NORTH DAKOTA DEPARTMENT OF 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

Mailing Address:

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

Printed on f9CVCled oaoer.
NORTH DAKOTA DEPARTMENT OF HEALTH

Environmental Health Section

Location:

1200 Missouri Avenue

Bismarck, ND 58504-5264

Fax#:

701-328-5200

Mailing Address:

P.O. Box 5520

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 Ie) and a telescopic chute attached to the end of

the conveyor. Air pollution control consists of:

[a] A dust suppression system for the secondary

crusherI 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 un loader for the temporary

storage of electrostatic precipitator ash.

3) One 450 ton lime storage silo equipped wi th a Dustex Model

3100 fabric filter type dust collector.
NORTH DAKOTA DEPARTMENT OF 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

Mailing Address:

P.O. Box 5520

Bismarck. NO 58506·5520

1D)~@H\l7~fil

1m APR 20 2000 ,

8p. AA

Printed on recycled paper.

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 submi t 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 resul ts. 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

EPABPERBB2993
UNITED 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, Division ofEnvironmental Engineering

Nonh Dakota Department of Health

P.O. Blix 5520

Bismaqk, ND 58506-5520

DearM!. Mount: I'" .,::!f,Jc,I~{.i

This is in response to your I~tter dated October 7, 1998, in which you requested EPA

Region vm's interpretation ofthe applicability ofthe 1992 WEPCO rule to electric utilities tha

upgrade and/or replace turbines. In your letter, you referenced an article in a recent edition of

Inside EPA Weekly Repon (Vol. 19, No. 37, September 18, 1998), as well as an

August 28. 1998, letter from EPA Region VII to Sunflower Electric Power Corporation

regarding the implications ofthe WEPCO rule on New Source Review (NSR) applicability for

specific modifications made at the source. Since NSR applicability is always case specific, an

applicability determination with respect to turbine modifications in general would be

inappropriate. Hence, Region vrn is providing a general discussion of only the pertinent aspec s

ofthe WEPCO rule and will work with the Department as necessary to address NSR applicability

to specific modifications at electric utilities on a case·by-case basis.

The purpose ofthe WEPCO final rulcmaking, promulgated on July 21, 1992

(57 FR 32314), was to ensure harmony between Tide I and Title N ofthe Clean Air Act with

respect to Title TV pollution control projects at electric utility plants. In addition, the rule

addresses the use of a current actual to future representative actual methodology for detenninin,

an emissions increase at the steam generating unit resulting from non·routine physical and/or

operational changes occurring at steam electric utility plants.

Changes at a steam electric utility plant must be analyzed to detennine ifthey trigger a

major modification as defined under federal regulations at 40 CFR 51. 166(bX2). We understan

that the state ofNorth Dakota has similar requirements under the North Dakota Air Pollution

Control Regulations at NDAC 33·15-15-01.1. Absent exclusion from the definition of

modification specified at 40 CFR 51.166(b)(2)(iii) and NDAC 33-15-15-0 l.I.x, a net increase I'

emissions could subject the steam generating unit to new source review. The WEPCO rule

indicates that such net emissions increase may be detennined based on current actual to future

representative actual emissions.
Sincerely.

It is critical to realize that each source's situation needs to be looked at case-by-case, and

we will be happy to work with you on fact specific cases to detcr;rnine how the rule applies. If

you have any further questions or concerns regarding this matter, please contact Kathleen Paser

at 303-312-6526.

~-.. Richard R. Long, Director tfl...- .. Air and Radiation Program

RRUKSP

cc: Tom Bachman, NO Department ofHea1th

Gary D. Helbling,,ND Department of Health

David Solomon, OAQPS

Carol Holmes, OECA

Jon Devine, OGC

Anna Wood, OPAR

Dan Rodriguez, EPA Region 7, ARTD/APC

Scott Whitmore, EPA Region 8, 8ENF-T
NORTH DAKOTA

DEPARTMENT OF HEALTH

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 \

Printed on recvcJed oaoer.

Waste

Management

701·328·5166

Water

Qualify

701-328-5210
NORTH DAKOTA

DEPARTMENT OF HEALTH

ENVIRONMENTAL HEALTH SECTtO

1200 Missouri Avenue

P.O. Box 5520

Bismatck. Nontl Dakota 58506·5520

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

Printed on recvcted DaDe!.

Wasle

Management

701-328·5166

Waler

aua~1y

701·328-5210
Page --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:

EPABSI POO7192
Page .....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.

EPA8SIPBB7193
04103/00 09: 07 "5'701 328 5200 ND ENV HE.-\LTH ..++ el"'A IHI 'lI!lIUV-.lIVVi)

NORTH DAKOTA

DEPARTMENT OF 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:

1200 MIssouri Avenue

P.O. Bee S520

BismalCk. Nor'lh Oakora 58508-5520

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
!¥IF''

'" .·~MC. MINNKOTA POWER

COOPERATIVE, INC.

MILTON YOUNG STATION

P.O. Box 127, CenterJ NO 58530-0127 Phone: (701) 794--8711

Fex; (701) 794-725a

November 20, 1995

Mr. Dana Mount, Director

Division of Environmental Engineering

North Dakota Department of Health

PO Box 5520

Bismarck, North Dakota 58502-5520

Subject: Permit To Operate No. F76009

Permit Revisions

Dear Mr. Mount

As you are aware, Milton R. Young Station, Unit 2 can not meet the Nax emission limit of

3820 lb./hr in the current Permit This emission limit was not added to our Permit until

1985. This limitation of 3820 Ib./hr was apparently baSed upon the original Permit to

construct application for the Unit It was not Minnkota Power's intent to have this value

utilized in the Permit when no applicable standard existed. The 0.80 IbJmmBTU

emission limit required by 40 CFR 60 subpart D is not applicable to this Unit. As the No"

emissions have not increased since the plant began operation, the elimination of this

restriction will not have eny effect upon the PSD baseline in North Dakota. Therefore,

.,/ based upon the above, we request that this Permit restriction be eliminated.

There also exist other Permit discrepancies which we believe·should be corrected at this

time. The present Permit to Operate lists Untt 1 as 235 MW, 2,500 mmBTU/hr heat

input and 1,714 mmlb/hr of steam. Unit 2 is listed as 440 MW, 4,696 mmBTU/hr heat

input and 3,200 Ib./hr of steam. These are nominal figures for the untts and do not

reflect the maximum capacities of the units. The following information was measured on

our continuous emission monitors during urge tests during the past year

DATE

UNIT 1 5-30-95

UNIT 2 5-26-95

HEAT INPUT

(mmBTU/hr)

3001,6

6261.6

GROSS

MEGAWATTS

277

517

EPA8SI pee7186
... . --, _..

Mr. Dana Mount

Page 2

November 20, 1995

There has been no changes in the either the turbine or the boiler in Unit 1. In Unit 2,

changes have been made to increase the boiler and turbine efficiencies. These

changes have not changed the maximum heat input capability of Unit 2. They have

allowed for increased electrical output from the generator and extended hours of

operation of the boiler at higher steam ioads prior to scheduled outages.

As the descriptions of the units could be viewed as Permit restrictions and in order to

more accurately reflect the maximum capabilities of the units as they were originally and

c:urrenUy are with respect to heat input. and are currenfly with respect to generator

output, we ask that the Penmit be revised accordingly. We also believe that the IbJhr of

sleam should be eliminated from the Permit as it is highly dependent steam pressure,

turbine backpressure, unit load, etc.

There appears to be e conflict between the Permit conditions for opacity: Par. 7.B.1),

and the rules. The Permit restrictions stale that the limitations apply at all times.

However, the rules (NDAC 33-15-03-04.4) provide for exceptions as does 40 CFR 60,

Subpart D. To clarify this, and make the Permit reStriction consistent with the rules, we

ask that the phrase "This standard applies at all limes." be deleted from the Permit.

If you have any questions, please contact Kevin Thomas or myself at (701)794-8711.

Sincerely,

MINNKOTA POWER COOPERATIVE, INC.

John T. Graves

Environmental Superintendent

c: File: 101.012

101.014

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