utiliz e 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 pr ogram 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 t he 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 require d 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 permitte e 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 du ration 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 pr ocess 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 th e 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 Fed eral, 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 ma nagement 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 emit 11 (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) T he 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

Parameters 12 (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 y ear 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 inc rements 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 pl an 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 cer tification 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 abate ment plan shall be prepared and fol lowed for the plant.

(b) All air pollution control equipment shall be operated and maintained in conformance with good engineering practices (i.e. ope rated and maintained according to

manufacturer's specifica tions 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 Re sources

, Northeast Region Headquarters, 2984 Shawano Avenue, Green Bay, WI, 54313

- 6727

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

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

(3) Stack Testing Requirements

(a) If the compliance emission test(s) can not be conducted within the time frames specified in this permit, the permit holder may request and the De partment 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 capacit y as practicable and in accordance with approved proce dures. 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 da ys prior to any stack testing so a Department repre sentative can witness the testing. At the time of notification, a

compliance emission test plan shall also be sub mitted to the Department for approval. When approved in writing, an equiva lent test metho d may be substituted for the reference

test method. The notifi cation and test plan shall be submitted to the Wisconsin Department of Natu ral Resources

, Northeast Region Headquarters, 2984 Shawano Avenue

, Green

Bay, WI, 54313

- 6727

. (d) Two copies of the r eport 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 J une 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 6 0 days after the end of

each reporting peri od.

(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 Avenu e , 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 De partment of Natural Resources Northeast Region

Headquarters, 2984 Shawano Avenue Box 10448, Green Bay, WI, 54307

- 0448 and to US EPA within 6 0 days

after the end of each re porting period.

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

mit.

(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 malfunc

tions 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 calibra

tion procedures for the process monitoring and control equipment instrumentation. This plan shall require an

instrumentation calibration at the frequency specified b y 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 instru mentation anomalies are noted.

(b) The m alfunction prevention and abatement plan shall require a copy of the operation and maintenance man

ual 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 s hall maintain an inventory of normal con

sumable items necessary to ensure operation of the control

device(s) in conformance with the manufac turer's specifications

and recom mendations. [s. NR 439.11, Wis. Adm. Code]

(3) The facility shall maintain reco rds of the instrumenta tion

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 appli cation. [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 (NO

x 

### ); (NO, NO 2 

### , NO 3 

### )

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 NO

x 

### formation.

Water in jection 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 n otify 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 O utput 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 signa l 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 s tated as Variable Control Voltage. The VCE

signal is determined by the lower of the Startup, Speed or Temperature control loops . T he VCE signal determine s the physical position of

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

3.3. T he VCE output was utilized to establish the linear water inj ection rate to the turbine

. T he 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. T he 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 o il 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 contro l system provides a

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

fuel inputs. The system provides a water flow proportional to fuel flow and fuel type. O peration procedure s for the unit i nclude 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 value s of w ater to f uel ratio ha ve units of GPM per mA . The water/fuel ratio will no t 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 set point for 30 seconds. This will alert the operator to troubleshoot

the water injection system.