1. PRELIMINARY DETERMINATION. 

ANALYSIS AND PRELIMINARY DETERMINATION FOR THE CONSTRUCTION AND 

OPERATION PERMITS FOR THE PROPOSED MODIFICATION 

OF TWO DIESEL ELECTRIC GENERATORS 

FOR 

CITY CENTER WEST, 

TO BE LOCATED AT 

525 JUNCTION ROAD, 

MADISON, DANE COUNTY, WISCONSIN 

Permit # 07-POY-022 and 113225200-F01

Facility ID # 113225200

This review was performed by the Wisconsin Department of Natural Resources, Bureau of Air 

Management in accordance with Chapter 285, Wis. Stats., and Sections NR 400 to NR 499, Wis. Adm. 

Code. 

Reviewed by: Paul Yeung Date:3/12/2007 

Peer review 

conducted by: /s/ POY for Susan Lindem Date:3/12/2007 

Preliminary Determination Approved by: Signature Date 

Regional Supervisor or Central Office 

Designee: /s/ Thomas Roushar 3/12/2007 

Stationary Source Modeling Team Leader: /s/ John A Roth 3/12/2007 

Compliance Engineer (reviewed/approved): /s/ POY for Ron Daggett 3/12/2007 

cc: Ronald Daggett — South Central Region 

Dane County Library Service, 201 W. Mifflin St., Madison, WI 53703-2597 
2. Introduction 

INTRODUCTION 

Stationary sources that are not specifically exempt from the requirement to obtain a construction permit 

under s. 285.60(5), Wis. Stats. or ch. NR 406, Wis. Adm. Code may not commence construction, 

reconstruction, replacement, relocation or modification unless a construction permit for the project has 

been issued by the Department of Natural Resource’s (DNR’s) Air Management Program. Owners or 

operators subject to the construction permit requirements must submit a construction and operation permit 

application to the DNR. The application is reviewed following the provisions set forth in ss. 285.60 to 

285.65, Wis. Stats. The criteria for permit issuance vary depending on whether the source is major or 

minor and whether the source is locating in an attainment or nonattainment area. 

Subject sources are to be reviewed with respect to the equipment and facility description provided in the 

application and for the resulting impact upon the air quality. The review ensures compliance with all 

applicable rules and statutory requirements. The plan review will show why the source(s) should be 

approved, conditionally approved, or disapproved. It will encompass emission calculations and an air 

quality analysis using US EPA models, if applicable. As a precautionary note, the emission estimates are 

based on US EPA emission factors (AP-42) or theoretical data and can vary from actual stack test data.

The sources included in this construction permit are also required to obtain an operation permit under s. 

285.60(1)(b), Wis. Stats. This review constitutes the Department’s review of applications for both the

construction permit and the operation permit for these units. This review may be updated when the 

compliance demonstration information is received. An operation permit may be issued after the applicant 

demonstrates that the sources included in the construction permit are in compliance with the applicable 

rules, emission limits and the conditions. Completion of this project will also result in a revision of the 

facility-wide operation permit. Once construction is complete and compliance with applicable 

requirements has been demonstrated, a revised facility-wide operation permit may be issued which 

incorporates the requirements of the construction permit. This preliminary determination also addresses 

the development of the revised facility-wide operation permit. 

3. General Application Information 

GENERAL APPLICATION INFORMATION 

Owner/Operator: City Center West 

525 Junction Road 

Madison, WI 53707 

Responsible Official: John Kothe, VP Operations 

608-663-7652 

Application Contact Person: Scott A Tebon, Construction Project Mgr 

608-663-7657 

Application Submitted By: Scott A Tebon, Construction Project Mgr 

608-663-7657 

Application submittal date: 01/29/2007 

Additional Information Submitted: January 29, 2007, February 1, 2007, February 5, 2007 and March 2, 

2007 

Date of Complete Application: March 2, 2007 

4. Project Description 

PROJECT DESCRIPTION 

The company owns the commercial properties at the location. There are two emergency electric 
generators on site, installed under the exemption under s. NR 406.04(1)(w), Wis. Adm. Code. The 

company is proposing to modify these generators such that they will be allow to provide electric power to 

the grid, thus making these peak shaving generators. 

The maximum theoretical emissions of criteria pollutants from these two generators combined exceed the

thresholds given in s. NR 406.04(2), Wis. Adm. Code. Thus a construction permit and an operation 

permit will be required. 

5. Source Description 

SOURCE DESCRIPTION 

Description of New or Modified Units. 

The two generators are both Detroit Diesel Generators Model 16V4000 with 2935 bhp and 2189 KW 

stand-by generation power. According to the manufacturer the maximum fuel usage is 0.326 pound per 

bhp-hour. The maximum heat input is 19.6 million BTU per hour. The maximum diesel fuel usage is 135 

gallons per hour. The maximum sulfur content of the diesel oil is 15 ppm. These were installed as 

emergency electric generators under the specific exemption at 525 Junction Road was installed in 2001 

(P01, S01) and the one at 535 Junction Road was installed in 2003 (P02, S02). 

There is another small emergency generator (P03, S03). This is a Detroit Diesel Generator Model 

150DSEJB with 160 KW maximum power. It was installed at the parking ramp of the commercial 

property complex. 

Stack Parameter Summary. 

Stack ID Circular or 

Rectangular

Discharge

Direction 

Exhaust

Obstacle 

Diameter or 

Width (if rect.)

Length (if 

rect.) Height Temp. Normal Flow Rate

Maximum 

Flow Rate

U, D, H True/False ft (m) ft (m) ft (m) °F ACFM ACFM

S01 C U FALSE 1.33 14 837 22116 22116

S02 C U FALSE 1.33 45 837 22116 22116

Insignificant Emissions Units. 

Boiler, Turbine, and HVAC System Maintenance. 

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

Convenience Water Heating. 

Fire Control Equipment. 

Janitorial Activities. 

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

Office Activities. 

Sanitary Sewer and Plumbing Venting. 

6. Cross Media Impacts 

CROSS MEDIA IMPACTS 

No cross media impact is expected from the project.
7. Emission Calculations 

EMISSION CALCULATIONS. 

Particulate Matter (PM) 

The company provided that the emission performance data from the generator manufacturer. The PM 

maximum emission is 294 grams per hour, thus the maximum PM emissions will be: 

294 g/hr / 453.6 g/# = 0.65 #/hr 

The applicable emission limit as given by s. NR 485.055, Wis. Adm. Code is 0.5 pound per million BTU. 

The hourly allowable emission rate will then be: 

19.6 mmbtu/hr x 0.5 #/mmbtu = 9.8 #/hr 

However, computer modelling results showed that the ambient air particulate matter impact will exceed 

the allowable increment. The company proposed a PM emission limit of 1.35 pound per hour. At that 

emission rate the PM will be: 

1.35 #/hr / 19.6 mmbtu/hr = 0.069 #/mmbtu. 

Annual PM potential to emit will be, based on the 200 hours/yr limit: 

200 hr/yr x 1.35 #/hr / 2000 #/ton = 0.14 ton/yr 

Both generators: 2 * 0.14 ton/yr = 0.28 ton/yr 

Sulfur Dioxide (SO2) 

The maximum fuel usage is 0.326 #/bhp-hr, at rated 2935 bhp, the maximum fuel usageis: 

 0.326 #/bhp-hr * 2935 bhp = 956.81 #/hr 

The maximum sulfur content is 15 ppm (0.0015%). Each pound of sulfur will produce a maximum of 2 

pounds of SO2 emissions. Thus the maximum SO2 emissions will be: 

 2 * 956.81 * 15E-6 #/hr = 0.029 #/hr 

Annual SO2 potential to emit will be, based on the 200 hours/yr limit: 

200 hr/yr x 0.029 #/hr / 2000 #/ton = 0.003 ton/yr 

Both generators: 2 * 0.003 ton/yr = 0.006 ton/yr 

Nitrogen Oxides (NOx) 

NOx The generator will meet the Tier 1 requirement for NOx of 6.9 g/bhp-hr 

 6.9 g/bhp-hr * 2935 bhp / 453.6 g/# = 44.65 #/hr 

Annual NOx potential to emit will be, based on the 200 hours/yr limit: 

200 hr/yr x 44.65 #/hr / 2000 #/ton = 4.47 tons/yr 
Both generators: 2 * 4.47 tons/yr = 8.94 tons/yr 

Carbon Monoxide (CO) 

CO The generator will meet the Tier 1 requirement for CO of 8.5 g/bhp-hr 

 8.5 g/bhp-hr * 2935 bhp / 453.6 g/# = 55 #/hr 

Annual CO potential to emit will be: 

200 hr/yr x 55 #/hr / 2000 #/ton = 5.5 tons/yr 

Both generators: 2 * 5.5 tons/yr = 11.0 tons/yr 

Volatile Organic Compound (VOC) 

VOC The generator will meet the Tier 1 requirement for VOC of 1.0 g/bhp-hr 

 1.0 g/bhp-hr * 2935 bhp / 453.6 g/# = 6.47 #/hr 

Annual VOC potential to emit will be, based on the 200 hours/yr limit: 

200 hr/yr x 6.47 #/hr / 2000 #/ton = 0.65 ton/yr 

Both generators: 2 * 0.65 ton/yr = 1.3 tons/yr 

The total HAP emission factor from diesel generator sets is given in Tables 3.4-3 and 3.4-4 in AP-42 by 

USEPA as 4.364 x 10-3 #/mmbtu. Maximum heat input for each generator will be 19.6 mmbtu/hr. Total 

HAP from each generator will be: 

4.364 x 10-3 #/mmbtu x 19.6 mmbtu/hr = 0.086 #/hr 

0.086 #/hr * 200 hr/yr / 2000 #/ton = 0.0086 tons/yr 

With both sets together, the total HAP emissions will be: 

0.086 #/hr x 2 = 0.172 #/hr 

0.0086 ton/yr x 2 = 0.017 ton/yr 

8. Wisconsin Hazardous Air Pollutant (NR 445) Review 

WISCONSIN HAZARDOUS AIR POLLUTANT (NR 445) REVIEW

The use of diesel oil as fuel in electric generators will result in some amounts of hazardous air pollutants 

(HAPs) emissions. Diesel oil is a distillate fuel oil which is a Group 1 virgin fossil fuel. Combustion of 

Group 1 virgin fossil fuels is exempt from the Emission Thresholds, Standards & Control Requirements 

listed in Table A, s. NR445.07; Wis. Adm. Code, however, CI engines are subject to the Fuel, Control &

Compliance Requirements of s. NR445.09, Wis. Adm. Code. 

The federal HAP emissions will be less than 0.1 ton per year based on potential to emit. 
9. Compliance and Technology Review 

COMPLIANCE AND TECHNOLOGY REVIEW

The generator set will emit criteria pollutants due to the internal combustion of #2 diesel fuel oil. The 

generator/engine set will have a PM emission limit of 1.35 pounds per hour. This emission limit is 

necessary to prevent any exceedance of the PM ambient air standard and increment consumption limit. 

According to the emissions data provided by the engine manufacturer, this PM emission limit should be 

met. The worst case PM emission rate is expected to be 0.65 pound per hour. 

The company proposed to limit the electricity output to 200-hrs per year. This will result in less than 100 

tons per year for each of the criteria pollutants. No environmental assessment will be necessary. To 

demonstrate compliance with this limit, the company proposed to keep monthly records on hours of 

operation for each generator. 

The company also proposed to limit the amount of diesel fuel burned to less than 10,000 gallons per any 

12 consecutive months for each generator. This will result in the avoidance of the applicability of s. NR 

445.09(3), Wis. Adm. Code. The two engines/generators will still be subject to the fuel requirement in s. 

NR 445.09(2), Wis. Adm. Code and will only combust fuel oil with a sulfur content no greater than the 

sulfur content that is allowed for on-road use at the time the fuel was purchased, when firing the engine 

with fuel oil. 

To demonstrate compliance with this limit, the company will keep monthly records on the gallons of fuel 

purchased each generator. 

 

10. Air Quality Review 

AIR QUALITY REVIEW

Mrs. Gail Good has performed the air quality review for the project, the following are her finding and

conclusion. 

II. MODEL RESULTS 

The results demonstrate that the ambient air quality standards for TSP, PM10, SO2, CO, and NOx will be attained and 

maintained assuming the emission rates and stack parameters listed in the attached source table. 

Modeling Analysis Results 

(All Concentrations in μg/m3

) 

1.

TSP – 24 hr PM10 – 24 hr PM10 – Annual 

Modeled Concentration 29.9 29.9 9.7 

Increment - 30.0 17.0 

%Increment Consumed - 99.7 57.1 

Background Concentration 69.3 56.0 22.2 

Total Concentration 99.2 85.9 31.9 

NAAQS 150.0 150.0 50.0 

% NAAQS 66.1 57.3 63.8 
Modeling Analysis Results 

(All Concentrations in μg/m3) 

2.

SO2 – 3 hr SO2 – 24 hr SO2 – Annual 

Modeled Concentration 30.3 6.7 0.45 

Increment 512.0 91.0 20.0 

% Increment Consumed 5.9 7.4 2.3 

Background 128.3 33.5 7.9 

Total Concentration 158.6 40.2 8.4 

NAAQS 1300.0 365.0 80.0 

% NAAQS 12.2 11.0 10.5 

Modeling Analysis Results 

(All Concentrations in μg/m3

) 

3.

CO – 1 hr CO – 8 hr NOx – Annual 

Modeled Concentration 3575.3 1510.4 6.7 

Increment - - 25.0 

% Increment Consumed - - 26.8 

Background Concentration 3188.0 890.4 13.6 

Total Concentration 6763.3 2400.8 20.3 

NAAQS 40000.0 10000.0 100.0 

% NAAQS 16.9 24.0 20.3 

D. CONCLUSION 

The results of the modeling analysis demonstrate that the applicable air quality standards will be satisfied assuming 

the emissions rates and stack parameters listed in the source table. Note that the generators at City Center West will 

be limited to 200 hours of operation per year. 

City Center West - Madison 

Stack Parameters 

ID LOCATION 

(UTM – NAD27) 

HEIGHT 

(M) 

DIAM 

(M) 

VELOCITY 

(M/S) 

TEMP 

(K) 

S1 294515, 4771961 4.27 0.41 80.9 720.2 

S2 294464, 4771974 13.72 0.41 80.8 720.2 

S3 294524, 4771960 2.44 0.10 70.4 838.6 

DEAN 294764, 4772289 3.35 0.36 63.6 760.8 
City Center West - Madison 

Emission Rates 

ID PM (#/HR) SO2 (#/HR) CO (#/HR) NOx (#/HR)* 

S1 1.352 0.014 54.7 44.36 (1.01) 

S2 1.352 0.014 54.7 44.36 (1.01) 

S3 0.22 - 4.7 3.79 (0.09) 

DEAN 0.65 - - 9.25 

* The generators are limited to 200 hours per year in order to get passing NOx results. The NOx emission rates 

were scaled accordingly. The rate is shown first with the scaled rate, used in the modeling, shown second. 

 

4. Emissions From New Equipment or Modification 

EMISSIONS FROM NEW EQUIPMENT OR MODIFICATION 

A. Stack Emissions. 

I. P01, S01 and P02, S02, each 

Potential to Emit 

Pollutant Pounds per Hour 

(lbs/hr) 

Tons per Year 

(TPY) 

Particulate matter (PM) 1.35 0.14 

Sulfur dioxide (SO2) 0.029 0.003 

Nitrogen oxides (NOx) 44.65 4.47 

Carbon monoxide (CO) 55.0 5.5 

Volatile organic compounds 

(VOCs) 

6.47 0.65 

5. Total Emissions From New Equipment or Modification 

TOTAL EMISSIONS FROM NEW EQUIPMENT OR MODIFICATION 

Pollutant Potential to Emit (TPY unless otherwise noted) 

Particulate matter (PM) 0.28 

Sulfur dioxide (SO2) 0.006 
Nitrogen oxides (NOx) 8.94 

Carbon monoxide (CO) 11.0 

Volatile organic compounds (VOCs) 1.3 

Total Federal HAPs 

(s. 112(b) pollutants) 

< 10 

6. Facility and Project Classification 

FACILITY AND PROJECT CLASSIFICATION 

1. Existing Facility Status. 

Currently, there are only three generators on site and they were all installed as emergency generators, 

based on the exemption in s. NR 406.04(1)(w), Wis. Adm. Code. By definition, they are limited to 

less than 200 hours per year. As such, the facility is a minor source for PSD, Part 70 and HAPs. 

2. Project Status. 

The company proposed to have the two larger generators to be peak shaving generators, but still 

proposed to be limited to 200 hours of operations. Thus, the project will result in the facility 

remaining as a minor source for PSD, Part 70 and HAPs. 

3. Facility Status after Completion of the Project.

The company proposed to have the two larger generators to be peak shaving generators, but still 

proposed to be limited to 200 hours of operations. Thus, the project will result in the facility 

remaining as a minor source for PSD, Part 70 and HAPs. 

4. Summary. 

NSR Applicability 

Existing Facility Proposed Project Facility After Project

Major Minor Major Minor Major Minor

PSD X X 

Non-Attainment NA 

Federal HAP X X X 

Part 70 Applicability 

Existing Facility Facility After Project

Part 70 FESOP (Syn. Minor) non-part 70 Part 70 FESOP (Syn. Minor) non-part 70

Status X X 

7. Environmental Analysis 

ENVIRONMENTAL ANALYSIS 

The proposed project is a Type III action under Chapter NR 150, Wis. Adm. Code, because there is a 

potential increase in hazardous emissions and the potential to emit of the project is less than 100 TPY for 

each criteria pollutant. 
A news release is required for this proposal and is included in the public comment notice. It is proposed 

that an environmental assessment not be completed. 

8. Rule Applicability 

RULE APPLICABILITY 

There is an NSPS subpart IIII promulgated on July 11, 2006 for compression ignition engines. The first 

model year subject to the NSPS will be 2007. These generators were installed prior to 2004. The NSPS

covers engines that have been modified. These generators will become peak shaving generators and thus

there will be a change in mode of operation. However, there will not be any increase of emissions, thus it 

is not a modification under NSPS. 

The generators are subject to the particulate matter emission limit of 0.5 pound per million heat input as 

given in s. NR 485.055, Wis. Adm. Code. However, at that emission rate the ambient air standard will be 

exceeded. To protect the ambient air standard, the applicant has proposed an emission limit of 1.35 

pound per hour for each generator. 

NR 485.05(4), Wis. Adm. Code states that the visible emission limit for semistationary diesel engines is 

40% opacity for no more than 5 minutes in any 30-minute period. However, these are stationary engines

producing electric power, not semistationary generators such as those in construction sites. Therefore, 

NR 431.05, Wis. Adm. Code with visible emission limit of 20% opacity will be applicable. 

The proposed project will result in the potential to emit of each criteria pollutant of less than 100 tons per 

year. There will be federally enforceable permit conditions in place in order to limit the potential to emit. 

The total potential to emit of federal hazardous air pollutants (HAPs) from the project will be less than 10 

tons per year. The proposed facility will be a synthetic minor source for PSD, Part 70 and the federal 

HAP program. 

The company proposes to limit the use of diesel fuel to less than 10,000 gallons per year for each 

generator, thus avoiding the applicability of s. NR 445.09(3), Wis. Adm. Code. The two 

engines/generators will still be subject to the fuel requirement in s. NR 445.09(2), Wis. Adm. Code and 

will only combust fuel oil with a sulfur content no greater than the sulfur content that is allowed for onroad use at the time the fuel was purchased, when firing the engine with fuel oil. 

9. New Source Performance Standards (NSPS) Applicability 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY 

For proposed construction of a source: 

1. Is the proposed source in a source category for which there is an existing or proposed NSPS? Yes

No Not applicable. (If yes, identify the source category.) 

2. Is the proposed source an affected facility? Yes No Not applicable. (Explain if necessary 

to clarify.) 

For the proposed modification of an existing source: 

1. Is the existing source, which is being modified, in a source category for which there is an existing or 

proposed NSPS? Yes No Not applicable. (If yes, identify the source category.) There is 

an NSPS subpart IIII promulgated on July 11, 2006 for compression iginition engines. The first 

model year subject to the NSPS will be 2007. These generators were installed prior to 2004. The 

NSPS covers engines that have been modified. These generators will become peak shaving 

generators and thus there will be a change in mode of operation. However, there will not be any 

increase of emissions, thus it is not a modification under NSPS. 
2. Is the existing source, which is being modified, an affected facility (prior to modification)? No 

3. Does the proposed modification constitute a modification under NSPS to the existing source? No 

4. Will the existing source be an affected facility after modification? No 

10. National Emission Standards For Hazardous Air Pollutants (NESHAPS) Applicability 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS) 

APPLICABILITY 

Part 61 NESHAPS: 

1. Will the proposed new or modified source emit a pollutant controlled under an existing or proposed 

NESHAPS? Yes No (if yes, identify the pollutant). 

2. Is the proposed new or modified source subject to an existing or proposed NESHAPS? Yes No 

(if yes, identify NESHAPS). 

Part 63 NESHAPS: 

1. Will the proposed new or modified source emit a pollutant controlled under an existing Part 63 

NESHAPS? Yes No (if yes, identify the pollutant). Formaldehyde 

2. Is the proposed new or modified source subject to an existing Part 63 NESHAPS? Yes No 

(if yes, identify NESHAPS). 

3. Is the proposed project subject to s. 112(g) of the Clean Air Act? Yes No. 

The section 112(g) rules only apply to case-by-case MACT standards that are developed for new 

construction or reconstruction of sources that (by themselves) constitutes a new major source of 

federal hazardous air pollutants (for source categories not covered under an existing Part 63 MACT 

standard). 

 

11. Criteria For Permit Approval 

CRITERIA FOR PERMIT APPROVAL 

Section 285.63, Wis. Stats., sets forth the specific language for permit approval criteria. The Department 

finds that: 

1. The source will meet emission limitations. 

2. The source will not cause nor exacerbate a violation of an air quality standard or ambient air 

increment. 

3. The source is operating or seeks to operate under an emission reduction option. Not Applicable. 

4. The source will not preclude the construction or operation of another source for which an air pollution 

control permit application has been received. 

12. Determination 

DETERMINATION 

The preliminary determination of the DNR Air Management Program is that this project when 

constructed or modified and operated consistent with the application and subsequent information 
submitted will be able to meet the emission limits and conditions included in the attached Draft Permit. A 

final decision regarding emission limits and conditions will be made after the Department has reviewed

and evaluated all comments received during the comment period. The proposed emission limits and other 

proposed conditions in the Draft Permit are written in the same form that they will appear in the 

construction permit and, where applicable, the operation permit. These proposed conditions may be 

changed as a result of public comments or further evaluation by the Department. 
13. Permit Fee Calculation 

CONSTRUCTION PERMIT FEE CALCULATION 

Basic Fees.

1. Construction or replacement of a PSD or NAA minor source or the 

PSD or NAA minor modification of a Part 70 minor source. 

[$2,300] 

$2300

 Total Basic Fees $2300

Additional Fees. 

2. The application is for a source not reviewed under ch. NR 405 or 

408, Wis. Adm. Code, where the applicant requested in writing and 

received the permit in 50 days or less. [$2,650] 

1 × $2650 $2650

3. The application is for a source which requires specific permit 

conditions to limit the facility potential to emit in order to make the 

source or modification a PSD, NAA or Part 70 minor source or a 

PSD or NAA minor modification. [$2,150] 

1 × $2150 $2150

4. The permit application required the review and analysis of 2 basic 

emissions unit(s). [$400 per basic emission unit, 2 basic emissions 

unit(s).] 

2 × $400 $800

5. The permit application is for a PSD or NAA minor source or minor 

modification to a major PSD or NAA source whose projected air 

quality impact requires a detailed air quality modeling analysis. 

[$700] 

1 × $700 $700

Total Additional Fee $6300

Total Fee (Total Basic Fee + Total Additional Fee) $8600

Credit(s). 

6. The initial fee submitted with the application. [$1,350 or $1,000 if 

the application was received before July 1, 2000] 

($1350)

7. The applicant publishes the newspaper notice. [$150] ($150)

 Total Credit ($1500)

TOTAL AMOUNT DUE (Total Fee + Total Credit) $7100