### NORTH DAKOTA DEPARTMENTOF HEALTH Environmental Health Section Location: 1200 Missouri Avenue Bismarck, NO 58504·5264 

### February 5, 2002

Mr. John Graves 

### Environmental Manager Minnkota Power Cooperative P.O. Box 13200 Grand Forks, NO 58208-3200 

### Re: Amended SIP Permit to Operate Dear Mr. Graves: Fax#: 701·328·5200 MailingAddress: P.O. Box 5520 Bismarck, NO 58506·5520

.-f • 

## v;-· O'·u 

## 6 l**83~**



### Enclosed is a copy of your renewed Permit to Operate for the Milton R. Young Station located near Center, North Dakota. The Permit to Operate is issued by the North Dakota Department of Health in 

### accordance with section 33-15-14-03 of the North Dakota Air 

### Pollution Control Rules_ Public comment regarding amending and reissuing of this permit was held beginning on December 20, 2001 and ending on January 19, 2002. During the public comment period, only one comment letter was received. 

### A copy of the comment letter and our response to that letter is enclosed. The Permit to Operate identifies the source units you are authorized to operate and lists the conditions under which the permit 

### is issued. You should read each condition carefully and note the restrictions placed on the source. If you have any questions concerning the Permit to Operate, please feel free to contact Tom Bachman of my staff at (701)382-5188. Sincerely,

.



# .

# ~~/L 

# hG

Terry 

### L. O'Clair, 

### P.E. Director Division of Air Quality TLO/TB:csc Enc: xc/enc: Kathleen Paser, 

### EPA Terrence Kardong, Dakota Resource Council Environmental Health Section Chiel's QUice 701·328-5150 Air Quality 701-328-5188 Municipal Facilities 701-328-5211 Waste Management 701-328-5166 Waler Qualily 701-328-5210 Website: www.health.Slate.nd.uslndhdlenviron Printedon f9CVCledoaoer.

### NORTHDAKOTA DEPARTMENTOFHEALTH Environmental Health 

### Section Location: 1200 Missouri Avenue Bismarck, ND 58504-5264 Fax#: 

### 701-328-5200 MailingAddress: 

### P.O. Box5520 Bismarck, ND 58506·5520



### AIR POLLUTION CONTROL PERMIT TO OPERATE

Pursuant to Chapter 23-25 of the North Dakota Century Code, and the Air Pollution Control Rules of the State of North Dakota, and in reliance on statements and representations heretofore made by the owner designated below, 

### a Permit to Operate is hereby issued authorizing such**o\~er** 

### to operate the source unites) 

### at the location designated below. This Permit to Operate is subject to all applicable rules and orders now or hereafter in effect of the North Dakota Department of Health and to any conditions specified below:

1. Owner: 2. 

### Permit Number A.

B. Name 

### Minnkota Power Cooperative, Inc. Address Box 127 Center, ND 58530 3.

4. 

### F76009 Installation Milton R_ Young Station

Units 

### 1 and 

### 2 Installation Location Center, North Dakota Oliver County 5. 

### Expiration Date: December 31, 2002 or upon issuance of the Title V Permit to Operate (whichever comes first). 6. Source Unit(s): A. Unit 1, a lignite-fired 235 MW (nominal net rating) electrical power generating facility, consisting of the following: 1) A Babcock 

### & wilcox cyclone-fired furnace with a nominal heat input rating of 2,500,000,000 BTU/hr and a boiler unit with a nominal rating of 1,714,000 pounds of steam per hour (identification numbers PL-3941 and RB-457) equipped with the following air pollution control equipment:

Environmental Health Seclion Chief's Office 701·328-5150 Air Quality 701-328-5188 Municipal Facilities 701·328·5211 Waste Management 701-328-5166 Water Quality 701-328-5210 Website: www.health.state.nd.us/ndhd/environ

### Page _2_ Permit No. of 

### .....:LL F76009



### a) Research-Cottrell, Inc. electrostatic precipitator of four units, with each unit divided into four 9 x 30 foot sections containing discharge electrode wires and Opzel type collecting electrode plates. 2) One fly ash silo equipped with a United Conveyor Model 1036 rotary unloader for the temporary storage of electrostatic precipitator ash. 31 [Reserved) 

### 4) Two 500,000 gallon fixed roof petroleum storage tanks used for storage of fuel oil. 5) A Cleaver Brooks boiler unit with a nominal rating of 60,000 lb of steam per hour fired on fuel oil. This unit is used on a standby basis. 6) A lignite handling system comprised of the following: a) Unloading Station A Stamler Model BF-29C-O-8F feeder equipped with a Hercules single roll breaker which prepares coal for unloading onto a Link Belt 42" x 332" unloading belt conveyor, referred to as conveyor 10. Air pollution control consists of a dust suppression system at,. the primary crusher discharge point. • b) Crusher House 1) A receiving hopper equipped with two Syntron Co. vibrating feeders, with each feeder with a nominal rating of 500 tons/hr. 2) Two half-capacity Pennsylvania ring hammer crushers, with each crusher having a nominal rating of 400 tonslhr, equipped with a Link Belt 36" x 495' stackout conveyor (referred to as conveyor I

### e) and a telescopic chute attached to the end of the conveyor. Air pollution control consists of: [a] A dust suppression system for the secondary crusher I 

### at the secondary crusher discharge point and for the 1-C conveyor belt.

### page _3_ Permit No. of 

### ....l2...- f76009

[bJ 

### An American Air Filter Company rotoclone for the l-C conveyor belt point near the secondary crusher. Type "W" discharge
c) Stackout and Reclaim Area Three underground reclaim hoppers equipped with Syntron Co. vibrating feeders, with each feeder with a nominal rating of 300 tons/hr, and a Link-Belt 30" x 875' reclaim belt conveyor (referred to as conveyor l-B). Air pollution control consists of a dust suppression system at the discharge points of the reclaim feeders. d) Coal Storage Bunkers A Link-Belt silo belt conveyor (referred to as conveyor I-A) discharging to seven coal storage silos located within the plant, each with a nominal rating of 420 tons. Air pollution control consists of an American Air Filter Co. Type "W" rotoclone for the storage silos and a #14 Type "0" rotoclone for various drop points in the tripper room. 8. Unit 2, a 440 MW (nominal net rating) lignite-fired electrical power generating facility, composed of the following: 1) A Babcock and wilcox cyclone fired furnace with a nominal heat input rating of 4,696 x 106 

### BTU/hr and a boiler unit with a nominal rating of 3,200,000 pounds of steam per hour equipped with the following air pollution control equipment: a) Two Wheelabrator Lurgi Model 90/40/4x9/12" electrostatic precipitators. Each precipitator is comprised of two chambers with four fields containing 90 gas passages, discharge electrode wires and collecting plates. b) A flue gas desulfurization system consisting of two modified Combustion Equipment Associates, Inc. spray tower scrubber absorber modules. The scrubbing system is designed to utilize a scrubbing medium consisting of either fly ash, fly ash supplemented with lime or lime. 2} One 40,000 cubic foot capacity fly ash silo equipped with a United Conveyor Model 1552-1 rotary unloader for the temporary storage of electrostatic precipitator ash. 3) One 450 ton lime storage silo equipped with a Dustex Model 3100 fabric filter type dust collector.

### NORTH DAKOTA DEPARTMENTOF HEALTH Environmental Health Section Location: 1200 Missouri Avenue Bismarck, NO 58504-5264 April 14. 2000



### John T. Graves, P.E. Environmental Manager Minnkota Power Cooperative, Inc. 1822 Mill 

### Road Grand Forks. NO 58208-3200 Fax': 701-32S-S200 MailingAddress: P.O. Box5520 Bismarck. NO 58506·5520

## 1D)~@H\l7~fil 

# 1m APR 20 

## 2000 , 

# 8p. AA

Printedon recycledpaper. 

### Re: Requested Permit Modification for Milton R. Young Station Dear Mr. Graves: 

### We have completed review of all Minnkota submittals pertaining to your Permit to Construct application (November 20, 1995) involving 

### increases in the rated heat input of both units at the Milton R. Young Station and the effective allowable emission rates on a mass 

### per unit of time basis (lb/hr). Included in these submittals were air quality modeling analyses to address impact of the requested emissions increase on Ambient Air Quality Standards (AAQS) and PSD Class II increments. In addition, the Department conducted modeling to address impact of the requested emissions increase at PSD Class I areas. The most recently documented AAQ5 and P5D Class II increment modeling results were submitted in an August 13, 1998 letter from you to Dana Mount. Upon review of that submit tal, it became apparent that boiler building dimensions assumed for the modeling analysis were not accurate. Through subsequent review of building drawings provided by Minnkota, along with an on-site inspection of the plant by Department and Minnkota personnel (August 6. 1999), a mutually agreed upon set of revised boiler building dimensions was established. Using these revised building dimensions, the Department remodeled 502 and NOx 

### emissions, and found predicted violations of AAQS and PSD Class II increments for S02' The predicted AAQS violations were confirmed by Minnkota (based on its own modeling) in a November 1, 1999 telephone discussion between Kevin Thomas and Rob White. The Department's modeling analysis for impact on PSD Class I areas is documented in "Calpuff Class I Area Analysis for Milton R. Young Generating Station" dated May 24, 

### 1999. That analysis revealed predicted violations of Class I increments, and significant exceedances of visibility threshold levels established by the National Park Service. Minnkota submitted a critique of the Department's Class I modeling analysis (October 1999), to which the Department responded (January 2000). 

### Lastly, Minnkota commented on Environmental Health Environmental Municipal Waste Water section Chiel's Office Engineering Facilities Management Quality 701-328-5150 701-328·5188 701·328-5211 701-328-5166 701-328-5210 

## EPA8PERl:ll:l2992

### Mr. Graves 2 April 14, 2000



### the Department's response in a February 2000 submittal. The Department has reviewed the Minnkota submittals regarding the Class I analysis, and has concluded that insufficient justification was provided to merit 

### revision of the Department's modeling methodology or results. Further, the Department has received concurrence on its modeling methodology for Milton R. Young Station from EPA and the National Park Service. In summary, current emission increases contribute to: modeling results indicate that proposed ambient at Milton R. Young Station will cause or

• 

### violations 

### of AAQS 

### for**SO~,**



### • violations 

### of PSD Class II 

### increments 

### for**SO~,**

• 

### violations 

### of PSD Class I 

### increments 

### for**SO~'** 

### and



### • exceedances 

### of Class I 

### area visibility threshold levels established by 

### the National Park Service. Given these modeling results for Milton R. Young Station, the Department cannot proceed to issue the Permit to Construct based on the application. In our meeting of April 11, 2000, you discussed a revised approach that involves limiting the requested increase in allowable emissions such that the increase will not cause a significant impact (modeled) in any Class I area. Because of this substantial change in the approach, the Department will consider it a new application and will process it when your submittal is complete. Our understanding from the April 11, 2000 meeting is that Minnkota will conduct/provide Calpuff modeling for determination of Class I significant impact. Note that updated AAQS and PSD Class II increment modeling must also be provided before the Department can process the new application. If you have any questions regarding this letter, please contact me. Sincerely,

# 9:it~~ Director, Division of Air Quality JLB/SW,gsh 

### xc; Dick Long, EPA Region VIII Francis J. 

### Schwindt, Chief, EHS Lyle Witham, Legal Counsel


## EPABPERBB2993UNITED STATES ENVIRONMENTAL PROTECTION A!3ENCY REGION VIII 999 18th STREET

- SUITE 500 DENVER. COLORADO 80202-2466 

### DEC -7 1998

Ref: 8P-AR
Dana K. Mount, P,E. Director, DivisionofEnvironmentalEngineering Nonh DakotaDepartmentofHealth P.O. Blix 5520 Bismaqk, ND 58506-5520

DearM!. Mount: I'" 

# .,::!f,J**c,I~{.i** Thisisin responsetoyour**I~tter** dated October7, 1998, inwhichyourequested EPA Region vm's interpretationoftheapplicabilityofthe 1992WEPCO ruleto electric utilities tha upgrade and/orreplaceturbines. In yourletter, you referenced anarticleinarecenteditionof Inside EPA Weekly Repon (Vol. 19, No. 37, September 18, 1998), as well as an August28. 1998, letterfromEPARegion VIIto SunflowerElectric PowerCorporation regardingtheimplications ofthe WEPCO ruleonNew Source Review (NSR) applicabilityfor specificmodifications made at the source. SinceNSRapplicabilityis always case specific, an applicabilitydeterminationwith respect toturbinemodifications ingeneral would be inappropriate. Hence, Region

### vrn is providing ageneraldiscussionofonlythepertinentaspec s oftheWEPCO rule and will workwiththeDepartment as necessaryto address NSRapplicability to specific modifications at electricutilities on acase·by-casebasis.
The purpose oftheWEPCO final rulcmaking, promulgated on July 21, 1992 (57 FR32314), was to ensureharmonybetweenTide Iand Title N oftheClean Air Actwith respect toTitle TV pollutioncontrol projects at electricutilityplants. In addition, therule addresses theuseofacurrentactualtofuture representativeactual methodology for detenninin, an emissions increase atthe steamgeneratingunit resultingfrom non·routine physical and/or operational changes occurring at steamelectric utilityplants. Changes at a steamelectricutilityplantmustbeanalyzedto detennineiftheytriggera majormodificationas definedunderfederal regulations at40CFR51. 166(bX2). Weunderstan thatthe stateofNorth Dakotahas similarrequirements undertheNorth Dakota AirPollution Control Regulations atNDAC 33·15-15-01.1. Absent exclusion from the definition of modification specified at40 CFR51.166(b)(2)(iii) andNDAC33-15-15-0l.I.x, anet increase I' emissionscould subjectthe steamgeneratingunit to new sourcereview. TheWEPCO rule indicates that suchnetemissionsincreasemaybedetenninedbased on current actual to future representativeactual emissions.Sincerely. Itiscritical to realize thateach source's situationneedsto belooked atcase-by-case, and we

### willbehappytoworkwithyouonfactspecificcasesto detcr;rninehowtherule applies. If you haveany furtherquestionsorconcernsregardingthismatter, pleasecontact KathleenPaser at303-312-6526.

### ~- 

# .. Richard R. Long, Director 

# tfl...-

.. Airand Radiation Program

RRUKSP

cc: TomBachman, NO DepartmentofHea1th GaryD. Helbling,,ND DepartmentofHealth David Solomon, OAQPS Carol Holmes, OECA Jon

### Devine,OGC AnnaWood, OPAR Dan Rodriguez, EPARegion7, ARTD/APC ScottWhitmore, EPARegion 8, 8ENF-TNORTH DAKOTA DEPARTMENTOFHEALTH
ENVIRONMENTAL HEALTH SECTION
May 6, 1997



### Mr. John Graves 

### Environmental Superintendent Minnkota Power Cooperative, Inc. P.O. Box 127 Center, NO 58530-0127 

### .Dear Mr. Graves: 1200 Missouri Avenue P.O. Box 5520 Bismarck, North Dakota 58506-5520 Fax '701-328·5200



### Please find enclosed a revised Permit to Operate for the Milton R. Young Station. Conditions 7.F. and 7.G. were revised as requested 

### in your April 21. 1997 submittal. If you 

### should have any questions, feel free to contact us. 

# ;::Zed h Dana K. Mount, P.E. Director, Division of**-~** 

### Environmental Engineering DKM/CDT, 

### saj 

### Ene:



### •

## • • 

## EPABSIP887198

Environmenlal Healttl Section and Enforcement

701·328·5150 Environmental Engineering 701-328-5188 MunIcipal Facilities 701·328-521 \ Printedon recvcJedoaoer. Waste Management 701·328·5166 Water Qualify 701-328-5210NORTH DAKOTA DEPARTMENTOF HEALTH

ENVIRONMENTAL HEALTH SECTtO
1200 Missouri Avenue P.O. Box5520 Bismatck. Nontl Dakota58506·5520 Fax_701·328-5200



### AIR POLLUTION CONTROL PERMIT TO OPERATE

Pursuant to Chapter 23 -25 of the North Dakota Century Code, and the Air Pollution Control Rules of the State of North Dakota, and in reliance on 

### statements and representations heretofore made 

### by the owner designated below, a Permit to Operate is hereby issued authorizing such owner to operate the source unites} at the location designated below. This Permit to Operate is subject to all applicable rules and orders now or hereafter in effect of the North Dakota Department of Health and to any conditions specified below:

1. Owner: 2. Permit Number
A.

B. Name Minnkota Power Cooperative, Inc. Address
Box 127 Center, NO 58530 3 _

4. F76009 Installation
Milton R. Young Station

Units 1 and 2 Installation Location Center, North Dakota Oliver County 5. Expiration Date:

6. Source Unit(s) : April 10, 2000

A. Unit 1, a lignite-fired 235 MW consisting of the following: electrical power generating facility, 

## EPA8SIPall7191 1) A Babcock & Wilcox cyclone-fired furnace with a heat input rating of 2,500,000, 000 aW/hr and a boiler unit rated at 1,714,000 pounds of steam per hour (identification numbers PL3941 and RB-457) equipped with the following air pollution control equipment:
Envifonmenlal Heallh Section and Enlorcement

701·328-5150 Environmental Engineering 701-328·51S8 MuniCipal Facilities 701-328-5211 PrintedonrecvctedDaDe!. Wasle Management 701-328·5166 Waler**aua~1y** 701·328-5210Page 

### --L Permit No. of 

### --llF76QQ9

a) Research-Cottrell, Inc. electrostatic precipitator of four units, with each unit divided into four 9 x 30 foot sections containing discharge electrode wires and Opzel type collecting electrode plates. 2) One fly ash 

### silo equipped with a United Conveyor Model 1036 rotary unloader for the temporary storage of electrostatic precipitator ash. 3) One fly-ash silo constructed of vitrified block material and equipped with a water injected, dustless unloader rated at 150 

### ton/hr. This silo is used on a standby basis for the temporary storage of precipitator ash. 4) Two 500,000 gallon fixed roof petroleum storage tanks used for storage of fuel oil. 5) A Cleaver Brooks boiler hour fired on fuel oil. unit rated at 60,000 Ib of steam per This unit is used on a standby basis. 6) A lignite handling system comprised of the following: Unloading Station a) A Stamler Model BF-29C-0-BF feeder equipped with a Hercules single roll breaker which prepares coal for unloading onto a Link Belt 42" x 332" unloading belt conveyor, referred to as conveyor 10. Air pollution control consists of a dust suppression system at the primary crusher discharge point. Crusher House b) A receiving hopper equipped with two Syntron Co. vibrating feeders, with each feeder rated at 500 ton/hr. c) Two half-capacity Pennsylvania ring hammer crushers. with each crusher rated at 400 ton/hr. equipped with a Link Belt 36" x 495' stackout conveyor (referred to as conveyor i-C) and a telescopic chute attached to the end of the conveyor. Air pollution control consists of:



# EPABSIPOO7192Page 

### .....l.- Permit No. of 

### ....lJL E76QQ9

(1) A dust suppression system for the secondary crusher, 

### at the secondary crusher discharge point and for the l-C 

### conveyor belt. (2) An American Air Filter Company Type "W" rotoclone for the l-C conveyor belt discharge point near the 

### secondary crusher.
Stackout and Reclaim Area
dl Three underground 

### reclaim hoppers equipped with Syntron Co. vibrating feeders, with each feeder rated at 300 ton/hr, and a Link-Belt 30" x 875' reclaim belt conveyor (referred to as conveyor 1-B). Air pollution control consists of a dust suppression system at the discharge points of the reclaim feeders. Coal Storage Bunkers
el A Link-Belt silo belt conveyor (referred to as conveyor l-A) discharging to seven coal storage silos located within the plant, each with a capacity of 420 tons. Air pollution control consists of an American Air Filter Co. Type "W" rotoclone for the storage silos and a #14 Type "0" rotoclone for various drop points in the tripper room. B. Unit 2, a 440 MW lignite-fired electrical power generating facility, composed of the following: 

### 1) A Babcock and Wilcox cyclone fired furnace with a heat input rating of 4,696 x 10' BTU!hr and a boiler unit rated at 3,200,000 pounds of steam per hour equipped with the following air pollution control equipment: a) Two Wheelabrator Lurgi Model 90!40/4x9!12 H electrostatic precipitators. Each precipitator is comprised of two chambers with four fields containing 90 gas passages, discharge electrode wires and collecting plates. b) A flue gas desulfurization system consisting of two modified Combustion Equipment Associates, Inc. spray tower scrubber absorber modules. The scrubbing system is designed to utilize a scrUbbing medium consisting of either fly ash, fly ash supplemented with lime or lime. 

## EPA8SIPBB719304103/00 09: 07 "5'701 328 5200 ND ENV HE.-\LTH

..++ el"'A IHI 'lI!lIUV-.lIVVi)

NORTH DAKOTA DEPARTMENTOF HEALTH
ENVIRONMENTAl HEALTH SECTION**Dec~mber** 19, 1995

Mr. 

### John T. 

### Graves Environmental Superintendent. Minnkota Power Cooperative, Inc. P.O. Box 127 Center, NO**se~30-01~7** 

# J**';h~l** Dear Mr. Grres: 1200MIssouriAvenue P.O. Bee S520 BismalCk. Nor'lh Oakora58508-5520 Fax#701·328-5200

This letter is·" 

### in

. response to your November 20, 1995 letter regarding heat inputs and allowable emissions for the Milton R. Young Station.
With regard to the NO. emission limit for Unit 2, we disagree that no applicable standard exists for NO'll' When t.he Milton R. Young Station Unit 2 was built, the Department had both a one-hour and annual N02 ambient air quality standard which were applicable t.o the facilit:y. The Permit to Construct application for Unit 2 listed 

### an expected emission 

### rate of 3820 lb/hr_ If you wish 

### to change this allowable emission rate, an ambient air quality impact assessment must be conducted which demonstrates compliance with the current annual NO:!. ambient. standard. In addition, the anal.ysis must also address the PSD increment for NOz. The PSO baseline date for NOz is October 31., 1.989. Any potential emissions above the actual emissions that existed on the baseline date will consume increment. If you can demonstrate that actual emissions on the baseline date equal**po~ential** emissions after the revised emission rate is established, there will be no increment 

### consumption. Regarding 

### the rated 

### heat input capacity of Units 1 and 

### 2, you have indicated that the numbers that currently appear on the Permit to Operate are nominal capacities. The initial application for Unit 

### 1 and all applications for 

### permit renewal for both units have indicated that these numbers 

### (or very similar numbers) are maximum rated heat inputs. 1t condition on the permits that have been issued 

### by the Department for these units states,**~This** permit is issued in reliance upon the accuracy and completeness of the information**se~** forth in this application. u These heat inputs havs
EnvltonmonliJl Heal1h SBC1lon 

# ""-**701~8-51SO** EnvironmefltW Enginooring 701·328-S1BB M\Klicipal**Faci~ti03** 701'328-5211 WaflH Quality 701-3280SZ10 

### EPAAc:JDOn.,

...._.Mr. 

### Graves 2 December 19, 1995

been relied upon in many ambient air quality impact assessments. The heat input stated times the allowable emission rate on a pound per million BTU basis was used to establish the maximum potential emissions from these units for modeling purposes. As with N02, any change in the heat inputs I which would effectively change the allowable emissions on a mass per unit time basis from the facility, will require an ambient air quality impact assessment:. which demonstrates compliance with the ambient air quality standards as well as the PSD increments. The baseline date for**S~** 

### is December 19, 1977. 

### Any increase of potential emissions above the actual emissions that existed on the baseline date will consume increment. We suggest that this ambient air quality assessment be delayed until the Department makes its final determination 

### on the Lignite Council's petition to change the ambient air quality standards for 502'
With regard to the alleged conflict between the permit condition for opacity and Section 33-1.5-03-04..4 of the North Dakota Air Pollution Control Rules, we disagree with your interpretation. Subsection 33-15-03-04.4 is intended for those types of processes qr operations that by their inherent design or operation can not achieve compliance with the opacity standards established in Chapter 3. We are not aware of any facilities at the Milton R. Young Station for which it is not technically feasible to meet the opacity standard. With regard to the standard, the Department does take into account startup, shutdowns, malfunctions and other circumstances that are unavoidable. We believe this permit condition is consistent with the rules.
We will be happy to meet with you to discuss any of these issues. If you have any questions, please feel free to contact Tum Bachman of my scaff.



### • Dana K. Mount, P.E. Director, Division of Environmental Engineering DKM/TB:saj



## EPI\8SIpae7202

# '"**.·~MC** 

## !¥IF''

. MINNKOTA POWER COOPERATIVE, INC. MILTON YOUNG STATION P.O. Box 127, Center J NO 58530-0127 Phone: (701) 794--8711 Fex; (701) 794-725a

November20, 1995

Mr. Dana Mount, Director Division ofEnvironmental Engineering North Dakota Department of Health PO Box5520 Bismarck, North Dakota 58502-5520 Subject: PermitTo Operate No. F76009 Permit Revisions Dear Mr. Mount
As you 

### are aware, Milton R. Young Station, Unit2 can not meet the Naxemission limit of 3820 lb./hrin the current Permit This emission limitwas not added to our Permit until 1985. This limitation of3820 Ib./hrwas apparently baSed uponthe original Permitto construct application forthe Unit Itwas not Minnkota Power's intentto have this value utilized inthe Permitwhen no applicable standard existed. The 0.80 IbJmmBTU emission limit required by40 CFR60 subpart D is notapplicabletothis Unit. Asthe No" emissions have not increased sincethe plant began operation, the elimination ofthis restriction will not have eny effect upon the PSD baseline in North Dakota. Therefore, .,/ based upon theabove, we request that this Permit restriction 

### be eliminated. There also existother Permit discrepancies which we believe·should becorrected atthis time. The present Permit to Operate lists Untt 1 as 235 MW, 2,500 mmBTU/hrheat input and 1,714 mmlb/hrofsteam. Unit2 is listed as440 MW, 4,696 mmBTU/hrheat inputand 3,200 Ib./hrofsteam. These are nominal figures forthe untts and do not reflectthe maximum capacities 

### ofthe units. The following information was measured on ourcontinuous emission monitors during urgetests during the pastyear

DATE UNIT 1 5-30-95 UNIT2 5-26-95 HEAT INPUT (mmBTU/hr) 3001,6 6261.6 GROSS MEGAWATTS 277 517



## EPA8SIpee7186

# ... . --,



### _ 

## ..

Mr. Dana Mount Page 2 November20, 1995 There has been no changes in the eithertheturbine orthe boilerin Unit 1. In Unit2, changes have been madeto increasethe boilerand turbine efficiencies. These changes have not changed the maximum heat input capability 

### ofUnit2. They have allowed forincreased electrical outputfrom the generatorand extended hours of operation ofthe boilerat highersteam ioads priorto scheduled outages. 

### Asthe descriptions

### ofthe units could beviewed as Permit restrictions and in orderto more accurately reflectthe maximum capabilities ofthe units as theywere originally and c:urrenUy are with respect to heat input. and are currenflywith respectto generator output, we askthatthe Penmit be revised accordingly. We also believe that the IbJhrof sleam should be eliminated from the Permitas it is highlydependentsteam pressure, turbine backpressure, unit load, etc. There appears to

### be e conflict between the Permitconditions foropacity: Par. 7.B.1), and the rules. The Permit restrictions stalethatthe limitations applyat all times. However, the rules (NDAC 33-15-03-04.4) provide forexceptions as does 40 CFR 60, Subpart D. To clarifythis, and makethe Permit reStriction consistent with the rules, we askthatthe phrase "This standard applies atall limes." 

### be deleted from the Permit. Ifyou haveany questions, please contact Kevin Thomas or myselfat (701 )794-8711. Sincerely, MINNKOTA POWER COOPERATIVE, INC.

John T. Graves Environmental Superintendent



### c: File: 101.012 101.014



# EPA8SIPBB71B7