AIR POLLUTION CONTROL OPERATION PERMIT RENEWAL

EI FACILITY NO: 128065080 OPERATION PERMIT NO.: 128065080-P30 

TYPE: Renewal of Part 70 source operation permit no. 128065080-P20 

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 - Concord Generating Station 

Street Address: N8914 County Trunk Hwy E,

Watertown, Jefferson County, Wisconsin 

Responsible Official, & Title: Terry Hoffman, Asset Manager

is authorized to operate an electric power generation facility described in the plans and specifications dated 

October 17, 2005, November 16, 2005, November 28, 2005, December 1, 2005, August 29, 2007, May 9, 2008, 

June 4, 2008, June 8, 2012, July 16, 2012, July 24, 2012, and August 30, 2012 and in conformity with the 

conditions herein. 

This renewed operation permit expires on January 15, 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, II, III and IV hereof.

Dated at Fitchburg, Wisconsin January 15, 2013

STATE OF WISCONSIN

DEPARTMENT OF NATURAL RESOURCES

For the Secretary

By /s/ Thomas Roushar

Thomas J. Roushar

Environmental Engineer Supervisor
 Page 2 of 21

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 128065080-P30 which then becomes the primary enforceable document:

Permit/Order Number Issuance Date Sources Covered & Description1 Permits Adopted

89-POY-116 October 18, 1990 For construction and operation of the four 

combustion turbine units. Not Applicable

97-JCH-154 February 4, 1998 For construction of inlet cooling system 

for each combustion turbine unit. Not Applicable

97-JCH-154-OP August 9, 2000 For operation of inlet cooling system for 

each combustion turbine. Not Applicable

128065080-P01 April 10, 1997 Total Facility1 89-POY-116, 97-JCH-154, and 

97-JCH-154-OP.

128065080-P02 September 5, 2000 Total Facility1

89-POY-116, 97-JCH-154, 97-

JCH-154-OP, and 128065080-

P01

128065080-P10 June 24, 2003 Total Facility1

89-POY-116, 97-JCH-154, 97-

JCH-154-OP, 128065080-P01, 

and 128065080-P02.

05-SDD-320 January 26, 2006 Modification of Combustion Turbines 

units 1 and 2 (P01 and P02) Not applicable

05-SDD-320-OP December 12, 2007 Operation of modified Combustion 

Turbines units 1 and 2 (P01 and P02) 05-SDD-320

128065080-P11 December 12, 2007 Total Facility1

89-POY-116, 97-JCH-154, 97-

JCH-154-OP, 128065080-P01, 

128065080-P02, 05-SDD-320, 

05-SDD-320-OP and 128065080-

P10.

128065080-P20 December 12, 2007 Total Facility1

89-POY-116, 97-JCH-154, 97-

JCH-154-OP, 128065080-P01, 

128065080-P02, 05-SDD-320, 

05-SDD-320-OP, 128065080-

P10, 128065080-P11, and 

128065080-P20.

08-SDD-104 September 3, 2012 Modification of Combustion Turbines 

units 3 and 4 (P03 and P04) Not applicable

128065080-P30 January 15, 2013 Total Facility1

89-POY-116, 97-JCH-154, 97-

JCH-154-OP, P01, P02, 05-SDD320, 05-SDD-320-OP, 

128065080-P10, 128065080-P11, 

and 128065080-P20.

1 - Total Facility refers to all existing units at the facility at the time of issuance of the permit listed.
 Page 3 of 21

Stack and Process Index:

Stack S01, Process P01, Control Device C01 – Combustion Turbine – Installed 7/7/93. This source is subject to New 

Source Performance Standards (NSPS) and Prevention of Significant Deterioration (PSD) requirements.

Stack S02, Process P02, Control Device C02 – Combustion Turbine – Installed 7/7/1993. This source is subject to New 

Source Performance Standards (NSPS) and Prevention of Significant Deterioration (PSD) requirements.

Stack S03, Process P03, Control Device C03 – Combustion Turbine – Installed 5/25/1994. This source is subject to 

New Source Performance Standards (NSPS) and Prevention of Significant Deterioration (PSD) requirements.

Stack S04, Process P04, Control Device C04 – Combustion Turbine – Installed 5/25/1994. This source is subject to 

New Source Performance Standards (NSPS), and Prevention of Significant Deterioration (PSD) requirements.

Stack S05, Process P05 – Inlet Cooling System – Installed 1999

Insignificant Emission Units:

Boiler, Turbine, and HVAC System Maintenance.

Convenience Space Heating (< 5 million BTU/hr Burning Gas, Liquid, or Wood).

Convenience Water Heating.

Demineralization and Oxygen Scavenging of Water for Boilers.

Fire Control Equipment.

Fuel Oil Storage Tanks (< 10,000 gal.).

Internal Combustion Engines Used for Warehousing and Material Transport.

Janitorial Activities.

Maintenance of Grounds, Equipment, and Buildings (lawn care, painting, etc.).

Office Activities.

Pollution Control Equipment Maintenance.

Purging of Natural Gas Lines.

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: 

None

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.
 Page 4 of 21

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 State of Wisconsin - Acid Rain Portion of an operation permit.

PART IV – This section contains Clean Air Interstate Rule (CAIR) Permit Requirements.
FID 128065080; Permit No. 128065080-P30 Page 5 of 21

Part I

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines - Installed 7/7/93, 7/7/93, 5/25/94 and 5/25/94 respectively. Each turbine

has an inlet cooler installed under permit 97-JCH-154. Units S01/P01 and S02/P02 were modified under permit 05-SDD-320 and Units S03/P03 and S04/P04 were 

modified under permit no. 08-SDD-104. These units are subject to New Source Performance Standards (NSPS) and Prevention of Significant Deterioration (PSD) 

requirements.

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

RECORDKEEPING & 

MONITORING REQUIREMENTS 

1. Particulate 

Matter Emissions

Continued on Next 

Page)

(1) Best Available Control 

Technology (BACT):

(a) 39.0 pounds per hour 

corrected to 59 degrees 

Fahrenheit.

(b) Best Available Control 

Technology (BACT) for 

particulate matter and PM10

has been determined to be 

good combustion practices 

and the use of natural gas 

and distillate oil with a sulfur 

content no greater than 

0.0015% (see Note 2).

(c) Total distillate oil use in 

turbines P01, P02, P03 and 

P04 combined may not 

exceed 2,664,760

gallons/month, averaged 

over any 12-month period.

(d) Total natural gas usage in 

turbines P01, P02, P03, and 

P04 combined may not 

exceed 1,356 million cubic 

feet/month, averaged over 

any 12-month period

(e) The total heat input to 

turbines P01, P02, P03, and 

P04 combined may not 

(1) The permittee shall operate a water injection system to control the 

formation of thermal nitrogen oxides whenever any of the turbines are 

on-line and are operating at loads at least 50 MW or higher.1 [s. NR 

405.08, Wis. Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD104 for P03 and P04 ]

(2) The permittee shall prepare a Start-up and Shut-down Plan for each 

of the turbines. This plan shall define normal start-up and shut-down 

procedures and sequences, including the normal duration of start-up and 

shut-down periods. [s. NR 407.09(4)(a), Wis. Adm. Code, 05-SDD-320 

for P01 and P02, and 08-SDD-104 for P03 and P04 ]

(3) Water injection into the combustion chamber may not fall below 90% 

or exceed 110% of the level required to comply with the nitrogen oxide 

emission limit of 25 ppmdv (at 15% O2 and 59 degrees Fahrenheit) when 

firing natural gas and 65 ppmdv (at 15% O2 and 59 degrees Fahrenheit) 

when firing distillate fuel oil or when co-firing distillate fuel oil and 

natural gas.1 [ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 

05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04 ]

(4) The water injection level referenced in condition I.A.1.b.(3), shall be 

determined in the most recent source performance test that demonstrated 

compliance with the NOx emission limits. [ss. NR 405.08 and NR 

407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04 ]

(1) Reference Test Method for 

Particulate Matter Emissions: 

Whenever compliance emission testing 

is required, US EPA Method 5, 

(including condensable backhalf 

emissions*)2 shall be used to 

demonstrate compliance. [s. NR 

439.06(1), Wis. Adm. Code]

(2) To meet the requirements of 

condition I.A.1.b.(5), the analysis in 

condition I.A.1.b.(6) may be performed 

by the permittee, a service contractor 

retained by the permittee, the fuel 

vendor or any other qualified agency. 

[s. NR 440.50(6)(e), Wis. Adm. Code, 

05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04 ]

(3) The permittee shall keep the 

following records for each turbine on 

an hourly basis: 

(a) The type of fuel used;

(b) The fuel consumption rate in units 

of 100 standard cubic feet per hour 

(100 scfh) when natural gas is used and 

gallons per hour when distillate oil is 

used; 

(c) The amount of water injected into 

 1

This condition is included to ensure the good combustion practice requirements of best available control technology are met.

2

 The requirement to include the condensable backhalf emissions in a compliance test is a State of Wisconsin Requirement.
FID 128065080; Permit No. 128065080-P30 Page 6 of 21

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

RECORDKEEPING & 

MONITORING REQUIREMENTS 

exceed 1,384,560

MMBTU/month, averaged 

over any 12-month period.

The operation of turbines 

P01, P02, P03, and P04 at 

less than 75 MW power 

output may not exceed 540 

hours in any month, 

averaged over any 12-month 

period. See Note 1.

Note 1. The fuel and 

operational restrictions are 

part of the BACT analysis 

and a key basis for the 

BACT analysis for all 

pollutants. 

Note 2. The fuel oil sulfur 

content limit of 0.0015% 

applies to all fuel oil 

purchased. 

[s. NR 405.08, Wis. Adm. 

Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 

for P03 and P04] 

(5) A representative sample shall be taken from each fuel lot of distillate 

oil received. The sample shall be analyzed by the permittee for sulfur 

content by weight using the procedures outlined in ss. NR 439.08(2), 

Wis. Adm. Code and the analysis retained by the permittee for a period 

of at least five years. [s. 285.65(3), Wis. Stats., 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

6) The Department will accept in lieu of an analysis of each fuel lot 

under (5) above, an analysis of a representative sample of the fuel lot of 

distillate oil fuel oil from which the fuel lot was taken. [s. 285.65(3), 

Wis. Stats., 05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 

and P04 ]

(7) Opacity may not exceed 10%.3 [ss. NR 405.08 and 440.11(3), Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 

and P04 ]

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

system (CMS) to continuously monitor and record on an hourly basis3: 

(a) The fuel consumption; and

(b) The ratio of water-to-fuel being fired in each turbine.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 

for P01 and P02, and 08-SDD-104 for P03 and P04] 

(9) The continuous monitoring system (CMS) required in condition 

I.A.1.b.(8) shall be:

(a) Accurate to within plus or minus 5.0% of the span of each flowrate 

meter; and 

(b) Shall meet the requirements of 40 CFR Part 75.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 

for P01 and P02, and 08-SDD-104 for P03 and P04]

the combustion chamber, in units of 

gallons per minute; and

(d) The ratio of water-to-fuel, 

determined from the mass flow rate of 

water to the mass flow rate of fuel, 

being fired in each turbine. 

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

05-SDD-320 for P01 and P02, and 08-

SDD-104 for P03 and P04 ]

(4) The permittee shall maintain a

monthly record of the following:

(a)the total MMBTU heat input to 

each turbine and a total for all turbines 

on a monthly basis. 

(b)the total heat input to the turbines 

for the most recent 12-month period. 

(c) the total number of hours that all 

turbines operated at less than 75 MW 

power output on a monthly basis.

(d) the total number of hours that all 

turbines operated at less than 75 MW 

power output for the most recent 12-

month period. [s. NR 439.04, Wis. 

Adm. Code]

 3 This condition is required to ensure that the good combustion practices required for best available control technology (BACT) are met.
FID 128065080; Permit No. 128065080-P30 Page 7 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines - (continued): These units are subject to New Source Performance 

Standards (NSPS) and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE 

DEMONSTRATION METHODS

c. REFERENCE TEST METHODS, RECORDKEEPING 

& MONITORING REQUIREMENTS 

2. Sulfur 

Dioxide and 

sulfuric acid 

mist

Continued on 

Next Page

(1) Best Available Control Technology 

(BACT):

4

(a) The permittee shall use natural gas 

with distillate oil as a back-up fuel 

whenever the turbines are operated.

(b) The permittee shall only use fuel with a 

sulfur content of no greater than 0.0015% 

by weight. (see Note 1.)

(c) The total usage of distillate fuel oil in 

turbines P01, P02, P03 and P04 combined 

may not exceed 2,664,760 gallons/month 

averaged over any 12-month period.

(d) The total usage of natural gas in 

turbines P01, P02, P03, and P04 combined 

may not exceed 1,356 million cubic 

feet/month averaged over any 12-month.

(e) The total heat input to turbines P01, 

P02, P03, and P04 combined, may not 

exceed 1,384,560 mmBtu/month averaged

over any 12-month period.

Note 1. The fuel oil sulfur content limit of 

0.0015% applies to all fuel oil purchased. 

[s. 285.65(7), Stats. and ss. NR 405.08 and 

NR 440.50(4), Wis. Adm. Code and 05-

SDD-320 for P01 and P02]

(1) The permittee shall fire only 

natural gas or distillate fuel oil. This 

condition is established to meet 

BACT emission limits. [s. NR 

407.09(4)(a)1., Wis. Adm. Code, 

05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04]

(2) A representative sample shall be 

taken from each fuel lot of distillate 

oil received. The sample shall be 

analyzed by the permittee for sulfur 

content by weight using the 

procedures outlined in s. NR 

439.08(2), Wis. Adm. Code and the 

analysis retained by the permittee for 

a period of at least five years. [s. 

285.65(3) Wis. Stats.]

(1) The permittee shall continuous monitor and record on an 

hourly basis of the type and amount of fuel used in each turbine. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

(2) Reference Test Method for Sulfur Dioxide Emissions: 

Whenever compliance emission testing is required, US EPA 

Method 20 shall be used to demonstrate compliance. [s. NR 

440.08(2), Wis. Adm. Code]

(3) To meet the requirements of condition I.A.2.b.(3), the 

analysis in condition I.A.2.b.(2) may be performed by the 

permittee, a service contractor retained by the permittee, the 

fuel vendor or any other qualified agency. [s. NR 440.50(6)(e), 

Wis. Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD104 for P03 and P04]

(4) The permittee shall submit semiannual excess emission 

reports to the Department. These reports shall be submitted to 

the Department within 30 days of the end of each 6 month 

period. [s. NR 440.07(3), Wis. Adm. Code, 05-SDD-320 for 

P01 and P02, and 08-SDD-104 for P03 and P04]

(5) The permittee shall keep a record of the calculation of 

mmBtu heat input to turbines P01,P02, P03 and P04 based on 

the monitoring requirements in the Acid Rain Program in 40 

CFR Part 75. [s. NR 439.04, Wis. Adm, Code, 05-SDD-320 

for P01 and P02, and 08-SDD-104 for P03 and P04]

 4 The best available control technology (BACT) requirements set pursuant to s. NR 405.08, Wis. Adm. Code are more restrictive than the new source performance standard (NSPS) 

requirements of s. NR 440.50(4), Wis. Adm. Code. Compliance with the BACT requirements is assumed to be compliance with the NSPS requirements.
FID 128065080; Permit No. 128065080-P30 Page 8 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

METHODS

c. REFERENCE TEST METHODS, RECORDKEEPING & 

MONITORING REQUIREMENTS 

2. Sulfur 

Dioxide 

(Continued) 

(3) The Department will accept, in lieu of an analysis of 

each fuel lot under (2) above, an analysis of a 

representative sample of the fuel lot of distillate fuel oil 

from which the fuel lot was taken. [s. 285.65(3) Wis. 

Stats.]

(a) The permittee shall retain copies of its distillate fuel 

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

facility for each fuel lot of distillate oil received 

pursuant to 40 CFR Part 60 Subpart GG, section 60.334. 

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

(b) The permittee shall further obtain certification from 

the fuel supplier that the applicable methods ins sec. NR 

439.08(2), Wis. Adm. Code were followed by the 

supplier in the preparation of said sulfur and heat 

content analyses. The lot's quantity of distillate fuel oil 

shall be included with copies of these analyses. [s. 

285.65(3) Wis. Stats.]

(c) When the turbine is supplied with natural gas, the 

sulfur content shall be determined once per year. These 

determinations shall be made by either the permittee or 

received from the fuel supplier.

[s. NR 440.50(5)(b), Wis. Adm. Code]

(6) For the purpose of the semiannual excess emission and 

monitoring system performance reports required above, periods of 

excess emissions that shall be reported for sulfur dioxide are:

Any daily period during which the sulfur content of the fuel being 

fired in the gas turbines exceeds 0.0015%, by weight. [ss. NR 

440.50(5)(c)2., Wis. Adm. Code, s. 285.65(7), Wis. Stats., 05-

SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

(7) The semiannual excess emission and monitoring system 

performance reports required above, shall contain:

(a) The dates that fuel exceeding the 0.0015% were fired;

(b) The type of fuel that exceeded the sulfur content limitation;

(c) The actual sulfur content of the fuel that was in excess of the 

appropriate weight limitation; and

(d) The amount of that fuel fired during that day

[ss. NR 440.50(5)(c)2., Wis. Adm. Code, NR 439.03(1)(a), Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for 

P03 and P04]
FID 128065080; Permit No. 128065080-P30 Page 9 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

METHODS

c. REFERENCE TEST 

METHODS, RECORDKEEPING, 

MONITORING REQUIREMENTS 

3. Nitrogen 

Oxides

Continued on 

Next Page

(1) Best Available Control Technology (BACT):

5

(a) 25 ppmdv (corrected to 15% O2 and 59 degrees Fahrenheit) 

while burning natural gas.

(b) 65 ppmdv (corrected to 15% O2 and 59 degrees Fahrenheit) 

while burning distillate oil or co-firing natural gas and distillate

fuel oil.

(c) Best Available Control Technology (BACT) for nitrogen 

oxide has been determined to be good combustion practice and 

use of water injection.

(d) The emissions during a startup and shutdown may not 

exceed 120 pounds for each startup/shutdown event from each 

turbine.

(e) The total emissions from the startup and shutdown of all four 

turbines combined may not exceed 96.4 tons in any 12 

consecutive month period.

(f) For purposes of calculating emissions to demonstrate 

compliance with condition (e), each startup period is defined as 

a startup and shutdown with a total duration of 42 minutes or 

less. When a startup and shutdown duration exceeds this level, 

emissions shall be calculated by accumulating additional startup 

events to equal or exceed the actual startup and shutdown 

period. 

(g) Total distillate oil use in turbines P01, P02, P03, and P04 

combined may not exceed 2,664,760 gallons/month, averaged 

over any 12-month period

(h) The total natural gas usage in turbines P01, P02, P03, and 

P04 combined may not exceed 1,356 million cubic feet/month, 

averaged over any 12-month period.

(1) The permittee shall operate a water 

injection system to control the formation of 

thermal nitrogen oxides whenever any of the 

turbines are on-line after the normal startup 

sequence as outlined in the plan required by 

condition I.A.1.b.(2) and until the units are 

taken off-line following a normal shutdown 

sequence as outlined in the plan required by 

condition I.A.1.b.(2).6 [s. NR 405.08, Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, 

and 08-SDD-104 for P03 and P04]

(2) Water injection into the combustion 

chamber may not fall below 90% or exceed 

110% of the level required to comply with the 

nitrogen oxide emission limit of 25 ppmdv (at 

15% O2 and 59 degrees Fahrenheit) when 

firing natural gas and 65 ppmdv (at 15% O2

and 59 degrees Fahrenheit) when firing 

distillate fuel oil or when co-firing distillate 

fuel oil and natural gas.6

 [ss. NR 405.08 and 

NR 407.09(4)(a)1., Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD-104 

for P03 and P04]

(1) The permittee shall keep the 

following records for each turbine on 

an hourly basis: 

(a) The type of fuel used;

(b) The fuel consumption rate in units 

of 100 standard cubic feet per hour 

(100 scfh) when natural gas is used 

and gallons per hour when distillate 

oil is used; 

(c) The amount of water injected into 

the combustion chamber, in units of 

gallons per minute; and

(d) The ratio of water-to-fuel, 

determined from the mass flow rate of 

water to the mass flow rate of fuel, 

being fired in each turbine. 

[ss. NR 440.50(5)(a) and NR 

439.04(1)(d), Wis. Adm. Code, 05-

SDD-320 for P01 and P02 and 08-

SDD-104 for P03 and P04]

 5 The best available control technology (BACT) requirements set pursuant to s. NR 405.08, Wis. Adm. Code are more restrictive than the new source performance standard (NSPS) 

requirements of s. NR 440.50(3), Wis. Adm. Code. Compliance with the BACT requirements is assumed to be compliance with the NSPS requirements. 6 This condition is included to ensure the good combustion practice requirements of best available control technology are met.
FID 128065080; Permit No. 128065080-P30 Page 10 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

METHODS

c. REFERENCE TEST METHODS, 

RECORDKEEPING & MONITORING 

REQUIREMENTS 

(i) The total heat input to turbines P01, P02, P03, 

and P04 combined may not exceed 1,384,560 

MMBTU/month, averaged over any 12-month 

period.

(j) The operation of turbines P01, P02, P03, and 

P04 combined at less than 75 MW power output 

may not exceed 540 hours in any month, averaged 

over any 12-month period. See Notes 1 and 2.

Note 1: Startup is defined as the period of time 

from the start of ignition until the unit load reaches 

50 MW(e) and water injection commences. A 

shutdown begins when unit load drops below 50 

MW(e) and water injection stops and ends when 

the flame is out. A startup/shutdown event is the 

combination of one startup and one shutdown.

Note 2: The fuel and operational restrictions are 

part of the BACT analysis and a key basis for the 

BACT analysis for all pollutants.

[ss. NR 405.08 and NR 440.50(3), Wis. Adm. 

Code, 05-SDD-320 for P01 and P02, and 08-

SDD-104 for P03 and P04]

(2) The permittee shall maintain the 

following records, compiled on a monthly 

basis

(a) the total emissions from each 

startup/shutdown event during the month

(b) the total emissions from all 

startup/shutdown events for the previous 

12 months of operation

[ss. NR 440.50(5)(a) and NR 

439.04(1)(d), Wis. Adm. Code, 05-SDD320 for P01 and P02, and 08-SDD-104 

for P03 and P04]
FID 128065080; Permit No. 128065080-P30 Page 11 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITS b. COMPLIANCE DEMONSTRATION METHODS c. REFERENCE TEST METHODS, RECORDKEEPING 

& MONITORING REQUIREMENTS 

3. Nitrogen 

Oxides 

(continued)

Continued on 

Next Page

(4) Correction of the emission rates in conditions I.A.3.a.(1) and 

I.A.3.b.(2) to 59 degrees Fahrenheit shall be calculated as 

follows:

E59 = ET x [0.81 + 0.00235(T+460) - (3.83 x 10-6

) x (T+460)2]

-1

where:

E59 is the emission rate at 59 degrees Fahrenheit in ppmdv.

ET is the emission rate at temperature T in ppmdv.

T is the temperature that the emission rate ET was measured at.

[s. NR 407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

(5) The permittee shall install and operate a continuous 

monitoring system (CMS) to continuously monitor and record on 

an hourly basis7

: 

(a) The fuel consumption; and

(b) The ratio of water to fuel being fired in each turbine.

[ss. NR 440.50(5)(a), NR 405.08, and NR 407.09(4)(a)1., Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 

for P03 and P04]

(6) The continuous monitoring system (CMS) required in 

condition I.A.3.b.(5) above shall be: 

(a) Accurate to within plus or minus 5.0% of the span of each 

flowrate meter; and 

(b) Approved by the Department.

[ss. NR 440.50(5)(a), NR 405.08, and NR 407.09(4)(a)1., Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 

for P03 and P04]

(3) The permittee shall submit semiannual excess emission 

reports to the Department. These reports shall be submitted to 

the Department within 30 days of the end of each 6 month 

period. [s. NR 440.07(3), Wis. Adm. Code and 05-SDD-320 

for P01 and P02 and 08-SDD-104 for P03 and P04]

(4) For the purpose of the semiannual excess emission reports

required in condition I.A.3.c.(3) above, periods of excess 

emissions that shall be reported for nitrogen oxides are: 

Any one-hour period within the normal operating range8 of each 

unit during which the average fuel-to-water ratio, as measured 

by the continuous monitoring system (CMS), falls below 90% 

or exceeds 110% of the water-to-fuel ratio determined in the 

most recent source performance test that demonstrated 

compliance with the nitrogen oxide emission limit.

[ss. NR 407.09(1)(c)1.b. and 440.50(5)(c)1., Wis. Adm. Code, 

05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 and 

P04]

(5) Each semiannual excess emission report required in 

condition I.A.3.c.(3) above, shall contain:

(a) The average water-to-fuel ratio;

(b) Average fuel consumption; and

(c) Gas turbine load during the period of excess emissions; and

(d) The graphs or figures developed under s. NR 

440.50(6)(b)2., Wis. Adm. Code.

[s. NR 440.50(5)(c)1., Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

 7 This condition is required by the new source performance standard (NSPS) requirements of s. NR 440.50(5)(a) and is also required to ensure that the good combustion practices 

required for best available control technology (BACT) are met.

8 The normal operating range does not include startup and shutdown provided startup and shutdown are performed according to the normal sequences as outlined in the plan 

required by condition I.A.1.b.(2).
FID 128065080; Permit No. 128065080-P30 Page 12 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITS b.COMPLIANCE 

DEMOS

c. REFERENCE TEST METHODS, RECORDKEEPING & MONITORING REQUIREMENTS 

3. Nitrogen 

Oxides 

(continued)

Continued on 

Next Page

(6) Each semiannual excess emission report required in condition I.A.3.c.(2) above shall include: 

(a) The magnitude of excess emissions computed in accordance with s. NR 440.13(8), Wis. Adm. Code9, any 

emission factor or factors used, and the date and time of commencement and completion of each time period of 

excess emissions. 

(b) The process operating time during the reporting period. 

(c) Specific identification of each period of excess emissions that occurs during startups, shutdowns and 

malfunctions of the turbines. The nature and cause of any malfunction, if known, and the corrective action taken of 

preventative measures adopted. 

(d) The date and time identifying each period during which the continuous monitoring system was inoperative and 

the nature of the system repairs or adjustments.

(e) When no excess emissions have occurred or the continuous monitoring system have not been inoperative, 

repaired or adjusted, such information shall be stated in the report.

[s. NR 440.07(3), Wis. Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

(7) If the total duration of excess emissions for the reporting period is less than 1% of the total operating time for 

the reporting period and continuous monitoring system (CMS) downtime for the reporting period is less the 5% of 

the total operating time for the reporting period, only the summary report form (s. NR 440.07(4) figure 1, Wis. Adm. 

Code) shall be submitted and the excess emissions report need not be submitted unless requested by the Department. 

[s. NR 440.07(4)(a), Wis. Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

(8) If the total duration of excess emission for the reporting period is 1% or greater of the total operating time for 

the reporting period or the total continuous monitoring system (CMS) downtime for the reporting period is 5% or 

greater of the total operating time for the reporting period, the summary report form (s. NR 440.07(4) figure 1, Wis. 

Adm. Code) and the excess emissions report shall both be submitted. [s. NR 440.07(4)(b), Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

 9

The permittee shall reduce all data to one-hour averages (any 60-minute period commencing on the hour). One hour averages shall be computed from 4 or more data points 

equally spaced over each one-hour period. Data recorded during periods of continuous monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments 

may not be included in the data averages. An arithmetic or integrated average of all data may be used. All excess emissions shall be converted into units of the standard using the 

applicable conversion procedures specified in the standard. After conversion into the units of the standard, the data may be rounded to the same number of significant digits used 

in the standard to specify the emission limit. [s. NR 440.13(8), Wis. Adm. Code]
FID 128065080; Permit No. 128065080-P30 Page 13 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITS b.COMPLIANCE 

DEMO. METHODS

c. REFERENCE TEST METHODS, RECORDKEEPING & MONITORING REQUIREMENTS 

3. Nitrogen 

Oxides 

(continued)

(9) Reference Test Method for Nitrogen Oxide Emissions:

(a) Whenever performance testing is required, US EPA Method 20 or Method 7E shall be used to determine 

nitrogen oxide and oxygen concentrations. 

(b) The span values shall be 100 ppm of nitrogen oxide and 21% oxygen or a span value approved by the 

Department in writing prior to the test.

(c) The nitrogen oxide emissions shall be determined at 30, 50, 75 and 100% of peak load or at 4 points in the 

normal operating range of the gas turbine, including the minimum point in the range and peak load. All loads 

shall be corrected to ISO conditions using the appropriate equations supplied by the manufacturer.

(d) The continuous monitoring system (CMS) shall be used to determine the fuel consumption and the water-tofuel ratio that correlates to the measured emission rates at 30, 50, 75 and 100% of peak load or at 4 points in the 

normal operating range of the gas turbine, including the minimum point in the range and peak load. All loads 

shall be corrected to ISO conditions using the appropriate equations supplied by the manufacturer.

(e) The nitrogen oxide emission rate (NOx) shall be computed for each test run using the following equation:

 NOx = (NOxo)(Pr/Po)

0.5 e19(Ho-0.00633) (288K/Ta)1.53

 where:

 NOx is the emissions of NOx at 15% oxygen and ISO standard ambient conditions, volume percent

 NOxo is the observed NOx concentration, ppm by volume

 Pr is the reference combustor inlet absolute pressure at 101.3 kilopascals ambient pressure, mm Hg

 Po is the observed combustor inlet absolute pressure at test, mm Hg

 Ho is the observed humidity of ambient air during test, g H2O/g air

 Ta is the ambient temperature during test, K

(f) Instead of using the above equation, manufacturers may develop ambient condition correction factors to 

adjust the nitrogen oxide emission level measured by the performance test as provided in s. NR 440.08, Wis. 

Adm. Code to ISO standard day conditions. These factors are developed for each gas turbine model they 

manufacture in terms of combustion inlet pressure, ambient air pressure, ambient air humidity, and ambient air 

temperature. They shall be substantiated with data and shall be approved by the Department before the initial 

performance test. [ss. NR 440.50(6)(c) and NR 440.08(2), Wis. Adm. Code, 05-SDD-320 for P01 and P02, 

and 08-SDD-104 for P03 and P04]
FID 128065080; Permit No. 128065080-P30 Page 14 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards 

(NSPS) and Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

METHODS

c. REFERENCE TEST METHODS, 

RECORDKEEPING & MONITORING 

REQUIREMENTS 

4. Carbon 

Monoxide

Continued on 

Next Page...

(1) Best Available Control Technology (BACT): 

(a) 20.0 pounds per hour (corrected to 59 degrees 

Fahrenheit) when operating at or above 75 MW output; 

(b) 300.0 pounds per hour (corrected to 59 degrees 

Fahrenheit) when operating below 75 MW output;

(c) Best Available Control Technology (BACT) for 

carbon monoxide has been determined to be good 

combustion practices;

(d) The emissions during a startup and shutdown may 

not exceed 382 pounds for each startup/shutdown event, 

from each turbine;

(e) The total emissions from the startup and shutdown 

of all four turbines combined may not exceed 306.0 tons 

in any 12 consecutive month period.

(f) For purposes of calculating emissions to demonstrate 

compliance with condition (e), each startup period is 

defined as a startup and shutdown with a total duration 

of 42 minutes or less. When startup and shutdown 

durations exceed this level, emissions shall be 

calculated by accumulating additional startup events to 

equal or exceed the actual startup and shutdown period. 

(g) Total distillate oil use in turbines P01, P02, P03, and 

P04 combined may not exceed 2,664,760

gallons/month, averaged over any 12-month period

(h) The total natural gas usage is turbines P01, P02, 

P03, and P04 combined may not exceed 1,356 million 

cubic feet/month, averaged over any 12-month period

(i) The total heat input to turbines P01, P02, P03, and 

P04 may not exceed 1,384,560 MMBTU/month, 

averaged over any 12-month period.

(j) The operation of turbines P01, P02, P03, and P04 at 

less than 75 MW power output may not exceed 540 

hours in any month, averaged over any 12-month 

period. 

See Notes 1 and 2.

(1) The permittee shall operate a water injection 

system to control the formation of thermal 

nitrogen oxides whenever any of the turbines are 

on-line after the normal startup sequence as 

outlined in the plan required by condition 

I.A.1.b.(2) and until the units are taken off-line 

following a normal shutdown sequence as 

outlined in the plan required by condition 

I.A.1.b.(2).10 [s. NR 405.08, Wis. Adm. Code, 

05-SDD-320 for P01 and P02, and 08-SDD-104 

for P03 and P04]

(2) Water injection into the combustion chamber 

may not fall below 90% or exceed 110% of the 

level required to comply with the nitrogen oxide 

emission limit of 25 ppmdv (at 15% O2 and 59 

degrees Fahrenheit) when firing natural gas and 

65 ppmdv (at 15% O2 and 59 degrees Fahrenheit) 

when firing distillate fuel oil or when co-firing 

distillate fuel oil and natural gas.10 [ss. NR 

405.08 and NR 407.09(4)(a)1., Wis. Adm. 

Code, 05-SDD-320 for P01 and P02, and 08-

SDD-104 for P03 and P04]

(3) The water injection level referenced in 

condition I.A.4.b.(2), shall be determined in the 

most recent source performance test that 

demonstrated compliance with the NOx emission 

limits. [ss. NR 405.08 and NR 407.09(4)(a)1., 

Wis. Adm. Code, 05-SDD-320 for P01 and 

P02, and 08-SDD-104 for P03 and P04]

(1) Reference Test Method for Carbon 

monoxide Emissions: Whenever 

compliance emission testing is required, 

US EPA Method 10 shall be used to 

demonstrate compliance. [s. NR 

439.06(4)(a), Wis. Adm. Code]

(2) The permittee shall keep the following 

records for each turbine on an hourly basis: 

(a) The type of fuel used;

(b) The fuel consumption rate in units of 

100 standard cubic feet per hour (100 scfh) 

when natural gas is used and gallons per 

hour when distillate oil is used; 

(c) The amount of water injected into the 

combustion chamber, in units of gallons 

per minute; and

(d) The ratio of water to fuel, determined 

from the mass flow rate of water to the 

mass flow rate of fuel, being fired in each 

turbine. 

[s. NR 439.04(1)(d), Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD104 for P03 and P04] 

(3) The permittee shall maintain the 

following records, compiled on a monthly 

 10 This condition is included to ensure the good combustion practice requirements of best available control technology are met.
FID 128065080; Permit No. 128065080-P30 Page 15 of 21

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION 

METHODS

c. REFERENCE TEST METHODS, 

RECORDKEEPING & MONITORING 

REQUIREMENTS 

Note 1: Startup is defined as the period of time from 

the start of ignition until the unit load reaches 50 

MW(e) and water injection commences. A shutdown 

begins when unit load drops below 50 MW(e) and water 

injection stops and ends when the flame is out. A 

startup/shutdown event is the combination of one 

startup and one shutdown.

Note 2: The fuel and operational restrictions are part of 

the BACT analysis and a key basis for the BACT 

analysis for all pollutants.

[s. NR 405.08, Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

(4) The permittee shall install and operate a 

continuous monitoring system (CMS) to 

continuously monitor and record on an hourly 

basis11: 

(a) The fuel consumption; and

(b) The ratio of water to fuel being fired in each 

turbine.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. 

Adm. Code and 05-SDD-320 for P01 and P02]

(5) The continuous monitoring system required 

in condition I.A.4.b.(4) above shall be:

(a) Accurate to within plus or minus 5.0% of the 

span of each flowrate meter; and 

(b) Approved by the Department.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04]

basis:

(a) the total emissions from each 

startup/shutdown event during the month; 

and 

(b) the total emissions from all 

startup/shutdown events for the previous 

12 months of operation.

[s. NR 439.04(1)(d), Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD104 for P03 and P04]

 11 This condition is required by the new source performance standard (NSPS) requirements of s. NR 440.50(5)(a) and is also required to ensure that the good combustion practices 

required for best available control technology (BACT) are met.
FID 128065080; Permit No. 128065080-P30 Page 16 of 21

A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) 

and Prevention of Significant Deterioration (PSD) requirements.

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

METHODS, 

RECORDKEEPING & 

MONITORING 

REQUIREMENTS 

5. Volatile 

Organic 

Compounds

Continued on 

Next Page...

(1) Best Available Control Technology (BACT): 

(a) 5.0 pounds per hour (corrected to 59 degrees 

Fahrenheit) when operating at or above 75 MW output;

(b) 16.0 pounds per hour (corrected to 59 degrees 

Fahrenheit) when operating below 75 MW output;

(c) Best Available Control Technology (BACT) for 

volatile organic compounds has been determined to be 

good combustion practices;

(d) The emissions during a startup and shutdown may not 

exceed 20.1 pounds for each startup/shutdown event from 

each turbine;

(e) The total emissions from the startup and shutdown of 

all four turbines combined may not exceed 16.0 tons in any 

12 consecutive month period;

(f) For the purposes of calculating emissions to 

demonstrate compliance with condition (e), each startup 

period is defined as a startup and shutdown with a total 

duration of 42 minutes or less. When startup and shutdown 

durations exceed this level, emissions shall be calculated 

by accumulating additional startup events to equal or 

exceed the actual startup and shutdown period. 

(g) The total distillate fuel oil use in turbines P01, P02, 

P03, and P04 combined may not exceed 2,664,760

gallons/month, averaged over any 12-month period.

(h) The total natural gas usage is turbines P01, P02, P03,

and P04 combined may not exceed 1,356 million cubic 

feet/month, averaged over any 12-month period

(i) The total heat input to turbines P01, P02, P03, and P04

combined may not exceed 1,384,560 MMBTU/month, 

averaged over any 12-month period.

(j) The operation of turbines P01, P02, P03, and P04 

combined at less than 75 MW power output may not 

exceed 540 hours in any month, averaged over any 12-

(1) The permittee shall operate a water injection system to control 

the formation of thermal nitrogen oxides whenever any of the 

turbines are on-line after the normal startup sequence as outlined in 

the plan required by condition I.A.1.b.(2) and until the units are 

taken off-line following a normal shutdown sequence as outlined in 

the plan required by condition I.A.1.b.(2).12 [s. NR 405.08, Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for 

P03 and P04]

(2) Water injection into the combustion chamber may not fall 

below 90% or exceed 110% of the level required to comply with 

the nitrogen oxide emission limit of 25 ppmdv (at 15% O2 and 59 

degrees Fahrenheit) when firing natural gas and 65 ppmdv (at 15% 

O2 and 59 degrees Fahrenheit) when firing distillate fuel oil or 

when co-firing distillate fuel oil and natural gas.12 [ss. NR 405.08 

and NR 407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

(3) The water injection level referenced in condition I.A.5.b.(2), 

shall be determined in the most recent source performance test that 

demonstrated compliance with the NOx emission limits. [ss. NR 

405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 for 

P01 and P02, and 08-SDD-104 for P03 and P04]

(1) Reference Test Method for Volatile 

Organic Compound Emissions: 

Whenever compliance emission testing 

is required, US EPA Method 25A shall 

be used to demonstrate compliance. [s. 

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

(2) The permittee shall keep the 

following records for each turbine on 

an hourly basis: 

(a) The type of fuel used;

(b) The fuel consumption rate in units 

of 100 standard cubic feet per hour 

(100 scfh) when natural gas is used and 

gallons per hour when distillate oil is 

used;

(c) The amount of water injected into 

the combustion chamber, in units of 

gallons per minute; and

(d) The ratio of water to fuel, 

determined from the mass flow rate of 

water to the mass flow rate of fuel, 

being fired in each turbine. 

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

and 05-SDD-320 for P01 and P02

and 08-SDD-104 for P03 and P04]

(3) The permittee shall maintain the 

following records, compiled on a 

monthly basis:

(a) the total emissions from each 

startup/shutdown event during the 

month

 12 This condition is included to ensure the good combustion practice requirements of best available control technology are met.
FID 128065080; Permit No. 128065080-P30 Page 17 of 21

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

METHODS, 

RECORDKEEPING & 

MONITORING 

REQUIREMENTS 

month period.

See Notes 1 and 2.

Note 1: Startup is defined as the period of time from the 

start of ignition until the unit load reaches 50 MW(e) and 

water injection commences. A shutdown begins when unit 

load drops below 50 MW(e) and water injection stops and 

ends when the flame is out. A startup/shutdown event is 

the combination of one startup and one shutdown.

Note 2: The fuel and operational restrictions are part of the 

BACT analysis and a key basis for the BACT analysis for 

all pollutants.

[s. NR 405.08, Wis. Adm. Code, 05-SDD-320 for P01 

and P02, and 08-SDD-104 for P03 and P04]

(2) Each turbine may not be operated more than 260 hours 

per month averaged over each 12 consecutive month 

period.13 [s. 285.65(7), Wis. Adm. Code, 05-SDD-320 for 

P01 and P02, and 08-SDD-104 for P03 and P04]

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

system (CMS) to continuously monitor and record on an hourly 

basis14: 

(a) The fuel consumption; and

(b) The ratio of water to fuel being fired in each turbine.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

(5) The continuous monitoring system (CMS) required in 

condition I.A.5.b.(4) above shall be: 

(a) Accurate to within plus or minus 5.0% of the span of each 

flowrate meter; and 

(b) Approved by the Department.

[ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code, 05-

SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

(6) To demonstrate that the operating hours of each turbine do not 

exceed 260 hours per month averaged over each 12 consecutive 

month period, the permittee shall calculate the monthly average

hours of operation over each 12 consecutive month period by 

dividing the total hours of operation during the previous 12 

consecutive months by 12. These calculations shall be performed 

within ten business days of the end of each calendar month. [s. NR 

407.09(4)(a)1., Wis. Adm. Code, 05-SDD-320 for P01 and P02, 

and 08-SDD-104 for P03 and P04]

(b) the total emissions from all 

startup/shutdown events for the 

previous 12 months of operation

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

05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04]

(3) The permittee shall keep monthly 

records of: 

(a) The hours that each turbine 

operated; and

(b) The calculations required by 

condition I.A.5.b.(6) for each turbine. 

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

05-SDD-320 for P01 and P02, and 

08-SDD-104 for P03 and P04]

 13 This condition was elected by the facility to limit the potential volatile organic compound emissions to less than 100 tons per year to avoid the prevention of significant deterioration (PSD) 

requirement that requires preconstruction monitoring for sources with potential emissions greater than 100 tons per year. The operating hours shall include the time required for startup and shutdown. 14 This condition is required by the new source performance standard (NSPS) requirements of s. NR 440.50(5)(a) and is also required to ensure that the good combustion practices required for best 

available control technology (BACT) are met.
FID 128065080; Permit No. 128065080-P30 Page 18 of 21

S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4) - Four Combustion Turbines. These units are subject to New Source Performance Standards (NSPS) and 

Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE 

DEMONSTRATION 

METHODS

c. REFERENCE TEST METHODS, RECORDKEEPING & MONITORING 

REQUIREMENTS

6. Visible 

Emissions

(1) 10% opacity.15 [ss. NR 

405.08 and 440.11(3), Wis. 

Adm. Code, 05-SDD-320 for 

P01 and P02, and 08-SDD-104 

for P03 and P04]

NOTE: The compliance 

demonstration methods 

for visible emissions are 

the same as those for 

particulate matter 

emissions listed in 

conditions I.A.1.b.(1) 

through (8).

(1) Reference Test Method for Visible Emissions: Whenever compliance emission testing 

is required US EPA Method 9 shall be used to demonstrate compliance. [s. NR 

439.06(9)(a)1., Wis. Adm. Code and 05-SDD-320 for P01 and P02]

NOTE: The record keeping requirements for visible emissions are the same as those for 

particulate matter emission listed in conditions I.A.1.c.(3)

7. All 

Pollutants

(1) Natural gas use may not 

exceed 1.243 x 106 cubic feet per 

hour for each turbine.16 [s. 

285.65(4), Wis. Stats., 05-SDD320 for P01 and P02, and 08-

SDD-104 for P03 and P04]

(2) Distillate oil use may not 

exceed 8,611 gallons per hour for 

each turbine.16 [s. 285.65(4), 

Wis. Stats., 05-SDD-320 for P01 

and P02, and 08-SDD-104 for 

P03 and P04]

(3) The operation of turbines 

P01, P02, P03 and P04 combined 

at less than 75 MW output may 

not exceed 540 hours/month 

averaged over any 12-month 

period, excluding 

startup/shutdown periods. [s. 

285.65(7), Wis. Stats., 05-SDD320 for P01 and P02, and 08-

SDD-104 for P03 and P04]

(1) The permittee shall 

keep hourly records of 

the type and amount of 

fuel used in each turbine 

in units of 100 standard 

cubic feet per hour (100 

scfh) when natural gas is 

used and gallons per 

hour when distillate oil 

is used. [s. NR 

407.09(4)(a)1., Wis. 

Adm. Code and 05-

SDD-320 for P01 and 

P02]

(1) The permittee shall maintain records of the following for each hour of operation of each 

turbine:

(a) the amount of time, in minutes, that are shutdown minutes (only if a portion of the hour 

is considered shutdown time);

(b) the amount of time, in minutes, that are startup minutes (only if a portion of the hour is 

considered startup time);

(c) the amount of time, in minutes, in which the turbine is operating at less than 75 MW 

output, but greater than 50 MW output (this time is considered less than 75 MW output 

operation);

(d) The amount of time, in minutes, in which the turbine operated at greater than or equal to 

75 MW output.

[s. NR 439.04, Wis. Adm. Code and 05-SDD-320 for P01 and P02 and 08-SDD-104 for 

P03 and P04]

(2) The permittee shall keep monthly records of the following for each turbine: 

(a) the time, in minutes, in which the turbines operated at or greater than 75 MW output;

(b) the amount of time the turbines operated at less than 75 MW output but greater than 50 

MW output;

(c) the number of minutes of startup and shutdowns which occurred during the month; and

(d) the total startup and shutdown emissions to demonstrate compliance with conditions 

I.A.3.a.(1)(e), I.A.4.a.(1)(e) and I.A.5.a.(1)(e). 

[s. NR 439.04, Wis. Adm. Code and 05-SDD-320 for P01 and P02]

(3) The records required by condition (2) above shall be available no later than the 15th of 

the month following the month for which the record has been kept. [s. NR 439.04, Wis. 

Adm. Code, 05-SDD-320 for P01 and P02, and 08-SDD-104 for P03 and P04]

 15Sec. NR 431.05(1), Wis. Adm. Code allows 20% opacity. However, as a condition for best available control technology (BACT) for particulate matter emissions, opacity shall 

be limited to 10%.

16This is the usage amount that the permittee applied for in 89-POY-116.
FID 128065080; Permit No. 128065080-P30 Page 19 of 21

ZZZ. Conditions Applicable to the Entire Facility. {

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

RECORDKEEPING & MONITORING 

REQUIREMENTS

1. State 

Hazardous 

Pollutants 

(HAPs)

(1) No owner or operator 

of a source may cause, 

allow or permit emissions 

of a hazardous air 

contaminant listed in 

Table A of s. NR 445.07, 

Wis. Adm. Code, in such 

quantity or concentration 

or for such duration as to 

cause an ambient air 

concentration of the 

contaminant off the 

source property that 

exceeds the concentration 

in column (g) of Table A 

for the contaminant.[s. 

NR 445.07(1)(a), Wis. 

Adm. Code)]*

(1) The permittee shall only burn Group 1 virgin fossil fuels 

(Natural gas, propane, distillate #2 and diesel fuel oil) when 

firing any fuel combustion sources.[s. NR 407.09(4)(a)3.b., Wis. 

Adm. Code]*

(2) When the permittee elects to change the existing operation 

by using a new raw material/fuel, product change or production 

capacity increase, or other operational changes, the permittee 

shall determine, either analytically or through the use of technical 

calculations, the facility’s new or increased potential emissions 

of any state hazardous air pollutant (State HAP) emitted, 

assuming maximum operation conditions. [s. NR 

407.09(4)(a)3.b., Wis. Adm. Code]* 

(3) The permittee shall determine if the facility’s new or 

increased potential emission rate of any State HAP exceeds the 

applicable published de minimus value in Table A of s. NR 

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

Code]*

(4) When the facility’s new or increased potential emission rate 

of any State HAP exceeds a published de minimus value, the 

permittee shall evaluate the impact of the pollutant’s emission 

and determine if any additional action needs to be taken to 

protect the ambient air quality standard.[s. NR 407.09(4)(a)3.b., 

Wis. Adm. Code]*

(1) Whenever any hazardous air pollutant 

concentration or emission rate testing of 

any material is required for demonstrating 

compliance, the permittee shall use a test 

method and testing protocol approved by 

either the US EPA or the Department.[ss. 

NR 407.09(1)(c)1.a. & 4(a)1. and NR 

439.06(8), Wis. Adm. Code]

(2) Recordkeeping and monitoring are 

not required for any applicable 

requirement where the facility does not 

have the potential to violate the emission 

limitations under normal operating 

conditions. The facility does not presently 

have the potential to emit, under normal 

operation conditions, any State HAP at an 

emission rate that has been determined to 

be injurious.[ss. 285.65(3) and 

285.63(4)(b), Wis. Stats.]*
FID 128065080; Permit No. 128065080-P30 Page 20 of 21

ZZZ. Conditions Applicable to the Entire Facility. {

ZZZ. Conditions Applicable to the Entire Facility. {Table Heading}

ZZZ. Conditions Applicable to the Entire Facility. 

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

RECORDKEEPING & 

MONITORING REQUIREMENTS

2. Malfunction 

Prevention and 

Abatement Plan.

(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 

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

Code]

(3) The facility shall submit the plan to the 

Wisconsin Department of Natural Resources, 

South Central Region Headquarters for 

review. 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]

(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, 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. [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]

Not Applicable
FID 128065080; Permit No. 128065080-P30 Page 21 of 21

ZZZ. Conditions Applicable to the Entire Facility. {Ta

CONDITION a. CONDITIONS

3. Reporting 

Malfunction 

Prevention and 

Abatement Plan.

((1) Submit 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 South Central Region Air Program, 3911 Fish Hatchery Road, WI 53711, phone 608-275-

3266 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.

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

(2) Submit a certification of compliance with the requirements of this permit to the Department and U.S. EPA annually. 

(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, South Central Region Air Program, 3911 Fish 

Hatchery Road, WI 53711, phone 608-275-3266 and to Compliance Data - Wisconsin, Air and Radiation Division, U.S. EPA, 77 W. 

Jackson, Chicago, IL 60604 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.

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

4. Compliance 

Testing

(1) Whenever compliance emission tests are required by the Department:

(a) Any compliance emission tests required by the Department shall be conducted while operating at 100% capacity17. If operation at 

100% capacity is not feasible, the sources shall operate at a capacity which is approved by the Department in writing. 

(b) The reference test methods outlined in this permit shall be used unless an alternate, U.S. EPA approved, test method is approved 

by the Department in writing. 

(c) The Department shall be informed at least 20 working days prior to any tests so a Department representative can witness the 

testing. 

(d) At the time of notification, a compliance test plan shall also be submitted for approval. 

(e) Two copies of the report on any required tests shall be submitted to the Department for evaluation within 60 days after the tests. 

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

}

 17100% capacity for this facility means that they shall operate at the maximum capacity achievable on the day of the test, given the ambient conditions for that day. Ambient 

conditions affect the maximum capacity that can be obtained by the combustion turbines.