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: W e Energies

- Concord Generating Station

Street Address: N8914 County Trunk Hwy E

, Watertown, Jefferson County, Wisconsin

Responsible Official, & Title: Terry Hoffman

, Asset Manager

is autho rized to operate an e lectric p ower g eneration 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 1 5 , 201 8 [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 upo n 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 en forceable.
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 I V hereof.

Dated at Fitchburg , Wisconsin January 1 5 , 2013

STATE OF WISCONSIN DEPARTMENT OF NATURAL RESOURCES 

### For the Secretary

By /s/ Thomas Roushar Thomas J. Roushar Environmental Engineer SupervisorPage 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 & Description 1 Permits Adopted

89

- POY

- 116 October 18, 1990 For construction and operation of the four combust ion 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 Ap plicable

128065080

- P01 April 10, 1997 Total Facility 1 89

- POY

- 116, 97

- JCH

- 154, and 97

- JCH

- 154

- OP

.

128065080

- P02 September 5, 2000 Total Facility 1 89

- POY

- 116, 97

- JCH

- 154, 97

- JCH

- 154

- OP, and 128065080

- P01

128065080

- P10 June 24, 2003 Total Facility 1 89

- PO Y

- 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 un its 1 and 2 (P01 and P02) 05

- SDD

- 320

128065080

- P11 December 12, 2007 Total Facility 1 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 Facility 1 89

- PO Y

- 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

1280 65080

- P30 January 15 , 2013 Total Facility 1 89

- POY

- 116, 97

- JCH

- 154, 97

- JCH

- 154

- OP, P01, P02, 05

- SDD

320, 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 issua nce 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
Sour ce 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 T urbine

– 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:

B oiler, 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. Purg ing of Natural Gas Lines. Sanitary Sewer and Plumbing Venting.
P ermit 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 limitation s 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 th e applicable limitation or if the Department determines that the emission limitation s 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 lega l 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, incl uding 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.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 standa rd 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 init ial and periodic test schedules, if testing is required, will be stated here. Notwithstanding 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

r elevant 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 wi ll 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 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 tha t 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 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 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**

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### 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

. E ach 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 PM 10 has been determined to be good combustion p ractices and the use of natural gas and distillate oil with a sulfur content no greater than 0.0 01 5% (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 pe riod

. (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 , 0 5

- SDD

- 320 for P01 and P02 , and 08

- SDD

104 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 norm al 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 t o comply with the nitrogen oxide emission limit of 25 ppmdv (at 15% O 2 and 59 degrees Fahrenheit) when firing natural gas and 65 ppmdv (at 15% O 2 and 59 degrees Fahrenheit) when firing distillate fuel oil or when co

- firing distillate fuel oil and natural g as. 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 tha t demonstrated compliance with the NO x 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) m ay 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 ke ep the following records for each turbine on

a n 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**

**- P**  **30 Page**  **6 of**  **21**

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION METHODS c. REFERENCE TEST METHODS, RECORDKEEPING & MONITORING REQUIREMENTS
exceed 1,384,560 MMB TU/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 restrict ions 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

- SD D

- 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. St ats. , 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) Th e permittee shall install and operate a continuous monitoring system (CMS) to continuously monitor and record on an hourly basis 3 : (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 ba sis. (b) the total he at 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 ou tput 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 requi red for best available control technology (BACT) are met.**FID 128065080 ; Permit**  **No. 128065080**

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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 fu el with a sulfur content of no greater than 0.0 015% 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 P0 4 combined, may not exceed 1,384,560 mmBtu/month average d 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 recei ved. 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 S ulfur 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

- SDD

104 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 a nd 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**

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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) requ irements.

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 a nalyses 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 i ns 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 ex ceeds 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 c ontain: (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 t hat 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**

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A. S01/P01 (**1), S02/P02 (**2), S03/P03 (**3) and S04/P04 (**4)

- Four C ombustion Turbi nes. 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 R EQUIREMENTS
3. Nitrogen Oxides

Continued on Next Page (1) Best Available Control Technology (BACT) : 5 (a) 25 ppmdv (corrected to 15% O 2 and 59 degrees Fahrenheit) while burning natural gas. (b) 65 ppmdv (corrected to 15% O 2 an d 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 star t up /shutdown event from each turbine

. (e) The total emissions from the sta rtup and shutdown of all four turbines combined may not exceed 96.4 tons in any 12 consecutive month pe riod. (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

ove r any 12

- month period (h) T he t otal 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 form ation 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% O 2 and 59 degrees Fahrenheit) when firing natural gas and 65 ppmdv (at 15% O 2 and 59 degrees Fahrenheit) when firing distillate fuel oil or when co

- firing distillate fuel oil and natural gas. 6 [s s. 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

a n hourly basis: (a) The type of fuel used; (b) The fuel consumption r ate 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 a vailable control technology (BACT) requirements set pursuant to s. NR 405.08, Wis. Adm. Code are more restrictive than the ne w source performance standard (NSPS) requirements of s. NR 440.50(3), Wis. Adm. Code. Compliance with the BACT requirements is ass umed 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**

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A. S01/P 01 (**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. COMPLIAN CE 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 permitt ee 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

- SDD

320 for P01 and P02, and 08

- SDD

- 104 for P03 and P04]**FID 128065080 ; Permit**  **No. 128065080**

**- P**  **30 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 Standard s (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:

E 59 = E T x [0.81 + 0.00235(T+460)

- (3.83 x 10 - 6 ) x (T+460) 2 ] - 1

where: E 59 is the emissio n rate at 59 degrees Fahrenheit in ppmdv. E T is the emission rate at temperature T in ppmdv. T is the temperature that the emission rate E T 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 basis 7 : (a) The fuel consumption; and (b) The ratio of water to fuel being fired in each turbine. [ss. NR 440.50(5)(a), NR 40 5.08, 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 o f 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
repor ts 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 semian nual 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 range 8 of each unit during which the average fuel

- to

- water ra tio, 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 P 03 and P04]

7 This condition is required by the new source performance standard (NSPS) requ irements 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**

**- P**  **30 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. LIM ITS 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 s hall include: (a) The magnitude of excess emissions computed in accordance with s. NR 440.13(8), Wis. Adm. Code 9 , any emission factor or factors used, and the date and time of commencement and completion of each time period of excess emissions. (b) The p rocess 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 correct ive 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

- SD D

- 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**

**- P**  **30 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.
P OLLUTANT 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 E PA 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 appr opriate equations supplied by the manufacturer. (d) The continuous monitoring system (CMS) shall be used to determine the fuel consumption and the water

- to

fuel 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 (NO x ) shall be computed for each test run using the following equation:

NO x = (NO xo )(P r /P o ) 0.5 e 19(Ho

- 0.00633) (288K/T a ) 1.53

where:

NO x is the emissions of NO x at 15% oxygen and ISO standard ambient conditions, volume percent NO x o is the observed NO x concentration, ppm by volume P r is the reference combustor inlet absolute pressure at 101.3 kilopascals ambient pressure, mm Hg P o is the observed combustor inlet absolute pressure at test, mm Hg H o is the observed humidit y of ambient air during test, g H 2 O/g air T a 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 amb ient 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**

**- P**  **30 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. C OMPLIANCE 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 eac h startup/shutdown event, from each turbine ; (e) The total emissions from the star tup 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 shut down 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) T he t otal 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 Note s 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

ou tlined 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% O 2 and 59 degrees Fahrenheit) when firing natural g as and 65 ppmdv (at 15% O 2 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 NO x emission limits. [ss. NR 405.08 and NR 407.09(4)(a)1., Wis. Adm. Code , 05

- SDD

- 3 20 for P01 and P02, and 08

- SDD

- 104 for P03 and P04] (1) Reference Test Method for Carbon monoxide Emissions: Whenever complian ce 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 a n hourly basis: (a) The type of fuel used; (b) The f uel 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

- SDD

104 for P03 and P04]

(3) The permit tee 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**

**- P**  **30 Page**  **15 of**  **21**

POLLUTANT a. LIMITATIONS b. C OMPLIANCE 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 basis 11 : (a) The fuel consumption; and (b) The ratio of water to f uel 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

- SDD

104 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 requi red to ensure that the good combustion practices required for best available control technology (BACT) are met.**FID 128065080 ; Permit**  **No. 128065080**

**- P**  **30 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)

an d Prevention of Significant Deterioration (PSD) requirements.

POLLUTANT a. LIMITATIONS b. COMPLIANCE DEMONSTRATION METHODS c. REFERENCE TEST METHODS, RECORDKEEPING & MONITORING REQUIREMENTS

5. Volatile Organic Compounds

Con tinued 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

e ach turbine ; (e) The total emissions from the st artup 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 s tartup 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 st artup and shutdown period. (g) T he t otal 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) T he t otal natural gas usage is turbines P01, P02, P03

, and P04 com bined 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 turbin es 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 therma l 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 requi red 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 nitr ogen oxide emission limit of 25 ppmdv (at 15% O 2 and 59 degrees Fahrenheit) when firing natural gas and 65 ppmdv (at 15% O 2 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 complia nce with the NO x 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

a n hourly basis: (a) The type of fuel used; (b) The fuel consumption rate in units of 100 standard cubic feet per hour (100 scfh) w hen 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 m ass 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 emis sions 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**

**- P**  **30 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 fue l 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 t han 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 basis 14 : (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) T he 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. Cod e, 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 4 07.09(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 condit ion 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 poten tial 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 requi red to ensure that the good combustion practices required for best

available control technology (BACT) are met

.**FID 128065080 ; Permit**  **No. 128065080**

**- P**  **30 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. LIMITAT IONS 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 P 04] 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 testin g 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 emissi on listed in conditions I.A.1.c.( 3 )

7. All Pollutants (1) Natural gas use may not exceed 1.243 x 10 6 cubic feet 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]

(2) Distillate oil u se 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 54 0 hours/month averaged over any 12

- month period, excluding startup/shutdown periods. [s. 285.65(7), Wis. Stats. , 05

- SDD

320 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 i n 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 recor ds 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 whi ch 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 requ ired by condition (2) above shall be available no later than the 15 th 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]

15 Sec. NR 431.0 5(1), Wis. Adm. Code allows 20% opacity. However, as a condition for best available control technology (BACT) for particulat e matter emissions, opacity shall be limited to 10%.
16 This is the usage amount that the permittee applied for in 89

- POY

- 116.**FID 128065080 ; Permit**  **No. 128065080**

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ZZZ. Conditions Appli cable 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 t he 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 sou rces. [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, eit her 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 proto col 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 viola te 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**

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

### ZZZ. Conditions Appl icable 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 e mission
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 malfunct ion 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 h istory, 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 pla n 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**

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Z ZZ. 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 e very 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, 391 1 Fish Hatchery Road, WI 53711, phone 608

- 27 5

- 3266 w ithin 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, accur acy 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 Janua ry 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

- Wi sconsin, 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) An y compliance emission tests required by the Department shall be conducted while operating at 100% capacity 17

. 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 re presentative 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 af ter the tests. [s. NR 439.07, Wis. Adm. Code]

}

17 10 0% 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 turbine s.